ML20214W071
| ML20214W071 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/05/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-87-06, GL-87-6, NUDOCS 8706150071 | |
| Download: ML20214W071 (4) | |
Text
f e.
b Alotomo Power Company 600 Nortn 18th Street Post Office Box 2641 eirmingham, Alabama 35291-0400 Telephone 205 250-1835 R. P. Mcdonald Alabama Power Senior Vice President the southem ekttrc system 10CFR50.54(f)
June 5, 1987 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Docunent Control Desk Washington, D. C.
20555 Joseph M. Farley Nuclear Plant - Units 1 and 2 Response to Generic Letter 87-06 Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves Gentlemen:
By letter dated March 13,1987 (Generic Letter 87-06), the NRC staff requested Alabama Power Company to provide information regarding the periodic verification of leak tight integrity of pressure isolation valves.
Pressure isolation valves (PIVs) are defined as any two valves in series within the reactor coolant pressure boundary (RCPB) which separate the high pressure reactor coolant system (RCS) from an attached low pressure system.
These valves are normally closed during power operation. The letter requests that Alabama Power Company submit a list of PIVs and a description of the periodic tests or other measures performed to assure the integrity of the valves as an independent barrier at the RCPB along with the acceptance criteria for leakage, operational limits and frequency of test performance.
The letter also states that if current plant Technical Specifications require leak rate testing of all of the PIVs in the plant, a reply to that effect will be sufficient. This information was requested within 90 days of the letter pursuant to 10 CFR 50.54(f).
Alabama Power Company first addressed this issue for Unit 1 in response to a February 23, 1980 letter from the NRC staff which described the Event V scenaric identified by the " Reactor Safety Study" (WASH-1400, NUREG 75/014, October 197S). Based on information supplied by Alabama Power Company (letter dated March 24,1980), the NRC issued an Order for Modification of License (Event V Order) dated April 20, 1981. The order required Alabama Power Company to implement Technical Specifications for Unit I which incorporated limiting conditions for operation and periodic surveillance for the life of the plant for four check valves at the Class 1-Class 2 boundary for low head injection to the RCS hot legs. The leakage acceptance criteria O
8706150071 870605
~
PDR ADOCK 05000348 a
P pop glg
?
o U. S. Nuclear Regulatory Commission Page 2 June 5, 1987 included a maximum allowable leakage rate of 5.0 gallons per minute provided the latest measured rate had not exceeded the rate determined by the previous test by an amount that reduced the margin between measured leakage rate and the maximum permissible rate of 5.0 gallons per minute by 50% or greater.
This issue was first addressed for Unit 2 during the NRC operating license review phase prior to issuance of the full power license. Section 3.9.4 of Supplement 5 to the Unit 2 Safety Evaluation Report (SER) discusses the resolution of this issue at the time that the full power license was issued. In addition, Alabama Power Company identified certain valves in the safety injection, residual heat removal and boron injection systems for inclusion in the Technical Specifications as PIVs. The acceptance criteria for leakage consisted of a maximum allowable leakage rate of 1.0 gallon per minute.
The NRC staff and Alabama Power Company continued to review the list of PIVs for Units 1 and 2 as part of the review of the Inservice Testing Program for Pumps and Valves. At the same time, the NRC staff undertook a generic review of leakage acceptance criteria for PIVs. By letter dated May 2,1983 the staff issued a letter documenting completion of their review of the Unit 1 Inservice Testing Program for Pumps and Valves. This letter recommended that the Unit 1 Technical Specifications be revised to include a list of valves corresponding to the list of valves appearing in the Unit 2 Technical l
Specifications. By letters dated July 5, September 27 and November 28, 1983, Alabama Power Company submitted additional information that enabled the staff and Alabama Power Company to arrive at an appropriate list of PIVs for Units 1 and 2.
The NRC staff officially concurred with this list of PIVs by letter dated January 26, 1984.
l Concurrently, the NRC staff issued Amendment 25 to the Unit 2 Technical l
Specifications (letter dated September 8,1983) which allowed, on a one-time only basis, the application of a modified version of the Unit 1 PIV leakage acceptance criteria.
