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{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 June 14, 2011 South Carolina Electric and Gas Company, Inc.
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 14, 2011 LICENSEE:              South Carolina Electric and Gas Company, Inc.
Virgil C. Summer Nuclear Station (VCSNS), Unit No.1  
FACILITY:              Virgil C. Summer Nuclear Station (VCSNS), Unit No.1 SUB~IECT:             


==SUMMARY==
==SUMMARY==
OF MARCH 31, 2011, MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY TO DISCUSS NFPA-B05 LICENSE AMENDMENT (TAC NO. ME5954) On March 31, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of South Carolina Electric and Gas Company, Inc. (SCE&G, the licensee), at NRC Headquarters in Rockville, Maryland.
OF MARCH 31, 2011, MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY TO DISCUSS NFPA-B05 LICENSE AMENDMENT (TAC NO. ME5954)
SCE&G requested the public meeting to discuss the current status of its plans to submit a license amendment request (LAR) based on the National Fire Protection Association Standard B05, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" (NFPA-B05).
On March 31, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of South Carolina Electric and Gas Company, Inc. (SCE&G, the licensee), at NRC Headquarters in Rockville, Maryland. SCE&G requested the public meeting to discuss the current status of its plans to submit a license amendment request (LAR) based on the National Fire Protection Association Standard B05, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" (NFPA-B05). A list of attendees is provided as Enclosure 1.
A list of attendees is provided as Enclosure
SCE&G's presentation (see Enclosure 2) included the following topics:
: 1. SCE&G's presentation (see Enclosure
* NFPA-B05 Project Goals: Submit an LAR to transition VCSNS Unit 1 to a performance based fire protection program via NFPA-B05. This would include eliminating the self induced station blackout (SISBO) strategy, minimization of operator manual actions (OMAs) for fire occurring outside the main control room and addressing all current industry issues concerning multiple hot shorts/spurious events, the feasibility of operator actions and "authorized" use of OMAs.
: 2) included the following topics: NFPA-B05 Project Goals: Submit an LAR to transition VCSNS Unit 1 to a based fire protection program via NFPA-B05.
* NFPA-B05 Project Status
This would include eliminating the induced station blackout (SISBO) strategy, minimization of operator manual actions (OMAs) for fire occurring outside the main control room and addressing all current industry issues concerning multiple hot shorts/spurious events, the feasibility of operator actions and "authorized" use of OMAs. NFPA-B05 Project Status Nuclear Safety Compliance Assessment (NSCA) NSCA Open Items Major Transition Report Attachments VC Summer Fire Probabilistic Risk Assessment (PRA) VC Summer Fire PRA Results -The Fire PRA (FPRA) core damage frequency takes credit for modifications on protecting circuits, alternate seal injection, incipient detection and reactor coolant pump shutdown seals. Fire PRA Results Summary including dominant risk sequences Relative improvement value of modifications VCSNS FPRA Peer Reviews Significant Peer Findings Performance-Based Solutions Performance-Based Fire Modeling
* Nuclear Safety Compliance Assessment (NSCA)
-2 General discussion of modifications.
* NSCA Open Items
SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator. Nonpower Operations Radioactive Release Analysis Implementation Actions Condition Monitoring NFPA-805 Project Issues -including station management review of the transition report and targeted submittal of the LAR by June 28, 2011. NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished.
* Major Transition Report Attachments
They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power. The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 -1000 pages in length. Members of the public representing other utilities and industry groups were in attendance.
* VC Summer Fire Probabilistic Risk Assessment (PRA)
* VC Summer Fire PRA Results - The Fire PRA (FPRA) core damage frequency takes credit for modifications on protecting circuits, alternate seal injection, incipient detection and reactor coolant pump shutdown seals.
* Fire PRA Results Summary including dominant risk sequences
* Relative improvement value of modifications
* VCSNS FPRA Peer Reviews
* Significant Peer Findings
* Performance-Based Solutions
* Performance-Based Fire Modeling
 
SCE&G                                            -2
* General discussion of modifications. SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator.
* Nonpower Operations
* Radioactive Release Analysis
* Implementation Actions
* Condition Monitoring
* NFPA-805 Project Issues - including station management review of the transition report and targeted submittal of the LAR by June 28, 2011.
* NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished. They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power.
The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 - 1000 pages in length.
Members of the public representing other utilities and industry groups were in attendance.
Public Meeting Feedback forms were available at the meeting but no comments were received.
Public Meeting Feedback forms were available at the meeting but no comments were received.
j)Robert Martin, s7nt;? Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395  
j) Robert Martin, s7nt;?~ger Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395


