ML091530050

Commitment Reduction Summary Report

ML091530050
Person / Time
Site:	Summer
Issue date:	05/29/2009
From:	Archie J South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML091530050 (2)

Text

Jeffrey B. Archie Vice President,Nuclear Operations 803.345.4214 May 29, 2009 A SCANA COMPANY Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 COMMITMENT REDUCTION

SUMMARY

REPORT A review of VCSNS's Commitment Reduction Program, which was developed following NEI 99-04 "Guidelines for Managing NRC Commitment Changes", determined that South Carolina Electric & Gas (SCE&G) did not notify the NRC of three previously performed commitment reductions. This oversight has been entered into the station's corrective action program. The three commitment reductions, which were not communicated to the NRC, are attached.

Should you have any questions, please call Mr. Bruce Thompson at (803) 931-5042.

Very truly yours, rey B. Archie JW/JBA/gr Attachment c: K. B. Marsh R. E. Martin S. A. Byrne NRC Resident Inspector N. S. Carns K. M. Sutton J. H. Hamilton NSRC R. J. White RTS (CR-08-04855)

K. J. Browne File (810.46)

L. A. Reyes PRSF (RC-09-0065)

)4ý)01 SCE&G I Virgil C.Summer Nuclear Station

• P.0.Box 88 . Jenkinsville, South Carolina 29065 -T(803) 345.5209 - www.scana.com

Document Control Desk Attachment CR-08-04855 RC-09-0065 Page 1 of 1 After a review of commitment reductions performed by VCSNS, it was determined that three commitment reductions previously performed were not reported to the NRC, as required by NL-121 "Regulatory Commitment Reduction". The following commitment reductions, with a brief justification were performed in 1999:

990001 Relaxation of Staff Position in GL 83-28, Item 2.2, Part 2, & SCE&G response to GL 90-03 The periodic contact of non-NSSS vendors commitment made in response to GL 90-03 was deleted based on the ongoing program of vendor interface existing in Engineering Services Procedure ES-507 "Vendor Manual Review and Approval".

990109 Elimination of the Commitment to Danger Tag 120 VDC Control Power Breakers This commitment was made in error; danger tagging the 120 VDC control power breakers would not have prevented NRC violation 93-17-02. In addition to not being deemed a corrective action from the Root Cause Analysis of the above violation, it was determined that danger tagging these breakers created a safety hazard due to their location (tight confines in proximity to energized equipment). As an alternative, the 120 VDC Control Power Breakers were added to the "Component Realignment and Verification Log," which satisfies the NRC's concern about independent verification for initial tagging and restoration.

990374 Replacement of Reliability Centered Maintenance The requirements of this commitment were superseded by 10CFR50.65 "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants".