ML20011E836
| ML20011E836 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 02/14/1990 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9002220562 | |
| Download: ML20011E836 (3) | |
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\\ke Prnident Charlotte, N C 2k242 Nuclear Production (701)373 4531 DUKEPOWER February 14, 1990 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D.C.
20555
Subject:
Catawba Nuclear Station Docket Nos. 50-413 and 50-414 NRC Inspection Report Nos. 50-413, 414/89-27 Gentlemen:
Mr. Caudie A. Julian's letter dated October 26, 1989 transmitted an Inspection Report for the Catawba Nuclear Station which identified two weaknesses associated with the Inservice Testing program. The weaknesses pertained to not fully complying with Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs. Specifically, the weaknesses were (1) failure to update'the IST implementing procedures as necessary.to reflect all positions of Generic Letter 89-04; and (2) absence of a program for regular testing of certain relief valves. The Inspection Report also discussed an oral commitment.
made at the inspection exit interview, that Catawba would review the guidelines-of the generic letter and i:nplement any changes needed within six months. Mr. Julian's letter requested that I inform his office if the Station's understanding of the commitment differs from the-repott statements.
The Station has completed a preliminary review of its IST program against the guidance of Generic Letter 89-04 and commits to modifying three specific areas that Duke considers deficient. T'ie need for any other improvements will be
- determined by the Station on a case-by-case basis. The areas to be modified are itemized below. The target dates for full implementation of the IST revisions are also listed.
- Item 1 (Full Flow Testing of Check Valves)-and Item 2 (Alternate to Full Flow Testing of Check Valves) in Attachment 1 to Generic Letter 89-04 will be incorporated into Catawba's IST program by the end of Unit 2 E003 outage. The U2EOC3 outage is currently projected to end on August 16, 1990.
- Item 3 (Back Flow Testing of Check Valves) in Attachment 1 to the Generic Letter will be incorporated into the IST program. A review of all check valves to determine the applicability of backflow testing will be completed by January 1, 1991. Procedures will be dveloped and implemented by the applicable U1E005 and U2EOC4 outages.
- Item 5 (limiting Values of Full-Stroke Times for Power Operated Valve.s) in Attachment 1 to the Generic Letter will be incorporated into the IST program by January 1, 1991.
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U. S. Nuclect R:guletory Commic2 ion February 14, 1990
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page Two I do not believe additional changes to the IST program or the impicmenting procedures beyond those described'above are justified at this time. However, as the Station approaches the end of the first 10 year IST period, further i
consideration will be given to expanding the scope of the IST program as discussed in the Generic Letter.
The NRC' reviewed and approved the Catawba Unit 1 and 2 IST program in.the 1987 SER and TER prepared by EG&G Idaho. This review was performed using current acceptance criteria including Standard Review plan Section 3.9.6 (See TER pages 1-2). Generic Letter 89-04 further indicates that the technical positions in Attachment 1 to the Generic Letter were used by the Staff in itu review of programs for which SERs have been issued. By letter dated July 21, 1989, the NRC notifled Duke that Catawba Units 1 and 2 should have been listed in Table 2 of the Generic Letter (plants with approved IST programs for which no response to the' Generic Letter was needed).
Generic. Letter 89-04 is unclear a9 to whether plants with approved programs are expected to review and modify implementing procedures. The Statien's s
implementing procedutns were developed consistent with its IST progra*a as previously approved by the NRC nnd I believe that the proccdures are effective'. To the extent the NRC believes a requiremunt to modify procedures exists for plants wit.h approved-programs, I believe this is a new position and should have been treated as a backfit under 10 CFR 50.109. In the absence of a backfitting analysis complying with Section 50.109 that demonstrates that further procedural changes are juatified, I conclude that the commitments doscribed above are sufficient.
Very Truly Yours.
M' /$ 4 1al B. Tuckce.
01119002/rgm cc:
Mr. S. D..Ebneter Regional Administrator, Region 17 U
S. Nuclear Regulatory Commissica 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. C. A. Julian, Chief Engineering Branch
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4 Dr. K. N. Jabbour, Project Manager-Office.of Nuclear Reactor Regulation 4-U.
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