IR 05000395/2007502

07/16/2007-Summary of Public Meeting - Virgil C. Summer Nuclear Station, to Discuss Significance on Apparent Violation Documented in Inspection Report 50-395-07-502

ML072120280
Person / Time
Site:	Summer
Issue date:	07/30/2007
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Archie J South Carolina Electric & Gas Co
References
NUREG-0654 IR-07-502
Download: ML072120280 (76)

Text

uly 30, 2007

SUBJECT:

PUBLIC MEETING SUMMARY - VIRGIL C. SUMMER NUCLEAR STATION -

DOCKET NO. 50-395

Dear Mr. Archie:

This refers to the meeting conducted at your staffs request at the Region II Office in Atlanta, Georgia on July 16, 2007, at 10:30 a.m. The purpose of the meeting was to discuss the significance of the Apparent Violation (AV) documented in Inspection Report No. 50-395/2007-502. The AV involved changes made to your emergency plan that may have decreased the effectiveness of the plan and failed to maintain a standard emergency classification scheme.

Your presentation at the meeting (Enclosure 2) included a general discussion of the changes made to your emergency plan over the last 26 years; a discussion of the elements of a NUREG-0654 standard emergency classification scheme; a discussion of the decrease in effectiveness portion of the AV for three emergency action levels (EAL) identified in the inspection report; and a discussion of the EAL added to your emergency plan to address reduced inventory events. As you presented at the meeting, you concluded that the standard NUREG-0654 EAL scheme was not affected by your revisions to the detection methods for EALs 301, 401, and 411. You agreed that the addition of EAL 397 created a non- standard scheme. You also concluded that the changes to the EALs cited in the inspection report did not decrease the effectiveness of your emergency plan. You also committed to provide us with a corrective action plan by August 17, 2007. The information you presented at the meeting will be considered in making a decision. On July 24, 2007, you submitted decrease in effectiveness reviews for the EALs discussed during the meeting (Enclosure 3).

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

SCE&G 2 ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-395 License No.: NPF-12 Enclosures:

1. List of Attendees 2. Meeting Presentation - EAL Apparent Violation 3. Decrease In Effectiveness Reviews

SCE&G 3 cc w/encl:

R. J. White Nuclear Coordinator Mail Code 802 S.C. Public Service Authority Virgil C. Summer Nuclear Station Electronic Mail Distribution Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius LLP Electronic Mail Distribution Henry J. Porter, Director Div. of Radioactive Waste Mgmt.

Dept. of Health and Environmental Control Electronic Mail Distribution R. Mike Gandy Division of Radioactive Waste Mgmt.

S. C. Department of Health and Environmental Control Electronic Mail Distribution Bruce L. Thompson, Manager Nuclear Licensing (Mail Code 830)

South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Electronic Mail Distribution Robert M. Fowlkes, General Manager Engineering Services South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Electronic Mail Distribution Thomas D. Gatlin, General Manager Nuclear Plant Operations (Mail Code 303)

South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Electronic Mail Distribution David A. Lavigne, General Manager Organization Development South Carolina Electric & Gas Company Vigil C. Summer Nuclear Station Electronic Mail Distribution

LIST OF ATTENDEES South Carolina Electric & Gas Company - Virgil C. Summer Nuclear Station J. Archie, Vice President, Nuclear Operations R. Fowlkes, General Manager, Engineering Services D. Gatlin, General Manager, Nuclear Plant Operations D. Goldston, Operations Administrative Supervisor B. Thompson, Manager Nuclear Licensing R. Williamson, Supervisor, Emergency Services S. Zarandi, General Manager, Nuclear Support Services A. Cribb, Nuclear Licensing Supervisor *

J. Knox, Emergency Planning Specialist *

R. White, S.C. Public Service Authority Nuclear Coordinator *

Nuclear Regulatory Commission W. Travers, Regional Administrator, Region II K. Kennedy, Deputy Director, Division of Reactor Safety (DRS), RII J. Olmstead, Acting Regional Counsel and Enforcement Officer, RII B. Bonser, Chief, Plant Support Branch 1, RII L. Miller, Senior Emergency Preparedness Inspector, RII J. Kreh, Emergency Preparedness Inspector, RII R. Trojanowski, Senior Regional Government Liaison Officer, RII S. Sparks, Senior Enforcement Specialist, RII John Zeiler, Summer NRC Senior Resident Inspector *

