ML040490823

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Unit 1, License Amendment Surveillance Requirement 4.0.5, Associated Basis and Bases 3/4.4.2, 3/4.4.6 and 3/4.4.10
ML040490823
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 02/18/2004
From: Cotton K
NRC/NRR/DLPM/LPD2
To: Byrne S
South Carolina Electric & Gas Co
Cotton K R, NRR/DLPM, 301-415-1438
References
TAC MC0834
Download: ML040490823 (18)


Text

February 18, 2004 Mr. Stephen A. Byrne Senior Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, South Carolina 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: SURVEILLANCE REQUIREMENT 4.0.5, ASSOCIATED BASIS, AND BASES 3/4.4.2, 3/4.4.6 AND 3/4.4.10 (TAC NO. MC0838)

Dear Mr. Byrne:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 166 to Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station (VCSNS), Unit No. 1.

The amendment changes the Technical Specifications (TSs) in response to your application dated July 29, 2003, as supplemented January 12, 2004.

This amendment revises language and references in the Surveillance Requirement (SR) 4.0.5, associated Basis, and Bases 3/4.4.2, 3/4.4.6, and 3/4.4.10. In the current plant TSs, the reference for inservice testing (IST) and inservice inspection (ISI) activities is the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME BPV Code),

Section XI. The licensee proposed to reference the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and the ASME BPV Code,Section XI for IST activities and ISI activities, respectively. These changes reflect the fact that the pump and valve testing requirements previously contained in Subsections IWP and IWV of the ASME BPV Code,Section XI, have been replaced by the requirements in the 1998 Edition of the ASME OM Code, 2000 Addenda, for the licensees third 120-month IST interval. These TS changes are required to implement the VCSNS third 120-month IST program update in accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR)

Section 50.55a(f)(5)(ii). In addition, the licensee proposed to add definitions for double the quarterly (3 month) frequency, and biennially or every two years as used in the ASME OM Code, to SR 4.0.5b. The licensee also proposed to delete and testing from the discussion of the Structural Integrity Program and delete wording associated with obtaining relief in accordance with 10 CFR 50.55a(g)(6)(i) from Basis 3/4.4.10, because structural integrity is verified by ISI (not IST) and because TSs need not specify the provision under which relief from structural integrity requirements may be granted.

S. Byrne A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's Biweekly Federal Register notice.

Sincerely,

/RA/

Karen R. Cotton, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 166 to NPF-12
2. Safety Evaluation cc w/enclosures: See next page

ML040490823

  • SE Input **NLO w/Changes NRR-058 OFFICE PDII-1/PM PDII-2/LA DE/EMEB*

OGC**

PDII-1/SC NAME KCotton BClayton DTerao RHoefling JNakoski DATE 2/17/04 2/11/04 09/23/03 2/5/04 2/11/04

SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY DOCKET NO. 50-395 VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 166 License No. NPF-12 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by South Carolina Electric & Gas Company (the licensee), dated July 29, 2003, as supplemented January 12, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Facility Operating License No. NPF-12 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 166, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. South Carolina Electric &

Gas Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: February 18, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 166 TO FACILITY OPERATING LICENSE NO. NPF-12 DOCKET NO. 50-395 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3/4 0-2 3/4 0-2 3/4 0-3 3/4 0-3 B 3/4 0-3 B 3/4 0-3 B 3/4 4-2 B 3/4 4-2 B 3/4 4-5 B 3/4 4-5 B 3/4 4-15 B 3/4 4-15

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 166 TO FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By application dated July 29, 2003, as supplemented January 12, 2004, South Carolina Electric

& Gas Company (SCE&G, the licensee) requested changes to the Technical Specifications (TSs) for the Virgil C. Summer Nuclear Station (VCSNS). The proposed changes would revise references in the Surveillance Requirement (SR) 4.0.5, associated Basis, and Bases 3/4.4.2, 3/4.4.6, and 3/4.4.10. In the current plant TS the reference for inservice testing (IST) and inservice inspection (ISI) activities is the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME BPV Code),Section XI.

