ML20151A247

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Requests Relief from ASME Code,Section XI Hydrostatic Test Requirements for Steam Generator Blowdown Sys.Relief Needed to Support Steam Generator Blowdown Sys Mod Scheduled to Commence on 880916.Fee Paid
ML20151A247
Person / Time
Site: Summer 
Issue date: 03/30/1988
From: Nauman D
SOUTH CAROLINA ELECTRIC & GAS CO.
To: Hayes J
NRC, NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8804060391
Download: ML20151A247 (4)


Text

th C4r na Electric & Gas Company Dan. Nau n

,g Columbia. SC 29218 Noctear Operabons (803) 748-3513 SCE&G March 30, 1988 Document Control Desk U. S. Nuclear Regulatory Ccmmission Washington, DC 20555 Attention: Mr. J. J. Hayes, Jr.

Subject:

Virgil C. Summer Nuclear Station Occket No. 50/395 Operating License No. NPF-12 ASME Section XI Hydrostatic Testing of Steam Generator Bloadoon System

Dear Mr. Hayes:

South Carolina Electric & Gas Ccmpany (SCE&G) nereoy reauests relief from tne ASME Code /Section XI hydrostatic testing requirements for the Virgil C.

Summer Nuclear Station Unit No. 1 Steam Generator Blondean System.

Details of this relief request are contained in the attachment to this letter.

Inis relief request is needed to support the Steam Generator Elowdoan System modification anich is scheduled to commence September 16, 1988.

It is requested that Inis relief be granted as soon as possible, but n0 later than September 1, 1968.

Also attached is a check for $150.00 pursuant to tne requirements of 10CFR170.

If you have any questions, please advise us.

Very truly yours,

  • ~

D. A. Nauman AMM/0AN:lCd Attachment pc:

J. G. Connelly, Jr./0. W. Oixon, Jr./T. C. Nichols, Jr.

41 E. C. Roberts M\\

W. A. Wi

'ams, Jr.

J. C. Snelson L

I kp J. N.

G. O. Percival

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g, J. J. Hayes, Jr.

R. L. Prevatte O[v,ph C. A. Price NSRC N

thf General Managers J. B. Knotts, Jr.

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B. Clary

'RTS v

W. R. Higgins NPCF R. M. Campbell, Jr.

File (810.20)

K. E. Hodland 8804060391 880330 PDR ADOCK 05000395 B

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  • d Occument Control Desk-March 30, 1988 Page 2 O

HYOR0 STATIC TESTING OF STEAM GENERATOR BLOWD0fN SYSTEM SYSTEM PRESSURE TESTING RELIEF REQUEST SYSTEM (80) Steam Generator Bicacoon System CODE CLASS 2

SYSTEM DRAWihG NUMBER D-302-781 SYSTEM FUNCTION The BD System function is to assist in controlling the chemistry of the secondary side of the steam generator by reducing the soluble and particulate chemical impurities concentrated b) evaporation of secondary aater in the steam generator (SG). By removing a small fraction of the water from the steam generator on a continuous basis, control of chemical impurities can be achieved.

SYSTEM MODIFICATION The current design of tne BD isolation valves (XVG-503A, B.C-ED) is one that is susceptible to thermal binding. SCE&G intends to replace tnese valves with a design that is less susceptible to thermal binding. Design and installation will be in accorcance aith the ASME Code,Section XI, 1977 Edition through and including Summer, 1978 Addenda.

SYSTEM TEST REQUIREMENTS Subsequent to repairs or mcdifications cy aelding anich penetrate the pressure bouncary on piping greater than one inch diameter, conduct a hycrostatic test on piping ahere such repairs or modifications aere performed.

Pursuant to ASME Code,Section XI, 1977 Edition through anc including Sumrer 1978 Addenda, hycrostatic test pressure is 1.25 Psv or 1470 PSI anere Ps, is the lowest pressure setting among the main steam safety valves.

BASIS FOR REllEF Performing tne required hydrostatic test on the BD piping subsequent to the modification aould be extremely difficult, impractical, and expensive cue to the following:

i

-r s

Document Control Desk March 30, 1988 Page 3 1.

Due to the locatien of the valves to be replaced, a hydrostatic test, as required by the code, would impact the secondary side of the Steam Generators and portions of the Main Feedwater, Main Steam, and 80 Systems.

2.

The inability to maintain pressure due to potential leakage througn the Feedaater Isolation Valves, : lain Steam Isolation Valves, and other valves connected to the system.

3.

Additional time and effort to pin or block main steam constant support and variable spring hangers.

4.

Additional time and effort to remove tne Main Steam Safety Valves and blank the inlet piping.

5.

Potential for placing excess stress on the Steam Generator shells.

6.

Potential for damage to system instrumentation and considerable time to isolate or remove instrumentation.

7.

Potential for damage to Main Steam System and its hangers due to static loads caused by water solid condition.

8.

Potential for damage to Steam Generator tube bundles.

9.

Isolation and preparation of this system nould result in additional radiation exposure to personnel.

10.

In addition to the above nine (9) 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 STEAM GENERATOP BLOWDOWN SYSTEM PIPING WELOS Prior to declaring the BD System operable, the folicaing examinations aill be performed on the affected ED System piping a' elds -- except for Item 4, anicn will be completeo at the end of the First Inservice Inspection Interval:

1.

MT Examination on the root pass and final aeld surface pursuant to ASME Code Section V, Article 7.

2.

Visual Examination.

3.

Perform inservice Leak Test at nominal cperating pressure, i

4.

Perform njarostatic Test at tne end of the 10 Year Inter'.al.

l l

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a, Document Control Desk March 30, 1988 Page 4 IMPLEMENTATION The alternate examinations aill be performed in accordance aith appioved written procedures by qualified personnel after the modification and before the system is declared operable.