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| {{#Wiki_filter:March 21, 2006Mr. Jeffery ArchieVice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, South Carolina 29065 | | {{#Wiki_filter:March 21, 2006 Mr. Jeffery Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, South Carolina 29065 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| VIRGIL C. SUMMER NUCLEAR STATION - REQUEST FOR ADDITIONALINFORMATION REGARDING INSTRUMENTATION TEST AND COMPLETION TIMES (TAC NO. MC8898) | | VIRGIL C. SUMMER NUCLEAR STATION REQUEST FOR ADDITIONAL INFORMATION REGARDING INSTRUMENTATION TEST AND COMPLETION TIMES (TAC NO. MC8898) |
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| ==Dear Mr. Archie:== | | ==Dear Mr. Archie:== |
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| The Nuclear Regulatory Commission staff is reviewing the license amendment application forthe Virgil C. Summer Nuclear Station dated November 15, 2005, concerning instrumentationtest and completion times and find that we need additional information as identified in the enclosure. | | The Nuclear Regulatory Commission staff is reviewing the license amendment application for the Virgil C. Summer Nuclear Station dated November 15, 2005, concerning instrumentation test and completion times and find that we need additional information as identified in the enclosure. |
| | This request for additional information was discussed with your staff on March 20, 2006, and your staff indicated that a response could be provided by May 1, 2006. Please contact me if you have any questions. |
| | Sincerely, |
| | /RA/ |
| | Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395 |
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| This request for additional information was discussed with your staff on March 20, 2006, and your staff indicated that a response could be provided by May 1, 2006. Please contact me if you have any questions. Sincerely, /RA/Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395
| | ==Enclosure:== |
| | Request for Additional Information cc: See next page |
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| ==Enclosure:==
| | ML060800003 NRR-088 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/LPL2-1/BC NAME RMartin CSola EMarinos DATE 3/21/06 3/21/06 3/21/06 |
| Request for Additional Information cc: See next page
| | |
| | REQUEST FOR ADDITIONAL INFORMATION RISK INFORMED JUSTIFICATION FOR EXTENDING ALLOWED OUTAGE TIME (AOT) BYPASS TEST TIMES VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) |
| | : 1. Westinghouse Commercial Atomic Power report (WCAP) -14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS [reactor protection system] and ESFAS |
| | [engineered safety feature actuation system] Test Times and Completion Times, dated October 1998, Section 11.0, Implementation of the Proposed Technical Specification Changes, Item 3, notes that a change to the action for an inoperable slave relay to following the expiration of the slave relay AOT, the component affected by the inoperable slave should be declared inoperable and the TS [Technical Specification] |
| | action for this component should be followed. Is this modification required for the Virgil C. Summer Nuclear Station (VCSNS) TS? Explain why or why not. |
| | : 2. Confirm that the VCSNS RPS utilizes the solid state protection system for the logic portion of the RPS. |
| | : 3. Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Section 2.3 and RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: |
| | Technical Specifications, Section 3, as part of the key principles in implementing risk-informed decisionmaking, establishes the need for an implementation and monitoring program to ensure that extensions to TS AOT or surveillance test intervals do not degrade operational safety over time and that no adverse degradation occurs due to changes in the licensing basis due to unanticipated degradation or common cause mechanisms. An implementation and monitoring program is intended to ensure that the impact of the proposed TS change continues to reflect the reliability and availability of structures, systems and components impacted by the change. Provide information on the VCSNS implementation and monitoring program as applied to the incorporation of WCAP-14333 at VCSNS. |
| | : 4. The analysis for WCAP-14333 assumed that maintenance on master and slave relays, logic cabinets, and analog channels while at power occurs only after a component failure, and that preventive maintenance does not occur. The topical report does not preclude the practice of at-power preventive maintenance but limits the total time a component is unavailable due to corrective or preventive maintenance to the values used in the analysis. If preventive maintenance is to be performed at VCSNS, confirm that the unavailability for components evaluated in WCAP-14333 are consistent with the plant specific estimates at VCSNS and do not exceed those assumed in the analysis. |
