ML16187A160
| ML16187A160 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/25/2016 |
| From: | Bill Dean Office of Nuclear Reactor Regulation |
| To: | Lippard G South Carolina Electric & Gas Co |
| Monarque S, NRR/JLD, 415-1544 | |
| References | |
| CAC MF2338 | |
| Download: ML16187A160 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 25, 2016 Mr. George Lippard Ill, Vice President Nuclear Operations South Carolina Electric and Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - RELAXATION OF SCHEDULE REQUIREMENTS FOR ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" (CAC NO.
MF2338)
Dear Mr. Lippard:
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A735), the U.S. Nuclear Regulatory Commission (NRC) issued order EA-12-049 to South Carolina Electric and Gas Company (SCE&G, the licensee), requiring certain actions at Virgil C. Summer Nuclear Station, Unit 1 (VCSNS),
associated with the Fukushima Near-Term Task Force Recommendations. Order EA-12-049 directed that actions be taken by licensees to develop and implement strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event.
Section IV of the order states that the Director, Office of Nuclear Reactor Regulation, may relax or rescind certain conditions of the order upon demonstration of good cause. By letter dated August 13, 2015 (ADAMS Accession No. ML15231A025), SCE&G submitted a request for relaxation of the schedule requirement for full implementation for VCSNS as prescribed in Section IV A.2 of NRC Order EA-12-049. That requirement states, in part, "All holders of operating licenses issued under Part 50 .. . shall complete full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a, or December 31 , 2016, whichever comes first."
In its letter dated August 13, 2015, SCE&G requested that the required date for full implementation for VCSNS be relaxed until July 31, 2016. The requested schedule relaxation would allow the licensee additional time to design and implement a new alternate emergency feedwater (EFW) suction strategy, update associated procedures, and complete training associated with this alternate strategy. In its August 13, 2015, letter, SCE&G noted that the Condensate Storage Tank (CST) does not meet the high wind protection from the tornado hazard requirements in Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, and therefore cannot be credited for those events. As such, VCSNS is pursuing the alternate EFW suction strategy to supply water to the Turbine Driven EFW Pump in the event the CST is rendered inoperable.
In addition, the July 31, 2016, relaxation date was also requested due to the number of procedure changes and station training activities scheduled for the first quarter of 2016 to ensure compliance with the National Fire Protection Association Standard 805,
G. Lippard "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," by March 31, 2016.
This relaxation was evaluated and approved by the NRC by letter dated October 4, 2015 (ADAMS Accession No. ML15243A450). As described in the October 4, 2015, letter, the NRC staff approved the relaxation because the licensee demonstrated good cause as well as its ability to provide feedwater from alternate sources if the CST was rendered unavailable during the relaxation period.
Subsequently, on June 30, 2016, SCE&G submitted another letter (ADAMS Accession No. ML16188A197) requesting an additional 60 days over the current compliance date of July 31, 2016. The additional 60 days are requested to allow adequate time to complete required testing of the new EFW system and to resolve any issues identified during testing, without undo time pressure. This same letter explains the sequence of events that led to this request.
In its letter dated June 30, 2016, SCE&G explained that, after the 2015 fall outage was completed, the licensee began working on the design of the alternate EFW suction strategy, which involves a major engineering modification to the plant. Initially, the licensee planned on installing two BO-kilowatt (kW) diesels in the Service Water Pump House (SWPH). These diesels would power two independent pumps located in the SWPH bay. While implementing the alternate approach, several unanticipaded issues emerged, including habitability and the amount of space maintenance personnel would be left with to perform maintenance on the Service Water Pumps inside the SWPH.
The licensee also explained that, on March 18, 2016, a revised approach to the alternate strategy was approved to install the two 80-kW diesels outside the protected area. The revised approach will have the two diesels installed in a new structure designed to meet the VCSNS tornado missile protection specifications, and the two diesels will provide power to the alternate EFW pumps via underground cables that extend approximately 1,500 feet. The licensee stated that during the excavation of the underground cable conduit, unmarked underground systems were uncovered that extended the excavation schedule. In addition, concrete thickness that exceeded the as-built drawings of the SWPH further extended the excavation schedule.
The licensee stated that, given the described circumstances, the current schedule for the alternative EFW modification only has 2 days of margin. Furthermore, the licensee stated that, besides completing required testing without undo time pressure, the additional 60 days would also allow VCSNS to perform training, without undo time pressure, for Operations personnel ,
who would be required to implement this strategy in a short timeframe during a beyond-design-basis external event.
The NRC staff agrees that, based on the importance of the alternate EFW suction strategy and the significant safety enhancements it would provide, additional time is warranted to ensure a successful strategy is developed and implemented with procedures and training completed, as necessary. The NRC staff also considers that VCSNS will continue to have alternative feedwater sources available in case that the CST is not available, and that those alternative sources will continue to be available during the additional requested time . Therefore, the request for an additional 60 days for VCSNS to complete the remaining work and achieve the capability to fully implement the requirements of Order EA-12-049 is based on good cause.
Given the plant-specific circumstances at VCSNS, and acknowledging that the proposed
G. Lippard completion date is prior to December 2016, the ultimate implementation date of the order, the NRC staff approves the request for additional time to comply with Order EA-12-049.
Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of the order for full order implementation for VCSNS is relaxed until September 30, 2016.
If you have any questions, please contact Milton Valentin at 301-415-2864.
Sincerely, William M. Dean, Director Office of Nuclear Reactor Regulation Docket No. 50-395 cc: Listserv
ML16187A160 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JOMB/BC(A) OE NAME MValentin Slent MHalter RFretz DATE 07/05/2016 07/05/2016 07/06/2016 07/06/2016 OFFICE OGC* NRR/JLD/D NRR/D NAME DCylkowski JDavis (MShams for) WDean IBMcDermott for!
DATE 07111/2016 07/15/2016 07/25/2016