ML12270A301

Issuance of Amendment

ML12270A301
Person / Time
Site:	Summer
Issue date:	10/12/2012
From:	Martin R Plant Licensing Branch II
To:	Gatlin T South Carolina Electric & Gas Co
Martin R
References
TAC ME8952
Download: ML12270A301 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555..0001 October 12, 2012 Mr. Thomas D. Gatlin 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, ISSUANCE OF AMENDMENT (TAC NO. ME8952)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 192 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit No.1, in response to your letter dated June 29,2012, as supplemented on September 12, September 20, and October 10, 2012. The amendment adds Notes to Technical Specification 3.5.4, for the refueling water storage tank (RWST) to allow administrative control of the seismically qualified RWSTJnon-seismic spent fuel pool purification loop interface. This change would only be applicable for the next two fuel cycles.

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

Sincerely.

~~~anager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 192 to NPF-12

2. Safety Evaluation cc wJencls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY DOCKET NO. 50-395 VIRGIL C. SUMMER NUCLEAR STATION, UNIT No.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 192 Renewed License No. NPF-12

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by South Carolina Electric & Gas Company (the licensee), dated June 29,2012, as supplemented on September 12, September 20, and October 10, 2012, 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

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 Renewed 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. 192, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed 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 thirty (30) days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-12 Date of Issuance: October 12, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 192 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 DOCKET NO. 50-395 Replace the following page of the License with the enclosed page as indicated. The revised page is identified by amendment number and contains a marginal line indicating the areas of change.

Remove Page Insert Page License License License No. NPF-12, page 3 License No. NPF-12, page 3 Technical Specification Technical Specification 3/4 5-9 3/4 5-9

(3)

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The technICal SpN"IflClliOtlI contaInId In ApperIcb A. "1IIY!led 1hrough Amendment ~:19ant... EnWonmenIld ProfectIori pian cOnIafned n Appendix B,...~ IncarporatId In..........-d bnIe. South Carolina EItCIdC, Gil Con.,...,.... op.... the faclllly In 4ICIC:OIdanc:e with the TechnlClIl SpedfIcatfont.Itd the EfWirormenlil PI'OIIC'b\\ PIIn.

Renewed FacUlty OperatinQ L.1oan88 No. NPF*12

_ndlllCnt rb. 192

,. ~.',, *. '-,'.. *1 EMERGENCY CORE COOLING SYSTEMS 314.5.4 REFUELING WATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.5.4 The refueling water storage tank (RWST) shall be OPERABLE with:

a.

A minimum contained borated water volume of 453,800 gallons,

b.

A boron concentration of between 2300 and 2500 ppm of boron. and

c.

A minimum water temperature of 40°F.

APPLICABILITY: MODES 1. 2, 3 and 4.

ACTION:

With the refueling water storage tank inoperable. restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN 'Nithin the follo'Ning 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.5.4 The RWST shall be demonstrated OPERABLE:

a.

At least once per 7 days by:

1.

Verifying the contained borated water volume in the tank. and

2.

Verifying the boron concentration of the water.

b.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWST temperature when the outside air temperature is less than 40"F.

• RWST piping may be unlsolated from non-safety related piping for s 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under administrative controls to perform SR 4.5.4.a.2.

RWST piping may be unisolated from non-safety related piping for S 30 days (cumulative) per fuel cycle under administrative controls for filtration.

These alignments cannot be used after RF-22 (Fall 2015).

SUMMER - UNIT 1 3/45-9 Amendment No. 44. 5e. e1,192

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 192 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION. UNIT 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By letter dated June 29,2012, as supplemented September 12, September 20, and October 10, 2012, (Agencywide Documents Access and Management System Accession Nos.

ML121850005, ML12258A073, ML12268A319 and to be assigned, respectively), South Carolina Electric & Gas Company (SCE&G, the licensee), submitted a license amendment request (LAR) for the Virgil C. Summer Nuclear Station (VCSNS), Unit No.1.

The amendment changes Technical Specification (TS) "Refueling Water Storage Tank" (RWST) 3.5.4 (TS 3.5.4) such that the non-seismically qualified piping of the Spent Fuel Pool (SFP) purification system may be connected to the RWST's seismically qualified piping by manual operation of a seismically qualified RWST boundary valve. This action would be performed under administrative controls for limited periods oftime specified as (a) up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for performance of surveillance requirement 4.5.4a.2, which is done at least once per 7 days, to verify the boron concentration of the RWST water and (b) up to 30 days cumUlative per fuel cycle for filtration.

These changes cannot be used after refueling outage RF-22 (Fall 2015).