| | Enclosure |
| | |
| | See the submittal, Implementation Guideline, Table 1, Analog Channel Calibration as an example. |
| | : 5. Provide the date of the VCSNS probabilistic risk assessment (PRA) industry peer review and date of certification. |
| | : 6. Confirm that the WCAP-14333 reference plant assumptions for human reliability are applicable to VCSNS. As an example, see the B level Facts and Observations (F&Os) discussion for HR-06 on pages 18 and 19 of the submittal. |
| | : 7. The licensees submittal states that due to the generic analysis of WCAP-14333 the second F&O concerning internal floods has no impact on the proposed changes. |
| | The Nuclear Regulatory Commission (NRC) staff notes that internal flooding may have unique plant specific vulnerabilities and may not be bounded by the generic analysis. |
| | Internal floods were not part of the implementation guidance for WCAP-14333. Provide a plant-specific assessment (either qualitative or quantitative) to confirm that VCSNS internal flooding results are bounded by WCAP-14333 for this F&O. |
| | : 8. Provide an assessment of the external events risk impact including seismic, fire, and external floods and high wind risk with respect to the proposed completion time and bypass time extensions in RG 1.177 Section 2.3.2, Scope of the PRA for TS Applications. |
| | : 9. Provide a discussion on the following aspects of PRA quality as applicable to the VCSNS PRA. |
| | : 1. The plant-specific PRA reflects the as-built, as-operated plant. |
| | : 2. Applicable PRA updates conducted since completion of individual plant examination (IPE) and individual plant examination of external events (IPEEE) and the status of any improvements identified by the IPE and IPEEE. |
| | : 3. Reference PRA quality assurance programs/procedures, including expected PRA revision schedules. |
| | : 4. PRA adequacy and completeness with respect to evaluating the proposed AOT and bypass time extensions with emphasis on Tier 3. |
| | : 5. Plant design or operational modifications not reflected in the WCAP-14333 PRA used in this application that are related to or could impact this license amendment application. Justify the acceptability of not including these modifications in the PRA as part of this application. |
| | : 10. RG 1.174 states that as part of the evaluation of risk, the cumulative risk of the present TS change in light of past applications should be understood. Cumulative risks were not |
| | |
| | addressed by VCSNS. Provide an evaluation of the cumulative risk impact of previous TS changes (including WCAP-10271) per RG 1.174, Section 3.3.2, as applicable to the implementation of WCAP-14333. |
| | : 11. Regarding page 9 of 26 of the application, for the restriction listed under Tier 2 provide a procedure reference that incorporates these changes. Are these restrictions considered licensee commitments? |
| | : 12. Page 9 of 26 of the licensees submittal states that the VCSNS Tier 3 requirements are addressed through VCSNS Operations Administrative Procedures consistent with the requirements Title 10 of the Code of Federal Regulations (10 CFR), section 50.65(a)(4). |
| | Provide a discussion on the applicability of the VCSNS 10 CFR 50.65(a)(4) configuration risk management program (CRMP) to the additions and clarifications provided in RG 1.177, Section 2.3.7.2, Key Components 1 through 4, for CRMP programs that implement section a(4) of 10 CFR 50.65(a)(4) and the guidance provided by RG 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. |
| | In addition, identify the programs and procedures in place to implement the CRMP at VCSNS. |
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| ML060800003 NRR-088OFFICENRR/LPL2-1/PMNRR/LPL2-1/LANRR/LPL2-1/BCNAMERMartinCSolaEMarinosDATE3/21/063/21/063/21/06 EnclosureREQUEST FOR ADDITIONAL INFORMATIONRISK INFORMED JUSTIFICATION FOR EXTENDING ALLOWED OUTAGE TIME (AOT) BYPASS TEST TIMES VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)1.Westinghouse Commercial Atomic Power report (WCAP) -14333-P-A, Rev. 1,"Probabilistic Risk Analysis of the RPS [reactor protection system] and ESFAS[engineered safety feature actuation system] Test Times and Completion Times," datedOctober 1998, Section 11.0, "Implementation of the Proposed Technical SpecificationChanges," Item 3, notes that a change to the action for an inoperable slave relay to"following the expiration of the slave relay AOT, the component affected by theinoperable slave should be declared inoperable and the TS [Technical Specification]action for this component should be followed." Is this modification required for the VirgilC. Summer Nuclear Station (VCSNS) TS? Explain why or why not. 2.Confirm that the VCSNS RPS utilizes the solid state protection system for the logicportion of the RPS. 3.Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment inRisk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Section 2.3and RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:Technical Specifications," Section 3, as part of the key principles in implementingrisk-informed decisionmaking, establishes the need for an implementation andmonitoring program to ensure that extensions to TS AOT or surveillance test intervalsdo not degrade operational safety over time and that no adverse degradation occursdue to changes in the licensing basis due to unanticipated degradation or commoncause mechanisms. An implementation and monitoring program is intended to ensurethat the impact of the proposed TS change continues to reflect the reliability andavailability of structures, systems and components impacted by the change. Provideinformation on the VCSNS implementation and monitoring program as applied to theincorporation of WCAP-14333 at VCSNS.4.The analysis for WCAP-14333 assumed that maintenance on master and slave relays,logic cabinets, and analog channels while at power occurs only after a componentfailure, and that preventive maintenance does not occur. The topical report does notpreclude the practice of at-power preventive maintenance but limits the total time acomponent is unavailable due to corrective or preventive maintenance to the valuesused in the analysis. If preventive maintenance is to be performed at VCSNS, confirmthat the unavailability for components evaluated in WCAP-14333 are consistent with theplant specific estimates at VCSNS and do not exceed those assumed in the analysis. See the submittal, "Implementation Guideline," Table 1, "Analog Channel Calibration" asan example. 5.Provide the date of the VCSNS probabilistic risk assessment (PRA) industry peer reviewand date of certification.6.Confirm that the WCAP-14333 reference plant assumptions for human reliability areapplicable to VCSNS. As an example, see the "B" level Facts and Observations (F&Os)discussion for HR-06 on pages 18 and 19 of the submittal.7.The licensee's submittal states that due to the generic analysis of WCAP-14333 thesecond F&O concerning internal floods has no impact on the proposed changes. The Nuclear Regulatory Commission (NRC) staff notes that internal flooding may haveunique plant specific vulnerabilities and may not be bounded by the generic analysis.Internal floods were not part of the implementation guidance for WCAP-14333. Providea plant-specific assessment (either qualitative or quantitative) to confirm that VCSNSinternal flooding results are bounded by WCAP-14333 for this F&O.8. Provide an assessment of the external events risk impact including seismic, fire, andexternal floods and high wind risk with respect to the proposed completion time andbypass time extensions in RG 1.177 Section 2.3.2, "Scope of the PRA for TSApplications."9. Provide a discussion on the following aspects of PRA quality as applicable to theVCSNS PRA.1.The plant-specific PRA reflects the as-built, as-operated plant.
| | Mr. Jeffrey B. Archie VIRGIL C. SUMMER NUCLEAR STATION South Carolina Electric & Gas Company cc: |
| 2.Applicable PRA updates conducted since completion of individual plantexamination (IPE) and individual plant examination of external events (IPEEE)and the status of any improvements identified by the IPE and IPEEE.3.Reference PRA quality assurance programs/procedures, including expectedPRA revision schedules.4.PRA adequacy and completeness with respect to evaluating the proposed AOTand bypass time extensions with emphasis on Tier 3.5.Plant design or operational modifications not reflected in the WCAP-14333 PRAused in this application that are related to or could impact this licenseamendment application. Justify the acceptability of not including thesemodifications in the PRA as part of this application.10. RG 1.174 states that as part of the evaluation of risk, the cumulative risk of the presentTS change in light of past applications should be understood. Cumulative risks were not addressed by VCSNS. Provide an evaluation of the cumulative risk impact of previousTS changes (including WCAP-10271) per RG 1.174, Section 3.3.2, as applicable to theimplementation of WCAP-14333. 11.Regarding page 9 of 26 of the application, for the restriction listed under Tier 2 provide aprocedure reference that incorporates these changes. Are these restrictions consideredlicensee commitments? 12.Page 9 of 26 of the licensee's submittal states that the VCSNS Tier 3 requirements areaddressed through VCSNS Operations Administrative Procedures consistent with therequirements Title 10 of the Code of Federal Regulations (10 CFR), section 50.65(a)(4). Provide a discussion on the applicability of the VCSNS 10 CFR 50.65(a)(4) configurationrisk management program (CRMP) to the additions and clarifications provided in RG 1.177, Section 2.3.7.2, Key Components 1 through 4, for CRMP programs thatimplement section a(4) of 10 CFR 50.65(a)(4) and the guidance provided by RG 1.182,"Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." In addition, identify the programs and procedures in place to implement the CRMP atVCSNS.
