ML20214W348

Requests Rev to Relief Request 4.1.2 for Relief from ASME Code,Section XI,1980 Edition Requirements Re Inservice Insp, to Include Plant Svc Water,Demineralized Water,Core Spray & Other ASME Class 3 Piping Sys.Rev Encl.Fee Paid

ML20214W348
Person / Time
Site:	Hatch
Issue date:	11/14/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
References
0842C, 842C, SL-1470, TAC-64164, NUDOCS 8612100193
Download: ML20214W348 (3)

Text

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• Georca Power Company a . 333 Piedrnont Avenue

. Atlanta, Georgia 30308 Tel:phor'e 404 526 6526 Maihng Address:

Post Office Box 4545 Atlanta, Georgia 30302 g Georgia Power L T. Gucwa ttre sout? min t4 doc sgfem Manager Nuclear Safety and Licensing 0842C November 14, 1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 6 Division of Boiling Water Reactor Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555-NRC DOCKET 50-321 OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 INSERVICE INSPECTION RELIEF REQUEST .

Gentlemen:

By letter dated July 18, 1985, Georgia Power Company (GPC) submitted to ' the NRC several requests for relief from the ASME Code,Section XI, 1980 Edition with Addenda through Winter 1980, relative to inservice inspection. The subject relief requests were required by GPC in order to complete the first 10-year inservice inspection interval at Plant Hatch

- Unit 1 during the Winter 1985-86 maintenance / refueling outage.

Included in our July 18, 1985, submittal was Relief Request 4.1.2 which . pertained to the performing of system pressure tests on ASME Class 3 buried piping. Specifically, Relief Request 4.1.2 pertained to the piping in the plant service water systeins which were designed without including provisions for the testing of buried pfping, as later required by Paragraph IWA-5244 of the ASME Code. Further, the visual examination for leakage at ground level for the service water systems' piping is not feasible, since the majority of the piping is buried under asphalt.

Normal system functional testing was proposed as an alternate means of testing. Relief Request 4.1.2 was subsequently approved by the NRC letter dated November 7,1985.

Since the completion of the first 10-year inservice inspection interval at- Plant Hatch Unit 1 during .the Winter 1985-86 outage, we have reevaluated Relief Request 4.1.2 and believe that a revision is necessary in order to address all MME Class 3 piping systems which are af*ected in a manner similar to the plant service water systems discussed above.

Accordingly, Relief Request 4.1. 2 has been revised to include plant service water, demineralized water, core . spray, and any other system's piping which cannot be tested in accordance with the requiremdnts of ASME 8612100193 G61114

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Georgia Power 1 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 November 14, 1986 Page Two Code,Section XI, Paragraph IWA-5244. Normal system functional testing is proposed as an alternate means to the ASME Code,Section XI testing requirements, since the functional testing demonstrates the leaktight integrity of all safety-related buried piping. GPC requests that the NRC grant this relief request in accordance with 10 CFR 50.55a(g)(6).

Pursuant to the requirements of 10 CFR 170, enclosed herein is our check in the amount of $150.00 as payment of the application fee for review of the subject relief request.

Should you have any questions in this regard, please contact this office at any time.

Sincerely, WcGy L. T. Gucwa JAE/lc

Enclosures:

1) Relief Request 4.1.2

2) Application Fee Check c: Georgia Power Comoany U.S. Nuclear Regulatory Commission Mr. J. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr. Mr. P. Holmes-Ray, Senior Resident Mr. H. C. Nix, Jr. Inspector-Hatch GO-MORMS 0842C w" - .

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. 1:.

Georgia Power d ENCLOSURE NRC DOCKET 50-321 OPERATING LICENSE DPR-57  ;

EDWIN I. HATCH NUCLEAR PLANT UNIT 1 INSERVICE INSPECTION RELIEF REQUEST 4.1.2 l

4.1. 2 System Pressure Tests on ASME Class 3 Buried Piping 4.2.1.2 Requirement From Which Relief is Requested Table IWD-2500-1 of ASME Code,Section XI requires a system pressure test -

for Class 3 components, including buried piping.

4.1. 2. 2 Justification The systems (e.g., plant service water demineralized water, core spray, and any other system's piping which cannot be tested in accordance with the requirements of ASME Code,Section XI, Paragraph IWA-5244) were designed without including provisions for the testing of buried piping as required by Paragraph IWA-5244. In addition, the visual examination for 4

leakage at ground level is not feasible, since the majority of the piping is buried under asphalt.

4.1. 2. 3 Testing in Lieu of ASME Section XI Requirements 1-Required pump operability testing done quarterly demonstrates the integrity oT the buried piping by proving that the required flow is i available for the RHR service water, HPCI, and RCIC systems. A large

. break in buried piping would be detected in the plant service water system, which is a normally operating system, by the affect of the flow 4

to equipment - downstream of the break. Some non-safety related systems (demineralized water, etc.) draw from the condensate storage tank (CST) and are considered as part of the Class 3 boundaries of the tank. In these systems a break would not reduce the level of the CST below the minimum reserve safety-related volume due to the tank design. In addition, the water level of the CST is monitored on a daily basis.

0842C E-1 11/14/86 l

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