RC-14-0196, License Amendment Request LAR-06-00055 - License Amendment Request to Adopt NFPA 805 Response to Request for Additional Information

License Amendment Request LAR-06-00055 - License Amendment Request to Adopt NFPA 805 Response to Request for Additional Information

ML14350A217
Person / Time
Site:	Summer
Issue date:	12/11/2014
From:	Gatlin T South Carolina Electric & Gas Co
To:	Shawn Williams Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR-06-00055, RC-14-0196
Download: ML14350A217 (24)

Text

k t Thomas D. Gatlin Vice President,Nuclear Operations 803.345.4342 December 11,2014 A SCANA COMPANY RC-14-0196 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Attn: S. A. Williams

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST-LAR-06-00055 LICENSE AMENDMENT REQUEST TO ADOPT NFPA 805 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

References:

1. Thomas D. Gatlin, SCE&G, Letter to NRC Document Control Desk, License Amendment Request - LAR-06-00055, "License Amendment Request to Adopt NFPA 805 Response to Request for Additional Information" dated November 15, 2011 (RC-11-0149)

2. Shawn A. Williams, NRC, to Thomas D. Gatlin, SCE&G, "Virgil C. Summer Nuclear Station Unit - 1 (VCSNS) - Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC NO. ME7586)" dated July 11, 2014

[ML14182A473]

3. Thomas D. Gatlin, SCE&G, Letter to NRC Document Control Desk, License Amendment Request - LAR-06-00055, "License Amendment Request to Adopt NFPA 805 Response to Request for Additional Information" dated October 9, 2014 (RC-14-0158)

South Carolina Electric & Gas Company (SCE&G),. acting for itself and as agent for.

South Carolina Public Service Authority pursuant to 10 CFR 50.90, submitted License Amendment Request (LAR) per Reference 1 and several responses to Requests for Additional Information (RAI) to adopt NFPA 805. NRC review and audit of these requests determined that additional information was required and an RAI was issued per Reference 2. In addition to the response to the RAI, SCE&G was requested to revise Attachment S and the license condition with the current implementation status and completion time.

Virgil C.Summer Station *Post Office Box 88 . Jenkinsville, SC. 29065 *F (803) 941-9776 V.

I Document Control Desk LAR-06-00055 RC- 14-0196 Page 2 of 2 SCE&G provided the response to the RAI in Reference 3. During a conference call on December 3, 2014, the NRC identified additional changes to the license condition that were necessary to be consistent with other NFPA-805 license conditions. SCE&G also provided a proposed date change for completing the NFPA 805 Penetration Seal Documentation (Attachment S, Table S-2 item 12) to the end of 2015. It was agreed that SCE&G would resubmit attachment S and the license condition with the agreed upon changes.

Attachment 1 contains a revised Attachment S, Attachment 2 provides the revised list of commitments, Attachment 3 provides a marked up License Condition and Attachment 4 provides the typed revised License Condition.

If you have any questions about this submittal, please contact Bruce L. Thompson at (803) 931-5042.

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

K!)h/,

Executed dn 1/4- Thomas D. Gatlin RLP/TDG/wm Attachment 1- Attachment S Attachment 2- List of Regulatory Commitments Attachment 3- Marked up License Condition Attachment 4- Retyped License Condition c: K. B. Marsh S. A. Williams S. A. Byrne NRC Resident Inspector J. B. Archie S. E. Jenkins N. S. Carns Paulette Ledbetter J. H. Hamilton K. M. Sutton J. W. Williams NSRC W. M. Cherry RTS (CR-06-00055)

V. M. McCree File (813.20)

PRSF (RC-14-0196)

• Document Control Desk Attachment 1 LAR-06-00055 RC-14-0196 Page 1 of 9 VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 1 Attachment S

A- 0 RC-14-0196 Attachment S RC-14-0196 Attachment S S. Plant Modifications and Items to be Completed During Implementation Plant Modifications, Items to be Completed During Implementation and Items Completed Page 1

-_0 RC-14-0196 Attachment S

.~ RC-14-0196 Attachment S Table S-1, Plant Modifications Committed, provided below includes a description of the modifications, along with the following information:

• Item ECR number,

• Risk ranking of the modification,

• Location of the modification,

• Problem statement,

• Proposed change,

• An indication if the modification is currently included in the Fire PRA,

• Compensatory Measure in place,

• A risk-informed characterization of the modification and compensatory measure, and

• The modification completion date.

