ML20101E712
| ML20101E712 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/18/1984 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-82-28, NUDOCS 8412260360 | |
| Download: ML20101E712 (6) | |
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- Alabama Power Company.
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2 Birmingham, Alabama 35291.
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- Telephone 205 783-6090 "D
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Senior Vice President.
-1 1riintriose Buiroing
-AlabamaPbwer?
d 2 December 18,:1984
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/ Docket:Nos. 50-348
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50-3647 J
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I Di rector, ' Nucl ear Reactor, Regul ati on U. S. Nuclear Regulatory Comission z
cWashington, D.C.
20555E Attention:Mr. D. G. Eisenhut:
Joseph M. Farley Nuclear Plant _ Units 1 and 2 n,;
. Inadequate Core Cooling Instrumentation' System
' Alabama Power Company has reviewed and hereby provides a response ito NRC letter dated November 30, 1984 entitled, "NUREG-0737 Item II.F.2,
, Inadequate Core Cooling ' Instrumentation - (Generic Letter 82-28) -
- Joseph M. Farley Nuclear Plant, Units 1~ and 2".
The major. conclusions 'of the November 30, 1984 letter.-are that' (1)
.the NRC "will require APCo-to complete the'insta11ation of an approved
.. Inventory Tracking. System (ITS) concept prior to startup after the
_ seventh refueling outage _ for Unit 1 and the fourth refueling outage for -
Uni.t 2" ~and (2) that the Alabama Power Company proposed "three-outage
-installation schedule is dominated by convenience and cost a
considerations and that [APCo has] failed to assign an appropriate safety priority to this requirement".
[
. respond to both of these NRC conclusions. ' Alabama Power Company takes
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~ The purpose of this letter and its ' Attachment is to formally
- strong exception to the NRC assertion that appropriate safety priority.
,has not been assigned to this-issue ~and that the proposed installation schedule is dominated by cost and convenience considerations. Alabama Power Company hereby requests a meeting with the NRC Staff and its Management to discuss the safety priority' assertion and to resolve the y details of_ the Inventory Tracking System installation schedule.
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Mr. D. G. Eisenhut December 18, 1984
.U.' S. Nuc ear. egu atory omm ss on Page 2 l
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i An itemization of Alabama Power Company and NRC letters documenting actions taken'to provide an ITS for the:Farley Nuclear Plant is provided in the Attachment to this letter. The major factors which have precipitated the present installation schedule are:
(1) The time invested by Alabama Power Company in perticipating in the non-invasive reactor vessel level system research and development effort, which contributed significantly to the indJstry's knowledge of reactor vessel level systems.
It is noted that'this effort was sanctioned by the NRC and was entered into by Alabama Power Company recognizing that the total cost of the research and development and long term
-qualification efforts would likely exceed the cost of a then commercially available system.
(2) The extensive period required for the NRC to finalize the requirements of an acceptable ITS (July 1979 to December 1982).
(3) The inadvisability of procuring equipment prior to NRC Staff approval, which may later be determined by the Staff to be either unnecessary or unacceptable (e.g., seismic SPDS equipment, non-invasive vessel level system). The NRC delayed 13 months in responding to Alabama Power Company's stated intention to select an ITS only after such a system had been operationally and technically proven. To the knowledge of Alabama Power Company, to this date no such system has been approved for operation by the NRC.
(4).The inadvisability of installing equipment in the reactor and control room which, in the judgement of Alabama Power Company, had unresolved technical and operations problems with potential safety implications (Alabama Power Company March 10, 1983 letter).
It is noted that these concerns have been or will be adequately resolved as documented in Alabama Power Company's letter of May 11, 1984.
It should be noted that a written justification for continued operation without an ITS until the Unit i eighth and Unit 2 fifth refueling outages was provided to the NRC Staff in letter dated March
-10, 1983. To the knowledge of Alabama Power Company, there has not been any quantitative analysis performed by the NRC Staff to justify the position that a safety issue exists which warrants extended plant shutdowns for the installation of an ITS in 1985 or 1986.
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i Mr.< D. ' G T Ei senhut - _
December 18, 1984
- U.LS. Nuclear Regulatory Comission Page 3 The material.provided in the Attachment and the reasons described above refute'the.NRC Staff conclusion that the Alabama Power Company-schedule ~ is " dominated by convenience and cost considerations" and
~ demonstrate that the proposed implementation schedule is realistic and pl ant-specific. Generic Letter 82-28 required the development of such a
- schedule based on plant-specific aspects and conditions.
Alabama Power Company efforts to obtain an ITS contradict the NRC
- Staff assertion that this requirement did not receive an appropriate
' safety priority.
