CNS-15-031, Commitment Change Evaluation Report for 2014: Difference between revisions

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{{#Wiki_filter:( ENERGY.Kelvin Henderson Vice President Catawba Nuclear Station Duke Energy CN01VP 1 4800 Concord Road York, SC 29745 o:803.701.4251 f: 803.701.3221 CNS-15-031 March 24, 2015 U.S. Nuclear Regulatory Commission Attention:
{{#Wiki_filter:Kelvin Henderson
Document Control Desk Washington, DC 20555-0001
( ENERGY.
Vice President Catawba Nuclear Station Duke Energy CN01VP 1 4800 Concord Road York, SC 29745 o:803.701.4251 f: 803.701.3221 CNS-15-031 March 24, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001


==Subject:==
==Subject:==
Duke Energy Carolinas, LLC (Duke)Catawba Nuclear Station, Units 1 and 2 Docket Nos.: 50-413 and 50-414 Commitment Change Evaluation Report for 2014 Attached is a summary of commitment change evaluations completed during the 2014 calendar year for Catawba Nuclear Station. These evaluations and subsequent commitment changes were made based on the guidance defined in NEI 99-04, Guidelines for Managing NRC Commitments, and have no adverse effect on compliance with NRC rules and regulations.
Duke Energy Carolinas, LLC (Duke)
Catawba Nuclear Station, Units 1 and 2 Docket Nos.: 50-413 and 50-414 Commitment Change Evaluation Report for 2014 Attached is a summary of commitment change evaluations completed during the 2014 calendar year for Catawba Nuclear Station. These evaluations and subsequent commitment changes were made based on the guidance defined in NEI 99-04, Guidelines for Managing NRC Commitments, and have no adverse effect on compliance with NRC rules and regulations.
Questions regarding this report should be directed to Cecil Fletcher, Regulatory Affairs Manager, at 803-701-3622.
Questions regarding this report should be directed to Cecil Fletcher, Regulatory Affairs Manager, at 803-701-3622.
Sincerely, elvin Henderson Vice President, Catawba Nuclear Station Attachment F)www.duke-energy.com a U. S. Nuclear Regulatory Commission March 24, 2015 Page 2 xc: V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G. Edward Miller NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-G9A 11555 Rockville Pike Rockville, MD 20852-2738 G. A. Hutto Senior Resident Inspector CN01NC Catawba Nuclear Station Annual Commitment Change Summary Report for 2014 Docket Nos. 50-413 and 50-414 NRC Notification Number Source Document Original Commitment Modified Commitment Required Yes 2014-C-001 NRC Generic Letter Response (November 27,1997) and Commitment Change #2002-C-005 The intake and pit inspections will be performed on a three year frequency commencing from the last RN intake and Train B pump pit inspection conducted on 4/24/02.Defer the inspection of Nuclear Service Water (RN) Pump Pit A to no later than 11/20/2014.
Sincerely, elvin Henderson Vice President, Catawba Nuclear Station Attachment F) www.duke-energy.com
This is a one-time deferral.The inspection of the A train RN Pump Pit is due 07/07/2014.
 
This inspection was scheduled for March of 2014 but could not be performed due to issues with providing adequate isolation of the pit. In order to minimize safety system unavailability, this inspection will be performed during scheduled valve maintenance which will require A train of RN to be removed from service.The most recent A train pit inspection was performed during refueling outage 1EOC17, October, 2010. No structural issues were identified with the condition of the pit and associated structures, as documented in the work order completion comments.The A and B train pits are operated in the same manner. Therefore, the condition of the B train pit is considered to be indicative of the condition of the A pit.The latest inspection of the B pit was performed in February, 2012. The results of that inspection concluded that no structural issues were present with respect to concrete, structural steel or the intake screens. As noted in the Corrective Action Program, the pit was in very good condition (C-12-1403).
a U. S. Nuclear Regulatory Commission March 24, 2015 Page 2 xc:
This indicates the A pit is also in a similar Page 1 NRC Notification Number Source Document Original Commitment Modified Commitment Required condition.
V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G. Edward Miller NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-G9A 11555 Rockville Pike Rockville, MD 20852-2738 G. A. Hutto Senior Resident Inspector CN01NC
 
