ML20136C991

Responds to 850912 Request for Info Re License Condition 2.C.(12)(b).Plant Meets Requirements of Rev 1 to Branch Technical Position Rsb 5-1.Condition Met W/O Upgrading Seismic Qualification of PORV Operators

ML20136C991
Person / Time
Site:	Farley
Issue date:	11/18/1985
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8511210203
Download: ML20136C991 (9)

Text

Malling Address

, Atb m3 Power Company

. 600 North 18th Strnt Post Of fice Box 2641 Dirmingham. Alt bama 35291 Telephone 205 783-6090 R. P. Mc Donald Senior Vice President Fhntndge Buildmg /Md[)d[Ild bOWCf November 18, 1985 Docket No. 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 2 Safety Grade Backup Means of Reactor Coolant System Depressurization Gentlemen:

By letter of September 12, 1985, the NRC advised Alabama Power Company that further clarif9ation was needed in order to conclude the review of Unit 2 License Condition 2.c.(12)(b). This license condition, which was issued as part of the full-power operating license on March 31, 1981, states, " 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 Position RSB 5-1, Rev.1." Startup from the first refueling outage on Unit 2 occurred on December 3,1982. Alabama Power Company submitted a letter on October 21, 1982 regarding compliance with this license condition and startup after the first refueling outage.

Since this was a license condition for startup, Alabama Power Company ,

has obviously assumed that the NRC concurred with Alabama Power Company's letter of October 21, 1982 or the NRC would have initiated further correspondence prior to the startup. It is noted that the NRC does not formally remove such conditions from our currently effective licenses, in addition, Alabama Power Company had not received any formal correspondence after the submittal of the October 21, 1982 letter until receipt of the NRC letter of September 12, 1985.

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Mr. S. A. Varga November 18, 1985 U. S. Nuclear Regulatory Conanission Page 2 The September 12, 1985 NRC letter specifically requested Alabama Power Company to provide the following information for the NRC to conclude that License Condition 2.C.(12)(b) has been met:

(a) specific (as opposed to general) citations to documents showing " upgrading of the operators on the power-operated relief valves," and (b) review and referencing of the Diablo Canyon test of March 28, 1985 to show Farley Unit 2 can achieve cold shutdown using only safety grade equipment and natural circulation.

With respect to item (a) License Condition 2.C.(12)(b) requires Alabama Power Company to assure that the Farley Nuclear Plant design is in accordance with the requirements of Table 1 of BTP RSB 5-1, Revision

1. As a Class 2 plant, Alabama Power Company has demonstrated that Farley Nuclear Plant meets the requirements of the BTP. The basis for this determination is that for Class 2 plants manual a:tions and repairs are acceptable. Therefore, License Condition 2.C.(12)(b) is satisfied without upgrading the seismic qualification of the PORV operators and no further action is required of Alabama Power Company. However, Alabama Power Company recognizes the importance of the PORVs operating properly during RCS overpressurization transients. Alabama Power Company accordingly has performed further reviews to detennine the qualification status of the PORV operators. In the interest of resolving this issue with the NRC, Alabama Power Company directed Westinghouse, in cooperation with Copes-Vulcan, to perform a plant-specific evaluation to obtain certification of the seismic qualification of the Farley Unit 2 PORV operators even though this is beyond the scope of the requirements of the operating license. Alabama Power Company has obtained confirmation from Westinghouse that the PORV operators are seismically qualified to functionally operate during post-SSE conditions. Item (a) of the September 12, 1985 lettee thus has been fully resolved. A more detailed response to item (a) is provided in the attachment to this letter.

With respect to item (b), Alabama Power Company does not consider the NRC request to be a requirement of License Condition 2.C.(12)(b),

but rather an attempt by the NRC to reopen the previously closed License Ccnditions 2.C.(9)(b) and 2.C.(12)(c). Alabama Power Company further considers itself to be in full compliance with all of the dated requirements of the Unit 2 Operating License and, in particular, License Conditions 2.C.(9)(b),2.C.(12)(b)and2.C.(12)(c). By letter of October 21, 1982, full compliance with condition 2.C.(12)(b) was demonstrated per the requirements of Table 1 in BTP RSB 5-1, Revision

1. License Conditions 2.C.(9)(b) and 2.C.(12)(c) were approved as being satisfactorily completed by the NRC per the SER issued on November 10, 1982. It appears that the NRC letter of September 12,1985 is attempting to reopen issues that were considered resolved by the NRC

Hr. S. A. Varga November 18, 1985 U. S. Nuclear Regulatory Commission Page 3 almost three years ago prior to startup following the first refueling outage. Moreover, it is unreasonable for the NRC to now contend that the only acceptable means of satisfying a license condition which required compliance prior to resuming power operation in December 1982 is to utilize the results of a March 1985 test. A more detailed response to Item (b) of the September 12, 1985 letter is provided in the attachment to this letter.

