ML092010132

Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01 (10CFR50.54f)

ML092010132
Person / Time
Site:	Catawba
Issue date:	07/15/2009
From:	Morris J R Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-08-001, TAC MD7844
Download: ML092010132 (6)

Text

SDuke JAMES R. MORRIS Energy Vice President Duke Energy Corporation Catawba Nuclear Station 4800Concord Road.York, SC 29745 July 15, 2009 803-701-4251 803-702-3221 fax U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike, Rockville, MD 20852

Subject:

Duke Energy Carolinas, LLC (Duke)Catawba Nuclear Station -Unit 2 Nine-Month Supplemental (Post-Outage)

Response to NRC Generic Letter 2008-01 (10CFR50.54f)

References:

1. NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008.2. Letter from Duke Energy Carolinas, LLC to the NRC, Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", Three-Month Response, dated May 8, 2008 3. Letter from Duke Energy Carolinas, LLC to the NRC, Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", Nine-Month Response, dated October 13, 2008 4. Letter from NRC to Duke Energy Carolinas, LLC, Generic Letter 2008-01,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", Proposed Alternative Course of Action, Catawba Nuclear Station, Unit. 2 (TAC No. MD7844), dated September 25, 2008 The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 1)to request that each licensee evaluate the licensing basis, design, testing, and corrective actions for the emergency core cooling (ECCS), decay heat removal (DHR), and containment spray systems to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.

As requested in Reference 4, please find attached Duke's supplemental response to the nine month response letter (Reference 3). This supplemental response is being submitted within 90 days of startup from the outage in which the deferred actions were completed.

GL response activities that remain to be accomplished, such as the long-term items identified in Reference 4, are considered to be confirmatory.

In summary, Duke has concluded that the subject systems at Catawba Nuclear Station -Unit 2 are operable and that Catawba Nuclear Station -Unit 2 is currently in compliance with the licensing basis documentation and applicable regulations, including 10 CFR 50 Appendix B, Criteria Ill, V, X1, XVI, and XVII, with respect to the concerns outlined in GL 2008-01 regarding managing gas accumulation in these systems/functions.

www. duke-energy.

corn U.S. Nuclear Regulatory Commission July 15, 2009 Page 2 There are no new commitments contained in this supplemental response.Please contact Phil Barrett at (803) 701-4138 if additional questions arise.Sincerely, Jmres R. Morris, Vice President Catawba Nuclear Site Attachment U.S. Nuclear Regulatory Commission July 15, 2009 Page 3 xc: w/attachment Mr. Luis Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303-8931 Andy Hutto NRC Senior Resident Inspector Catawba Nuclear Station J. H. Thompson, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 8 G9A Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission July 15, 2009 Page 4 James R. Morris affirms that he is the person who subscribed has name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.,.

James'. Morris, Vice President, Catawba Nuclear Station Subscribed and sworn to me: 7 -1 e- 0-o vq Date Notary Public My commission expires: 7- /0- .z) 12-Date% SEAL,,,

Attachment to Letter dated July 15, 2009 Nine-Month Supplemental (Post-Outage)

Response to NRC Generic Letter 2008-01 This attachment provides the Nine-Month Supplemental (Post Outage) Response to Generic Letter 2008-01 for actions that were deferred until the next refueling outage as requested by the NRC in Reference 4 of the cover letter.The following information is provided in this attachment: " A description of the results of evaluations that were performed pursuant to Generic Letter 2008-01 on the previously incomplete activities, such as system piping walkdowns, at Catawba Unit 2 (see section A of this attachment).

• A description of any additional corrective actions determined necessary to assure system operability and compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license with respect to the subject systems, including a schedule and a basis for that schedule (see Section B1 of this Attachment)." Summary of any changes or updates to previous corrective actions, including any schedule change and the basis for the change. (See Section B2 of this Attachment).

• The original conclusions documented in the 9 month response with respect to the licensing basis evaluation, testing evaluations, and corrective action evaluations have not changed.

Attachment to Letter dated July 15, 2009 Nine-Month Supplemental (Post-Outage)

Response to NRC Generic Letter 2008-01 A. EVALUATION RESULTS 1. Design Basis Documents No changes were required to Design Basis Documents.

2. Confirmatory Walkdowns As identified in Duke's 3 month response to the GL, field verification of certain portions of the affected systems on Catawba Unit 2 could not be completed due to piping inaccessibility.

Duke committed to complete this verification during the next available refueling outage after the October 14, 2008 GL 9 month response date.The scope of piping to be field verified was defined in Duke's 3 month GL response as the following:

1. Safety Injection system Cold and Hot Leg injection piping inside containment

2. Chemical and Volume Control system Cold Leg injection piping inside containment

3. Residual Heat Removal system Cold and Hot Leg injection piping inside containment

4. Residual Heat Removal suction piping from the Hot Leg(s) inside containment Walk downs and surveys for that piping was completed as required.

Configuration of vent valves with plant drawings and the adequacy of vents were verified.

No evidence of waterhammer was observed during field walkdowns.

Pipe slope that was identified during field walkdowns was evaluated to be of no impact to system operability.

System venting procedures performed prior to systems being required operable verified systems to be sufficiently full.3. Vent Valves No new vent valves are required as a result of the Catawba Unit 2 containment walk down.4. Procedures Procedures were reviewed as part of the 9 month GL response.

No additional procedures or revisions were required based on field walkdowns.

B. DESCRIPTION OF NECESSARY ADDITIONAL CORRECTIVE ACTIONS 1. Additional Corrective Actions There are no additional corrective actions that are required.2. Corrective Action Updates There are no changes to the corrective actions provided in the 9 month GL response.Conclusion Duke has evaluated the previously unevaluated portions of the applicable systems at Catawba Unit 2 that perform the functions described in the GL and has concluded that these systems are operable.