ML20135H389
| ML20135H389 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/12/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20135H388 | List: |
| References | |
| NUDOCS 8509230197 | |
| Download: ML20135H389 (10) | |
Text
- o UNITED STATES
, g d o NUCLEAR REGULATORY COMMISSION we.SmNCTON, D. C. 20$55 g r N...../
ENCLOSURE SAFETY EVALUATION ON LICENSE CONDITION 2.C.(12)(b)'
JOSEPH M. FARLEY NUCLEAR PLANT UNIT 2 DOCKET NO. 50-364 BACKGROUND On March 31, 1981 the NRC issued Facility Operating Licensee No. NPF-8 to th Alabama Power Company (APC0) for the operation of Joseph M. Farley Nuclear Plant Unit 2. By letter of October 21, 1982 (Reference 1) APCo claims compliance with Licensee Condition 2.C.(12)(b) but also refers to License Conditions 2.C.(12)(a) and 2.C(12)(c). These three license
__ conditions state: -
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"The licensee shall modify procedures and, if necessary, equipment used for natural circulation cooldown as follows:
(a) Prior to exceeding 5 percent power, the licensee shall perform tests to demonstrate manual operation of an atmospheric steam dump valve.
(b) Prior to startup following the first refueling, the licensee shall make provisions (or modifications) as necessary to assure that the safety grade backup means of reactor coolant system depressurization is in accordance with the requirements of Table 1 in Branch Technical Positions RSB 5-1, Rev.1 [ Underlining added.]
(c) Prior to startup following the first refueling, the licensee shall provide to the NRC natural circulation cooldown procedures, based on reactor natural circulation cooldown test results applicable to Farley Unit 2."
On October 21, 1982, the APC0 claimed compliance with 2.C.(12)(b) but the opening sentence of the APC0 letter (Reference 1) indicates that its purpose was to provide:
" assurance that the safety grade means of reactor coolant system depressurization is in accordance with the requirements of Table 1 in Branch Technical Position RSB 5-1, Rev.1 [ Reference 2]."
Additionally, the APC0 letter (Reference 1) said:
" Alabama Power Company has independently evaluated the applicable ,
requirements of Table 1 in Branch Technical Position [BTP] RSB 5-1, '
Rev.1, and determined that Farley Unit 2 complies without need of modification or additional provisions. This conclusion agrees with the NRC findings [on BTP RSB 5-1] published in Supplement No. 5 to 85092301978509g64 PDR ADOCK O PDR P
NUREG-0771; therefore, based on completion of the three conditions [in Supplement 5 (Reference 3)], Licensing Condition 2.C.(12)(b) has been met and is considered complete by Alabama Power Company."
Thus, the APCO claimed that it complied with 2.C.(12)(b) because it complied with NRC findings on Farley 2 relative to compliance with BTP RSB 5-1.
Those NRC findings are (Reference 3, last paragraph):
" Subject to the conditions discussed herein, we find that the capa-bility to achieve cold shutdown for Farley Unit 2 satisfies the applicable requirements of BTP RSB 5-1, meets the applicable require-ments of General Design Criterion 34, " Residual Heat Removal," and is acceptable. We will condition the full-power license to require:
(1) tests of manual control of steam dump valves prior to full-power operation. N.(1)
(2) upgrading of the operators on the power-operated relief valves
_- . after completion of EPRI tests, and N.(2) {
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(3) natural circulation cooldown test results and cooldown procedures, prior to startup following the first refueling.
N.(3)
The APC0 letter (Reference 1) claims compliance with BTP RSB 5-1 on the basis that:
"These three conditions [N.(1) - N.(3)] were included in the Unit 2 Operating License and have been addressed as follows:
(1) The requirement to demonstrate manual control of the Farley Steam Dump Valves License Condition 2.C.(12)(a), was completed prior to exceeding 5 percent power; A.(1)
(2) Qualification of the Farley PORVs, License Condition 2.C.(21)(d)(1), was documented in Alabama Power Company letters i dated June 25, 1981, September 30, 1981 and July 1, 1982.
