ML20100N196

Requests Relief from Requirements of IWV-3427(b) of ASME Code Section XI Re Future Testing of 16 Msivs.Util Proposes That Valves Be Tested Each Refueling Outage Using Parameters Per Tech Specs

ML20100N196
Person / Time
Site:	Hatch
Issue date:	04/04/1985
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
1531N, NED-85-182, TAC-57410, TAC-57411, NUDOCS 8504180427
Download: ML20100N196 (2)

Text

' Georgia Power Ccmpany .

, 333 P edmont Avenue so % Atlanta. Georgia 30300

.' Telephone 404 5264526 MaMng Address;

Post Office Box 4545 At!anta, Geo gia 30302 Georgia Power L T. Gucwa the southem eiwtnc system Manager Nuclear Engineenry and Chef Nuclear Eng neer ED-85-182 1531N April 4, 1985

-Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear; Regulatory Commission Washington, D. C.- 20555 MRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, PFF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REQUEST FOR RELIEF FROM ASE SECTION XI CODE REQUIREENTS Gentlemen:

- As a result of experience in leak rate' testing of the Main Steam Isolation Valves (MSIV) at Plant Hatch, Georgia Power Company (GPC) requests relief from the application of some of the requirements of IWV-3427(b) of the 1980 edition of the ASE Section XI Code to the future testing of these valves. The sixteen valves affected by this relief request are Hatch Unit 1 valves IB21-F022A,B,C,0 and 1821-F028A,B,C,D, and Hatch Unit 2 valves 2821-F022A,B,C,D and 2B21-F028A,B,C,D. The Code relief, justified herein, provides for testing of the MSIVs using Technical Specification requirements only.

The ASE Section XI Code requires that Category A valves, such as the MSIVs, be tested at least once every 24 months unless a test. shows that the margin .(between the measured leakage rate and the maximum permissible rate) has been reduced by 50% or greater. If there is a reduction in margin by 50% or greater as discussed above, the frequency of leakage testing should be doubled (i.e., performed approximately every 12 months) and performed to coincide with a cold shutdown. In - addition, trending of the" leakage rates is required.

Technical Specifications for both Hatch units require that the.MSIVs be tested on a more frequent basis- than required by the ASE Section XI Code.

These 24" air-operated globe valves are tested once per refueling outage by applying pneumatic pressure (28 psig) between the inboard and outboard MSIVs with a maximum allowable leakage of 11.5 standard cubic feet per hour (SCFH) per valve. - This allowable leakage is small. when compared to other Category A valves. . Some leakage may occur through mechanically sound valves because the inboard MSIV is Ieverse tested, which -tends to lift the globe from the 4

valve seat, thereby allowing -leakage that would not occur during a normal pressurization.

S ,0 9504190427 850404 , g\g.

PDR ADOCKOUOOg3 1

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w; Georgia Power mA ..

. Director of Nuclear. Reactor Regulation

- Attention: Mr. -John F. Stolz, Chief Operating Reactors Branch No. 4

' April 4, 1985 Page Two Since the' normal testing frequency applied by the Technical Specifications is more frequent than that applied by IWV-3422 of the ASME

- Section XI Code' - it . is ' the opinion ' of- GPC that the the " double test frequency" provision of IWV-3427(b) ineed not be applied. .Using these conservative' test criteria, with low allowable leakage at a frequency of

= once per refueling outage, any'significant degradation of the MSIVs should

.be detected. With fuel cycle lengths extending beyond twelve months, as with the planned, eighteen taonth cycles, a potential. exists for unnecessary prolonging of plant cold shutdowns for MSIV testing to meet the " double test .

frequency"' provision of IWV-3427(b) even .though the valves meet the Technical Specification leakage requirement. Testing of the MSIVs and any resultant ~ repair (s) brought about by the' Code requirements can become the critical path to outage completion. Further, additional testing and/or repair (s) impacts ALARA. Therefore, GPC proposes that these valves be tested each refueling outage using the parameters as defined in .the Technical' Specifications in lieu of applying the " double test frequency" provision of IWV-3427(b).

Georgia Pcwer Conpony req sts that NRC review this relief request in an

, expeditious manner so that relief can' be granted to accommodate MSIV leakage rate testing during the Hatch Unit ~2 ' maintenance / refueling outage . scheduled to begin on April.5,1985. The staffs of GPC and Southern Company Services, Inc. are available for additional discussion should E C so desire.

Sincerely yours, c/l'E A m L. T. Gucwa JAE/M3/mb xc

J. T. Beckham, Jr.

H. C. Nix, Jr.

J. N. Grace (W C- Region II)

Senior Resident Inspector 9

' F00776