Table S-1 Plant Modifications Committed In Item Rank Location Problem Statement Proposed Change Fire Comp Measure Risk Informed Characterization Completion PRA ECR50784: Low As Defined Additional insights gained Provide protection of Yes Yes Protection in the form of 3 2015 NFPA 805 during performance of tubing/ circuits from the hour to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rating is Circuit/ Tubing NFPA 805 analysis effects of fire. being provided for select Protection defining circuit and circuits identified through equipment interactions, the NSCA.

ECR50799: Medium RB412 Improvement in station Provide lower leakage Yes None Alternate Seal Injection 2015 NFPA 805 RCP equipment to address Loss RCP Seals [Outage]. obviates much of the Seal of Seal Cooling/ LOCA benefit of this modification.

Replacement scenarios for RCP Seals. This would be ranked "High" if not for Alternate Seal Injection.

ECR50810: High As Defined Fire protection feature Provide mitigation Yes Yes A sensitivity study for the 2015 NFPA 805 enhancements. strategies to address fire PRA showed that this Hazard fire initiators or limit fire modification was highly Protection propagation. important.

Page 2 Plant Modifications, Plant Items to Modifications, Items During Implementation Completed During be Completed to be and Items Completed Implementation and Items Completed Page 2

RC-14-0196 Attachment S Table S-1 Plant Modifications Committed In Item Rank Location Problem Statement Proposed Change FirePA Measure Comp Risk Informed Characterization Completion PRA ECR71588: Low Various Improve documentation of Document updates to Yes None Integrity of fire barriers is 2015 NFPA 805 penetration seal designs to include improved maintained by the quality of Penetration Seal penetration tests. penetration details and penetration seal Documentation alignment with vendor installations vs. fire test tests. configurations (important to fire scenario development).

ECR50856: Medium As Defined Improve availability and Provide alternate No None Communication is implicitly 2015 NFPA 805 reliability of station backup, protected considered in credit for Fire Communication communication system(s) communication system PRA operator actions.

during fire scenarios, to support fire event. However, many are performed in the control room where communication is not threatened by fire.

Note: ECR71588 is not a plant modification. This ECR was added to Table S-1 to emphasize the importance and size of the scope.

Plant Modifications, Items to be Completed During Implementation and Items Completed Page 3

RC**4-0196 Attachment S Table S-2, Implementation Items, provided below includes those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the full implementation of new NFPA 805 fire protection program.

Completion dates are as follows: items 3, 6, 7, 8, 10, 13, 14, 17, 19 and 21 will be completed within 180 days of NRC approval; items 1, 2, 4, 11 and, 12 will be completed by 12/31/2015; and items 5, 15, 16, 18, 20, 22 and 23 will be completed by 3/31/2016.

Table S-2 Implementation Items Item Primary NFPA 805 Description LAR Section / Source Corrective Action No. Code Section 1 3.2 FP Plan Table B-1 Open Items- Revise Fire Protection Program 4.1.2 and Attachment A CR11-03925/01 Administrative procedures (e.g. FP Program Plan, Transient Material Control, Compensatory Measures) as needed for implementation of NFPA 805 Program as defined in Attachment A.

2 3.2.3 Procedures Table B-1 Open Items - Revise Fire Protection Preventive 4.1.2 and Attachment A CR1 1-03925/02 Maintenance and Surveillance procedures to improve alignment to scope and frequencies associated with NFPA Code requirements as defined in Attachment A and NFPA Code of Record Document.

3 3.3 Prevention Table B-1 Open Items - Revise Fire Protection Program Technical 4.1.2 and Attachment A CR1 1-03925/03 procedures (e.g. Electrical Cable, Insulation Materials, Interior Finishes) as needed for implementation of NFPA 805 Program as defined in Attachment A.

