ML19053A544
| ML19053A544 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/22/2019 |
| From: | Lippard G South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 19-086, LAR-16-00644 | |
| Download: ML19053A544 (9) | |
Text
A SCANA COMPANY Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 February 22, 2019 SOUTH CAROLINA ELECTRIC & GAS COMPANY VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 Serial No.19-086 VCS LIC/BAB RO Docket No. 50-395 License No. NPF-12 Page 1 of 2 SUPPLEMENTAL LETTER TO LICENSE AMENDMENT REQUEST - LAR-16-00644 LICENSE AMENDMENT REQUEST - REVISE REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 4.4.6.2.2 Reference 1: LICENSE AMENDMENT REQUEST - LAR-16-00644, LICENSE AMENDMENT REQUEST-REVISE REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 4.4.6.2.2, Dated October 8, 2018. [ML18281A014]
Reference 2: S.A. Williams, NRC e-mail to B. Dalick, SCE&G, V.C. Summer Nuclear Station, Unit 1 - LAR RCS SR 4.4.6.2.2", dated February 14, 2019.
During NRC staff review of the Technical Specification (TS) pages provided with the application dated October 08, 2018 (Reference 1 ), NRC staff identified a need for clarification of the TS wording associated with the frequency extension. This submittal contains VCSNS's corrected TS page.
These revisions supersede the proposed changes from Reference 1. Attachment 1 contains the marked-up version of the affected TS page. Attachment 2 contains the reprinted version of the affected TS pages. Attachment 3 contains the existing TS bases pages marked to show the proposed changes.
If there are any questions or if additional information is needed, please contact Michael S. Moore at (803) 345-4752.
I declare under penalty of perjury that the foregoing is true and correct.
Georg
. Lippard Site Vi e President V.C. Summer Nuclear Station Commitments contained in this letter: None V. C. Summer Nuclear Station. P. 0. Box 88, Jenkinsville, South Carolina* 29065
- F (803) 941-9776
- www.sceg.com
cc:
(Without Attachments Unless Indicated)
G. J. Lindamood - Santee Cooper C. Haney - NRC Region 11 S. E. Jenkins - SCDHEC (w/ attachments)
S. A. Williams - NRC Project Mgr. (w. attachments)
NRC Resident Inspector Serial No.19-086 Docket No. 50-395 Page 2 of 2
be:
(Without Attachments Unless Indicated)
S. M. Zarandi -VCS R. R. Haselden - VCS J. H. Hamilton - VCS C. D. Sly - IN2SE M. S. Moore - VCS J. A. Langan -MPS D. R. Taylor - NAPS B. A. Garber - SPS James Roth - IN2SE Vickie Hull - IN2SE (w/ attachments)
W. S. Blair - RS Paulette Ledbetter (w/ attachments)
RTS (CR-16-00644)
File (813.20)
PRSF - VCS (w/ attachments)
Concurrences:
See Correspondence Routing and Approval CHOP Sheet Verification of Accuracy None Action Plan:
None Serial No.19-086 Supplement to LAR-16-00644 Page 1 of 1 Changes to the UFSAR, USAR, QA Topical Report, ISFSI FSAR, DSAR or PSDAR:
None
Serial No.19-086 Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 ATTACHMENT 1 EXISTING TS PAGES MARKED TO SHOW THE PROPOSED CHANGES
REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continuedl
- b.
Monitoring the reactor building sump inventory at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
- c.
Measurement of the CONTROLLED LEAKAGE to the reactor coolant pump seals when the Reactor Coolant System pressure is 2235 +/- 20 psig at least once per 31 days with the modulating valve fully open. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 or 4.
- d.
Performance of a Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 11l This requirement is not applicable to primary-to-secondary leakage.
- e.
Monitoring the reactor head flange leakoff system at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
4.4.6.2.2 Each Reactor Coolant System Pressure Isolation Valve specified in Table 3.4-1 shall be demonstrated OPERABLE by verifying leakage to be within its limit.
- a.
During startup following each refueling outage, which may be extended to a performance-based frequency not to exceed 3 refueling outages !to a maximum of 60 months) following 2 consecutive satisfactory tests.
- b.
Prior to returning the valve to service following maintenance repair or replacement work on the valve.
- c.
Prior to entering MODE 2 following valve actuation due to automatic or manual action or flow through the valve for valves denoted on Table 3.4-1 by an asterisk*.
- d.
The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 or 4.
4.4.6.2.3 Primary-to-secondary leakage shall be verified ~ 150 gallons per day through any one steam generator at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.(1l
( 1) Not required to be performed/completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.
SUMMER - UNIT 1 3/4 4-20 Amendment No. 179
Serial No.19-086 Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 ATTACHMENT 2 REVISED (CLEAN) TS PAGES Replace the following pages of the Technical Specifications with the attached revised pages.
