ML20206F771

Submits Addl Info Re Performance of Sys Pressure Tests at Facility When Reactor Critical.Differential Costs Incurred While Performing Sys Pressure Tests Noncritical Encl

ML20206F771
Person / Time
Site:	Hatch
Issue date:	04/06/1987
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
SL-2284, NUDOCS 8704140357
Download: ML20206F771 (5)

Text

_ _ _ _ _ _ _ - _ _ _ _ _

Georg a Power Company 333 Pi edmont Avenue D

• Atlanta, Georgia 30308 Telephone 404 526-6526 Mainng Address; Post Office Box 4545 Attanta, Georgia 30302 h Georgia Power L T. Gucwe ' ** ' >#Nem ehfr< sy+m Manager Nuclear Safety and Licensing SL-2284 1279C 1

April 6, 1987 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDHIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REOUEST FOR ADDITIONAL INFORMATION RELATIVE TO SYSTEM PRESSURE TESTS Gentlemen:

In a meeting with members of the NRC staff held in Bethesda, Maryland, on April 1, 1987, Mr. James H. Sniezek (NRC) requested that Georgia Power Company (GPC) submit to the NRC additional information relative to the performance of system pressure tests at Plant Hatch when

the reactor is critical. The requests and the additional information are as follows:

1. Provide the differential costs incurred when performing the tests without achieving heatup by being critical.

} 2. Identify those areas which cannot be visually inspected.

The differential cost incurred when performing the test " cold" is approximately $900,000. A breakdown of the major contributors is enclosed.

The estimate does not include any additional costs relative to mid-cycle inspections (required by NRC Generic Letter 84-11), since it is l Our understanding that the NRC allows nuclear heating to achieve the l required temperatures. Hid-cycle inspections have been performed on 16 )

occasions since June 1984. '

When performing system leakage or hydrostatic tests at Plant Hatch, i all areas of the reactor coolant pressure boundary are accessible with the following exceptions:

0L l 8704140357 870406 1 PDR ADOCK 05000321 1% i p PDR l l

Georgia Powerkh U. S. Nuclear Regulatory Commission ATTN: Document Control Desk April 6, 1987 Page Two

1. Reactor Vessel Head Area - The reactor vessel head area is inspected by visual observation through a manhole cover.

However, the inspection is not complete, since only one side of the vessel head is observable. As discussed during the meeting, any vessel-to-head leakage would be detected via the flange seal leakage detection system.

2. Biological Shield Area - The interior of the Hatch Unit 1 biological shield is accessible during testing. Personnel do enter this area during pressure testing and conduct a visual inspection. Piping is not visible for inspection where it passes through the biological shield. However, leakage is this area would more than likely be noticed via observation on the inside and outside of the shield wall. Normally, the Hatch Unit 2 biological shield interior is not accessible during pressure testing. A manway is available; however, it is bolted shut and not opened for inspection. Leakage within this area would be noticeable by inspection of the drywell floor area. Also, piping which penetrates the shield wall is not accessible within the penetration.

During the course of the meeting, the question of personnel safety during the performance of visual inspections was discussed at length.

Therefore, we believe that the provision of additional information relative to this issue is appropriate. As stated in the meeting, GPC is extremely proud of its industrial safety record which extends to an excess of nine million manhours worked at Plant Hatch without the I occurrence of a lost-time accident. GPC's record stands as the "best" in l the nuclear industry and is a direct reflection upon the planning, 1 training, and caution taken at Plant Hatch when potentially hazardous work activities are performed. In preparation for and in performance of the ASME Code, Section XI-required visual inspections, the following precautions are taken as a minimum:

a. Prior to the actcal walkdowns, all personnel who are scheduled to participate in an inspection thoroughly rehearse the i activities in which they will be engaged. I

b. Prior to the actual inspection, the test engineer / coordinator ,

and the VT-2 qualified inspector who will accompany him to perform the inspections completely walkdown the areas which will be inspected.

c. Inspections are performed by teams of personnel with at least l two people on the team.

700775 I

GeorgiaPower d U. S. Nuclear Regulatory Commission ATTN: Document Control Desk April 6,1987 Page Three

d. All personnel receive safety and ALARA training prior to the inspection.

e. Protective clothing, including icepacks, is required for any area in which the temperature exceeds 120*F. Entry into any area in which the temperature exceeds 160*F is not allowed without the express approval of plant management.

f. Before inspection teams are allowed to enter the area to be inspected, radiological and temperature surveys are conducted.

Subsequent to the April meeting, GPC contacted other utilities to determine whether they performed visual inspections (other than ASME Code, Section XI-required VT-2 inspections) of the _ reactor coolant pressure boundary piping while at, or near, rated pressure and temperature. In response to our inquiry, most of the utilities contacted indicated that they do perform a visual inspection of the piping when either coming down from power or during power ascension. The inspections are, at least occasionally, performed when the reactor is critical.

He appreciate the attention that you have given this matter and hope that this additional information will enable you to resolve this issue.

Should you have any questions or concerns, please contact this office at any time.

Sincerely, 9 --

L. T. Gucwa

\

JDH/lc

]

Enclosures l 1279C

- 700775

Georgia Powerd U. S. Nuclear Regulatory Commission ATTN: Document Control Desk l April 6,1987 Page Four 1

i 4

c: Georaia Power Company U.S. Nuclear Regulatory Commission Mr. J. P. O'Reilly Dr. J. N. Grace, Regional Administrator

! Mr. J. T. Beckham, Jr. Mr. J. H. Sniezek, Deputy Executive d

Mr. H. C. Nix, Jr. Director for Operations G0-NORMS Mr. R. M. Bernero, Director - Division of Poiling Hater Reactor Licensing 1 Mr. D. R. Muller, Project Director -

BHR Project Directorate #2 Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch Mr. G. Rivenbark, Licensing Project Manager - Hatch I

I 4

i I l i

i i

4 1

H 1279C 700775

.- . ~ . _ - . . . _ _ _ _ _ . . - , . , _ . . - _ _ _ - _ , _ - . . . -

GeorgiaPower b ENCLOSURE NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDHIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 DIFFERENTIAL COSTS INCURRED HHILE PERFORMING SYSTEM PRESSURE TESTS NON CRITICAL Aporoximate Cost Average Replacement Power Cost $875,000 Miscellaneous (cost to run 34,000 I

recirculation pumps, procedures, i system lineup and restoration)

TOTAL $909,000 l RECURRING $899,000 NOTE: It is assumed that a 3-day critical path is added to the schedule.

4 l

i i

a l 1279C 04/06/87 !

7C3775 4