A.(2)
(3) License Condition 2.C.(9)(a) was completed prior to exceeding 5 percent power. Alabama Power Company's letter of Jul described compliance with License Condition 2.C.(9)(b) y 8, 1982 and License Condition 2.C.(12)(c). These license conditions constitute Alabama Power Company's connitments related to natural circulation cooldown tests and procedures."
A.(3)
CLARIFICATION OF THE ISSUES The underlying issue is whether the APC0 has complied with 2.C.(12)(b), but l the APC0 letter (Reference 1) on that license condition only addresses I compliance with non-license conditions N.(1)-N.(3). This issue was 1
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- - discussed (Reference 7) with APC0 representatives who indicated that 2.C.(12)(b) was intended to assure compliance with the following requirement from Table 1 in BTP RSB 5-1, Revision 1 (Reference 2).
" Provide upgrading and additional valves to ensure operation of .
auxiliary pressurizer spray using only safety-grade subsystem meeting single failure. Possible alternative may involve using pressurizer power-operated relief valves (PORVsj, which have been upgraded. Meet SSE [ Safe Shutdown Earthquake] and single failure without manual operation inside containment." [ Underlining added.]
The APC0 statements in References 1 and 7 indicate to the staff that APC0:
(a) is apparently aware of the e'xistence of alternatives; (b) knowingly chose a PORV alternative related to N.(2); (c) expects to show compliance with N.(1)-N.(3) in order to show compliance with 2.C.(12)(b).
The staff accepts the APC0 approach because compliance with N.(1)-N.(3) will ensure compliance with BTP RSB 5-1, and compliance with BTP RSB 5-1 implies-the staff has no concern over 2.C.(12)(b).
t EVALUATION AND DISCUSSION We have evaluated the APC0 claim that it complies with BTP RSB 5-1 because it complies with the three NRC findings H.(1)-N.(3) quoted above from Reference 3. This was be done by the following:
(a) examining each finding N.(1) with respect to the origiral under- ,
lying staff discussion in Reference 3,
, (b) correlating that staff discussion with its sumary statement N.(i),
(c) testing the compliance claim A.(i) against the staff discussion and the N.(i),
(d) drawing a conclusion as to whether N.(i) is satisfied, and (e) if necessary, identif compliance with N.(i)ying licensee actions needed to ensure CONCERNING NRC FINDING N.(1) REGARDING STEAM DUMP VALVES The pertinent staff discussion from
Reference:
3 is:
" Heat removal and coolant' circulation under natural circulation conditions is ... controlled by use of the steam generator atmospheric dump valves and the auxiliary feedwater= system.
The three air-operated atmospheric dump. valves at Farley 2 (one per steam generator) are seismic Category 1. Air is supplied from plant instrument air system backed up by the emergency compressed air system.
The most limiting single failure would be the loss of one '
main steam line dump valve. The valves could be operated by manual action (outside of containment) to-correct for this single failure. By letter dated Octcber 23, 1980, the' applicant has comitted , ,
to perform tests to confirm the feasibility of this type of manual control action prior to full-power operation. Mechanical failure could prevent opening of the single dump valve. Manual action to correct for this failure could be taken to close an upstream isolation valve and replace or repair the dump valve." [ Underlining added.]
The underlined words in this quotation were restated in a shorter fonn in NRC Finding N.(1).
The APCO Compliance Claim A.(1) says "the requirement to demonstrate manual control of the Farley Steam Dump Valves ... was completed prior to exceeding 5 percent power." This claim appears to adequately address the underlined requirement above and also the suninary statement N.(1) so the staff has no concern over N.(1) and considers it satisfied.
CONCERNING NRC FINDING N.(2) ON PORV OPERATOR UPGRADING The pertinent staff discussion from Reference 3 is:
-[ " Cool and, hence, depressurize the pressurizer to 425 pounds per square inch gauge by injection of borated water through the pressurizer spray.
This pressure must be reached to pennit shutdown cooling with the RHR system.