R. Kahler, NSIR *

M. Norris, NSIR *

D. Johnson, NSIR *

R. Schmitt, NSIR *

Members Of The Public Larry Garner

• Participated by telephone Enclosure 1

EAL Apparent Violation NRC Inspection Report 395/2007502 Enclosure 2 1

AGENDA

• Opening Remarks

• Discussion of Apparent Violation

• Standard EAL Schemes

• Decrease in Effectiveness Discussion

• Closing Remarks Enclosure 2 2

Opening Remarks Dan Gatlin Plant Manager Enclosure 2 3

Opening Remarks

• SCE&G has made significant improvements to the Emergency Plan over the years

- Most changes were made to detection methods to assure timely recognition and classification of emergency situations

- Changes were based on simulator experience, improved instrumentation, and improved understanding of accident progression (48 revisions in 26 years, currently on Rev 53)

- Numerous NRC-SCE&G Interactions Enclosure 2 4

Opening Remarks

• SCE&G review of change of standard scheme, and NRC DIE examples

- Standard scheme was changed as cited in one example, with the addition of reduced inventory initiating condition, but with good intentions!

- SCE&G agrees with violation on basis of non-standard scheme

- Detection Method Changes do not result in a decrease in effectiveness (DIE) for the examples cited Enclosure 2 5

Opening Remarks

• SCE&G Corrective Actions

- Extensive review of all changes back to Rev. 5 in accordance with RIS 2007-01 with results entered into our corrective action program

- Interim Revision of the Emergency Plan will address our review results and the observations listed in attachment 2 of the inspection report

• References to EOP steps and transitions will be removed

- Conversion to NEI 99-01 in progress with submittal planed for third quarter Enclosure 2 6

Apparent Violation

• Two GE and Two SAE EAL changes that:

- Resulted in a Failure to Maintain a Standard EAL Scheme and/or

- Decreased the Effectiveness of the Emergency Plan

• Four EAL initiating conditions were cited:

EAL Scheme Change DIE SAE 397 X SAE 301 X X GE 401 X X GE 411 X X Enclosure 2 7

Standard EAL Schemes

• Three Standard EAL Schemes have been approved by the NRC:

- NUREG-0654,

- NUMARC/NESP-007

- NEI 99-01

• Our Scheme is based on NUREG-0654 Enclosure 2 8

Standard EAL Schemes

• Elements of a NUREG-0654 Standard Scheme

- Emergency classification and action level scheme as set forth in Appendix 1 of NUREG-0654

- Initiating conditions shall include examples found in Appendix 1

• Detection Methods are not identified in NUREG-0654 as a factor for determining a Standard EAL Scheme (is referenced in NEI 99-01)

Enclosure 2 9

Standard EAL Schemes

• NUREG-0654 requires specific instruments, parameters or equipment status shall be shown for each emergency class, in the plant specific emergency procedure

- Our detection methods (DMs) identify the specific instruments, parameters or equipment status for each emergency class

- Our DMs have been further enhanced by incorporating instruments, parameters or equipment status as referenced in Emergency Operating Procedures (EOPs)

Enclosure 2 10

Standard EAL Schemes

• It is SCE&Gs position that the regulatory requirement to maintain a NUREG-0654 standard scheme is based on maintaining the initiating conditions incorporated in the Emergency Plan approved by the NRC

- Changes to the Detection methods that ensure the initiating condition is recognized in a timely manner does not create a non-standard scheme

• The standard EAL Scheme has not been affected by revisions to the detection methods of EAL 301, 401 and 411 Enclosure 2 11

EAL 397

• Addition to the Standard Scheme

- SCE&G added two Initiating Conditions to address loss of inventory events during shutdown conditions

- The NRC cited the addition of EAL 397 as an EAL that was not consistent with the standard EAL schemes, resulting in a non-standard EAL Enclosure 2 12

EAL 397

• Loss Of Residual Heat Removal Flow For More Than 40 Minutes During Half-pipe Operations With Vessel Head Installed And High Head Safety Injection/Charging Unavailable Enclosure 2 13

NRC Basis for AV

• This EAL is not Consistent with the Standard EAL schemes resulting in a Non-Standard EAL Enclosure 2 14

History of EAL 397

• This initiating condition was added as a result of NUREG-1269

- This Initiating Condition was added as an ALERT by revision 23.