As stated in the June 29, 2012 LAR: "During plant operation in Modes 1 through 4, the RWST is required to be operable to maintain a borated water supply for accident mitigation purposes. The RWST is the source of suction for the Residual Heat Removal pumps and the Containment Spray pumps during normal operation (Modes 1 through 4). The suction of the charging pumps is automatically aligned to the RWST on a Safety Injection signal. During refueling operation (Modes 5 and 6), the RWST is required to be operable as a borated water supply should the boric acid storage system not be operable. The contents of the RWST are also used to fill the refueling cavity during refueling operation. The water in the RWST is borated to a concentration sufficient to ensure that shutdown margin is maintained when the reactor is at cold shutdown conditions should RWST water be added to the reactor." To be considered operable, the RWST must meet the water volume, boron concentration, and temperature limits established in the TS surveillance requirements (SRs). SR 4.5.4.a.2 requires sampling the RWST contents at least once per 7 days to verify boron concentration is within limits.

- 2 Historically, until October 11, 2011, VCSNS was periodically using the SFP Purification Loop to filter the RWST water while in plant conditions and modes for which the RWST was required to be operable. The licensee utilized the alignment for RWST water mixing prior to weekly surveillance sampling of the boron concentration as required by TS SR 4.5.4.a.2. The licensee also used this alignment prior to refueling outages to filter the RWST water. The license used procedure changes to direct manual operator action to isolate the RWST from the SFP Purification Loop in the event of a Reactor Trip or at the direction of the Shift Supervisor. The operation was discontinued as a result of information in the Institute of Nuclear Power Operations (INPO) operating experience report number 33653 and NRC Information Notice (IN) 2012-01, "Seismic Considerations - Principally Issues Involving Tanks" (IN 2012-01) (ADAMS Accession No. ML11292A175).

Proposed Changes The proposed change is to add the following Note to TS 3.5.4:

"RWST piping may be unisolated from non-safety related piping for s; 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under administrative controls to perform SR 4.5.4.a.2".

"RWST piping may be unisolated from non-safety related piping for s; 30 days (cumulative) per fuel cycle under administrative controls for filtration".

"These alignments cannot be used after [Refueling Outage] RF-22 (Fall 2015)".

The NRC staff's review of the LAR identified that additional clarifying information was needed.

The supplemental submittal dated September 12, 2012, provided such information for the reactor systems review. The supplemental submittals dated September 20 and October 10,2012, provided such information for the accident dose analysis review. These supplements provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on July 24,2012 (77 FR 43379).

2.0 Regulatory Evaluation The Commission's regulatory requirements related to the contents of TS, set forth in Title 10 of the Code ofFederal Regulations (10 CFR), Section 50.36, require that the TS limiting conditions for operations are consistent with assumed values of the initial conditions in the licensee's safety analyses. Section 50.36(c)(2)(i) states: "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

NRC Information Notice (IN) 2012-01, "Seismic Considerations - Principally Issues Involving Tanks" stated that it provided examples and references to events in which licensees failed to recognize various seismic considerations and system alignment issues that could impact safety.

Examples were identified in which licensees failed to recognize that aligning non-seismic piping to the RWST would require TS [Limiting Conditions for Operation] action statement entry, system modifications, or license amendments. The IN noted that TS would not allow applying

- 3 compensatory measures, such as manual actions in place of the closed boundary valve, for periods longer than the TS completion time for restoring the RWST to operable status, unless the TS expressly permit operation under such measures. The licensee's LAR of June 29, 2012, demonstrates that the licensee recognizes the circumstances described in the IN including the need to apply for amendment of TS 3.5.4 such that the TS would expressly permit operation under the specific measures of RWST recirculation for surveillance requirement purposes and filtration to improve the quality of the water for refueling activities. Accordingly, as noted in the licensee's letter dated June 29, 2012, the licensee applied for amendment of its facility operating license, including the TS, pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit." This safety evaluation addresses the staff's review of that application, and its supplements.

Title 10 of the Code of Federal Regulations, Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," establishes the minimum requirements for the principle design criteria of nuclear power plants.

Regulatory Guide 1.13 (RG 1.13), "Spent Fuel Storage Facility DeSign Bases," contains guidance for the design of spent fuel storage facilities to ensure conformance with the relevant GDCs.

Regulatory Position C.6 states that drains or permanently connected systems that could reduce the coolant inventory to unsafe levels should not be installed. Regulatory Position C.13 states that a filtering system should be provided to remove radioactive materials and other contaminants from the spent fuel pool coolant.

3.0 TECHNICAL EVALUATION

3.1 Reactor Systems Review 3.1.1 Regulatory Evaluation The regulatory requirements and guidance utilized by the staff for this section are 10 CFR 50.36, GDC-2, GDC-35 and NRC IN 2012-01. GDC-2 and GDC-35 provide:

General Design Criterion 2 (GDC-2), "Design Bases for Protection Against Natural Phenomena,"

requires that the systems, structures, and components (SSC) important to safety be designed to withstand natural phenomena such as earthquakes.