4 2.6 Monitoring Table B Enhance VCSNS Condition Monitoring Program to 4.1.2 and Attachment A CR1 1-03925/04 include NFPA 805 elements. (NFPA 805 Sections 3.2.3(3), 2.6) 5 3.4.2 Pre-Fire Plans & 4.3 Table B Update Fire Pre Plans to include NFPA 805 elements, 4.1.2 / 4.4.2 and Attachment A/E CR1 1-03925/05 Radiation Release Fire PRA and Radiological Release elements. (NFPA 805 Section 3.4.2) 6 3.4 Industrial Fire Brigade Table B Enhance VCSNS Fire Brigade Member qualification to 4.1.2 and Attachment A CR1 1-03925/06 include NFPA 805 elements. (NFPA 805 Section 3.4.1) 7 3.4.3 Training and Drills Table B Enhance VCSNS Emergency Response training 4.1.2 / 4.4.2 and Attachment A/E CR1 1-03925/07 program to include NFPA 805 elements. (NFPA 805 Sections 3.4.3, 3.4.4 and 3.4.5) 8 3.4.6 Communications Table B Complete communications study and define strategies to 4.1.2 and Attachment A/G CR1 1-03925/08 ensure viable communications exists to support the fire brigade and other plant personnel during the course of a fire emergency. (NFPA 805 Section 3.4.6) and Items Completed Page 4 Plant Modifications, Items Plant Modifications, be Completed to be Items to During Implementation Completed During Implementation and Items Completed Page 4

RC-14-0196 Attachment S Table S-2 Implementation Items Item Primary NFPA 805 Description LAR Section / Source Corrective Action No. Code Section 9 N/A - removed prior to LAR submittal.

10 3.8.2 Detection Table B Rework any smoke detectors found to not in compliance 4.1.2 and Attachment A CR11-03925/10 with NFPA 72E. (NFPA 805 Section 3.8.2) 11 3.8.2 Detection & 3.11 Table B-l/ B Update Surveillance procedures for "Required" Fire 4.1.2 and Attachment A/C CR1 1-03925/11 Passive FP Features Barriers and ERFBS defined in the NSCA and Fire PRA. (NFPA 805 Sections 3.8.2 and 3.11) 12 3.11 Passive FP Features Table B Update Station Fire Barrier Penetration sealing details to 4.1.2 and Attachment A CR11-03925/12 improve alignment with test protocols acceptable to the Authority Having Jurisdiction. (NFPA 805 Sections 3.11) 13 2.7.2 Configuration Control NFPA 805 - Complete update to Fire PRA procedures to manage 4.7 and Attachment B CR11-03925/13

& 3.2.3 Procedures configuration control of NFPA 805 Analysis documents. (NFPA 805 Section 2.7.2) 14 2.7.2 Configuration Control NFPA 805 - Complete update to Engineering procedures to manage 4.7 and Attachment B CR1 1-03925/14

& 3.2.3 Procedures configuration control of NFPA 805 Analysis documents. (NFPA 805 Section 2.7.2) 15 1.4 Performance Objectives TR08620-312 - Update of station operating procedures, including the 4.2.4 and Attachment C CR1 1-03925/15

& 3.4.2 Pre-Fire Plans conducting associated training (which are not modification related) to incorporate insights and the change in operational shutdown strategy in response to a fire at the station.

16 1.4 Performance Objectives TR07800-008 - Completion of Administrative procedures and 4.3.2 and Attachment D CR1 1-03925/16

& 3.3.1 FP Operational documents to support the implementation of the non-power modes of Activities plant operating states for implementation of NFPA 805.

17 2.7.3.4 Qualification of NFPA 805 - Complete the identification of Training qualifications 2.7.3.4 and 4.7.2 CR1 1-03925/17 Users & 3.2.1 Intent including the training of technical personnel responsible for update and maintenance of the NFPA 805 Analysis. (NFPA 805 Section 2.7.3.4) 18 2.7.1.2 FPP Design Basis NFPA 805 - Complete the development and issuance of the Fire 4.7.1 CR1 1-03925/18 Documents & 3.2.3 Safety Analysis (FSA) to summarize area results and insights from Procedures the NFPA 805 Analysis. (NFPA 805 Section 2.7.1.2) 19 3.4.4 Fire Brigade Table B Improve controls on procurement of FP Equipment to 4.1.2 and Attachment A CR1 1-03925/22 Equipment ensure consistency with NFPA Standards Plant Modifications, Items to be Completed During implementation and Items Completed Page 5

`Irsýceke. RC-14-0196 Attachment S Table S-2 Implementation Items Item Primary NFPA 805 Description LAR Section I Source Corrective Action No. Code Section 20 2.7.2 Configuration Control Resolve (including timing) for 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Emergency Lighting with the CR1 1-03925/25

&3.2.3 Procedures elimination of Operator Manual Actions [except for Control Room Evacuation]

21 Incorporate the recommendations of TR07800-01 1, "Seismic-Fire PRA RAI 35 CR1 1-03925/26 Interactions" into plant procedures and training.