• It was first communicated to the NRC in VCS response to question 9 of Generic Letter 87-12 on September 18, 1987

- Where VCS committed to clarifying the initiating criteria for the emergency classifications for loss of RHR.

Enclosure 2 15

History of EAL 397

• Two initiating conditions were added in revision 23 :

- NOUE: Loss of RHR flow for more than twenty minutes during half pipe operation with the reactor vessel head installed

- Alert: Loss of RHR flow for more than forty minutes during half pipe operation with the reactor vessel head installed Enclosure 2 16

History of EAL 397

• During a review of revision 26, the NRC stated that the initiating condition: Loss of RHR flow for more than twenty minutes NOUE met the requirement of an ALERT rather than an NOUE.

(Ref: NRC letter dated May 16, 1990 from Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards)

• As a Result, the NOUE and this ALERT were shifted to an ALERT and a SAE in Revision 27.

Enclosure 2 17

History of EAL 397

• The NRC documented their review of Revision 27 and concluded that the changes met the planning standards of 10 CFR 50.47 (b) and the requirements of Appendix E to 10 CFR 50

- (Ref: NRC letter dated August 29, 1990 from Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards).

• This EAL is similar to EAL CS2 SAE in NEI-99-01 Enclosure 2 18

Standard EAL Schemes Summary:

• The standard EAL Scheme has not been affected by revisions to the detection methods of EAL 301, 401 and 411

• EAL 397 was added as an enhancement to address PWR reduced inventory events

• SCE&G agrees that the addition of EAL 397 created a non-standard scheme Enclosure 2 19

Decrease in Effectiveness

• We will discuss the decrease in effectiveness portion of the apparent violation in the following order:

- EAL 301

- EAL 401

- EAL 411 Enclosure 2 20

Decrease in Effectiveness

• A change in an emergency preparedness requirement that results in the degradation or loss:

- of the capability to perform a function or

- perform a function in a timely manner, as contained in the emergency plan.

Enclosure 2 21

EAL 301

• Known LOSS-OF-COOLANT ACCIDENT (LOCA) Greater than Charging Pump Capacity As the NRC stated this initiating condition remained essentially the same between revisions 5 and 53.

• This EAL maintains a Standard scheme.

Enclosure 2 22

NRC Basis for AV

• The changes to the EAL may increase the number of classifiable SAE events.

• The detection methods which are reliant on an EOP transition point or entry point could result in a delay in making the SAE declaration Enclosure 2 23

(LOCA) Greater than Charging Pump Capacity Detection Methods Rev. 5 Rev. 53 Pressurizer low pressure reactor trip; ANY of the following indications (1 and OR 2 OR 3 OR 4):

Pressurizer low pressure safety injection signal, and RM-A2 high 1) Evaluate the following indications alarm; and to determine if a LOCA condition High Reactor Building Sump level; exists (similar to EOP-1.0):

and a. Pressurizer low pressure High Reactor Building humidity; and reactor trip.

High Reactor Building pressure. b. Pressurizer low pressure safety injection.

c. Reactor Building pressure 1.5 psig, d. Abnormal Reactor Building sump level, e. RBCU Drain Flow High, f. Abnormal radiation levels on RM-A2 or RM-G7, or RM-G18.