GDC 35 - "Emergency core cooling," requires that a system to provide abundant emergency core cooling shall be provided. The safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

This evaluation is based on the staff's review of the June 29, and September 12, 2012 submittals.

-4 3.1.2 Technical Evaluation 3.1.2.1 Licensee's Discussion of Provisions for Using RWST Isolation Valve The information in the licensee's June 29 and September 12,2012, submittals that is applicable to the reactor systems review is as follows:

During plant operation in Modes 1 through 4, the RWST is required to be operable to maintain a borated water supply for accident mitigation purposes. The RWST is aligned to the suction of the residual heat removal pumps and the containment spray pumps during normal operation in Modes 1 through 4. The suction of the charging pumps is automatically aligned to the RWST on a safety injection signal. During refueling operation in Modes 5 and 6, the RWST is required to be operable as a borated water supply should the boric acid storage system not be operable. The contents of the RWST are also used to flood the refueling cavity during refueling operation. The water in the RWST is borated to a concentration sufficient to ensure shutdown margin is maintained when the reactor is at cold shutdown conditions should RWST water be added to the reactor.

The SFP Purification Loop is a subsystem of the spent fuel pool cooling system that is connected to portions of the RWST piping. The SFP Purification Loop piping is non-safety grade and not seismically qualified. During an evaluation of a seismic event, the failure of the non-seismic SFP Purification Loop piping must be considered. Such a failure could potentially result in a loss of RWST inventory should the ASME code boundary valve between the RWST and the SFP Purification Loop be open with the SFP Purification Loop aligned to the RWST.

The licensee's final safety analysis report (FSAR) states, "The spent fuel cooling system cools spent fuel pool water to remove decay heat from the spent fuel elements. It also provides for purification of the water in the spent fuel pool and RWST, provides for transfer of water between the RWST and spent fuel pool, maintains boron concentrations, monitors radiation levels and monitors and maintains spent fuel pool water level to ensure adequate cooling and shielding."

The FSAR also states that the design basis of the spent fuel cooling system includes: "Provide for filtering and/or demineralization to clean the water in the RWST."

The primary function of the SFP Purification Loop is to maintain the optical clarity of the spent fuel pool water avoiding delays and providing for safer handling of the fuel. This system is also used to purify the refueling water in the refueling canal and RWST. Prior to refueling outages, the SFP Purification Loop is also used to re-circulate the RWST water to ensure a representative sample for the required boron concentration surveillance. Also before refueling outages, the SFP Purification Loop is used to filter the RWST prior to filling the refueling cavity.

The surveillance testing of the RWST boron concentration requires sampling of the tank contents every seven days. The licensee mixes the RWST by re-circulating it to receive accurate sample results. The alignment for recirculation requires unisolating the RWST piping from the SFP Purification Loop which is non-safety related and not seismically qualified. In order to perform the alignment, the licensee has credited manual operator action to close the RWST piping's seismically qualified isolation valve in the event of a seismic event.

-5 The licensee proposes to add notes to LCO 3.5.4 to allow the SFP Purification Loop to be aligned to the RWST to perform recirculation of the RWST for required weekly boron concentration sampling. The notes would allow this alignment under administrative controls. These administrative controls include stroking the manually operated boundary valve open and closed prior to circulating the RWST water through the SFP Purification System, establishing a designated operator to control the valve, and establishing a preplanned communication method between the operator and the Shift Supervisor. The notes would only be allowed to be applied through refueling outage RF-22.

The operator designated to perform the manual action on the boundary valve will be a part of the normal shift compliment. The procedure does not allow this operator to be part of the fire brigade.

The operator will also be required to stay within the seismically qualified Auxiliary Building (AB) and Control Building (CB) 412 foot elevation. The designated operator will be a licensed operator or a valve operator qualified auxiliary operator. The control room operator is required to participate in a brief with the designated operator. The control room operator will be responsible for contacting the designated operator and directing performance of the action and the method of communication will be addressed during the required brief. The operator actions required by the designated operator in the AB are to secure the SFP Purification Pump, and manually close the RWST Isolation valve XVT06701-SF. The SFP Purification Pump control is located in the AB at the 412 foot elevation. The operator then has to walk down a corridor and exit the AB into the CB, climb a stair tower, and descend a ladder to shut XVT06701-SF at the base of the RWST. The designated operator is briefed to be readily available and able to secure the RWP pump and close XVT06701-SF within 10 minutes. The operators are required to carry flashlights and radios.

The XVT06701-SF valve constitutes the boundary between the seismic Category 1 piping to the RWST and the downstream attached non-safety related piping. The XVT06701-SF valve is a typical 3-inch manually operated globe valve. The XVT06701-SF valve is located in the vertical piping run at approximately 413.5 feet elevation in the RWST pit. The total length downstream of the valve that is seismically supported is approximately 15 feet. Code Class 2 support SIH-1469 is located on the horizontal pipe section at the 402.5 foot elevation.

