ML20128Q129
| ML20128Q129 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/23/1985 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8507260589 | |
| Download: ML20128Q129 (5) | |
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SOUTH CAROLINA ELECTRIC & GAS COMPANY POST OFFICE 764 COLuusiA South CAnoLINA 29218
- o. w. oi.o. ;.
July 23, 1985 VICE PassineNT NuCLEAm OremarioNs Mr. Harold R.
Denton 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. N P F-12 ASME Section XI Hyd ro s t at ic 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.
In a letter dated April 3, 1985, SCE&G requested h yd ro s t a t ic testing relief for the Feedwater System in order to rotate the bodies of the three Fe edwater Reve rse Flush Valves at the plant.
To support the Steam Generator Manifold Inspection [ Operating a mod i fic a t ion must be mad e to allow License Condition 2.C(14)],
permanent access to the manifold.
Preliminary design and procurement a c t iv i t ie s are now complete and this modification will be accomplished during the scheduled October 1985 re fueling outage.
A relief f rom hyd rostatic testing of the feedwater system is hereby being requested for this modification.
The relief requested in this letter is synonymous with that in the April 3, 1985 letter and involves the elimination of a single h yd r o s t a t ic test to the entire Feedwater System.
Implementation of this mod i f ic a t ion will alleviate the need for future relief requests supporting the performance of the required inspections.
Please find enclosed the application fee of one hundred fifty dollars ($150.00) required by Title 10 of the Code of Federal Regulation, Part 170.
Should you have any questions, please advise.
B507260589 050723 Yours very truly, PDR ADOCK 05000395 p
P PDR
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W.
Dixon, Jr.
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Hyd ro s t a tic Testing of Feedwater System Page Two July 23, 1985 i
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Mr. Harold R.
Denton Hyd ros t at ic Testing of Fe edwater System
' July 23, 1985 ATTACHMENT SYSTEM PRESSURE TESTING RELIEF REQUEST SYSTEM (FW) Feedwater System CODE CLASS 2
SYSTEM DRAWING NUMBER D-302-083 SYSTEM FUNCTION a flow path for water to the Steam The Feedwater System provides Generators (S/G) where such water absorbs and removes heat from the Reactor Coolant System.
SYSTEM MODIFICATION I '
In order to provide permanent access for the required visual inspection of the Steam Generator preheater baffles, SCE&G in tend s to install blank flanges on three (3) existing 2" half cou plings l
(one per steam generator) located on the main feedwater piping.
Design and installation will be in accordance with the ASME Code,Section XI, 1977 Edition through and inc lud in g summer 1978 Addenda.
SYSTEM TEST REQUIREMENT l
Subsequent to repairs or modifications by welding which penetrate l
the pressure boundary on piping greater than one inch diameter, l
conduct a hyd rostatic test on piping where such repairs or
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modifications were performed.
l Pursuant to ASME Code,Section XI, 1977 Edition throu gh and including summer 1978 Addenda, h yd r o s t a t ic test pressure is 1.25 Pev or 1470 PSI where Psv is the lowest pressure s e t t in g among the main steam sa fety valve s.
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O Mr. Harold R.
Denton Hydrostatic Testing of Feedwater System Page Two July 23, 1985 ATTACHMENT BASIS FOR RELIEF Performing the required hyd ro s t a t ic test on the Feedwater piping subsequent to the modification would be extremely difficult, impractical, and expensive due to the following:
1.
The inability to maintain pressure due to potential leakage through the Feedwater Isolation Va lv e s, 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 Sa fety Va lv e s and blank the inlet piping.
4.
Potential for placing excess stress on the Steam Generator shells.
5.
Potential for damage to system in s t ru men t a t ion, or c ons id erab le time delay due to additional time and effort expended to isolate or remove in s t ru me n t a t ion.
6.
Potential for damage to Steam Generator tube bundles.
7.
Isolation and preparation of this sys tem would result in additional radiation exposure to personnel.
In ad d i t ion to the above seven (7) reasons, the alternate a level of con fidence and examinations specified will p r ov id e quality equal to or better than the required testing per the ASME Code.
ALTERNATE EXAMINATIONS FOR MAIN FEEDWATER PIPING WELDS Prior to declaring the Feedwater System operable, the f o llow in g examinations will be performed to the a f fected Feedwater System piping we ld s--e xc e p t for Item 4, which will be completed at the end of the First Inservice Inspection Interval:
1.
MT Examination on the root pass and final we ld surface pur suan t l
to ASME Code Section V, Article 7.
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Mr. H a r o ld R.
Denton Hyd ros t at ic Testing of Feedwater System Page Three July 23, 1985 ATTACHMENT 2.
Visual Examination.
3.
Perform Inservice Leak Test at nominal operating pressure.
4.
Perform H yd ro s t a t ic 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 the Feedwater Modification and be fore the system is declared o p e r ab l e.
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