ML20028E193

Application to Amend License NPF-2,revising Tech Specs 3/4.6 Re Containment Sys,To Extend Cold Shutdown Period from 30 H to 96 H on one-time Basis.Class III Amend Fee Encl

ML20028E193
Person / Time
Site:	Farley
Issue date:	01/14/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20028E194	List: ML20028E193 ML20028E198
References
NUDOCS 8301210063
Download: ML20028E193 (6)

Text

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W Addmes

, Alabamt Power Company 600 North 18th Street Pcst Offica Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6081 F. L Cleyton, Jr.

%%;'OM*"' AlabamaPbwer the sot.fhern ektinC System Janua ry 14, 1983 Docket No. 50-348 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 1 Containment Integrity Technical Specification Change Request Gentlemen:

Unit 1 Technical Specification 4.6.1.2.d. requires Alabama Power Company to perform leak rate testing of electrical, piping and other containment penetrations to verify containment integrity. As a result of testing in preparation for the Unit I re'ueling outage, one electrical penetration dir not meet the test acceptance criteria. This condition required that Technical Specification 4.6.1.1.c. be met; however, the measured leakage was in excess of 0.60 L a such that the ACTION statement of Technical Specification 3.6.1.1. was invoked. This ACTION statement requires containment integrity be restored within one hour or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Due to the scheduled testing of reactor coolant system (RCS) pressure isolation valves, main steam safety valves and pressurizer safety valves during initial plant cooldown for the 4th refueling outage, proceeding to cold shutdown within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> could extend the refueling outage as decribed herein and result in increased occupational exposure. Therefore, Alabama Power Company requests a one-time extension of Technical Specification 3.6.1.1. LC0 cold shutdown period from 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

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Mr. S. A. Varga Janua ry 14, 1983 U. S. Nuclear Regulatory Commission Page 2 At approximately 3:00 p.m. (CST) on January -14,1983, one electrical penetration leaked in such a manner as to create a condition where the combined leakage rate exceeded 0.60 La. Unit I will accordingly be in Hot Standby by 10:00 p.m. (CST)

Janua ry 14, 1983. Since a refueling outage was planned to begin at midnight January 14, 1983, the requirement to achieve cold shutdown within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> creates a conflict with the presently scheduled refueling outage.

The scheduled plan for the Unit I refueling outage during initial shutdown for testing of the reactor coolant system (RCS) pressure isolation valves, main steam safety valves and pressurizer safety valves is greater than the 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> Technical Specification LC0 limit. This testing must be done while the RCS is pressurized to identify valves requiring repair such that repair activities can be accomp.ished during the refueling outage. The final valve test is then performed during critical path startup from the refueling outage as required by Technical Specification 4.4.7.3.1.

Therefore, if the initial valve testing is not done during shutdown, this testing would be required to be performed during critical path startup of the unit. Any valve problems discovered at that time would extend the refueling outage to allow RCS depressurization, RCS draindown, valve repair and valve retest and result in increased occupational exposure.

The extension of the LC0 from 30 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for the one-time change does not involve any appreciable increased risk to the health and safety of the public due to:

1. Containment electrical penetrations have two seals; one accessible to the inside containment, and one accessible j to the outside containment. The test method used is to

! pressurize between the two seals. The outside seal has no l measurable leakage; all leakage is through the inside seal into containment. Therefore, physical containment integrity exists because the outside seal has been found

! to have no measurable leakage when subject to a required test pressure of 48 psig.

2. Reduced potential of offsite radiological exposure.

3. Small probability of an accident during this interval.

4 The reactor is subcritical with all full length control i rods inserted.

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Mr. S. A. Varga Janua ry 14. 1983 U. S. Nuclear Regulatory Commission Page 3 Based on the above, Alabama Power Company respectfully requests that the LC0 cold shutdown period of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in Technical Specifications 3.6.1.1. be extended to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to allow sufficient time for completion of RCS pressure isolation valve testing. This request is made on the basis that the refueling outage could be extended without such a one-time change and the return to power operations delayed. A detailed safety evaluation for this change is included in Attachment 1 and the proposed revision to the Technical Specifications is included in Attachment 2.