Enclosure 2 24

(LOCA) Greater than Charging Pump Capacity Detection Methods Rev. 53

--- - - - - - - - - OR - - - - - - - - - - - -

2. Direct Entry into EOP-2.0 from EOP-1.0 due to the RCS NOT Being Intact.

- - - - - - - - - - - OR - - - - - - - - - - - -

3. Stuck Open and Unisolable Pressurizer PORV or Safety Valve Leading to Pressurizer Relief Tank Rupture.

- - - - - - - -- - - - OR - - - - - - - - - - - -

4. Initiating Bleed and Feed per EOP-15.0. (Refer to Initiating Condition 411 for possible escalation.)

Enclosure 2 25

301 - Known LOSS-OF-COOLANT ACCIDENT (LOCA) Greater than Charging Pump Capacity

• The DM changes do not cause an increase in the number of classifications:

- DM in Rev 5 and in the current 1ST DM are essentially the same, yet have been enhanced as follows:

• Additional Radiation Monitors were added to allow diversity since RM-A2 isolates on an SI

• Abnormal RM indications versus High alarm was added since a small break LOCA may not cause the RM to reach alarm setpoint

• RB pressure 1.5 psig was added to provide a quantitative value for high RB pressure (above Tech Spec limit)

• RBCU drain Flow High provides the indication of humidity in the Reactor Building.

• These additions clarify the DM without causing additional inappropriate classifications Enclosure 2 26

301 - Known LOSS-OF-COOLANT ACCIDENT (LOCA) Greater than Charging Pump Capacity

• EOP transitions do not delay the classification:

- If the indications in DM 1 are met, the classification is made without delay

- Detection Methods 2, 3, and 4 are OR DMs that provide additional guidance.

• DM 2 is the EOP transition from 1.0 to 2.0 due to a LOCA. This transition occurs within 10 minutes of the SI

• DM 3 and 4 remind the operator that a stuck open safety or PORV is a LOCA greater than charging pump capacity

- DM 2, 3, and 4 do not delay the classification Enclosure 2 27

301 - Known LOSS-OF-COOLANT ACCIDENT (LOCA) Greater than Charging Pump Capacity Conclusion:

• SCE&G maintains that the current wording in EAL 301 has not caused a decrease in effectiveness of the plan

- This Initiating Condition was run on the simulator 44 times with 44 timely and accurate classifications in the last three years Enclosure 2 28

EAL 401

• Small And Large LOCAs With Failure Of ECCS To Perform Leading To Severe Core Degradation Or Melt As the NRC stated this initiating condition remained essentially the same between revisions 5 and 53.

• This EAL maintains a Standard scheme.

Enclosure 2 29

NRC Basis for AV

• The revised EAL applied more restrictive criteria to when the EAL would be met and:

- could reduce the number of classifiable events or

- could delay the GE declaration Enclosure 2 30

Perform Leading To Severe Core Degradation Or Melt Detection Methods Rev 5 Rev 53 Safety injection signal with Failure of BOTH of the following reactor trip; and after depressurizing the RCS to < 140 psig per EOP-14.0.

1) Status lamps indicate safety injection system Failure of (1 AND 2):

and RHR pumps not ------------------------

running: or 1. High Head Injection Flow 2) Flow indicators for AND Safety Injection Systems read zero; and 2. Low Head Injection Flow RMG-5, RMG-7, RMG-l8, high alarm; and RM-A2 high alarm Enclosure 2 31

EAL 401 Background

• The current DMs focus control room personnel to the Failure of the High head and Low Head SI

• EOP-14.0 for inadequate core cooling would be in progress

- Entry conditions for EOP-14 are precursors for core damage and high RB radiation

• Low head Injection will inject only after RCS has been depressurized below 140 psig Enclosure 2 32

EAL 401

• The DM changes do not reduce the number of classifiable events:

- Our detection methods ensure the initiating condition of loss of high head and low head SI are determined prior to the declaration

• The DM changes do not delay the declaration:

- The dynamics of a SBLOCA and a LBLOCA are not the same, therefore the declaration time will be different.

• The RHR pump status during a LBLOCA will be readily determined because the RCS will be depressurized

• During a SBLOCA the RCS must be depressurized to determine the RHR pump status

• This results in a timely and accurate classification Enclosure 2 33

EAL 401

• Conclusions:

- SCE&G maintains that the current wording for the DM in EAL 401 has not caused a decrease in effectiveness of the plan Enclosure 2 34

EAL 411

• Transient Initiated by Loss of Feedwater and Condensate Systems (principal heat removal system) followed by Failure of Emergency Feedwater System for Extended Period. Core Melting Possible in Several Hours.

