ML20203N999
| ML20203N999 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/30/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| 2696N, SL-689, NUDOCS 8605060258 | |
| Download: ML20203N999 (2) | |
Text
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G3orgia Power Company 333 Ptedmont Avenue Atlanta. Georgia 30308 Telephone 404 526-6526 Mailing Address:
Fbst Office Box 4545 Atlanta, Georg:a 30302 Georgia Power L. T. Gucwa tw undem omtre spmm Manager Nuclear Safety and Licensing SL-689 2696N April 30,1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 ASME CODE SECTION XI - HYDROSTATIC LEAK TEST Gentlemen:
Recently Georgia Power Company (GPC) has had discussions with the NRC staff regarding interpretation of ASME Code Section XI, 1980 Edition, Article IWB-5000 (" System Pressure Tests").
During an exit interview, an NRC inspector identified this as an unresolved item.
The focus of the discussion is Note 5 of ASME Code Table IWB-2500-1 examination category B-P (for all pressure retaining components).
Note 5 states that "the system leakage test (IWB-5221) shall be conducted prior to plant startup following each reactor refueling outage."
GPC's position is that " plant startup", as used in Note 5, means prior to placing the unit in service, which, more precisely, we define as prior to admitting steam to the turbine.
Such definition permits utilizing nuclear steam in the system leakage test after placing the reactor mode switch in the STARTUP/ HOT STANDBY position and pulling control rods.
Not only has this has been GPC's historical practice at Plant Hatch, but we also believe this practice to be preferred.
The nuclear steam system leakage test performed in this " hot" mode is less detrimental to the reactor pressure vessel and components than performing the leakage test under colder conditions due to greater thermal margins between vessel temperature and calculated nil ductility temperature.
Leakage under hot conditions is more readily detectable under this approach since elevated temperature would tend to open leakage paths.
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i GeorgiaPower A Director of Nuclear Reactor Regulation Attention: Mr. D. Huller, Project Director BWR Project Directorate No. 2 April 30,1986 Page Two In reaching our conclusion, we rely, in part, upon the Note's contrasting use of the words " plant" and "reac to r", clearly indicating different entities.
- Further, the general definition of the word
" components" (IWA-2110(h)) supports the proposition that the "pl an t" is broad in scope, encompassing subparts therein, such as reactor vessels.
Consistent with these interpretative aids, reactor start-up is permitted following each reactor refueling outage prior to system leakage test; but plant start-up is limited by the test precondition.
We understand that, although a definitive interpretation by the NRC has not been adopted, discussions within the NRC on this Code provision have viewed the language as precluding GPC's practice of nuclear heatup to perfonn leakage tests.
Since we may be in disagreement with the NRC interpretation concerning the use of nuclear heat, and since startup of Plant Hatch Unit 1 from a refueling outage is imminent, we hereby request temporary relief from the possible NRC interpretation of Note 5 prohibiting the withdrawal of control rods.
Such relief would permit us to return Plant Hatch Unit 1 to service and provide suitable opportunity to resolve the issue.
If temporary relief is not acceptable, we will, of course, pursue alternate hydro procedures which could prolong the outage for four (4) to seven (7) days.
If such alternate procedures are used, GPC will pursue Commission review of what is viewed as a change in interpretation by the staff (10 CFR 50.109).
Sincerely yours, g7&cm L. T. Gucwa LTG/mb xc:
Mr. J. P. O'Reilly Mr. J. T. Beckham, Jr.
fir. H. C. Nix, Jr.
Dr. J. N. Grace (NRC-Region II)
Senior Resident Inspector 10017S
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