ML18065A619

Comments of GL 95-07,in Response to NRC Request for Info on Estimated Time for Collecting Info on Issue of Power Operated Gate Valves & Susceptibility to Pressure Locking/ Thermal Binding

ML18065A619
Person / Time
Site:	Palisades
Issue date:	04/03/1996
From:	Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-95-07, GL-95-7, NUDOCS 9604110181
Download: ML18065A619 (2)

Text

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POWERiNii llAICHlliAN"S PROlillESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 3, 1996 Information and Records Management Branch (T-6F33)

U S Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

COMMENTS ON GL 95-07 BURDEN ESTIMATE Palisades recently completed the review and evaluation of power operated gate valves and their susceptibilify to pressure locking I thermal binding (PLTB) in response to NRC Generic Letter 95-07. Generic Letter 95-07 also included a public reporting burden estimate for information collected to respond to this issue. The estimated time was expected to be 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> per response. The NRC requested voluntary information on this estimate and other aspects of the response.

The PLTB Project T earn at Palisades spent considerably more time in the collection and evaluation of this issue than was estimated by the NRC. The following responds to the NRC request for information:

1. We used approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> to perform the requested inspections, immediate corrective actiqns, and associated ,testing. This cost is estimated at

$2,500.

2. We used contractor support for 850 hours0.00984 days <br />0.236 hours <br />0.00141 weeks <br />3.23425e-4 months <br /> to prepare the requested reports, engineering analyses and project documentation. Additionally, the technical direction and review performed directly by Palisades staff on this issue totaled approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />. The total cost for this portion of the activity is estimated at $65,500.

3. There were no associated short term costs incurred as a result of the inspection findings.

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4. We estimate a total cost of $35,000 to implement the long term corrective

. actions. This includes the modifications required to eliminate the potential for pressure locking.

The resulting total burden* incurred to comply with the GL 95-07 requirements was 1050 hours0.0122 days <br />0.292 hours <br />0.00174 weeks <br />3.99525e-4 months <br /> which cost $68,000. The expected future implementation costs are $35,000 for a total cost of $103,000.

The evaluation did identify valves which are potentially susceptible to PLTB. Corrective actions are scheduled to ensure this common cause failure will not occur. We recognize that the corrective actions will significantly enhance the safety and reliability of power operated gate valves. Howeve_r the NRC estimate for the resources needed to complete this* effort was very low.

Richard W Smedley Manager, Licensing CC Desk Officer, Office of Information and Regulatory Affairs Project Manager, NRR, USNRC