The supplemental letter dated January 12, 2004, provided clarifying information that was within the scope of the initial notice and did not change the initial proposed no significant hazards consideration determination.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(f)(5)(ii), requires that, if a revised inservice test program for a facility conflicts with the TSs for that facility, the licensee shall apply to the Commission for amendment of the TSs to conform the TSs to the revised program. The licensee shall submit this application, as specified in 10 CFR 50.4, at least 6 months before the start of the period during which the provisions become applicable, as determined by 10 CFR 50.55(f)(4).

As required by 10 CFR 50.92, a proposed license amendment for a facility licensed under 10 CFR 50.22 shall not: (i) involve a significant increase in the probability or consequences of an accident previously evaluated; or (ii) create the possibility of a new or different kind of accident from any accident previously evaluated; or (iii) involve a significant reduction in a margin of safety.

It is stated in 10 CFR 51.22 that an environmental assessment or environment impact statement for a license amendment is not required if: (i) the amendment involves no significant hazards consideration, (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

The VCSNS third 120-month IST interval begins on August 1, 2004, and ends on July 31, 2014.

The previous VCSNS 120-month IST interval was developed based on the ASME BPV Code,Section XI, Subsections IWP and IWV for pumps and valves. Pursuant to 10 CFR 50.55a(f),

the upcoming 120-month IST interval is required to be developed in accordance with the 1998 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) including the 1999 and 2000 Addenda. The 1998 ASME OM Code, 2000 Addenda, replaced Subsections IWP and IWV of the previous edition of ASME BPV Code. By letter dated July 29, 2003, the licensee, proposed several changes to the VCSNS TSs in order to reflect the deletion of Subsections IWP and IWV from the ASME BPV Code,Section XI. Also, the licensee proposes to add surveillance interval definitions for double the quarterly (3 month) frequency and biennially or every two years as used in the ASME OM Code. NUREG-1482, Section 6, Revised Standard Technical Specifications, supports the addition of biennially or every two years frequency and recommends that licensees revise their TSs prior to the periodic IST Program update.

The NRCs findings with respect to authorizing or denying the TS amendment are given below.

3.0 TECHNICAL EVALUATION

3.1 General License Amendment Request (LAR) 03-1864 In the LAR 03-1864 the licensee states that the proposed TS amendment will:

a)

Update SR 4.0.5 to reflect the deletion of Subsections IWP and IWV from ASME Section XI with approval of the 2000 Addenda.

The Bases for 4.0.5, 3/4.4.2 and 3/4.4.10 are also being revised to reflect the applicability of the ASME OM Code to inservice testing activities.

b)

Incorporate the recommendations of NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Section 6, Revised Standard Technical Specifications, and revise SR 4.0.5 to facilitate implementation of the 3rd Interval IST Program.

c)

Add the ASME OM Code biennial frequency and increased frequency interval for quarterly tested pumps in an Alert status to SR 4.0.5b.

d)

Revise Bases 3/4.4.10 to clarify the applicability of ASME Section Xl to inservice inspection activities and delete reference to Relief Request requirements, which are processed in accordance with the regulations under 10 CFR 50.55a.

3.2 Specific License Amendment Requested According to the LAR 03-1864, the specific changes will revise the following:

a)

TS 4.0.5 and Bases SR 4.0.5 and the Bases are being revised to reflect the applicability of ASME Section XI to the conduct of inservice inspection activities, and the ASME OM Code for inservice testing activities. The change will be accomplished by referencing the applicable Code and Addenda for these activities as required by 10 CFR 50.55a, and deleting specific reference to Section Xl of the ASME Boiler and Pressure Vessel Code.

The Bases are also being revised to delete the discussion associated with the TS definition of OPERABLE that conflicts with the ASME Boiler and Pressure Vessel Code provision, which allows a 24-hour grace period before declaring a valve incapable of performing its specified function inoperable.

TS 4.0.5 TS 4.0.5 is being revised to delete (g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

TS 4.0.5b Additional terminologies for the conduct of inservice inspection and inservice testing activities are being defined. The frequencies include the biennial, or every 2 year frequency of the ASME OM Code and increased frequency interval for quarterly tested pumps in an ASME OM Code Alert status, where the corrective actions of the Code require doubling the testing frequency.