==Enclosures:==
==Enclosures:==
: 1. List of Attendees
: 1. List of Attendees
: 2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation]
: 2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation] Staff, March 31, 2011 cc w/encls: Distribution via Listserv
Staff, March 31, 2011 cc w/encls: Distribution via Listserv LIST OF NRC MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY, INC. REGARDING LICENSE AMENDMENT APPLICATION ON FIRE MARCH NAME AFFILIATION Robert Martin NRC/NRRlDORL Patrick Boyle NRC/NRRlDORL Paul Lain NRC/NRRlDRA Alex Klein NRC/NRRIDRA Doug Pickett NRC/NRRIDORL Donnie Harrison NRC/NRRlDRA Stephen Dinsmore NRC/NRRlDRA Gary Cooper NRC/NRRlDRA Samson Lee NRC/NRRlDRA Dan Gatlin SCE&G George Williams SCE&G Eric Rumfelt SCE&G Gerald LOignon, Jr SCE&G Wayne Stuart SCE&G Gil Williams SCE&G Bruce Thompson SCE&G Michael Kammer SCE&G Tom Basso NEI Via Telephone Conference Bridge Line
* Robert Layton PNNL Bijan Najafi SAIC Paul Amico SAIC Larry Young Entergy Vesna Dimitrijevic AREVA NP Michael Seaman-Huynh SC Office of Regulatory Staff Sal Dolcemascolo SONGS
* based on prior notifications Enclosure 1 


NFPA805 Lice"nse // Am __ ..
LIST OF ATTENDEES NRC MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY, INC. (SCE&G)
March 31,2011 VC Summer Dan Gatlin Vice President, VC Summer Unit 1 Wayne Stuart General Manager, Engineering Services Bruce Thompson Manager, Nuclear licensing Mike Kammer NFPA 805 Project Manager Gerald Loignon Supervisor, PRA Group Eric Rumfelt Supervisor, Nuclear Licensing George Williams Supervisor, Engineering Programs v.c. SUMMER NUCLEAR STATION Enclosure 2 1
REGARDING LICENSE AMENDMENT APPLICATION ON FIRE PROTECTION MARCH 31,2011 NAME                      AFFILIATION Robert Martin              NRC/NRRlDORL Patrick Boyle              NRC/NRRlDORL Paul Lain                  NRC/NRRlDRA Alex Klein                NRC/NRRIDRA Doug Pickett              NRC/NRRIDORL Donnie Harrison            NRC/NRRlDRA Stephen Dinsmore          NRC/NRRlDRA Gary Cooper                NRC/NRRlDRA Samson Lee                NRC/NRRlDRA Dan Gatlin                 SCE&G George Williams            SCE&G Eric Rumfelt              SCE&G Gerald LOignon, Jr        SCE&G Wayne Stuart               SCE&G Gil Williams              SCE&G Bruce Thompson             SCE&G Michael Kammer             SCE&G Tom Basso                  NEI Via Telephone Conference Bridge Line
* Robert Layton              PNNL Bijan Najafi              SAIC Paul Amico                SAIC Larry Young                Entergy Vesna Dimitrijevic        AREVA NP Michael Seaman-Huynh SC Office of Regulatory Staff Sal Dolcemascolo          SONGS
* based on prior notifications Enclosure 1


NFPA805 Project Goals NFPA805 Transition: Successfully submit an LAR to transition VCSummer Unit to a Performance Based Fire protection Program NFPA80S (10CFRSO.48(c))
3/30/2011 NFPA805 Lice"nse //
[Letter October VC Summer Goals (Additional) SISBO: Eliminate the SISBO Strategy Fires outside Main Control Room: Minimize, to extent possible, Operator Manual Actions Industryl CLB Issues: Address all current industry concerning Multiple Spurious Operations/ Feasibility of Operator Actions and use of Operator Actions in Appendix R IIIG.2 V.C. SUMMER NUCLEAR STATION NFPA805 Project Status Major Tasks NSCA Modell Open Issues FirePRA Performance Based Resolution (VFDR) -Fire Risk Evaluation
Am __ .~. 9_ffTein'r~'r1e6'deS March 31,2011 VC Summer Attendees Dan Gatlin      Vice President, VC Summer Unit 1 Wayne Stuart    General Manager, Engineering Services Bruce Thompson  Manager, Nuclear licensing Mike Kammer      NFPA 805 Project Manager Gerald Loignon  Supervisor, PRA Group Eric Rumfelt    Supervisor, Nuclear Licensing George Williams  Supervisor, Engineering Programs v.c. SUMMER NUCLEAR STATION Enclosure 2 1
-Performance Based Fire Modeling Non Power Operations NFPA805: NFPA Code Compliance Radioactive Release Analysis Fire Protection Program -Administrativel Condition Monitoring V.C. SUMMER NUCLEAR STATION 2


Nuclear Safety Compliance Assessment (NSCA) Status/ Updates PCCKS Updates Complete Model Development:
3/30/2011 NFPA805 Project Goals NFPA805 Transition:
Open Issue Complete NSCA Model Review (SCE&G) Complete ECR Package Reviews (SCE&G) Complete NSCA Model Updates Complete Finalize Open Issues (DROID) Complete Finalize Detailed Mod (Detail) Finalizing Documentation/
* Successfully submit an LAR to transition VCSummer Unit 1 to a Performance Based Fire protection Program via NFPA80S (10CFRSO.48(c)) [Letter October 2006]
SCE&G Reviews Finalizing V.C. SUMMER NUCLEAR STATION NSCA Open ORal OS: NSCA Open Items VFOR (Green): Performance Based Solutions Other Solutions Modifications Additional Circuit analysis Model Updates V.C. SUMMER NUCLEAR STATION
VC Summer Goals (Additional)
* SISBO: Eliminate the SISBO Strategy
* Fires outside Main Control Room: Minimize, to the extent possible, Operator Manual Actions (OMA)
* Industryl CLB Issues: Address all current industry issues concerning Multiple Spurious Operations/ Events, Feasibility of Operator Actions and use of Operator Manual Actions in Appendix R IIIG.2 areas.
V.C. SUMMER NUCLEAR STATION NFPA805 Project Status Major Tasks
* NSCA Modell Open Issues
* FirePRA
* Performance Based Resolution (VFDR)
  - Fire Risk Evaluation
  - Performance Based Fire Modeling
* Non Power Operations
* NFPA805: NFPA Code Compliance
* Radioactive Release Analysis
* Fire Protection Program
  - Administrativel Condition Monitoring V.C. SUMMER NUCLEAR STATION 2


Major TR Attachments Attachment 81: Chapter 3 Compliance
3/30/2011 Nuclear Safety Compliance Assessment (NSCA)
Status/ Updates
* PCCKS Updates                  Complete
* Model Development: Open Issue Complete
* NSCA Model Review (SCE&G) Complete
* ECR Package Reviews (SCE&G) Complete
* NSCA Model Updates            Complete
* Finalize Open Issues (DROID)  Complete
* Finalize Detailed Mod (Detail) Finalizing
* Documentation/ SCE&G Reviews Finalizing V.C. SUMMER NUCLEAR STATION NSCA Open Items
* ORal OS: NSCA Open Items
* VFOR (Green):
Performance Based Solutions
* Other Solutions
* Modifications
* Additional Circuit analysis
* Model Updates V.C. SUMMER NUCLEAR STATION 3
 
3/30/2011 Major TR Attachments 1: Chapter 3 Compliance
* No issues
* No issues
* Substantially Attachment 82: Transition Shutdown
* Substantially Complete 2: Transition Shutdown Strategy
* Issued for Review
* Issued for Review
* Adding NFPA Compliance References
* Adding NFPA Compliance References
* Note: Not transitioning existing SD Attachment 83: Area by Area
* Note: Not transitioning existing SD strategy 3: Area by Area Assessment
* Incorporating Fire Risk Evaluations v.c. SUMMER NUCLEAR STATION VC Summer Fire PRA FPRA Peer Reviews Complete Peer Review Comment Resolution May 2011 Documentation/
* Incorporating Fire Risk Evaluations v.c. SUMMER NUCLEAR STATION VC Summer Fire PRA FPRA Peer Reviews           Complete Peer Review Comment Resolution May 2011 Documentation/ Final SCE&G review May 2011 V.C. SUMMER NUCLEAR STATION 4
Final SCE&G review May 2011 V.C. SUMMER NUCLEAR STATION 4


VC Summer Fire PRA Results Fire PRA*
3/30/2011 VC Summer Fire PRA Results Fire PRA*
* CDF 3.83 E-05/yr
* CDF                   3.83 E-05/yr
* LERF 1.47 E-07/yr Internal Events PRA
* LERF                   1.47 E-07/yr Internal Events PRA
* CDF 1.67 E-05/yr
* CDF                   1.67 E-05/yr
* LERF 1.56 E-07/yr
* LERF                   1.56 E-07/yr
* Includes credits for modifications V.C. SUMMER NUCLEAR STATION Fire PRA Results Dominant Risk Sequences
* Includes credits for modifications V.C. SUMMER NUCLEAR STATION Fire PRA Results Summary Dominant Risk Sequences
* Loss of RCP Seal Cooling With Seals Susceptible To Failure
* Loss of RCP Seal Cooling With Seals Susceptible To Failure
* Fire-induced Safety Injection in conjunction with PORV challenge
* Fire-induced Safety Injection in conjunction with PORV challenge
* Consequential Steamline Break with EFW Pump Runout
* Consequential Steamline Break with EFW Pump Runout
* Consequential Primary PORV LOCA \l.C. SUMMER NUCLEAR STATION 5
* Consequential Primary PORV LOCA
                                      \l.C. SUMMER NUCLEAR STATION 5


Relative Improvement:
3/30/2011 Relative Improvement: Modifications
* Protecting Circuits
* Protecting Circuits
* Alternate Seal Injection
* Alternate Seal Injection
* Incipient Detection
* Incipient Detection
* RCP Shutdown Seals v.c. SUMMER NUCLEAR STATION VCSNS FPRA Peer Reviews August 2010 30 findings Fire Scenario Selection:
* RCP Shutdown Seals v.c. SUMMER NUCLEAR STATION VCSNS FPRA Peer Reviews August 2010
Not Reviewed 3 SRs related to "new" procedures:
* 30 findings
Not Reviewed 3 SRs related to Fa and UNC NR due to FSS NR February 2011: Focused Scope 16 findings Most findings involved providing more justification/documentation
* Fire Scenario Selection: Not Reviewed
[Do not affect Licensing Amendment Request Contain all Findings, and How each has been resolved V.C. SUMMER NUCLEAR STATION 6
* 3 SRs related to "new" procedures: Not Reviewed
* 3 SRs related to Fa and UNC NR due to FSS NR February 2011: Focused Scope
* 16 findings
* Most findings involved providing more specific justification/documentation [Do not affect results]
Licensing Amendment Request
* Contain all Findings, and
* How each has been resolved V.C. SUMMER NUCLEAR STATION 6


