ML16243A464
| ML16243A464 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/29/2016 |
| From: | Lippard G South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049 | |
| Download: ML16243A464 (9) | |
Text
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A SCANA COMPANY U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001
Dear Sir I Madam:
George A. Lippard Vice President, Nuclear Operations (803) 345-4810 August 29, 2016 RC-16-0129
Subject:
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 SEVENTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIC3N-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)
References:
- 1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession Number ML12054A735
- 2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174
- 3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378
- 4. SCE&G Letter, Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),
dated October 17, 2012, ADAMS Accession Number ML12296A252
- 5. SCE&G Letter, Virgil C. Summer, Unit 1, Overall Integrated Plan as Required by March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013, ADAMS Accession Number ML13063A150 On March 12, 2012, the Nuclear Regulatory Commission issued Order EA-12-049 (Reference 1) to South Carolina Electric & Gas Company (SCE&G). Reference 1 was immediately effective and directed SCE&G to develop, implement, and maintain guidance and V. C. Summer Nuclear Station* P. 0. Box 88
- Jenkinsville, SC* 29065
- F (803) 941-9776
Document Control Desk RC-16-0129 CR-12-01078 Page 2 of 2 strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.
Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C.1. Reference 2 endorses industry guidance document NEI 12-06, Revision O (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the initial status report regarding mitigation strategies at the Virgil C. Summer Nuclear Station (VCSNS) Unit 1. Reference 5 provided the OIP for VCSNS Unit 1.
In addition, Reference 1 requires submission of status reports at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports.
The purpose of this letter is to provide the seventh six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Bruce L. Thompson at (803) 931-5042.
I certify under penalty of perjury that the foregoing is true and correct.
TS/GAL/wm Enclosure Virgil C. Summer Nuclear Station (VCSNS) Unit 1-Seventh Six-Month Status Report for the Implementation of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049) c:
K. B. Marsh S. A. Byrne J.B. Archie N.S.Carns J. H. Hamilton S. M. Shealy W. M. Cherry C. Haney (w/attachments)
S. A. Williams (w/attachments)
M. 0. Valentin (w/attachments)
NRC Resident Inspector K. M. Sutton NSRC RTS (CR-12-01078)
File (815.07)
PRSF (RC-16-0129)
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 1of7 VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ENCLOSURE SEVENTH SIX-MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER EA-12-049)
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 2 of 7 1
Introduction South Carolina Electric & Gas Company (SCE&G) developed an Overall Integrated Plan (OIP)
(Reference 1 in Section 8) for Virgil C. Summer Nuclear Station (VCSNS) Unit 1, documenting the diverse and flexible strategies (FLEX) in response to Nuclear Regulatory Commission (NRC) Order EA-12-049 (Reference 2 in Section 8). Subsequently, SCE&G provided the first, second, third, fourth, fifth, and sixth six-month status reports (References 3, 4, 5, 6, 7, and 8 in Section 8, respectively). This report, the seventh six-month status report, provides an update of milestone accomplishments including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, which occurred during the period between February 15, 2016, and August 18, 2016, hereafter referred to as the "update period."
2 Milestone Accomplishments The following milestone(s) were completed during the update period:
Submit 6-month update Procure on-site equipment 3
Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The table has been modified during this update period to reflect the addition of an alternate Emergency Feedwater (EFW) modification and changes to the full implementation schedule requirement (see Section 5 for more information).
- ~~t,<::,*,'
Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:
Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Complete Update 6 Feb 2016 Complete Update 7 Aug 2016 Complete
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 3 of 7 Milestone FLEX Strategy Evaluation Walk-Throughs or Demonstrations Perform Staffing Analysis Modifications:
Modifications Evaluation Unit 1 Design Engineering Evaluation Unit 1 Implementation Outage Alternate EFW Modification Storage:
Design Storage Building Storage Implementation FLEX Equipment:
Procure On-Site Equipment Develop Strategies with RRC Install Off-Site Delivery Station (if Necessary)
Procedures:
PWROG issues NSSS-specific guidelines Create Site-Specific FSPs Create Maintenance Procedures Training:
Develop Training Plan Training Complete T~rget.*
Revisec1
- Target Completion
- Activity Status
(;ompletion Date Date Aug 2013 Complete Aug 2015 Complete Ju12014 Complete Dec 2013 Complete Jan 2015 Complete Nov 2015 Complete Jul2016 In Progress Sep 2016 Jul2014 Complete Jul2015 Complete Oct 2014 Complete Aug 2016 Nov 2014 Complete Aug 2013 Complete May 2013 Complete Complete with exception Feb 2014 of the Alternate EFW Sep 2016 Strategy Complete with exception Oct 2014 of the Alternate EFW Sep 2016 Strategy Jan 2015 Complete Jul2015 Complete with exception Sep 2016 of the Alternate EFW
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 4 of 7 Unit 1 FLEX Implementation Submit Completion Report
- "Target>:
~~*filpletidh.
. D~te*.):
Nov 2015 Jan 2016 4. Changes to Compliance Method Strategy Complete with exception of the Alternate EFW Modification In Review Sep 2016 Nov 2016
- No changes to the compliance method as documented in the Overall Integrated Plan (Reference 1) or to the changes that were submitted in References 3, 4, 5, 6, 7, or 8 of this status report were made during this update period.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation In a letter to the NRC, VCSNS Unit 1 requested a schedule relaxation of the requirement for full implementation of Order EA-12-049 (Reference 9 in Section 8). The NRC responded to the request, relaxing the requirement of the order for full implementation for VCSNS Unit 1 until July 31, 2016 (Reference 10 in Section 8).