Bases 3/4.4.2 Reference to Section Xl of the Boiler and Pressure Vessel Code is being deleted for overpressure device testing and replaced with the ASME OM Code.

Bases 3/4.4.6 Reference to the ASME Code, Section Xl, Part OM-10 is being replaced by the ASME OM Code.

Bases 3/4.4.10 The Bases is being revised to reflect the fact that maintaining the structural integrity of ASME Code Class 1, 2 and 3 components is an inservice inspection activity by deleting and testing. References to Relief Request approval requirements will also be deleted from the Bases.

Summary of Specific Changes1 Page Affected Section Bar Description of Change Reason for Change 3/4 0-2 4.0.5a 4.0.5b 1

Rewrite of 4.0.5 a., b. - Reworded to remove reference to Section XI.

a. - Removed prescriptive relief statement.

General reference to ASME Code encompassesSection XI and OM Code for all inservice testing and inspection requirements.

3/4 0-3 4.0.5b 4.0.5e 1

Rewrite of 4.0.5

b. - Remove specific reference to Boiler and Pressure Vessel Code; Added double the quarterly and biennial frequency.
e. - Remove specific reference to Boiler and Pressure Vessel Code.

General reference to ASME Code encompassesSection XI and OM Code for all inservice testing and inspection requirements and to add frequency definitions applicable to ASME OM Code.

B 3/4 0-3 4.0.5 1

Rewrite of 4.0.5 - Remove specific reference to Boiler and Pressure Vessel Code. Identified ASME OM Code for pump and valve surveillance.

General reference to ASME Code encompassesSection XI and OM Code for all inservice testing and inspection requirements.

B 3/4 4-2 3/4.4.2 1

Remove specific reference to Boiler and Pressure Vessel Code.

Identified ASME OM Code for valve surveillance.

ASME OM Code is appropriate 3rd interval Code for valve surveillance.

B 3/4 4-5 3/4.4.6 1

Remove specific reference to Boiler and Pressure Vessel Code.

Identified ASME OM Code for valve surveillance ASME OM Code is appropriate 3rd interval Code for valve surveillance.

B 3/4 4-15 3/4.4.10 1

Rewrite to remove reference to 10CFR 50.55a(g)(6)(i) prescriptive relief statement In accordance with current 10 CFR 50.55a (g).

1

Reference:

LAR 03-1864, Attachment 1, pages 1-2 3.3 Basis for License (TS) Amendment According to the licensee:

TS amendments to SR 4.0.5 are required in order to comply with the periodic IST Program requirements of 10 CFR 50.55a(f)(4)(ii). SR 4.0.5 directs that IST activities are conducted in accordance with ASME Section XI, but the applicable edition of the ASME Code for the third IST Program update directs that IST activities are conducted in accordance with the ASME OM Code. Therefore, revision of SR 4.0.5 and associated Basis is requested to reflect the applicable test Codes specified in 10 CFR 50.55a.

Basis for SR 4.0.5 is being revised to delete a cited example of a conflict with ASME Section XI and the TS definition of OPERABLE because the Section XI of the ASME BPV Code will no longer be applicable to the conduct of IST activities. In addition, the licensee states that, the ASME OM Code does not contain a similar provision that would allow a 24-hour grace period before declaring a component inoperable when the component is incapable of performing its design function.

The revision of TS 4.0.5 prior to the IST update is a recommendation in NUREG-1482, Section 6, and the amendment of TS 4.0.5 will eliminate a potential TS noncompliance during NRC review of Relief Requests from impractical ASME OM Code requirements submitted prior to the start of the new interval, and discovered during the early months of implementation.

The addition of biennial or 2 year frequency terminology to SR 4.0.5b is supported by NUREG-1482, Section 3.1.3. The increased frequency for quarterly inservice tested pumps in an Alert status has also been added to SR 4.0.5b in accordance with the corrective actions of ASME OM Code.

