ML20053B755
| ML20053B755 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/24/1982 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR TAC-47007, TAC-47008, NUDOCS 8206010207 | |
| Download: ML20053B755 (11) | |
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Ars% Go q; a 303Q May 24, 1982 Georgia Power J. T. Beckham, Jr.
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. Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 PRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 CONTROL OF HEAVY LOADS Gentlemen:
In your letter of February 16, 1982 you requested that Georgia Power Company's (GPC) six-month report be revised to meet your December 22, 1980 request for information.
The intent of NUREG-0612, as interpeted by GPC, is the assurance that the risk associated with heavy load handling is as low as reasonably achievable.
This assurance can be achieved through a review of the controls -for such load handling operations, and the accomplishment of improvements determined to be necessary by that "eview.
We have performed a complete review of overhead handling systems at Plant Hatch, including the performance of conservative load drop analyses in those cases where the potential for a significant accident was determined to exist.
The results of those analyses were reported in our six and nine month submittals.
Table 1 (attached) summarizes our findings, and expands on our justification for the determination that no safety concern exists which has not been adequately addressed.
It is our conclusion, based on this conservative approach, that no further myiew of the design bases for load handling systems is required to meet the intent of NUREG-0612.
I.
Actions taken in response to NUREG-0612 As stated in our six-month
- report, a complete, systematic evaluation of overhead load handling systems at Plant Hatch Units 1 and 2 was performed.
The purpose of the evaluation was to identify those load handling systems from which a dropped load could impact i
the reactor ' vessel, spent fuel, or equioment required for safe shutdown or decay heat removal; and to determine reasonable actions to reduce the risk and consequences of such an accident.
Factors which affect this risk can be characterized as either " human" or
" equipment" factors.
With respect to " human" factors, several changes were found to be appropriate as a results of this evaluation.
1.
Safe load paths were defined per the guidelines of NUREG-0612, Section 5.1.l(1), where required.
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8206010 p07 i 3 g
.GeorgiaPowerd i
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Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 May 24, 1982 3
Page Two l
t i
i 2.
Procedures were developed and implemented per the guidelines of Section 5.1.l(2), where required.
3.
Operator training is being implemented per the guidelines of Section 5.1.1(3).
4.
Crane inspection, testing, and maintenance were begun in l
accordance with the guidelines of Section 5.1.1(6).
5.
Special attention was given to procedures, equipment, and personnel for the handling of heavy loads over the reactor core.
' \\ ["
Since historical data indicate that the majority of load handling accidents could have been avoided with improved operating and s
,N maintenance practices, (Ref:
NUREG-0612 Sections 4.1-4.3) emphasis has been placed on this area.
With respect to " equipment" factors, the follcwing actions were s
taken :
1.
Credit was taken for cranes which satisfied the single failure
.~
proof requirements of NUREG-0612, Section 5.1.6.
Because the design features of these cranes made the likelihood of a load drop extremely small, such an accident was not postulated.
2.
In limited cases credit was taken' for administrative controls imposed to prevent the movement of heavy loads over spent fuel or equipment required for safe shutdown or decay heat removal 4
(see Table 1 items 28, 30, and 34).
)
1 3.
Where cranes did not meet single failure proof criteria and administrative controls could not be, imposed, the dropping of.
the load was assumed and the, consequences of the drop analyzed.
In -all cases the consequences were shown to be j
acceptable for one of the following reasons (see Table-1):
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GeorgiaPower d Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 May 24, 1982 Page Three A.
Crane travel for the area / load combination is prohibited by electrical interlocks or mechanical stops.
B.
System redundancy and separation precludes loss of the capability of the particular system to perform its safety-related function following the load drop in the area.
C.
Site-specific considerations eliminate the need to consider the particular load / equipment combination.
D.
The likelihood of a handling system failure for this load is extremely small (i.e.,
Section 5.1.6 of NUREG-0612 satisfied).
E.
Analysis demonstrates that crane failure and load drop will not damage safety-related equipment.
II. JUSTIFICATION OF RESPONSE Georgia Power Company takes exception to the recommendations of NUREG-0612, sections 5.1.1 (4),
(5),
and (7) which address verification of design codes for cranes and lifting devices.
These guidelines, in most cases, were not in effect at the time of manufacture of the Plant Hatch lifting devices.
Our evaluation to determine the value of meeting these recommendations (section 5.1.1 (4), (5), and (7)) led us to conclude that no perceptible increase 4
in plant safety would result, and therefore, that the expenditure l
of manpower resources would not be justified.
Measures have l
already been taken to address the remaining recommendations of section 5.1.1 as previously discussed.
