ML20097D991

Requests Extension Until 851130 of Equipment Qualification Program Deadline,Per 10CFR50.49(g),due to Delays in Extensive Equipment Replacement Effort.Response Requested So Final Planning for Upcoming Outage Can Proceed

ML20097D991
Person / Time
Site:	Hatch
Issue date:	09/11/1984
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-84-491, TAC-55488, TAC-55489, NUDOCS 8409180068
Download: ML20097D991 (5)

Text

Georga Pcwer Company 333 P:edmont Avenue Atlanta, Georga 30308 s

Telephone 404 526-6526 Maeg A&jress-Post O!Lce Bcx 4545 At:anta. Georga 30302 Georgia Power L T. Gucwa n,, y 9 7,g g pc.

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Manager Naciear Engreenrg and Ch;et Nucear Engneer NED-84-491 September 11, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Cattnission Washington, D. C.

20555 NRC DOCKET 50-321 OPEPATING LICENSE DPR-57 EDNIN I. HATCH NUCLEAR PLANT UNIT 1 ECUIIEENT QUALIFICATION PROGRIM DEADLINE EXTENSION RECUEST Gentimen:

Paragraph (g) of 10 CFR 50.49 rquires that envirorrnental qualification of electrical equipnent defined by paragraph (b) of that regulation, be cmpleted by the end of the second refueling outage after March 31, 1982 or by March 31, 1985, whichever is earlier.

The above-described outage for Plant Hatch Unit 1 is currently scheduled to begin by October 1,1984 and last between eight cad ten weeks.

Georgia Power Cmpany (GIC) has determined that the large scale modification and/or replacment of quipnent needed to fully meet 10 CER 50.49 will not be fully cmpleted at the end of that upcming outage; therefore a request for extension of the qualification deadline is necessitated.

GPC has abarked on an abitious and extensive progrm in an attspt to meet all of the stated and implied rquirenents of the equipnent qualification rule.

In many cases GPC has pursued replacenent of quipnent rather than relying on marginally-acceptable engineering analyses to prove that necessary quipnent would perform its intended function during an accident.

This effort har been both expensive and time-consuming, and has placed a heavy burden on the skilled manpower available at Plant Hatch, due to the large nmber of quipuent itens which are being replaced.

'Ihe manhours which will be required to canplete the Hatch-1 progran will not be available during the upcaning outage as scheduled, due to its short length and also due to work which must be canpleted to meet other regulations and carmitments.

Since the vast majority of the quipnent qualification work involves renovire critical systens frm service, it can only be canpleted while the plant is shut down.

8409100068 840911

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PDR ADOCK 05000321 P

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' Georgia Power d Director of Nuclear Reactor Regulation Attention:- Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Septenber 'll,1984 Page ho GPC has just empleted a 235 day outage on Hatch-2, which in addition to refueling, included replacenent - of the recirculation systen piping and extensive equipnent modifications and replacanent for the equipnent

. qualification progran.

Experience gained during that outage leads GPC to conclude that such a. massive amount of work can only be performed under conditions which foster high levels of activity control and coordination if personnel and plant safety are to be assured.

The plant maintenance and modification. activities scheduled for the upcoming Unit 1 outage, which follows closely the long and arduous Unit 2 outage, present undue deaands on personnel resources.

GPC has thus determined that overall plant safety would be enhanced by the rescheduling of a nmber of planned modifications until a later outage.

GEC has previously-requested qualification deadline extensions for certain Hatch 1 equipment itens by letters dated July 6,17, and 19, 1984

-(NED-84-369, 383, and 391, respectively).

It ha been determined that certain additional itens cannot be qualified prior to the end of the upcming. outage.

% erefore, GPC requests that a qualification deadline extension to.Novenber 30, 1985 be granted, under the provisions of 10 CFR 50.49 (g), for the existing Hatch 1 squipnent itens listed in the ' enclosure to this letter.

