Text

NRR E-mail Capture - V.C. Summer, Unit 2 and 3, Request for Additional Information Regarding Emergency Action Level Scheme LAR 14-13R
	ML16137A251
Person / Time
Site:	Summer, Washington State University
Issue date:	05/16/2016
From:	Shawn Williams; Plant Licensing Branch II
To:	Ayanna Rice; South Carolina Electric & Gas Co
References
	Download: ML16137A251 (6)
	v • d • e

1 NRR-PMDAPEm Resource From:

Williams, Shawn Sent:

Monday, May 16, 2016 10:22 AM To:

RICE, APRIL R Cc:

BOUKNIGHT, JUSTIN R

Subject:

V.C. Summer, Unit 2 and 3, Request for Additional Information Regarding Emergency Action Level Scheme LAR 14-13R Attachments:

RAIs Summer Unit 2 and 3, EAL Scheme LAR.pdf Ms. Rice, By letter dated December 1, 2015, South Carolina Electric & Gas Company (SCE&G, the licensee) requested approval for an emergency action level (EAL) scheme change for the Virgil C. Summer Nuclear Station (VCSNS), Units 2 and 3 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15335A448). SCE&G proposes to revise their current EAL scheme for VCSNS Units 2 and 3 from one based on Nuclear Energy Institute (NEI) document NEI 07-01, Methodology for Development of Emergency Action Levels for Passive Reactors, Revision 0 (ADAMS Accession Number ML092030210), to an alternative scheme.

The NRC staff has determined that additional information is needed to continue the review as discussed in the Attachment. We request that SCE&G respond to this request within 60 days of the date of this e-mail.

Sincerely, Shawn Williams, Senior Project Manager Docket Nos.52-027, 52-028

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V.C. Summer, Unit 2 and 3, Request for Additional Information Regarding Emergency Action Level Scheme LAR 14-13R Sent Date:

5/16/2016 10:21:58 AM Received Date:

5/16/2016 10:21:59 AM From:

Williams, Shawn Created By:

Shawn.Williams@nrc.gov Recipients:

"BOUKNIGHT, JUSTIN R" <JUSTIN.BOUKNIGHT@scana.com>

Tracking Status: None "RICE, APRIL R" <ARICE@scana.com>

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REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY ACTION LEVEL SCHEME CHANGE VIRGIL C. SUMMER NUCLEAR STATION, UNITS 2 AND 3 LICENSE NOS. NPF-93 AND NPF-94 By letter dated December 1, 2015, South Carolina Electric & Gas Company (SCE&G, the licensee) requested approval for an emergency action level (EAL) scheme change for the Virgil C. Summer Nuclear Station (VCSNS), Units 2 and 3 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15335A448). VCSNS proposes to revise their current EAL scheme for Units 2 and 3 from one based on Nuclear Energy Institute (NEI) document NEI 07-01, Methodology for Development of Emergency Action Levels for Passive Reactors, Revision 0 (ADAMS Accession Number ML092030210), to an alternative scheme.

The requests for additional information (RAIs) listed below are needed to support NRC staffs continued technical review of the proposed EAL scheme change.

RAI-VCSNS-01 For Section 5.1 (Definitions), the definition of SAFETY SYSTEM was inappropriately carried over from NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 6 (ADAMS Accession No. ML12326A805). This document is not applicable to VCSNS as NEI 99-01 is for non-passive reactor designs. In NUREG-1793, Final Safety Evaluation Report Related to Certification of the AP1000 Standard Design, dated September 2004, Section 22, Regulatory Treatment of Non-Safety Systems, provides the staffs position on safety and non-safety systems as it relates to the AP1000 design. VCSNS may not be able to use the SAFETY SYSTEM definition provided in NEI 99-01 as it does not encompass these important non-safety systems. Please develop another definition that: (1) will not create confusion by having multiple definitions of SAFETY SYSTEM in licensee EAL schemes; (2) will encompass the safety systems applicable to VCSNS, and (3) will encompass the important non-safety systems applicable to VCSNS as discussed in NUREG-1793. Once this definition has been developed, please ensure that the applicable EALs that use this defined term are revised accordingly.

RAI-VCSNS-02 RIS 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," and Supplements 1 and 2, recommend that licensees provide appropriate justification for submittals that are different than the NRC published or endorsed guidance used to develop the proposed EAL scheme. While this RIS was speaking to non-passive reactor designs that use NEI 99-01 as an EAL scheme development guidance, this rationale also applies to passive reactor designs (i.e., AP1000, ESBWR). This additional information is needed for the staff to support its technical evaluation of the proposed changes to the guidance in NEI 07-01, Methodology for Development of Emergency Action Levels Advanced Passive Light Water Reactors (Revision 0). The justification should include the differences and deviations between the approved EAL scheme (based on NEI 07-01) for VCSNS, Units 2 and 3, and the proposed EAL scheme. The staff noted that the proposed EAL scheme for VCSNS Units 2 and 3, adopted the NEI 99-01 (Revision 6) EAL scheme guidance; however, NEI 99-01 is not directly applicable to VCSNS Units 2 and 3 due to the reactors passive design.