Significant Peer Findings FQ: Inability to create "one top" model results in inability to calculate importance measures Status: May 2011 Completion (Cutset reviews) FSS: Some Main Control Room Abandonment Scenarios not quantified Status: Complete FSS: Dependency between automatic and manual suppression not considered Status: May 2011 Completion UNC: Sensitivity analysis was not completed (for LERF) report was still "draft" Status: May 2011 Completion V.C. SUMMER NUCLEAR STATION Performance Based General Information Total Fire Areas 71 Total DROIDS 597 Total VFDR 334 Fire Modeling (NFPA805, 4.2.4.1) Total Fire Areas 5 Fire Areas Fire Risk Evaluations (NFPA805, 4.2.4.2) Total Fire Area FRE 32 Status > 80% V.C. SUIIIINIER NUCLEAR STATION 7
3/30/2011 Significant Peer Findings FQ: Inability to create "one top" model results in inability to calculate importance measures Status: May 2011 Completion (Cutset reviews)
FSS: Some Main Control Room Abandonment Scenarios not quantified Status: Complete FSS: Dependency between automatic and manual suppression not considered Status: May 2011 Completion UNC: Sensitivity analysis was not completed (for LERF) report was still "draft" Status: May 2011 Completion V.C. SUMMER NUCLEAR STATION Performance Based Solutions General Information Total Fire Areas         71 Total DROIDS             597 Total VFDR               334 Fire Modeling (NFPA805, 4.2.4.1)
Total Fire Areas         5 Fire Areas Fire Risk Evaluations (NFPA805, 4.2.4.2)
Total Fire Area FRE       32 Status                   > 80%
V.C. SUIIIINIER NUCLEAR STATION 7


Performance Based Fire Modeling NFPA805, Section 4.2.4.1
3/30/2011 Performance Based Fire Modeling NFPA805, Section 4.2.4.1
* Maximum Expected Fire Scenario (MEFS)
* Maximum Expected Fire Scenario (MEFS)
* Limiting Fire Scenario (LFS) Manage "Fire" within Space
* Limiting Fire Scenario (LFS)
Manage "Fire" within Space
* Address Fire Scenario (s)
* Address Fire Scenario (s)
* Fuel Package
* Fuel Package
Line 92: Line 151:
* Hot Gas Layer
* Hot Gas Layer
* Direct Heat Transfer (Radiation, Convective)
* Direct Heat Transfer (Radiation, Convective)
V.C. SUMIIIIER NUCLEAR STATION Modification Title General Discussion NFPA805 Circuit! Tubing Protection I Provide protection of tubingl circuits from the effects of fire(Train Separation!
V.C. SUMIIIIER NUCLEAR STATION Modification Title                   General Discussion IProvide protection of tubingl circuits from the effects of NFPA805 Circuit! Tubing Protection      fire(Train Separation! Spurious Operation)
Spurious Operation)
NFPA805 RCP Seal Replacement         IProvide lower leakage RCP Seals [Risk Reduction! Outage]
NFPA805 RCP Seal Replacement I Provide lower leakage RCP Seals [Risk Reduction!
IEliminate affects of common TB West fire (TB01) affecting
Outage] .NFPA8051DA 115kV Supply Reroute I Eliminate affects of common TB West fire (TB01) affecting 115kV and 230kV offsite power to 1 DAI 1 DB (Risk Reduction!
.NFPA8051DA 115kV Supply Reroute        115kV and 230kV offsite power to 1DAI 1DB (Risk Reduction!
Outage] NFPA805 Hazard Protection I Provide mitigation strategies to address fire initiators or means to propagate fires NFPAa05 Instrument Air Recovery . Provide autostart capability for the Diesel Driven Air I Compressor (XACOO14)
Outage]
NFPA805 Communication i Provide altemate backup, protected communication system to I support fire event Incipient Detection i Provide Incipient Detection System at the top of selected electrical panels in the Relay and Upper Cable Spreading i Rooms (Risk Reduction)
NFPA805 Hazard Protection IProvide mitigation strategies to address fire initiators or means to propagate fires
Alternate Seal Injection (MSPI) I Provide addition high pressure pump! Diesel Generator to I mitigate loss of RCP seal cooling (Risk Reduction) 8
                                      . Provide autostart capability for the Diesel Driven Air NFPAa05 Instrument Air Recovery ICompressor (XACOO14) i Provide   altemate backup, protected communication system to NFPA805 Communication Isupport fire event i Provide Incipient Detection System at the top of selected
~FPA805 Incipient Detection              electrical panels in the Relay and Upper Cable Spreading i Rooms (Risk Reduction)
IProvide addition high pressure pump! Diesel Generator to Alternate Seal Injection (MSPI)
Imitigate loss of RCP seal cooling (Risk Reduction) 8


Non Power Operations Preliminary Document Issued SCE&G Internal Review:
3/30/2011 Non Power Operations Preliminary Document Issued     Complete SCE&G Internal Review:           Complete Current Status                  May 2011
Current May 2011
* Restraint: Final NSCA Model Updates
* Restraint:
* Addressing Comments! Reissue
Final NSCA Model Updates
* Finalizing DROIDs! Final SCE&G Review V.C. SUlllllllfER NUCLEAR STATION Radioactive Release Analysis
* Addressing Comments!
* Completed (2009)
Reissue
* Readdressing due to FA009-0056 (4th Otr 2011)
* Finalizing DROIDs! Final SCE&G Review V.C. SUlllllllfER NUCLEAR STATION Radioactive Release Analysis Completed (2009) Readdressing due to FA009-0056 (4th Otr 2011) OutSide Radioactive Release study Radioactive Release Report In Process -Impact: Fire Preplans and coordination with HPJ Chemistry  
* OutSide Radioactive Release study
-Address Gaseous J Liquid Release V.C. SUMMER NUClEAR STATION 9
* Radioactive Release Report In Process
    - Impact: Fire Preplans and coordination with HPJ Chemistry
    - Address Gaseous J Liquid Release V.C. SUMMER NUClEAR STATION 9


