ML20246L599
| ML20246L599 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/01/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8905180357 | |
| Download: ML20246L599 (3) | |
Text
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4 g
y gthgergina Elletric & Grs Comptny me B ethem kinsville SC 20065 Nuclear Operations SCE&G sa-,-
May 1, 1989 Mr. S. D. Ebneter Regional Administrator U. S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30323
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Request for Relief - Technical Specification 3.6.4
Dear Mr. Ebneter:
South Carolina Electric & Gas Company (SCE&G) hereby requests that the Enforcement Discretion policy be utilized to provide relief from the Action Statement requirements to Technical Specification 3.6.4, " Containment Isolation Valve," in order to restore XVT-8880-SI, " Accumulator Inlet Nitrogen Supply Valve," to operable status. Valve XVT-8880-SI performs as the "outside" containment isolation valve for containment penetration #320 (see attached sketch), and is presently in an inoperable condition due to mechanical problems.
Currently, in accordance with Action (b) of Technical Specification 3.6.4, XVT-8880-SI is deactivated in the closed position. However, in order to repair this valve. Technical Specifications would either require entry into Action Statement 3.0.3 or entry into Mode 5, the mode in which Technical Specification 3.6.4 is not applicable.
SCE&G, as a matter of principle, does not desire to enter Action Statement 3.0.3 and, furthermore, considers entry into Mode 5 an unnecessary transient on the plant for repairs of XVT-8880-SI.
Also, the existing condition of the fuel necessitates limiting the thermal transients on the fuel. SCE&G requests that the NRC allow the valve to be repaired while the plant is in Modes 1 through 4.
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May 1, 1989 Page 2 I
The repair to XVG-8880-SI requires the removal of the valve internals. Since i
this maintenance activity will result in noncompliance with the Tecnrical Specifications, SCE&G proposes to maintain the containment isolation function by demonstrating the leak tightness of XVC-8947-SI, " Accumulator Nitrogen Supply Check Valve," which is the "inside" containment isolation valve.
It is estimated that a time frame of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is necessary for the process of repairing and testing the valve.
It is proposed that if the repair is not l
complete within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then Technical Specification 3.0.3 will be applied.
SCE&G considers that the prudent action is to repair the valve without imposing an unnecessary transient on the plant (i.e., repair the valve in Mode 5 in accordance with the literal interpretation of the Technical Specifications).
It is important to note that this repair could be made by voluntarily entering Specification 3.0.3.
It is preferred not to enter 3.0.3 because of the short time duration that the plant will be outside the Action Statement and because the "inside" containment isolation valve will have been leak tested. Therefore, this action will provide an overall enhancement of the safety of the plant.
'Should you have any questions, please call us at your convenience.
Very truly yours, O. S. Bradham ARK /0SB:lcd c:
D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
G. O. Percival General Managers R. L. Prevatte J. J. Hayes, Jr.
J. B. Knotts, Jr.
C. A. Price /R. M. Campbell, Jr.
NSRC l
R. B. Clary NPCF J. R. Proper RTS (TSP 890006)
K. E. Nodland File (813.20)
J. C. Snelson
Attachm5nt I to Mr. 5. D. Ebnstar Mey 1,,1989 l
P;.go 1 of 1 l
I i
i inside Reactor Building i Outside Reactor Building I
I Accu lators
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g 8947 3
8880 I
l I
1 f%
1 l
8893 l
Nitrogen i
Supply 1
I 1
l
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