Under natural circulation conditions the normal supply for the pressurizer spray from the cold legs of two coolant loops is lost. In this case, the pressurizer spray can be supplied by flow from the centrifugal charging pumps through a line branching off from the charging line of the chemical and volume control system. This supply could be lost by a single failure involving either closing of a single valve in the supply line or opening of one of several valves in lines connected to the supply line. If manual actions to correct for such failures were not successful, A BACKUP METHOD OF DEPRESSURIZATION
[ upper case added] would involve opening either of the two seismic Category 1 power-operated relief valves on the pressurizer, which discharges to the pressurizer relief tank. The power-operated relief valves (PORVs) and their air supply meet seismic Category 1 requirements, but their operators do not. The licensee has stated that the PORVs will be upgraded after completion of the Electric Power Research Institute (EPRI) testing program on safety relief valves and PORVs (see Item II.D.1, Section 22.5 of [ Reference 3]). Each PORV has a motor-operated isolation valve which is seismic Category 1 and is powered by emergency buses. Manual action may be taken in the event of PORY failure to position or the valve may be repaired, if necessary."
[Underliningadded.]
i The underlined words in the quotation were restated with insignificant !
changes in NRC Finding N.(2) as a summary of the above discussion.
The APC0 Compliance Claim A.(2) says " Qualification of the Farley PORVs ...
was documented." This claim of compliance is not acceptable because:
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(a) The NRC has not accepted the PORVs as qualified (Item II.D.1 of NUREG-0737) as of September 1, 1985, and, (b) The licensee did not indicate that acceptance of the PORVs included acceptance of adequate operator upgrading as required specifically by the staff in the above quotation and in the sunnary statement N.(2).
The licensee should:
(a) review the requirements for upgrading the operators on the PORVs; (b) determine whether additional action is required, and, (c) notify us of their plans or else document compliance with N.(2).
(Documentation should be specific, and not by general reference to one or more letters or reports of broad scope. That documentation can however be to reports still under staff review.) ,
9; CONCERNING NRC FINDING N.(3) REGARDING NATURAL CIRCULATION CDOLDOWN The pertinent staff discussion from Reference 3 is:
"Depressurize the pressurizer to 425 pounds per square inch gauge ... ;
to permit shutdown cooling with the RHR system. ...
" Branch Technical Position RSB 5-1 requires that a natural circulation test with supporting analysis be conducted to demonstrate the ability to cooldown and depressurize the plant and to demonstrate that boron mixing is sufficient under such circumr,tances. Comparison with perfortance of previously tested plants of similar design may be substituted for these tests, if justified. The licensee plans to reference tests to be conducted at Diablo Canyon which might affect boron mixing under natural circulation.
"The licensee's comparisons of system and upper head region charac-teristics for Farley and Diablo Canyon suggest that the results of the Diablo Canyon Test and supporting analysis should satisfy the BTP RSB 5-1 requirements. The staff had planned to deter reaching a conclusion on this matter until the Diablo Canyon results had been reviewed. However, since the Diablo Canyon tests rey not be completed prior to the first refueling of Farley 2 or may not provide satisfactory results, we have asked and the licensee has committed to submit test results applicable to Farley Unit 2 prior to startup following the first refueling if Diablo Canyon results applicable to Farley 2 are not available.
"The licensee has provided a summary of procedures for cooldown of Farley 2 by natural circulation and has committed to writing specific procedures for this operation after completion of tests and analyses applicable to Farley 2.
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. "This testing is not necessary for first-cycle operation of Farley Unit 2. The major purpose of the natural circulation test is to obtain infonnation on the time needed to take tne plant from hot standby to the cut-in point of the RHR system under conditions such as extended loss-of-offsite power when the RC5 pumps are not available.. It would be preferable to run this test after the first reload when the decay heat is relatively large. This would result in more meaningful test data and testing under conditions more representative of those occurring over the 40-year plant life. For Farley Unit 2, operation at full power is acceptable because the seismic condensate storage tank supply is backed up by the seismic Category I service water system.
With this supply to the auxiliary feedwater system, the plant could be maintained at hot standby or slowly brought to the cut-in point of the RHR system." [ Underlining added.]
The underlined words in the above quotation was restated in a shorter fann in NRC finding N.(3) as a sunnary of the above discussion. It should be explicitly noted however that N.(3) is tied to the requirements of BTP RSB 5-1 and hence to the use of safety grade systems (per Reference 2). ,
"._ The APC0 Compliance Claim A.(3) is very broad and correspondingly imprecise.'