Implementation Actions Modification Scoping Engineering Procedures Condition Monitoring Program FAQ10-0059 Fire Preplans Fire Brigade Training Updates Fire Protection Admin Procedures Resolution of Code Requirements  
3/30/2011 Implementation Actions
/ Self Assessments Fire Safety Analysis Operations Procedure/
* Modification Scoping
Training V.C. SUMMER NUCLEAR STATION Condition Monitoring Reliability/
* Engineering Procedures
Availability being measured Data back fit for FP Features Procedure/
* Condition Monitoring Program FAQ10-0059
Model Developed (Samples)
* Fire Preplans
* FS Detectors FS Alarm System FS Main
* Fire Brigade Training Updates
* Fire Pumps Monitoring FAQ10-0059 Resolution V.C. SUMIIIIER NUCLEAR STATION 10
* Fire Protection Admin Procedures
* Resolution of Code Requirements / Self Assessments
* Fire Safety Analysis
* Operations Procedure/ Training V.C. SUMMER NUCLEAR STATION Condition Monitoring Reliability/ Availability being measured Data back fit for FP Features Procedure/ Model Developed (Samples)
* FS Detectors
* FS Alarm System
* FS Main
* Fire Pumps Monitoring FAQ10-0059 Resolution V.C. SUMIIIIER NUCLEAR STATION 10


NFPA 805 Project Issues Project Challenges
3/30/2011 NFPA 805 Project Issues Project Challenges
* VC Summer RF19 (April/ May 2011) Station Management Reviews of NFPA805 LARI Transition Report LAR Significant Issuesl Gaps
* VC Summer RF19 (April/ May 2011)
Station Management Reviews of NFPA805 LARI Transition Report LAR Significant Issuesl Gaps
* None identified or expected LARI Transition Report
* None identified or expected LARI Transition Report
* June 28, 2011 v.c. SUMMER NUCLEAR STATION NFPA805 Project Results NFPA805 Transition: Successfully submit an LAR to transition VCSummer Unit 1 to a Performance Based Fire protection Program via NFPA805 (10CFR50.48(c))
* June 28, 2011 v.c. SUMMER NUCLEAR STATION NFPA805 Project Results NFPA805 Transition:
[June 2011] VC Summer Goals (Additional) SISBO: Eliminate the SISBO Strategy [Accomplished] Fires outside Main Control Room: Minimize, to the extent possible, Operator Manual Actions (OMA) [Accomplished] Industryl CLB Issues: Address all current industry issues concerning Multiple Spurious Operationsl Events, Feasibility of Operator Actions and use of Operator Manual Actions in Appendix R IIIG.2 areas. [Accomplished]
* Successfully submit an LAR to transition VCSummer Unit 1 to a Performance Based Fire protection Program via NFPA805 (10CFR50.48(c)) [June 2011]
V.C. SUMMER NUCLEAR STATION 11
VC Summer Goals (Additional)
* SISBO: Eliminate the SISBO Strategy [Accomplished]
* Fires outside Main Control Room: Minimize, to the extent possible, Operator Manual Actions (OMA) [Accomplished]
* Industryl CLB Issues: Address all current industry issues concerning Multiple Spurious Operationsl Events, Feasibility of Operator Actions and use of Operator Manual Actions in Appendix R IIIG.2 areas. [Accomplished]
V.C. SUMMER NUCLEAR STATION 11
 
3/30/2011 Questions V.C. SUIIIIIIIIER NUCLEAR STATION 12


Questions V.C. SUIIIIIIIIER NUCLEAR STATION 12 General discussion of modifications.
SCE&G                                            -2
SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator. Nonpower Operations Radioactive Release Analysis Implementation Actions Condition Monitoring NFPA-805 Project Issues -including station management review of the transition report and targeted submittal of the LAR by June 28, 2011. NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished.
* General discussion of modifications. SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator.
They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power. The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 -1000 pages in length. Members of the public representing other utilities and industry groups were in attendance.
* Nonpower Operations
* Radioactive Release Analysis
* Implementation Actions
* Condition Monitoring
* NFPA-805 Project Issues - including station management review of the transition report and targeted submittal of the LAR by June 28, 2011.
* NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished. They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power.
The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 - 1000 pages in length.
Members of the public representing other utilities and industry groups were in attendance.
Public Meeting Feedback forms were available at the meeting but no comments were received.
Public Meeting Feedback forms were available at the meeting but no comments were received.
IRA! Robert Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395  
IRA!
Robert Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395


