ML20100G764
| ML20100G764 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/03/1985 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8504080410 | |
| Download: ML20100G764 (4) | |
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I SOUTH CAROLINA ELECTRIC & GAS COMPANY PO$r OFFICE 764 COLUMetA. SOUTH CAROLINA 29218
- o. W. DixoN, J.,
s$e5."o$.$r~du.
April 3,.1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Virgil C.
Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 ASME Code,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.
This relief request is needed to support a modification to rotate the Feedwater Reverse Flush Valves.
Details of this relief request are contained in the attachment to this letter.
Please find enclosed the application fee of one hundred fifty dollars ($150.00) required by Title 10 of the Code of Federal Regulations, Part 170.
If you have any questions, please advise.
8504080410 850403
~
PDR ADOCK 05000395 D.
JAW /OWD/gj
Attachment:
cc:
V.
C.
Summer C.
A.
Price T.
C.
Nichols, Jr./O. W.
Dixon, Jr.
C.
L.
Ligon (NSRC)
E.
H. Crews, Jr.
K.
E. Nodland E.
C. Roberts R. A.
Stough W. A. Williams, Jr.
G.
O.
Percival D. A.
Nauman C. W.
Hehl J. N.
Grace J.
B.
Knotts, Jr.
Group Managers NPCF O.
S.
Bradham File fL.m s ch A,
- tSo Mal 7312.
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l-IAttachment' J-Pige 1 of-3
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- HYDROSTATIC TESTING OF PEEDWATER SYSTEM RELIEF REQUEST 3:
SYSTEM
' CODE CLASS 2
^
SYSTEM DRAWING-NUMBER, D-3 0 2-0 8 3 -
SYSTEM FUNCTION.
The Feedwater System provides a flow path for water to the Steam Generators where~the water absorbs and removes heat from the Reactor-Coolant System.
SYSTEM MODIFICATION
~
ISCEEG intends to rotate the body of the Feedwater Reverse Flush 5 Valves (1678A,-B, C) 180*.
These-valves are vertical stem-Anchor / Darling 3"
- 15006 globe valves.
The flow
. characteristics of the valves-are such.that flow normally enters the valve-from under the globe and exits to one side when the' globe is lifted; however, a previous modification to ii
-provide for-Feedwater System warming-has resulted in a
. reversed direction of flow through the valves.
The reversed i
' direction of flow causes minor system perturbations when the
' valves are opened.
Though these perturbations are of minor concern ' during l the short term, long ~ term maintenance
]
considerations justify the reorientation :of the valves.
I SYSTEM TEST REQUIREMENT-Subsequent: to. repairs or modifications by welding which penetrate-the\\ pressure boundary on piping greater than one
' inch. diameter, a hydrostatic test is to be conducted on piping o,
-where such repairs or modifications were performed.
o JPursuant to ASME Code,Section XI, 1977 Edition through and including Summer 1978 Addenda, hydrostatic test pressure is
.l.25'Psv,or 1470 PSI where Psv is the lowest pressure setting among the main steam safety valves.
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.Page.2 of 3
- BASIS FOR RELIEF
-- Performing the required Hydrostatic Test on the Feedwater
. pipingLsubsequent te the modification would be extremely difficult, impracticai, and expensive due to.the following:
1..
The difficulty of? controlling pressure in the steam
' generators, when water solid, due to the acceptable leakage rates through various valves connected to the system..
l2. - Additional time and effort.to pin or block main steam constant support and variable spring hangers.
- 3.-
Additional time'and effort to'removeothe Main Steam Safety Valves and blank-the inlet piping.
- 4.=
Technical Specification Table 5.7-1 limits hydrostatic test cycles on the secondary; system to five per steam generator over the operating life of the plant.
To effect such a measure for the welds on the three inch pipir.g is.
. considered to be an excessive extension of these
-requirements.
. 5. - Potential for damage to_ system instrumentation, or
. considerable time delay due to additional time and effort 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.
7.
Isolation. and ' preparation of this system would result.irt additional radiation exposure to personnel.
In. addition to the above seven (7) 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.
ALTERNATE EXAMINATIONS FOR FEEDWATER VALVE TO PIPING WELDS Prior ~to entering Mode 2, the following. examinations will be performed on the.affected Feedwater System piping welds, except: Item 5, which will1be completed at the end of the First Inservice Inspection. Interval:
1.=
MT Examination on.the root pass and final weld surface pursuant to - ASME Code Section V, Article 7.
Attachment Page 3 of 3 ALTERNATE EXAMINATIONS FOR FEEDWATER VALVE TO PIPING WELDS ( cont' d )
2.
RT Examination on the final weld surface pursuant to ASME Code Section V, Article 2.
3.
Visual Examination 4.
Performance of Inservice Leak Test at nominal operating pressure.
5.
Performance oi Hydrostatic Test at the end of the 10 Year Interva l.
IMPLEMENTATION The alternate examinations, items 1 through 3, will be performed in accordance with approved written procedures by qualifed personnel after the Feedwater Reverse Flush Valve modification is complete.
The performance of an inservice leak test will be performed during heat up prior to entering Mode 2.
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