ML20151R856

Safety Evaluation Supporting Related Inservice Testing Program & Request for Relief of Utils

ML20151R856
Person / Time
Site:	Summer
Issue date:	04/19/1988
From:	Office of Nuclear Reactor Regulation
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ML20151R839	List: ML20151R834 ML20151R856 ML20195J152
References
NUDOCS 8804280112
Download: ML20151R856 (15)

Text

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/ 'o

~g UNITED STATES

! g NUCLEAR REGULATORY COMMISSION

• *; j WASHINGTON, D. C. 20555

\...../

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND RE0 VEST FOR RELIEF SOUTH CAROLINA ELECTRIC AND GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY V. C. SUMMER NUCLEAR STATION DOCKET NO. 50-395 INTRODUCTION The Code of Federal Regulations, 10 CFR 50.55a(g), requires that inservice ,

testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific written relief has been requested by the licensee and granted by the Comission pursuant to 10 CFR 50.55a(a)(3)(1),

(a)(3)(ii),or(g)(6)(1). In requesting relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulties without a compensating increase in the level of quality an( safety, (3) conformance with certain requirements of the applicable Code edition and addends is impractical for its facility.

The Regulation, 10 CFR 50.55a(a)(3)(i), (a)(3)(ii), and (g)(6)(i), authorizes the Commission to grant relief from these requirements upon making the necessary findings. The NRC staff's findings with respect to granting or not granting the relief reauested as part of the licensee's IST Program are contained in the Safety Evaluation (SE) issued on the licensee's program.

The IST program addressed in this SE covers the first ten-year inspection interval that began on January 1, 1984. By letters dated January 5, 1983, l

March 1, 1983, March 17, 1983, August 2, 1984, and January 28, 1985, South Carolina Electric and Gas Company submitted the IST program and revisions for l Summer. This SE does not address the revised IST program submitted December 23, 1987.

l The program is based on the requirements of Section XI of the 1980 Edition of t the ASME Code, Winter Addendum, and remains in effect until January 1, 1994.

EVALUATION The IST program, the requests for relief from the requirement of Section XI and the justification for testing certain valves at cold shutdown have been reviewed by the staff with the assistance of its contractor, EG8G Idaho, Inc.,

(EG&G). On February 24 and 25,1982, EG&G and staff members met with licensee representatives in a working session to discuss the Summer IST Program. The Technical Evaluation Report (TER) provided in the Enclosure is EG&G's evaluation of the licensee's inservice testing program and relief requests.

8804200112 880419 PDR ADOCK 05000395 p PDR

v The staff concurs with and adopts, as part of this SE, the evaluations and conclusions contained in the TER. A summary of the staff's determinations is presented in Table 1 of this SE. The granting of relief is based upon the licensee fulfilling the commitments made in the basis for each relief reauest and the performance of the alternate proposed testing.

Table 1 also reflects the staff review of relaxations permissible under the code. Subsections IWV-3412(a) and 3522 of Section XI of the ASME Code permit the relaxation of the valve exercising frequency to cold shutdowns if quarterly exercising is impractical. The word "agree", in the attached Table 1, indicates the staff's agreement with the technical justification for cold shutdown testing. These justifications are not treated by the staff as relief requests since this relaxation is allowed by the ASME Code.

Table 2 provides a listing of those relief requests being granted under 10 CFR 50.55a(g)(6)(i) and includes the basis for the impracticality and burden determination. No relief requests are being granted under 10 CFR 50.55a(a)(3)(ii). Valve relief recuest P.1, which is evaluated in TER Section 3.1.1, is being granted under 10 CFR 50.55(a)(3)(1) based on the determination that the alternative proposed by the licensee provides an acceptable level of quality and safety.

In the TER, EG&G identified a number of omissions and inconsistencies in the Sumer IST program. These items are listed and sumarized in Appendix C of the TER and are, in most cases, also discussed in the body of the TER.

CONCLUSION Based on the review of the licensee's IST program submittals, the staff concludes that with the resolution of open items identified in Appendix C of the TER, the IST program, as evaluated and modified by thi.i SE, will provide reasonable assurance of the operation readiness of safety-related pumps and valves to perform their safety-related functions. The staff has determined that granting relief, pursuant to 10 CFR 50.55a(a)(3)(i) and (g)(6)(i) is authorized by law and will not endanger life or property, er the comon defense and security and is otherwise in the public interest considering the alternative imposed or the burden that could result if the requirements were imposed on the facility. In addition, the staff has determined 10 CFR 50.55a(a)(3)(1) alternatives proposed by licensee are acceptable. The IST program and revisions submitted for Sumer, dated January 5,1983, March 1,1983, March 17, 1983, August 2, 1984 and January 28, 1985, are acceptable for implementation provided the items noted in Appendix C of the TER are corrected within 3 months of the receipt of this SER. The licensee should address each of the items, l correcting the IST program and testing procedures and/or by providing the NRC l

with the acoropriate relief requests and supporting bases as appropriate.