| | Mr. R. J. White Nuclear Coordinator S.C. Public Service Authority c/o Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 802 Jenkinsville, South Carolina 29065 Resident Inspector/Summer NPS c/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, South Carolina 29065 Chairman, Fairfield County Council Drawer 60 Winnsboro, South Carolina 29180 Mr. Henry Porter, Assistant Director Division of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Mr. Thomas D. Gatlin, General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 300 Jenkinsville, South Carolina 29065 Mr. Ronald B. Clary, Manager Nuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, South Carolina 29065 Ms. Kathryn M. Sutton, Esquire Winston & Strawn Law Firm 1400 L Street, NW Washington, DC 20005-3502}} |
| Mr. Jeffrey B. ArchieVIRGIL C. SUMMER NUCLEAR STATIONSouth Carolina Electric & Gas Company cc:Mr. R. J. WhiteNuclear CoordinatorS.C. Public Service Authorityc/o Virgil C. Summer Nuclear StationPost Office Box 88, Mail Code 802Jenkinsville, South Carolina 29065Resident Inspector/Summer NPSc/o U.S. Nuclear Regulatory Commission576 Stairway RoadJenkinsville, South Carolina 29065Chairman, Fairfield County CouncilDrawer 60Winnsboro, South Carolina 29180Mr. Henry Porter, Assistant DirectorDivision of Waste ManagementBureau of Land & Waste Management Dept. of Health & Environmental Control2600 Bull StreetColumbia, South Carolina 29201Mr. Thomas D. Gatlin, General ManagerNuclear Plant OperationsSouth Carolina Electric & Gas CompanyVirgil C. Summer Nuclear StationPost Office Box 88, Mail Code 300Jenkinsville, South Carolina 29065Mr. Ronald B. Clary, ManagerNuclear LicensingSouth Carolina Electric & Gas CompanyVirgil C. Summer Nuclear StationPost Office Box 88, Mail Code 830 Jenkinsville, South Carolina 29065Ms. Kathryn M. Sutton, EsquireWinston & Strawn Law Firm1400 L Street, NWWashington, DC 20005-3502}} | |
Letter Sequence RAI |
|---|
TAC:MC8898, RPS and ESFAS Test Times and Completion Times - WCAP-14333 (Open) |
|
MONTHYEARML0608000032006-03-21021 March 2006
V.C. Summer - Request for Additional Information Regarding Instrumentation Test and Completion Times
Project stage: RAI
RC-06-0067, LAR 05-2926 Implementation of WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times Response to Request for Additional Information2006-05-31031 May 2006
LAR 05-2926 Implementation of WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times Response to Request for Additional Information
Project stage: Response to RAI
RC-06-0173, V. C. Summer - LAR 05-2926, Implementation of WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of RPS and ESFAS Test Times and Completion Times - Summarized List of Commitments2006-09-29029 September 2006
V. C. Summer - LAR 05-2926, Implementation of WCAP-14333-P-A, Rev. 1, Probabilistic Risk Analysis of RPS and ESFAS Test Times and Completion Times - Summarized List of Commitments
Project stage: Other
ML0624306842006-10-24024 October 2006
V. C. Summer, License Amendment, WCAP-14333, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times.
Project stage: Acceptance Review
ML0630000262006-10-24024 October 2006
Technical Specifications, Implementing Approved Changes in Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times.
Project stage: Request
2006-03-21
[Table View] |
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|---|
Category:Letter
MONTHYEARML24038A0322024-02-0707 February 2024
(Vcsns), Unit 1, 10 CFR 21 Report - Emergency Diesel Generator Flash Contactor Relay
IR 05000395/20230042024-01-31031 January 2024
Integrated Inspection Report 05000395/2023004
ML24022A1582024-01-22022 January 2024
(Vcsns), Unit 1 - Reply to a Notice of Violation: EA-23-093
ML24022A1202024-01-22022 January 2024
Notification of Target Set Inspection and Request for Information (NRC Inspection Report 05000395/2024403)
ML24018A0112024-01-18018 January 2024
CFR 21 Report Emergency Diesel Generator Fuel Oil Piping
IR 05000395/20240112024-01-17017 January 2024
Notification of VC Summer Station Comprehensive Engineering Team Inspection - U.S. Nuclear Regulatory Commission Inspection Report 05000395/2024011
ML23361A1042023-12-21021 December 2023
Inservice Testing Program for Pumps and Valves Fifth Interval Update and Associated Relief and Alternative Requests
IR 05000395/20230912023-12-21021 December 2023
