ML20196K280

Requests Exemption from ASME Code Section III Requirements for Portions of Svc Air Piping from Inboard Primary Containment Isolation Barriers Through Outboard Isolation Valves.Justification Provided.Fee Paid

ML20196K280
Person / Time
Site:	Hatch
Issue date:	03/04/1988
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-4306C, TAC-67395, NUDOCS 8803150263
Download: ML20196K280 (4)

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• Georg a Powar Company 333 P>edmont Annue Acanta, Georg a 30308 Telephone 404 526-6526 a.1:ng Address' Post O'fce Box 4545 Manta. Georg a 30302 Georgia Power L T. Gucwa the southem e'ectrc system j

vanager wear sa'ety SL 4306c and LcenSng 0165I X7GJ17-H790 March 4, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D. C.

20555 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EXEMPTION REQUEST:

ASHE SECTION III RECUIREMENTS Gentlemen:

Georgia Power Company (GPC) has recently determined that certain portions of installed piping which penetrates primary containment on Plant Hatth Unit 2 cannot be documented to meet ASHE Section III, Safety Class 2, Seismic Category 1 requirements, as required by the Plant Hatch Unit 2 Final Safety Analysis Report (FSAR).

For reasons provided below, GPC has determined that a valid basis exists to request an ASHE Code exemption for the subject piping.

GPC hereby requests such an exemption.

The Unit 2 FSAR describes the torus to drywell vacuum breaker test lines (12 service air lines penetrating primary containment) as being ASME Section III, Safety Class 2, Seismic Category 1.

Recent investigation has revealed that this piping may not be installed in accordance with the FSAR description.

Rather, the piping was installed per ANSI B31.1 requirements.

GPC requests exemption from ASHE Section III, Safety Class 2 documentation requirements for that portion of service air piping which extends from the inboard primary containment isolation barriers (air cylinder, 2T48-F323A-L) through the outboard isolation valves (2T48-F342A-L).

The following information is provided in support of this request.

During Unit 2 construction, 12 air supply test lines to the torus to drywell vacuum breakers were designed and installed in accordance with ANSI B31.1.

It has beq,1 determined that the portion of the air lines that penetrates the torus is part of primary containment and thould meet ASHE Section III Class 2 requirements from the inboard to outboard isolation boundaries.

The pipe is type 304 stainless steel 1/2" NPS outside the torus and 1" NPS inside the torus.

All connections are socket welds or threaded.

Two design kjf 8803150263 880304 g9p q

PDR ADOCK 05000366 I )

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b GeorgiaPower d U. S. Nuclear Regulatory Commission March 4, 1988 Page Two changes have been implemented after construction.

One change added a flex hose inside the torus and was installed in accordance with ANSI B31.1.

The other change added a flex hose outside the torus and was installed in accordance with ASHE Section III Class 2.

It has been determined that the existing lines cannot be upgraded to ASME Section III Class 2

classification without modification due to the fact that some weld documentation required for Class 2, but not required for B31.1, is not available.

The materials used for original construction (and both design changes) were ASME Section III Class 2.

However, the class of one Swagelock fitting on each line cannot be determined and the weld filler metal is not fully traceable.

The weld procedures used were documented on the isometric Jrawings and were qualified in accordance with ASHE Section IX.

Pelder qualification was in accordance with ASHE section IX as j

required by ANSI B31.1.

The heat number of weld rod used on one line was recorded and that heat of rod was approved for ASME Section III I

welds.

All of the subject welds (184) have been inspected by liquid penetrant in accordance with Section III Class 2 and are acceptable.

A seismic evaluation has been performed.

The anchor configuration was determined using as-built walkdown information.

In order to simplify the analysis, the anchors were grouped based on the design configuration.

The loads on each anchor in the group were based on stress analyses performed to determine the enveloping load These loads were applied to the governing anchor configuration case.

for the group.

This approach shows the stresses and/or deflections in the governing case are at 95% to 100% of the design allowable, as specified in the FSAR/ Project Design Criteria.

However, if a more detailed analysis were performed using the actual loads and configuration for each

anchor, the worst case stresses and/or deflections would be shown to be approximately 80% to 85% of the design allowable.

In order to ensure that seismic requirements are met, a design change to one support on each line is being implemented.

Ferrite has been checked on one weld on each line and ranged from 4.4 to 7.0 Ferrite Number (FN) in the diluted weld metal.

The pipe is 0 FN.

These values indicate that the undiluted weld metal or weld rod met the requirement for 5 FN minimum.

0165I mm

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Georgia Power b U. S. Nuclear Regulatory Commission March 4, 1988 Page Three GPC requests that the subject lines be treated as B31.1 upgraded to Class 2 for ASHE Section III, with Section XI inspection and testing requirements.

Documentation of this exemption will be reflected in the next FSAR update.

Summary of Basis for Exemotion Reauest:

1.

Except for one Swagelock fitting and the weld rod used, all materials are certified to ASME Section III Class 2.

2.

ASME Section III Class 2 inspection has been performed.

3.

Seismic evaluation has been performed.

4.

Helders and weld procedures were qualified in compliance with ASME Section IX.

5.

Replacing the lines would not change configuration but would only provide the missing weld metal documentation.

6.

Several lines on Unit 1

including these lines were designed and installed as B31.1 prior to being covered by ASME and were upgraded under Section XI without upgrading the documentation.

7.

The intended service (station air) is higher pressure than torus pressure during a Design Base Accident.

I Payment of the filing fee in the amount of one hundred and fifty i

dollars is enclosed.

Please contact this office at any time if you desire further information.

Sincerely,

1. c:5;L.e L. T. Gucwa REB /lc

Enclosure:

Filing Fee - $150.00 c:

see next page Ol65I

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l Georgia Power abL U. S. Nuclear Regulatory Commission March 4, 1988 Page Four 1

c:

Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Reaulatory Commission. Washinaton Mr.~t. P. Crocker, Licensing Project Manager - Hatch l

U. S. Nuclear Reaulatory Commission. Reaion II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch a

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