RC-98-0093, Forwards Relief Request as Rev to Previously Approved Relief Request to Implement ASME Code Case N-416-1

Forwards Relief Request as Rev to Previously Approved Relief Request to Implement ASME Code Case N-416-1

ML20247B211
Person / Time
Site:	Summer
Issue date:	04/29/1998
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.147, RTR-REGGD-1.147 RC-98-0093, RC-98-93, NUDOCS 9805070315
Download: ML20247B211 (4)

Text

_

NIE## ~

South Carolma Electric & Gas Company Gary J. Ttylor N (( Q Virgil C. Summer Nuclear Station P. O. Box 88 Vico Przsident Nuclear Operatens Jenkinsvdle, SC 29065 (803) 345-5209 (803) 635-1461 April 29,1998 RC-98-0093 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 RELIEF REQUEST TO IMPLEMENT ASME CODE CASE N-416-1 (NRR 980001)

South Carolina Electric and Gas Company (SCE&G) hereby submits the attached relief request as a revision to a previously approved relief request (TAC NO. M89213).Section XI of the 1989 Edition of the ASME Code requires that a hydrostatic pressure test be performed after welded repairs or the installation of replacement items by welding on Class 1,2 and 3 piping / components. VCSNS has previously gained approval of a relief request that grants alternative test requirements for the Class 1 and 2 activities. That relief request duplicated the guidance contained in Code Case N-416-1 for Class 1 and 2 piping / components only. This relief request seeks to increase the scope of the previous relief by including the Class 3 piping / components. VCSNS is hereby requesting the full implementation of Code Case N-416-1, including the provisions added by the NRC in the Draft Regulatory Guide DG-1050 (Revision 12 to Regulatory Guide 1.147).

The previously granted relief request duplicated the guidance of N-416-1 for Class 1 and 2 activities. The basis for that relief request is still valid and it is also valid for Class 3 activities. The reason the previous relief request did not include the Class 3 activities was that, although the ASME approved the Code Case, acceptance of the Class 3 alternate test /

by the NRC was questionable at the time. Subsequently, the NRC has approved the use of /

Class 1,2, and 3 provisions of the Code Case at several utilities (such as Beaver Valley-TAC NOS. M89465 and M89466, and St. Lucie-TAC NOS. M94246 and M94247). The NRC has also approved the inclusion of Code Case N-416-1 (with provisions) in Draft Revision 12 of Regulatory Guide 1.147. /f/.p/g Based on the discussion above, the details included with the attached relief request, and the fact that the NRC has approved similar relief requests for use at Beaver Valley, St.

Lucie, and other nuclear plants, as well their approval of the Code Case for inclusion in 9305070315 980429 l

PDR ADOCK 05000395 P PDR s NUCLEAR EXCELLENCE- A SUMMER TRADITIONI

.a v 7)

l Document Control Desk '

RC-98-0093 NRR 980001 Page 2 of 2 4

quality and safety as required in 10CFR50.55a(a)(3)(i). Therefore, SCE&G has met all the necessary requirements of 10CFR50.55a to allow the approval of the relief request as an alternate means of compliance with Section XI of the ASME Code.

This relief request and a recently discovered microbiological induced corrosion (MIC) leak in a Class 3 Service Water line at VCSNS was discussed with Mr. Mark Padovan of the NRC on April 20,1998. The leak has no operability impact and meets the criteria of Generic Letter 90-05 for continued operation. VCSNS would like the option of repairing the leak on-line, however, due to the time and complexity involved to perform a hydrostatic test, the plant would have to shutdown to effect repairs. The timely approval of this relief request would allow the repair to be completed on line should the leak monitoring program indicate progressive degradation. SCE&G requests the review and approval of this relief request be carried out as expeditiously as practical, but no later than February 1,1999.

SCE&G is submitting the attached relief request in accordance with 10 CFR 50.55a(a)(3)(i).

Should you have any questions, please call Mr. David Haile at (803) 34.5-4322.

Very Truly Yours, 6 6 d- E u car Gary J. Taylor DCH/JT/GJT/jt Attachment c: J. L. Skolds NRC Resident inspector W. F. Conway J. B. Knotts, Jr.

R. R. Mahan (w/o attachment) NSRC R. J. White RTS (NRR 980001)

L.A.Reyes File (810.19-2)

L. M. Padovan DMS (RC-98-0093)

General Managers

Attachm:nt to Docum:nt Control Desk Lett:r

+

RC-98-0093 NRR 980001 Page 1,of 2 RELIEF REQUEST TO IMPLEMENT ASME CODE CASE N-416-1 I

Subject:

This relief request provides approval to utilize the alternate requirements of Code Case N-416-1 following a welded repair or replacement of a component by welding for Class )

1,2, or 3 piping / components.

Components:

ASME Class 1,2, or 3 piping and/or components that would require a hydrostatic test following a welded repair on the pressure boundary per IWA-4700.

Current Code Requirement:

Subparagraph IWA-4700 requires that, after certain repairs by welding on the pressure retaining boundary, a system hydrostatic test shall be performed in accordance with IWA-5000.

Alternative Requirement:

As an alternative to the above requirements, apply the guidance of Code Case N-416-1 for welded repairs or_ installation of replacement items by welding. In addition, a surface examination of the root pass layer of butt and socket welds of the pressure retaining boundary of Class 3 componentt:, will be performed when a surface examination is called for by Section Ill.

Basis for Rollef:

As described in the previous SER evaluation (TAC NO. M89213) for V.C. Summer, l dated December 1,1994, concerning use of the provisions of Code Case N-416-1 on Class 1 and 2; hardships are generally encountered with the performance of '

hydrostatic testing in accordance with the Code. Examples of the hardships are:

gagging safety / relief valves, placing the system in a oficormal state, erecting temporary supports for steam lines,and the expense of additional resources required to set-up, calibrate and operate special test gauges and equipment. Also, the hydrostatic test can extend the system out-of-service time that may lead to plant shutdowns due to exceeding allowed outage times in Technical Specifications or at least extend outage duration.

' ' Attachm:nt to Docum:nt Control Desk Litt:r i RC-98-0093 NRR 980001 Page 2,,of 2 Basis for Relief (Cont'd):

The SER also describes that the piping components are designed, based on numerous types of design loadings which are postulated to occur under various modes of operation. Since the hydrostatic test only imparts a small increase above design to one of the loading factors, it is clear that the hydrostatic test does very little to demonstrate the total structural integrity of the pressure boundary. Therefore, the hydrostatic test is regarded as a means of enhanced leak testing. Also, industry experience indicates that leaks are not being discovered as a result of hydrostatic test pressures propagating a preexisting flaw through wall, but rather, the majority of the system leaks are identified during normal operation.

Based on the NDE that is performed, per this relief request, it is highly unlikely that a leak would be found at all and even more unlikely that hydrostatic conditions would be necessary to detect a leak that would not be readily detected at system operating pressure. Therefore, the alternative requirements provided in this relief request '

provide an acceptable alternative to the ASME Code and maintain the level of quality or safety.

i

_ _ _ - _ _ _ _ . - _