Final Significance Determination of a White Finding and Notice of Violation and Assessment Followup Letternrc Inspection Report 05000395/2023091
ML23354A1802023-12-20020 December 2023
301 Examination Report with Cover Letter
ML23347A0492023-12-12012 December 2023
Technical Specification Bases Changes Updated Through November 2023
ML23334A2462023-11-30030 November 2023
Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
ML23334A2372023-11-30030 November 2023
(Vvsns), Unit 1 - Annual Commitment Change Summary Report
ML23332A1942023-11-28028 November 2023
(Vcsns), Unit 1, Correction of Typographical Error in License Amendment Request - Inverter Allowed Outage Time (AOT) Extension
ML23317A2242023-11-0909 November 2023
(Vcsns), Unit 1 - License Amendment Request - Inverter Allowed Outage Time (AOT) Extension
ML23289A1172023-11-0303 November 2023
Tribal Request for Scoping Comments Concerning the Environmental Review of the V.C. Summer SLRA
ML23289A1152023-11-0303 November 2023
Ltr to R. Nelson - Request for Scoping Comments Concerning the Environmental Review of the V.C. Summer SLRA
ML23289A1162023-11-0303 November 2023
Ltr to W. Emerson - Request for Scoping Comments Concerning the Environmental Review of the V.C. Summer SLRA
IR 05000395/20234032023-11-0101 November 2023
Material Control and Accounting Program Inspection Report 05000395/2023403 Cover
IR 05000395/20230032023-11-0101 November 2023
Integrated Inspection Report 05000395/2023003
ML23284A1792023-10-16016 October 2023
Subsequent License Renewal Application Online Reference Portal
ML23275A0142023-10-11011 October 2023
SLRA - Acceptance and Opportunity for Hearing - Letter
ML23284A1662023-10-10010 October 2023
(Vcsns), Unit 1 - Request for Regulatory Conference; (EA-23-093)
IR 05000395/20230902023-10-0404 October 2023
NRC Inspection Report 05000395/2023090 and Preliminary Yellow Finding and Apparent Violation
IR 05000395/20230112023-09-27027 September 2023
Focused Engineering Inspection Report 05000395/2023011
ML23250A3112023-09-20020 September 2023
Request to Revise Reactor Vessel Material Surveillance Capsule Withdrawal Schedules
ML23244A2352023-09-18018 September 2023
Request to Use a Subsequent Edition of the ASME Code, Section XI
ML23230A0012023-09-15015 September 2023
Request to Use a Provision of a Previous Edition of the ASME Boiler and Pressure Vessel Code, Section XI, for Non-Destructive Examinations
ML23235A0432023-09-0505 September 2023
Receipt and Availability of the Subsequent License Renewal Application
IR 05000395/20234012023-08-30030 August 2023
Security Baseline Inspection Report 05000395/2023401
ML23242A1192023-08-29029 August 2023
(Vcsns), Unit 1 - Inservice Inspection (ISI) Owner'S Activity Report (OAR) for Refueling Outage 27
ML23243B0362023-08-25025 August 2023
Request for FEMA Consultation on the Dominion Energy Proposal to Consolidate the Emergency Operations Facility for the Virgil C. Summer Nuclear Station Unit 1
IR 05000395/20230052023-08-23023 August 2023
Updated Inspection Plan for Virgil C. Summer Nuclear Station (Report 05000395 2023005)
ML23233A1752023-08-17017 August 2023
Application for Subsequent Renewed Operating License
IR 05000395/20230022023-08-14014 August 2023
Integrated Inspection Report - Integrated Inspection Report 05000395/2023002 and Apparent Violation
IR 05000395/20230102023-08-12012 August 2023
Biennial Problem Identification and Resolution Inspection Report 05000395/2023010
ML23207A1102023-07-26026 July 2023
NRC Regulatory Issues Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations
IR 05000395/20234412023-07-17017 July 2023
95001 Supplemental Inspection Report 05000395/2023441 and Follow Up Assessment Letter
ML23190A0012023-07-0909 July 2023
Special Report 2023-003 Inoperable Radiation Monitoring Instrumentation Channel
ML23187A5092023-07-0606 July 2023
Request for Federal Emergency Management Agency Consultation on the Dominion Energy Proposal to Consolidate the Emergency Operations Facility for the Virgil C. Summer Nuclear Station Unit 1
ML23178A1682023-06-26026 June 2023
2022 Annual Report of Emergency Core Cooling System (ECCS) Model Changes Pursuant to the Requirements of 10 CFR 50.46
ML23173A1052023-06-22022 June 2023
Special Report 2023-002 Inoperable Loose-Part Monitoring System Channel
ML23163A2352023-06-12012 June 2023
Request to Use a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI, for the SPS Sixth Inservice Inspection (Isi) Intervals and VCSNS Fifth ISI Interval
