ML20151Q987
| ML20151Q987 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/02/1988 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8808120010 | |
| Download: ML20151Q987 (4) | |
Text
.
a.
Alabr>na Power Comptny 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 352914400 Telephone 2052501837 W, G. Hairstort. lti Senice Vice President NuclearOperations tre soawn electre system August 2, 1988 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Vashington, DC 20555 Gentlemen Joseph M. Farley Nuclear Plant Units 1 and 2 NRC Inspection Report Nos. 50-348/88-04 and 50-364/88-04 By letter dated June 8, 1988, the NRC forwarded the results of the Systematic Assessment of Licensee Performance (SALP) Board evaluation of Farley Nuclear Plant for 1988. Alabama Power Company has reviewed this report and provides comments in an attachment to this letter.
Alabama Power Company appreciates the opportunity to provide comments on the SALP report and requests that these comments be considered in the NRC's final conclusion.
In addition to the attached comments, Alabama Power company requests that comments and discussions from the July 7, 1988 meeting be taken into consideration for final disposition of the SALP report.
If you have any questions, please advise.
Respectfully submitted, b4
/'
I 1/
//
h 6
V. G. Hairston, III
/' %
VGH,III/BHVidst-V8.3 Attachments cc:
Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. V. H. Bradford N
0908120010 BEKM302 1
PDR ADOCK O 38 G
i
1988 SA' F* Cm m t e.
NRC Inspecti w wt
~o.
50-348/88-04 ;m
-366'68-04 No.
Reference Comment 1.
Page 12, 2nd 1
.This paragraph contains several factual errors (Section IV.B.1) in regard to steam generator and secondary side chemical treatment:
The report states, "Since this sludge had already.initieted tube' denting, Sludge has not been shown to cause tube denting. Crevice hideout and the resultant crevice pH and corrosion cause denting. Boric acid soaks and online addition was preventatively. initiated on Unit 1 due to support plate crevice corrosion (a
' precursor of denting). The same treatment was initiated on Unit 2 due to stress corrosion cracking occurring t
at support plate intersections (nondenting related). Tube deformation has not been substantiated at FNP1 or FNP2 (approximately 8 tubes in 2A steam generator have questionable indications. The other tubes cre not in question). Neither FNP unit has had a-problem with eddy current test probe.
passage due to restrictions which would be caused by denting.
The report states that the addition of boric acid "complicated the pH control needed to prevent general corrosion and pipe thinning." Boron decreases secondary pH slightly but does not cause pH control problems.
The report states, "Consequently, the licensee planned to take two major steps to provide additional protection to the steam generators.
...beginning in the next fuel cycles, morpholine vill be substituted for ammonia for pH
)
control in an effort to maintain higher pH conditions in the carbon steel piping."
The decision to add morpholine was not based on inadequate or complicated pH control but rather on the reduction of erosion / corrosion and of steam i
generator sludge loading that would be j
provided by using morpholine as a secondary pH elevating additive.
l
1988 SALP Comminta
'NRC Inspection Report-No.
' 50-348/88-04 and 50-364/88-04 Page 2 No.
Reference Comment 2.
Page 12, 2nd 1 Morpholine has been added at 4-10 ppa, not (Section IV.B.1) substituted for ammonia, in Unit 2 Cycle 6 and Unit 1 Cycle 9.
Note that ammonia-from decomposition of hydrazine is the dominant i
determinant in steam generator pH control.
l 3.
Page 15 2nd 1 The deviation for failure' to ;,3ntrol class in (Section IV.C.1) service water is not indicative the progress that has been made siner August 1, l
1986.
Extensive testing during the SALP l
period has resulted in the development of an effective methodology which is environmentally acceptable.
4.
Page 26, 2nd 1 In discussing problems identified in
-(Section IV.I.1) environmental qualification and procurement control, the report states, "The licensee has i
been slow to acknowledge and correct some of these problems." APCo disagrees with this conclusion.
Where it could be demonstrated
{
that problems existed, APCo's corrective action was taken in a timely manner.- It would appear that APCo's efforts to explore inspection findings as to their validity has been interpreted as slow acknowledgment and corrective action.
5.
Page 26, 4th 1 The report states, "In January 1988, the (Section IV.I.1) proposal to install a vent on the 2B charging pump suction lint was canceled." No proposal was canceled. A design change was voided as a result of concerns over the adequacy of the proposed design to vent the accumulated hydrogen and the fact that operational practices had been adopted to prevent adverse affects to the 2B pump.
The report further states, "The licensee had been avare of this problem since 1979 but had not instituted permanent corrective action other than running or venting the pump."
Contrary to this assertion, APCo was not aware of the total problem since 1979. This incorrect perception on the part of the Staft vas discussed at length in the enforcement conference.
s1 1988 SALP CcamInts NRC Inspection Report No.
- 50-348/88-04 and 50-364/88-04 Page 3 No.
Reference Comment 6.
Page 32, 1st & 2nd 1 The report draws conclusions regarding the
-(Sectinn IV.L.1) environmental qualification program which APCo disagrees with. Whereas the SALP is not an appropriate forum to thoroughly discuss the difference of opinions on environmental qualification, the following concerns are highlighted:
1.
The report states that inspections found the environmental qualification
. program to be marginal during the early development stages. To the contrary, correspondence and the.NRC SER seem to indicate the environmental qualification prograa was satisfactory in the early development stages.
2.
The report states that inadequate i
staffing was a contributor to environmental qualification deficiencies. APCo does not agree that inadequate staffing was provided.
3.
The report. cites "extensive use of unqualified terminal blocks in instrument circuits inside containment". The issue on terminal i
blocks has been thoroughly discussed.
APCo has maintained the blocks were qualified but-the-issue regarding instrument inaccuracy could not be resolved until the blocks were replaced with qualified splices.
]
4.
It is inappropriate to cite the issue l
of upgrade of equipment qualification in accordance with 10 CFR 50.49(1) in the'SALP report.
This issue resulted from misunderstanding and miscommunication on behalf of both APCo and the NRC.
It is not indicative of a programmatic l
breakdown in engineering support.
J
_. ~.
.