22 Validate/update the Fire PRA model to reflect the as built PRA RAI 13 CR1 1-03925/27 modifications and completed implementation items. This will also include a verification that the resulting change in risk is either less than that currently estimated in Attachment W or is within the guidance of RG 1.174. Should the validation/update of the model reflecting as-built modifications and completed implementation items provide results that do not meet RG 1.174 risk guidelines, actions will be taken to restore compliance with the guidelines. These actions may include re-analysis, additional modeling, procedure changes or even hardware changes to the plant. The course of action taken will be specific to the issue that is causing RG 1.174 not to be met.

23 Upon completion of the project upgrading the PRA model, VCSNS PRA RAI 54 CR11-03925/31 will work with the PWROG and schedule a full scope peer review.

Note: Changes to station procedures and Training associated with station hardware modifications (Table S-1 and Table S-3) normally coincide with scheduled turnover of the equipment to the VCSNS Operation's organization, and are not included in the above table.

and Items Completed Page 6 Plant Modifications, Plant Modiflications, Items be Completed to be Items to During Implementation Completed During Implementation and Items Completed Page 6

._ý& RC-14-0196 Attachment S Table S-3, Plant Modifications Completed, provided below includes a description of the modifications, along with the following information:

• Item ECR number,

• Risk ranking of the modification,

• Location of the modification,

• Problem statement,

• Plant change,

• An indication if the modification is currently included in the Fire PRA,

• Compensatory Measure in place,

• A risk-informed characterization of the modification and compensatory measure, and

• The modification completion year.

Table S-3 Plant Modifications Completed In Fire Comp Risk Informed Item Rank Location Problem Statement Plant Change Measure Characterization Completion PRA ECR50577: Low Yard Operator manual action Provide auto start Yes CLB/ FEP Instrument air importance 2012 NFPA 805 required to start Diesel capability for the Diesel in the internal events Instrument Air Driven Air Compressor Driven Air Compressor model is associated with Recovery (Eliminate OMA). (XAC0014). Steam Generator Tube Rupture. It is not as important for fire scenarios.

ECR50780: High AB Improvement in station Provide addition high Yes None A sensitivity study for the 2013 Alternate Seal equipment to address Loss pressure pump/ Diesel fire PRA showed that this Injection (MSPI) of Seal Cooling/ LOCA Generator to mitigate modification was highly scenarios for RCP Seals. loss of RCP seal important.

cooling (NFPA 805 Credit).

Completed Items Completed Page 7 Plant Plant Modifications, Items to Modifications, Items Completed During be Completed to be Implementation and During implementation and Items Page 7

RC-14-0196 Attachment S Table S-3 Plant Modifications Completed In Comp Risk Informed Item Rank Location Problem Statement Plant Change Fire M p risk Informed PRAPA Measure Characterization Completion ECR50800: High TB436 Address vulnerability of Reroute 115kV Feed to Yes CLB/ FEP A sensitivity study for the 2014 NFPA 805 1 DA loss of the 230kV and ESF bus IDA (Risk) fire PRA showed that this 115kV Supply 115kV feed from 1 DX to [Outage]. modification was highly Reroute 1DA and 1DB (ESF important.

Busses) due to a single TB fire.

ECR50811: High CB Improve early indications of Provide Incipient Yes None A sensitivity study for the 2013 NFPA 805 fire precursors in key risk Detection System at the fire PRA showed that this Incipient significant areas of the top of selected modification was highly Detection plant. electrical panels in the important.

Relay and Upper Cable Spreading Rooms.