I l

For those items of this SE which will necessitate procedural changes, the

! licensee has 90 days to implement the changes. For those items of this SE which will necessitate design modifications, the licensee has until startup following the next refueling outage to implement the modification.

l l

4 b

As noted in the introduction, this SE is not based upon a review of the licensee's revised IST program as described in their December 23, 1987 letter.

If all or part of the revised program and/or the two relief requests of that letter have been implemented and those portions implemented are not addressed in this SE, then the licensee has 90 days to provide a justification as to why this implementation meets the findings of this safety evaluation and the requirements of the ASME Code Section XI. The licensee should provide a detailed listing of all deviations and of their rationale for the acceptability of these deviations. If the staff finds these justifications adequate, they will be able to implement only those portions found acceptable in the enclosed evaluation. Relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC.

Principal Contributor: K. Dempsey Dated: APR 191988

i Page No. 1

, 01/07/88 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC

=

Pump 2.2.1 IWP-3100 Measure XPP-141A,141B, Measure pump flow Relief A.1 pump parameters. 4A, and 4B rates at least once Denied each month but no other parameter.

Pump 2.3.1 IWP-3100 MElsure XPP 45A and 45B Measure pump Interim B.1 pump flow rates. differential Relief pressure quarterly Expires in recirculation end of flow path, next R0 Pump 2.4.1 IWP-3100 Measure XPP-39A, 39B, Measure vibration Relief B.2 pump bearing and 39C of motor inboard Granted temperature and and outboard vibration. bearings.

Pump 2.5.1 IWP-3100 Measure XPP-13A and 13B Measure Interim C.1 pump flow rate differential Relief and vibration, pressure in Expires recirculation path end of quarterly and next R0 -

disassemble and inspect pumps annually.

Pump 2.6.1 IWP-?l00 Measure XPP-43A, 43B, Measure pump Interim D.1 pump flow rates. and 43C differential Relief pressure monthly in Expires recirculation flow end of path, next R0 Pump 2.1.1 IWP-3220 Analyze All pumps in Review test data Relief E.1 pump test data the IST within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> Denied within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. program. excluding weekends and holidays.

Pump 2.7.1 IWP-3100 Heasure XPP-48A, 488, Disassemble and Interim F.1 pump bearing and 48C inspect the pumps Relief temperature and annually. Expires vibration, end of next R0

, Page'No. 2 01/07/88 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY

' NUMBER & SUBJECT TESTING USNRC Valve App. A Exercise during Agree A.1 cold shutdowns.

Valve App A Exercise during Agree A.2 cold shutdowns.

Valve App. A Exercise during Agree A.3 cold shutdowns.

Valve App. A Exercise during Agree A.5 cold shutdowns.

Valve 3.9.1 IWV-3417 IVV-7096 Take corrective Relief A.6 Trending valve actions only if Denied stroke times. measured stroke time exceeds 5 seconds.

Valve App. A Exercise during Agree B.1 cold shutdowns.

Valve 3.2.1 IWV-3521 Test XVC-8481A, Partial-stroke Relief B.2 frequency. 8481B, and exercise quarterly Granted 8481C and full-stroke exercise during refueling outages.

Valve App. A Exercise during Agree B.7 cold shutdowns. ,

Valve App. A Exercise during Agree B.8 cold shutdowns.  ;

Valve App. A Exercise during Agree B.9 cold shutdowns.

Valve App. A Exercise during Agree B.10 cold shutdowns.

Valve App. A Exercise during Agree ,

8.11 cold shutdowns.

L ,

i Page No. 3' I, 01/07/88 i

VIRGIL C. SUMMER NUCLEAR STATION I

TABLE 1

SUMMARY

OF RELIEF REQUESTS l

RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF- BY NUMBER & SUBJECT TESTING USNRC

'l

)

l

. Valve 3.9.1 IWY-3417 XVG-8107 Take corrective- Relief '

B.12 Trending valve actions only if Denied stroke times. measured stroke time exceeds 10 seconds, f Valve 3.9.1 IWV-3417 XVG 8108 Take corrective Relief l

B.13 Trending valve actions only if Denied stroke times. measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 LCV-II5C and Take corrective Relief B.14 Trending valve ll5E actions only if Denied  !

stroke times, measured stroke time exceeds 10 seCoDds.

Valve 3.9.1 IWV-3417 XVT-8104 Take corrective Relief l B.15 Trending valve actions only if Denied i stroke times. measured stroke l time exceeds 10 l seconds.

Valve App. A Exercise during Agree C.1 cold shutdowns.

Valve App. A Exercise during Agree ,

C.2 cold shutdowns.

t Valve App. A Exercise during Agree C3 cold shutdowns.

Valve App. A Exercise during Agree C.4 cold shutdowns.

Valve App. A Exercise during Agree C.5 cold shutdowns.

Valve App. A Exercise during Agree C.6 cold shutdowns,

'Page No. 4-

, 01/07/88 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD 0F BY NUMBER & SUBJECT TESTING USNRC Valve 3.3.1 IWV-3521 XVC-1022A, Disassemble, Relief C.7 Exercise check 10228, 1034A, inspect, and Granted valves to safety and 1034B manually exercise positions during each quarterly, refueling outage.

Valve App. A Exercise during Agree C.8 cold shutdowns.

Valve App. A Exercise during Agree D.1 cold shutdowns.

Valve 3.9.1 IWV-3417 XVG-1611A, Take corrective Relief D.2 Trending valve 16118, and actions only if Denied stroke times. 1611C measured stroke time exceeds 5 seconds.

Valve App. A Exercise during Agree D.4 cold shutdowns.

Yalve App. A Exercise during Agree D.5 cold shutdowns.

I Valve 3.4.1.! IWV-3411 Test XVG-2660 Exercise valve Relief F.1 frcquency. during refueling Denied outages.

Valve App. A Exercise during Agree F.2 cold shutdowns.

Valve 3.4.1.2 IWV-3411 Test XVG-2662A and Exercise valve Relief F.3 frequency. 26628 during refueling Denied outages.

Valve App. A Exercise during Agree G.1 cold shutdowns.

Valve 3.9.1 IWV-3417 XVM-2801A, Take corrective Relief G.3 Trending valve 28018, and actions only if Denied stroke times. 2801C measured stroke time exceeds 5 seconds, t . . . , - . . . . . _ . - - .. .- - - -- , . . . . - - _ . _

'Page No. 5 01/07/88 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC Valve 3.9.1 IWV-3417 XVG-2869A, Take corrective Relief G.4 Trending valve 28698, and actions only if Denied stroke times. 2869C measured stroke time exceeds 10 seconds.

Valve App. A Exercise during Agree J.1 cold shutdowns.

Valve 3.5.2.1 IWV-3521 Test XVC-8997A, Full-stroke Relief J.2 frequency. 89978, and exercise valves Granted 8997C during refueling outages. ,

Valve 3.5.2.2 IWV-3521 Test XVC-8995A, Full-stroke Relief J.3 frequency. 8995B, and exercise valves Granted >

8995C during refueling outages.

Valve App. A Exercise during Agree J.4 cold shutdowns.

. Valve App. A Exercise during Agree J.5 cold shutdowns.

Valve 3.5.2.3 IL'V 3521 Test XVC-8990A, Full-stroke Relief J.6 frequency. 8990B, and exercise valves Granted 8990C during refueling outages.

Valve 3.5.2.4 IWV-3521 Test XVC-8992A, Full-stroke Relief J.7 frequency. 8992B, and exercise valves Granted 8992C during refueling outages.

Valve 3.5.2.5 IWV-3521 Test XVC-8948A, Disassemble, Relief J8 frequency. 89488, 8948C, inspect, and Granted 8956A, 89568, manually exercise and 8956C valves each refueling outage.

t

' Page No. 6

, 01/07/88 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC Valva App. A Exercise during Agree J.9 cold shutdowns.

Valve App. A Exercise during Agree J.11 cold shutdowns.

Valve 3.5.4 IWV-3521 Test XVC-8926 Full-stroke Relief J.12 frequency. exercise valve Granted during refueling outages.

Valve App. A Exercise during Agree J.13 cold shutdowns.

Valve App. A Exercise during Agree J.14 cold shutdowns. ,

Valve 3.5.2.6 IWV-3521 Test XVC-8993C Full-streke Ralief J.15 frequency. exer:ise valves Granted during refueling outages.

Valve 3.5.1.1 IWV-3411 Test XVG-8801A and Exercise valves Relief J.16 frequency. 83018 curing refueling Granted outages.

