ML20059E734
| ML20059E734 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/04/1994 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401120205 | |
| Download: ML20059E734 (4) | |
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Duke Power Company D L Ron Carauin Nut leur Ceneration [kpartment Lice hendent 4800 ConconiRoad
-(803)! Lib 3205 Othce
- York.SC29il3 (1103)&11-3426 Fca 1
DUKEPOWER January 4, 1994 U.
S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555
Subject:
Catawba Nuclear Station Dockets Nos. 50-413 and 50-414 Supplemental Response to Notice of Violation No. 50-413, 414/93-26-02 Attached is supplemental information concerning our Reply to Notice of Violation 50-413, 414/93-26-02 [ Example 1].
This supplement was committed to in Duke Power's letter to the NRC dated November 29, 1993.
Also note that this supplement revises the completion dates for the commitments under Example 2 of that response which were erroneously listed as 02/30/94.
Very truly yours, D. L.
Rehn i
\\ KEN:SUP#193.26 j
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S.
D.
Ebneter Regional Administrator, Region II R.
E.
Martin, ONRR R.
J.
Freudenberger Senior Resident Inspector 95dil20205 940104 C
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-6 DUKE POWER COMPANY-CATAWBA NUCLEAR STATION SUPPLEMENTAL RESPONSE TO VIOLATION 413,414/93-26-02
's Notice of Violation 10 CFR 50.73(a)(2)(1)(B) requires that the licensee submit to the NRC a Licensee Event Report for any operation or condition prohibited by the plant's Technical Specification (TS) within 30 days after the event has been discovered.
i 10 CFR 50.73(a)(2)(iv) required that the licensee submit to the NRC an LER for any event or condition that resulted in a manual or automat ic actuation of any engineered safety feature.
The opening of the Ice Condenser lower inlet doors during a containment pressurization event is considered an automatic actuaLion of an engineered safety feature.
Contrary t.o the above:
[ Example 1J On August 18, 1992, the licensee's f ailure to perform portions of the outside containment leakage testing at the required frequency required by Technical Specification 6.8.4.a.
was identified.
The licensee failed to submit a Licensee Event Report (.LER) for the violation of Technical Specification 6.8.4.a., Primary Coolant Sources Outside Containment, within 30 days of discovering the violation.
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[ Example 2)
On January 31, 1993, with Unit 2 (erroneously stated in Inspection Report as Unit 1) in Mode 4, a water hammer event occurred in the Residual Heat Removal System suction piping and caused a pipe break in a vent line connected in the RHT suction piping inside containment. The subsequent containment pressure increase caused the Ice Condenser lower inlet doors to open.
The licensee failed to submit an LER for this event within 30 days.
This is a Severity Level IV Violation.
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4 DUKE POWER COMPANY i
CATAWBA NUCLEAR STATION l
SUPPLEMENTAL RESPONSE TO VIOLATION 413,414/93-26-02
RESPONSE
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i 1.
Reason For Violation
[ Example 1]
l The Catawba Periodic Test (CPT) program was developed to e
comply with all TS surveillance requirements.
At the i
time the program was developed, surveillance frequencies were derived from TS Table 1.1 and 4.0.2, due to our ur:derstanding that. the 25% grace period applied to all TS surveillances, including those in the Administrative section.
When this question was originally brought to our attention, our evaluation concluded that a violation i
of technical specifications had not occurred since technical specification intervals as originally applied under our CPT program had not been exceeded.
After further review and discussions with the NRC, station i
management has determined that it may not have been appropriate to apply the 25% grace period to surveillance requirements to the Administrative section of TSs.
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[ Example 2]
i The cause for not reporting the ice condenser door opening as an ESF actuation is that policy guidance / management expectations were not well defined or understood.
Nuclear-System Directive (NSD) 202, 10 CFR 50.72 Reports, provides guidance for determining the reportability of station events or conditions.
Although
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section 202.7.2 of this directive defines ESF actuations j
and lists ESF systems, it does not give direction on actuation of a passive system. Procedure RP/0/B/5000/13, NRC Notification Requirements, provides guidance for reporting of plant conditions..4 of this j
procedure list ESF actuations for Catawba. Although this i
enclosure states that it is a guideline only and that it may not contain all ESF actuations, it does not list the I
ice condenser in the list of actuations.
In response to j
an event involving McGuire Nuclear Station ESF actuation reportability, Catawba Operations Training provided training on what constitutes an ESF actuation.
This training along with other Containment Building related training does not include momentary opening of the ice condenser doors.
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION SUPPLEMENTAL RESPONSE-TO VIOLATION 413,414/93-26-02 2.
Corrective Actions Taken And Results Achieved
[ Example 1]
LER 413/93-010, Missed Technical Specification
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Surveillance, was submitted to the NRC on 12/22/93.
[ Example 2]
The investigation of this event was originally documented
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in a Station Report.
This Station ' Report was later revised due to additional evidence that the ice condenser doors had opened and submitted to the NRC on 10/25/93 as LER 414/93-04, Ice Condenser Door Opened Due To Residual Heat Removal System Transient.
3.
Corrective Actions To Be Taken To Avoid Further Violations
[ Example 1]
The CPT program will be revised by 02/14/94 to perform leak rate testing at the test interval as listed in l
Section 6.8.4 of TS.
[ Assigned to OPS]
A review will be completed by 02/14/94 to ensure 4.0.2 is appropriately applied to other sections of TSs. [ Assigned to RGC]
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[ Example 2]
NSD 202 will be reviewed and revised as necessary by a
i 02/28/94. [ Assigned to REG)
Operations training will be revised to reflect NSD 202
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changes if necessary by 03/30/94. [ Assigned to OPT]
RP/0/A/5000/13 ESF actuation reporting requirements will i
be revised as necessary by 02/28/94. [ Assigned to RGC]
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Date Of Full Compliance Duke Power Company is now in full compliance.
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