ECR50812: High CB Disconnect switches could Protect or reroute the Yes Yes The PRA showed that 2014 NFPA 805 not mitigate spurious disconnect switch spurious operation of these Disconnect operation for all potential cables. components was a Switch Rework circuit failure conditions. significant risk contributor.

Page 8 Plant Modifications, Plant to be Items to Modifications, Items Implementation and During Implementation Completed During be Completed Items Completed and Items Completed Page 8

. Document Control Desk Attachment 2 LAR-06-00055 RC-14-0196 Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION UNIT I DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 2 List of Regulatory Commitments The following table identifies those actions committed to by SCE&G, Virgil C. Summer Nuclear Station in References 1 and 3 as modified by Attachment S, Tables S-1, S-2 and S-3 of this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Bruce L. Thompson, Manager, Nuclear Licensing, (803) 931-5042.

Commitment Due Date/Event ECR50577: NFPA 805 Instrument Air Completed Recovery (2012)

Provide auto start capability for the Diesel Driven Air Compressor (XAC0014).

ECR50780: Alternate Seal Injection (MSPI) Completed Provide addition high pressure pump/Diesel (2013)

Generator to mitigate loss of RCP seal cooling (NFPA 805 Credit).

ECR50784: NFPA 805 Circuit/Tubing 2015 Protection Provide protection of tubing/circuits from the effects of fire.

ECR50799: NFPA 805 RCP Seal 2015 Replacement Provide lower leakage RCP Seals [Outage].

ECR50800: NFPA 805 1 DA 115kV Supply Completed Reroute (2014)

Reroute 115kV Feed to ESF bus 1 DA (Risk)

[Outage].

• Document Control Desk Attachment 2 LAR-06-00055 RC-14-0196 Page 2 of 2 Commitment Due Date/Event ECR50810: NFPA 805 Hazard Protection 2015 Provide mitigation strategies to address fire initiators or limit fire propagation.

ECR5081 1: NFPA 805 Incipient Detection Completed Provide Incipient Detection System at the top (2013) of selected electrical panels in the Relay and Upper Cable Spreading Rooms.

ECR50812: NFPA 805 Disconnect Switch Completed Rework (2014)

Protect or reroute the disconnect switch cables.

ECR71588: NFPA 805 Penetration Seal 2015 Documentation Document updates to include improved penetration details and alignment with vendor tests.

ECR50856: NFPA 805 Communication 2015 Provide alternate backup, protected communication system to support fire event.

Implementation Items listed in Enclosure 2, Table S-2, Implementation Items, Attachment S, Table S-2. provided below includes those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the full implementation of new NFPA 805 fire protection program. Completion dates are as follows: items 3, 6, 7, 8, 10, 13, 14, 17, 19, and 21 will be implemented within 180 day of NRC approval; items 1, 2, 4, 11, and 12 will be complete by 12/31/2015; and items 5, 15, 16, 18, 20, 22, and 23 will be complete by 3/31/2016.

. Document Control Desk Attachment 3 LAR-06-00055 RC-14-0196 Page 1 of 6 VIRGIL C. SUMMER NUCLEAR STATION UNIT I DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 3 Marked Up License Condition

RG. 11 03 49 RC-14-0196 Attachment M R&44-O~49 RC-14-0196 Attachment M M. License Condition Changes 4 Pages Attached 1 PPage

• RG1-3-0349 RC-14-0196 Attachment M Replace the current VCSNS fire protection license condition 2.c (18) with the standard license condition in Regulatory Position 3.1 of RG 1.205, Revision 1, modified as shown below. In support of this change, VCSNS has developed a Fire Probabilistic Risk Assessment (Fire PRA) during the course of its observation of VCSNS's transition to NFPA 805. Outstanding high level findings from the Fire PRA Peer review are included in Attachment V.

