ML090850346

Duke Energy Carolinas, LLC (Duke), Catawba Nuclear Station, Units 1 and 2, Commitment Change Evaluation Report for 2008

ML090850346
Person / Time
Site:	Catawba
Issue date:	03/16/2009
From:	Morris J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML090850346 (5)

Text

Duke JAMES R. MORRIS Vice President MrEnergy Duke Energy Corporation Catawba Nuclear Stati6n 4800 Concord Road York, SC 29745 803-701-4251 803-701-3221 fax March 16, 2009 U.S. Nuclear Regulatory Commission.

Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke)

Catawba Nuclear Station, Units 1 and 2 Docket Nos.: 50-413 and 50-414 Commitment Change Evaluation Report for 2008 Attached is a summary of commitment change evaluations completed during the 2008 calendar year for Catawba Nuclear Station. These evaluations and subsequent commitment changes were made based on the guidance defined in NEI 99-04, Guidelines for Managing NRC Commitments, and have no adverse effect on compliance with NRC rules and regulations.

Questions regarding this report should be directed to Toni Pasour at 803-701-3566.

Sincerely, J. R. Morris Attachments www. duke-energy. com

U. S. Nuclear Regulatory Commission March 16, 2009 Page 2 xc:

L. A. Reyes, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 J. H. Thompson (addressee only)

NRR Project Manager (CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 A. T. Sabisch Senior Resident Inspector (CNS)

CN01NC

Catawba Nuclear Station Annual Commitment Change Summary Report for 2008 Docket Nos. 50-413 and 50-414 NRC Notification Number Source Document Original Commitment Modified Commitment Required NRC Generic Letter Response This change revised the frequency Defer the inspection of RN Pit B from Yes 2008-C-001 (11/27/1997) and Commitment of the RN Pit inspections to a 3 year 2EOC15 to 2EOC16 in April of 2009.

Change #2002-005 frequency beginning with the last RN intake and Train B inspection During 2EOC15, degradation of 2ATD conducted on 4/24/02. required unit 2 ETB to be aligned to SATB. With the plant in this alignment, the draining of the B train RN pit would have required both the 1B and 2B RN pumps to be tagged out, rendering the corresponding diesel generators inoperable. This alignment would have placed Unit 1 in an Oram-Sentinel RED condition. Deferring the scheduled B train RN pit cleaning to a later date would maintain the operability of the 1 B diesel emergency power supply and minimize the safety impact on Unit 1.

Deferring this inspection and cleaning of the B train RN pit until 2EOC16 in April of 2009 will result in the inspection exceeding the 3 year commitment.

Exceeding the commitment by four months will not result in any degradation of the RN system based on the past 3 inspections and the positive trend of less material in the pit in subsequent inspections.

This commitment change is a one-time deferral and will not be incorporated as a permanent commitment.

Spec. CNS-1274.00-00-0005, The existing commitment reads: "At The revised commitment reads:

License Renewal Aging Catawba, non-destructive testing "At Catawba, non-destructive testing Management Programs, Sec. (NDT) is performed on the (NDT) is performed on each

'4.18, Heat Exchanger perimeter tubes of each (reolacement) containment spray heat I r P J Page 1

NRC Notification Number Source Document Original Commitment Modified Commitment Required Preventive Maintenance containmentspray heat exchanger exchangeras needed based on operating Activities - Containment Spray, at least every five years." experience and engineering evaluation of Monitoring & Trending test data."

All four Catawba containment spray heat exchangers have been replaced with ones having new design features. Tube material was changed from original stainless steel to titanium, which has superior corrosion resistance to pitting degradation. Tube support baffle design was changed to a more rigorous metal strip, cage design, which significantly reduces potential for tube support vibrational damage. Flow path of service water cooling changed from shell side to tube side to enhance effectiveness of tube cleaning maintenance to remove fouling deposits.

• NRC Generic Letter 89-13 Work requests were generated to Continue to perform the quarterly flush of Yes 2008-C-003

• NRC Inspection Report 94- radiograph the sections of pipe the RN to CA piping immediately 17, 9/9/1994 leading to the CA suction. These upstream of the RN/CA isolation valves

• Duke Power Response to work requests were converted to and perform the RN to CA flow NRC IR 94-17, PIP C' predefined model work orders with measurement test every 18 months on 1555 (6/1/1995) an annual frequency. the affected unit.

The radiographic test of the small sections of RN to CA piping has not detected any Asiatic clams during the eight years of inspection. The radiographic testing of the RN-CA piping does not provide any additional benefit in assuring the reliability of the system to perform this design basis function. In lieu of radiographic test, the quarterly RN to CA piping flushes will be maintained, as well as the unit specific 18 month test of the RN to CA flow testing.

Duke Power Response to NRC Generic Letter 89-13 states: Inspections of nuclear safety related Yes 2008-C-004 Generic Letter 89-13, Service "Inspection and maintenance. service water piping internal coatings will Water System Problems program should provide for repairof be performed one year following the initial Page 2

NRC Notification Number Source Document Original Commitment Modified Commitment Required Affecting Safety-Related defective protective coatings and coating application. Subsequent Equipment, dated 1/26/1 990 corroded service water system inspections will be performed at three to piping and components that could five year intervals.

adversely affect performance of At the time of the original response to GL their intended safety functions. " 89-13, no service water piping was The January 26, 1990 response internally coated. The ongoing service from Duke Power states: "No water piping refurbishment at Catawba internal protective coatings exist in has resulted in the coating of portions of service water piping." the service water system. Therefore, the initial response to GL 89-13 is no longer valid. In order to comply with the recommendation of GL 89-13, inspections of the currently applied coatings and future coating applications should be performed.

Catawba calculation CNC-1 167.01 0002, Justification of Plastocor Coating System for Safety-Related Nuclear Service Water (RN) Piping, states: "This evaluation assumes that the coating system will be inspected after the first year of service and then on three to five year intervals. "

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