Prior to recirculation, the operator will be required to stroke the valve XVT06701-SF open and then closed. Stroking the manually operated boundary valve XVT06701-SF open and closed prior to performing circulation through the loop allows the operators to observe that the valve functions properly. If any discrepancies are noted with XVT06701-SF during the operation, the operator will be required to stop and contact the Control Room for instructions.

The licensee indicated in its September 12, 2012, submittal that during a seismic event, should the SFP Purification Loop be severed, it would drain at approximately 468 gallons per minute (gpm). This flow rate would take approximately 32.2 minutes for the RWST to drain out of the 3 inch pipe and down to its minimum TS required level for FSAR accident analyses. The administrative controls require the valve be closed within 10 minutes of the initiating event.

Maintaining the RWST at the 94 percent level provides 22.2 minutes of margin between when the valve is administratively required to be closed and when the TS minimum level of the RWST would be reached. The main control board is provided with an RWST Lo Level Alarm at 93 percent level point. The time that it takes from when the Lo Level Alarm comes in at 93 percent until when the TS required level is reached is 21.5 minutes. This leaves 11.5 minutes of margin between when the valve is administratively required to be closed and when the TS minimum level of the RWST would be reached. The licensee described scenarios in which they evaluated the

-6 time it would take the operator to reach and secure the pump and then reach and operate the valve. The licensee found that when they stationed the designated operator at the furthest credible point from the valve, the time to complete the isolation of the RWST from the SFP Purification Loop was approximately 5 minutes and 48 seconds with an additional 2 minutes conservatively added to operate the valve. The staff has found that the licensee has provided reasonable assurance that the RWST will be isolated from the SFP Purification Loop within the procedurally required 10 minutes.

The licensee evaluated the failure to isolate the leak path as a single failure. As a result of the valve XVT06701-SF being the assumed single failure, all of the ECCS and Reactor Building Spray System pumps and other equipment would function. The licensee found that the failing to close the boundary valve was not the limiting single failure for NPSH calculations or switchover times.

3.1.2.2 Summary and Conclusion The staff has reviewed the proposed TS changes to TS 3.5.4 regarding allowing non-seismically qualified piping of the SFP Purification System to be connected to the RWST seismic piping by manual operation of a RWST seismically qualified boundary valve under administrative controls for limited time periods. The limited time periods are up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for performance of SR 4.5.4.a.2 and up to 30 cumulative days per fuel cycle for filtration of the RWST water. The changes are to be applied only for the next two cycles. They cannot be used after Refueling Outage RF-22 (fall 2015). The staff has concluded that there is reasonable assurance that the isolation valves will remain intact during a seismic event and that the designated operator will be able to perform the required functions within the procedurally required 10 minute completion time.

Further the staff has found that there is reasonable assurance that the RWST will remain above the TS minimum required level in the event of a seismic event. Therefore, the NRC staff has concluded that the proposed TS change is acceptable from a reactor systems perspective.

3.2 Balance of Plant 3.2.1 Regulatory Evaluation The regulatory requirements and guidance utilized by the staff for this section are GDC-2, NRC IN 2012-01, and RG 1.13. This evaluation is based on the staffs review of the licensee's June 29, 2012 submittal.

3.2.2 Technical Evaluation As specifically discussed above in Section 2.0, the licensee's LAR dated June 29, 2012, proposed changes to TS 3.5.4 that would support recirculation of the RWST through the SFP Purification Loop for adequate mixing prior to performance of SR 4.5.4.a.2. This change also supports extended use of the SFP Purification Loop to filter the RWST contents prior to refueling outage operations.

Following Reactor Coolant System (RCS) pipe ruptures, the VCSNS RWST provides a source of water to the charging pumps, residual heat removal pumps, and reactor building spray pumps.

The tank contains a minimum volume of 453,800 gallons of water as required per LCO 3.5.4.a.

The RWST is safety related and seismically qualified. The SFP Purification Loop, a SUb-system

- 7 of the SFP Cooling System, provides purification of the water in the SFP and RWST. The components of the SFP Purification Loop are non-safety related and not seismically qualified.

SR 4.5.4.a.2 requires verification of the boron concentration of the RWST water at least once per 7 days. In order to obtain the most accurate sample, the RWST contents should be mixed to preclude any stratification since the last sampling. The licensee has stated that the only method of recirculating the contents of the RWST is by using the SFP Purification Loop. This operation opens the RWST contents to the non-seismically qualified piping of the SFP Purification Loop and results in inoperability of the RWST, per the NRC staff interpretation communicated in IN 2012-01.

