RC-17-0135, Annual Commitment Change Summary Report

Annual Commitment Change Summary Report

ML17310B068
Person / Time
Site:	Summer
Issue date:	11/03/2017
From:	Lippard G South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RC-17-0135
Download: ML17310B068 (3)

Text

SCE&G A SCANA COMPANY George A. Lippard Vice President. Nuclear Operations 803.345.4810 Document Control Desk November 3, 2017 U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS), UNIT NO. 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ANNUAL COMMITMENT CHANGE

SUMMARY

REPORT Please find attached the 2016 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, please call Mr. Bruce Thompson at (803) 931-5042.

WCM/GAL/ts Very truly yours, Attachment c: K. B. Marsh S. A. Byrne J. B. Archie N. S. Cams J. H. Hamilton G. J. Lindamood W. M. Cherry C. Haney S. A. Williams NRC Resident Inspector K. M. Sutton NSRC RTS (LTD 662, RR 8850)

File (810.46)

PRSF (RC-17-0135)

V. C. Summer Nuclear Station

• P. 0. Box 88

• Jenkinsville, South Carolina

• 29065

• F (803) 941-9776

• www.sceg.com

Document Control Desk Attachment RC-17-0135 Page 1 of 2 The following commitment changes, with a brief justification, were performed during 2016 in accordance with VCSNS's Regulatory Commitment Management Program. This program was developed following NEI 99-04, "Guidelines for Managing NRC Commitment Changes." The changes are documented in the station's corrective action program condition reports (CRs):

CR-13-04877 Commitment - SCE&G committed to make changes to VCSNS plant documentation as a result of plant modifications to resolve Generic Letter (GL) 96-06 water hammer issues in the Service Water system. Under 10 CFR 50.59, various procedures, Technical Specification Bases, and FSAR would be changed to ensure the licensing and design bases reflect GL 96-06 commitments. Administrative controls through operating procedures would require the service water booster pump (SWBP) control to be placed in the pull-to-lock if it did not energize after a loss of offsite power (LOOP).

Change - In lieu of the administrative change to place the SWBP in pull-to-lock, additional control circuit interlocks between valve XVB03107A(B) and the SWBP were installed to prevent the SWBP from starting at a later time.

Justification for Change/Deletion - In correspondence RC-07-0143, VCSNS's submittal of "Response to NRC Questions Regarding Response to Generic Letter 96-06 (TAC NO.

M96872)", the following was stated:

"Further, if during the LOOP scenario described above, should 3107A(B) close at a later time, the SWBP may start, resulting in a pipe waterhammer. In order to mitigate this waterhammer condition, SCE&G intends to include in the modification one of the following:

1. Installation of additional control circuit interlocks between valve 3107A(B) and the SWBP to prevent the SWBP from starting at a later time.

2. Provide administrative controls through operating procedures. These procedures would require the SWBP control to be placed in pull-to-lock if it did not energize after a LOOP."

In subsequent correspondence RC-07-0184, "SCE&G Action Commitments Regarding Response to NRC Questions Regarding Response to Generic Letter 96-06 (TAC NO.

M96872)," SCE&G committed to implement option 2. Option 2 was later determined not acceptable, and option 1 was implemented under engineering change ECR-50567S.

CR-12-01102 Commitment - SCE&G committed to review the Phase 2 Staffing Analysis Report with the final validated FLEX Support Procedures (FSPs) and other applicable procedures. Revise and resubmit Phase 2 Staffing Analysis Report, if required.

Change - Due to a relaxation of the schedule requirements (NRC letter, "Virgil C. Summer Nuclear Station, Unit 1 - Relaxation of the Schedule Requirements of Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis

Document Control Desk Attachment RC-17-0135 Page 2 of 2 External Events (TAC No. MF2338)," dated October 4, 2015 [ML15243A450]), VCSNS submitted a commitment date change in correspondence RC-16-0028 for completing the review of the Phase 2 Staffing Analysis Report from February 15, 2016 to August 15, 2016.

Justification for Change/Deletion - On June 16, 2015, VCSNS submitted its response to the NRC's request for additional information regarding Phase 2 staffing submittals associated with Near-Term Task Force Recommendation 9.3. The Phase 2 Staffing Analysis Report was completed using draft Emergency Operating Procedure and FSP documents. The submittal contained a commitment to review the report based on the final validated FSPs and any applicable new procedures that were not available when the shift staffing study table tops were conducted. If required, the Phase 2 staffing analysis was to be revised and resubmitted by February 15, 2016.

The NRC approved the June 16, 2015 Phase 2 staffing analysis submittal on February 7, 2016.

The approval stated, "The NRC staff reviewed your Phase 2 staffing submittal and confirmed that your existing emergency response resources, as described in your emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the event response strategies that were developed in response to NRC Order EA-12-049 without the assignment of collateral duties that would impact the performance of assigned emergency plan functions." The NRC staff concluded that VCSNS's Phase 2 staffing submittal adequately addressed the response strategies needed to respond to a Beyond-Design-Basis External Events using the station's procedures and guidelines.

The original commitment date was based on VCSNS fully complying with Order EA-12-049 at the end of its fall outage (Refueling Outage 22) starting the beginning of October 2015.

However, the request for schedule relaxation was made and granted allowing VCSNS to fully comply with EA-12-049 by implementing a new emergency feed water (EFW) suction strategy by July 31, 2016. The request was required because it was determined the station's Condensate Storage Tank did not meet the high wind protection from tornado hazard requirements to be creditable water supply for NEI 12-06. Final validated FSPs and possible new procedures was not finalized because of the need to implement the new EFW suction strategy.

The new EFW suction strategy was implemented, the FLEX procedures updated, and training associated with this new FLEX strategy validated. VCSNS did not foresee any issues that caused the approved Phase 2 Staffing Analysis Report to change due to implementation of the new EFW suction strategy. In order to verify this, VCSNS committed to change the commitment date to August 15, 2016 to allow additional time to ensure the approved Phase 2 staffing analysis and the final validated FSPs, and any new applicable procedures, were completed.