ML20118A105

Applicant Exhibit A-112,consisting of 830107 Ltr Re Closure of Completed License Conditions

ML20118A105
Person / Time
Site:	Farley
Issue date:	05/18/1992
From:	Clayton F ALABAMA POWER CO.
To:
References
CIVP-A-112, NUDOCS 9207310120
Download: ML20118A105 (11)

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' If S R Director, Nuclear Reactor Regulation 5-13-95 U. 5. Nucleaa Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 2 Closure of Corneleted License Conditions Gentlemen:

The operating license f or the Joseph H. Farley Nuclear Plant - Unit 2 contains several license conditions that have been cortpleted by Alabama Power Company but have not been previously identified to the NRC as being cortplete. Many of these license conditions have resulted in commitments f or additional action beyond the requirements of the license. Attacnec is a description cf nine licente conditions that are complete and the subsequent commitments rr.ade to address any remaining outstanding issues such as NUREG-0737. Since the nue license conditions are cofeplete, Alabama Power Company resp 0:tfu11y requests that they be f orrtally closed by the NRC. This lette.* supercedes our letter of October 19, 1982 relating to these conditions.

Yours very truly, L C ,

FLCJr/GGY: 1sh.D34 Att u hinant cc: Mr. R. A. Thomas ,

Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford watun%

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M E4 '52 11:05 scuTmr44 IOCLR44u Y mcJtcT p,3 DD ATTACNMENT (1) 1.icense Condition 2.r;.(18)(a). (b) and (c)_ <

Requirement: The licensee shall take the following remedial actions, or al.ternative actions, acceptable to the NRC, with regard to

'he environmental qualification requirenants for Class IE equipment (a) Complete and auditable records shall be available and maintained at a central location which describes the

• environmental qualification method used for all safety related electrical equipment in sufficient detail to document the degree of compliance with WREG-0588, " Interim Staff Position on Environmental Qualification of Safety Related Elet.crica!

Equipment " dated December 1979. Such records shall be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified to document conplete compliance no later than June 30, 1982.

(b) Within 90 days of receipt of the equipment cualification safety evaluation (Appendix B to SER NUREG-0117), the licantee shall either Supplement (i) provide m 6,issing documentation identified in O Sections 3.0, 4.2 and 4.3 of the equipment qualification safety evaluation which will demonstrate compliance of the applicable equipent with NUREG-05BS, or (ii) commit to corrective actions which Will result in documentation of compliance of applicable equipment with NUREG-0588 no later than June 30, 1982.

(c) No later than June 30, 1982, all safety-related electrical equipment in the f acility shall be qualified in accordance with the provisions of NUREG-0588.

Response: Alabama Power Company has made several submittals oocumenting the environmental qualification of applicable equipment in accordance with NUREG-0588. The completion date of June 30, 1982 for hadng all applicable equipment qualif ted has been superseded by 10 CFR 50.49 which suspends the completion date requirement. All current action on this issue is being taken in accordance with 10 CFR 50.49 and HUREG-0588. Alabama Pcwer Company has completed all applicable requirements of this license condition and requests that it be formally closed by the NRC.

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't#A E4 '?2 itlet H3m toct rca.ty Frc tCT p,4 l

l ATTACHMENT 07.132s Q License Condition 2.C.(20)

(2) .-

Requirements Prior to April 30, 1981, the licensee shall provide a schedule to the HRC for bringing the factif ty into cdepliance with Revision 2 of Regulatory Guide 1.97

" Instrumentation for Light Water Coolec Nucitar Power Plants to Assess Plant Conditions During and Following an Accident.' dated December 1980.

Rtsponset Alabama Power Company letter dated March 30, 1981 by documented tortpliance with license condition 2.C.(20)ision f orwarding a schedule to meet the requirements of Rev 2 of Regulatory Guide 1.97. Subsequently, Alabama Power Company letter dated November 16. 1902 stated that the previously transmitted schedule was being withdrawn based on a t.lutual agreement between the NRC and Alabstra Power Company. The recently issued HRC Gentric Letter 82-33 establishes the latest guidance for demonstrating conpliance with Regulatory Guide 1.97 such that all current action on this issue is being taken in accordance with the Generic letter, Alabama Power Company has completed all applicable requiren:r.ts af this license condition and requests that it be formally closed by the 6 NRC.

