ML20083B353

Application for Amend to Licenses NPF-2 & NPF-8,consisting of Proposed Changes to Tech Specs 3/4 4-36,3/4 3-40, 3/4 3-57,3-4 6-19 & B3/4 4-14,in Response to Generic Ltr 83-37 & NUREG-0737.Class III & I Fees Encl

ML20083B353
Person / Time
Site:	Farley
Issue date:	12/12/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S NRC
Shared Package
ML20083B354	List: ML20083B353 ML20083B359
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-TM GL-83-37, NUDOCS 8312210117
Download: ML20083B353 (9)

Text

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Mrihng Addrsts

, Alabama Power Company

. 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.

Senior %ce President December 12, 1983 Fhntridge Building A abamaPower we soun:m enc g,wm l

Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. S. A. Yarga Joseph M. Farley Nuclear Plant - Units 1 and 2 Response to Generic Letter 83-37, NUREG-0737 Technical Specifications Gentlemen:

NRC Generic Letter 83-37, dated November 1,1983, requested submittal of certain technical specification changes based on NUREG-0737 items scheduled for completion after December 31, 1981. In response to that request, Alabama Power Company herewith submits proposed technical specification changes based on the guidance in Generic Letter 83-37.

Attachment 1 contains a response to each of the NUREG-0737 items listed in Enclosure 1, " Staff Guidance on Technical Specifications for NUREG-0737 Items Scheduled Af ter December 31, 1981," to Generic Letter 83-37. Attachment 2 contains the proposed technical specification changes for Farley Nuclear Plant, Units 1 and 2.

The proposed changes do not involve a significant hazards consideration as defined in 10CFR50.92. These changes are similar to example (ii) of " Examples of Amendments That Are Considered Not Likely to Involve Significant Hazards Considerations" listed in 48FR14870 dated April 6, 1983. These changes are similar in that an additional limitation, restriction and control not presently included in the technical specifications are involved. Additionally, the proposed changes are in accordance with NRC guidance contained in Generic Letter 83-37.

The Plant Operations Review Committee has reviewed this proposed change. The Nuclear Operations Review Board will review this change at a future meeting.

8312210117 831212 a PDR ADOCK 05000 g WOW 9%400

, m Mr. S. A. Varga December 12, 1983 U. S. Nuclear Regulatory Commission Page 2 l

l The class of this proposed technical specification change is designated as Class III for Unit 1 and Class I for Unit 2 in a*cordance with 10CFR170.22 requirements and a check for $4,400 to cover the fee required is enclosed. This proposed change is being made at the request of the NRC and does not involve an impact on plant operation. Since the reactor vessel head vent system is not currently operational, NRC is requested to approve the enclosed Technical Specification changes by July 1,1984 with the provision that the effective date for proposed Technical Specification 3/4.4.12 is no earlier than prior to entry into Mode 1 following the third refueling outage at Unit 2. This schedule is compatible with Alabama Power Company's plan to make the vent system operational as will be described in a letter scheduled for submittal on December 15, 1983.

In accordance with 10CFR50.30 (c)(1)(1), three (3) signed originals and forty (40) additional copies of this proposed change are enclosed.

As noted by the distribution, a copy of this letter is being sent to the Alabama State Designee in accordance with 10CFR50.91 (b)(1).

If you have any questions, please advise.

Yours very tru ,

$N hN. L. Clayton, Jr.

FLCJ r/GGY:lsh-D13 SWORN TO AND SUBSCRIBED BEFORE ME Attachments THIS 10 tb DAY OFdeadge,-1983 cc: Mr. R. A. Thr; mas Mr. G. F. Trowbridge Mr. J. P. O'Reilly clCv NM Notary Public Mr. E. A. Reeves Mr. W. H. Bradford Dr. I. L. Myers My Commission Expires: l-lb 47

bc: Mr. W. O. Whitt '

Mr. R. P. Mcdonald Mr. H. O. Thrash M r. O. D. Ki n gsl ey , J r.

Mr. W. G. Hai rston, III Mr. J. W. McGowan i Mr. C. D. Nesbitt Mr. R. G. Berryhill Mr. D. E. Mansfield Mr. J. A. Ripple Mr. W. G. Ware Mr. L. B. Long Mr.-B. J. George Mr. J. R. Crane Mr. K. C. Gandhi Reference Listing i

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l ATTACHMENT 1 l RESPONSES TO ENCLOSURE 1 0F GENERIC LETTER 83-37

1) Reactor Coolant System Vents NRC Guidance At least one reactor coolant system vent path (consisting of at least two valves in series which are powered from emergency buses) shall be operable and closed at all times (except shutdown and refueling) at each of the following locations:

a) Reactor Vessel Head b) Pressurizer Steam Space c) Reactor Coolant System High Point.

For the plants using a power operated relief valve (PORV) as a reactor coolant system vent, the block valve is not required to be closed if the PORV is operable.

