ML20059N069
| ML20059N069 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/28/1990 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9010100009 | |
| Download: ML20059N069 (4) | |
Text
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South Ciro na ftrarte & Gas Comp 1ny' hn ko a
+e Jenhnsville. GC ND65 Nuclear Operations e
(It03) 34f4D40 t
SCE&G
,, um.,
September 28, 1990 l
P Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 i
Operating License No. NPF-12 Resubmittal of ISI Valve Test Relief Request i
f Gentlemen:
South Carolina Electric & Gas Company (SCE&G), in a letter dated March 21 S
1990, submitted a request for relief from testing Residual Heat Removal (RHR) containment isolation valves XVG 8701 A/B at the frequency specifiM en the ASME Section XI Code. On April 3, 1990, SCE&G withdrew the request ~because r
the Virgil C. Summer Nuclear Station'(VCSNS) Refueling Outage V was in j
progress and SCE&G could not devote the manpower necessary to present a detailed justification for filing the request.
j With this letter, SCE&G is resubmitting the attached relief request. Upon approval of this request VCSNS intends to test the valves to all of the code t
requirements except frequency, which will be as specified in 10CFR50, Appendix J.
The ASME Code requires the valves to be tested every two years.
l whereas Appendix J requires a testing frequency of once every forty months.
j In the " Reasons for Request" category of the Relief Request, SCE&G states I
that valves 8701 A/B are not required to be tested at the Type C Leak Rate frequency delineated in 10CFR50, Appendix J.
Sections II.F. through II.H. of I
Appendix J categorize (as Type A, B, or C) the different types of primary reactor containment leakage tests based upon the type of leakage.they are
. designed.to detect. Additionally, these sections provide specific criteria for valves and penetrations meant to be classified as Type B or C.
Per these sections, valves 8701 A/B are not Type 8 valves because they do not constitute containment penetrations such as air lock door sealc, doors with resilient seals or gaskets, or penetrations whose design incorporates.
l _
resilient seals, gaskets or sealant compounds.
Likewise, valves 8701 A/B are l
not Type C valves because the VCSNS RHR containment isolation valves:
I i
i 1.
do not provide a direct connection between the inside and outside
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atmospheres of the primary reactor containment under normal operation.
r 2.
are not required to close automatically upon receipt of a containment isolation signal in response to controls intended to effect containment isolation, r
9010100009 90'09 W "
PDR ADOCK 05000393 N-t P
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a Document Ccntrol Desk
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September 28, 1990 Page 2 of 3
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3.
are not required to operate intermittently under post accident conditions, and 4.
are not part of the main steam or feed. vater piping of a boiling water reactor.
Because val'ves 8701 A/B clearly do not meet the criteria for Type B or C classification SCE&G contends that the valves should be classified as Type A and, therefore, tested per paragraph III.D.l.a which specifies three tests in t
ten years, or once every forty months.
Type A containment isolation valves whict are required to be in service during Type A testing are tested according to paragraph Ill.A.1.d., which states that the valves "shall be tested in tecordance with Ill.C."Section III.C. provides the methodology for testing Type C valves.Section III.C.
does not provide testing frequencies because they are delineated, for all valve types, in Section Ill.D. Since valves 8701 A/B are Type A valves, they are subject to testing every forty months per tne requirements of Section 111.0.1. Although these' valves are permitted to be tested according to Type C methodology, they are not Type C valves and are, therefore, not subject to:
testing at the Type C frequency.
Because valves 8701 A/B are Category A valves in ASME Section XI classification, paragraph IWV-3422 of the Code requires them to be tested at a frequency of every two years. The NRC Staff has stated in Generic Letter c
89-04 that the leak test procedures and requirements for containment
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isolation valves specified in 10CFR50, Appendix J, are equivalent to the requirements of Section XI, paragraphs IWV-3421 through IWV-3425. SCE&G is requesting relief from the Code required frequency and-intends to test the valves at the frequency specified for Type A valves in 10CFR50, Appendix J.
In addition to being tested as containment isolation valves, VCSNS Technical l
Specification 3.4.6.2, " Reactor Coolant System (RCS) Operational Leakage,"
requires that valves 8701 A/B be tested as pressure isolation valves to ensure that leakage at RCS operating pressure (2235 1 20 psig)doesnot exceed one gallon per minute.
This test is performed on each valve during startup following each refueling outage, and prior to returning the valves to service following maintenance repair or replacement work.
SCE&G requests the NRC to review and approve this request by April 1, 1991.
Additionally, VCSNS would like to arrange a meeting with the NRC to discuss, in detail, the justification for this relief request..Please contact i-Mr. E. W. Rumfelt of my staff at (803) 345-4192 to schedult en appointment convenient for both parties.
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e Document Control Desk September 28, 1990 Page 3 of 3 Should you have any questions, please call at your convenience.
(
Very truly yours, John L. Skolds EWR/JLS:lcd Attachment c:
O. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts t
R. V. Tanner S. D. Ebneter J. J. Hayes, Jr.
General Managers NRC Resident inspector J. B. Knotts, Jr.
G. G. Williams L. B. Collier E. W. Rumfelt NSRC NPCF RTS (NRR900005)
File (810.19-2) l l
h i
a
' to Document Control Desk Letter September 28, 1990 Page 1 of I ISI VALVE TEST RELIEF REQUEST Relief Request II:
P.1. Revision 1 Components: Valves XVG08701A and XVG08701B Code Category: A Code Class: 2 Function: These valves provide Residual Heat Removal (RhR) TRAIN "A" ar,d, RHR TRAIN "B" inside Reactor Building containment isolation. They are closed-during normal operation and closed post accident.
Existing Test Requirement: Perform 10CFR50, Appendix J alternative Type A Leak Test in accordance with ASME Section XI code test frequency every two (2) years.
Alternate Test frequency: As permitted by 10CFR50, Appendix J, perform Type A alternative Leak Test method every 40 1 10 months.
Reasons for Request: SCELG is requesting relief from the ASME Code required testing frequency to save outage time and to decrease personnel exposure.
SCE&G feels this request is justified because:
(a) 10CFR50, Appendix J, recognizes that these valves require Leak Rate testing at the Type A frequency (40 1 10 months) in lieu of the Type C frequency of every two years.
1 (b)
Even though the ASME Code requires that these valves be tested every two years, the NRC has stated (Generic Letter 89-04) that the leak test procedures and requirements for containment isolation valves specified in 10CFR50, Appendix J, are equivalent to the requirements specified in the ASME Code.
(c)
The frequency specified for Leak Rate testing these valves in VCSNS Technical-Specification 3.6.4, " Containment isolation Valves," is 40 1 10 months.
(d)
The 30 Day Water Seal, which is the alternative test method utilized by VCSNS, is recognized in 10CFR50, Appendix J, as an acceptable alternative to Type A and Type C Leak Testing, j
(e)
Testing at the reduced frequency will result in a reduction in radiation dose of approximately 200 mr per refueling outage.
(f)
These valves will continue to be tested each outage as RCS Pressure Isolation Valves per VCSNS Technical Specification 3.4.6.2.
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