ML081560651

Request for Additional Information, Emergency Action Level Review

ML081560651
Person / Time
Site:	Summer
Issue date:	06/16/2008
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 MD6874
Download: ML081560651 (7)

Text

June 16, 2008 Mr. Jeffery B. Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1, REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY ACTION LEVEL REVIEW (TAC NO. MD6874)

Dear Mr. Archie:

By letter dated September 28, 2007 to the U.S. Nuclear Regulatory Commission (NRC), the South Carolina Electric and Gas Company (SCE&G, the licensee) requested NRC review and approve a proposed change to the emergency action level (EAL) scheme used at the Virgil C. Summer Nuclear Station (VCSNS). On May 28, 2008, the NRC staff held a telephone discussion with the SCE&G staff regarding some process changes and issues associated with the NRC review of changes to emergency plans and EALs. The Procedure and Script for Licensee Calls Concerning Changes in Processing Emergency Plan And Emergency Action Level Reviews outline for the discussion is available in the Agencywide Documents and Accession Management System (ADAMS), Accession No. ML081410466. As a result of the NRC staff review, a need for additional information was identified, as stated in the enclosure.

Please provide a response the enclosed requests for additional information within thirty (30) days of receipt of this letter.

If you have any questions, please contact me at 301-415-1493.

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 w/enclosure: See next page

June 16, 2008 Mr. Jeffery B. Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1, REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY ACTION LEVEL REVIEW (TAC NO. MD6874)

Dear Mr. Archie:

By letter dated September 28, 2007 to the U.S. Nuclear Regulatory Commission (NRC), the South Carolina Electric and Gas Company (SCE&G, the licensee) requested NRC review and approve a proposed change to the emergency action level (EAL) scheme used at the Virgil C. Summer Nuclear Station (VCSNS). On May 28, 2008, the NRC staff held a telephone discussion with the SCE&G staff regarding some process changes and issues associated with the NRC review of changes to emergency plans and EALs. The Procedure and Script for Licensee Calls Concerning Changes in Processing Emergency Plan And Emergency Action Level Reviews outline for the discussion is available in the Agencywide Documents and Accession Management System (ADAMS), Accession No. ML081410466. As a result of the NRC staff review, a need for additional information was identified, as stated in the enclosure.

Please provide a response the enclosed requests for additional information within thirty (30) days of receipt of this letter.

If you have any questions, please contact me at 301-415-1493.

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:

Safety Evaluation cc w/enclosure: See next page DISTRIBUTION:

Public RidsAcrsAcnw&mMailCenter RidsOgcRp LPL2-1 R/F RPedersen, NRR RidsNrrDorlLp2-1 RidsRgn2MailCenter RidsNrrPMRMartin RidsNrrLAGLappert ADAMS Accession: ML081560651 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NSIR NRR/LPL2-1/BC NAME RMartin GLappert KWilliams MWong DATE 6/16/08 6/5/08 05/29/08 6/16/08 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 (VCSNS)

DOCKET NO. 50-395 1

RAI EAL QUESTION Explain the apparent inconsistency in the terms dose rate (milli Rems/hour 1 VARIOUS (mR/hr)) and dose (milli Rems, (mRem)), throughout the September 28, 2007, submittal.

Explain in more detail why credit for the alternate ac power supply (AAC) should 2 VARIOUS be given in the VCSNS EAL scheme.

Explain the addition of the statement and releases are not terminated within 3 RU1.2 60-minutes to the last paragraph of the generic bases.

4 RU2.1 Explain the use of unexpected instead of unplanned in the generic bases.

5 RA2.1 Explain how SCE&G will differentiate between RA2.1 and RU2.1.

Explain why the Central Alarm System (CAS) and Secondary Alarm System (SAS) is necessary for declaration instead of just CAS or just SAS?

6 RA2.3 Explain why the bases wording provided in the guidance was not used.

The identified Mode Applicability for CU1.1 is Mode 5 and 6. Your Basis information seems to imply Mode 1-4 applicability, for example, to affect a safe shutdown Why is that information relevant to CU1.1?

7 CU1.1 Also, please discuss the context of the phrase Although the AAC is not designed for DBA loads, with respect to the remainder of the Basis.

CG2.1 The last bullet in Table C-4 requires further explanation. The applicability is to 8 ANY unplanned pressure rise in containment. No evaluation is expected or CG2.2 justified. Please explain.

9 CA3.1 What is the scale for the instrument(s) that will indicate the 10-psig value?

1 In a discussion with SCE&G on May 28, 2008, the Procedure and Script for Licensee Calls Concerning Changes in Processing Emergency Plan And Emergency Action Level Reviews provided in ADAMS Accession No. ML081410466, SCE&G indicated that it would adopt the Nuclear Energy Institute 99-01, Revision 5 guidance document for EALs with no deviations. Accordingly, no RAIs related to adopting NEI 99-01 Revision 5, wording have been included in these RAIs.

1 RAI EAL QUESTION Can the Radio system inform the NRC?

CU4.1 Is the satellite phone system an ordinary means of communication, or tested 10 frequently? If tested, how often and where is this controlled?

SU4.2 Why are the other FTS phones (HPN, etc.) not used?

11 CU5.1 How is the last sentence of paragraph 1 (basis) applicable to this EAL?

Elaborate on the timeliness of the actions needed to asses the annunciators and 12 HU1.1 retrieve data, including the availability of qualified personnel to make this determination.

Explain why an EAL for hurricanes, seiche, etc, as stated in the guidance, is not 13 NEI HU1.5 provided?

HU3.1 Elaborate on how it was determined that paragraph 1 of the generic basis is 14 correct.

HA3.1 15 HU6.1 Justify the inclusion of the last paragraph of the bases.

SA2.1 Why is Hot Standby included as an Operating Mode for SA2.1?

16 SS2.1 Only actions taken at the reactor control console can be considered, not tripping the turbine or other control room actions that cause a trip. Elaborate on why this SG2.1 is considered appropriate or revise to be consistent with the guidance.

The last paragraph, Significant transients are listed . . . is incomplete. Please 17 SA4.1 provide a complete sentence/paragraph.

Why is the last sentence of the first paragraph in the generic basis section 18 SU5.2 included? Please elaborate.

Explain in more detail why no other loss or potential loss thresholds were 19 FB developed.

Virgil C. Summer Nuclear Station cc:

Mr. R. J. White Nuclear Coordinator S.C. Public Service Authority c/o Virgil C. Summer Nuclear StationPost Office Box 88, Mail Code 802 Jenkinsville, SC 29065 Resident Inspector/Summer NPS c/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, SC 29065 Chairman, Fairfield County Council Drawer 60 Winnsboro, SC 29180 Mr. Henry Porter, Assistant Director Division of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, SC 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, SC 29065 Mr. Bruce L. Thompson, Manager Nuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, SC 29065 Ms. Kathryn M. Sutton Morgan, Lewis & Bockius LLP 111 Pennsylvania Avenue, NW.

Washington, DC 20004