Factors which reflect a high level of comitment and effort-to obtain an operationally sound ITS are:
)(1).. Alabama Power Company contributed substantially to the development phase of an ITS through its involvement in the non-invasive water level pilot project.
Significant funds, man-power and the use of the Farley facility were contributed in this early prototype effort.
(2) An exhaustive engineering study was performed to assess the commercially available systems before bids were issued.
p (3) An evaluation of an actual ITS installation was made which included a review of the design, installation and operational factors of.a level system in a facility similar to the Farley Nuclear Plant.
(4) Alabama Power Company aggressively pursued the procurement of an ITS once the technical, operational and safety i'
uncertainties had been addressed.
In conclusion, it is Alabama Power Company's position that ITS
. implementation schedules should be reviewed based on the level of effort expended, integrated schedules for completion of this and other
-licensing modifications and the overall management of licensing issues l
' by the utility. This position is consistent with Generic Letter 82-28 l
which states that schedules should be realistic and take into account l
the unique' aspects of each plant. Alabama Power Company believes that the points of this letter, the Attactuient and the letters referenced
~ therein clearly prove that efforts to obtain an ITS at the Farley
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- Nuclear Plant have been forthright and technically responsive, and that
'at no time have we compromised the safety priority of this matter.
Alabama Power Company, therefore, requests an expedited meeting to i
discuss the Farley ITS and its installation schedule.
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Mr. D'. G. ' Ei senhut December 18, 1984 U. S.; Nuclear' Regulatory Commission Page 4
'If there are any questions, please advise.
Yours very trul,
b R. P. Mcdonald RPM /CJS:ddb-D-Tech Spec II Attachment cc: Mr. L. B. Long SWORN TO AND SUBSCRIBED BEFORE ME Mr. G. F. Trowbridge Mr. J. P. O'Reilly THIS /A
- DAY OFSMg 1984 Mr. E. A. Reeves Mr. W. H. Bradford
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Notary P0tWIC My Connission Expires:
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,g ATTACHMENT" t
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,A LLetter Letter 1DatedI Sunnery-fJ uly -1979 :
NRC issued NUREG-0578 (TMI-2 Lessons Learned)-
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which included vessel level provisions. '
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02-09-81 J
. APCo provided the NRC with a detailed plan for -
' development, installation and testing of the Farley Nuclear Plant Units 1 and 2 prototype vessel level' system utilizing excore neutron detectors.
06-29-81 APCo provided the NRC with a list and schedule for completing the remaining activities associated with testing, qualification and completion of development for the prototype vessel level system.
08-03-82
'APCo determined, as stated in the EPRI Report NP-2354 dated April'1982, that the prototype systems did not meet the required performance standards of NUREG-0737. Item II.F.2.
APCo then initiated a review of commercially available vessel level systems to determine their compliance with NUREG-0737 provisions. APCo committed to submit a status of this review to the NRC by 02-01-83.
'12-10-82 NRC. issued Generic Letter 82-23 (Inadequate Core Cooling Instrumentation System).
02-01 APCo acknowledged receipt of NRC Generic Letter 82-28 and connitted to submit results'of the vessel level study by liarch 10, 1983, as requested by Generic Letter 82-28.
03-1043 APCo summarized results of the study which indicated that the commercially available systems for vessel level had potential problems affecting their design and installation. APCo connitted to select a design for a reactor vessel level system that was operationally proven following the completion of a post-implementation review and approval of operation by the NRC. APCo planned l
to integrate the installation of vessel level t
with Supplement 1 to NUREG-0737 activities.
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= 04-02-84' NRC letter responding to APCo's 03-10-83 l
submittal.
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O' et g Attachment
.Page 2' Letter letter
' Dated Summary 05-11-84 APCo comitted to install either the Combustion Engineering or Technology for Energy Corporation reactor vessel level system at Farley Nuclear Plant within three refueling outages for each unit.
Installation was scheduled to be completed during the Unit 18th R.O. (02-12-88) and the' Unit 2 5th R.O. (09-04-87). This schedule was integrated with the NUREG-0737 Supplement 1 activities to avoid impact on other ifcensing issues.
07-06-84 APCo provided plans to issue bids and select a reactor vessel level vendor. The implementation schedule of three refueling outages was described and a bar chart schedule provided. A justification for continued plant operation without a reactor vessel level system until 1988 was provided.
09-17-84 APCo informed the NRC that an unplanned outage at Unit 2 had precluded the completion of bid evaluation by the end of September 1984. APCo committed to select a reactor vessel level system in October 1984.
10-08-84 APCo provided details of the procurement, design and installation issues resulting from bid evaluations for the reactor vessel level system.
11-30-84 APCo stated that an ITS purchase award had been made for each unit.