Filtration of the RWST water prior to refueling improves the visual clarity of the water in the refueling cavity. Visual clarity is a factor for reducing errors during fuel movement and other refueling activities performed underwater in the refueling cavity. This operation requires connecting the RWST to the SFP Purification Loop and recirculating the RWST water for an extended period of time. This operation also results in inoperability of the RWST.

If an earthquake were to cause the failure of non-seismically qualified SFP Purification Loop piping during the recirculation of the RWST, the RWST volume could begin to drain through the ruptured lines. As discussed in Section 4 and in Attachment 6 of the June 29,2012 LAR, the licensee has proposed compensatory measures to ensure that the RWST can be manually isolated from the SFP Purification Loop before the RWST volume drops below the amount credited in the UFSAR accident analysis. A briefed, dedicated operator will be stationed on the 412 foot elevation of the auxiliary building or control building. The instructions to the operator for stopping the SFP Purification Pump and closing the valve at the seismic boundary of the RWST within ten minutes are included in the plant System Operating Procedure 123, "Spent Fuel Cooling System," for which the change control processes of 10 CFR 50.59, "Changes, tests and experiments" apply.

The NRC staff has reviewed the LAR with respect to its impact on the SFP and refueling operations. Use of the SFP Purification Loop to re-circulate and purify the contents of the RWST has been performed at VCSNS prior to this submittal. The SFP Purification Loop is non-safety related and non-seismically qualified, and is therefore not required to maintain its integrity in the event of an earthquake. In accordance with GDC-2 and the guidance in RG 1.13, the SFP Purification Loop is connected to the SFP such that a rupture in any portion of the system will not drain the SFP below the design low water level.

Meeting SR 4.5.4.a.2 ensures that the RWST can perform its safety related function.

Recirculation of the RWST water is a desirable operation in order to ensure accurate sampling of the RWST boron concentration during the performance of SR 4.5.4.a.2. TS 3.5.4 is revised by the addition of a Note that provides a four-hour time limit for the performance of SR 4.5.4.a.2.

Filtration of the RWST water to improve visual clarity is desirable prior to entering a refueling outage. The compensatory measures proposed by the licensee for the response to a rupture in SFP Purification Loop piping will be the same during the verification of boron concentration or filtration activities. A 30-day per fuel cycle time limit for the filtration of the RWST water is proposed in the revised TS 3.4.5.

- 8 3.2.3 Summary and Conclusion The NRC staff finds that the proposed amendment will provide adequate protection for the RWST and SFP while the RWST is aligned to the SFP Purification Loop. In light of the routine nature of this operation at the VCSNS, the additional compensatory measures described by the licensee, and the proposed TS time limits, the NRC staff finds the proposed amendment to be acceptable from a balance-of-plant perspective.

3.3 Human Performance 3.3.1 Regulatory Evaluation The regulatory requirements and guidance utilized by the staff in its human factors review are as follows:

1.

Appendix A, "General Design Criteria [GOG] for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (10 CFR) Part SO, Criterion 19, "Control room," states: "A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.... Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures."

2.

Title 10 CFR, Section SO.120, "Training and qualification of nuclear power plant personnel," which requires the use of the systems approach to training for non-licensed operators, shift supervisors, shift technical advisors, instrumentation and controls technicians, electrical maintenance personnel, mechanical maintenance personnel, radiological protection technicians, and chemistry technicians.

3.

NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition": Chapter 13 addresses "Conduct of Operations",

specific sub-chapters considered in this review were Chapters 13.2.1, "Reactor Operator Requalification Program; Reactor Operator Training", and 13.S.2.1, "Operating and Emergency Operating Procedures". Chapter 18 provides review guidance for "Human Factors Engineering".

4.

NUREG-1764, "Guidance for the Review of Changes to Human Actions";

S.

GL 82-33, "Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability";

6.

NUREG-0700, "Human-System Interface Design Review Guidelines," Revision 2;

7.

NUREG-0711, "Human Factors Engineering Program Review Model," Revision 2;

8.

IN 97-78, "Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times".

- 9 This evaluation is based on the staff's review of the June 29,2012 LAR.

3.3.2 Technical Evaluation 3.3.2.1 Description of Operator Action(s) and Assessed Safety Significance The proposed TS change would revise TS 3.5.4, "Refueling Water Storage Tank" such that the non-seismically qualified piping of the Spent Fuel Pool (SFP) purification system may be connected to the RWST's seismically qualified piping by manual operation of an RWST seismically qualified boundary valve under administrative controls for limited periods of time. This action is conditional on assignment of a dedicated, qualified crew member to be available to isolate the RWST in a timely manner, so that it retains its safety function of being a source of reactor coolant during transients and accidents. This is proposed as an interim action until a design solution makes the action unnecessary (fall, 2015).