The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages 3/4 4-20 Insert Pages 3/4 4-20
REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENIS_(Qpntlnued)
- b.
Monitoring the reactor building sump inventory at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
- c.
Measurement of the CONTROLLED LEAKAGE to the reactor coolant pump seals when the Reactor Coolant System pressure is 2235 +/- 20 psig at least once per 31 days with the modulating valve fully open. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 or 4.
- d.
Performance of a Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.<1J This requirement is not applicable to primary-to-secondary leakage.
- e.
Monitoring the reactor head flange leakoff system at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
4.4.6.2.2 Each Reactor Coolant System Pressure Isolation Valve specified in Table 3.4-1 shall be demonstrated OPERABLE by verifying leakage to be within its limit.
- a.
During startup following each refueling outage, which may be extended to a performance-based frequency not to exceed 3 refueling outages (to a maximum of 60 months) following 2 consecutive satisfactory tests.
- b.
Prior to returning the valve to service following maintenance repair or replacement work on the valve.
- c.
Prior to entering MODE 2 following valve actuation due to automatic or manual action or flow through the valve for valves denoted on Table 3.4-1 by an asterisk*.
- d.
The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 or 4.
4.4.6.2.3 Primary-to-secondary leakage shall be verified :5 150 gallons per day through any one steam generator at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.<1)
(1) Not required to be performed/completed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.
SUMMER - UNIT 1 3/4 4-20 Amendment No. 479,
Serial No.19-086 Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 ATTACHMENT 3 Existing TS Bases Pages Marked to Show the Proposed Changes
- ------------------- --*~~-
REACTOR COOLANT SYSTEM BASES OPERATIONAL LEAKAGE (Continued)
An early warning of PRESSURE BOUNDARY LEAKAGE or UNIDENTIFIED LEAKAGE is provided by the automatic systems that monitor containment atmosphere radioactivity and containment sump level. It should be noted that leakage past seals and gaskets is not PRESSURE BOUNDARY LEAKAGE. These leakage detection systems are specified in LCO 3.4.6.1, "Reactor Coolant System, Leakage Detection Systems."
Part (d) notes that this SR is not applicable to primary-to-secondary leakage because leakage of 150 gallons per day cannot be measured accurately by an RCS water inventory balance.
The 72-hour frequency is a reasonable interval to trend leakage and recognizes the importance of early leakage detection in the prevention of accidents.
4.4.6.2.2 This Surveillance Requirement verifies RCS Pressure Isolation Valve integrity thereby reducing the probability of gross valve failure and consequent intersystem LOCA.
r----~~
4.4.6.2.3 This Surveillance Requirement verifies that primary-to-secondary leakage is less than or equal to 150 gpd through any one steam generator. Satisfying the primary-to-secondary leakage limit ensures that the operational leakage performance criterion in the Steam Generator Program is met. If this Surveillance Requirement is not met, compliance with LCO 3.4.5 should be evaluated. The 150-gpd limit is measured at room temperature as described in Reference 2. The operational leakage rate limit applies to leakage through any one steam generator. If it is not practical to assign the leakage to an individual steam generator, all the primary-to-secondary leakage should be conservatively assumed to be from one steam generator.
The Surveillance Requirement is modified by a note, which states that the Surveillance is not required to be pertormed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. For Reactor Coolant System primary-to-secondary leakage determination, steady state is defined as stable Reactor Coolant System pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and reactor coolant pump seal injection and return flows.
The frequency of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is a reasonable interval to trend primary-to-secondary leakage and recognizes the importance of early leakage detection in the prevention of accidents. The.
primary-to-secondary leakage is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Reference 2).
References
- 1.
NEI 97-06, "Steam Generator Program Guidelines"
- 2.
EPRI TR-104788, "Pressurized Water Reactor Primary-to-Secondary Leak
(.;11irlelines" Pressure Isolation Valve (PIV) testing is being conducted on a performance-based testing interval. Performance-based is defined as a PIV which demonstrates good performance for two consecutive outages and, may have its test interval extended to every third refueling outage (to a maximum of 60 months). A PIV, which has demonstrated leakage less than Its TS allowable leakage limit for two consecutive outages is classified as a good performer. In the event of a PIV leakage test failure, PIV testing would require the component to return to the initial interval of every refueling outage, or two years until good performance Is re-established.
Those PIVs listed in TS Table 3.4-1 will be demonstrated OPERABLE by verifying their leakage rates are within TS allowable leakage limits via testing performed at a frequency based on their "good" performance, ranging from every refueling outage to every third refueling outage (to a maximum of 60 months).
SUMMER - UNIT 1 B 3/4 4-4h Amendment No. BRN 07 001, BRN-12-001 I
I