ML20098A945

Application for Amends to Licenses NPF-2 & NPF-8,consisting of Supplemental Response to Generic Ltr 83-43 Re LER Reporting Requirements

ML20098A945
Person / Time
Site:	Farley
Issue date:	09/14/1984
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20098A947	List: ML20098A945 ML20098A948
References
GL-83-43, NUDOCS 8409250328
Download: ML20098A945 (5)

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-// M2;lling Addrsss Alabama Power Company

'd 600 North 18th Street Post Office Box 2641 Ermingham, Alabama 35291 Telephone 205 783-6000 R. P. Mcdonald nee $'Eu"#9 Alabama Power

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September 14, 1984 Docket Nos. 50-348 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 - Units 1 and 2 Supplemen+al Responte to Generic Letter 83-43, Reporting Requirements of 10CFR50.72 and 10CFR50.73 Gentlemen:

Pursuant to NRC letter dated July 25, 1984, this letter and its Attachments form Alabama Power Company's supplemental response to Generic Letter 83-43, dated December 19, 1983. This letter, in conjunction with Alabama Power Company's letters dated February 3 and July 6,1984 (Item 1 only), forms a complete response to Generic Letter 83-43.

Attachment I contains a discussion of each proposed change to the Farley Nuclear Plant - Units 1 and 2 Technical Specifications and provides supporting background information and justifications.

Attachment 2 lists the changed Technical Specification pages and includes the proposed changed pages. The proposed changes do not involve a significant hazards consideration as defined in 10CFR50.92. These changes F are similar to example (vii) of " Examples of Amendments That Are Considered Not Likely to Involve Significant Hazards Considerations" listed in 48FR1487') dated April 6,1983. These changes are similar in that they represent a change to make the Licenses conform to changes in the regulations, where the license changes result in very minor changes to the facilities operations, clearly in keeping with the regulations.

Additionally, the proposed changes are in accordance with NRC guidance contained in Generic Letter 83-43.

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f D Mr. S. A. Varga Page 2 U. S. Nuclear Regulatory Comission September 14, 1984 The Plant Operations Review Committee has reviewed this supplement and the Nuclear Operations Review Board will review this supplement at a future meeting. Alabama Power Company requests that the NRC review and approve these proposed changes to the Technical Specifications as soon as practicable in order to eliminate the inconsistency between 10CFR50.72 and 10CFR50.73 and the existing Technical Specifications.

Because the original proposed technical specification change and this supplement are being submitted at the request of the NRC and since Generic Letter 83 -43 stated that no license amendment fee is required for changes which implement the Generic Letter, no License Application or Approval fee is enclosed.

In accordance with 10CFR50.90, three (3) signed originals and forty (40) conforming copies of this supplement are enclosed. Pursuant to 10CFR50.91(b), a copy of this letter and its attachments have been provided to Mr. Dan Turner, the designated representative of the State of Alabama.

If you have any questions, please advise.

Yours very truly, N

R. P. Mcdonald RPM /CJS:ddb-D Tech Spec I SWORN TO AND SUBSCRIBE 0 BEFORE ME THIS /g d DAY OF 5 4 p 1984 Attachments ,

cc: Mr. L. B. Long Mr. J. P. 0' Reilly /b /22.Mid

~ ' ' ' no ttr? Publ ic Mr. E. A. Reeves j /

Mr. W. H. Bradford My Commission Expires: /o/2 y/ds Mr. G. F. Trowbridge '

Mr. D. Turner I

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f gtachment1 I ' . '-

Y Proposed Administrative Technical

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Specification Changes

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1) -Change to Technical. Specification 3.0.2 (Both Units 1 and 2)

The first sentence'has been modified ~ pursuant to 10CFR50.73(a)(2)(O(B) to clarify: when Licensee Event Reports, should be submitted.

2)f Change to Technical Specifications.

3.1.1.3, Action a.3 3.11.1.3, Action a 3.3.3.9, Action b 3.11.2.2, Action a O '

'3.7.11.1,' Action. a;b.2 3.11.2.3, Action a y J 3.7.11.2, Action' a 3.11.2.4, Action a 3.7.11.3, Action a 3.11.3, Action b 3.7.11.4, Action.'a 3.11.4, Action a 3.7.11.5,' Action a 3.12.1, Action a;c 3.7.12, Action a 3.12.2, Action a;b 3.11.1.2, Action a (Both Units 1 and 2)

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- Delete the phrase ", in lieu of any other report required by.