In accordance with the generic risk categories established in Appendix A to NUREG-1764, this task sequence is considered "risk-important" due to the fact that its failure would jeopardize the ECCS injection and recirculation phases of a LOCA. Because of its risk importance, the NRC staff performed a "Level One" review, i.e., the most stringent ofthe graded reviews possible under the guidance of NUREG-1764.

3.3.2.2 Operating Experience Review The overall issue of using non-seismic piping aligned with non-seismic system piping was discovered during a review of operating experience, as discussed in IN 2012-01. The Spent Fuel Pool Purification Loop has been used in the past at VCSNS, Unit 1, to perform mixing.

The licensee utilized operating experience from the Joseph M. Farley Nuclear Plant, Units 1 and 2, to develop the VCSNS operating strategy as well as to establish reasonable durations for weekly testing and pre-outage RWST purification.

A review of relevant Licensee Event Reports for the last twenty-five years was done by the staff to confirm that the proposed manual actions have an operating history of successful implementation.

No negative trends were identified. Based on the above, the staff finds the licensee's application of operating experience acceptable.

3.3.2.3 Functional Requirements Analysis and Function Allocation As stated in the guidance in NUREG-0711: "The objective of the functional requirements analysis and functional allocation review is to verify that the applicant has (1) defined the plant's functions that must be performed to satisfy plant safety objectives, and (2) that the allocation of those functions to human and system resources has resulted in a role for personnel that takes advantage of human strengths and avoids human limitations." In its LAR, the licensee has appropriately defined the required safety function of protecting the RWST inventory from inadvertent draining.

Prior experience has shown that operators, when assigned this task, had sufficient time and resources available to perform it reliably. The staff finds the licensee's approach to be acceptable based on the demonstration of adequate margin to proposed time constraints, prior successful

- 10 performance, and the licensee's intent, as stated on page 2 of Attachment 1 to the June 29, 2012 LAR, to implement "physical modifications to be made to the subject systems, eliminating the need for manual operator action."

3.3.2.4 Task Analysis Because this interim operator action is not a new action, the only aspect requiring reanalysis was the establishment of time constraints for the action sequence. The licensee indicates that given a break in the line containing the isolation valve, the available time for operator action to maintain RWST volume above the volume used in the FSAR accident analyses is 32.2 minutes and that the valve can be closed within 10 minutes to isolate the RWST from the non-seismic SFP Purification System. The design and operational values for the timing of the action sequence were validated (see Human Factors Verification and Validation, below). The walkthrough testing demonstrated adequate margin to the design time limit. The staff finds the licensee's task timing acceptable based on their validation of adequate margin to proposed time constraints.

3.3.2.5 Staffing Normal staffing and qualification are not affected by the proposed LAR. There are no new or additional qualifications required to perform the action sequence within the time constraints established. However, if a non-licensed operator is dedicated to the isolation function required by this LAR, they must be "valve operator" qualified.

3.3.2.6 Human-System Interface Design Human-System Interface (HSI) design, including the design of the Safety Parameter Display System will not be affected by the proposed LAR.

3.3.2.7 Procedure Design No changes are required to the Emergency Operating Procedures (EOPs). However, the existing operating procedure covering the action (Procedure SOP-123, Attachment 7 to the LAR), which is subject to the change control process of 10 CFR 50.59, does require changes to stipulate that the individual designated to perform the manual actions must be briefed. This brief covers the method of communication the operator will have with the control room, the limitations on location of the assigned operator (remain within the AB 412 foot and CB 412 foot elevation), the location of the valve to be manipulated, ingress and egress path, and the initiating conditions which require securing the valve. The procedure also requires that the isolation valve that isolates the RWST seismically qualified piping from the non-seismic piping of the SFP Purification System must be pre-tested each time that the RWST is aligned to the SFP. This revision will enhance operator understanding, and minimize the possibility of a single failure ofthe isolation valve. The staff finds the revised procedure acceptable based on the history of successful usage of the prior version and the licensee's validation and verification (V&V) of the revisions to the procedure to confirm its effectiveness (See 4.2.10 below for more information on V& V).

- 11 3.3.2.8 Training Program and Simulator Design Because the proposed action has a long history of successful implementation, and is supported by written procedures, the licensee concluded that additional training is not necessary. Based on the above, the staff finds that the training already provided is acceptable.

3.3.2.9 Human Factors Verification and Validation Time testing of the proposed action was performed to demonstrate sufficient margin to the licensee-established design values. The feasibility of the valve operator completing required actions within the time available was validated using Operations Administrative Procedure (OAP) 101.3, Timeline Validation of Required Operator Actions. A physical walkdown of the route to be taken by the dedicated valve operator was conducted, beginning at the furthest point from the valve within the operators restricted area and ending with the purification pump being secured.

The results of this study indicate that operators are able to isolate RWST flow to the non-seismic systems. The licensee also found that the operator action is achievable within the operational goal of 10 minutes as directed by procedure, providing substantial margin to the 32.2 minute value. Based on the results of these walkthrough demonstrations, the staff finds that the actions are feasible and can be reliably performed by the operators using the revised procedure within the conservative operational time established (ten minutes).