Valve 3.5.1.2 IWV-3411 Test XVG-8888A and Exercise valves at Relief J.17 frequency. 8888B cold shutdowns when Denied one loop of LHSI can be taken out of service. ,

Valve 3.5.3 IWV-3411 Test XVG-8809A and Exercise valves at Relief ,

J.18 frequency. 8809B cold shutdowns when Denied one loop of LHSI can be taken out of service.

Valve 3.9.1 IWV-3417 XVG-8801A and Take corrective Relief J.19 Trending valve 8801B actions only if Denied stroke times, measured stroke time exceeds 10 seconds.

- - . . . . , _ . _ . - .m.___ _ __. . , . , - _ _ , - _ - - _ , , _ , - -

Page No. 7 01/07/88 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC Valve 3.9.1 IWV-3417 XVG-8885 Take corrective Relief J.20 Trending valve actions only if Denied stroke times. measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVG-8884 Take corrective Relief J.21 Trending valve actions only if Denied stroke times, measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVG-8886 Take corrective Relief J.22 Trending valve actions only if Denied stroke times, measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVG-8945A anj Take corrective felief J.23 Trending valve 8945B actions only if Denied stroke tires. measured stroke tir,e exceeds 10 SGConds.

Valve 3.9.1 IWV-3417 XVG-8942 Take corrective Relief J.24 Trending valve actions only if Denied stroke times, meacured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVG-8803A and Take corrective Relief J.25 Trending valve 8803B actions only if Denied stroke times. measured stroke time exceeds 10 seconds.

Valve 3.5.1.3 IWV-3300 Verify XVG-8811A and Verify remote Relief J.26 . remote position 88118 position indication Denied indication every once every 5 years.

2 years.

l l

i f

Page No. 8

' 01/07/88 4 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY I NUMBER & SUBJECT TESTING USNRC Valve 3.6.2 IWV-3521 XVC-3009A and Disassemble, Relief K.1 Exercise check 30098 inspect, and Granted valves to safety manually exercise positions during each quarterly, refueling outage.

Valve App. A Exercise during Agree K.2 cold shutdowns.

Valve 3.6.3 IWV-3521 XVC-3013A and Disassemble, Relief K.3 Exercise check 30138 inspect, and Granted l valves to safety manually exercise i positions during each l quarterly. refueling outage.

! Valve 3.6.1 IWV-3300 Verify XVG-3004A and Verify remote Relief K.4 remote position 3004B position indication Denied indication every once every 5 years.

2 years.

Valve App. A Exercise during Agree L.1 cold shutdowns, j Valve 3.9.1 IWV-3417 XVT-3104, 3165, Take corrective Relief L.2 Trending valve and 3169 actions only if Denied stroke times. measured stroke time exceeds 10 seconds.

Valve App. A Exercise during Agree M.1 cold shutdowns.

Valve App. A Exercise during Agree N.1 cold shutdowns.

Valve 3.9.1 IWV-3417 XVB-0001A, Take corrective Relief N.2 Trending valve 0001B, 0002A, actions only if Denied stroke times. and 00029 measured stroke time exceeds 5 seconds.

1

' Page No. 9 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF .TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC Valve 3.1.1 IWV-3421 thru All passive Leak test valves to Cenditio P.1 3427 Measure containment Appendix J and nal leakage rate of isolation Technical Relief Category A valves Specifications Granted valves, requirements.

Valve App A Exercise during Agree Q.1 cold shutdowns.

Valve 3.9.1 IWV 3417 PCV-445A and Take corrective Relief Q.2 Trending valve 444B actions only if Denied stroke times. measured stroke time exceeds 2 seconds.

Valve 3.9.1 IWV-3417 PCV-4458 Take corrective Relief Q.3 Trending valve actions only if Denied stroke times, measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVG-8000A, Take corrective Relief Q.4 Trending valve 8000B, and actions only if Denied stroke times. 8000C measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVX-6050A and Take corrective Relief R.1 Trending valve 6054 actions only if Denied stroke times, measured stroke time exceeds 5 seconds.

Valve 3.9.1 IWV-3417 XVG-6056 an/ Take corrective Relief R.2 1 rending valve 6057 actions only if Denied stroke times, measured stroke

, time exceeds 5 seconds.

Valve 3.9.1 IWV-3417 XVG-6066 and Take corrective Relief R.3 Trending valve 6067 actions only if Denied stroke times. measured stroke time exceeds 5 seconds.

Page No. 10 VIRGIL C. SUMMER NUCLEAR STATION TABLE 1 SVHMARY OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING VSNRC Valve 3.7.1 IWV-3300 Verify XVX-6050A and Verify closed Relief R.4 remote position 6054 position indication Denied indication every by Appendix J leak 2 years. testing, open indication not verified.