On June 30, 2016, VCSNS Unit 1 submitted a request for an additional 60 days to accommodate the expanded project scope required to implement the Alternate Em.ergency Feedwater FLEX Strategy to fully comply with NRC Order EA-12-049 (Reference 11 in Section 8). The NRC responded to the June 30, 2016 request, allowing an additional 60 days from July 31, 2016 to meet EA-12-049 requirement for full implementation (Reference 12 in Section 8).
The requirement of EA-12-049 for full order implementation was relaxed until September 30, 2016.
6 Open Items VCSNS Unit 1 response to the NRC's concern regarding the seismic design of the Emergency Response Building (ERB), FLEX Storage Building (FSB), and the Containment Access Ramp (CAR) Storage Area is provided below.
The Emergency Response Building (ERB), Flex Storage Building (FSB), and Containment Access Ramp (CAR) Storage Area are the site structures which house FLEX Equipment required/credited during response to a beyond design basis seismic event. A discussion regarding the acceptability of each of the structures to withstand the Safe Shutdown Earthquake (SSE) event and provide adequate protection to enclosed equipment is provided below.
- 1. Emergency Response Building: The seismic design criteria and loadings for the ERB were developed in accordance with ASCE 7-10 as an Essential Facility (Category IV),
which is the most conservative and robust of the potential options. To ensure conformance with the NRC expectation that the ERB supports fulfillment of FLEX mitigating strategies, Design Calculation DC02490-004 Revision 1, has been developed,
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 5 of 7 in part, to analyze the ERB with respect to the SSE. The calculation evaluates the seismic lateral force resisting system (LFRS) components of the structure, in high bay location of the ERB where the equipment is to be stored. The conclusion of the calculation is that the seismic LFRS of the ERB is expected to withstand the SSE seismic forces and the ERB will remain accessible and will experience no catastrophic damage.
- 2. FLEX Storage Building: The seismic design criteria and loadings for the FSB were developed in accordance with ASCE 7-10 as an Essential Facility (Category IV), which is the most conservative of the potential options. To ensure conformance with the NRC expectation that the FSB supports fulfillment of FLEX mitigating strategies, Design Calculation DC02490-005 Revision 0, has been developed, in part, to analyze the FSB with respect to the SSE. The FSB was designed to a wind speed in excess of the ASCE 7-10 wind speed requirements, in an attempt to demonstrate functionality during low intensity tornado events. Due to the increased wind speed used, the forces due to the design high wind of 188 mph bound the lateral SSE forces and therefore control the design of the lateral force resisting system design for the FLEX Storage Building (FSB).
The conclusion of the calculation is that the seismic LFRS of the FSB is expected to withstand the SSE seismic forces and the FSB will remain accessible and will experience no catastrophic damage.
- 3. Containment Access Ramp Storage Area: The CAR storage area is a part of the Intermediate Building East Penetration Area, and is a Safety Related/Seismic Category 1 concrete structure which is integral with the Intermediate Building structure. Therefore, the CAR concrete structure was designed to withstand the SSE event As part Of the FLEX response, a metal panel curtain wall and roll-up door were added to the CAR area to enclose the access opening for the storage area and provide a suitable FLEX equipment storage area. Design Calculation DC03440-004 Revision 0, was developed as part of the FLEX implementation to provide structural design of the enclosure wall and associated supports. The steel enclosure was designed for both the ASCE 7-10 wind and seismic loadings, and also the SSE loadings. Due to the light weight of the enclosure wall, the wind loadings controlled the design. In conclusion, the concrete and steel enclosures of the CAR Storage Area were both designed to withstand the SSE event.
7 Potential Draft Safety Evaluation Impacts No potential impacts to the Draft Safety Evaluation have been identified.
8 References The following references support the information contained within this enclosure.
- 1. SCE&G Letter, Virgil C. Summer, Unit 1, Overall Integrated Plan as Required by March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2013, Agencywide Documents Access and Management System (ADAMS) Accession Number ML13063A150
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 6 of 7
- 2. NRC Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, ADAMS Accession Number ML12054A735
- 3. SCE&G Letter, Virgil C. Summer, Unit 1, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2013, ADAMS Accession Number ML13242A273
- 4. SCE&G Letter, Virgil C. Summer, Unit 1, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014, ADAMS Accession Number ML14063A203
- 5. SCE&G Letter, Virgil C. Summer, Unit 1, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2014, ADAMS Accession Number ML14245A405
- 6. SCE&G Letter, Virgil C. Summer, Unit 1, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 27, 2015, ADAMS Accession Number ML15062A007
- 7. SCE&G Letter, Virgil C. Summer, Unit 1, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 24, 2015, ADAMS Accession Number ML15239A750
- 8. SCE&G Letter, Virgil C. Summer, Unit 1, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 26, 2016, ADAMS Accession Number ML16061A005
- 9. SCE&G Letter, Request for Schedule Relaxation from NRG Order EA-12-049, "Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," dated August 13, 2015, ADAMS Accession Number ML15231A025
- 10. NRC Letter, Virgil C. Summer Nuclear Station, Unit 1 - Relaxation of the Schedule Requirements of Order EA-12-049 "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated October 4, 2015, ADAMS Accession Number ML15243A450
- 11. SCE&G letter, Request for an Additional Sixty Days to Comply with NRG Order EA 049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated June 30, 2016, ADAMS Accession Number ML16188A197
Document Control Desk Enclosure RC-16-0129 CR-12-01078 Page 7 of 7
- 12. NRC letter, Virgil C. Summer Nuclear Station, Unit 1 - Relaxation of Schedule Requirement for Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (CAC NO. MF2338), dated July 25, 2016, ADAMS Accession Number ML16187A160