3.3.2.10 Human Performance Monitoring Strategy The procedures and actions proposed by this LAR will be included in licensee's configuration control program. This will ensure that subsequent changes to the plant, procedures, or programs will not invalidate the action or the credited action times. Based on the administrative protection against inadvertent change and the licensee's plan to obviate the manual action in the longer term by redesign, the staff finds the licensee's long-term monitoring strategy acceptable.

3.3.2.11 Summary Based on the statements provided by the licensee, i.e., that time-testing results demonstrate significant margin to design, that appropriate administrative controls will be applied to procedures, that a dedicated, qualified operator will perform the action, and that operators have substantial in-house operating experience, the staff concludes that the proposed LAR is acceptable from the human performance point of view.

3.4 Accident Dose Analysis 3.4.1 Regulatory Evaluation The regulatory requirements and guidance utilized by the staff for this section are 10 CFR 50.67, "Accident source term" and 10 CFR Part 50, Appendix A, Criterion 19, "Control room."

This evaluation is based on the staff's review of the June 29,2012, submittal and the September 20 and October 10, 2012 supplements.

- 12 3.4.2 Technical Evaluation The NRC staff reviewed the submittals noted above to assess the impact of the proposed changes on the licensing basis accident analyses approved by the staff for implementation of the alternative source term (AST) at VCSNS. The proposed changes involve the opening of safety related isolation valve (XVT06701) between seismic piping and non-seismic piping that was considered closed in accordance with the approved design basis accident analyses conducted to ensure compliance with 10 CFR 50.67 and GDC-19. The opening of the valve places the plant in an operational condition that is outside of the design assumptions considered in the radiological dose analysis for the period of time that the valve is open. Specifically, opening the valve creates the potential for a new radiological release pathway that is not available with the valve closed.

The licensee has proposed actions to restore the valve to the closed position in the event of an accident occurring during the time when the valve was open.

The staffs review considered a seismically induced core damage incident (Le., loss of off-site power (LOOP) and loss of coolant accident (LOCA)) and destruction of non-seismic piping downstream of the isolation valve (XVT06701) coupled with the failure of the isolation valve to close as indicated in the LAR. The likelihood of this scenario occurring is low. If a seismically induced core damage incident were to occur destroying the non-seismic piping downstream of the isolation valve (XVT06701), and the valve cannot be manually closed, there is a potential for recirculation fluid which leaks into the 20 inch reactor water storage tank (RWST) header to be released. This release pathway would be analyzed as an additional source of engineered safeguards features (ESF) leakage in the LOCA dose analysis. The staffs review also considered the impact of a release and determined the dose to the control room (CR) operator to be the limiting radiological dose because there is significant margin to the acceptance criterion of 25 rem total effective dose equivalent (TEDE) in the licensee's LOCA dose analysis for the exclusion area boundary and low population zone.

The licensee's licensing basis AST LOCA dose analysiS includes a dose contribution from ESF leakage. The contribution to the CR LOCA dose from ESF leakage is 0.283 rem TEDE based on an assumed ESF leak rate of 12,000 cubic centimeters per hour (cc/hr) or 0.053 gallons per minute (gpm). The remaining contributions to the CR LOCA dose amount to 0.726 rem TEDE. Since the CR accident dose acceptance criterion is 5 rem TEDE, there is a substantial margin (approximately 4 rem) in the dose analysis to accommodate an increase in ESF leakage.

The licensee provided additional information documenting a bounding assessment of leakage into the RWST header which concluded that the leakage could be as high as 0.1414 gpm. Assuming the dose from ESF leakage is directly proportional to the ESF leakage rate, the additional dose from the failed isolation valve would be approximately 0.755 rem. If this additional contribution to ESF leakage is factored into the CR LOCA dose analysis, the total dose to the CR operator would remain below the acceptance criterion. Therefore, the NRC staff finds with reasonable assurance that the licensee's proposed intermittent operation of isolation valve (XVT06701) through the next two fuel cycles is acceptable from a dose consequence perspective.

- 13 4.0 TECHNICAL SPECIFICATION ASPECTS 4.1 Regulatory Evaluation - Technical Specifications The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. This regulation requires that the TS include items in five specific categories.

These categories include (1) safety limits, limiting safety system settings and limiting control settings, (2) LCOs, (3) SRs, (4) design features, and 5) administrative controls.

Additionally, 10 CFR 50.36(d)(3) defines SRs as requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The staff reviewed the proposed changes for compliance with 10 CFR 50.36. In general, licensees must fully describe and justify the desired technical specification changes. The staff then makes a determination as to whether the proposed changes maintain adequate safety.

Changes that result in relaxation (less restrictive condition) of current TS requirements require detailed justification.

