ML20324A737
| ML20324A737 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/19/2020 |
| From: | Mark D. Sartain Dominion Energy South Carolina |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 20-351 | |
| Download: ML20324A737 (7) | |
Text
Dominion Energy South Carolina, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060 DominionEnergy.com Attn: Document Control Desk November 19, 2020 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOMINION ENERGY SOUTH CAROLINA (DESC)
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 Dominion Energy Serial No.:
20-351 NRA/YG:
RO Docket No.:
50-395 License No.: NPF-12 LICENSE RENEWAL COMMITMENT FIRE PROTECTION PROGRAM - SPRINKLER HEAD INSPECTION DATE CHANGE Dominion Energy South Carolina (DESC), acting for itself and as an agent for South Carolina Public Service Authority (Santee Cooper), hereby submits the enclosed request for approval to change the implementation date of VCSNS License Renewal (LR)
Commitment 8 in Appendix A of Safety Evaluation NUREG-1787, "Safety Evaluation Report Related to the License Renewal of the Virgil C. Summer Nuclear Station."
License Renewal Commitment 8 is related to fire protection program sprinkler head testing/replacement and specifies that fire sprinkler testing/replacement wHI be performed prior to the end of the initial term of the operating license (August 6, 2022). DESC has determined that the Commitment 8 implementation date is not aligned with the associated NFPA Code 25 requirements and seeks to modify the implementation date to align with the requirements of the Code.
NFPA Code 25 requires fire sprinkler head testing/replacement prior to 50 years of sprinkler system life, and subsequent testing/replacement at 10-year intervals. For VCSNS, 50 years of sprinkler system life has been conservatively determined to occur in April 2029. Therefore, completing the testing/replacement in accordance with LR Commitment 8 would cause the station to perform the 50-year sprinkler testing/replacement activity at least 6.5 years (August 2022 vs. April 2029) earlier than required by NFPA Code 25.
DESC is requesting a change to the Commitment 8 implementation schedule which currently states that VCSNS will perform this testing or replacement "prior to the end of the current operating term," to a statement indicating that VCSNS will perform this testing or replacement "per the requirements of NFPA Code 25 (i.e., at or before 50 years of service life)."
A detailed description of, and justification for, the proposed change is enclosed with this letter. DESC requests NRC review and approval of this request by September 30, 2021.
Serial No.20-351 Docket No. 50-395 Page 2 of 2 Should you have any questions, please contact Mr. Yan Gao at (804) 273-2768.
Respectfully,
~
Mark D. Sartain Vice President - Nuclear Engineering & Fleet Support Commitments contained in this letter: None
Enclosure:
License Renewal Fire Protection Program Commitment Date Revision cc:
U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 Mr. Vaughn Thomas NRC Project Manager U.S. Nuclear Regulatory Commission Mail Stop 04 F-12 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector V. C. Summer Nuclear Station Ms. Anuradha Nair-Gimmi Bureau of Environmental Health Services South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Mr. G. J. Lindamood Santee Cooper - Nuclear Coordinator 1 Riverwood Drive Moncks Corner, SC 29461
Enclosure Serial No.20-351 Docket No. 50-395 License Renewal Fire Protection Program Commitment Date Revision Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Dominion Energy South Carolina, Inc. (DESC)
Serial No.20-351 Docket No. 50-395
Enclosure:
Page 1 of 4 License Renewal Fire Protection Program Commitment Date Revision 1.0 PURPOSE/BACKGROUND The purpose of this letter is to request approval of an implementation schedule change for License Renewal Commitment 8, associated with fire protection sprinkler head testing/replacement, for VC Summer Nuclear Station (VCSNS).
Dominion Energy South Carolina (DESC) has a License Renewal (LR) commitment that requires VCSNS to perform fire sprinkler head inspection testing/replacement prior to the end of the initial term of the operating license (August 6, 2022). This testing/replacement activity is specified in LR Commitment 8, listed in Appendix A of Reference [5.1].
A discussion related to completing the sprinkler testing/replacement is also contained in the Nuclear Regulatory Commission Safety Evaluation Report (SER), NUREG-1787, "Safety Evaluation Report Related to the License Renewal of the Virgil C. Summer Nuclear Station," Section 3.0.3.3, "Fire Protection Program" [5.1 ]. VCSNS stated testing/
replacement would be performed in accordance with NFPA Code 25, which states that testing/replacement should be performed prior to year-50 of sprinkler system life, with subsequent testing/replacement performed at 10-year intervals. However, to ensure this requirement was completed prior to year-50 of sprinkler system life, the plant conservatively committed to perform the testing/replacement prior to the end of the current operating license term.
1.1 Original Commitment NUREG-1787 [5.1], Appendix A -VCSNS Commitment List Associated with the Renewal of Operating License, Commitment 8, "Fire Protection Program," states:
Appendix A - VCSNS Commitment List Associated with Renewal of the Operating License No.
Commitment FSAR Supp. Location Implementation Schedule Source (LRAApp.A)
The following enhancement will be incorporated into the Fire Protection Program prior to the period of extended operations.
Sprinklers will either be LRA Appendix B, replaced, or representative Prior to the end of the Section B.1.5; 8
samples will be submitted to a 18.2.15.1, current operating Response to RAI recognized laboratory for field Mechanical license term.
B.1.5-1 of extended service testing in according with operations.
NFPA code 25. Subsequent replacement or field service testing of representative samples will occur at 10-year intervals.