These measures, with the elimination of concerns regarding hazards previously discussed, are more than suitable alternatives to the "after-the-fact" design code verification. We feel that Georgia Power Company's approach meets I
GeorgiaPower A Director of Nuclear Reactor Regulation i
U. S. Nuclear Regulatory Commission Washington, D. C.
20555 May 24, 1982 Page Four the intent and achieves the objectives of NUREG-0612 as stated in section 5.1, and it is our position that no further action is required beyond those already taken or underway.
J.
T. Beckham, Jr. states that he is a Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.
GEORGIA POWER COMPANY By
^
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. T. Beckham, Jf.
Sworn o and subscribe before me this 24th day of May'tLarge 1982 g-Notary Public. Georgia. State a
/
/
[L My Commission Expires Sept. 20,1983 Notary Public WEB /mb Enclosure xc:
H. C. Nix i
R. F. Rogers, III J. P. O'Reilly (NRC-Region II)
TABLE 1 Justification of Exclusion from Item No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category 1.
H4P-1 HPCI Pump and Turbine Major maintenance would not be undertaken when B
Holst the system is required to be operational.
In audition, redundant systems, the RCIC or ADS Systems, could be used in the event of damage to HPCI components.
2.
HNP-1 RHR Pump and Core Spray The worst case drop analyzed would result in B
Pump Holst sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
3.
HNP-1 RHR Heat Exchanger Holst The worst case drop analyzed would result in B
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
4.
HNP-1 RHR Pump and Core Spray The worst case drop analyzed would result in B
Pump Holst sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
5.
HNP-1 RHR Heat Exchanger Hoist The worst case drop analyzed would result in B
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
6.
FNP-1 Recirc. Motor MG Set "A" Imposed lift height restrictions; Technical C,E Holst Specifications require plant shutdown when recirculation not available, therefore lifting would not occur while operatirg.
MAY24 1982
_ _ _.. _ ~. -. _ ~
TABLE 1 (Continued)
Justification of Exclusion from Item No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category 7.
HNP-1 Recire. Motor MG Set "B" Imposed lift height restrictions; Technical C,E Holst Specifications require plant shutdown when recirculation not available, therefore lifting would not occur while operating.
i
- 8. -
HNP-2 CRD Pump and Hatch Holst No essential equipment located in load path.
E 9.
HNP-2 RCIC Pump, Turbine and No essential equipment located in load path.
E Hatch Holst 10.
HNP-2 Core Spray Pump "A" Holst The worst case drop analyzed would result in B
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
'll.
HNP-2 RHR Pump "A" Holst The worst case drop analyzed would result in 8
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
12.
HNP-2 RHR Pump "C" Holst The worst case drop analyzed would result in B
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
13.
HNP-2 RHR Heat Exchanger "A" The worst case drop analyzed would result in B
Holst sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
-14.
HNP-2 Core Spray Pump "B" The worst case drop analyzed would result in B
Holst sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
MAY 2 41982
TABLE 1 (Continued)
Justification of Exclusion from Item No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category 15.
HNP-2 RHR Pump "D" Holst The worst case drop analyzeo would result in 8
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
16.
HNP-2 RHR Pump "B" Holst The worst case drop analyzed would result in 8
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
17.
HNP-2 RHR Heat Exchanger "B" The worst case drop analyzed would result in 8
Holst sufficient safety grade systems being 4
available to achieve and maintain safe shut-down conditions.
18.
HNP-2, HPCI Pump and Turbine Major maintenance would not be undertaken when 8
Holst the system is required to be operational.
In addition, redundant systems, the RCIC or ADS Systems, could be used in the event of damage to HPCI components.
19.
HNP-2, Recirc. Pump MG Set "A" Imposed lift height restrictions; Technical C,E Holst Specifications require plant shutdown when recirculation not available, therefore lifting would not occur while operating.
20.
HNP-2, Recire. Pump MG Set "B" Imposed lift height restrictions; Technical C,E Holst Specifications require plant shutdown when j
recirculation not available, therefore lifting would not occur while operatirg.
21.
HNP-2, Chiller Unit "A" Holst No impact on safe shutdown equipment.
E 22.
HNP-2, Chiller Unit "B" Holst No impact on safe shutdown equipment.
E MAY 2 41982
~
TABLE 1 (Continued)
Justification of Exclusion from Item No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category !
23.
Diesel Generator "1A" Holst The worst case drop analyzed would result in B
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
24.
Diesel Generator "lB" Hoist The worst case drop analyzed would' result in B
sufficient safety grade systems being available to achieve and maintain safe shut-dcwn conditions.
25.
Diesel Generator "1C" Holst The worst case drop analyzed would result in B
sufficient safety grade system <., being available to achieve and maintain safe shut-down conditions.
26.
Diesel Generator "2A" Holst The worst case drop analyzed would result in 8
sufficient safety grade systems being available to achieve and maintain safe shut-down conditions.
27.