ML23159A2332023-06-0808 June 2023
License Amendment Request - Emergency Response Organization Augmentation Time Change, Emergency Operations Facility Relocation and Other Emergency Plan Changes
ML23156A3092023-06-0505 June 2023
Requalification Program Inspection Virgil C. Summer Nuclear Station Unit 1 - 05000395/2023003
2024-02-07
[Table view]
Category:Request for Additional Information (RAI)
MONTHYEARML23270B8712023-09-27027 September 2023
NRR E-mail Capture - Draft RAIs for License Amendment Request (LAR) to Revise the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan (L-2023-LLA-0083)
ML22263A0502022-09-19019 September 2022
NRR E-mail Capture - Draft Request for Additional Information for Proposed Alternative Request RR-4-26 Extension of Steam Generator Primary Inlet Nozzle Dissimilar Metal Weld Inspection Interval V.C. Summer Unit 1
ML22194A9422022-07-13013 July 2022
NRC 50.59 Inspection (IP 71111.17T) Information Request
ML22075A0482022-03-16016 March 2022
V.C. Summer Nuclear Station - Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000395/2022401
ML21333A1892021-11-29029 November 2021
NRR E-mail Capture - Draft RAI for Summer LAR Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b, (TSTF-425)
ML21253A1352021-09-0808 September 2021
Document Request for VC Summer Nuclear Station - Radiation Protection Inspection - Inspection Report 2021-04
ML21154A2792021-06-0303 June 2021
Requalification Program Inspection 05000395/2021003 - Virgil C. Summer Nuclear Station, Unit 1,
ML21145A0222021-05-24024 May 2021
003 Radiation Safety Baseline Inspection Information Request
ML21131A0402021-05-11011 May 2021
NRR E-mail Capture - V.C. Summer, Unit 1 - Final RAI for the Spring 2020 RFO Sgtir Review
ML21020A0562021-01-20020 January 2021
Email Capture Upcoming V.C. Summer POV Inspection (IP71111.21N.02) Information Request
ML20342A1822020-12-0707 December 2020
NRR E-mail Capture - Final RAI for Summer LAR - TS 3.6.4
ML20342A3822020-12-0707 December 2020
NRR E-mail Capture - Final RAIs for Summer Fs LOCA LAR
ML20321A2112020-11-16016 November 2020
NRR E-mail Capture - Summer, Unit 1 - Final RAIs for the SG Tube Inspection Report Review
ML20196L7782020-07-13013 July 2020
Notification of Virgil C. Summer Nuclear Station Design Bases Assurance Inspection U.S. Nuclear Regulatory Commission Inspection Report 05000395/2020010
ML20106E8902020-04-15015 April 2020
Program Inspection RFI
ML20056E3042020-02-25025 February 2020
VC Summer 2020-002 Radiation Safety Baseline Inspection Information Request
ML19211D5102019-07-30030 July 2019
NRR E-mail Capture - Virgil C. Summer Nuclear Station, Unit No. 1 - Request for Additional Information LAR-16-01490 NFPA-805 (Supplement to PRA RAI 03)
ML19179A1262019-06-27027 June 2019
NRR E-mail Capture - Virgil C. Summer Nuclear Station, Unit No. 1 - Request for Additional Information LAR-16-01490 NFPA-805 Program Revisions
ML19095A6532019-04-0404 April 2019
NRR E-mail Capture - Virgil C. Summer Nuclear Station, Unit No. 1 - Request for Additional Information NFPA-805 Program Revisions LAR
ML19072A1442019-03-13013 March 2019
NRR E-mail Capture - Virgil C. Summer Nuclear Station, Unit No. 1 - Request for Additional Information LAR-16-01490 NFPA-805 Program Revisions
ML19009A1052019-01-0909 January 2019
NRR E-mail Capture - Virgil C. Summer Nuclear Station, Unit No. 1 - Request for Additional Information LAR-10-02395, TS 3.8.2, D.C. Sources - Operating
ML18249A1932018-09-0505 September 2018
TS 4.3.3.6 SR LAR - Request for Additional Information
ML18225A0932018-08-13013 August 2018
Notification of Inspection and Request for Information
ML18218A2622018-08-0101 August 2018
Emergency Preparedness Program Inspection Request for Information
ML18066A0002018-03-0808 March 2018
Request for Additional Information Integrated Leak Rate Test Peak Calculated Containment Internal Pressure Change
ML18023B0692018-02-15015 February 2018
Request for Additional Information Relief Request (RR-4-13), Use of Risk-Informed Process as an Alternative for the Selection of Class 1 and Class 2 Piping Welds
ML17095A2842017-05-11011 May 2017
Request for Additional Information License Amendment Request for Implementation of TSTF-411 (WCAP-15376-P-A), Revision 1
ML17067A5322017-03-0808 March 2017
Notification of Radiation Protection Baseline Inspection and Request for Information