==Enclosures:==
==Enclosures:==
: 1. List of Attendees
: 1. List of Attendees
: 2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation1 Staff, March 31, 2011 cc w/encls: Distribution via Listserv DISTRIBUTION:
: 2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation1 Staff, March 31, 2011 cc w/encls: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL2-1 RtF RidsOgcRp Resource PLain, NRR RidsAcrsAcnw_MailCTR Resource RidsRgn2MailCenter Resource SBush-Goddard, EDO Region 2 RidsNrrDraAfpb Resource RidsNrrDorlLpl2-1 Resource AKlein, NRR RidsNrrLAMOBrienResource RidsNrrPMSummer Resource DPickett.
PUBLIC           LPL2-1 RtF           RidsOgcRp Resource             PLain, NRR RidsAcrsAcnw_MailCTR Resource         RidsRgn2MailCenter Resource     SBush-Goddard, EDO Region 2 RidsNrrDraAfpb Resource               RidsNrrDorlLpl2-1 Resource     AKlein, NRR RidsNrrLAMOBrienResource               RidsNrrPMSummer Resource       DPickett. NRR PBoyle, NRR                           RidsOpaMailResource             DHarrison, NRR SDinsmore. NRR                         GCooper, NRR                   SLee, NRR ADAMS Accession No ML11152A080 PFFICE       DORULPL2-1tPM             DORULPL2-1/LA       DORULPL2-1/BC     DORULPL2-1/PM NAME       RMartin                   MOBrien             GKulesa            RMartin wtminor changes DATE       06/08/2011               06/06/2011         06/14/2011         06/1412011 OFFICIAL RECORD COpy}}
NRR PBoyle, NRR RidsOpaMailResource DHarrison, NRR SDinsmore.
NRR GCooper, NRR SLee, NRR ADAMS Accession No ML11152A080 PFFICE DORULPL2-1tPM DORULPL2-1/LA DORULPL2-1/BC DORULPL2-1/PM NAME RMartin MOBrien wtminor changes GKulesa RMartin DATE 06/08/2011 06/06/2011 06/14/2011 06/1412011 OFFICIAL RECORD COpy}}

Latest revision as of 19:03, 12 November 2019

Summary of March 31, 2011, Meeting with South Carolina Electric and Gas Company to Discuss NFPA-805 License Amendment
ML11152A080
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 06/14/2011
From: Martin R
Plant Licensing Branch II
To:
Office of Nuclear Reactor Regulation
Martin R, , DORL/LPL2-1 415-1493
References
TAC ME5954
Download: ML11152A080 (16)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 14, 2011 LICENSEE: South Carolina Electric and Gas Company, Inc.

FACILITY: Virgil C. Summer Nuclear Station (VCSNS), Unit No.1 SUB~IECT:

SUMMARY

OF MARCH 31, 2011, MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY TO DISCUSS NFPA-B05 LICENSE AMENDMENT (TAC NO. ME5954)

On March 31, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of South Carolina Electric and Gas Company, Inc. (SCE&G, the licensee), at NRC Headquarters in Rockville, Maryland. SCE&G requested the public meeting to discuss the current status of its plans to submit a license amendment request (LAR) based on the National Fire Protection Association Standard B05, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" (NFPA-B05). A list of attendees is provided as Enclosure 1.

SCE&G's presentation (see Enclosure 2) included the following topics:

  • NFPA-B05 Project Goals: Submit an LAR to transition VCSNS Unit 1 to a performance based fire protection program via NFPA-B05. This would include eliminating the self induced station blackout (SISBO) strategy, minimization of operator manual actions (OMAs) for fire occurring outside the main control room and addressing all current industry issues concerning multiple hot shorts/spurious events, the feasibility of operator actions and "authorized" use of OMAs.
  • NFPA-B05 Project Status
  • Nuclear Safety Compliance Assessment (NSCA)
  • Major Transition Report Attachments
  • VC Summer Fire PRA Results - The Fire PRA (FPRA) core damage frequency takes credit for modifications on protecting circuits, alternate seal injection, incipient detection and reactor coolant pump shutdown seals.
  • Fire PRA Results Summary including dominant risk sequences
  • Relative improvement value of modifications
  • Significant Peer Findings
  • Performance-Based Solutions
  • Performance-Based Fire Modeling

SCE&G -2

  • General discussion of modifications. SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator.
  • Nonpower Operations
  • Radioactive Release Analysis
  • Implementation Actions
  • Condition Monitoring
  • NFPA-805 Project Issues - including station management review of the transition report and targeted submittal of the LAR by June 28, 2011.
  • NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished. They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power.

The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 - 1000 pages in length.

Members of the public representing other utilities and industry groups were in attendance.

Public Meeting Feedback forms were available at the meeting but no comments were received.

j) Robert Martin, s7nt;?~ger Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. List of Attendees
2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation] Staff, March 31, 2011 cc w/encls: Distribution via Listserv

LIST OF ATTENDEES NRC MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY, INC. (SCE&G)

REGARDING LICENSE AMENDMENT APPLICATION ON FIRE PROTECTION MARCH 31,2011 NAME AFFILIATION Robert Martin NRC/NRRlDORL Patrick Boyle NRC/NRRlDORL Paul Lain NRC/NRRlDRA Alex Klein NRC/NRRIDRA Doug Pickett NRC/NRRIDORL Donnie Harrison NRC/NRRlDRA Stephen Dinsmore NRC/NRRlDRA Gary Cooper NRC/NRRlDRA Samson Lee NRC/NRRlDRA Dan Gatlin SCE&G George Williams SCE&G Eric Rumfelt SCE&G Gerald LOignon, Jr SCE&G Wayne Stuart SCE&G Gil Williams SCE&G Bruce Thompson SCE&G Michael Kammer SCE&G Tom Basso NEI Via Telephone Conference Bridge Line

