ML20207P428
| ML20207P428 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/13/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| NUDOCS 8701160125 | |
| Download: ML20207P428 (3) | |
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DUKE POWER GOMPANY P.O. box 33180 CHARLOTTE, N.C. 28942
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January 13, 1987 U.S. Nuclear Regulatory Commission
. Document Control Desk Washington, D.C.
20555
Subject:
Catawba Nuclear. Station.
Dockst Nos. 50-413, 50-414 1
Reference:
RII:EHG NRC/0IE Inspection Report 50-413/86-46, 50-414/86-49 '
Gentlemen:
Pursuant to 10CFR2.201, please find attached a response to the violation which was identified in the above referenced Inspection Report. Duke Power Company does not consider any information contained in this report to be proprietary.
Very truly yours, D'
W Hal B. Tucker JSW/94/jgm
. Attachment rc:
Dr. J. Nelson Grace NRC Resident Inspector Regional Administrator Catawba Nuclear Station U.S. Nuclear Regulatory Commission Region II 101 Marietta Street NW Suite 2900 Atlanta, Georgia 30323
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8701160125 870113 0
PDR ADOCK 05000413 0
DUKE POWER COMPANY CATAWBA NUCLEAR STATION RESPONSE TO VIOLATION IN INSPECTION REPORT.
50-413/86-46 AND'50-414/86-49 Violation 50-413/86-46, Severity Level V (Supplement 1):
10 CFR 50.59 states that the licensee may conduct tests not described in the safety analysis ' report, without prior Commission approval, unless the proposed test involves a change in the technical specifications incorporated in the license or an unreviewed safety question. It also states that the licensee shall furnish to the NRC annually or at such shorter intervals as may be specified in the
' license, a report containing'a brief description of such tests including a summary of the safety evaluation of each.
Contrary to the above, although at least eight tests not described in the safety analysis report were performed in 1985, neither the licensee's 1985 annual report required by 10 CFR 50.59, dated July 1,1986, nor other correspondence to the NRC included a brief description of the tests including a summary of-the safety evaluation of each. This violation applies to Unit 1 only.
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RESPONSE
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1.
Admission or-denial of the alleged violation:
Duke Power admits the violation as clarified below.
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2.
Reason for violation:
i The violation resulted because of a lack of administrative procedures to ensure the inclusion of the two identified procedures (TT/1/B/9100/10 and TT/1/A/6100/03) in the annual 10 CFR 50.59 report. This led to an oversight which resulted in the exclusion of procedures covered by 10 CFR 50.59.
The admission of this violation is based on the fact that the safety evaluation of the two procedures indicated these should have been reported under 10 CFR 50.59.
Subsequent reevaluation has indicated there is general reference to these tests in the Catawba FSAR as shown below. However, the admission of the violation does r.ot apply to the other six procedures identified in Paragraph 5 of Inspection Report Nos. 50-413/86-46 and 50-414/86-49.
It is Duke's opinion that the context of these procedures is adequately addressed in the Catawba FSAR. Therefore this does not create a situation where a test or experiment not described in the FSAR is involved.
While these procedures are not specifically listed in the Catawba FSAR, it is Duke's opinion that the general description of station testing activities contained in the FSAR adequately cover these procedures. Our application of the regulation has been made through a technical evaluation of the test procedure based upon~two key considerations
- 1) The test does not involve an abnormal mode of operation and 2) the test does not impact the safety of plant operations. We feel this is consistent with the available NRC guidance on 10 CFR 50.59 contained in the Inspection and Enforcement Manual (rart 9800 CFR Discussions, 1/1/84) which states that it is not necessary for a test to be delineated in the FSAR as long as an abnormal mode of operation is not involved.
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. Listed below are the procedures in question with appropriate reference to.
applicable sections of the Catawba FSAR.
It is Duke's opinion these sections
. generally describe the context of these procedures as addressed in 10 CFR 50.59.
Temporary Test-Procedure Title FSAR Section TT/1/A/1200/15A Mechanical Penetration Bellows 6.2.4 and Technical Specification 4.6.1.2 TT/1/B/9100/10 Condenser Sulfur Hexafluoride 10.4.1.4 Test Injection TT/1/A/1250/04A Auxiliary Feedwater Automatic 10.4.9.4 Start Temperature Test TT/0/A/9100/07 Leak Test of 1RF 356 and 2RF 356 9.4.1.4 and 9.5.1.4 TT/1/A/9100/05 Operability of Diesel Engine 9.5.6.4 Stop-Run Valve TT/1/A/9100/09 Component Cooling ESF Flow Balance 9.2.2.2 TT/1/A/6100/03 Decreasing NC Pressure for NCP 9.3.4.4 & Technical Specification 3.4.6.2 TT/1/A/9100/16 VA Rebalance Flow Monitoring 9.4.3.4 & Technical-
-Specification 4.7.7 j
(3) The corrective steps which have been taken and the results achieved:
No immediate corrective actions were deemed necessary. Even though the violation is admitted for two procedures it is not felt that the prescribed tests impacted the safety of plant operations.
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(4)
Corrective steps which will be taken to avoid further violations:
Administrative procedures will be developed and implemented to ensure inclusion of applicable procedures in the annual 10 CFR 50.59 report.
(5) Date of full compliance:
The identified improvements will be incorporated into the upcoming 1986 calendar year 10 CFR 50.59 report.