(18) Fire Protection System South Carolina Electric & Gas Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated 11/15/11, (and supplements dated 1/26/12, 10/10/12, 2/1/13, 4/1/13, 10/14/13, 11/26/13, 1/9/14, 2/25/14, 5/2/14, 5/11/14, 8/14/14, 10/9/14, and 12/11/14) and as approved in the safety evaluation report dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

a. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

b. Prior NRC review and approval is not required for individual changes that result in a risk

-7 -8 increase less than 1 xl0 /year (yr) for CDF and less than lx10 /yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

21 Page

RG 4 RC-14-0196 Attachment M Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall approve the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall approve the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

• Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

• Gaseous Fire Suppression Systems (Section 3.10); and,

• Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated . The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

(2) The licensee shall implement the modifications to its facility, to com.plete the t.ansitio to full compliance with 10 CFR 50.48(G) by Derember 31, 2015 as described in Attachment S, Table S-1, "Plant Modifications Committed," of SCE&G letter RC-14-0196, dated December 31 Page

RG 110149 RC-14-0196 Attachment M R~-14-OM9 RC-14-0196 Attachment M 11, 2014, by the end of the calendar year 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

E=CR50577: NFPA 805 Instrument Air Recvery ECGR50780: Alternate Seal Injection (MSPI)

ECR50784: NFPA 805 ir-.Uit/Tubing Proteci*On ECR -0799: NFPA 805 RCP Seal Replacement EC R60800: N.FPA 805 1DA 11 5kV & .S ,pReroute

=CRn'810:. NFPA 805 Hazard ProtecDtiGn ECR5081 1: NFPA 805 Incipient DetectioR S

ECR50812: NFPA 805 DiGconnect Switch Rework i

ECR70588 ECR71588: NFPA 805 Pen atwen Seal Documentation I eLI i CY1D7-jr-r-13 IE'DA Otr-= t'rl:, .. 44.-,,-..,

(3) The licensee shall Gemplete implementatiem the items listed in Attachment S, Table S-2, "Implementation Items," of SCE&G letter RC-14-0196, dated December 11, 2014, submitted i letter RC 14 0158 dated OGctber 9, 2014, by the com.pletion dates specified in Table S 2 to complete the transition to full compliance with 10 CFR 50.48(c) by March 31, 2016 as follows:

a. Items 3, 6, 7, 8, 10, 13, 14, 17, 19, and 21 within 180 days of NRC approval.

b. Items 1, 2, 4, 11, and 12 by December 31, 2015.

c. Items 5, 15, 16, 18, 20, 22, and 23 by March 31, 2016.

-- L--II -----

\*r/ +He iicen~ee shalli m~ ; apprlopiate

-intain rompensato; Ir neasu res in plaeeun completion of the mn FHO M-10 V"O V "VO V MrM-l C2" above.

License condition 2.c (18) shall be superseded upon full implementation of the NFPA 805 license condition:

Fire Protection System (Section 9.5.1, SSER 4)

Virgil C. Summer Nuclear Station shall implement and maintain in effect all provisions of the approved fire protection program as describedin the FinalSafety Analysis Report for the facility, and as approved in the Safety Evaluation Report (SER) dated February 1981 (and Supplements dated January 1982 and August 1982) and Safety Evaluationsdated May 22, 1986, November 26, 1986, and July 27, 1987 subject to the following provisions:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintainsafe shutdown in the event of fire.

41 Page

R' 110149 RC-14-0196 Attachment M No other license conditions need to be revised or superseded.

VCSNS implemented the following process for determining that these are the only license conditions required to be either revised or superseded to implement the new FPP which meets the requirements in 10 CFR 50.48(a) and 50.48(c):

A review was conducted of the VCSNS Facility Operating License NPF-12, by VCSNS licensing staff and NFPA 805 Transition Team. The review was performed by reading the Operating License and performing electronic searches. In addition, outstanding LARs that have been submitted to the NRC were also reviewed for potential impact on the license conditions.

Refer to Enclosure 3 for the proposed VCSNS Facility Operating License NPF-12 markups and retyped pages.

51 Page

Document Control Desk LAR-06-00055 RC-14-0196 Page 1 of 5 VIRGIL C. SUMMER NUCLEAR STATION UNIT I DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 4 Operating License & Technical Specification Changes Attachment to License Amendment No. LAR-06-00055 To Facility Operating License No. NPF-12 Docket No. 50-395 Replace the following pages of the Operating License and Appendix A 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 Insert Pages OL Page 7 OL Page 7 OL Page 7a OL Page 7b OL Page 8 OL Page 8 TS Page 6-11 TS Page 6-11 (Submitted with RC-1 1-0149)

e

b. In the event that one-third thickness semi-circular reference flaws cannot be detected and discriminated from inherent anomalies, the entire volume of the weld shall be examined during the inservice inspection.

c. The reporting of the inservice inspection examination results shall be documented in a manner to define qualitatively whether, the weldment and the heat affected zone and adjacent base metal on both sides of the weld were examined by ultrasonic angle beam techniques.