  • Robert Layton PNNL Bijan Najafi SAIC Paul Amico SAIC Larry Young Entergy Vesna Dimitrijevic AREVA NP Michael Seaman-Huynh SC Office of Regulatory Staff Sal Dolcemascolo SONGS
  • based on prior notifications Enclosure 1

3/30/2011 NFPA805 Lice"nse //

Am __ .~. 9_ffTein'r~'r1e6'deS March 31,2011 VC Summer Attendees Dan Gatlin Vice President, VC Summer Unit 1 Wayne Stuart General Manager, Engineering Services Bruce Thompson Manager, Nuclear licensing Mike Kammer NFPA 805 Project Manager Gerald Loignon Supervisor, PRA Group Eric Rumfelt Supervisor, Nuclear Licensing George Williams Supervisor, Engineering Programs v.c. SUMMER NUCLEAR STATION Enclosure 2 1

3/30/2011 NFPA805 Project Goals NFPA805 Transition:

  • Successfully submit an LAR to transition VCSummer Unit 1 to a Performance Based Fire protection Program via NFPA80S (10CFRSO.48(c)) [Letter October 2006]

VC Summer Goals (Additional)

  • SISBO: Eliminate the SISBO Strategy

V.C. SUMMER NUCLEAR STATION NFPA805 Project Status Major Tasks

  • NSCA Modell Open Issues
  • FirePRA
  • Performance Based Resolution (VFDR)

- Fire Risk Evaluation

- Performance Based Fire Modeling

  • Non Power Operations
  • NFPA805: NFPA Code Compliance
  • Radioactive Release Analysis

- Administrativel Condition Monitoring V.C. SUMMER NUCLEAR STATION 2

3/30/2011 Nuclear Safety Compliance Assessment (NSCA)

Status/ Updates

  • PCCKS Updates Complete
  • Model Development: Open Issue Complete
  • NSCA Model Review (SCE&G) Complete
  • ECR Package Reviews (SCE&G) Complete
  • NSCA Model Updates Complete
  • Finalize Open Issues (DROID) Complete
  • Finalize Detailed Mod (Detail) Finalizing
  • Documentation/ SCE&G Reviews Finalizing V.C. SUMMER NUCLEAR STATION NSCA Open Items
  • ORal OS: NSCA Open Items
  • VFOR (Green):

Performance Based Solutions

  • Other Solutions
  • Modifications
  • Additional Circuit analysis
  • Model Updates V.C. SUMMER NUCLEAR STATION 3

3/30/2011 Major TR Attachments 1: Chapter 3 Compliance

  • No issues
  • Substantially Complete 2: Transition Shutdown Strategy
  • Issued for Review
  • Adding NFPA Compliance References
  • Note: Not transitioning existing SD strategy 3: Area by Area Assessment
  • Incorporating Fire Risk Evaluations v.c. SUMMER NUCLEAR STATION VC Summer Fire PRA FPRA Peer Reviews Complete Peer Review Comment Resolution May 2011 Documentation/ Final SCE&G review May 2011 V.C. SUMMER NUCLEAR STATION 4

3/30/2011 VC Summer Fire PRA Results Fire PRA*

  • CDF 3.83 E-05/yr
  • LERF 1.47 E-07/yr Internal Events PRA
  • CDF 1.67 E-05/yr
  • Includes credits for modifications V.C. SUMMER NUCLEAR STATION Fire PRA Results Summary Dominant Risk Sequences
  • Loss of RCP Seal Cooling With Seals Susceptible To Failure
  • Fire-induced Safety Injection in conjunction with PORV challenge
  • Consequential Steamline Break with EFW Pump Runout

\l.C. SUMMER NUCLEAR STATION 5

3/30/2011 Relative Improvement: Modifications

  • Protecting Circuits
  • Alternate Seal Injection
  • Incipient Detection
  • RCP Shutdown Seals v.c. SUMMER NUCLEAR STATION VCSNS FPRA Peer Reviews August 2010
  • 30 findings
  • Fire Scenario Selection: Not Reviewed
  • 3 SRs related to "new" procedures: Not Reviewed
  • 3 SRs related to Fa and UNC NR due to FSS NR February 2011: Focused Scope
  • 16 findings
  • Most findings involved providing more specific justification/documentation [Do not affect results]

Licensing Amendment Request

  • Contain all Findings, and
  • How each has been resolved V.C. SUMMER NUCLEAR STATION 6

3/30/2011 Significant Peer Findings FQ: Inability to create "one top" model results in inability to calculate importance measures Status: May 2011 Completion (Cutset reviews)

FSS: Some Main Control Room Abandonment Scenarios not quantified Status: Complete FSS: Dependency between automatic and manual suppression not considered Status: May 2011 Completion UNC: Sensitivity analysis was not completed (for LERF) report was still "draft" Status: May 2011 Completion V.C. SUMMER NUCLEAR STATION Performance Based Solutions General Information Total Fire Areas 71 Total DROIDS 597 Total VFDR 334 Fire Modeling (NFPA805, 4.2.4.1)