- As the NRC stated the Initiating Condition for EAL number 411 remained essentially the same between Revisions 5 and 53

• This EAL maintains a Standard scheme.

Enclosure 2 35

NRC Basis for AV

• The revised EAL applied more restrictive criteria to when the EAL would be met and could:

- reduce the number of classifiable events or

- could delay the GE declaration Enclosure 2 36

411 - Transient Initiated by Loss of Feedwater and Condensate Systems followed by Failure of Emergency Feedwater System for extended period. Core melting possible in several hours.

Rev 5 Rev 53 Reactor trip on low feedwater ALL of the following exists flow; and Decreasing wide-range (1 AND 2):

steam generator levels toward off-scale low on all steam generators; -------------------------

and 1. Inability to Establish Bleed and 1) Emergency feedwater flow Feed Cooling when required indicators indicate zero flow 2 per EOP-15.0 min. after required; or - - - - - - - - - AND - - - - - - - - - - -

2) Status lamps indicate 2. Core Exit Temperatures >

emergency feedwater pumps not 700°F.

running 2 min. after required; and Emergency feedwater cannot be restored within 30 min.

Enclosure 2 37

411 - Transient Initiated by Loss of Feedwater and Condensate Systems followed by Failure of Emergency Feedwater System for extended period. Core melting possible in several hours.

• The original detection method was based on time EFW was not available

• It did not take into consideration actions in EOP-15.0 for:

- restoring feedwater and condensate system flow to the S/Gs or

- Establishing bleed and feed core cooling to prevent possible core melting in several hours Enclosure 2 38

411 - Transient Initiated by Loss of Feedwater and Condensate Systems followed by Failure of Emergency Feedwater System for extended period. Core melting possible in several hours.

• Changes to the DMs did not reduce the number of classifiable events or delay the GE declaration

- The changes ensured the initiating condition was met prior to the classification Enclosure 2 39

EAL 411

• Conclusions:

- SCE&G maintains that the current wording in EAL 411 has not caused a decrease in effectiveness of the plan Enclosure 2 40

Summary

• Changes were made focused on improving the emergency plan, and therefore public health and safety

• Detection methods were changed to allow timely and accurate classifications of the NUREG 0654 initiating conditions

• The effectiveness of the emergency plan has been demonstrated through 26 yrs of successful exercises

• Questions Enclosure 2 41

Closing Remarks Jeff Archie Vice President Nuclear Plant Operations Enclosure 2 42

Closing Remarks

• Continuous Improvement has been a cornerstone of VCSNS Success

• Changes to detection methods were enhancements as a result of:

- Industry and internal lessons learned

- Technology Improvements

- Issues identified during simulator exercises Enclosure 2 43

Closing Remarks

• With the exception of the addition of EAL 397, we have maintained a standard scheme consistent with the regulatory requirements of NUREG-0654 for the examples cited

• Our evaluation of each of the cited examples have determined that the examples do not decrease the effectiveness of the plan.

• We do not dispute the violation related to EAL 397 Enclosure 2 44

Short Term Corrective Actions

• SCE&G is addressing the underlying issues in RIS 2007-01

- Each condition identified during our review comparing REV 5 to our current EALs will be dispositioned in accordance with RIS 2007-01

- Each observation identified in attachment 2 of the inspection report will be dispositioned

- Reference to specific EOP steps and transitions will be deleted

• SCE&G is requesting enforcement discretion until December 1st 2007, to complete the above proposed corrective actions

- A corrective action plan will be provided by 8/15/2007 Enclosure 2 45

Corrective Actions to Prevent Recurrence

• The station is in the process of transitioning to NEI 99-01

- Contracted with a recognized industry expert in EAL conversions

- Draft EALs and bases have been developed and are currently being verified and validated

- The NEI 99-01 scheme is scheduled to be submitted to the NRC in the 3rd Quarter 2007 Enclosure 2 46

Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3 Enclosure 3