However, concerning N.(3), it appears to say:
"[The condition N.(3) was] included in the Unit 2 Operating License and
... addressed [by prior completion of] License Condition 2.C.(9)(a)
[and by a licensee] letter of July 8,1982 [(Reference 4) which]
described compliance with License Condition 2.C.(9)(b) and License Condition 2.C.(12)(c)".
This broad claim makes it necessary to review 2.C.(9)(a), 2.C.(9)(b) and 2.C.(12)(c) to determine compliance with N.(3). These are reviewed in sequence:
License Condition 2.C.(9)(a) is quoted:
" Prior to exceeding five percent power the licensee shall provide to the NRC the results of the following seven augmented low power tests.
natural circulation i
natural circulation with simulated loss of offsite power l
natural circulation with loss of pressurized heaters effect of steam generator secondary side isolation on natural circulation natural circ.ulation at reduced pressure cooldown capability of the charging and let down system simulated loss of all onsite and offsite ac power."
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This condition identifies itself as being applicable to " prior to exceed-ing five percent power" so it is not relevant to N.(3) which is applicable "after the first reload when the decay heat is relatively large."
i Lunder11ntng added.J N.(3) being satisfied. onAdditionally, this basis, 2.C.(9)(a))could be satisfied 2.C. (9)(a was established without to assure
- operator training that would satisfy post-TMI requirement I.G.1 of NUREG-0737, and operator training is not limited to use of safety grade
! systems, but such limitation is required by 2.C.(12)(b) and BTP RSB 5-1 andN.(3). Hence N.(3) must still be shown to be satisfied, t '
i License Condition 2.C.(9)(b) is quoted:
l "After operation for 25,000 MW(e) days and at its next shutdown of
- . sufficient time duration but in any case no later than prior to the j startup following the first refueling outage results of a test of natural circulation cooldown with boron mixing shall be submitted to the NRC,
- However, this license condition may be satisfied in the same time frame by j the licensee's providing analyses to show that test results of such test ~
g performance at other plants are applicable to Farley 2." ,
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This quotation documents that the staff is willing to accept the results of tests at other plants if the licensee demonstrates applicability to Farley 2.
. However, 2.C.(9)(b) is not the same as N.(3). For example, these are not the same in their references to boron mixing and to procedures. On this basis, we i find that compliance with 2.C.(9)(b) does not automatically imply compliance
- with N.(3). Additionall , the APC0 argument (in Reference 4) concerning j compliance with 2.C.(9)(y) b relies on tests conducted at Salem, Sequoyah and ,
i North Anna, but no licensee submittals claim that the Salem and Sequoyah tests !
j used only safety grade systems, and the staff has found (in Reference 6) that ,
j the North Anna tests did not rely on only safety grade systems. HenceN.(3)
- must still be shown to be satisfied.
License Condition 2.C.(12)(c) is quoted:
4 " Prior to startup following the first refueling, the licensee shall i provide to the NRC natural circulation cooldown procedures, based on reactor natural circulation cooldown test results applicable to Farley Unit 2."
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The APC0 claims compliance with 2.C.(12)(c) on the basis that (Reference 4):
i " Test results at other plants are a>plicable to the Farley Nuclear j Plant. Unit 2; thereby, obviating tie requirement to run a natural l circulation cooldown test with boron mixing on this unit."
t l Wenotethat,inReference5,thestaffacknowledged2.C.(12)(c)assatisfied.
! We also note that the wording of 2.C.(12)(c) is very close to the wording of
! N.(3). However, we are here dealing with satisfying N.(3) as a means of
! satisfying both BTP RSB 5-1 and license condition requirement 2.C.(12)(b).
l Both of these focus on safety grade depressurization. We find:
a l .(a) the APC0 argument (in Reference 4) concerning compliance with 2.C.(12)(c) relies on tests conducted at Salem, Sequoyah and North
Anna, but no licensee submittals claim that the Salem and Sequoyah tests used only safety grade systems, (b) the staff has found (in Reference 6) that the North Anna tests did not rely on only safety grade systems and did not cool the reactor down to the temperature where the Residual Heat Removal System could have been used, and (c) the staff has found (in Reference 6) that the North Anna licensee must still shew that the results of the Diablo Canyon test (of March 28,1985) are applicable to the North Anna Plant.
