ML19122A517

Annual Commitment Change Summary Report

ML19122A517
Person / Time
Site:	Summer
Issue date:	05/02/2019
From:	Lippard G South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
19-206, VCS LIC/WCM, Rev. 0
Download: ML19122A517 (6)

Text

< scE&G. A SCANA COMPANY May 2, 2019 U. S. Nuclear Regulatory Commission Serial No.: 19-206 Attention: Document Control Desk VCS LIC/WCM: Rev 0 Washington, DC 20555-0001 Docket No.: 50-395 License No.: NPF-12 SOUTH CAROLINA ELECTRIC & GAS (SCE&G) COMPANY VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 ANNUAL COMMITMENT CHANGE

SUMMARY

REPORT Please find attached the 2018 Annual Commitment Change Summary Report. The commitment changes were performed in accordance with VCSNS's Regulatory Commitment Management Program, which was developed following guidance from NEI 99-04 "Guidelines for Managing NRC Commitment Changes."

Should you have any questions or require additional information, please contact Mr.

Michael S. Moore at (803) 345-4752.

~~

George Lippard Site Vice President V.C. Summer Nuclear Station V. C. Summer Nuclear Station, P. 0. Box 88, Jenkinsville, South Carolina, 29065, F(803) 941-9776

• www.sceg.com

Serial No.19-206 Docket No. 50-395 Page 2 of 2 Commitments contained in this letter: None

Attachment:

Summary of Commitment Changes cc: G. J. Lindamood Nuclear Coordinator Santee CooperNCSNS Catherine Haney Regional Administrator U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 S. A. Williams Senior Project Manager - VCSNS U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B-1 A 11555 Rockville Pike Rockville, Maryland 20852 NRC Senior Resident Inspector VCSNS

ATTACHMENT Summary of Commitment Changes Virgil C. Summer Nuclear Station - Unit 1 South Carolina Electric and Gas

Serial No.19-206 Docket No. 50-395 Page 1 of 3 The following commitment changes, with a brief justification, were performed during 2018 in accordance with Virgil C. Summer Nuclear Station's (VCSNS) Regulatory Commitment Management Program, which was developed following NEI 99-04, "Guidelines for Managing NRG Commitment Changes." The changes are documented in the station's corrective action program condition reports (CRs):

CR-18-02427 Commitment - SCE&G committed to submit a license amendment request (LAR) identifying doors DRIB/105A&B as doors that were evaluated to have variances from NFPA-80 requirements . Changes were applied to the doors but an LAR was required to address cited violation 05000395/2016007-01 received for the door variances and to update the current license basis. The commitment was to submit the LAR by June 30, 2018.

Change - The commitment date to submit the LAR for doors DRIB/105A&B doors was changed from June 30, 2018 to August 31, 2018.

Justification for Change/Deletion - Changes in the scope of the LAR and additional time needed to review information necessary to support the LAR were in progress (CR-16-05919).

In the station's original NFPA-805 LAR submittal, SCE&G did not identify doors DRIB/105A&B as fire doors that did not meet the self-closing requirements in accordance with NFPA-80. The oversight resulted in SCE&G receiving an NRG violation. In response to the violation, SCE&G initially committed to update the station's licensing design basis through a revision to the NFPA-805 LAR by April 28, 2017. Due to additional time being needed to complete the analysis and review the information )

necessary to support the LAR's resubmittal , SCE&G submitted a revised commitment I date for the LAR's resubmittal from April 28, 2017 to November 30, 2017. Due to the changes in the scope of the LAR to address (1) update of the Fire Probabilistic Risk (

Assessment (Table 'W') to correct modeling errors; (2) address de-scoped plant modifications; (3) identify DRIB/105A&B as doors that have been evaluated for variances from NFPA-80 requirements; and (4) revision of documentation impacted by the noted changes, additional time was required to support the LAR resubmittal. The additional effort and subsequent reviews required to support changes in scope of the LAR necessitated a change in the resubmittal date from November 30, 2017 to June 30, 2018 .

SCE&G identified the need for additional time to complete preparation of the LAR submittal and submitted a change in commitment date to the NRG (Reference RC 0074, dated June 18, 2018) updating the LAR submittal date from June 30 , 2018 to August 31, 2018.

Serial No.19-206 Docket No. 50-395 Page 2 of 3 CR-18-01018 Commitment - The station committed to verify the Spent Fuel Pool Level Indication (SFPLI) function (transmitters ILT09780-FX and ILT09781-FX), verify battery capability, and replace Lithium C-cell batteries every 6 months.

Change - The replacement schedule for the Lithium C-cell batteries was extended from every 6 months to every 18 months.

Justification For Change/Deletion - The history of performance and function of the new SFPLI equipment revealed the calibration frequency supported a replacement frequency from 6 months to 18 months. Preventative Maintenance (PM) feedback after several performances found the indicators worked properly and that the station had been unnecessarily replacing the batteries. Engineers agreed to the frequency extension based on equipment performance and the as-found conditions.

CR-13-04375 Commitment - SCE&G committed to full implementation of the Open Phase Isolation System (OPIS) in the letter from Thomas D. Gatlin, "Response to Request for Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System [ML14035A455]. Full implementation of the OPIS was based on the below schedule:

1. Installation of the OPIS system on engineered safeguards feature (ESF) transformer XTF-4 by RF-23 (July 2017).

2. Enabling of trip function on ESF transformer XTF-31 by December 31, 2018.

3. Enabling of the trip function on ESF transformers XTF-4 and XTF-5 by December 31, 2018 .

4. Full implementation of the OPIS by December 31, 2018.

On December 11, 2017 (ML17346A577), SCE&G submitted a commitment change revising the OPIS installation schedule as follows:

1. Installation of the OPIS system on transformer XTF-4 will be in the Fall 2018 during refueling outage 24 (RF-24).

2. Enabling of trip function on ESF transformer XTF-31 by December 31, 2018.

3. Enabling of the trip function on ESF transformers XTF-4 and XTF-5 by June 30, 2020.

4. Full implementation of the OPIS by June 30 , 2020.

Change - Perform the OPIS installations according to the revised schedule.

1. Install the OPIS Trip Function on ESF Transformer XTF-31 by October 31, 2020.

Serial No.19-206 Docket No. 50-395 Page 3 of 3

2. Install the OPIS Trip Function on ESF Transformers XTF-4 and XTF-5 by October 31, 2020.

3. Full implementation of the OPIS by October 31,2020.

Justification for Change/Deletion - On December 11, 2017, SCE&G submitted a commitment date change as a result of an RF-23 outage emergent issue requiring the delay of installation of the OPIS system on XTF-4 . By letter dated September 20, 2018, NEI communicated to the NRC a revision to the NEI Open Phase Condition Industry Initiative. This revision provided an extension of the open phase monitoring period into 2020 for plants that had not accumulated the full 24 months of monitoring .

VCSNS subsequently changed the commitment date for full implementation of the OPIS from June 30, 2020 to October 31, 2020. VCSNS will also enable the trip function on transformers XTF-4 , XTF-5, and XTF-31 by the end of October 2020 . These commitment date changes were proposed in accordance with the 24-month monitoring period extension detailed in the NEI Open Phase Condition Industry Initiative

[ML18268A114].