In this letter, the staff alluded to their generic review of the leakage acceptance criteria for PIVs and stated that licensees would be allowed to implement the new criteria upon approval of the NRC's proposed criteria.
On April 10, 1984, Alabama Power Company therefore submitted a proposed technical specification change for Units 1 and 2 for leakage testing of RCS PIVs. This proposed change standardized the list of PIVs for the two units and revised the leakage acceptance criteria per NRC guidance included in the September 8,1983 SER for Amendment 25 to the Unit 2 T^chnical Specifications. The NRC staff concurred with this proposed change and issued Amendments 50 and 41 for Units 1 and 2, respectively, by letter dated October 15, 1984. These amendments resulted in the list of PIVs and leakage acceptance criteria that presently appear in the Unit 1 and Unit 2 Technical Specifications.
.c U. S. Nuclear Regulatory Commission Page 3 June 5, 1987 In light of the previous discussion, Alabama Power Company is confident that the selection of RCS PIVs and associated leakage testing for the Farley r
Nuclear Plant has been extensively reviewed and the Unit 1 and Unit 2 4
Technical Specifications contain the proper list of PIVs and leakage testing requirements. A list of references which document the review of this -issue for the Farley Nuclear Plant is provided as an Attachment.
1 If you have any questions or comments, please contact us.
Respectfully submitted, ALABAMA POWE OMPANY W
R. P. Mcdonald
(
RPM / JAR:ks-T.S.2
-Attachment 3
. Mr. L. B. Long SWORN TO AND SUBSCRIBED BEFORE HE xc:
Dr. J. N. Grace THIS.[ 4 DAY OF () CtnO
, 1987 Mr. E. A. Reeves 2
Mr. W. H. Bradford Notary Pgic '
My Commission Expires:
k-//-87 4
9
~
---,ug-e e-.-
w-,-y-w-wevew-w w w w e v w-w, e,w< s re-<*,www =r w w -
-5,w ev.w r wmpr'-
vewr a--"w-**T'~7--
-~-v-'----'w m -'+-"Y
-~ M %v9&' W '
- 9"T*7*
'--*=-r*******
t Attachment 1.
NRC letter dated February 23,1980, " LWR Primary Coolant System Pressure Isolation Valves."
2.
APCo letter to NRC dated March 24, 1980, " LWR /PCS Pressure Isolation Valves."
3.
NRC letter dated April 20, 1981 (Event V Order).
4.
Supplement No. 5 to the Safety Evaluation Report related to the operation of Joseph M. Farley Nuclear Pla;.t Unit 2, March 1981.
5.
NRC letter dated May 2,1983, " Completion of Review of Requests for Relief and Inservice Testing Program for Pumps and Valves - Joseph M.
Farley Nuclear Plant, Unit No.1."
6.
APCo letter to NRC dated July 5,1983, " Requests for Relief from Inservice Testing Requirements."
7.
NRC letter dated September 8,1983, " Amendment No. 25 to Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant, Unit No. 2."
8.
APCo letter to NRC dated September 27, 1983, " Inservice Testing of Primary Pressure Isolation Valves."
9.
APCo letter to NRC dated November 28, 1983, " Response to NRC Draft on Open IST Items."
- 10. NRC letter dated January 26,1984, " Relief from ASME Section XI Requirements from Inservice Testing Program for Pumps and Valves -
Joseph M. Farley Nuclear Plant Units Nos.1 and 2."
- 11. APCo letter to NRC dated April 10, 1984, " Proposed Technical Specification Change for Leakage Testing of Reactor Coolant System Pressure Isolation Valves."
- 12. NRC letter dated October 15,1984, " Amendment No. 50 to Facility Operating License No. NPF-2 and Amendment No. 41 to NPF-8 for the Joseph M. Farley Nuclear Plant, Units Nos.1 and 2."
ks:D-T.S.2
__