ML20008G315
| ML20008G315 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/29/1981 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0313, RTR-NUREG-313, TASK-A-42, TASK-OR GL-81-04, GL-81-4, TAC-46662, TAC-46663, TAC-49156, NUDOCS 8107070306 | |
| Download: ML20008G315 (4) | |
Text
o Georg a Power Cornpany 333 Piedmont Avcque AManta. Gec'gta 30308 Telephone 404 526-7020 P.talng Address Post Glf ce Box 4545 gm At:aota. Georg a 30302 Georgia Power J. T. Beckham, Jr.
Vice Preacent and General Manager Nuc!ea Generation d) sk
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U. S. Nuclear Regulatory Commission
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Office of Nuclear Reactor Regulation
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Division of Licensing JUL 0 61981* e Washington, D. C.
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ATTENTION: Mr. Darrell G. Eisenhut, Director
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tRC DOCKETS 50-321, 50-366
/MI OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 NUREG-0313, REVISION 1 IMPLEMENTATION-RESPONSE Gentlemen:
Georgia Power Company hereby submits the following information in response to NRC Generic Letter 81-04 dated February 26, 1981, regarding the implementation of NtREG-0313, Revision 1,
" Technical Report On Material Selection and Processing Guidelines For BWR Coolant Pressure Boundary Piping".
Please be advised that Technical Specification changes will not be submitted for either unit for implementation of the NUREG, but, by this letter, Georgia Power Company commits to performing augmented inservice inspection on
" nonconforming, noncervice-sensitive" and
" nonconforming, service-sensitive" piping as discussed herein.
In addition, Technical Specification changes pertaining to leakage detection systems will nut be made as existing Technical Specifications for both units and the leakage detection systems meet the intent of NUREG-0313, Revision 1 and Regulatory Guide 1.45.
The Hatch units were built before issuance of NUREG-0313, and stainless steel piping and safe ends at that time were Type 304 material.
This material, including weld material, as defined in NUREG-0313, Revision 1 is considered as nonconfc ming.
Class 1 anonconforming, nonservice-sensitive" and " nonconforming, service-sensitive" piping and safe ends (as defined in NUREG-0313, Revision 1) found in each of the Hatch units are as follows:
Nonconforming, Nonservice-Sensitive, 22" Reactor Recirculation (Recirc) Mani'old 28" Reactor Recirculation (Recirc) Suction and Discharge 6" Reactor Water Cleanup (RWCU) Suction 8107070306 810629 D PDR ADOCK 05000321l, g\\
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-U.-S. Nclear Regulatory Commission 10ffice.of Nclear Reactor Regulation.
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- Page Two.L.
" June 29, 1981"
'Nonconforminai Service-Sensitive 14"- Reactor Recirculation-(Recirc) Bypass
- 12" Reactor. Recirculation (Recirc) Risers Recirc tInl' ti Nozzle. Thermal Sleeve Attachm'ent Welds e
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-20" Residual-Heat RemovalL(RM )-Suction.
24" Residual Heat Removal'(RM ) Return The 10" Core, Spray and 3" Control Rod Drive (CRD) hydraulic return piping would normally have ~ been identified as nonconforming, service-sensitive
' material;1 however, modifications have been. performed either -prior - to. or
.during commercial operation -and conforming materials -have.' been installed.
5 Therefore, ' those particular. lines are exempt from augmented inservice
~ inspection.- It. should - be noted that there; is not any Class 2 stainless steel ; on either unit under the jurisdiction of the inservice inspection program.g 11
. Georgia Power Company takes exception to the designating of Recirc Riser piping 'as being service-sensitive.
The NUREG itself indicates that there
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-has. not..been any :inpidence of. intergranular~ stress corrosion _. cracking
- (IGSCC) in domestic plants.- In-addition, by designating the Riser piping
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l accordingly, inspection ~ personnel would be faced with much higher radiation
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exposure in order to meet NUREG-0313, Revision 1 examination requirements.
1Therefore',. Georgia -Power Company will consider the Recirc Riser piping 'as having the same inspection requirements as 'nonservice-sensitive piping and
~ ill perform augmented inservice ' inspection on an 80-month frequency in w
accordance >with the requirements of Section IV.B.l.b of NUREG-0313, Rev.1.
- This positiva is-considered-justifiable since there has not been any
' incidence of IGSCC; of ? this particular. piping in domestic BWR's.
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- additior., radiation 'levelsm were approximately 2 R/hr. on several of the Recirc Riser ~ piping welds' on Hatch Unit 1 during the last outage and ALARA concepts must be. considered and adhered to.
If examination - of the. Riser piping during the80-month period reveals no incidence of IGSCC, the examination frequency thereafter shall revert to 120 months as prescribed in
- Section.XI of the ASME. Boiler and Pressure Vessel Code.