(9) Design Description - Control (Section 4.3.2. SER)

SCE&G is prohibited from using part-length rods during power operation.

(13) Deleted (14) Deleted (15) Deleted (16) Cable Tray Separation (Section 8.3.3, SSER 4)

Prior to startup after the first refueling outage, SCE&G shall implement the modifications to the cable trays discussed in Section 8.3.3 of Supplement No. 4 to the Safety Evaluation Report or demonstrate to the NRC staff that faults induced in non-class 1E cable trays will not result in failure of cable in the adjacent Class 1 E cable trays.

(17) Alternate Shutdown System Section 9.5.1, SSER 4)

Prior to startup after the first refueling outage, SCE&G shall install a source range neutron flux monitor independent of the control complex as part of the alternate shutdown system.

(18) Fire Protection System South Carolina Electric & Gas Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated 11/15/11 (and supplements dated 1/26/12, 10/10/12, 2/1/13, 4/1/13, 10/14/13, 11/26/13, 1/9/14, 2/25/14, 5/2/14, 5/11/14, 8/14/14, 10/9/14, and 12/11/14) and as approved in the safety evaluation report dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Renewed Facility Operating License No. NPF-12

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-7a-Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

a. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

b. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10 7/year (yr) for CDF and less than 1 xl 0-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall approve the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard."

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative Renewed Facility Operating License No. NPF-12

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-7b-to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall approve the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

" Fire Alarm and Detection Systems (Section 3.8);

" Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

" Gaseous Fire Suppression Systems (Section 3.10); and,

" Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated

_ The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

(2) The licensee shall implement the modifications to its facility, as described in Attachment S, Table S-1, "Plant Modifications Committed," of SCE&G letter RC-14-0196, dated December 11, 2014, by the end of the calendar year 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

(3) The licensee shall implement items listed in Attachment S, Table S-2, "Implementation Items," of SCE&G letter RC-14-0196, dated December 11, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by March 31, 2016 as follows:

a. Items 3, 6, 7, 8, 10, 13, 14, 17, 19, and 21 within 180 days of NRC approval.

b. Items 1,2, 4, 11, and 12 by December 31, 2015.

c. Items 5, 15, 16, 18, 20, 22, and 23 by March 31, 2016.

Renewed Facility Operating License No. NPF-12

(19) Instrument and Control Vibration Tests for Emergency Diesel Engine Auxiliary Support Systems (Section 9.5.4, SER)

Prior to startup after the first refueling outage, SCE&G shall either provide test results and results of analyses to the NRC staff for review and approval which validate that the skid-mounted control panels and mounted equipment have been developed, tested, and qualified for operation under severe vibrational stresses encountered during diesel engine operation, or SCE&G shall floor mount the control panels presently furnished with the diesel generators separate from the skid on a vibration-free floor area.

(20) Solid Radioactive Waste Treatment System (Section 11.2.3, SSER 4)

SCE&G shall not ship "wet" solid wastes from the facility until the NRC staff has reviewed and approved the process control program for the cement solidification system.

(21) Process and Effluent Radiological Monitoring and Sampling Systems (Section 11.3, SSER 4)

Prior to startup after the first refueling outage, SCE&G shall install and calibrate the condensate demineralizer backwash effluent monitor RM-L11.

(22) Core Reactivity Insertion Events (Section 15.2.4, SSER 4)

For operations above 90% of full power, SCE&G shall control the reactor manually or the rods shall be out greater than 215 steps until written approval is received from the NRC staff authorizing removal of this restriction.

(23) NUREG-0737 Conditions (Section 22)

SCE&G shall complete the following conditions to the satisfaction of the NRC staff. Each item references the related subpart of Section 22 of the SER and/or its supplements.

a. Procedures for Transients and Accidents (I.C.1, SSER 4)

Prior to startup after the first refueling outage, SCE&G shall implement emergency operating procedures based on guidelines approved by the NRC staff.

Renewed Facility Operating License No. NPF-12