ML17059C5382017-02-23023 February 2017
Notification of Inspection and Request for Information
ML16302A1252016-11-0808 November 2016
Request for Additional Information License Amendment Request for Implementation of TSTF-411 and WCAP-15376-P-A, Revision 1
RC-16-0112, NRC Request Information Baseline Radiation Safety Inspection2016-07-0707 July 2016
NRC Request Information Baseline Radiation Safety Inspection
ML16111A0912016-05-0303 May 2016
Request for Additional Information Regarding the Station Physical Security Plan, Revision 14
ML16097A0812016-04-0808 April 2016
Request for Additional Information
ML16064A0332016-03-0303 March 2016
NRR E-mail Capture - Request for Additional Information Related to the March 1, 2016, Exigent Amendment Request
ML16042A4712016-02-18018 February 2016
Request for Additional Information
ML15320A3382015-12-0101 December 2015
Request for Additional Information Regarding License Basis Changes in Steam Generator Tube Rupture Analysis
RC-15-0177, Submits LAR-12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis Response to Response for Additional Information2015-11-0505 November 2015
Submits LAR-12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis Response to Response for Additional Information
ML15261A0512015-09-22022 September 2015
Request for Additional Information Regarding License Basis Changes in Steam Generator Tube Rupture Analysis
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Text
March 21, 2006 Mr. Jeffery Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, South Carolina 29065
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION REQUEST FOR ADDITIONAL INFORMATION REGARDING INSTRUMENTATION TEST AND COMPLETION TIMES (TAC NO. MC8898)
Dear Mr. Archie:
The Nuclear Regulatory Commission staff is reviewing the license amendment application for the Virgil C. Summer Nuclear Station dated November 15, 2005, concerning instrumentation test and completion times and find that we need additional information as identified in the enclosure.
This request for additional information was discussed with your staff on March 20, 2006, and your staff indicated that a response could be provided by May 1, 2006. Please contact me if you have any questions.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395
Enclosure:
Request for Additional Information cc: See next page
ML060800003 NRR-088 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/LPL2-1/BC NAME RMartin CSola EMarinos DATE 3/21/06 3/21/06 3/21/06
REQUEST FOR ADDITIONAL INFORMATION RISK INFORMED JUSTIFICATION FOR EXTENDING ALLOWED OUTAGE TIME (AOT) BYPASS TEST TIMES VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
- 1. Westinghouse Commercial Atomic Power report (WCAP) -14333-P-A, Rev. 1, Probabilistic Risk Analysis of the RPS [reactor protection system] and ESFAS
[engineered safety feature actuation system] Test Times and Completion Times, dated October 1998, Section 11.0, Implementation of the Proposed Technical Specification Changes, Item 3, notes that a change to the action for an inoperable slave relay to following the expiration of the slave relay AOT, the component affected by the inoperable slave should be declared inoperable and the TS [Technical Specification]
action for this component should be followed. Is this modification required for the Virgil C. Summer Nuclear Station (VCSNS) TS? Explain why or why not.
- 2. Confirm that the VCSNS RPS utilizes the solid state protection system for the logic portion of the RPS.
- 3. Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Section 2.3 and RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking:
Technical Specifications, Section 3, as part of the key principles in implementing risk-informed decisionmaking, establishes the need for an implementation and monitoring program to ensure that extensions to TS AOT or surveillance test intervals do not degrade operational safety over time and that no adverse degradation occurs due to changes in the licensing basis due to unanticipated degradation or common cause mechanisms. An implementation and monitoring program is intended to ensure that the impact of the proposed TS change continues to reflect the reliability and availability of structures, systems and components impacted by the change. Provide information on the VCSNS implementation and monitoring program as applied to the incorporation of WCAP-14333 at VCSNS.