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U. S. Maclear Regulatory Commission Office of. Nuclear Reactor Regulation D
Washington, D. C.
20555~
Page Three Nune 29,'1981-l
. Augmented l inservice inspection will be performed.on both Hatch units for
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the nonconforming, nonservice-sensitive and ' nonconforming,1 service-sensitive 2 piping., Class.1 welds. will be : selected in accordance with NUREG-0313, Revision 11 Sections IV.B.l.b and IV.B.2.b for nonservice-sensitive and-
' service-sensitive piping,- respectively, except - that high stress' welds will Ibe id mtified from the unit stress report.
Hathh ?Unitj 1 service-sensitive -piping was fully. examined during the Inservice inspection' performed during the 1978 refueling outage per original commitment';to EC.
No indications of IGSCC were detected.. Examination 4
areas included.-4"'Recirc _ Bypass (capped),_ 3" CRD Hydraulic Return _ (capped),
20" RHR Suction,724";RHR' Return, and:10" Core Spray.
Core Spray pipinq and safe ends have subsequently been replaced with conforming material. The CRD
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~ Hydraulic Return was cut and-capped during the previous refueling outage and is of ' conforming.materialf also; 1The Recirc. Inlet Nozzle Thermal Sleeve attachment ' welds were not' examined at that time as they were not considered service-sensitive.
Georgia Power Company met its original commitment to NRC and after mo eL than three years.of operation found no indications of IGSCC r
and considers performing examinations during three successive refueling outages as. unnecessary.
The next: refueling outage for Unit 1, which is
. tentatively-scheduled for Spring 1982, will be considered the first of the three! 36-month. + ~12-month examinations. ' Examination areas will include 4" Recirc Bypass -(capped), Recirc Inlet Nozzle Thermal Sleeve attachment welds,
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20" RHR; Suctin, Jand : 24" R$ Return. - Georgia - Power Company commits to
. performing a $d ' examination of the 'Recirc Inlet Nozzle Thermal Sleeve attachment - welds, _ dependent upon radiation levels encountered, during -the
^ next refueling outage.
In case indications are found, the other 50% will be examined. 'In the event these 36-mont] + 12-month period examinations reveal no. unacceptable : indications for three sTJccessive-inspections, the frequency l
of examination ' will ' --revert to ~80-month periods.
This schedule for performing the ' examinations of the service-sensitive lines is considered L
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justified due to good inservice inspection.and operating histories.
- The. examination of the Unit 1 nonservice-sensitive lines, which : will
- include the Recirc Riser piping, will be examined on an 80-month frequency O
as required'by_the-NUREG.
Examinations on this frequency are considered to
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have started during. inservice inspection activities in March 1981 (during the _ refueling outage).~
In the event there are no indications, examination 1
ifrequency will: revert to 120 months as prescribed by Section XI of ASME
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Examination :of the Unit 2 service-sensitive lines will continue to be
. performed in accordance with commitments already made to' NRC to examine the
- lines. during' three successive refueling outages.
The examination schedule isl included in the' existing Unit 2 Long-Term : Inservice Examination Plan for l.
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GeorgiaPbwerd U..S. NtJclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.
20555 Page Four June 29, 1981 Class 1 Components.
The Recirc Inlet Nozzle Thermal Sleeve attachment welds will be added to those examinations to be performed.
It should be noted that Georgia Power Company will take credit for tha 100% examination of the attachment welds performed during January 1979 and commits to performing examinations on a representative sample of 50% of the attachment welds, dependent upon radiation levels, during the next two refueling outages.
If examinations of service-sensitive lines are free of IGSCC indications, the examination frequency will be extended to three 36-month + 12-month period examinations, and later to an 80-month period examinstion, as appropriate.
Unit 2 nonservice-sensitive line examinations, including the Recirc Riser
- piping, will be performed on an 80-month frequency.
These examinations shall be considered to have started at commerical coeration (i.e., September 1979) of the unit.
The examination frequency will revert to a 120-month frequency if the lines are free of IGSCC indications after the 80-month examination period.
With regard to specifying a replacement schedule for the nonconforming material as requested by NRC Generic Letter 81-04, Georgia Power Company cannot justify the indiscriminate replacement of piping that has not shown signs of IGSCC in the Hatch plant.
The inspection program described above should identify development of IGSCC in the systems involved.
Due to this and the high radiation exposure involved in the replacement of the piping, Georgia Power Company does not plan to replace piping that has not shown evidence of IGSCC at Plant Hatch.
In the event that repairs or replacement of nonconforming material is required, at such time the affected component will be replaced with conforming material and processed in accordance with Section III of N'JREG-0313, Revision 1.
If you have any questions in this regard, please contact this office.
Sincerely yours,
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J. T. Beckham, Jr.
Vice President and General Manager Nuclear Generation e/r t 00AE/mb xc:
M. Manry R. F. Rogers, III
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