We extensive equipnent replacanent effort which GPC has undertaken has been : fraught with the types of delays and other problens which plague the

-nuclear grade equipment procurenent process. Many delays have resulted fre qualification testing of both existing and new types of equipnent, as vendors have attenpted -to develop methods for meeting the latest requirements. Testing of a few itens is still not fully empleted.

GPC believes that the additional confidence in the ability of plant systens to protect the public health and safety, which should result frm the cmpletion of the Hatch-1 qualification progran, outweighs the problens which have occurred during implenentation.

We have determined that the

' delay in ~cmpletion of the progran will enhance overall plant safety by improving. managenent control of outage activities. 'Furthermore, GIC has sutnitted Justifications for Continued Operation (JCDs), for all sluipnent itens for which an extension is requested, by letter dated July 24, 1984 (NED-84-395).

I GeorgiaPower A Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Septenber 11, 1984 Page Three Your earliest attention to this request is solicited so that final planning for the upcming Unit 1 outage can proceed.

If you have questions regarding this request, please contact this office.

Yours very truly,

/,7~ 6 c =

L. T. Gucwa CBS irb

/

Enclosure xc:

J. T. Beckhar., Jr.

H. C. Nix, Jr.

J. P. O'Reilly (NRC-Region II)

Senior Resident Inspector

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ENCIOSURE

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(page 1 of 2)

NRC DOCKET 50-321 OPERATING LICENSE DPR-57 EIMIN I HA'ICH NUCLEAR PIANT UNIT 1 EQUIPMENI' QUALIFICATION PROGRAM DEADLINE EXTENSION REQUEST GPC recpests that the 10 CFR 50.49(g) g2alification deadline be extended to November 30, 1985, for the followirg ecpipment items:

Plant MPL M1mber Etglipment Description B21-M19 Motorized Valte Operator B31-F031A,B Motorized Valve Operator Ell-F004D Motorized Valve Operator Ell-F008 m torized Valve Operator Ell-F009 m torized Valve Operator Ell-W 21A,B Motorized Valve Operator Ell-W 22.

m torized Valve Operator Ell-F028A,B Motorized Valve Operator Ell-W 75A mtorized Valse Operator E21-F004A,B m torized Valve Operator E21-ET)05A,B m torized Valve Operator E41-F001 Motorized Valve Operator E41-E003 Motorized Valve Operator E41-F006 '

Motorized Valve Operator E41-F007 m torized Valve Operator E41-F0ll m torized Valve Operator E41-E012 m torized Valve Operator E41-E041 Motorized Valve Operator E41-N074 Limit Switch 1

E51-F008 Motorized Valve Operator E51-F031 m torized Valve Operator G31-E001 m torized Valve Operator

.G31-F004 m torized Valve Operator PS2-F875 Motorized valv? Operator P52-N021 Presaire Switch September 11, 1984

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DCIDSURE (page 2 of 2)

NRC DOCKET 50-321 OPERATING LICENSE DPR-57 i

EIMIN I. HA'ICH NUCLEAR PIANP UNIT 1 EQUIINENP QUALIFICATION PROGRAM DEADLINE EXTENSION REQUEST Plant MPL M1mber Ecpipment Description T41-N019A,B Rnperattire Switch T41-N020A,B Tenperature Switch T41-N021A,B Tenperature Switch T46-N005B,C Differential Presm re Transmitter T47-N003 Tenperature Element T47-N009 Tenperature Element T48-Fil2A,B Hydrattlic Valve Operator T48-K001 Power alpply T48-K0llA,B Power Slipply T48-N001 Presm re Transmitter T48-N009A,B,C,D Tenperature Elsnent T48-N014A,B Flow Transmitter T48-N021A,B Differential Presmre Transmitter T48-N210 Differential Presm re Switch T48-N211 Differential Presm re Switch H1-16 PVC Jacketed Cable J2-03 PVC Jacketed Cable J2-04 PVC Jacketed Cable M5-20 PVC Jacketed Cable N1-04 PVC Jacketed Cable N3-03 PVC Jacketed Cable N3-04 PVC Jacketed Cable September 11, 1984

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