Basis 3/4.4.2 is being revised to reflect the requirement during the third IST interval to perform overpressure device testing to the ASME OM Code, replacing ASME Section Xl for compliance with the periodic update requirements of 10 CFR 50.55a(f)(4)(ii).

Basis 3/4.4.6 is being revised to delete reference to Part OM-10 for the correction of RCS

[reactor coolant system] pressure isolation valve leakage collected at less then full functional differential pressures. Part 10 of the ASME OM Code is not applicable for the performance of valve IST during the third interval due to the periodic update requirements of 10 CFR 50.55a(f)(4)(ii). OM Part 10, Paragraph 4.2.2.3(b)(4) and ISTC-3630(b)(4) of the ASME OM Code utilize the same correction equation for leakage rates collected at less than full functional differential pressure, therefore, this change does not alter any technical requirement.

Basis 3/4.4.10 is being revised to delete and testing from the discussion of the Structural Integrity Program, and delete wording associated with obtaining relief in accordance with 10 CFR 50.55a(g)(6)(i). ISI activities maintain the structural integrity of Code Class piping systems and supports. IST activities monitor the operational readiness of components by monitoring critical performance parameters against baseline values. The requirements for relief are being deleted based on the fact that this requirement is covered by the regulation, 10 CFR 50.55a.

Requested changes meet the requirements of 10 CFR 50.92 for No Significant Hazards Consideration, since the TS amendment does not, (i) involve a significant increase in the probability or consequences of an accident previously evaluated, or (ii) create the possibility of a new or different kind of accident from any accident previously evaluated, or (iii) involve a significant reduction in a margin of safety. Also, the proposed changes meet the requirements of 10 CFR 51.22 for categorical exclusion of environmental assessment, since the TS amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) a significant increase in individual or cumulative occupational radiation exposure.

3.4 Evaluation of LAR 03-1864 The licensees amendment request proposes revisions to TS SR 4.0.5, associated Basis, and TSs Bases 3/4.4.2, 3/4.4.6, and 3/4.4.10.

Existing TSs SR 4.0.5a and 4.0.5b are related to ISI of ASME Code Class 1, 2 and 3 components and IST of ASME Code Class 1, 2 and 3 pumps and valves. The SR 4.0.5a states that IST shall be performed in accordance with Section XI of the ASME BPV Code and applicable addenda as required by 10 CFR 50.55(a). The proposed change to TS SR 4.0.5a revises reference to IST of ASME Code Class 1, 2, and 3 pumps and valves, and states that IST of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with the ASME OM Code and applicable addenda as required by 10 CFR 50.55a. The SR 4.05b currently states that the surveillance intervals for ISI and IST activities shall be in accordance with ASME BPV Code,Section XI. The proposed change to SR 4.05b revises reference to IST, and states that the surveillance intervals for ISI and IST shall be in accordance with the applicable ASME Code and Addenda. The proposed changes to SR 4.0.5a and SR 4.0.5b are necessary to implement the VCSNS third 120-month interval IST Program in a manner consistent with the TS. The staff finds this proposed TS SR change to be acceptable.

The deletion of the wording associated with obtaining relief from SR 4.0.5a does not change the meaning or purpose of SR 4.0.5a and does not relinquish the licensee of its responsibility to seek relief from Code test requirements when they are impractical. The language in SR 4.0.5a relating to obtaining relief from the ASME Code is redundant to specific requirements in 10 CFR 50.55a. Therefore, the TS does not need to make reference to the requirements of 10 CFR 50.55a regarding the need to obtain relief from the Code.

Existing TS SR 4.0.5b addresses the following surveillance intervals: weekly, monthly, quarterly, semiannually, every 9 months, and yearly; but it does not address the surveillance intervals of double the quarterly (e.g., used when pumps hydraulic parameters in the alert range), and biennially or every 2 years. The proposed TS SR 4.0.5b change would add, Double the Quarterly and Biennially surveillance intervals to the list of required frequencies for performing ISI and IST activities. The proposed change will maintain consistency with the ASME Code requirements. Therefore, the staff finds this proposed TS amendment to be acceptable.