~ Specification 6.9.1,".

c. '.The intent of this phrase was to ensure that the Licensee

, understood that a "Special Report" was different than a " Reportable Occurrence" and that there was not a need to submit 2 reports for s the same event. Since there are no longer any " Reportable Occurrences" in Section 6.9.1, this phrase is superfluous and-therefore has been deleted from the above mentioned Specifications.-

< 3) Change to! Technical' Specification 4.2.2.2.e and Bases 3/4.2.2 and 3e= q 3/4.2.3. , (Both Units.1 and 2) h, Change the references to Specification 6.9.1.14 to Specification

• .6.9.1.11. This change is precipitated by the renumbering of the

% Radial Peak Factor Limit Report Section as.a result of deleting the

' 'd ;1" Reportable Occurrence" sections of Section 6.9.1, pursuant to

.,1 Generic Letter 83-43.

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s Attachment 1 Proposed Administrative Technical Specification Changes Page 2 -  !

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4) . Change to Technical Specifications 3.3.3.10, Action "c" and

.3.3.3.11, ~ Ac ti on "c" . (Both Units 1 and 2)

Action "c" has been deleted and Action "d" designated as Action "c". The intent of these action statements was to relieve Licensees and the NRC Staff of writing and reviewing, respectively, comparatively non-significant Reportable Occurrences. Since Reportable Occurrences have been deleted pursuant to Generic Letter 83-43 and 10CFR50.73, these action statements are superfluous;and have therefore been deleted.

5) Change to Technical Specification 3.4.9,11 odes 1, 2, 3, 4 and 5, Action "a" (Both Units 1 and 2)

Delete last two sentences, the first of which begins with "A REPORTABLE OCCURRENCE"..

-Since Reportable Occurrences have been deleted from the Technical Specifications pursuant to 10CFR50.73 and Generic Letter 83-43, this report has been deleted.

6) Change to Technical Specifications 3.5.2, Action "b" and 3.5.3, Action "c" (Both Units 1 and 2)

This reporting requirement is now codified in 10CFR50.73(a)(2)(iv). These action statements have, therefore, been deleted in their entirety.

7) Change to Technical' Specification 4.6.1.6.4 (Both Units 1 and 2)

This reporting requirement is now codified in 10CFR50.73(a)(2)(ii). This section has, therefore, been deleted in -its entirety. In addition, the deletion of this reporting item from the Technical Specifications is consistent with recent NRC approved technical specifications.

8) Change to Technical Specification 4.7.10.3 (Both Units 1 and 2)

.This section has been deleted in its entirety. This is not a "Special Report"'as described in Technical Specification 6.9.2 and

_ Generic Letter 83-43; therefore, .it is considered appropriate, in light of the issuance of 10CFR50.73, to remove this reporting

- requirement from the Technical Specifications.

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Proposed Administrative: Technic'ai Specification Changes

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9) . Change to Technical Specification 4.8.1.1.3 (Both Units 1 and 2)

'This section has been deleted Lin its entirety. Since this is not a

, _ "Special' Report" 'and the' Reportable Occurrence section of the Technical Specifications have been deleted, this section has been deleted pursuant-to Generic Letter 83-43. In addition, an annual

' report of the Diesel Generators' reliability has been added to

. Section 6.9.1.12 of the Technical Specifications pursuant to

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Generic' Letter 84-15, " Proposed Staff Actions to Improve and xMaintain Diesel Generator Reliability", dated July 2,' 1984.

10) ' Change to' Technical Specification Tables 4.11.1, note "g"; 4.11.2, _

g note "h" and 4.12.1, note "c"._ -(Both Units 1 and 2)

," iThe phrase'"in lieu of any other report" has been deleted and reference.to Technical Specification 6.9.1.8 has been verified to

. exist in each of the notes. 'The reason for this change is the same -

as for: Item'2, above.

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11) c Change to Technical Specification 3.12.1, Action "b" (Both Units 1 and 2)-

, Action "b" has ~been' deleted in its entirety and Actions "c" and "d" y have been designated as Actions "b" and "c" respectively. The-safety significant aspects of this reporting requirement have been codified'in 10CFR50.73(a)(2)(viii)(A) and (B) as well 'as 10CFR50.73(a)(2)(ix).- This is not a "Special Report" and the .

. thirty-day (30) reporting requirements of Section 6.9.1.13 are no longer;in effect as-a result of the issuance of 10CFR50.73 and Generic Letter 83-43; therefore,-this action statement has been

-- del eted. It should be noted that this information will continue to be : included in the Annual Radiological Environmental Operating Report pursuant to- existing Technical Specification 6.9.1.7. -

s 12)1 Change to Technical- Specification Bases 3/4.4.6 (Both Units 1 and 12)

--The last paragraph of the page has been modified by deleting the iword "promptly" Land ' substituting in the place of " Specification 6.9.1",~ "10CFR50.73". This change is consistent with the guidance-

.provided in Generic Letter 83-43 and supplements the same change

made in Technical Specification 4.4.6.5(c) in Alabama Power Company

letter - dated ~ J uly - 6, 1984.

- :13)1 Change tio Appendix B, Section'4.1- (Both Units 1 and 2)

- The first paragraph has been modified to conform to the requirenents of the newly issued 10CFR50.72.

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