Diesel Generator "2B" Holst The worst case drop analyzed would result in 8
sufficient safety grade systems being available to achieve and maintain safe shut-i down conditions.
28.
HNP-1, Turbine Building Over-The limited clearance between the top of C
' head Crane the control building and the turbine build-ing overhead crane will not permit trans-porting a load over the control building.
Movement of the Control Building Ventila-tion and Air Conditioning Equipment will be controlled by adherence to our estab-lished safe load path and an operational procedure MAY 2 41982
TABLE 1 (Continued)
Justification of Exclusion from Item No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category 29.
HNP-1 and 2 Water Intake Movement of plant equipment in this area C,E Structure Mobile Crane will require the use of a mobile crane, our evaluation of the plant equip-ment located in this area revealed that a load drop would have no impact on safe shutdown or decay heat removal due to suf-ficient physical separation complete with steel barriers from essential equipment and the use of redundant systems.
30.
HNP-2 Turbine Building Over-The limited clearance between the top of C
head Crane the control building and the turbine build-ing overhead crane will not permit trans-
. porting a load over the control building.
Movement of the Control Building Ventila-tion and Air Conditioning Equipment will be controlled by adherence to our estab-lished safe load path and an operational procedure.
31.
HNP-1 Reactor Building Over-HNP-1 Reactor Building Overhead Crane has 0
head Crane been modified to be single-failure proof.
Use of this cIane will be controlled by strict administrative procedures and will follow established safe load paths.
For further information, refer to Section 10.20.5 in the HNP-1 FSAR.
32.
HNP-1 Refueling Platform No impact on safe shutdown equipment. Used E
Monorail to handle fuel assemblies between the fuel pool and the reactor vessel.
33.
HNP-1 Spent Fuel Pool Jib No impact on safe shutdown equipment.
This-E Crane 0.5 ton capacity crane is used to assit fuel assembly movement in the spent fuel pool.
WAY 2 41982
9 TABLE 1 (Continued)
Justification of Exclusion from ltem No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category 34 H1P-2 Reactor Building Over-Use of this crane is procedurally restricted.
C,E bead Crane It is not single-failure proof.
It will not be used over any equipment required to reach and maintain cold shutdown. Drops of reactor internals required to be moved by this crane have been analyzed and determined to meet the evaluation criteria of Section 5.1.4 (2) of NUREG-0612.
35.
HNP-2 Refueling Platform No impact on safe shutdown equipment. Used E
Manorail to handle fuel assemblies between the fuel pool and the reactor vessel.
36.
HNP-2 Spent Fuel Pool Jib No impact on safe shutdown equipment.
This Crane 0.5 ton capacity crane is used to assist fuel assembly movement in the spent fuel pool.
37.
HNP-1 MSIV "A" Holst Plant will be shutdown prior to maintenance B,C,E in this area.
A load drop would not impact on essential equipment for safe shutdown or decay heat removal.
The redundant MSIV's will assure primary system integrity.
38.
HNP-1 MSIV "B" Holst Plant will be shutdown prior to maintenance in B,C,E this area.
A load drop would not impact on essential equipment for safe shutdown or decay heat removal.
The redundant MSIV's will assure primary system integrity.
39.
HNP-1 MSIV "C" Holst Plant will be shutdown prior to maintenance in B,C,E this area. A load drop would not impact on essential equipment for safe shutdown or decay beat removal. The redundant MSIV's will assure primary system integrity.
MAY 2 4 _1982
TABLE 1 (Continued)
Justification of Exclusion from Item No.
Name Paragraph 2.1.1, Enclosure (3)
Hazard Elimination Category' 40.
FNP-1 MSIV "D" Holst Plant will be shutdown prior to maintenance in B,C,E this area. A load drop would not impact on essential equipment for safe shutdown or i
The redundant MSIV's will assure primary system integrity.
41.
FNP-2 RWCU Regen. Hx Trolley Sufficient physical separation from load im-E pact to essential safety-related equipment.
42.
HNP-2 RWCU Non-regen. Hx Sufficient physical separation from load im-E Trolley pact to essential safety-related equipment.
43.
WP-2 Fuel Pool Cooling Hx Sufficient physical separation from load im-E Holst pact to essential safety-related equipment.
44.
W P-2 CRD Repair Area Sufficient physical separation from load im-E Monorail pact to essential safety-related equipment.
45.
HNP-1 CRD Repair Area Jib Sufficient physical separation from load im-E Crane Holst pact to essential safety-related equipment.
46.
HNP-2 MSIV Bridge Crane Plant will be shutdown prior to maintenance in B,C,E this area. A load drop would not impact on essential equipment for safe shutdown or de-cay heat removal.
The redundant MSIV's will assure primary system integrity.
2 i
MAY 2 41982
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