Catawba Nuclear Station Annual Commitment Change Summary Report for 2014 Docket Nos. 50-413 and 50-414 NRC Notification   Number       Source Document                 Original Commitment                     Modified Commitment Required Yes     2014-C-001 NRC Generic Letter Response The intake and pit inspections will  Defer the inspection of Nuclear Service (November 27,1997) and       be performed on a three year       Water (RN) Pump Pit A to no later than Commitment Change #2002-C-  frequency commencing from the        11/20/2014. This is a one-time deferral.
005                          last RN intake and Train B pump pit inspection conducted on 4/24/02. The inspection of the A train RN Pump Pit is due 07/07/2014. This inspection was scheduled for March of 2014 but could not be performed due to issues with providing adequate isolation of the pit. In order to minimize safety system unavailability, this inspection will be performed during scheduled valve maintenance which will require A train of RN to be removed from service.
The most recent A train pit inspection was performed during refueling outage 1EOC17, October, 2010. No structural issues were identified with the condition of the pit and associated structures, as documented in the work order completion comments.
The A and B train pits are operated in the same manner. Therefore, the condition of the B train pit is considered to be indicative of the condition of the A pit.
The latest inspection of the B pit was performed in February, 2012. The results of that inspection concluded that no structural issues were present with respect to concrete, structural steel or the intake screens. As noted in the Corrective Action Program, the pit was in very good condition (C-12-1403). This indicates the A pit is also in a similar Page 1
 
NRC Notification   Number           Source Document                 Original Commitment                     Modified Commitment Required condition.
Therefore, deferring the next committed A train pump pit inspection by four months (11/30/14) to minimize safety system unavailability will not result in any potential challenge of the A train of the RN system from being capable of meeting its design basis requirements.
Therefore, deferring the next committed A train pump pit inspection by four months (11/30/14) to minimize safety system unavailability will not result in any potential challenge of the A train of the RN system from being capable of meeting its design basis requirements.
This deferral is only applicable to this single occurrence.
This deferral is only applicable to this single occurrence.
Yes 2014-C-002 Letter from Thomas P. Harrall, Monitor the status of the TSTF Complete the evaluation of TSTF-523 and Duke Energy, to NRC, dated effort to provide revisions to submit a letter to the NRC providing a October 13, 2008, "Generic NUREG-1431 Technical schedule for submittal of a License Letter 2008-01, 9-Month Specifications and their associated Amendment Request by October 15, Response" Bases in regard to the periodic 2014.venting surveillance.
Yes     2014-C-002 Letter from Thomas P. Harrall, Monitor the status of the TSTF       Complete the evaluation of TSTF-523 and Duke Energy, to NRC, dated     effort to provide revisions to       submit a letter to the NRC providing a October 13, 2008, "Generic     NUREG-1431 Technical                 schedule for submittal of a License Letter 2008-01, 9-Month         Specifications and their associated Amendment Request by October 15, Response"                       Bases in regard to the periodic     2014.
Catawba will evaluate the resolution of TS issues Duke Energy's evaluation of TSTF-523 is with respect to the changes continuing.
venting surveillance. Catawba will evaluate the resolution of TS issues Duke Energy's evaluation of TSTF-523 is with respect to the changes           continuing. Additional time is needed to contained in the TSTF traveler, and complete the evaluation, and to prepare, submit a license amendment           process, and submit an LAR. Therefore, request based on this evaluation     Duke Energy is revising the commitments within 180 days following NRC         to complete the evaluation and provide a approval of the TSTF.               schedule for submittal of an LAR by October 15, 2014. Duke Energy believes that the actions completed in response to Generic Letter 2008-01 provide confidence that safety will be preserved during the extended evaluation period that the revised regulatory commitments afford.
Additional time is needed to contained in the TSTF traveler, and complete the evaluation, and to prepare, submit a license amendment process, and submit an LAR. Therefore, request based on this evaluation Duke Energy is revising the commitments within 180 days following NRC to complete the evaluation and provide a approval of the TSTF. schedule for submittal of an LAR by October 15, 2014. Duke Energy believes that the actions completed in response to Generic Letter 2008-01 provide confidence that safety will be preserved during the extended evaluation period that the revised regulatory commitments afford.Yes 2014-C-003 Letter from Bill Pitesa, Duke Implementation Milestone 8 of the Revise Implementation Milestone 8 Energy, to NRC dated April 15, Cyber Security Plan is to Complete completion date of June 30, 2015, to 2011, "License Amendment Operational and Management December 31, 2017.Request for Cyber Security controls as provided in NEI 08-09, Plan" Rev. 6, Appendix E, by June 30, The scope of the Critical Digital Asset 2015. (CDA) assessment activities was substantially underestimated by Duke Page 2 NRC Notification Number Source Document Original Commitment Modified Commitment Required Energy. The Milestone 8 completion date was established prior to any significant work being performed on program implementation; therefore, the scope of the assessment activities was not fully appreciated.
Yes     2014-C-003 Letter from Bill Pitesa, Duke   Implementation Milestone 8 of the   Revise Implementation Milestone 8 Energy, to NRC dated April 15, Cyber Security Plan is to Complete   completion date of June 30, 2015, to 2011, "License Amendment       Operational and Management           December 31, 2017.
The scope of the CDA assessment activities was also substantially underestimated by the industry in general, as evidenced by the need for additional industry guidance.Therefore, Duke Energy (DEC) is revising the commitment for Milestone 8 completion date of June 30, 2015, to December 31, 2017. Milestone 8 pertains to the date that complete operational and management controls, as provided in Nuclear Energy Institute 08-09, Revision 6, Appendix E, will be achieved.
Request for Cyber Security     controls as provided in NEI 08-09, Plan"                           Rev. 6, Appendix E, by June 30,     The scope of the Critical Digital Asset 2015.                                 (CDA) assessment activities was substantially underestimated by Duke Page 2
Based on the status of the cyber security program, Duke Energy believes that safety will be preserved during the approval period that the revised regulatory commitments afford.Page 3}}
 
