ML062340002
| ML062340002 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/24/2006 |
| From: | Martin R NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | Archie J South Carolina Electric & Gas Co |
| Martin R, NRR/DORL, 415-1493 | |
| References | |
| TAC MD2057 | |
| Download: ML062340002 (5) | |
Text
October 24, 2006 Mr. Jeffrey Archie 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 REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY (TAC NO. MD2057)
Dear Mr. Archie:
The Nuclear Regulatory Commission staff is reviewing the license amendment application for the Virgil C. Summer Nuclear Station dated May 24, 2006, concerning steam generator tube integrity and find that we need additional information as identified in the enclosure.
Please contact me if you have any questions.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395
Enclosure:
Request for Additional Information cc: See next page
ML0623340002 NRR-088 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/CSGB/BC NRR/LPL2-1/BC NAME RMartin CSola AHiser EMarinos DATE 10/24/06 10/24/06 08/25/06 10/24/06
REQUEST FOR ADDITIONAL INFORMATION TUBE INTEGRITY TECHNICAL SPECIFICATION APPLICATION (TSTF-449)
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
By letter dated May 24, 2006Property "Letter" (as page type) with input value "RC-06-0084, License Amendment Request - LAR 05-3594, Steam Generator Tube Integrity" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. (ML061500440 [Agencywide Document Access and Management System Accession Number]), South Carolina Electric and Gas Company (SCE&G, the licensee),
submitted a request to revise the Virgil C. Summer Nuclear Station (VCSNS) technical specification (TS) requirements in response to Technical Specification Task Force (TSTF)
Standard Technical Specification Change Traveler, TSTF-449, "Steam Generator Tube Integrity,"
Revision 4 (ML051090200).
1.
Provide a clarification regarding the difference between Attachment II to SCE&Gs application, Proposed Technical Specification Changes (Mark-Up), and Attachment III, Proposed Technical Specification Changes (Retyped), such as for SR 4.4.6.2.1.d, wherein the retyped TS page adds and controlled leakage that was not included in the markup version.
2 Provide a confirmation that all aspects of the proposed revised Bases for the operational leakage TS 3/4.4.6.2 are in agreement with the current VCSNS approved design and licensing bases.
3.
TSTF 449, Revision 4, discusses steam generator (SG) Repair Criteria in Chapter 4, Section 10, and discusses SG Repair Methods in Section 12. The Revision History for the TSTF states:
All references to repairing SG tubes which satisfy the tube repair criteria are bracketed. If tube repair methods have been approved for a particular plant, the material in the brackets will be retained. For those plants without approved tube repair methods, the material is not incorporated in the plant-specific Specifications.
The proposed inserts for VCSNS TS 3/4.4.5, 6.8.4.k, 6.9.1.12 and Bases sections sometimes incorporate the bracketed TSTF references for SG repair methods and sometimes do not incorporate them. Since provisions for the repair of SG tubes are not currently included in the VCSNS TSs, discuss your plans for removing all references to repair, as designated by the bracketed information in the TSTF.
4.
Proposed Action in LCO 3.4.6.2.b states:
With any UNIDENTIFIED LEAKAGE, IDENTIFIED LEAKAGE, or CONTROLLED LEAKAGE greater than the above limits, reduce the leakage rate to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Since the proposed definition for IDENTIFIED LEAKAGE in TS 1.15.c includes primary to secondary leakage, this proposal is not consistent with TSTF-449, nor is it consistent with the changes proposed for Limiting Condition for Operation (LCO) 3.4.6.2.a. TSTF-449 does not permit 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to reduce PRIMARY TO SECONDARY LEAKAGE to within limits, as discussed in Chapter 4, Technical Analysis, Section 2, Operational LEAKAGE Actions of the TSTF. Please revise LCO 3.4.6.2.b to exclude PRIMARY TO SECONDARY LEAKAGE from this action statement.
5.
Proposed TS 6.9.1.12 appears to be inconsistent with TSTF-449 since it places an additional qualifier on the reporting requirements. Please discuss your plans to modify your reporting requirements such that the report will be submitted following "completion of an inspection" rather than "completion of a steam generator tube inspection."
Mr. Jeffrey B. Archie 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. Thomas D. Gatlin, 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