Valve 3.9.1 IWV-3417 FCV-0602A and Take corrective Relief S.1 Trending valve 0602B actions only if Denied stroke times. measured stroke time exceeds 10  :

seconds.

Valve 3.9.1 IWV-3417 XVG-8706A and Take corrective Relief S.2 Trending valve 8706B actions only if Denied stroke times, measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-S417 MVT-6412A, Take corrective Relief T.1 Trending valve 64128, 6490A, actions only if Denied stroke times. and 6490B reasured stroke time exceeds 5 seconds.

Valve 3.9.1 IWV-3417 MVT-6384A, Take corrective Relief T.2 Trending valve 63848, 6385A, actions only if Denied stroke times, and 6385B measured stroke time exceeds 10 seconds.

Valve 3.9.1 IWV-3417 XVG-6516, 6517, Take corrective Relief T.3 Trending valve 6518, and 6519 actions only if Denied stroke times, measured stroke time exceeds 7.5 seconds.

Valve 3.8.1 IWV-3300 Verify XVX-9339, 9341, Verify closed Relief U.1 remote position 9356A, 93568, position indication Denied t indication every 9357, 93648, by Appendix J leak 2 years. 9364C, 93658, testing, open 9365C, 9387, position not 9398A, 9398B, verified, and 9398C

1 Page No. 11 01/07/88

, VIRGIL G. SUttER NUCLEAR STATION TABLE 2

SUMMARY

OF RELIEF REQUESTS GRANTED UNDER 10 CFR 50,55afa)(6)(i)

RELIEF REQUEST TER BURDEN IF CODE NUMBER SECTION IMPRACTICALITY RE0'TS IMPOSED Pump 2.3.1 Lack of installed Shutdown until instruments B.1 flow instruments. are procured and installed.

Pump 2.4.1 Pump deaign precludes Significant redesign and B.2 measurement of replacement, vibration per code.

Pump 2.5.1 Lack of installed Shutdown until instruments C.1 flow-instruments. are procured and installed.

Pump 2.6.1 Lack of installed Shutdown until instruments 0.1 flow instruments, are procured and installed.

Pump 2.7.1 Lack of installed Shutdown until instruments F.1 flow instruments, are procured and installed.

Valve 3.2.1 System design Reactor trip and reactor B.2 precludes full stroke head removal.

exercising quarterly and at CSD. * .

Valve 3.3.1 System design S/G chemistry contamination.**

C.7 precludes full stroke exercising quarterly and at CSD.

Valve 3.5.2.1- System design Reactor shutdown and reactor J.2 precludes full stroke head removal, exercising quarterly and at CSD.

Valve 3.5.2.2 System design Thermal stress to injection J.3 precludes full stroke piping and reactor head exercising quarterly removal, and at CSD.

Valve 3.5.2.3 System design Thermal stress to injection J.6 precludes full stroke piping and reactor head exercising quarterly removal, and at CSD.

• CSD - cold shutdown

• • S/G - steam generator

n' Page'12 1

• 01/07/88 VIRGIL G. SUMMER NUCLEAR STATION TABLE 2 (CONTINUED)

SUMMARY

OF RELIEF REQUESTS GPANTED UNDER 10 CFR 50.55afo){6)(i)

RELIEF REQUEST TER . BURDEN IF CODE NUMBER SECTION IMPRACTICALITY RE0'TS IMPOSED Valve 3.5.2.4 System design Thermal stress to injection J.7 precludes full stroke piping and reactor head exercising quarterly removal.

and at CSD.

Valve 3.5.2.5 System design Reactor shutdown, reactor J.8 precludes full stroke head removal and reactor exercising quarterly internals damage.

and at CSD.

Valve 3.5.4 System design Reactor shutdown and reactor J.12 precludes full stroke head removal.

exercising quarterly and at CSD.

Valve 3.5.2.6 System design Thermal stross to injection J.15 precludes full stroke piping and reactor head exercising quarterly removal, and at CSD.

Valve 3.5'.1 1 System design Reactor shutdown and damage J.16 precludes full stroke to injection piping.

exercising quarterly and at CSD.

Valve 3.6.2 System design Eceipment damage in K1 precludes full stroke cv '

nment, exercising quarterly and at CSD.

Valve 3.6.3 System design Equipment damage in K.3 precludes full stroke containment and chemistry exercising quarterly containment of RWST.*

and at CSD.

• RWST - refueling water sto' e tank

,