Serial No.20-351 Docket No. 50-395
Enclosure:
Page 2 of 4 1.2 Revised Commitment Implementation Schedule statement is proposed to be revised and this submittal letter and its subsequent NRC approval letter will be referenced as the source to the revised Implementation Schedule statement:
Appendix A - VCSNS Commitment List Associated with Renewal of the Operating License No.
Commitment FSAR Supp. Location Implementation Schedule Source (LRAApp.A)
The following enhancement will LRA Appendix B, be incorporated into the Fire Section B.1.5; Protection Program prior to the Response to RAI period of extended operations.
B.1.5-1 of extended Sprinklers will either be replaced, Per the requirements operations.
or representative samples will be 18.2.15.1, of NFPA Code 25 (i.e.,
Note: This 8
submitted to a
recognized submittal letter laboratory for field service testing Mechanical at or before 50 years and subsequent in according with NFPA code 25.
of service life)
NRC approval Subsequent replacement or field letter will be service testing of representative referenced as samples will occur at 10-year source to the intervals.
revision.
2.0 JUSTIFICATION During VCSNS implementation of License Renewal Commitments prior to entering the period of extended operation (PEO), it was determined that the implementation schedule for Commitment 8 is approximately 6.5 years earlier than required by the corresponding NFPA Code 25 requirement.
VCSNS provided RAI response B.1.5-1 in RC-03-0112 [5.2] that stated:
"Section 8.1.5 of the LRA lists the sprinkler testing/replacement as an enhancement to the Fire Protection Program. Testing/replacement will be performed in accordance with NFPA Code 25, which states that this should be done prior to year 50 of sprinkler system life, with subsequent testing performed at 10 year intervals. To ensure testing is performed prior to year 50 of sprinkler system life, VCS will perform this testing prior to the end of the current operating term (August 6, 2022)."
The last sentence of this RAI response committed the station to completing fire sprinkler testing/replacement approximately 6.5 years sooner than the corresponding NFPA Code 25 requirement.
NFPA Code 25 (1999 Edition) Section 2.3.3.1, "sprinklers" states that where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing.
NFPA Code 25 also contains a requirement to perform this testing/replacement every 10 years after the initial year-50 testing/replacement activity.
The 50-year service life of sprinkler systems does not necessarily occur at year-50 of
Serial No.20-351 Docket No. 50-395
Enclosure:
Page 3 of 4 plant operation. Rather, the service life is defined as beginning at the time the sprinkler system is installed and functional.
A review of fire protection design specifications and related documents did not identify a specific date when VCSNS fire sprinkler systems were placed in service. Segments of sprinkler systems were placed into service as plant construction progressed, such that there is not a single date for initialization of the entire system. In order to determine a bounding year-50 service date, historical construction records and inspection reports were reviewed to assess the timeframe for original installation of VCSNS sprinkler systems. This review found a significant number of design and licensing activities related to sprinkler systems and determined that physical installation ofVCSNS sprinkler systems did not occur prior to April of 1979. Therefore, a bounding date of March 31, 1979 is considered a conservative date on which to base the fire sprinkler head testing/replacement schedule.
Accordingly, sprinkler testing/replacement directed by Commitment 8 (as modified) will be completed by April 2029 in order to ensure the sprinklers within the scope of license renewal are initially replaced/tested prior to year-50 of sprinkler service life.
3.0 CONCLUSION
VCSNS License Renewal Fire Protection Program Commitment 8 is credited for aging management of the VCSNS fire protection sprinkler heads that are within scope of license renewal. Commitment 8 requires replacement of sprinklers or removal of a sample set of sprinkler heads for performance testing at an approved laboratory prior to 50 years of service and subsequently at 10-year intervals.
The proposed change to the implementation schedule for this testing/replacement does not change the intent or function of the aging management program. The proposed implementation schedule change would align the program replacement/testing requirements with the requirements in NFPA Code 25. The station will still be required to perform sprinkler head testing at or before the 50-year service life of the sprinkler systems and to determine if further programmatic actions are warranted to manage the effects of aging in sprinkler heads through the PEO.
4.0 PRECEDENT The NRC issued an SE for a similar request to St. Lucie Unit 1 related to, "One-Time Inspection of Class 1 Small Bore Piping Revised Commitments and Revised Inspection Plan," [5.4], [5.5] and [5.6].
5.0 REFERENCES
Serial No.20-351 Docket No. 50-395
Enclosure:
Page 4 of 4 5.1 U.S. Nuclear Regulatory Commission (NRC) NUREG-1787, "Safety Evaluation Report Related to the License Renewal of the Virgil C. Summer Nuclear Station,"
published March 31, 2004 (ADAMS Accession ML041040070) 5.2 RC-03-0112, "Responses to Request for Additional Information (RAI) for the Review of License Renewal Application for Virgil C. Summer Nuclear Station," dated June 12, 2003 (ADAMS Accession# ML031681125) 5.3 NFPA 25, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems," 1999 Edition, Section 2.3.3.1 5.4 Letter from Christopher Costanzo (FPL) to U.S. Nuclear Regulatory Commission (L-2015-126), "License Renewal One-Time Inspection of Class 1 Small Bore Piping Revised Commitments and Revised Inspection Plan," May 11, 2015, (Adams Accession Number ML15140A394).
5.5 NRC Safety Evaluation, St. Lucie Unit No. 1 - One-Time Inspection Small-Bore Piping Inspection Plan, May 11, 2015 (TAC MF4754, Adams Accession Number ML15069A172).
5.6 Letter from Michael Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-385), "License Renewal Commitment Change Summary," published September 28, 2011 (Adams Accession Number11285A309).