RC-96-0168, Submits Suppl Info,As Requested by NRC to Support SE Presented as Attachment II to Util ,Requesting Amend to TS Re MOVs Thermal Overload Protection & Bypass Devices

Submits Suppl Info,As Requested by NRC to Support SE Presented as Attachment II to Util ,Requesting Amend to TS Re MOVs Thermal Overload Protection & Bypass Devices

ML20115E876
Person / Time
Site:	Summer
Issue date:	07/11/1996
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RC-96-0168, RC-96-168, NUDOCS 9607160269
Download: ML20115E876 (6)

Text

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• South Ctrolins Elictric & Gas Compiny Gtry J.Trylor P.O. Box 88 Vice President Jenkinsville, SC 29065 Nuclear Operations (803i 345 4344 SCE&G esammcmwy July 11,1996 RC-96-0168 I

l Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. A.R. Johnson l Gentlemen:

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Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO.NPF-12 TECHNICAL SPECIFICATION CHANGE -TSP 940007 i MOTOR OPERATED VALVES THERMAL OVERLOAD l PROTECTION AND BYPASS DEVICES SUPPLEMENTAL INFORMATION

Reference:

G. J. Taylor Letter to Document Control Desk, RC-95-0184, November 14,1995 South Carolina Electric and Gas Company (SCE&G), acting for itself and as agent t for South Carolina Public Service Authority, hereby submits supplemental information, as requested by your staff, to sup > ort the Safety Evaluation presented as Attachment II to the referenced letter datec. November 14,1995, requesting

, amendment to the Virgil C. Summer Nuclear Station (VCSNS) Technical i Specifications (TS).

This supplement addresses the Criterion of the NRC TS Policy Statement, the Bases questions of the Policy Statement concerning LCOs and Surveillances, and human factors considerations, as encouraged by the Policy Statement. Based on the responses achieved for these criteria, along with the initial evaluation submitted, SCE&G contends that relocation of the indicated TS to VCSNS plant programs isjustified.

This proposed TS amendment request has previously been reviewed by both the Plant Safety Review Committee and the Nuclear Safety Review Committee.

These statements and matters set forth herein are true and correct to the best of my i knowledge, information, and belief.

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' Document Control D:sk TSP 940007 RC-96-0168 I Page 2 of 2 1

1 Should you have questions, please call Mr. Jim Turkett at (803) 345-4047. l Very truly yours, f & $J M 67 Gary J. Taylor

! JWT/GJT/dr Attachment l c: J. L. Skolds J. B. Knotts Jr.

W. F. Conway M. K. Batavia l R.R.Mahan (w/o Attachment) K. R. Jackson l R. J. White RTS(TSP 940007) l l S. D. Ebneter File (813.20)

NRC ResidentInspector j DMS (RC-96-0168)  !

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STATE OF SOUTHCAROLINA  :

TO WIT :

l COUNTY OF FAIRFIELD  :

Ihereby certify that on the nd day of Ja4 19f_/,_, before me, the l subscriber, a Notary Public of the State of Soutif Carolina, personally appeared Stephen A.B ne, being duly sworn, and states that he has signature authority as l designated b theVice President, Nuclear Operations of the South Carolina l

Electric & G s Company, a corporation of the State ofSouth Carolina, that he provides the foregoing response for the purposes therein set forth, that the statements made are true and correct to the best of his knowledge, information, ,

and belief, and that he was authorized to provide the response on behalf of said '

l Corporation.

WITNESS my Hand and Notarial Seal MIM s.

M Nbtary Public My Commission Expires

Date NUCLEAR EXCELLENCE - A SUMMER TRADITION!

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, . Document Control Desk l -

Att chm:nt l TSP 940007

! RC-96-0168 I

Page 1 of4 SUPPLEMENTAL SAFETY CONSIDERATIONS FOR TSP 940007 SAFETY EVALUATION FOR REMOVING THE SPECIFICATION FOR MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION l

AND BYPASS DEVICES FROM THE l VIRGIL C. SUMMER NUCLEAR STATION

} TECHNICAL SPECIFICATIONS t

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] POLICY STATEMENT CRITERION l The proposed amendments to TS 3/4.8.4 have been reviewed in accordance with the l l Commission Policy Statement Criterion (s) for Technical Specifications as published )

l in 10 CFR 50.36, September 29,1995. ,

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I Criterion 1 -Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. l The thermal overload protection and bypass devices installed at VCSNS do not provide any function in the detection of pressure boundary leakage.

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Criterion 2 - A process variable, design feature, or operating restriction that is an \

initial condition of a design basis accident or transient analysis that either assumes the failure oforpresents a challenge to the integrity of a fission product barrier.

I The thermal overload protection and bypass devices installed at VCSNS are not used '

to define an initial condition of a design basis accident (DBA) or transient analyses j that impacts the integrity of fission product barriers. j l

Criterion 3 - A structure, system, or component that is part of the primary success path

and which functions or actuates to mitigate a design basis accident or transient that l either assumes the failure oforpresents a challenge to the integrity of a fission product barrier.

The thermal overload protection and bypass devices installed at VCSNS are automatic functioning devices energized only when the associated equipment they j protect are energized. These devices serve as subcomponents for the electrical circuit of components which are part of the primary success path and do not directly function nor actuate, in and of themselves, to mitigate a DBA or transient where a fission product barrier is assumed failed or challenged.