APCo Response Alabama Power Company's compliance with NUREG-0737 item II.B.1 is described in letters dated January 14,1981, June 25,1981 and April 30, 1982. Of the three locations mentioned in the above guidance, only the Reactor Yessel Head is applicable to Farley Nuclear Plant for this technical specification. Pressurizer steam space is covered by an existing technical specification, and Farley Nuclear Plant does not have a Reactor Coolant System High Point l separate from the Reactor Yessel Head. Alabama Power Company's compliance with the NRC's guidance for Reactor Coolant System Vents (for all applicable locations and plant specific differences) is described in Attachment 2.

2) Post-Accident Sampling NRC Guidance Licensees should ensure that their plant has the capability to obtain and analyze reactor coolant and containment atmosphere samples under accident conditions. An administrative program should be established, implemented and maintained to ensure this capability. The program should include:

a) training of personnel b) procedures for sampling and analysis, and c) provisions for maintenance of sampling and analysis equipment.

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Attachment 1 Responses to Enclosure 1 of Generic Letter 83-37 Page 2 It is acceptable to the Staff, if the licensee elects to reference this program ,in the administrative controls section of the Technical Specifications and include a detailed description of the program in the plant operation manuals. A copy of the program should be easily available to the operating staff during accident and transient conoitions.

APCo Response The current Farley Nuclear Plant Technical Specification is in accordance with the NRC's guidance.

3) Long Term Auxiliary Feedwater System Evaluation NRC Guidance The objective of this item is to improve the reliability and performance of the auxiliary feedwater ( AFW) system. Technical Specifications depend on the results of the licensee's evaluation and staff review of each plant. The limiting conditions of operation (LCO) and surveillance requirements for the AFW system should be similar to safety-related systems. These specifications are for a plant which has three auxiliary feedwater pumps. Pl ant-specific Technical Specifications could be established by using the I generic Technical Specifications for the AFW system.

APCo Response Tne current Farley Nuclear P1 ant Technical Specification is technically in accordance with the NRC's guidance; however, there are minor editorial differences in that the FNP Technical i Specification includes inservice testing as a part of another l Technical Specification. No modifications are planned for this l Technical Specification.

l l 4) Noble Gas Effluent Monitors NRC Guidance Noble gas effluent monitors provide information, during and following an accident, which is considered helpful to the operator in assessing the plant condition. It is desired that these monitors be operable at all times during plant operation, but they are not required for safe shutdown of the plant. In case of i

failure of the monitor, appropriate actions should be taken to l restore its operational capability in a reasonable period of time.

Considering the importance of the availability of the equipment and l

possible delays involved in administrative controls, 7 days is considered to be the appropriate time period to restore the operability of the monitor. An alternate method for monitoring the effluent should be initiated as soon as practical, but no later than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the identification of the failure of the monitor. If the monitor is not restored to operable conditions

Attachment 1 R;sp:ns s to Enclosure 1 of Generic letter 83-37 Page 3 l l

within 7 days after the failure, a special report should be i submitted to the NRC within 14 days following the event, outlining I the cause of inoperability, actions taken and the planned schedule i for restoring the system to operable status.

APCo Response In accordance with NRC guidance, the proposed Technical Specification is included in Attachment 2.

5) Sampling and Analysis of Plant Effluents NRC Guidance Each operating nuclear power reactor should have the capability to collect and analyze or measure representative samples of radioactive iodines and particulates in plant gaseous effluents during and following an accident. An administrative program should be established, implemented and maintained to ensure this capability. The program should include:

a) training of personnel b) procedures for sampling and analysis, and c) provisions for maintaining of sampling and analysis equipment.

lt is acceptable to the staff, if the licensee elects to reference this program in the administrative controls section of the Technical Specifications and include a detailed description of the program in the plant operation manuals. A copy of the progrzm should be readily available to the operating staff during accident and transient conditions.

APCo Response The current Farley Nuclear Plant Technical Specification is in accordance with the NRC's guidance.

6. The Containment High-Range Radition Monitor NRC Guidance A minimum of two in-contair. ment radiation-level monitors with a maximum range of 108 rad /hr (107 R/hr for photon only) should be operable at all times except for cold shutdown and refueling outages. In case of failure of the monitor, appropriate actions should be taken to restore its operational capability as soon as possible. If the monitor is not restored to operable condition within 7 days after the failure, a special report should be

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Attachment 1 Responses t3 Encicsure 1 of Generic Letter 83-37 Page 4 submitted to the NRC within 14 days following the event, outlining the cause of inoperability, actions taken and the planned schedule for restoring the equipment to operable status. The setpoint for the high radiation level alarm should be determined such that spurious alarms will be precluded. Note that the acceptable calibration techniques for these monitors are discussed in NUREG-0737.

APCo Response The current Farley Nuclear Plant Technical Specification is in accordance with the NRC's guidance.

