RC-06-0173, V. C. Summer - LAR 05-2926, Implementation of WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of RPS and ESFAS Test Times and Completion Times - Summarized List of Commitments

V. C. Summer - LAR 05-2926, Implementation of WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of RPS and ESFAS Test Times and Completion Times - Summarized List of Commitments

ML062760318
Person / Time
Site:	Summer
Issue date:	09/29/2006
From:	Archie J South Carolina Electric & Gas Co
To:	Martin R Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 05-2926, RC-06-0173, WCAP-14333-P-A Rev 1
Download: ML062760318 (3)

Text

Jeffrey B. Archie Vice President,NuclearOperations 803-345-4214 A SCANA COMPANY September 29, 2006 RC-06-0173 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTN: Mr. Robert E. Martin

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST - LAR 05-2926 IMPLEMENTATION OF WCAP-14333-P-A, REV. 1, "PROBABILISTIC RISK ANALYSIS OF THE RPS AND ESFAS TEST TIMES AND COMPLETION TIMES"-

SUMMARIZED LIST OF COMMITMENTS

Reference:

1. J. B. Archie, SCE&G, Letter RC-06-0158, to Document Control Desk, USNRC, dated August 31, 2006

2. J. B. Archie, SCE&G, Letter RC-06-0087, to Document Control Desk, USNRC, dated May 31, 2006

3. J. B. Archie, SCE&G, Letter RC-05-0143, to Document Control Desk, USNRC, dated 11/15/2005 South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for South Carolina Public Service Authority, hereby submits a summarized list of regulatory commitments pursuant to a telephone conference between Arnie Cribb, SCE&G, Cliff Doutt, NRC, and yourself on August 28, 2006, related to the above referenced license amendment request (LAR). The LAR proposes changes to the V. C. Summer Nuclear Station (VCSNS) Reactor Trip System Instrumentation and Engineered Safety Feature Actuation System Instrumentation Allowed Outage and Bypass Test times.

Commitments I through 4 were identified in Reference 3. Commitments 5 and 6 are located in Reference 2 in Response 3 and Response 9.4. Commitment 7 was identified in Reference 1.

These commitments have been captured in the VCSNS Corrective Action program in CER 05-2926.

Ifyou have any questions or require additional information, please contact Mr. Robert G. Sweet at (803)-345-4080.

I certify under penalty of perjury that the foregoing is true and correct.

Executed on AJC/JBAdr c: see page 2 Ac /

SCE&G I Virgil C.Summer Nuclear Station - P.O.Box 88 . Jenkinsville, South Carolina 29065 .T(803) 345.5209 .www.scona.com

Document Control Desk LAR 05-2926 RC-06-0173 Page 2 of 2 Attachment(s):

1. List of Regulatory Commitments c: K. B. Marsh S. A. Byrne N. S. Cams J. H. Hamilton R. J. White W. D.Travers NRC Resident Inspector P. D. Ledbetter K.M. Sutton T. P. O'Kelley RTS (LAR 05-2926)

File (813.20)

DMS (RC-06-0173)

Document Control Desk Attachment I LAR 05-2926 RC-06-0173 Page 1 of I LIST OF REGULATORY COMMITMENTS VCSNS will implement administrative controls to include the following restrictions when a logic cabinet is unavailable.

1. Activities that degrade the availability of the emergency feedwater system, RCS pressure relief system (pressurizer PORVs and safety valves), AMSAC, or turbine trip, should not be scheduled when a logic cabinet is inoperable for maintenance.

2. One complete ECCS train that can be actuated automatically must be maintained when a logic train is inoperable for maintenance.

3. Activities that cause master relays or slave relays in the available train and activities that cause analog channels to be unavailable should not be scheduled when a logic train is inoperable for maintenance.

4. Activities on electrical systems (e.g., AC and DC power) and cooling systems (e.g.,

service water and component cooling water) that support systems of functions listed in the first three bullets should not be scheduled when a logic cabinet is inoperable for maintenance. That is, one complete train of a function that supports a complete train of a function noted above must be available.

In addition:

5. VCSNS will develop a procedure specifically to monitor the components affected by this LAR including logic cabinets, master relays, slave relays, and analog channels. The assumptions regarding component unavailability due to test and maintenance activities in the analysis supporting WCAP-14333 will be evaluated to ensure that the intent of these assumptions are met at VCSNS.

6. The VCSNS PRA and EOOS will be updated to include representative signals to model the reactor trip and ESFAS to the appropriate depth to perform Tier 3 evaluations.

Signals not explicitly modeled will either be added to the model or addressed by surrogates.

7. As described in PRA Evaluation 06-05, V. C. Summer will change PRA fault tree gate EFW-MDPB-ACT from an "and" gate to an "or" gate on the next PRA update.