RC-11-0196, Response to Request for Additional Information NRC Bulletin 2011-01 Mitigating Strategies

Response to Request for Additional Information NRC Bulletin 2011-01 Mitigating Strategies

ML11354A247
Person / Time
Site:	Summer
Issue date:	12/15/2011
From:	Gatlin T South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CR-11-05793, RC-11-0196, TAC ME6488, BL-11-001
Download: ML11354A247 (5)

Text

Thomas D. Gatlin Vice President,Nuclear Operations 803.345.4342 A SCANA COMPANY December 15, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 REQUEST FOR ADDITIONAL INFORMATION NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" (TAC NO. ME6488)

Reference:

1. Thomas D. Gatlin, SCE&G, letter to Document Control Desk, 60-Day Response to NRC Bulletin 2011-01 dated July 11, 2011 (RC-1 1-0106)

2. William (Billy) Gleaves, NRC, letter to Thomas D. Gatlin, SCE&G, Request for Additional Information Re: NRC Bulletin 2011-01 "Mitigating Strategies" (TAC No. ME6488) dated November 15, 2011 South Carolina Electric & Gas Company (SCE&G) received an NRC letter dated November 15, 2011 (Reference 2), requesting additional information (RAI) regarding the Virgil C. Summer Nuclear Station 60-day response to NRC Security Bulletin 2011-01 "Mitigating Strategies" (Reference 1). SCE&G has reviewed the request for additional information and hereby submits the attached response.

If you have any questions or require additional information, please contact Mr. Bruce Thompson at (803) 931-5042.

I certify under penalty of perjury that the information contained herein is true and correct.

121-15-)l m g - -

Executed on Thomas D. Gatlin Vice President, Nuclear Operations TS/TDG/bq Attachment c: K. B. Marsh R. E. Martin S. A. Byrne NRC Resident Inspector J. B. Archie K. M. Sutton N. S. Cams NSRC J. H. Hamilton RTS (CR-11-05793)

R. J. White File (815.02)

W. M. Cherry PRSF (RC-11-0196)

V. M. McCree I Virgil C.Summer Station.- Post Office Box 88.- Jenkinsville, SC

- 29065 - F(803) 345-5209

Document Control Desk Attachment I CR-1 1-05793 RC-1 1-0196 Page 1 of 4 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REVIEW OF 60-DAY MITIGATING STRATEGIES BULLETIN RESPONSES SUBMITTED IN RESPONSE TO NRC BULLETIN 2011-01 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50-395

1. Describe in detail the maintenance or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

The bulletin requested that each licensee describe in detail the maintenance and testing on equipment procured to support the mitigating strategies to ensure that it will be functional when needed. In the context of the mitigating strategies, these devices are commonly used for firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product releases. The NRC staff could not determine if you performed activities to ensure that these devices will be functional when needed.

RESPONSE

There is no current maintenance or testing of B.5.b nozzles/flow devices. The equipment is inspected in conjunction with the required inventory of this equipment and any obvious discrepancies are noted. However, there is no scheduled test or maintenance of this equipment (i.e. the nozzles are not functionally tested or provided with any periodic preventative maintenance).

Beyond Design Basis Mitigating Guideline (BDMG) -1.0, "SPENT FUEL POOL MAKEUP AND SPRAY STRATEGIES," directs use of the following spray nozzles: 1) portable monitor appliances with either a master stream spray nozzle or stacked straight stream nozzles and 2) flow monsters/diverters. The recommended preventative maintenance for the monitor is primarily after each use or as needed.

There is a recommendation to grease the worm gear at least every 6 months or as-needed. The manufacturer of the master stream nozzles does not list any specific periodic maintenance or testing. The manufacturer does indicate that maintenance can be performed if the nozzle tip becomes difficult to turn but suggests using lubricant sparingly since excess grease can attract dirt and cause interference with moving parts.

The straight stream nozzles and flow monsters are open discharge devices and do not have any moving parts that would require testing or maintenance to ensure the devices are functional.

Document Control Desk Attachment I CR-1 1-05793 RC- 11-0196 Page 2 of 4 An action has been created in the VCSNS Corrective Action Program (CR-1 1-05793) to establish appropriate procedures and/or preventative maintenance tasks to perform periodic maintenance/testing, in accordance with vendor recommendations, of portable monitor appliances and master stream spray nozzles used to accomplish B.5.b strategies.