Licensees may revise the technical specifications provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The staff evaluated the TS changes contained in the licensee's amendment request by comparing them to the Requirements of 10 CFR 50.36.

4.2 Technical Evaluation - Technical Specifications The current VCSNS RWST TS require the RWST to be operable in MODES 1 through 4. Aligning the RWST with the SFP Purification Loop could render the RWST inoperable during a seismic event since the SFP Purification Loop consists of non-seismically qualified piping. The licensee states is Section 4 of Attachment 1 to its June 29, 2012, LAR that it is operationally desirable to re-circulate the RSWT contents to obtain the desired boron concentration sample accuracy, as well as for filtration of the RWST water prior to refueling outages. When the RWST is inoperable, the current RWST TS requires the RWST to be restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of being made inoperable. If the RWST is not restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the licensee is required to bring the plant to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The licensee proposed adding two notes to TS 3.5.4, as well as a footnote describing how long the notes would be applicable. The notes and footnote would read:

1)

RWST piping may be unisolated from non-safety related piping for s; 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under administrative controls to perform SR 4.5.4.a.2.*

2)

RWST piping may be unisolated from non-safety related piping for s; 30 days (cumulative) per fuel cycle under administrative controls for filtration. *

- 14

• UThese alignments cannot be used after [Refueling Outage] RF-22 (Fall 2015)."

The staff reviewed the proposed changes and determined that the changes are less restrictive than the licensee's current requirements. Based on the similarity of the actions to be performed for both notes with the precedent established for a plant of similar general design (Farley), the complexity of the RWST and SFP Loop including the number of valves to be repositioned and the fluid flow rates required to achieve the desired results, the staff concluded that both notes are acceptable. The staff determined that the footnote restricting the applicability of the notes to the next two fuel cycles is acceptable, given the complexity of developing a permanent solution to allow RWST sampling and filtration without reliance on manual actions to achieve isolation.

The licensee submitted proposed TS Bases pages that describe the notes, footnote, and some of the details of the administrative controls necessary to unisolate RWST piping. While the staff does not approve TS Bases pages, the staff did review the pages. The staff determined the TS Bases language is consistent with the licensee's justification for the proposed change.

4.3 Conclusions - Technical Specifications The staff determined that the proposed changes meet the regulatory requirements of 10 CFR 50.36. The staff determined the proposed change is less restrictive than the licensee's current requirements, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The staff determined that all proposed changes are acceptable.

5.0 Commitments No part of this safety evaluation relies on licensee commitments. The licensee provides a commitment to implement the amendment within 14 days; however, Section 3 of the NRC license amendment pages establish the time for effectiveness and implementation.

6.0 STATE CONSULTATION

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

7.0 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. 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (77 FR 43379, dated July 24,2012). 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 amendments.

- 15

8.0 CONCLUSION

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) there is reasonable assurance that 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.

Principal Contributor: J. Miller, NRR L. Ward, NRR E. Davidson, NRR G. W. Lapinsky, NRR M. Blumberg, NRR J. Parillo, NRR Date: October 12,2012

October 12, 2012 Mr. Thomas D. Gatlin 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, ISSUANCE OF AMENDMENT (TAC NO. ME8952)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 192 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit No.1, in response to your letter dated June 29,2012, as supplemented on September 12, September 20, and October 10, 2012. The amendment adds Notes to Technical Specification 3.5.4, for the refueling water storage tank (RWST) to allow administrative control of the seismically qualified RWST/non-seismic spent fuel pool purification loop interface. This change would only be applicable for the next two fuel cycles A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's Biweekly Federal Register notice.

Sincerely, IRA!

Robert E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 192 to NPF-12

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

Public RidsNrrDirsltsb Resource J. Miller. NRR LPL2-1 RtF RidsOgcRp Resource L Ward, NRR RidsNrrPMSummer Resource RidsNrrDorlDpr Resource E. Davidson, NRR RidsAcrs_AcnwMailCTR Resource RidsRgn2MailCenter Resource G. W. Lapinsky. NRR RidsNrrLASFigueroa Resource RidsNrrDorlLp2-1 Resource ADAMS A ccesslon No. ML12270A301

• B$Y memo OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRRISRXB/BC NRRISBPB/BC NRR/AHPB/BC NAME RMartin SFi!:;Jueroa CJackson GCasto UShoop DATE 10/12/12 10/11112 09/17/12 08/10/12

• 08/22/12 OFFICE NRR/AADB/BC*

NRRISTSB/BC OGC NLO NRR/LPL2-1/BC NRR/LPL2*1/PM NAME TTate RElliot (MHamm for)

CKanatas RPascarelii RMartin DATE 10/9/12 10/11/12 10/11/12 10/12/121 10/12/12 OFFICIAL RECORD COPY