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I tFA 24 '9211:CV SrA%CRf4 IOCLR4%RLEY PROJECT P.G l

ATTACHMENT U

(3) _ License Condition F.C.(21)(a)

Requireaant! The licensee Whall complete each of the following conditions to the satisf action of the NRC by the times 4 i n'di c at e d . Each of the following conditions sferences I the appropriate iters in Section 22.5, " Dated Requirements" in SER $upplement 5, NUREG-0117:

(a) Gufdance for the Evalu_at_i_on and Develooment of F rocedures f or _ Transients and Accidentt_;(l.C.1)

Prior to startup following the first refueling efter January 1,1,';;. complete the upgradie 9 of emergency procedures and associated operator training.

Response Alabama Power Company has made several submittels relating to license condition 2.C.(21)(a) and has referenced the Westinghouse Owners Group transmittal of Noveniber 30, 1981 which contains the latest available guidelines for energency operating procedures. The actions taken by ,

Alabama Power Company in assor,iation with the Wen inghouse <

Owners Group satisfy the applicable requirements (f '

license concition 2.C.(21)(a). Subsequent actico by the O

V NRC (i.e., issuance of Generic Letter 82-33) establishes revised guidance on u,mgrading energency operating procedures such that all current action on this issue is being taken in accordance with the Generic Letter.

Alabama Power Company has completed all applicable requirements of l'*ense condition 2.C.(21)(a) and requests that it be forma 11, closed by the NRC.

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h'-A 24 '92 11:06 SOUTFCW toJCLR4r4LTY FROXCT P.6 ATTACHMENT (4) License condition 2.C.(21)(b)  ;

Requi rerpent s (b) Reactor Coola_nt $ystem Vent 3 (11.D.1) f l

Submit a design description and operating procedures for reactor coolant system vents prior to Jul 1

, 1981 and complete installation prior to July 1982.

Response: Alabant Powe- Company letters dated June 25, 1981 and l December 25, 1 R 1 document completion of all installation i work associated with the reactor system vents. Operating procedures were submitted as part of the Westinghouse Owners Group letter dated November 30, 1981. Final ,

implementation of the reactor coolant system vent oper- i ating procedures will not be accomplished until NRC approvai is given for the design of the installed system. .

Alabama Power Company has completed all requirements of license condition 2.C.(21 (b) and requests that it be formally closed by the NR . ,

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tSei 24 '92 11:06 SCUTG I4JCLf14WLEY PROJECT P.7

] ATTACHMENT gge)

O (5) LicenseCondition2.C.(21)(c)(1)._(2)and(31 ,

Requirenent: (g) Inadequate Core Cooling instruments (!!.F.2)

For the proposed reactor vessel watar level instrument, (1) Provide detailed design irformation identified in Section 22.5 of SER Supplement 5, Reevirement A, Parts (1)(a), (3), (4), (7), (8) and (9) prior to July 1,1981.

(2) Provide results of tests on f arley Unit 1 for consideration in this f acility prior to July 1, 1981.

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' (3) Provide planned program to complete developmet t.

including any additional test data needed to l determine feasibility, prior to January 1,1982.

l Response: Alabama Power Coinpany letter dated June 29, 1981 documented compliance with license conditions s 2.C.(21)(g)(1), (2), and (1). Subsecuently, Alabana Power s Company letter dated August 3,1982 stated that the previously transmitted program plan was being terniinated based on a nutual agreement between the NRC and Alabama Power Company. The recently issued NRC Generic Letter 82-28 establishes the latest guidance on this subject such l that all current action is being taken in accordance with the Generic Letter, Alabama Power Company has completed all requirements of these license conditions and requests

that they be formally closed by the NRC.

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tWI 74 'e2 11 07 c(11TWRti tin.ReTARLEY FRCTCCT F.A ATTACilNENT (6) License Condition 2.C.(21)(h)(1)

Requirements (h) Commission Orders on Babcock & Wilcox Plants.

Subsequently Applied to all PWR Plants (II.K.2.)

Prior to January 1,1982, (1) Subnit a detailed analysis of the thermal eschanical conditions in the reactor vessel during recovery from small break LOCAs with an extended loss of all feedwater (ll.K.2.13).