NRC Notification Number Source Document       Original Commitment           Modified Commitment Required Energy. The Milestone 8 completion date was established prior to any significant work being performed on program implementation; therefore, the scope of the assessment activities was not fully appreciated. The scope of the CDA assessment activities was also substantially underestimated by the industry in general, as evidenced by the need for additional industry guidance.
Therefore, Duke Energy (DEC) is revising the commitment for Milestone 8 completion date of June 30, 2015, to December 31, 2017. Milestone 8 pertains to the date that complete operational and management controls, as provided in Nuclear Energy Institute 08-09, Revision 6, Appendix E, will be achieved. Based on the status of the cyber security program, Duke Energy believes that safety will be preserved during the approval period that the revised regulatory commitments afford.
Page 3}}

Latest revision as of 14:53, 31 October 2019

Commitment Change Evaluation Report for 2014
ML15085A050
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 03/24/2015
From: Henderson K
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-15-031
Download: ML15085A050 (5)
v • d • e


Text

Kelvin Henderson

( ENERGY.

Vice President Catawba Nuclear Station Duke Energy CN01VP 1 4800 Concord Road York, SC 29745 o:803.701.4251 f: 803.701.3221 CNS-15-031 March 24, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke)

Catawba Nuclear Station, Units 1 and 2 Docket Nos.: 50-413 and 50-414 Commitment Change Evaluation Report for 2014 Attached is a summary of commitment change evaluations completed during the 2014 calendar year for Catawba Nuclear Station. These evaluations and subsequent commitment changes were made based on the guidance defined in NEI 99-04, Guidelines for Managing NRC Commitments, and have no adverse effect on compliance with NRC rules and regulations.

Questions regarding this report should be directed to Cecil Fletcher, Regulatory Affairs Manager, at 803-701-3622.

