ML20153B264
| ML20153B264 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/17/1988 |
| From: | Hood D Office of Nuclear Reactor Regulation |
| To: | Head G GEORGIA POWER CO. |
| References | |
| TAC-67395, NUDOCS 8803220014 | |
| Download: ML20153B264 (4) | |
Text
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[j9 UNITED STATES NUCLEAR REGULATORY COMMISSION y
j Wd$HINGTON, D. C. 20555 t/
March 17, 1988 Docket No.:
50-366 Mr. George F. Head Senior Vice President Georgia Power Company P.O. Box 4545 Atlanta, GA 30302
Dear Mr. Head:
SUBJFCT: ALTERNATIVE REQUIREMENTS, VACUUM BREAKER AIR SUPPLY TEST LINES FOR HATCH UNIT 2 (TAC NO. 67395)
By letter dated March 4, 1988 as supplemented by letter dated March 15, 1988, Georgia Power Company requested that the provisiens of 10 CFR 50.55a(a)(3) be applied to air supply test lines for the vccuum breakers of the Edwin I. Hatch Nuclear Plant. Unit 2.
This section of the regulation allows the NRC to accept alternatives to the requirements specified elsenhere in 10 CFR 50.55a for meeting the provisions of the ASME Boiler and Pressure Vessel Code when it can be demonstrated that (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the e e.ified requirements of 10 CFR 50.55a would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
The March 4, 1988 letter stated that the air supply test lines in question had originally been designed and installed in accordance with the require-ments of ANSI B31.1 and that only recently was it recogni:ed that the lines constitute a portion of primary containment and should meet ASMF Section III Class 2 requirements.
However, the existing lines cannot be upgraded to ASME Section III Class 2 without modification because some weld documentation required for ASME Section III Class 2, but not required for ANSI B31.1, is not available.
GPC has determined that documentation exists for all materials except for the weld rod material and that of one fitting.
All other requirements for Class ? classification have been satisfied, such as the inspection require-ments.and the seismic evaluation and qualification.
In addition, the welders and the weld procedures were determined to be ouelified and in compliance with ASME Section IX. All welds have been inspected by liquid penetrant and found to be acceptable.
The ferrite has also been checked on one weld in each line and found to be within acceptable limits.
Finally, GPC has committed to N
satisfy all relevant ASME Section XI requirements for inspection and testing.
The staff has reviewe6 the basis for the request by CDC and has concluded that the lines as installed provide an acceptable level oi quality and safety, and that replacement of the lines just to satisfy the documentation requirements 8803220014 880317 PDR ADOCK 05000366 P
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T
.4-Mr. George F. Head
-P-for Class L2 piping 'would not ~ add significantly to the safety of the plant.
Replacement of the lines solely to generate documentation would result in hardship without a compensating increase in the level of quality and safety.
Accordingly, pursuant to 10 CFR 50.55a(a)(3) the lines as installed, with'the additional tests and checks performed by the licensee, are acceptable as ar.
alternative to fully meeting the rec.uirements of ASME Section III Class 2.
Acceptance of this alternative is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that would result if the ASME Section III Class 2 requirements were fully imposed on the facility.
The orovisions of 10 CFR 50.55a(g) shall apply to these lines to the same extent as if the lines met the requirements of ASME Section III Class 2.
Further, the potential non-conformance of these lines with statements 'in the FSAR is a matter separate from the acceptance of this alternative under 10 CFR 50.55a(a)(3). Whether enforcement action is appropriate will be separately considered.
Sincerely, Darl S. Hood, Acting Director Project Directorate II-3 Division of Reactor Projects - I/II cc:
See next page s
DISTRIBUTION DOCKET FILE.
PD II-3 Reading HATCH PLANT FILE MRood LCrocker DHood OCG/WF Glainas SVarga NRC PDR LOCAL PDR EJordan JPartlow ACRS(10)
SEE PREVIOUS CONCURRENCES
- PD II-3 PD II-3
- 0CG/WF Glainas PD 11-3 NRood LCrocker ADD-2 DHood/ Acting PD 03/ /88 03/r//83 03/ /88 03/ /88 03/ /88
Mr. George F. Head for Class 2 piping would not add significantly to the safety of the plant.
Replacement of the lines solely to generate documentation would result in hardship without a compensating increase in the level of quality and safety.
Accordingly, pursuant to 10 CFR 50.55a(a)(3) the lines as installed, with the additional tests and checks performed by the licensee, are acceptable as an alternative to fully meeting the requirements of ASME Section III Class 2.
Acceptance of this alternative is authorized by law and will not endanger life or property or the cor. anon defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that would result if the ASME Section III Class 2 requirements were fully imposed on the facility.
Sincerely, Darl S. Hood, Acting Director Project Directorate II-3 Division of Reactor Projects - I/II cc: See next page DISTRIBUTION 1RICRT.M PD II-3 Reading HATCH PLANT FILE HRood LCrocker DHood OCG/WF Glainas SVarga l
NRC PDP l
LOCAL PDR J
w f-(
ACRS(10) 7-*v '
4
/
G inas D II-HRo B LCrocker A
-2 DHood/ Acting PD 03//4 /88 03//6 /88 03/ /88 03/q /88 03/j7/88 1
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Mr. George F. Head-Edwin I. Hatch Nuclear Plant, Georgia Power Company Units Nos. I and ?
l, cC'
< g G. F. Trowbridge, Esq.
Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington, D.C.
20037 Mr. L. T.
Gutwa Engineering Department Georgia Power Company g
P. O. Box 4545 Atlanta, Georgia S0302 Nuclear Safety and Compliance Manager Edwin I. Hatch Nucleir Plant Georgia Power Company P. O. Box 442 Paxley, Georgia 31513 g
Mr. Louis B. Long Southern Company Services, Inc.
c P. O. Box 2625 Birmingham, Alabama 35702 Resident Inspector U.S. Nuclear Regulatory Commission E
Route 1, Box 725 Baxley, Georgia 31513 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georiga 30323 Mr. Charles H._ Badger Office of Planning and Budget Room 610 270 Washington Street, S.W.
Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Commissioner Department of Natural Resources 270 Washington Street, N.W.
Atlanta, Georgia 30334 Chairman j
Appling County Commissioners
,i County Courthouse Baxley, Georgia 31513
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