- 4. The analysis for WCAP-14333 assumed that maintenance on master and slave relays, logic cabinets, and analog channels while at power occurs only after a component failure, and that preventive maintenance does not occur. The topical report does not preclude the practice of at-power preventive maintenance but limits the total time a component is unavailable due to corrective or preventive maintenance to the values used in the analysis. If preventive maintenance is to be performed at VCSNS, confirm that the unavailability for components evaluated in WCAP-14333 are consistent with the plant specific estimates at VCSNS and do not exceed those assumed in the analysis.
Enclosure
See the submittal, Implementation Guideline, Table 1, Analog Channel Calibration as an example.
- 5. Provide the date of the VCSNS probabilistic risk assessment (PRA) industry peer review and date of certification.
- 6. Confirm that the WCAP-14333 reference plant assumptions for human reliability are applicable to VCSNS. As an example, see the B level Facts and Observations (F&Os) discussion for HR-06 on pages 18 and 19 of the submittal.
- 7. The licensees submittal states that due to the generic analysis of WCAP-14333 the second F&O concerning internal floods has no impact on the proposed changes.
The Nuclear Regulatory Commission (NRC) staff notes that internal flooding may have unique plant specific vulnerabilities and may not be bounded by the generic analysis.
Internal floods were not part of the implementation guidance for WCAP-14333. Provide a plant-specific assessment (either qualitative or quantitative) to confirm that VCSNS internal flooding results are bounded by WCAP-14333 for this F&O.
- 8. Provide an assessment of the external events risk impact including seismic, fire, and external floods and high wind risk with respect to the proposed completion time and bypass time extensions in RG 1.177 Section 2.3.2, Scope of the PRA for TS Applications.
- 9. Provide a discussion on the following aspects of PRA quality as applicable to the VCSNS PRA.
- 1. The plant-specific PRA reflects the as-built, as-operated plant.
- 2. Applicable PRA updates conducted since completion of individual plant examination (IPE) and individual plant examination of external events (IPEEE) and the status of any improvements identified by the IPE and IPEEE.
- 3. Reference PRA quality assurance programs/procedures, including expected PRA revision schedules.
- 4. PRA adequacy and completeness with respect to evaluating the proposed AOT and bypass time extensions with emphasis on Tier 3.
- 5. Plant design or operational modifications not reflected in the WCAP-14333 PRA used in this application that are related to or could impact this license amendment application. Justify the acceptability of not including these modifications in the PRA as part of this application.
- 10. RG 1.174 states that as part of the evaluation of risk, the cumulative risk of the present TS change in light of past applications should be understood. Cumulative risks were not
addressed by VCSNS. Provide an evaluation of the cumulative risk impact of previous TS changes (including WCAP-10271) per RG 1.174, Section 3.3.2, as applicable to the implementation of WCAP-14333.
- 11. Regarding page 9 of 26 of the application, for the restriction listed under Tier 2 provide a procedure reference that incorporates these changes. Are these restrictions considered licensee commitments?
- 12. Page 9 of 26 of the licensees submittal states that the VCSNS Tier 3 requirements are addressed through VCSNS Operations Administrative Procedures consistent with the requirements Title 10 of the Code of Federal Regulations (10 CFR), section 50.65(a)(4).
Provide a discussion on the applicability of the VCSNS 10 CFR 50.65(a)(4) configuration risk management program (CRMP) to the additions and clarifications provided in RG 1.177, Section 2.3.7.2, Key Components 1 through 4, for CRMP programs that implement section a(4) of 10 CFR 50.65(a)(4) and the guidance provided by RG 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.
In addition, identify the programs and procedures in place to implement the CRMP at VCSNS.
Mr. Jeffrey B. Archie VIRGIL C. SUMMER NUCLEAR STATION South Carolina Electric & Gas Company cc:
Mr. R. J. White Nuclear Coordinator S.C. Public Service Authority c/o Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 802 Jenkinsville, South Carolina 29065 Resident Inspector/Summer NPS c/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, South Carolina 29065 Chairman, Fairfield County Council Drawer 60 Winnsboro, South Carolina 29180 Mr. Henry Porter, Assistant Director Division of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Mr. Thomas D. Gatlin, General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 300 Jenkinsville, South Carolina 29065 Mr. Ronald B. Clary, Manager Nuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, South Carolina 29065 Ms. Kathryn M. Sutton, Esquire Winston & Strawn Law Firm 1400 L Street, NW Washington, DC 20005-3502