7) Containment Pressure Monitor NRC Guidance Containment pressure should be continuously indicated in the control room of each operating reactor during Power Operation, Startup and Hot Standby modes of operation. Two channels should be operable at all times when the reactor is operating in any of the above mentioned modes. Technical Specifications for these monitors should be included with other accident monitoring instrumentation in the present Technical Specifications. Limiting conditions for operation (including the required Actions) for the containment pressure monitor should be similar to other accident monitoring instrumentation included in the present Technical Specifications.

APCo Response The current Farley Nuclear Plant Technical Specification is in accordance with the NRC's guidance.

8) Containnent Water Level Monitor NRC Guidance A continuous indication of containment water level should be provided in the control room of each reactor during Power Operation, Startup and Hot Standby modes of operation. At least one channel for narrow range and two channels for wide range instruments should be operable at all times when the reactor is operLting in any of the above modes. Narrow range instruments should cover the range from the bottom to the top of the containment sump. Wide range instruments should cover the range from the bottom of the containment to the elevation equivalent to a 600,000 gallon (or less if justified) capacity. Technical Specifications for containment water level monitors should be included with other accident monitoring instrumentation in the present Technical Specifications. LCOs (including the required

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Attachment 1 Resp:nses to Enclosure 1 of Generic Letter 83-37 Page 5 Actions) for wide range monitors should be similar to other accident monitoring instrumentation included in the present Technical Specifications. LCOs for narrow range monitors should include the requirement that the inoperable channel will be restored to operable status within 30 days or the plant will be brought to Hot Shutdown condition as required for other accident monitoring instrumentation.

APCo Response Alabama Power Company's compliance with the NRC's guidance is provided in Attachment 2.

9) Containment Hydrogen Monitor NRC Guidance Two independent containment hydrogen monitors should be operable at all times when the reactor is operating in Power Operation or Startup modes. LC0 for these monitors should include the requirement that with one hydrogen monitor inoperable, the monitor should be restored to operable status within 30 days or the plant should be brought to at least a hot standby conaition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If both monitors are inoperable, at least one monitor should be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant should be brought to at least hot standby condition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

APCo Response Alabama Power Company's compliance with the NRC's guidance is described in Attachment 2; however, there are plant-specific differences involving the surveillance requirements. The existing Farley surveillance requirements have provided acceptable demonstration of hydrogen monitor operability for a number of years. The difference in sample gases is based on the plant specific zero and span gas currently used at Farley Nuclear Plant.

10) Instrumentation for Detection of Inadequate Core Cooling NRC Guidance Subcooling margin monitors, core exit thermocouples, and a reactor coolant inventory tracking system (e.g., differential pressure measurement system designed by Westinghouse, Heated Junction Themocouple System designed by Combustion Engineering, etc.) may be used to provide indication of the approach to, existence of, and recovery from inadequate core cooling (ICC). This instrumentation should be operable during Power Operation, Startup and Hot Shutdown modes of operation for each reactor.

. Attachment 1 Resptnses to Enclosure 1 of Generic Letter 83-37 Page 6 Subcooling margin monitors should have already been included in the present Technical Specifications. Technical Specifications for core exit thermocouples and the reactor coolant inventory tracking system should be included with other accident monitoring instrumentation in the present Technical Specifications. Four core-exit thermocouples in each core quadrant and two channels in the reactor coolant inventory tracking system 3re required to be operable when the reactor is operating in any of the above mentioned modes. A minimum of two core-exit thermocouples in each quadrant and one channel in the reactor coolant invencory tracking system should be operable at all times when the reactor is operating in any of the above mentioned modes.

APCo Response Alabama Power Company's current Technical Specification conforms with the NRC guidance except that Farley Nuclear Plant does not have a reactor coolant inventory tracking system. As stated in letter dated March 10, 1983, Alabama Power Company is awaiting NRC approval of an operating system prior to installation of an inventory tracking system at Farity Nuclear Plant.

11) Control Room Habitability Requirements NRC Guidance Licensee should ensure that control room operators will be adequately protected against the effects of the accidental release of toxic and/or radioactive gases and that the nuclear power plant can be safely operated or shutdown under design basis accident conditions. If the results of the analyses of postulated accider.tal release of toxic gaces (at or near the plant) indicate any need for installing the toxic gas detection system, it should be included in the Technical Specifications. All detection systems should be included in the Technical Specifications. In addition to the above requirements, other aspects of the control room habitability requirements should be included in the Technical Specifications for the control room emergency air cleanup systems should be operable continuously during all modes of plant operation and capable of meeting design requirements.

APCo Response Alabama Power Company's current Technical Specification conforms with the NRC guidance except for plant-specific design differences since Farley Nuclear Plant does not have a filter bypass system.

Other differences involve actual plant design values such as control room air temperature. No modifications are planned for this Technical Specification.

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