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. Document Control Desk Attachment l 'I'SP 940007 i

l RC-96-0168 Page 2 of 4 l Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The thermal overload protection devices installed at VCSNS are subcomponents of their associated equipment and function to provide low level overcurrent protection ,

to their associated equipment electrical power circuits; except when bypassed by a bypass device, ifinstalled. Operating experience has shown that thermal overloads are highly reliable devices which, therefore, have minimal effect on equipment operability.

Under accident conditions, the by 3 ass devices serve to remove the thermal overload protection from equipment, upon 3SF actuation signals, to preclude any potential for l thermal overloads causing nuisance trippin g of the associated load. Thus, the design function of the bypass device is to allow the Load to receive power, even under slight overload (overcurrent) conditions, because operation of the load is what is desired.

l Circuit fault conditions (severe overcurrent) would still be cleared by tripping of the upstream circuit breaker, should this condition develop. Failure of the bypass device to function will not, by itself, prevent the load from receiving power to operate.

Therefore, the thermal overload protection and bypass devices installed at VCSNS do not constitute components which are significant to the public health and safety.

l l BASES TO SUPPORT RELOCATION l (Address Surveillance Bases Questions Posed in Policy Statement) ,

, The proposed amendments to TS 3/4.8.4 have been reviewed in accordance with the Commission Policy Statement Criterion (s) for Technical Specifications as published in the Federal Register / Vol. 58, No.139/ Thursday, July 22,1993/ Rules and Regulations (pp. 39136-39137) and as codified in 10CFR50.36.

1. What is thejustification for the Technical Specification, i.e., which Policy

\ Statement criterion requires it to be in the Technical Specifications ?

1 l The proposed amendments do not fulfill any of the Criterion of the Policy Statement l necessary for inclusion in TS.

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2. What are the Bases for each LCO, i.e., why was it determined to be the lowest l functional capability orperformance levelfor the system or component in question '

necessary for safe operation of the facility and, what are the reasons for the Applicability of the LCO? l The thermal overload protection and bypass devices are subcomponents whose primary function ca )a sility or performance level is not directly associated with safe I operation of the faci: ity. Limiting Condition for Operation (LCO) for the existing TS refer the licensee to the associated equipment or system that these devices protect.

TS provides sufficient criteria for the determination of the associated equipment or system operability.

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Attachment TSP 940007 RC-96-0168 Page 3 of 4

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3. What are the Bases for each Action, i.e., why should this remedial action be taken if the associated LCO cannot be met; how does this Action relate to other Actions associated with the LCO; and whatjustifies continued operation of the system or component at the reduced state specified in the LCO for the allowed time period?

Action for the existing TS refer the licensee to the associated equipment or system that these devices protect for the Action to be implemented. TS provides sufficient criteria within the Action for the associated equipment or system to determine operability.

4. What are the bases for each Safety Limit ?

There are no safety limits associated with the thermal overload protection and bypass devices, t l

l 5. What are the Bases for each Surveillance Requirement and Surveillance l Frequengy; i.e., what specific functional requirement is the surveillance designed to verify ? Why is this surveillance necessary at the specifiedfrequency to assure that the system or component function is maintained, that facility operation will be within the Safety Limits, and that the LCO will be met?

Surveillance requirements for these devices were developed due to SCE&G's commitment to Regulatory Guide (RG) 1.106 in the VCSNS FSAR. The frequency was conservatively estabhshed to coincide with refueling shutdowns when the

( associated equipment or systems would not require operation and would be i l

accessible. The surveillance and frequency provide assurance that the thermal overload protection and bypass devices provide the protection feature for which they )

are desi l devicee.gned; Safety Limits and LCOs for facility operation are not affected by these l

l HUMAN FACTORS CONSIDERATIONS Relocation to the established VCSNS plant procedures will decrease the number of source documents that plant personnel must maintain and subscribe to in order to perform the activities addressed by RG 1.106. Potential for human error is decreased (omissions of activities, missed surveillances, etc.) as the program is centrally focused within the plant program.

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TSP 940007 RC-96-0168 Page 4 of 4 VCSNS CONTROIS TO ASSURE LCO ANDSURVEILLANCE ACTIVITIES ARE NOT COMPROMISED The requirements of RG 1.106 for thermal overload protection and bypass devices are implemented through VCSNS plant surveillance test procedures (STPs). The implementing STPs address actions corresponding to the LCOs and Action statements of the existing TS.

The implementing procedures are controlled through Station Administrative Procedure (SAP) 139, " Procedure Development, Review, App'roval, and Control."

Any pr,oposed change is further screened through SAP-107, 10 CFR 50.59 Unreviewed Safety Question Review Process." Also, SAP-139 requires a review to determine if any commitments are impacted by a proposed revision or change to the implementing procedures. This review is directed to SAP-630, " Procedure /

Commitment Accountability Program (P/ CAP)" to identify any commitments (TS, FSAR, RG, etc.) that impact a procedure.

The P/ CAP was established to assure regulatory compliance is maintained in VCSNS plant procedures. Any proposed revision or chan re which could compromise a -

regulatory commitment is screened through the 9/ CAP.

SUMMARY

- SUPPLEMENTAL SAFETY EVALUATION Based on the Criterion of the Policy Statement and the questions licensees were directed to consider in the Policy Statement, SCE&G has determined that TS 3/4.8.4.2 may be relocated to plant programs and removed from TS. Human factors considerations also support relocation.

This supplemental safety evaluation supports the TS amendment request submitted November 14,1995 and reiterates that the proposed amendments to TS 3/4.8.4 involve no substantive changes to SCE&G's commitment in FSAR Appendix 3A to comply with RG 1.106, only format changes due to its relocation from TS to plant procedures.

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