ML20079L594
| ML20079L594 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/18/1983 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8302230381 | |
| Download: ML20079L594 (5) | |
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r SOUTH CAROLINA ELECTRIC & GAS COMPANY POST OFFICE 764 COLuus:A. south CAROLINA 29218 O. W.OlMON,JR.
Vice P.ESIDENT uucuan o 4fious February 18, 1983 Mr.-Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 ASME Section XI Hydrostatic Testing of Feedwater System
Dear Mr. Denton:
South Carolina Electric and Gas Company (SCE&G) hereby requests relief from the ASME Code /Section XI hydrostatic testing requirements for the Virgil C. Summer Nuclear Station Unit No. 1 Feedwater System.
Details of this relief request are contained in the attachment to this letter.
The Steam Generator and Feedwater piping modifications as described in SCE&G letter to Mr. Denton, dated February 14, 1983, are tentatively scheduled to begin March 8, 1983.
Unless otherwise notified prior to April 1, 1983, it is our intent to implement this relief request in order to meet present scheduling activities and return the plant to operating status in a timely manner.
If you have any questions, please call us.
Ver trul y
6 O. W. D xon, r
ARK:OWD:dwf/fjc Attachment cc:
See Page Two EGO 2230381 830218 DR ADOCK 05000395 p
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a Mr. Harold R. Denton Hydrostatic Testing of Feedwater System Page Two February 18, 1983 cc:
V.
C.
Summer E.
C.
Roberts H.
N.
Cyrus T.
C.
Nichols, Jr.
O. W.
Dixon, Jr.
M.
B. Whitaker, Jr.
J.
P.
O'Reilly H.
T.
Babb D.
A.
Nauman C.
L. Ligon (NSRC)
W.
A. Williams, Jr.
R.
B.
Clary O.
S. Bradham A.
R.
Koon C.
A.
Price G.
J.
Braddick J.
L.
Skolds J.
B.
Knotts, Jr.
B. A. Bursey NPCF File l
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Mr. Harold R. Denton Hydrostatic Testing of Feedwater System Page Three February 18, 1983 SYSTEM PRESSURE TESTING RELIEF REQUEST SYSTEM (FW) Feedwater System CODE CLASS 2
SYSTEM DRAWING NUMBER D-302-083 SYSTEM FUNCTION The Feedwater System provides a flow path for water to the Steam Generators (S/G) where such water absorbs and removes heat from the Reactor Coolant System.
SYSTEM TEST REQUIREMENT Subsequent to repairs or modifications by welding which penetrate the pressure boundary on piping greater than one inch diameter, conduct a hydrostatic test on piping where such repairs or modifi-cations were performed.
Pursuant to ASME Code,Section XI, 1977 Edition through and including Summer 1978 Addenda, hydrostatic test pressure is 1.25 Psv or 1470 PSI where Psv is the lowest pressure setting among the main steam safety valves.
O Mr. Harold R.
Denton Hydrostatic Testing of Feedwater System Page Four February 18, 1983 BASIS FOR RELIEF Performing the required hydrostatic test on the Feedwater piping subsequent to the Steam Generator and Feedwater piping modifica-tions and repairs would be extremely difficult, impractical, and expensive due to the following:
1.
The inability to maintain pressure due to potential leakage through the Feedrater Isolation Valves, Main Steam Isolation Valves, and other valves connected to the system.
2.
Additional time and effort to pin or block main steam constant support and variable spring hangers.
3.
Additional time and effort to remove the Main Steam Safety Valves and blank the inlet piping.
4.
Potential for placing excess stress on the Steam Generator shells.
5.
Potential for damage to system instrumentation, or considerable time delay due to additional time and ef fort expended to isolate or remove instrumentation.
6.
Potential for damage to the Main Steam System and its hangers due to static loads caused by water solid condition.
i 7.
Potential for damage to Steam Generator tube bundles.
l 8.
Isolation and preparation of this system would result in additional radiation exposure to personnel.
9.
In addition to the above eight (8) reasons, the alternate examinations specified will provide a level of confidence and quality equal to or better than the required testing per the ASME Code.
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d Mr. Harold R. Denton Hydrostatic Testing of Feedwater System Page Five February 18, 1982 ALTERNATE EXAMINATIONS FOR MAINFEED WATER PIPING WELDS Prior to declaring the Feedwater System operable, the following examinations will be performed to the affected Feedwater System piping welds--except for Item 5, which will be completed at the end of the First Inservice Inspection Interval:
1.
Radiographic Examination pursuant to ASME Code Section V, Article 2.
2.
MT Examination on the root pass and final weld surface pursuant to ASME Code Section V, Article 7.
3.
"Best Effort" Ultrasonic Examination performed in accordance with ASME Code Section V, Article 5.
4.
Perform Inservice Leak Test at nominal operating pressure and subsequent Visual (VT-2) Examination.
5.
Perform Hydrostatic Test at the end of the 10 Year Interval.
IMPLEMENTATION The alternate examinations will be performed in accordance with approved written procedures by qualified personnel after Feedwater Pipe Replacement and before the system is declared operable.