ML20070P148

Objects to NRC 821230 Decision to Delay Review of Util 821008 Request to Change Tech Specs,Deleting Turbine Valve Testing Requirements.Interim Relief from Tech Spec 3/4.3.4 Should Be Granted Due to Unnecessary Transients

ML20070P148
Person / Time
Site:	Farley
Issue date:	01/18/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S NRC
References
TAC-48973, TAC-52539, TAC-53434, NUDOCS 8301260210
Download: ML20070P148 (4)

Text

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, Mailing Addr2cs 4 #

l Alabama Power Company

! 600 North 18th street Post Office Box 2641

• Brmingham, Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.

R" 'a'Ol4'"' Alabama Power the Southern 6xtrc system January 18, 1983 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 Turbine Valve Technical Specification Deletion Request Gentlemen:

Alabama Power Company submitted a proposed change to the Farley Nuclear Plant - Unit 2 Technical Specifications on October 8, 1982, requesting deletion of the turbine valve testing requirements. A r,upplemental letter dated December 10, 1982, clarified a potential misunderstanding regarding the Westinghouse recommendations fcr turbine valve testing and restated the urgency of the proposed technical specification change since the plant is being subjected to unnecessary transients and a loss of electric generation capacity without concomitant safety benefits.

The NRC letter of December 30, 1982, stated that review of the proposed technical specification change would require about one year to complete.

Alabama Power Company objects to the decision made to delay Lool j'

review of this Farley Nuclear Plant - Unit 2 submittal. The NRC decision appears contrary to the stated policy of assigning highest priority to safety issues involving unnecesary loss of electric generation capability. Therefore, Alabama Power Company requests that NRC proceed as soon as possible with review of the turbine valve technical specification deletion request submitted on October 8, 1982. Since turbine valve testing is not a generic requirement by the NRC (i.e. , not all plants have this requirement) further delay on the basis of NRC review of a generic issue is unwarranted and interim relief from the Unit 2 Technical Specifications should be granted during the NRC review.

8301260210 830118 PDR ADOCK 05000364 P PDR

mr 2WW-MM dh Mr. S. A. Varga Janua ry 18, 1983 U. S. Nuclear Regulatory Commission Page 2 In response to the three reasons cited for the extended review schedule in the December 30, 1982 NRC letter, Alanama Power Company has the following comments:

1. NRC Reason:

"This issue, the probability of turbine missile generation, concerns turbine manufacturers in addition to Westinghouse.

Our staff is in the process of resolving the issue generically.

Specifically, technical reports describing methods and procedures for calculating design speed and destructive overspeed missile generation probabilities have been submitted to us by the Westinghouse Steam Turbine Division and are currently under review. These reviews are scheduled for completion within a year. The results will be directly applicable to Farley Unit No. 2 in that they will establish acceptable methods for settling revised inspection and test schedules and procedures for essentially all Westinghouse turbine governor and overspeed protection systems."

Comment:

As stated in the Alabama Power Company letter of December 10, 1982, the requested technical specification change is based on analysis done specifically for the Farley Nuclear Plant and should not be applied generically to other plants.

Additionally, the analysis was not based on turbine missile generation methods or procedures; it was based on turbine valve failure probabilities. The October 8, 1982 letter conclusively demonstrated that turbine valve testing at the Farley Nuclear Plant does not significantly af fect turbine missile generation analyses. Therefore, this NRC reason for delaying review due to a generic evaluation of Westinghouse systems is inappropriate since the Alabama Power Company submittal is not dependent on and does not involve the turbine missile generation issue being addressed by the Westinghouse Steam Turbine Divison.

Regarding the issue of turbine missile generation, Alabama Power Company has submitted all NRC requested information on this subject as documented in NUREG-0117. Supplement No. 5, dated March 1981. During the recent refueling outage, the low  !

pressure turbine rotors of Farley Nuclear Plant - Unit 2 were i replaced with rotors having upgraded discs.

y g g g.. .y Mr. S. A. Varga January 18, 1983 U. S. Nuclear Regulatory Commission Page 3

2. NRC Reason:

i "Your staff requests deletion of Technical Specification 3/4.3.4 arguing that accidental trips and refueling shutdowns satisfactorily demonstrate the operability of the turbine overspeed protection system. However, this is not consistent with the current ' Functional Test Requirements for Nuclear Turbines' supplied to customers by the Westinghouse Steam Turbine Division."

Comment:

As stated in the Alabama Power Company letter of December 10,

, 1982, the Westinghouse document " Functional Test Requirements for Nuclear Turbines" is completely consistent and compatible with the requested technical specification deletion. This statement is supported by Westinghouse in a letter dated December 10, 1982, that was attached to the Alabama Power Company letter of the same date. The Westinghouse letter addresses matters relating to turbine valve testing separate and distinct from nuclear plant safety issues. Therefore, this NRC reason for delaying review is not compatible with previous information supplied by Alabama Power Company and Westinghouse.

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3. NRC Reason:

" Westinghouse Nuclear Energy System Report, WCAP-10161, used to support the request, requires extensive interaction with the l manufacturer and cannot be completed on your requested schedule. Prior to completing our review we do not have an adequate basis to reach a decision on your request. We propose l

to use WCAP-10161 in conjunction with our review of the Westinghouse generic reports on this issue."

Comments:

Alabama Power Company is available on short notice to interact with the NRC Staff on any questions raised regarding WCAP-10161. Since the October 8,1982 submittal of WCAP-10161, no such request for interaction has been received. Again, use of WCAP-10161 in conjunction with Westinghouse generic reports on turbine missile generation is inappropriate since WCAP-10161 is not dependent on any ongoing generic discussion and is only

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Mr. S. A. Varga January 18, 1983 U. S. Nuclear Regulatory Commission Page 4 applicable to the Fatley Nuclear Plant. Alabama Power Company knows of no documented analytical basis for the existing testing requirement contained in the Unit 2 Technical Specifications and contends that it was ratchetted by the NRC into accepting this requirement during the operating license review. Therefore, it is the judgement of Alabama Power Company that this reason for delaying review is not appropriate.

In concl usion, Alabama Power Company requests that NRC review of the October 8,1982 submittal be reinstated as soon as possible. Additionally , it is requested that until review is

completed, interim relief from Technical Specification 3/4.3.4 should be granted on the basis that the plant is being subjected to unnecessary transients and a loss of electric generation capacity without demonstrated safety benefits. Since turbine valve testing is not an NRC generic requirement and the present technical specification requirement is without documented analytical basis, further delay on the basis of NRC review of a generic issue is unwarranted.

Alabama Power Company welcomes any opportunity to work with the NRC to expedite review and resolution of this proposed '

technical specification change.

Yours very truly,

( )& D'

[y . L.

F Clayton, J r.

FL CJ r/GGY:mj h-D37 cc: Mr. R. A. Thomas Mr. G. F . Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford

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