ML20044G749

Application for Amend to License NPF-12,changing TS 4.7.1.2.a.2 to Perform Turbine Driven Pump Surveillance Test at Secondary Steam Pressure Greater than or Equal to 865 Psi

ML20044G749
Person / Time
Site:	Summer
Issue date:	05/25/1993
From:	Skolds J SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation
Shared Package
ML20044G750	List: ML20044G749 ML20044G755
References
RC-93-0143, RC-93-143, NUDOCS 9306040197
Download: ML20044G749 (3)

Text

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South Carolina Electric & Gen Company John L Skolds

$u7iearStens l l"5 Sf am f scEao c ..-,

May 25, 1993 RC-93-0143 -

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Assistant Director for Projects, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555  :

Mr. S. D. Ebneter Regional Administrator U. S. Nuclear Regulatory Commission Region II, Suite 2900 ,

101 Marietta Street, N.W.

Atlanta, GA 30323 Gentlemen: .

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 EMERGENCY FEEDWATER SYSTEM TECHNICAL SPECIFICATION 4.7.1.2 '

OPERABILITY OF TURBINE DRIVEN EMERGENCY FEEDWATER PUMP REQUEST FOR ENFORCEMENT DISCRETION AND TECHNICAL SPECIFICATION CHANGE (TSP 930009)

In accordance with 'CFR2, Appendix C, South Carolina Electric & Gas Company (SCE&G) requests Enforcement Discretion from compliance with existing technical specification surveillance requirement 4.7.1.2.a.2, and submits an exigent amendment request to License NPF-12 to change the Technical Specification (TS) 4.7.1.2.a.2 for VCSNS. Existing TS 4.7.1.2.a.2 prescribes that the turbine driven emergency feedwater pump be tested with secondary steam pressure greater than 900 psig. SCE&G proposes to change TS 4.7.1.2.a.2 to perform the turbine driven pump surveillance test at secondary steam pressure greater than or equal to 865 psig, see Enclosure 1. This request is intended to preclude unnecessary plant load reduction to perform -

the surveillance test.

The following information is provided in support of this request:

Existing Technical Specification Surveillance Requirement 4.7.1.2.a.2 requires that the turbine driven emergency feedwater pump (EFNP) be demonstrated operable by verifying that it develops a discharge pressure greater than or equal to 1330 psig at a flow greater than or equal to 97 gpm when the secondary steam supply pressure is greater than 900 psig. After the increase in the tube plugging in the steam generators during our recent refueling outage, the main steam pressure at-full power has decreased below 900 psig. This condition was expected and described in our submittal for increasing the Steam Generator Tube Plugging from 15% to 18%. The 900 psig ,

steam pressure required by the surveillance can not be achieved with the plant operating at full power.  ;

{) 9306040197 930525 h' PDR ADOCK 05000395 P PDR ,

I Assistant Director for Projects Mr. S. D. Ebneter TSP 930009 Page 2 of 3  !

The surveillance test for the turbine driven EFWP is due on May 27, 1993.

Preventive maintenance work associated with the pump is scheduled to be performed on May 25, 1993, thus requiring an acceptance test to be performed prior to returning the pump to service. The post maintenance testing is l performed in accordance with the surveillance requirement.

This request is based on the present design capability of the turbine driven i EFWP. The steam turbine governor valve throttles the steam supply flow down l to the maximum steam ring pressure of 750 psig for any steam supply pressures greater than 750 psig. The maximum calculated pressure drop'in the steam .;

supply line at full steam flow, including leakages, at turbine rating j conditions is approximately 112 psig. If the full flow pressure drop is 1 adopted as the maximum pressure loss, then the required pressure at the steam generators for performing the surveillance test shall be approximately 862 ,

psig, which is below existing operating conditions. Testing or operating the turbine driven EFWP when minimum secondary steam supply pressure is equal to or greater than 865 psig does not impact the performance of the pump since at this steam pressure the turbine is capable of developing the brake horsepower .j required by the pump for its full operating condition. '

i There are no compensatory measures needed to perform the surveillance test or _

operate the turbine driven EFWP when secondary steam supply pressure is equal to or greater than 865 psig. The surveillance requirement for discharge ,

pressure (1330 psig) and flow (97 gpm) will be met. j This request shall be valid through the current operating cycle and is justified on the basis of the analysis performed in support of the license amendment to increase the plugging margin of the steam generators, which was approved and issued as Amendment 111 on March 18, 1993. The testing of the .j pump at steam generator pressures lower than 900 psig does not affect the ,

operability of the pump. 1 The request to test the turbine driven pump at steam pressure below 900 psig l does not affect the ability of the emergency feedwater system to function )

following a design basis event; it will not change the availability of the  ;

l system, it will not change the flow parameters, and it will not impact the <

system response time or its initiation. Therefore, the request will not have a potential adverse impact on the public health and safety, nor will a  !

significant safety hazard be involved. I Since the proposed change does not involve any change to the operation of the plant or its physical configuration, there will be no adverse impact to the environment.

L l

l l i l

i Assistant Director for Projects Mr. S. D. Ebneter  !

TSP 930009 Page 3 of 3 Should you have any questions, please contact Mr. M. W. Gutierrez at (803) 345-4392.

Very truly yours, John L. S MWG: led  ;

Attachments c: 0. W. Dixon R. R. Mahan R. J. White >

G. F. Wunder .

NRC Resident Inspector J. B. Knotts Jr.

NSRC Central File System RTS (TSP 930009)

File (813.20)

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