Total Fire Areas 5 Fire Areas Fire Risk Evaluations (NFPA805, 4.2.4.2)

Total Fire Area FRE 32 Status > 80%

V.C. SUIIIINIER NUCLEAR STATION 7

3/30/2011 Performance Based Fire Modeling NFPA805, Section 4.2.4.1

  • Maximum Expected Fire Scenario (MEFS)
  • Limiting Fire Scenario (LFS)

Manage "Fire" within Space

  • Address Fire Scenario (s)
  • Fuel Package
  • Fire Location
  • Fire Type Focus: Impact on "Area" Targets
  • Hot Gas Layer
  • Direct Heat Transfer (Radiation, Convective)

V.C. SUMIIIIER NUCLEAR STATION Modification Title General Discussion IProvide protection of tubingl circuits from the effects of NFPA805 Circuit! Tubing Protection fire(Train Separation! Spurious Operation)

NFPA805 RCP Seal Replacement IProvide lower leakage RCP Seals [Risk Reduction! Outage]

IEliminate affects of common TB West fire (TB01) affecting

.NFPA8051DA 115kV Supply Reroute 115kV and 230kV offsite power to 1DAI 1DB (Risk Reduction!

Outage]

NFPA805 Hazard Protection IProvide mitigation strategies to address fire initiators or means to propagate fires

. Provide autostart capability for the Diesel Driven Air NFPAa05 Instrument Air Recovery ICompressor (XACOO14) i Provide altemate backup, protected communication system to NFPA805 Communication Isupport fire event i Provide Incipient Detection System at the top of selected

~FPA805 Incipient Detection electrical panels in the Relay and Upper Cable Spreading i Rooms (Risk Reduction)

IProvide addition high pressure pump! Diesel Generator to Alternate Seal Injection (MSPI)

Imitigate loss of RCP seal cooling (Risk Reduction) 8

3/30/2011 Non Power Operations Preliminary Document Issued Complete SCE&G Internal Review: Complete Current Status May 2011

  • Restraint: Final NSCA Model Updates
  • Addressing Comments! Reissue
  • Finalizing DROIDs! Final SCE&G Review V.C. SUlllllllfER NUCLEAR STATION Radioactive Release Analysis
  • Completed (2009)
  • Readdressing due to FA009-0056 (4th Otr 2011)
  • OutSide Radioactive Release study
  • Radioactive Release Report In Process

- Impact: Fire Preplans and coordination with HPJ Chemistry

- Address Gaseous J Liquid Release V.C. SUMMER NUClEAR STATION 9

3/30/2011 Implementation Actions

  • Modification Scoping
  • Engineering Procedures
  • Condition Monitoring Program FAQ10-0059
  • Fire Preplans
  • Fire Brigade Training Updates
  • Fire Protection Admin Procedures
  • Resolution of Code Requirements / Self Assessments
  • Fire Safety Analysis
  • Operations Procedure/ Training V.C. SUMMER NUCLEAR STATION Condition Monitoring Reliability/ Availability being measured Data back fit for FP Features Procedure/ Model Developed (Samples)
  • FS Detectors
  • FS Alarm System
  • FS Main
  • Fire Pumps Monitoring FAQ10-0059 Resolution V.C. SUMIIIIER NUCLEAR STATION 10

3/30/2011 NFPA 805 Project Issues Project Challenges

  • VC Summer RF19 (April/ May 2011)

Station Management Reviews of NFPA805 LARI Transition Report LAR Significant Issuesl Gaps

  • None identified or expected LARI Transition Report
  • June 28, 2011 v.c. SUMMER NUCLEAR STATION NFPA805 Project Results NFPA805 Transition:

VC Summer Goals (Additional)

  • SISBO: Eliminate the SISBO Strategy [Accomplished]

V.C. SUMMER NUCLEAR STATION 11

3/30/2011 Questions V.C. SUIIIIIIIIER NUCLEAR STATION 12

SCE&G -2

  • General discussion of modifications. SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator.
  • Nonpower Operations
  • Radioactive Release Analysis
  • Implementation Actions
  • Condition Monitoring
  • NFPA-805 Project Issues - including station management review of the transition report and targeted submittal of the LAR by June 28, 2011.
  • NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished. They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power.

The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 - 1000 pages in length.

Members of the public representing other utilities and industry groups were in attendance.

Public Meeting Feedback forms were available at the meeting but no comments were received.

IRA!

Robert Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. List of Attendees
2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation1 Staff, March 31, 2011 cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-1 RtF RidsOgcRp Resource PLain, NRR RidsAcrsAcnw_MailCTR Resource RidsRgn2MailCenter Resource SBush-Goddard, EDO Region 2 RidsNrrDraAfpb Resource RidsNrrDorlLpl2-1 Resource AKlein, NRR RidsNrrLAMOBrienResource RidsNrrPMSummer Resource DPickett. NRR PBoyle, NRR RidsOpaMailResource DHarrison, NRR SDinsmore. NRR GCooper, NRR SLee, NRR ADAMS Accession No ML11152A080 PFFICE DORULPL2-1tPM DORULPL2-1/LA DORULPL2-1/BC DORULPL2-1/PM NAME RMartin MOBrien GKulesa RMartin wtminor changes DATE 06/08/2011 06/06/2011 06/14/2011 06/1412011 OFFICIAL RECORD COpy