ML020090531
| ML020090531 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/09/2002 |
| From: | Mccree V Division Reactor Projects II |
| To: | Gordon Peterson Duke Energy Corp |
| References | |
| IR-01-005 | |
| Download: ML020090531 (4) | |
See also: IR 05000413/2001005
Text
January 9, 2002
Duke Energy Corporation
ATTN: Mr. G. R. Peterson
Site Vice President
Catawba Nuclear Station
4800 Concord Road
York, SC 29745
SUBJECT: RESPONSE TO DUKES COMMENTS ON NRC INTEGRATED INSPECTION
REPORT 50-413/01-05, 50-414/01-05 DATED OCTOBER 22, 2001
Dear Mr. Peterson:
Thank you for your response of December 4, 2001, which provided comments for consideration
pertaining to non-cited violation (NCV) 50-414/01-05-01, Failure to Implement Effective
Corrective Actions Associated with the Unit 2 Refueling Water Storage Tank (FWST) Level
Channel Failures, and NCV 50-413, 414/01-05-03, Failure to Identify a Condition Adverse to
Quality that Rendered the A Chiller Inoperable.
Concerning the first NCV, you took exception to the NRC conclusion that the FWST
instrumentation channels were unreliable. Your response described the reliability of the FWST
level system in terms of monitoring performed by your Maintenance Rule program as required
by 10CFR50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear
Plants. You stated the performance goals are established with limits of 99.8% system
availability and 100% system reliability and that the Unit 2 FWST level system has always met
or exceeded these goals. A review of your maintenance rule program indicated that these limits
apply to the Refueling Water (FW) risk-significant systems, structures, and components (SSC),
and not to the performance of individual FWST level channels, which is the focus of this
violation. Our review indicated that the performance of individual FWST level channels is
monitored under a different SSC and have different monitoring criteria.
Your response quoted the following statement from Inspection Report 50-413/01-05, 50-
414/01-05, The failure to implement timely corrective actions for this degraded condition had a
credible impact on plant safety in that reliable operation of FWST level channels 1 and 3 was
not assured from 1996 to 2001. The intent of this statement was to explain the impact of the
NCV on plant safety. Criterion XVI of 10 CFR 50, Appendix B, requires that measures shall be
established to assure that conditions adverse to quality, such as failures, malfunctions and
deficiencies are promptly identified and corrected. This requirement applies to all safety-related
SSC which includes each individual FWST level channel. Based on the number of level
channel deficiencies since 1996, and the absence of a root cause determination until the Fall of
2001, the NRC concluded that your corrective actions were inadequate, and that the FWST
level channels were unreliable because quality could not be assured for each channel. This
was considered to have had a credible impact on safety because the system configuration that
existed when two FWST level channels failed on July 23, 1998, remained unchanged until
grounding modifications were completed in June 2001. During this time, the inspectors
DEC 2
concluded that the FWST level channels were more vulnerable to lightning induced failures.
After further review of this issue, and consideration of your comments regarding FWST level
channel reliability, we concluded that the inspection report accurately describes your FWST
corrective actions and the impact on plant safety.
You also took exception to the list of Problem Investigation Process (PIP) reports listed in the
inspection report on pages 4 and 5, and stated that this list may provide the incorrect perception
that all the events were instrument failures. With only a few exceptions, all the PIPs listed in
the report described actual degraded equipment conditions associated with the Unit 2 FWST
level channels that occurred between July 1996 and August 2000. The report did not intend to
imply that all these documented events were actual instrument failures, unless identified as
such in the PIP description column of the table.
Regarding the second NCV, you commented that previously issued NRC Inspection Report 50-
413/01-04, 50-414/01-04, dated July 23, 2001, documented a licensee identified violation for
the same May 3, 2001, chiller event referenced in the second NCV. Your response contended
that this event, if significant enough to warrant multiple violations, should be credited as a
licensee identified finding as originally documented in the July 23, 2001, report. Our review
indicated that these NCVs identified two different performance deficiencies, both of which
warranted an individual NCV. The first performance deficiency resulted in NCV 50-413,414/01-
04-02 and involved your failure to develop appropriate written procedures or documented
instructions for maintenance activities on the A YC chiller. The second NCV identified a
performance deficiency involving the failure of licensed operators to perform an adequate
operability review of the A YC chiller during the May 3, 2001 event. This NCV was identified
through the baseline inspection program during the review and closure of Licensee Event
Report (LER) 50-413/2001-002. NRC Inspection Manual Chapter 0610*, Power Reactor
Inspection Reports, requires that when closing LERs, the NRC should identify any more-than-
minor findings or violations of regulatory requirements, and document these accordingly when
closing the LER.
After further review of this issue, and consideration of your comments, we agree that this
violation should also have been credited as a licensee-identified NCV. Consequently, we plan
to update the Plant Issues Matrix and the Reactor Oversight Process web page to reflect this
NCV as being licensee identified.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Victor M. McCree, Acting Director
Division of Reactor Projects
Docket Nos.: 50-413, 50-414
DEC 3
cc w/encl:
Regulatory Compliance Manager Richard P. Wilson, Esq.
Duke Energy Corporation Assistant Attorney General
Electronic Mail Distribution S. C. Attorney General's Office
Electronic Mail Distribution
Lisa Vaughn
Legal Department (PB05E) Vanessa Quinn
Duke Energy Corporation Federal Emergency Management Agency
422 South Church Street Electronic Mail Distribution
Charlotte, NC 28242
North Carolina Electric
Anne Cottingham Membership Corporation
Winston and Strawn Electronic Mail Distribution
Electronic Mail Distribution
Peggy Force
North Carolina MPA-1 Assistant Attorney General
Electronic Mail Distribution N. C. Department of Justice
Electronic Mail Distribution
Henry J. Porter, Assistant Director
Div. of Radioactive Waste Mgmt. County Manager of York County, SC
S. C. Department of Health Electronic Mail Distribution
and Environmental Control
Electronic Mail Distribution Piedmont Municipal Power Agency
Electronic Mail Distribution
R. Mike Gandy
Division of Radioactive Waste Mgmt. Manager
S. C. Department of Health and Nuclear Regulatory Licensing
Environmental Control Duke Energy Corporation
Electronic Mail Distribution 526 S. Church Street
Charlotte, NC 28201-0006
DEC 4
Distribution w/encl:
C. Patel, NRR
RidsNrrDipmlipb
PUBLIC
PUBLIC DOCUMENT (circle one): YES NO
OFFICE RII:DRP RII:DRP RII:DRP
SIGNATURE
NAME RHaag DRoberts MGiles
DATE 1/08/2002 1/7/2002 1/7/2002
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\Program Files\Adobe\Acrobat 4.0\PDF Output\ResponseTo
IR01-05.wpd