ML20073B202

Comment Supporting Proposed Rule 10CFR50.55a Endorsing Later Addenda & Editions of ASME Code Sections III & XI W/Noted Exceptions.Util Also Endorses Comments Submitted by NUMARC

ML20073B202
Person / Time
Site:	Summer
Issue date:	04/15/1991
From:	Skolds J SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR3796, FRN-57FR34666, RULE-PR-50 56FR3796-00016, 56FR3796-16, AD05-2-038, AD5-2, AD5-2-38, GL-89-04, GL-89-4, GL-90-09, GL-90-9, NUDOCS 9104240083
Download: ML20073B202 (2)

Text

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• 1, 21 Mr. Samuel J. Chilk Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, OC 20555 Attention: Docketing and Service Branch

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO NPF-12 COMMENTSONTHEPROPOSEDRULE-TO10CFR50.55a(PR910003)

South Carolina Electric & Gas Company (SCE&G) has reviewed the proposed rule

-to10CFR50.55a(reference 56FederalRegister3796)endorsinglateraddenda

-and editions of ASME Code Sections !!! and XI. SCE&G supports the endorsement with the exceptions noted. SCE&G also endorses the coments submitted by the Nuclear Management and Resources Council (NUMARC).

SCE&G considers that 10CFR50 Appendix J-provides an adequate basis for testing containment isolation valves and limiting leakage. SCE&G implements Appendix J by establishing conservative leakage limits by valve type to ensure total containment leakage is significantly_below the allowable limit.

Valves ~with leakage approaching / exceeding the conservative limit are repaired as soon as practical. By this-means.-total leakage it maintained significantly below the Appendix J. allowable value. The proposed rule would require immediate repair or replacement of a valve exceeding the licensee defined limit. This is considered too restrictive, based on the conservative limits already in place.

In order to provide the needed flexibility, SCE&G's very conservative limits would be raised to a value closer to the ASME OMa-1988 permissible leakage rate. We believe this would result in actual containment leakage rates greater than what is allowed in our current program.-

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ThereferencetoPosition11ofGenericLetter89-04(testingof.non-code components) in the Supplementary Information section of the rule is confusing since 10CFR50.55a deals with ASME Class 1, 2, and 3 pumps and valves. Non-code pumps and valves and the associated piping are not usually designed to-meet the requirements of ASME Section XI. SCE&G supports the NUMARC position that ASME Section XI test requirements should not be linked to non-code pumps and valves..

i 9104240083 910416 PDR PR SO 56 FRO 3796 PDR uy-e l

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Mr. Samuel J. Chilk PR 910003 Page 2 of 2 SCE&G considers the present snubber testing and inspection requirements of Technical Specifications (with the provisions of Generic Letter 90-09) and ASME Section XI 1977 Edition to be more than adequate. The requirements of the revision of OM-4 (OM-1987. Part 4; now ISTD) endorsed under the proposed rule would result in a significant manpower expenditure and radiation exposure with no identifiable increase in any margin of safety. SCE&G does support ISTD Revision 7 as a. replacement for the applicable Technical Specification and current ASME Section XI requirements for snubber testing m

and inspection.

If you have any questions concerning these comments. please call.

Very truly yours.

-John L. Skolds ARR:JLS: led c:

0. W. Dixon Jr.

R.-R.-Mahan R. J. White G. F. Wunder NUMARC General Managers-

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