The proposed change to SR 4.0.5e removes the reference to the ASME BPV Code, and makes a more general reference to the applicable ASME Code. SR 4.0.5 addresses SRs for both inservice inspection and testing of ASME Code Class 1, 2, and 3 components. Therefore, the staff finds the reference change from the ASME BPV Code to an applicable ASME Code to be acceptable, because IST and ISI requirements are now contained in separate Codes.

The proposed change to TS Basis 4.0.5 removes the reference to the ASME BPV Code for IST of ASME Code Class 1, 2, and 3 pumps and valves, and makes reference to IST of ASME Code Class 1, 2 and 3 pumps and valves that will be performed in accordance with a periodically updated edition and addenda of the ASME OM Code as required by 10 CFR 50.55a. In addition, the proposed change to TS Basis 4.0.5 removes an example that states, the TS definition of OPERABLE does not grant a grace period before a device that is not capable of performing its specified functions is declared inoperable and takes precedence over the ASME BPV Code provision, which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable. This example is no longer applicable to the ASME OM Code, because the ASME OM Code does not contain a provision that allows a 24-hour grace period before declaring inoperable a component that is incapable of performing its design function. Operational readiness is addressed and satisfied in the ASME OM Code. The OM Code states the pump shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established. The proposed changes are necessary to implement the VCSNS third 120-month interval IST program, since TS Basis need to make appropriate reference of the ASME Code.

Existing TS Basis Section 3/4.4.2 states, in part, that demonstration of the safety valves lift settings will be performed in accordance with the provisions of Section XI of the ASME BPV Code. The proposed change to TS Basis 3/4.4.2 revises reference to the source of requirements for the IST of ASME Code Class 1, 2, and 3 pumps and valves to the ASME OM Code. The proposed change is necessary to implement the VCSNS third 120-month interval IST program, since the TS Basis needs to make appropriate reference of the ASME Code.

Existing TS Basis Section 3/4.4.6 states, in part, that leakage from RCS Pressure Isolation Valves may be identified by surveillance testing performed during plant heatup or cooldown above 2000 psig and may be adjusted to obtain the leakage value at 2235 plus or minus 20 psig using calculation guidance provided by ASME Code Section XI, Part OM-10. The proposed change to TS Basis 3/4.4.6 revises reference to the source of requirements for the IST of ASME Code Class 1, 2, and 3 pumps and valves to the ASME OM Code. The proposed change is necessary to implement the VCSNS third 120-month interval IST program, since the TS Basis needs to make appropriate reference of the ASME Code.

Existing TS Basis Section 3/4.4.10 states, in part, that the inservice inspection and testing programs for ASME Class 1, 2 and 3 components ensure that structural integrity and operational readiness of these components will be maintained at an acceptable level throughout the life of the plant. The proposed change to Basis 3/4.4.10 deletes and testing because structural integrity of ASME Class 1, 2 and 3 components is verified by ISI, not IST.

The deletion of the wording associated to obtain relief in Basis 3/4.4.10 does not change the meaning or purpose of Bases 3/4.4.10. The words in Basis 3/4.4.10, about obtaining relief from the ASME Code, are redundant to specific requirements in 10 CFR 50.55a. Therefore, the TS Basis does not need to make reference to the requirements of 10 CFR 50.55a regarding the relief from the incorporated code. The staff finds that the deletion of the wording associated with obtaining relief from Basis 3/4.4.10 to be acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (68 FR 59219). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The proposed changes to TS SR 4.0.5, associated Basis and Bases 3/4.4.2, 3/4.4.6 and 3/4.4.10 comply with the requirements of 10 CFR 50.92, no significant hazards consideration, since the TS amendment does not: (i) involve a significant increase in the probability or consequences of an accident previously evaluated, or (ii) create the possibility of a new or different kind of accident from any accident previously evaluated, or (iii) involve a significant reduction in margin of safety.