In conclusion, Alabama Power Company considers the response to item (a) of the September 12, 1985 letter to fully resolve the issue associated with the upgrading of the PORV operator. With respect to item (b), the NRC's new interpretation of License Condition 2.C.(12)(b) constitutes a backfit in that the appropriate requirements for natural circulation cooldown test results and procedures have bsen previously demonstrated and approved by the NRC. Alabama Power Company therefore contends that any further actions taken to impose these additional requirements for testing on Farley Unit 2 should be conducted pursuant to the appropriate backfitting procedures.

If you have any questions, please advise.

Yours very t ly,

/V .

R. P. Mcdonald RPM / JAR:ddb-D26 Attachment cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford

Attachment APCo Response to Items (a) and (b) of NRC Letter of September 12, 1985 APCo Response to Item (a):

Branch Technical Position (BTP) RSB 5-1, Revision 1, Position A.1 requires that the reactor be taken from normal operating conditions to cold shutdown using only safety-grade systems. Position H, Implementation, divides plants into three classes for the purpose of implementing the requirements for compliance with the BTP. In accordance with the descriptions provided in Position H, which are based on construction permit docket dates and expected operating license issuance dates Farley Nuclear Plant is categorized as a Class 2 plant.

Table 1 of the BTP provides recommended implementation for the process of depressurization which is accomplished with pressurizer auxiliary spray or power-operated relief valves. The recommended implementation in Table 1 for Class 2 plants states, " Compliance will not be required if (a) dependence on manual actions inside containment after SSE or single failure or (b) remaining at hot standby until manual actions or repairs are complete are found to be acceptable for the individual plant."

Alabama Power Company notes that Table 1 requires depressurization using either the pressurizer auxiliary spray or power-operated relief valves, but not both. Class 2 plants are allowed either manual actions inside containment or to remain at hot standby conditions until manual actions can be taken or repairs can be completed. These manual actions or repairs are applicable to the auxiliary spray line, which consists of the Chemical Volume Control System (CVCS) connection to the pressurizer spray line. Additionally, Farley Nuclear Plant can remain at hot standby while the manual actions are completed. Maintaining Farley Nuclear Plant at hot standby is accomplished by the safety grade, seismic Category 1 auxiliary feedwater system including the normal feedwater source of the condensate storage tank and a redundant backup source of the safety grade, seismic Category 1 service water system.

, Therefore, Farley Nuclear Plant fully meets the recommended implementation of Table 1 for Class 2 plants and thus satisfies the applicable requirements of BTP RSB 5-1, Revision 1.

The NRC SER Supplement No. 5 for Farley Nuclear F . ant - Unit 2 (NUREG-0117, Supplement 5) states on page 6-15 that the auxiliary pressurizer spray line "could be lost by a single failure involving either clusing 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 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." Additionally, page 6-16 of the SER Supplement No. 5 states "the capability to achieve cold shutdown

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Attachment I. 'Page 2 APCo Response to Item (a): (Continued) for Farley Unit'2 satisfies the applicable requirements of BTP RSB 5-1, meets the applicable requirements of General Design Criteria 34,

' Residual Heat Removal', and is acceptable. We will condition the full-power license to require... upgrading of the operators on the power-operated relief valves... prior to startup following the first refueling outage." The SER wording that the PORV operators be upgraded in order to provide a-backup means of safety-grade depressurization never appeared in the Operating License. To do so, the NRC would have been imposing the Class 1 requirements of BTP RSB 5-1, Revision 1, Table 1 on Farley Nuclear Plant. This would have been in direct conflict with the requirements of the BTP for a Class 2 plant. The Septemt'en 12, 1985 NRC letter, however, is attempting to impose these Class 1 plant requirements on Farley -Nuclear Plant.

License Condition 2.C.(12)(b) requires Alabama Power Company to assure that the Farley Nuclear Plant design is in accordance with the requirements of Table 1 of BTP RSB 5-1, Revision 1. As a Class 2 plant, Alabama Power Company has demonstrated that Farley Nuclear Plant meets the requirements of the BTP. Therefore, License Condition 2.C.(12)(b) was satisfied prior to the startup after the first refueling on December

- 3,1982 without upgrading the seismic qualification of the PORV operators and no further action was required of Alabama Power Company.

However, Alabama Power Company recognizes the importance of the PORVs operating properly during RCS overpressurization transients. As described in Alabama Power Company letter of September 30, 1981 from F.