Alabama Power Company's Plant Operations Review Committee has r<. viewed this proposed change to the Technical Specifications ar.d las determined that the change does not involve an unreviewed safety question as shown in the attached safety evaluation. The Nuclear Operations Review Board is scheduled to review this change at a future meeting.

This amendment is designated as Class III for Unit 1 in accordance with 10 CFR 170.22 requirements. Enclosed is a check for $4,000.00 to cover the total amount of fees required.

In accordance with 10 CFR 50.30 (c)(1)(i), three signed origials and forty (40) additional copies of the proposed changes are enclosed.

Yours very truly, u }

KF. L. Clayton, J r.

FLCJr/ JAR:mjh-D34 Attachments SWORN TO AND SUBSCRIBED BEFORE ME cc: Mr. R. A. Thomas THI S jg'23 D AY OFs lem-, ,1983

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Mr. G. F. Trowbridge Mr. J. P. O' Reilly

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Mr. E. A. Reeves '

Mr. W. H. Bradford ~ N o t a ry P u'b l i c My Commission Expires de l1. , S-

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Attachment 1 Safety Evaluation for Proposed One-Time Change to FNP-1 Technical Specification 3.6.1.1

1. Background During Type B testing of containment electrical penetrations on January 14, 1983, in preparation for the 4th ref ueling outage, one electrical penetration failed to pass the test requirements of Technical Specifications 4.6.1.2.d. This condition required that Technical Specification 4.6.1.1.c. be met; however, the measured leakage was in excess of 0.60 La such that the ACTION statement of Technical Specification 3.6.1.1 was invoked. This ACTION statement requires containment integrity be restored within one hour or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Due to the scheduled testing of reactor coolant system (RCS) pressure isolation valves, main steam safety valves and pressurizer safety valves during initial plant cooldown for the 4th refueling outage, proceeding to Cold Shutdown within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> could extend the refueling outage and result in increased occupational exposure.

II. ,Raference Technical Specification 3/4.6.1 III. Bases The scheduled plan for the Unit I refueling outage during initial shutdown for testing of the reactor coolant system l

(RCS) pressure isolation valves, main steam safety valves and l

pressurizer safety valves is greater than the 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> Technical l Specification LC0 limit. This testing must be done while the RCS is pressurized to identify valves requiring repair such I

that repair activities can be accomplished during the refueling outage. The final valve test is then performed during critical path startup from the refueling outage as required by Technical j Speci fication 4.4.7.3.1. Therefore, if the initial valve testing is not done during shutdown, this testing would be l required to be performed during critical path startup of the unit. Any valve problems discovered at that time would extend the refueling outage to allow RCS depressurization, RCS l draindown, valve repair and valve retest and result in increased occupational exposure.

i

Attachment 1 Page 2 The extension of the LC0 from 30 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for the one-time change does not involve any appreciable increased risk to the health and safety'of the public due to:

1. Containment electrical penetrations have two seals; one accessible to the inside containment, and one accessible to the outside containment.

The test method used is to pressurize between the two seals. The outside seal has no measurable leakage; all leakage is through the inside seal into containment. Therefore, physical containment integrity exists because the outside seal has been found to have no measurable leakage when subject to a required test pressure of 48 psig.

2. Reduced potential of offsite radiological exposure.

3. Small probability of an a:cident during this interval.

4 The reactor is subcritical with ali full length control rods inserted.

Based on the above, Alabama Power Company respectfully requests that the LC0 cold shutdown period of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in Technical Specification 3.6.1.1. be extended to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> ti allow sufficient time for completion of RCS pressure isolation valve testing. This request is made on the basis that the refueling outage could be extended without such a one-time change and the return to power operations delayed.

IV. Conclusion The proposed change to Technical Specification 3.6.1.1. does not involve an unrevieed safety question as defined by 10CFR50.59.

Attachment 2 Proposed Change to Technical Specification Page 3/4 6-1, Section 3/4.6.1.1