ML20114D635
| ML20114D635 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/02/1992 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9209090216 | |
| Download: ML20114D635 (7) | |
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f l{1 h ouncInowen September 2,1992 U.S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D.C. 20555
Subject:
Catawba Nuclear Station Docket Nos. 50 413 and 50-414 i
Request For Commitment Date Extensions A self-initiated audit of violation response commitments was conducted by Catawba Nuclear Station Regulatory Compliance.
This audit identified four (4) violation response commitments which have not been fully implemented within the committed due date. Fui1her investigation determined the current status of the these commitments and the reasons for exceeding the committed due dates. Please find the irsuits of this investigation and the requests for extension on Attachment A.
In addition to these extension requests, please find justification for relaxation of the two (2) year safety related procedure tuview as committed in our Response to Violation 50-413/414,90-32-01 on Attachment B.
Very intly yours, k N J.L ( R
- M M.S. Tuckman Attachments 9209090216 920902 gDR ADOCK 05000413 f/fT I
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CATAWilA NUCLEAR STATION 50 413/414, 90 32-01 (CNS #7721)
Mr. Tuckman's letter, dated February 28,1991 (Reply to a Notice of Violation, last page),
stated Station Directive 4.2.1 will be revised to ensure all safety related Station Directives and those pans of Section manuals which address safety-related functions require a maximum review period of two (2) years (Non-safety related documents requires maximurn review period of five (5) years).
This revision to Station Directives 4.2.1 was approved Febntary 28, 1991. Ilowever, due to changes to ANSI 3.2 1988, a change was approved by the NRC in Amendment 14 to the Duke Power Company's Topical Raport, and subsequently the Duke Power Cornpany Administmtive Policy Manual Section 4.2, which allows frequency detenninations for periodic procedure reviews, not to exceed a six (6) year firquency. This change also allows individual sections to make their own decision regarding a need for review of non-safety related procedures.The frequency detenninations will be based on factors such as ty;m/ complexity of the activity involved, operational inaturity of the plant, activity imponance, current pmcedure condition, and pmcedure program effectiveness.
As a result of these changes, Catawba Nuclear Station Directive 4.2.1 was revised to reflect these new requirements for procedure reviews and approved on August 31,1992.
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i CATAWilA NUCLEAR STATION 50-413/414, 90-03-01 (CNS #7036 AND #7038)
Mr. Tucker's letter, date March 30,1990 (Reply to a Notice of Violation, page 6 and 7) stated:
l Design Engineering personnel will develop a design basis document (DBD) for the VA system. The DBD to the VA system will be evaluated by Design Engineering to detennine whether further potential foreign matter inputs to the VA system should be addressed. Following completion of this work, appropriate station procedures, FS AR and Technical Specincation revisions will be made.
Design Engineering will initiate a thorough and systematic review of ventilation system requirements and compare them against nominal operating data to ensure consistency with the FSAR and Technical Specification parameters.
Current Status:
The original DBD development schedule (March 30, 1990) for the VA system was December 31,1991. The Control Room Ventilation system (VC/YC) DBD was scheduled for completion December 31, 1992.
Ilowever due to priority given for development of the VC/YC system DBD first, the completion of the VA system DBD has been delayed. The thorough and systematic review of ventilation system requirements and the comparative against normal operating data was initiated, but not completed due to the delay of the development of the VA system DBD.
The immediate corrective actions which were implemented assures continued compliance with l
our current Technical Specincations,therefore we are requesting an extension for completion of this commitment until April 1,1993.
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CATAWilA NUCLEAR STATION 50-413/414, 90-201-A3 (CNS #8050)
Mr. Tuckman's letter, dated August 22,1991 (Reply to Notice of Subject Violation, page 6),
stated the status of the IAE pmcedure upgrade for procedures classified as Priority 2 was 478 out of 661 upgraded. The conunitment for the upgmde was to be completed by August 1,1992.
Current Status:
At the present time, Insimment and Electrical (IAE) has developed or upgraded 528 procedures classified as Priority 2. There are 75 Priority 2 procedures yet to complete. Of those,4? re either in the process of being rewritten or are awaiting final field validation.
Factors such as a major computer system changeover, numerous procedure changes required due to outage related work, and a new procedure validation process has caused exceeding the committed due date. The new validation process now requires the procedure user, as opposed to the writer, to perfonn the validations. This often requires waiting for an outage or scheduled calibration to perfonn the validation, however the quality of the validation is much better and the user gains more ownership of tbn procedure. We therefore request an extension for completion of thir commitment until April 31,1993.
CATAWDA NUCLEAR STATION 50 413,414/90-201-F (CNS #8062)
Mr. M.S. Tuckman's letter dated August 22,1991 (Reply to Subject Violation, page 17) stated complete battery replacement of all emergency battery pack lights, including a 100 percent capacity retest, was in progress and would be completed by December 1,1991.
Current Status:
Battery change-out and 100% capacity testing is complete for all of the 288 cmcrgency battery lights except battery light # 78. Battery light #78, a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> capacity light, has not been seplaced and tested due to questions about which type of light should be installed. It has been verified that the a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> light should be installed for light #78.
Due to the additional work required because of funher evaluation and detennination of the adequacy of these 1:ahts, the committed due date for this commitment was exceeded.We request an extension fer com sletion of the replacement and testing for battery light #78 until October 1,1992.
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