ML20206N985
| ML20206N985 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/08/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-85-003, IEB-85-3, SL-2211, NUDOCS 8704210069 | |
| Download: ML20206N985 (4) | |
Text
Georgia Fbwer Company 333 Piedmont Avenue Attanta Georgia 30308 Tal: phone 404 526-6526 Mailing Address:
Fbst Office Box 4545 Atlanta, Georgia 30302 Georgia Power &
L. T. Gucwa the sautnern etctnc system Manager Nuclear Safety and Licensing A
SL-2211 1244C April 8,1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 NRC DOCKETS 50-321 OPERATING LICENSES DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 IMPLEMENTATION SCHEDULE IE BULLETIN 85-03 Gentlemen:
Georgia Power Company (GPC) submitted a supplemental I.E. Bulletin (IEB) 85-03 response to the Nuclear Regulatory Connission (NRC) on March 12, 1987.
That response transmitted revisions to some of the enclosures contained in a previous submittal, clarified the implementation schedule, and addressed the method GPC would use to satisfy the IEB 85-03 requirements.
GPC has worked closely with the Boiling Water Reactor Owners Group on the subject Bulletin and has held several discussions on implementation with the NRC staff.
i Since the issuance of the supplemental response, GPC has been carefully reviewing the implementation aspects of the Balletin for the upcoming outage on Plant Hatch Unit 1 (Docket Number 50-321).
GPC initially scheduled implementation of actions (to satisfy the Bulletin requirements) to be taken during the refueling outage scheduled for April, 1987.
Since the time of the supplemental response, GPC has further examined actions necessary to fulfill the Bulletin requirements and has determined a need for deferral until the next refueling outage, which is scheduled for Fall,1988.
This letter presents the rationale for the implementation schedule extension.
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T Georgia Power d U. S. Nuclear Regulatory Commission April 8,1987 -
Page Two GPC has recognized that actions identified in IEB 85-03 constitute a continuing program to monitor and maintain motor operated valve operability. The current method of performing the determination of valve operability relies mostly on the use of signature analysis equipment.
This equipment is installed on a valve _and an electrical " signature" of valve operation is developed for the valve.
The interpretation of this signature determines the condition and operability of the valve.
Additionally, this signature can be used in future evaluations of the valve condition and operability since the signature can be considered as a " baseline" signature.
By comparing signatures taken in the future to the baseline signature, a determination of the relative condition and operability of the valve can be made.
I The Motor Operated Valve (MOV) diagnostic equipment which is currently available requires that transducers be mounted on the operator to perform the initial baseline testing.
This instrumentation set up will require personnel to operate in close proximity to existing radiation fields on some plant valves.
GPC has been successful in the past in reducing worker radiation exposure and it is GPC's continuing goal, to maintain worker radiation exposure ALARA ( As Low As Reasonably Achievable).
M0V testing vendors have also recognized the need to implement ALARA considerations and are in the process of developing a simplified method to evaluate valve performance.
The simplified method would involve the use of Motor Control Center (MCC) monitoring equipment.
These MCC readings would be correlated with signature tracings developed when the valve was accessible, to determine the status of the valve.
1 Current MOV testing vendors have not yet developed this MCC monitoring equipment.
GPC understands, based on conversations with these vendors, that MCC monitoring equipment should be available for commercial use sometime in the second or third quarter of 1987.
These time frames will not support the current Unit 1 outage schedule.
Since neither of the two primary MOV testing vendors have MCC monitoring equipment at the present time, GPC believes that when they do have this equipment available for commercial use, there will be no way to correlate the previously determined valve signature with the MCC readings.
This means that any work done to determine signatures for any valves during the April,1987 outage, would have to be redone (when the MCC testers are available).
GPC believes this would not be consistent with good ALARA t
radiological exposure management.
1 1244C roorts
l Georgia PowerA U. S. Nuclear Regulatory Commission April 8,1987 Page Three Additionally, until recently,- only one MOV testing vendor had-equipment available to perform in place testing of limitorque operators.
This equipment, while satisfactory, leaves a great deal to be desired with regards to reliability, ease. of operation, and overall testing-efficiency.
New vendor equipment-is being released which appears to offer significant economic and operational advantages.- The new equipment is simpler to operate, requires less set up time, provides more useable data, and is much more ' adaptable to. production. work in an operating nuclear plant.
It is anticipated that these equipment characteristics will substantially reduce personnel exposure levels associated with the -
implementation of the Bulletin requirements, and will more closely adhere to overall GPC ALARA exposure goals.
GPC plans to procure the equipment,-
+
develop new testing procedures, and properly train personnel in the use-of the equipment.
The current outage schedule does not provide sufficient time for all of these activities to be performed before the April, 1987 outage.
GPC estimates that substantial person-rem savings could be realized by use of the new equipment. Radiation fields in excess of 100 mrem per hour are not uncommon when working on MOVs, and worker exposure time could be reduced by two to four hours per valve.
Additionally, GPC believes that the current in place MOV valve switch settings are adequate to permit continued operation without compromising plant operational performance.
This conclusion is reached based on the satisfactory operational performance of the systems under normal operational conditions (normal operations and surveillances) as well as transient conditions (scrams).
Were the switch settings on the valves in any condition other than conservative, it is believed that 'this deficiency would have been detected during an operational transient.
i The deferment of the Unit 1 testing will allow for more training to be performed.
This training will be performed using plant personnel to ensure that a proficient, stable nucleus of trained personnel are available - to perform the required M0V testing.
The valve' testing personnel will be using the type of equipment that will -be used to perfonn the actual Bulletin MOV testing.
The use of this equipment for the training will increase personnel proficiency and familiarity with the set up process.
1244C l
700775
2 Georgia Power A i
U. S. Nuclear Regulatory Commission April 8,1987 Page Four i
The training for the plant personnel will include training on;some J
accessible plant valves.
While these valves may' be -in the Balance of I
Plant (B0P) systems and not covered by the current Bulletin requirements, j
the training on actual in plant valves will add realism to the training without necessarily adding to the personnel radiation exposure.. The training on actual valves will minimize the testing team's set up time and minimize the potential for radiation exposure once the team starts l
testing the Bulletin valves in radiation areas.
The training program will be used as the basis for performing the required Bulletin testing on -
the Unit 2 valves when these are tested in the upcoming Unit 2 refueling "i
- outage, j
In light of the potential, substantial savings in personnel exposure, and the enhancements resulting from a detailed, realistic training y
- program, GPC believes that a delay in the Plant Hatch Unit 1 implementation until the 1988 refueling outage is justified.
This defennent will allow for a more thorough and' complete implementation of
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the Bulletin requirements, combined with lower personnel radiation exposure. This will more fully implement GPC's commitment to maintaining personnel exposure ALARA.
If you have any questions in this regard, please contact this office at any time.
Sir cerely, i
NQ=
L. T. Gucwa 1
l LGB/lc t
c: Geors ia Power Company U. S. Nuclear Regulatory Commission i
Mr. s. P. O'Reilly Dr. J. N. Grace, Regional Administrator i
Mr. J. T. Beckham, Jr.
Mr. P. Holmes-Ray, Senior Resident Mr. H. C. Ni x, Jr.
Inspector - Hatch 4
GO-NORMS Mr. G. Rivenbark, Licensing Project Manager - Hatch 1244C r.,,c
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