L. Clayton, Jr. to S. A. Varga, the PORVs have been qualified per the EPRI test program.

In the interest of resolving this issue with the NRC, Alabama Power Company directed Westinghouse, in cooperation with Copes-Vulcan, to perform a plant-specific evaluation to obtain certification of the seismic qualification of the Farley Unit 2 PORY operators even though this is beyond the scope of the requirements of the operating license.

Alabama Power Company has obtained confirmation from Westinghouse that i the PORV operators are seismically qualified to functionally operate during post-SSE conditions. Thus, Alabama Power Company considers this response to fully resolve any NRC concerns stated in the letter of September 12, 1985. l APCo Response to Item (b):

Item (b)' of the September 12, 1985 NRC letter, concerning the review and the referencing of the Diablo Canyon natural circulation cooldown test of March 28, 1985 for applicability to Farley Nuclear Plant, is inappropriate. License Condition 2.C.(9)(b) states that "within 60 days af ter operation for 25,000 MW(c)-days, results for the tests of natural circulation cooldown boron mixing shall be submitted to li . .

Attachment Page 3 APCo Response to Item (b): (Continued) the NRC." The 60-day time interval was estimated to occur on approximately October 13, 1981; but, a subsequent license amendment allowed deferral of this requirement until startup from the first refueling outage on Unit 2 which occurred on December 3, 1982. Alabama Power Company demonstrated compliance with the requirements of this license condition during the first cycle of operation and so reported by letter of July 8, 1982. The NRC request to Alabama Power Company to re-evaluate these requirements approximately 3 years later is altogether inappropriate and unwarranted.

With regard to the natural circulation test, Branch Technical Position RSB 5-1, Revision 1, Section E allows comparison to other plants of similar design and the NRC SER Supplement No. 5 (page 6-15) states, " Comparison with performance of previously tested plants of similar design may be substituted for these tests, if justified."

Although Alabama Power Company originally intended to reference the Diablo Canyon test for natural circulation cooldown and boron mixing, no implication should be drawn that only the Diablo Canyon test results would be acceptable for reference. Diablo Canyon was chosen because its natural circulation characteristics were such that the results of its test would be representative of results which would be expected for Farley Unit 2, and the Diablo Canyon test results were expected to be available prior to issuance of the Farley Nuclear Plant Unit 2 operating license. But the NRC recognized that the Diablo Canyon test results might not be available in time for issuance of the license, and accordingly requested Alabama Power Company to investigate other alternatives. In this regard, the following statement was included in the SER r.upplement No. 5 (page 6-16):

However, since the Diablo Canyon tests may 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.

Additionally, the NRC stated on this same page that:

Subject to the conditions discussed herein, we find that the capability to achieve cold shutdown for Farley 2 satisfies the applicable requirements of BTP RSB 5-1, meets the applicable requirements of General Design Criteria 34, " Residual Heat Removal", and is acceptable. We will condition the full-power license to require... natural circulation cooldown test results and cooldown procedures, prior to startup following the first refueling.

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Attachment Page 4 APCo Response to Item (b): (Continued)

Alabama Power Company notes that the above statement includes both natural circulation cooldown test results and cooldown procedures. When the NRC issued the Unit 2 Operating License on March 31, 1981, it included the license conditions with it, and particularly 2.C.(9)(b) and 2.C.(12)(c). License Condition 2.C.(9) stated that:

(a) Prior to exceeding 5 percent, the licensee shall provide to the NRC the results of the following seven augmented low power tests: ...(b) Within 60 days after operation for 2S,000 MW(e)-days, results for the tests of natural circulation cooldown with boron mixing shall be submitted to the NRC.

Additionally, License Condition 2.C.(12) states:

The licensee shall modify procedures and, if necessary, equipment used for natural circulation cooldown as follows: (a)....(b)...,

(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.

License Condition 2.C.(9)(b), as originally written, specifically required results of the test for natural circulation cooldown with boron mixing and License Condition 2.C.(12)(c) specifically required procedures for natural circulation cooldown based on test results applicable to Farley Unit 2. Alabama Power Company contends that both License Conditions 2.C.(9)(b) and 2.C.(12)(c) were issued by the NRC in response to the SER Supplement 5 statement quoted above regarding conditioning of the license to require natural circulation cooldown test results and procedures. The NRC now states that compliance with License Condition 2.C.(9)(b) does not automatically imply compliance with the full-power license condition to provide natural circulation cooldown test results and cooldown procedures, prior to startup following the first refueling. Alabama Power Company does not agree with this statement.

