It is true that attorneys parse words.
Reading your code requirements, it is evident that the referenced code requirement is that the piping design takes into account the operating parameters such as pressure, dynamic forces, etc.
However, the code is not requiring a surge analysis. That is something completely different. A hazop study is also something completely different.
It is standard industry practice that cooling water systems do not operate in unusual pressure, flow, temperature, etc. conditions.
So, the answer to the question is that no hazop study is required because the piping design and operating parameters of the system are within piping design standards. The piping person who designed the cooling system should be able to verify that statement.