ML20009E005

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Submits Addl Response to NRC 810212 Ltr Re Violations Noted in IE Insp Repts 50-321/80-48 & 50-366/80-48.Corrective Actions:Plant Procedure Rewritten to Differentiate Between Changes Affecting Safety & Changes Not Affecting Safety
ML20009E005
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 06/05/1981
From: Beckham J
GEORGIA POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20009D994 List:
References
NUDOCS 8107240574
Download: ML20009E005 (2)


Text

1 Georgia Power Company .

w 333 P,eament Avenue .

gp At!arta. Geo gta 30308 Teiepnone 404 526 6526 Ma ang Accress Pos: onice Box 4545 Aranta. ceorg;a scac2 June 5, 1981 GeorgiaPower Power Generation Department United States Nuclear Regulatory Commission Office of Inspection and Enforcement REFEREtCE:

Region II - Suite 3100 RII: CEM 101 Marietta Street, NW 50-321/80-48 Atlanta, Georgia 30303 50-366/80-48 ATTENTION: Mr. James P. O'Reilly Gentlemen:

In accordance with our May 22, 1981, conversation with Mr. Lenahan of your staff, we submit the following additional response to Inspection Reports 50-321/80-48 and 50-366/80-48:

For the buried piping backfill operation, seismic loads were not initially considered for the design of the temporary utility supports in view of the estimated short construction period and the low probability of seismic event occurrence. This information was miscommunicated to the PRC, which understood that seismic loads would be considered. In the Atlanta meeting between the NRC Region II, GPCo and Bechtel in January. 781, the NRC required that seismic loads be considered and the result ,f the analysis for various conditions be repcrted. The results of tr.. . Ismic analysis were submitted to the NRC with the February, 1981 progress report. The analysis showed that the Class I buried piping satisfied the operability criteria (i.e., pressure + weight + CBE seismic stresses were less than the pipe yield stress) as well as equations 8 and 9 of NC 3600 of the ASME code.

The original conceptual design for excavating and backfilling of the buried piping called for buried pipes to be uncovered in 20 feet segments and in "checkared" or " hop-scotch" patterns. During the excavation, the contractor (SWP) suggested longer pipe segment exposures with temporary dead weight supports at 20 feet spans to expedite pipe rewrapping and backfilling operatinns. This change was appi'oved by the engineer (Bechtel) and construction continued. This change did not involve any change in the total scope of the DCR which was approved by the PRB nor did it raise any unreviewed safety questions and hence it was not submitted to the Plant Review Board for approval. Subsequently, plant procedure HNP-809 has been rewritten to more explicitly differentiate between changes affecting safety and those not affecting safety or the scope of the DCR. The determination of recortability to the PRB of changes to DCRs will be done by the cognizant engineer on a case-by-case basis. A general guideline for distinguishing recortable changes is not feasible.

8107240574 810710 PDR ADOCK 05000 G

GeorgiaPower d United States Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 June 5, 1981 Page Two We hope this information will clarify any questions concerning this matter. Please contact this office should further information be desired.

J. T. Beckham, Jr. states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.

GEORGIA POWER COMPANY By:

(/J. T. Beckham, Jr.

Sworn to and subscribed before me this 5th day of June, 1981.

Notary Public RES/mb Notary Pubhc. Georgia. State i' ' arge My Commission Expires Sept. 2v,1983 xc: M. Manry R. F. Rogers, III

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