Thus, we conclude that the tests used to satisfy 2.C.(12)(c) cannot be used to satisfy N.(3).
Concerning Compliance with N.(3):
The licensee should:
- (a) reactivate and update its earlier plan to reference the Diablo Canyon tests [as cited above in the staff discussion of N.(3) from Reference 3],and (b) review the Diablo Canyon test of March 28, 1985 and show the acceptability and the applicability of the results to the Farley 2 plant with respect to the capability required in BTP RSB 5-1 of using only safety grade systems for natural circulation cooldown, per N.(3),or (c) demonstrate the required systems and procedures capability by alternate means if the Diablo Canyon tests cannot be shown to be applicable to Farley 2.
SAFETY
SUMMARY
AND CONCLUSIONS The licensee claimed compliance with the requirements of License Condition 2.C.(12)(b) but its arguments in Reference 1 were addressed to the more general goal of providing:
" assurance that the safety grade means of reactor coolant system depressurization is in accordance with the requirements of Table 1 in Branch Technical Position RSB 5-1, Revision 1 [ Reference 2]."
This approach is acceptable to the staff because compliance with BTP RSB 5-1 ensures compliance with 2.C.(12)(b), but compliance has not yet been shown.
The licensee arguments were reviewed against prior staff findings (in Refer-ence 3) which documented three requirements N.(1)-N.(3) for Farley 2 compliance with BTP RSB 5-1. We conclude the following:
, 1. The finding N.(1) regarding steam dump valves is acceptable, l
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- 2. The finding N.(2) regarding PORV operator upgrading has not been shown to be complied with because the licensee referenced documents that are still under staff review and because the licensee did not document specific compliance with the action called for by N.(2).
- 3. The finding N.(3) regarding natural circulation cooldown contained a focus on safety grade depressurization. This was not addressed in the licensee's submittals. As a result, the staff found N.(3) has yet to be complied with.
In conclusion, the staff finds that compliance with BTP RSB 5-1, Rev. I needs further licensee clarification as follows:
- 1. Specific (as opposed to general) citations should be made to documents proving " upgrading of the operators on the power-operated relief valves,"
and
- 2. Review and reference to the Diablo Canyon test of March 28, 1985 should be made to show that Farley 2 can achieve cold shutdown using -
[ only safety grade equipment and natural circulation to satisfy N.(3), -
or
- 3. Demonstrate that the required systems and procedures capability exits by alternate means.
PRINCIPAL CONTRIBUTOR:
D. Langford 3
REFERENCES
- 1. " License Condition 2.C.(12)(b), Safety Grade Backup Means of RCS Depressurization," letter from F.L. Clayton, Jr. of Alabama Power Company to 5. A. Varga of the NRC, Docket 50-364, October 21, 1982.
- 2. " Design Requirements of the Residual Heat Removal System," Branch Technical Position RSB 5-1, Rev. 1, published in " Residual Heat Removal (RHR) System," Section 5.4.7 of the Standard Review Plan, NUREG-75/087, and republished in re-revised form in NUREG-0800.
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- 3. "Confornence to Branch Technical Position RSB 5-1," published in Supplement No. 5 to NUREG-0117. " Safety Evaluation Report Related to the Operation of Joseph M. Farley Nuclear Plant Unit 2," Section 6.5.1, Pages 6-14 to 6-16, March 1981.
- 4. " License Conditions 2.C.(9)(b) and 2.C.(12)(c), Boron Mixing and .'
- -- Natural Circulation Cooldown," letter from F.L. Clayton, Jr. of Alabama Power Company to 5. A. Yarga of the NRC, Docket 50-364. July 8,1982.
- 5. Letter from Steven A. Varga of the NRC to F.L. Clayton of Alabama Power Company, Docket 50-364, November 10, 1982.
- 6. " Safety Evaluation, Natural Circulation Test, North Anna Unit 2, Docket No. 50-339," January 18, 1985.
- 7. Conference call, David Langford and Edward Reeves of the NRC, with John Garlington, Jim Ripple and Douglas McKinney of the Alabama Power Company, March 25, 1985.
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