Moreover, as stated above, License Condition 2.C.(9)(b) originally required results of the test for natural circulation cooldown with boron mixing to be submitted to the NRC within 60 days after operation for 25,000MW(e)-days. Commercial operation for Unit 2 commenced on July 30, 1981, and the 60-day time interval af ter operation for 25,000 MW(e)-days was estimated to occur on approximately October 13, 1981. By letter of September 16, 1981, Alabama Power Company requested deletion of License Condition 2.C.(9)(b) on the basis that this test has been verified by other plants similar to Farley Unit 2 and that the completion of License Condition 2.C.(12)(c) will include the

7 Attachment Page 5 APCo Response to Item (b): (Continued) verification of this test. The NRC denied the Alabama Power Company request to delete License Condition 2.C.(9)(b), but granted deferral of the test until the first refueling outage through Unit 2 License Amendment No. 9. In the SER for this license amendment, the NRC stated, "Accordingly, we will require the licensee to submit the test results of the natural circulation tests with boron mixing prior to startup following the first ref ueling." Alabama Power Company notes that the NRC SER for Supplement No. 5 Section 6.5 specifically addresses the capability of the Farley Nuclear Plant residual heat removal system to meet the requirements of BTP RSB 5-1, Revision 1. Amendment 9 to the Farley Nuclear Plant Unit 2 Operating License, issued on October 20, 1981, revised License Condition 2.C.(9)(b) to read:

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 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 the licensee's providing analyses to show that test results of such test performance at other plants are applicable to Farley 2.

Clearly, License Condition 2.C.(9)(b) was issued by the NRC to address the requirements of BTP RSB 5-1, Revision 1. The statement in the NRC letter of September 12, 1985 that "... compliance with 2.C.(9)(b) does not automatically imply compliance with [the full-power license condition to provide natural circulation cooldown test results and cooldown procedures, prior to startup following the first refueling]"

reflects a new position inconsistent with the Unit 2 License Amendment No. 9 SER.

Alabama Power Company considers compliance with License Conditions 2.C.(9)(b) and 2.C.(12)(c) to fully satisfy the NRC full-power license conditions to provide natural circulation cooldown test results and cooldown procedures prior to startup following the first refueling.

Additionally, Alabama Power Company considers that the requirements for BTP RSB 5-1, Revision 1 have been fully met. By letters dated September 16,1981, July 8,1982 and October 21, 1982, Alabama Power Company demonstrated that (1) boron mixing and natural circulation cooldown test results at other plants, which were previously reviewed by the NRC, were directly applicable to Farley Unit 2, and (2) approved natural circulation cooldown procedures, based on natural circulation cooldown test results applicable to Farley 2, were in place. Therefore, Alabama Power Company demonstrated that License Conditions 2.C.(9)(b) and 2.C.(12)(c) were fully satisfied. By letter dated November 10, 1982, the NRC issued an SER which agreed that Alabama Power Company's commitment for License Conditions 2.C.(9)(b) and 2.C.(12)(c) was completed.

I-Attachment Page 6 APCo Response to Item (b): (Continued)

In.its September 12, 1985 letter, the NRC recognized that License Condition 2.C.(12)(c) had been previously approved by the NRC Staff but contended that this license condition did not satisfy BTP RSB 5-1, Revision 1 and License Condition 2.C.(12)(b) which focus on safety grade depressurization. Additionally, the NRC contended that Alabama 1 aaer Company's documentation of compliance with License Condition 2.C.(12)(c) by relying on tests conducted at Salem, Sequoyah and North Anna was unacceptable for satisfying the license conditions of natural circulation cooldown test results and procedures prior to startup following the first refueling. Furthermore, the NRC also contended that Alabama Power Company's documentation of compliance with License Condition 2.C.(9)(b) by relying on tests conducted at Salem, Sequoyah, and North Anna is unacceptable on the same basis as stated above for License Condition 2.C.(12)(c). The NRC contention that these tests are unacceptable for satisfying the license condition is based on its requirement that these tests be conducted using only safety grade equipment, as stipulated for Class 1 plants in BTP RSB 5-1, Revision 1.

However, Farley Nuclear Plant is a Class 2 plant which is not required to depend solely on safety grade equipment for depressurization but is permitted to take manual actions, as necessary.

The foregoing reflects that Alabama Power Company has demonstrated that Farley Nuclear Plant is in full compliance with License Conditions 2.C.(9)(b) and 2.C.(12)(c), which were issued to ensure compliance with the requirements of BTP RSB 5-1, Revision 1. Furthermore, the NRC stated that " License Conditions 2.C.(9)(b) and 2.C.(12)(c) are considered to be satisfactorily completed" in an SER on November 10, 1982. Approximately three years after Alabama Power Company has fulfilled these license conditions, the NRC in its letter of September 12, 1985 has now asked Alabama Power Company to re-evaluate the same requirements of License Conditions 2.C.(9)(b) and 2.C.(12)(c), under the auspices of 2.C.(12)(b) by means of using only safety grade systems.

Alabama Power Company believes this request of the NRC is inappropriate and unwarranted.

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