ML030150118
| ML030150118 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/30/2002 |
| From: | Gordon Peterson Duke Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML030150118 (4) | |
Text
"A Duke SPotwer A Duke Energy Company GARY R. PETERSON Vice President Catawba Nuclear Station Duke Power CNOI VP / 4800 Concord Rd York, SC 29745 803 831 4251 803 831 3221 fax grpeters@duke-energy corn December 30, 2002 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555
Subject:
Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Response to NRC Questions for Proposed Technical Specification Amendment for Nuclear Service Water System Pipe Replacement
Reference:
- 1) Letter from Gary R. Peterson to U.S. Nuclear Regulatory Commission dated September 12, 2002.
In Reference 1 Catawba Nuclear Station (CNS) requested an amendment to the Facility Operating License and Technical Specifications (TS) for temporary changes to support replacement of a section of nuclear service water system (NSWS) piping.
The changes would allow the "A" NSWS header for each unit to be removed from service for seven (7) days for pipe replacement.
Catawba listed several contingency measures in Reference 1 which would be used to reduce the overall plant risk during the pipe replacement evolution.
Recent discussions with members of the NRC staff have indicated that the NRC staff requests CNS to discuss how these contingency measures will be controlled.
In Reference 1 CNS listed eleven (11) contingency measures.
These contingency measures are considered NRC commitments during the time period that the "A" NSWS header on both units is out of service for pipe replacement.
Duke Energy has developed an administrative procedure, Nuclear System Directive (NSD) 214, Commitment Management Program, to ensure the proper management of NRC commitments.
This administrative procedure was developed following the guidance provided by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidelines for Managing NRC Commitment Changes.
www duke-energy.com
U.S. Nuclear Regulatory Commission Page 2 December 30, 2002 The NRC issued Regulatory Issue Summary (RIS) 2000-00-017, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, on September 21, 2000.
This RIS states that the NRC staff has reviewed NEI 99-04 and finds that it offers an acceptable way to manage regulatory commitments. Definitions and other guidance in NEI 99-04 are consistent with the principles described in Commission papers and the staff's internal guidance.
This administrative procedure has several steps to ensure that the proper process is used to change a commitment.
This includes a review to determine if 10 CFR 50.59 applies and a review against 10 CFR 50.92 to determine if a
significant hazards consideration exists.
This process will ensure that any changes are properly evaluated.
These contingency measures have been incorporated into the "Critical Evolution Plan" that has been developed for the pipe replacement project.
The plan was developed following the guidance of CNS Site Directive 3.0.18, "On-Line Maintenance."
Site Directive 3.0.18 has been developed to ensure that on-line maintenance is controlled and evaluated to reduce overall risk and following the requirements of 10 CFR 50.65(a) (4).
The plan requires review by the CNS Plant Operations Review Committee (PORC) and any changes to the plan have to be reviewed by PORC prior to implementation.
In addition, on page 3-2 of Reference 1, CNS discussed the excavation process and the compensatory action that would be in place for missile protection.
This compensatory action was developed under a process that requires the use of 10 CFR 50.59.
Changes to this compensatory action will require that those changes be reviewed against the criteria of 10 CFR-50.59 prior to implementation.
The items discussed in this letter have been reviewed against the No Significant Hazards Evaluation submitted in Reference 1 and CNS has determined that the previous No Significant Hazards Evaluation still remains valid and has not been affected.
U.S. Nuclear Regulatory Commission Page 3 December 30, 2002 Inquiries on this matter should be directed to R.
D.
Hart at (803) 831-3622.
Very truly yours, G.
R. Peterson RDH/s Attachments
U.S. Nuclear Regulatory Commission Page 4 December 30, 2002 xc (with attachments):
L.A. Reyes U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,
SW, Suite 23T85 Atlanta, GA 30303 Senior Resident Inspector (CNS)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station R.E. Martin (addressee only)
NRC Senior Project Manager (MNS)
U.S. Nuclear Regulatory Commission Mail Stop 08-G9 Washington, D.C. 20555-0001 H.J. Porter Assistant Director Department of Health and Environmental Control 2600 Bull St.
- Columbia, SC 29201