ML20214E283
| ML20214E283 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/12/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-1275 NUDOCS 8705220025 | |
| Download: ML20214E283 (2) | |
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1 l DumE POWER COMPANY P.O. mOX 33189.
CHAmL(FITE, N.C. 28949 HAL B. TUCKER --
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Tas.arssows esos possement -
(704) 37J-4808
, wamman.
May 12, 1987 U. S. Nuclear Regulatory Cosmission Attention: Dociment Control Desk Washington,- D..C. 20555
Subject:
'Cosments on Draft NUREG-1275
Dear Sir:
.By letter dated April 8, 1987 Mr. C. J. Heltenes, Jr. requested comments on the draft NUREG-1275,." Operating Experience Feedback Report - New. Plants". We have 3'
reviewed this documents and offer the following specific comments:
(1) Figure 2, page 6,- The Low Power License'date for Catawba 1 is indicated as July 18,1984. This date is correct for the fuel load license; the -
-low power license was issued on December 6, 1984 and should therefore be noted as 5 months after OL issuance.
(2) Table 1, page 12 and Table D The precommercial critical hours for Catawba 1 should be 2266 hours0.0262 days <br />0.629 hours <br />0.00375 weeks <br />8.62213e-4 months <br /> rather than 2166. The resulting i
scrams /1000 critical hours would be 3.97.
(3) Section 3.4 Unplanned Losses of System l Safety Function-(LSSF) - This performance indicator was. reviewed for technical accuracy. A review of-the actual LER's revealed that a number of the events should not have~
been included because they involved the. loss'of a non-safety function (i.e., fire protection) or because the LER demonstrated that the safety function had not been lost. Reporting requirements contained in the Tschnical Specifications result in a obvious tendency for a licenses to-over-report events. The problem'is then compounded by the NRC's review of'the LER's.- Many of the events listed under LSSF were not reported under 10 CFR 50.73(a)(2)(v) but were apparently recat.egorized when reviewed-by the NRC.
(4) Section 4.3.2.1 - Catawba 1 and 2-AIT The description of the Catawba Unit 2 Loss of Control Roca Test contains a number of inaccurate statements.
(a) In the first paragraph it is noted that "af ter another 31 minutes of i
unsuccessful attempts...'.' The '31 minutes should be changed to 3 minutes.- The event was terminated six minutes after the PORV's-d opened by tranwforring control back to the control room..
3 8705220025 870512 PDR ADOCK 05000413 f
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U. S.' Nucle r Regulttsry Co M acion May 12, 1987 Page TVo.
(b) 'Page 57, third paragraph - The last sentence notes that "no human engineering deficiency. review'(RED) was performed on the shutdown panels". As discussed in Duke's letter of December-12, 1986 to J.
M. Taylor, NRC, the subject modification was reviewed in accordance with the applicable design procedure. Rather the acknowledged' oversight was in failing to revise other design documents to reflect needed scale changes and panel labeling.
(c) Page 57, fourth paragraph - When listing other contributing factors,
" lack of termination test criteria" is included.- In the December 12, 1986 response, Duke pointed out that the test procedure did contain termination criteria.
The NRC would apparently have preferred more explicit criteria than had been included. However, as Duke pointed out, there is no regulatory requirement for such.
The above comments were previously conveyed to Dr. Patrick O'Reilly by telephone.
Very truly yours, p(
Hal B. Tucker ROS/29/sbn Attachment 4
xc:
Dr. Patrick O'Reilly U. S. Nuclear Reguintory Commission Washington, D. C.
20555 f
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