ML20198R557
| ML20198R557 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/30/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| SL-756, NUDOCS 8606100116 | |
| Download: ML20198R557 (2) | |
Text
- _ _ _ _ _ _ _ _ _ _ _ _
Georgia Power Company k
333 Pieomont Avenue Atlanta, Georg;a 30308 Telephone 404 526-6526 Mailing Address:
Post Office Box 4545 n3 Atlanta. Gecrgia 30302 f)
- L Georgia Power
" t' L T. Gucwa Manager Nuclear Safety SL-756 and Licensing May 30,1986 U. S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: LAR Region II - Suite 2900 50-321/366 101 Marietta Street, NW Inspection Atlanta, Georgia 30323 86-11 ATTENTION: Dr. J. Nelson Grace Gentlemen:
The following information is submitted in response to Inspection Report 86-11, which concerns the inspection conducted at Plant Hatch by Mr. B. R.
Crowley of your office on March 24-27, 1986.
One apparent violation was identified and applied to Hatch Units 1 and 2 VIOLATION:
" Technical Specification 6.8.1.c requires that procedures be implemented for surveillance and test activities of safety-related equipment.
10 CFR 50.55a (g)(4) requires that throughout the service life of a nuclear power plant, Class 1, 2, and 3 components shall meet the requirements of the Edition of ASME Section XI that becomes effective.
The applicable Edition of ASME Section XI, the 1980 Edition, requires pressure testing and VT-2 inspection of certain Class 2 and 3 systems each 40 months.
Contrary to the above, implementing procedures for scheduling and tracking pressure tests do not exist and Class 2 and 3 40-month pressure tests are not being scheduled and performed.
This is a Severity Level IV violation (Supplement I)."
RESPONSE TO VIOLATION:
After careful review, we have concluded that the alleged violation did not occur.
Contrary to the alleged violation, no specific regulatory requirement exists for implementing procedures for the scheduling and tracking of surveillance items, such as pressure tests.
Procedures are required for the actual performance of the necessary surveillance but are not required for the scheduling and tracking of said surveillance.
The required ASME Class 2 and 3 pressure tests are performed at Hatch Units 1 and 2 using approved plant procedures.
It should be noted that plant procedure 42IT-TET-001-0S was originally intended to be used for the 8606100116 86053o
{DR ADOCK 05000321 PDR l90 feT
w 9-Georgia Power A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 May 30,1986 Page Two RESPONSE TO VIOLATION (Continued):
performance of the required pressure tests;
- however, after additional review, it was determined that the use of alternate procedures would be more desirable.
The alleged violation states that the required pressure tests for ASME Class 2 and 3 systems "are not being scheduled and performed" (emphasis supplied).
While the required pressure tests had not been scheduled and performed at Hatch Unit 1 prior to the NRC's inspection of March 24-27, 1986, the tests were scheduled and performed prior to the end of the recent maintenance / refueling outage for the particular Unit, thereby meeting the requirements of the 1980 Edition of the ASME Section XI Code.
Therefore, the proposed violation is incorrect relative to the alleged failure to perform the required ASME Class 2 and 3 pressure tests at Hatch Unit 1.
The nominal end of the third 40-month period of the first 10-year inservice inspection interval for Hatch Unit 1 was December 30, 1985.
However, since the scheduled maintenance / refueling outage started prior to that date, the inspections for the third 40-month period continued throughout the extended outage.
It should be noted that the subject pressure tests were not required by earlier editions of the Code (i.e., the 1971 and 1974 Editions) which were used during the first two 40-month periods of commercial operation at Hatch Unit 1.
With regard to Hatch Unit 2, ASME Class 2 and 3 pressure tests were not required prior to January 1,1984, since the 1974 Edition of the Code, which was used prior to that date, did not require such pressure tests.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, Yh L. T. Gucwa JAE/tir c: Georgia Power Company Mr. J. P. O'Reilly Mr. J. T. Beckham, Jr.
Mr. H. C. Nix, Jr.
GO-NORMS U. S. Nuclear Regulatory Commission Senior Resident Inspector 700775