ML20212L576

Annual Commitment Change Summary Report

ML20212L576
Person / Time
Site:	Summer
Issue date:	07/30/2020
From:	Lippard G Dominion Energy Co, Dominion Energy South Carolina
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
20-246
Download: ML20212L576 (4)

Text

V. C. Summer Nuclear Station Bradham Blvd & Hwy 215, Jenkinsville, SC 29065 ~ Dominion Mailing Address :

P.O. Box 88, Jenkinsville, SC 29065

iiiiiii" Energy Dominion Energy.com July 30, 2020 Document Control Desk Serial No.

20-246 U.S. Nuclear Regulatory Commission VCS-LIC/HK RO Washington, DC 20555 Docket No. 50-395 License No. NPF-12 DOMINION ENERGY SOUTH CAROLINA (DESC)

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 ANNUAL COMMITMENT CHANGE

SUMMARY

REPORT Dominion Energy South Carolina hereby submits the 2019 Annual Commitment Change Summary Report. The commitment changes were performed in accordance with VCSNS's Regulatory Commitment Management Program, which was developed following guidance from NEI 99-04 "Guidelines for Managing NRG Commitment Changes."

Should you have any questions, please contact Mr. Michael Moore at (803) 345-4752 .

~

George A. Lippard Site Vice President V.C. Summer Nuclear Station

Attachment:

Summary of Commitment Changes cc:

G. J. Lindamood - Santee Cooper L. Dudes - NRG Region II V. V. Thomas - NRG Project Mgr.

NRG Resident Inspector

Serial No.20-246 Attachment I Page 1 of 3 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT

SUMMARY

OF COMMITMENT CHANGES

Serial No.20-246 Attachment I Page 2 of 3 The following commitment changes, with a brief justification, were performed during 2019 in accordance with Virgil C. Summer Nuclear Station's (VCSNS) Regulatory Commitment Management Program, which was developed following NEI 99-04, "Guidelines for Managing NRC Commitment Changes." The changes are documented in the station's corrective action program condition reports (CRs):

CR-19-00212 Commitment - VCSNS committed to disassemble and inspect the Turbine Driven Emergency Feedwater Pump (TDEFP) and Motor Driven Emergency Feedwater Pump (MDEFP) every 10 years to inspect for internal wear, based on NRC Bulletin 88-04, due to concerns with mini-flow conditions not meeting the vendor minimum flow requirements.

Change - VCSNS eliminated the need to continue performing periodic internal inspections per MMP-195.001 and MMP-195.002 for the TDEFP and MDEFPs, respectively.

Justification for Change - The 10 year (R06) internal inspection task frequency for the Emergency Feedwater Pumps (XPP0021A/B and XPP0008) is based on an NRC Bulletin 88-04 commitment, due to concerns with mini-flow conditions not meeting the vendor minimum flow requirements. Engineering Change Requests 50695E and 50695G resulted in mini-flow rates of approximately 135 gallons per minute (gpm) for the MDEFPs (for surveillance testing and DBE) and 300 gpm for TDEFP (surveillance testing) and 110 gpm (DBE). As a result, mini-flow greater than vendor minimum flow requirements are now demonstrated and measured during In-Service Testing.

CR-19-01771 Commitment- In LAR-05-3666, VCSNS committed to develop an Operations procedure to verify the operation of Alternate AC (AAC) to supply the 1DA and 1DB busses each refueling outage. The AAC source will normally be energized and monitored at VCSNS on a continuous basis and will be verified as an appropriate source at least weekly.

The capability of the AAC source will be verified by communicating with personnel at Parr Hydro Station to discuss which units are/will be supplying power as the AAC source.

Change - There were three changes made to this commitment. First, the frequency of verifying the operation of the AAC to supply the 1DA and 1DB buses was extended to R04 (6 years) to align with the 1DX scheduled maintenance and train specific outages.

Second, the station will continue using the 'or' statement for testing in STP-125-021 to verify AAC ability to supply 1DA or 1DB. Third, the station provided clarification as to whether LAR-05-3666, and its associated Safety Evaluation (SE), require weekly calls to Parr Hydro when Parr Hydro is not expected to be needed to support VCS Operations.

Serial No.20-246 Attachment I Page 3 of 3 Justification for Change - The first change is based on demonstrated maintenance and performance history in Station Outages since 2005, the reliability of the Parr Hydro Station and Parr Keep Warm Diesel are above the 95 percent reliability threshold. The Power Delivery organization and VCS Electrical Maintenance have historical data for satisfactory performance of Parr Hydro. There is not a specified frequency in the NUMARC 87-00, Appendix B Guidance for testing.

For the second change, when the station implemented the commitment to create a procedure to verify operation of the AAC to supply the 1DA and 1DB buses, the procedure was written with an 'or' versus an 'and'. Since the station can get power from 1DX to either bus (1 DA or 1DB) the commitment intent is met because of our ability to easily switch between the 1DA and 1DB power supplies.

The third change clarifies confusion as to whether LAR-05-3666, and its associated SE, requires a weekly call to Parr Hydro during periods when Parr Hydro is not expected to be needed to support VCS Operations. The SE indicates that VCSNS will call the Transmission System Operator (TSO) to discuss activities that could affect grid stability.

For example, Emergency Diesel Generator (EOG) maintenance, GL 2006-02 requires VCSNS to have weekly phone calls to discuss planned and emergent maintenance, and to contact the system dispatcher immediately prior to starting the maintenance. The intent of these calls is to discuss activities that could affect grid stability. Additionally, VCS Interfacing Switchyards Agreement (VISA) section 5.1.5.4 requires communication immediately before performing maintenance on equipment that was discussed as being grid-risk-sensitive or is required to mitigate the effects of a Loss of Offsite Power (LOOP).

These discussions include the expected length of time the equipment will be out of service and the need to assure the grid remains stable during this period. This equipment includes the EOG and the TDEFP. Therefore, weekly calls to Parr Hydro are only expected to occur to discuss EOG planned and emergent maintenance as well as activities that could affect grid stability or mitigate the effects of a LOOP