2. Describe in detail the testing and inventory of communications equipment to ensure that it is available and functional when needed.

The bulletin requested that each licensee describe in detail the testing and control of equipment supporting the mitigating strategies to ensure that it will be available and functional when needed. Communications equipment needed to support the mitigating strategies was described in the NRC Safety Evaluation documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA 026), and typically includes radios, satellite phones, spare batteries, and chargers. The NRC staff could not determine if you performed activities to ensure the communications equipment will be available and functional when needed.

RESPONSE

Operations personnel perform monthly communication checks in accordance with Attachment IV of Operations Administrative Procedure (OAP) -100.004, "Communication." The attachment includes checks of the Satellite Phone (SATPHONE) system and the Radio system from the base radio in the Control Room on "DIRECT" and VCS Repeater channels to Security, Maintenance, and Health Physics. Normal Operations radio communication is conducted on "OPS MAIN" (Radio Channel A-i) and is in daily use so it is not tested.

Emergency Planning (EP) conducts quarterly inventories of B.5.b Radiation Emergency Equipment in accordance with Emergency Plan Procedure (EPP) - 103, "Emergency Equipment Checklist" and EPP - 104, "Verification of Communications Operability."

The quarterly inventories include verifying operability of hand-held radios used during emergency procedures and ensuring minimum quantities of hand-held radios, spare batteries for radios, and chargers for hand-held radio batteries are in place. Batteries are replaced, as needed, during this inventory based on the shelf life established by manufacturer's recommendation. The operability of at least one radio and one SATPHONE located in a separate area is also verified during this quarterly inventory.

The Offsite Incident Command Post (ICP) radio is also tested by EP during quarterly operability verification of communications as listed in EPP - 104, "Verification of Communications Operability."

Document Control Desk Attachment I CR-1 1-05793 RC- 11-0196 Page 3 of 4

3. Describe in detail how you ensure there is sufficient fuel for the pumping source when needed.

The bulletin requested that each licensee describe in detail the maintenance of equipment supporting the mitigating strategies to ensure that it will be functional when needed. The NRC staff could not determine if you performed activities to ensure that sufficient fuel would be available for the pumping source so that it will be functional when needed.

RESPONSE

The following BDMGs, that utilize the fire pumper truck as a pumping source, contain notes indicating either:

"Notify the Incident Commanderthat the Fire Pumper Truck will need to be refueled at least 6 times (once every two hours) for the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the strategy."

"Notify the Incident Commanderthat the Fire Pumper Truck will need to be refueled once every two hours for extended runs."

"When supplying the fire header,the Fire Pumper Truck will need to be refueled at least 6 times (once every two hours) for the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the strategy."

" BDMG-1.0, "SPENT FUEL POOL MAKEUP AND SPRAY STRATEGIES"

• BDMG-2.0, "RWST MAKEUP"

" BDMG-5.0, "MANUALLY DEPRESSURIZE SGS AND USE LOW PRESSURE WATER SOURCES (TURBINE DRIVEN EMERGENCY FEEDWATER PUMP NOT AVAILABLE)"

" BDMG-7.0, "CONTAINMENT FLOODING WITH FIRE SERVICE"

• BDMG-8.0, "PORTABLE SPRAY FOR CONTAINMENT/ATMOSPHERE RELEASES"

• BDMG-9.0, "INCREASING RCS INVENTORY" These notes were added based on procedure enhancements identified in the Corrective Action Program (CR-08-02947). The run hours were based on a fuel usage calculation contained in Engineering Information Request (EIR) 81348, "B5b Diesel Fuel Usage Calculations." The EIR lists the diverse diesel fuel supplies that are available on-site.

The onsite Fleet Service station ensures fuel inventory is maintained in the B.5.b equipment (Fire Pumper truck, air compressor, and diesel generator set) as part of scheduled periodic runs on this equipment.

Document Control Desk Attachment I CR-1 1-05793 RC-11-0196 Page 4 of 4 An action has been created in the station's Corrective Action Program (CR-1 1-05793) to revise appropriate EP procedure(s) to reference available fuel sources and to specify the required actions needed to ensure adequate supply of diesel fuel oil for continued operation of B.5.b equipment.