Also, the proposed changes comply with the requirements of 10 CFR 51.22 and do not require an environmental assessment, since the TS amendment does not involve, (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

The NRC staff finds that the proposed TS changes are required to comply with the requirements of 10 CFR 50.55a (f)(5)(ii) for the third 120-month IST Program update of VCSNS and concludes that the proposed changes to SR 4.0.5, associated Basis, and Bases 3/4.4.2, 3/4.4.6, and 3/4.4.10 as described in the LAR 03-1864 are acceptable.

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy, Section 50.55a, Codes and Standards.

2.

Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy, Section 50.92, Issuance of amendment.

3.

Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 51, Chapter I, Title 10, Energy, Section 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review.

4.

U.S. Nuclear Regulatory Commission, Guidance for Inservice Testing at Nuclear Power Plants, NUREG-1482, April 1995.

5.

American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.

6.

American Society of Mechanical Engineers Operation and Maintenance Code, Inservice Testing of Nuclear Power Plant Components.

Attachment:

NRC Summary Chart Principal Contributor: Joel Rivera-Ortiz Date: February 18, 2004

ATTACHMENT Summary of TS Amendment Virgil C. Summer Nuclear Station Third 120-month Inservice Testing Interval Page Affected Section Amendment Remarks 3/4 0-2 Applicability SR 4.0.5a SR 4.0.5b Rewrite of 4.0.5 SR 4.0.5a & b. - Reworded to remove reference to Section XI.

SR 4.0.5a. - Removed prescriptive relief statement.

Acceptable 3/4 0-3 Applicability SR 4.0.5b SR 4.0.5e Rewrite of 4.0.5 SR 4.0.5b. - Remove specific reference to Boiler and Pressure Vessel Code; added double the quarterly and biennial frequency.

SR 4.0.5e. - Remove specific reference to Boiler and Pressure Vessel Code.

Acceptable B 3/4 0-3 Applicability Basis 4.0.5 Rewrite of Basis 4.0.5 - Remove specific reference to Boiler and Pressure Vessel Code. Identified ASME OM Code for pump and valve surveillance. Remove example of TS precedence over ASME Code.

Acceptable B 3/4 4-2 Reactor Coolant System Basis 3/4.4.2 Remove specific reference to Boiler and Pressure Vessel Code.

Identified ASME OM Code for valve surveillance.

Acceptable B 3/4 4-5 Reactor Coolant System Basis 3/4.4.6 Remove specific reference to Boiler and Pressure Vessel Code.

Identified ASME OM Code for valve surveillance.

Acceptable B 3/4.4-15 Reactor Coolant System Basis 3/4.4.10 Rewrite to delete and testing and to remove reference to 10CFR 50.55a(g)(6)(i) prescriptive relief statement.

Acceptable

Mr. Stephen A. Byrne VIRGIL C. SUMMER NUCLEAR STATION South Carolina Electric & Gas Company cc:

Mr. R. J. White, Nuclear Coordinator S.C. Public Service Authority c/o Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 802 Jenkinsville, South Carolina 29065 Resident Inspector/Summer NPS c/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, South Carolina 29065 Chairman, Fairfield County Council Drawer 60 Winnsboro, South Carolina 29180 Mr. Henry Porter, Assistant Director Division of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Mr. Jeffrey B. Archie, General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 300 Jenkinsville, South Carolina 29065 Mr. Ronald B. Clary, Manager Nuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, South Carolina 29065 Ms. Kathryn M. Sutton, Esquire Winston & Strawn Law Firm 1400 L Street, NW Washington, DC 20005-3502

DISTRIBUTION FOR VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: SURVEILLANCE REQUIREMENT 4.0.5, ASSOCIATED BASIS, AND BASES 3/4.4.2, 3/4.4.6 AND 3/4.4.10 (TAC NO. MC0838)

Dated: February 18, 2004 Hard Copy:

Public PDII-1 R/F BClayton (hard copy)

E-Mail:

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RidsNrrDlpmLpdii1 (JNakoski)

RidsNrrPMKCotton RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn2MailCenter (KLandis)

JRivera-Ortiz TBoyce RidsNrrDlpmDpr GHill (2)