Request: Alabama Power Company letters of January 14, 1981 ard December 22, 1981 documented the f act that license condition 2.C.(21)(h)(1) would be addressed as part of a Westinghouse Owners Group generic ef fort. The required analysis was submitted to the NRC by the Westinghouse Swners Group in a letter dated December 30, 1981. All subsequent action on this issue was agreed to by Alabama Power Company and the Westinghouse Owners Group in response to NUREG.0737, item 11.K.2.13. Alabama Power Company has completed all requirements of this license 6 condition and requests that it be formally closed by the NRC.

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in 2 92 site? SCUTWJ04 ttXLRSARLEY PROJECT p,9 ATTACHMENT 071331

, (7) License Condition 2.C.(21)(h)(2)

Requirement: (h) Corrmission Orders on _ Babcock & Wilcox Plants t Subsequently Appijec to all PWR Plants (II.K.2)

Prior to January 1, 1982, (2) Provide an analysis of the potential for voiding in the reactor coolant system during anticipated transient s (!!.K.2.17 ).

Response Alabama Power Company letter dated December 22, 1981 documented comp 11ence with license condition . .

2.C.(21)(h)(2) by referencing submittal of the required analysis attached to an April 20. 1981 letter from the westinghouse Owners Group. Alabama Powe Company has completed all requirements of this license condition and requests that it be formally closed by the NRC. c O

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W4i 24 '92 11:03 EdmCRM f 4JCLR40PE F%CJECT P.10 ATTACHMENT O (8) License condition 7.C.(21)(1)(2)(t) and (ii)

Requirement: (i) Final Recamendations of B80 lask Force (!!.K.3)

(2) With respect to tripping of reactor coolant pumps (RCPs) (11.K.3.5):

(1) Submit to the NRC for approval either (1) an evaluation which shows that sufficient time is available to the operator to manually trip the RCPs in the event of a small break LOCA, or (2) a description of design modifications required to provide for an automatic pump trip. This submittal is required within three conths af ter NRC determination of acceptability of the stra11 break LOCA nodel based on comparisons with LOFT test L3-6.

(ii) If required based on (1) above, completc plant nodification: to provide for automatic tripping of reactor ecolant pumps within 11 months af ter NRC determination of model acceptability, provided thera is en O appropriate outage during that time interval to r.omplete installation or during the first such scheduled outage occurring thereafter.

Request: Alabana Power Company letter dated December 22, 1981 documented compliance with license conditions 2.C.(21)(1)(2)(1) and (ii) by referencing submittal of the Westinghouse Owners Group evaluation in letters dated March 3. P, arch 23, and June 15, 1981. The conclut. ion was that automatic tripping of the RCPs is not required.

Alabana Power Comoany has comp 1tted all applicable requirements of these license conditions and requests that they be formally closed by the NRC.

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tm 24 '92 11:03 souteCRH ttcLR.fra.rY FROJECT re,11 t

- AliACHMINT gg (9) License Conditi.on 2.C(23(1)(4)(1) and (11)

Requirement 1 (1) Final _ Recommendations of B&O Tesk Force (*11.K.3)

(4) With respect-to a revised small break LOCA model, (1) Prior to January 1.1982, submit to the NRC a revised model to account for recent experimental data (!!.K.3.30).

(ii) Submit to the NRC the results of plant-specific calculations usin9 the NRC-approved revised model prior to January

1. 1983.

Response: Alabama Power Company letter of December 22, 1981 docuteented compliance with license conditions 2.C.(21)(1)(4)(1) and (ii) by r6ferencing the NRC approved small break LOCA model used in the licensing process for the Farley Nuclear Plant. Subsequently, NRC letter dated March 7,1982 recuested confirmation of a comreitment by Alabama Power Company to participate in the Westinghouse Owners Group effort to address NUREG-0737. Item !!.K.3.30 O. generically. This commitment was confirmed in Alabama Power Company letters of March 26,1982, June 4,1982 and 1 January 7. 1983. All current action on this issue is being taken in accordance with the January 7,1983 Alabama Power Company letter on NUREG-0737, item II.K.3.30. 1 Alabama Power Company has completed all requirements of license conditions 2.C.(21)(1)(4)(1) and (ii) and requests that they be formally closed by the NRC.

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