Please provide a difference/deviation matrix for the entire proposed EAL Basis Document for VCSNS Units 2 and 3 that clearly evaluates all the differences/deviations between the proposed scheme and the currently approved scheme based on NEI 07-01. NEI 07-01 provides detailed information (i.e., use of specific equipment and alarms/setpoints), and information to determine the appropriate changes applicable to a passive design versus a non-passive design. When evaluating the proposed EAL scheme, please describe why the detailed EALs as approved (based on NEI 07-01) are no longer applicable for the appropriate EAL.

NEI 99-01 can be used as a guide, however, NEI 07-01 is the approved EAL scheme for VCSNS Units 2 and 3, and as such, should be used as the source document for evaluation purposes. Many of the non-design related EALs from NEI 99-01 (Revision 6) are appropriate for VCSNS Units 2 and 3, but justification for the proposed EAL scheme (as compared to the approved EAL scheme) must be provided in order to reach our reasonable assurance finding.

RAI-VCSNS-03 Please confirm that all setpoints and indications used in the proposed EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication. For those EALs that the specific setpoint has not been determined yet, please confirm appropriate actions will be taken to verify that eventual setpoint will fall within the calibrated range of the stated instrument.

RAI-VCSNS-04 For EAL RA2.2, the threshold is based upon a Hi-Rad alarm on a list of radiation monitors.

Please confirm that this is the actual alarm applicable to this EAL for all the listed radiation monitors, and for the Refueling Bridge Portable Monitor. In addition, please explain why an elevated reading on these radiation monitors would not be applicable in addition to the alarm(s),

or revise accordingly.

RAI-VCSNS-05 For EAL RA3.1, the approved EAL specifies instrument RMS-JE-RE009 for the Central Alarm Station (CAS). Please explain why the proposed EAL states that the CAS will be monitored by survey rather than by an installed radiation monitor as previously referenced, or revise accordingly.

RAI-VCSNS-06 NOTE-09, states: Classification is not required if either train of RNS (normal residual heat removal) can be placed in service for Shutdown Cooling. Please explain: why this note was added; the impact this note has on EAL timing, and the effect this note has on the overall EAL scheme, for each applicable EAL.

RAI-VCSNS-07 For EAL CA1.1, please address the following:

1. Provide further justification for removal of timing note from this EAL, or revise accordingly;

2. Explain why the approved EAL scheme states that 64.5% RCS Hot Leg level is called Low 4 and the proposed EAL calls this Low 1; and

3. The approved EAL also has states a threshold for pressurizer level at 12% and lowering on RCS-LT-200. Please explain why this was removed, or revise accordingly.

RAI-VCSNS-08

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RAI-VCSNS-09 For EAL CS1.1, please address the following:

1. Explain why the timing was changed from the approveG³PLQXWHV'WR³PLQXWHV

and

2. Explain why the approved EAL cannot be implemented as it is more detailed and specific than the proposed EAL, or revise accordingly.

RAI-VCSNS-10 For EAL CU4.1, please explain why this EAL was added to the scheme, or revise accordingly.

RAI-VCSNS-11 For EALs CU6.1, SA2.1, SS2.1 and HG1.1, please explain why the approved EAL cannot be implemented, or revise accordingly. Specifically, this EAL was apparently carried over from NEI 99-01, Revision 6, which is problematic as it is not entirely applicable to the AP1000 design.

VCSNS Units 2 and 3 have digital instrumentation and control systems, and use the AP1000 passive reactor design. As a result, this EAL needs to be unique to VCSNS (Units 2 and 3) and the AP1000 design.

RAI-VCSNS-12 For EALs CU8, CA2 and CA7 (all from the approved EAL scheme), please explain why these were removed from the proposed EAL scheme, or revise accordingly.

RAI-VCSNS-13 For EAL HU3.1, please explain why the threshold for high winds > 145 mph was removed, or revise accordingly.

RAI-VCSNS-14 For EALs HU4.1 and HU4.2, please explain why the following areas from the approved EAL scheme were removed from the proposed EAL scheme, or revise accordingly:

x annex building, x

turbine building, and x

radwaste building.

In addition, if using the EAL from NEI 99-01, Revision 6, please explain why the Appendix R information is not carried over as well, or revise accordingly.

RAI-VCSNS-15 For EAL HS6.1, please explain why the timing was changed from the approved within 60 minutes to within 15 minutes. In addition, this EAL was apparently carried over from NEI 99-01, Revision 6, which is problematic as it is not entirely applicable to the AP1000 design.