ML19309G772

Submits Addl Info Re Inservice Insp & Testing,In Response to NUREG-0411 Requirements.All Inservice Examinations Will Be Performed Per 1974 ASME Code XI W/Addenda Through 1975. Requests Relief from Hydrostatic Test Temp & Test Duration

ML19309G772
Person / Time
Site:	Hatch
Issue date:	05/01/1980
From:	Widner W GEORGIA POWER CO.
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0411, RTR-NUREG-411 TAC-07811, TAC-08019, TAC-48084, TAC-48085, TAC-7811, TAC-8019, NUDOCS 8005070548
Download: ML19309G772 (3)

Text

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230 Peacntrae Strut Posr Office Box 4545 Anan:a. Georia 30302 feepnone 404 522 6060 b

Georgia Power Power Generation Department tM coat,ern entic sprem May 1, 1980 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 NRC DOCKET 50-366 OPELATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 INSERVICE INSPECTION INFORMATION SUBMITTAL AND RELIEF REQUEST Gentlemen:

Georgia Power Company hereby submits additional information regarding inservice inspection and inservice testing pursuant to Sections 5.2.10 and 5.2.11 of NUREG-0411, " Safety Evaluation Report" for Edwin I. Hatch Unit 2 Final Safety Analysis Report (FSAR). The inservice inspection and inservice testing plans were submitted with the FSAR.

In accordance with 10 CFR 50 requirements, the initial inservice examinations conducted during the first 40 months must comply with the edition and addenda of the ASME Section XI Code in effect no more than six months prior to commercial operation.

Sections 5.2.10 and 5.2.11 of the subject NUREG require that the licensee notify USNRC of the edition and addenda of the Section XI Code to which the examinations will comply. Please be advised that Plant Hatch Unit 2 vent into commerical operation on September 5, 1979; therefore, all exami-nations will be performed in accordance with the 1974 ASME Section XI Code with Addenda through Summer 1975.

Several problems, particularly in the area of hydrostatic testing, have arisen due to the use of the 1974 edition of ASME Section XI Code with Addenda through Summer 1975.

It is necessary that we request relief from the hydrostatic test temperature and test duration to which that particular edition and addenda of the code specifies.

The 1974 edition of the code specifies that hydrostatic testing for Class 1, 2, and 3 piping and components be performed at 100 F.

It is not possible for the licensee to meet that particular temperature requirement for the majority of the hydrostatic tests. There are several tests, however, which can be conducted at the required test temperature and are as follows:

Class 1 - 2B21-PT-1

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Class 2 and 3 - 2C41-PT-1, 2C41-PT-2.

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GeorgiaPower A Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission May 1, 1980 Page Two The reasons the above-referenced tests can be performed at 100 F are because they are either the nuclear boiler system (2B21) where heat is already being generated or standby liquid control system (2C41) whereas some of its piping is heat traced due to the sodium pentaborate solution temperature requirements.

It is necessary that all remaining Class 1, 2, and 3 hydrostatic tests be conducted at 1 700F. The piping contract for Plant Hatch Unit 2 originally specified that hydrostatic testing be performed at around 700F, plus nil ductility factor. This factor has been determined to be negative numbers and should have no bearing on the desired 1 700F hydrostatic test temperature.

In order to perform hydrostatic testing at the ASME-required temperature, it would be necessary to temporarily and/or permanently heat trace piping, not to mention extensive piping insulation removal and/or modifications to accommodate testing at the required 100 F.

Testing at 1000F would prove to be an undue hardship. Change to the lower temperature is justified and should be allowed by 10 CFR 50.55a.g.5.iv which allows changes in the in-service examination plan where hardship in testing exists. Please be advised that we are currently performing hydrostatic testing at > 700F at Plant Hatch Units 1 and 2 af ter ccusulting with the Hatch NRC project manager. We will continue to test at > 70 F in lieu of the ASME-specified temperature of 1000F for all hydrostatic testing onif where the 1000F temperature requirement cannot be met.

One additional problem exists with inservice inspection hydrostatic testing. The 1974 edition of the Section XI Code does not differentiate between test duration for insulated /non-insulated systems or components.

Currently, test pressure and temperature must be held for four (4) hours prior to performance of examination. All later addenda (e.g., winter, 1975) and codes (particularly the recently approved 1977 Section XI Code) differentiate between insulated /non-insulated piping for test duration. It is the licensee's intention to continue testing in accordance with the 1974 edition of the code (except for desired test temperature change as discussed above); however, we wish to request that hydrostatic testing duration be changed to reflect different test durations for insulated /non-insulated piping in accordance with the later addenda and codes. The desired change would be as follows:

For insulated systems, hold for four (4) hours after attaining the test pressure and temperature conditions prior to system walk-down examination, and ten (10) minutes for non-insulated systems or components.

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Georgia Power A Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission May 1, 1980 Page Three In addition to our declaration of the applicable code edition and addenda to which the inservice examination plans will conform, we request that you review the above-desired changes regarding hydrostatic test tem-perature and test duration for inservice inspection hydrostatic testing.

Please consider the hydrostatic test changes during your review of the long-term examinurion plan previously submitted to you for which we are awaiting your review and approval. Inservice examination activities for the first 40-month period of plant commercial operation have already begun during our recent (3/80) maintenance / surveillance outage.

If you have any questions or wish further discussion, please contact my office.

Sincerely yours, W. A. Widner Vice President and General Manager Nuclear Generation JAE/mb xc: Ruble A. Thomas George F. Trowbridge, Esquire R. F. Rogers, III J. T. Beckham, Jr.

M. Manry L. T. Gucwa J. R. Jordan C. V. Syx M. Belford R. A. Glasby C. L. Coggin l

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