Sincerely, elvin Henderson Vice President, Catawba Nuclear Station Attachment F) www.duke-energy.com

a U. S. Nuclear Regulatory Commission March 24, 2015 Page 2 xc:

V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G. Edward Miller NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-G9A 11555 Rockville Pike Rockville, MD 20852-2738 G. A. Hutto Senior Resident Inspector CN01NC

Catawba Nuclear Station Annual Commitment Change Summary Report for 2014 Docket Nos. 50-413 and 50-414 NRC Notification Number Source Document Original Commitment Modified Commitment Required Yes 2014-C-001 NRC Generic Letter Response The intake and pit inspections will Defer the inspection of Nuclear Service (November 27,1997) and be performed on a three year Water (RN) Pump Pit A to no later than Commitment Change #2002-C- frequency commencing from the 11/20/2014. This is a one-time deferral.

005 last RN intake and Train B pump pit inspection conducted on 4/24/02. The inspection of the A train RN Pump Pit is due 07/07/2014. This inspection was scheduled for March of 2014 but could not be performed due to issues with providing adequate isolation of the pit. In order to minimize safety system unavailability, this inspection will be performed during scheduled valve maintenance which will require A train of RN to be removed from service.

The most recent A train pit inspection was performed during refueling outage 1EOC17, October, 2010. No structural issues were identified with the condition of the pit and associated structures, as documented in the work order completion comments.

The A and B train pits are operated in the same manner. Therefore, the condition of the B train pit is considered to be indicative of the condition of the A pit.

The latest inspection of the B pit was performed in February, 2012. The results of that inspection concluded that no structural issues were present with respect to concrete, structural steel or the intake screens. As noted in the Corrective Action Program, the pit was in very good condition (C-12-1403). This indicates the A pit is also in a similar Page 1

NRC Notification Number Source Document Original Commitment Modified Commitment Required condition.

Therefore, deferring the next committed A train pump pit inspection by four months (11/30/14) to minimize safety system unavailability will not result in any potential challenge of the A train of the RN system from being capable of meeting its design basis requirements.

This deferral is only applicable to this single occurrence.

Yes 2014-C-002 Letter from Thomas P. Harrall, Monitor the status of the TSTF Complete the evaluation of TSTF-523 and Duke Energy, to NRC, dated effort to provide revisions to submit a letter to the NRC providing a October 13, 2008, "Generic NUREG-1431 Technical schedule for submittal of a License Letter 2008-01, 9-Month Specifications and their associated Amendment Request by October 15, Response" Bases in regard to the periodic 2014.

venting surveillance. Catawba will evaluate the resolution of TS issues Duke Energy's evaluation of TSTF-523 is with respect to the changes continuing. Additional time is needed to contained in the TSTF traveler, and complete the evaluation, and to prepare, submit a license amendment process, and submit an LAR. Therefore, request based on this evaluation Duke Energy is revising the commitments within 180 days following NRC to complete the evaluation and provide a approval of the TSTF. schedule for submittal of an LAR by October 15, 2014. Duke Energy believes that the actions completed in response to Generic Letter 2008-01 provide confidence that safety will be preserved during the extended evaluation period that the revised regulatory commitments afford.

Yes 2014-C-003 Letter from Bill Pitesa, Duke Implementation Milestone 8 of the Revise Implementation Milestone 8 Energy, to NRC dated April 15, Cyber Security Plan is to Complete completion date of June 30, 2015, to 2011, "License Amendment Operational and Management December 31, 2017.

Request for Cyber Security controls as provided in NEI 08-09, Plan" Rev. 6, Appendix E, by June 30, The scope of the Critical Digital Asset 2015. (CDA) assessment activities was substantially underestimated by Duke Page 2

NRC Notification Number Source Document Original Commitment Modified Commitment Required Energy. The Milestone 8 completion date was established prior to any significant work being performed on program implementation; therefore, the scope of the assessment activities was not fully appreciated. The scope of the CDA assessment activities was also substantially underestimated by the industry in general, as evidenced by the need for additional industry guidance.

Therefore, Duke Energy (DEC) is revising the commitment for Milestone 8 completion date of June 30, 2015, to December 31, 2017. Milestone 8 pertains to the date that complete operational and management controls, as provided in Nuclear Energy Institute 08-09, Revision 6, Appendix E, will be achieved. Based on the status of the cyber security program, Duke Energy believes that safety will be preserved during the approval period that the revised regulatory commitments afford.

Page 3

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