ML020090531: Difference between revisions

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| number = ML020090531
| number = ML020090531
| issue date = 01/09/2002
| issue date = 01/09/2002
| title = Response to Duke'S Comments on NRC Integrated Inspection Report 50-413/01-05, 50-414/01-05 Dated October 22, 2001
| title = Response to Dukes Comments on NRC Integrated Inspection Report 50-413/01-05, 50-414/01-05 Dated October 22, 2001
| author name = Mccree V
| author name = Mccree V
| author affiliation = NRC/RGN-II/DRP
| author affiliation = NRC/RGN-II/DRP
Line 20: Line 20:
Duke Energy Corporation
Duke Energy Corporation
ATTN: Mr. G. R. Peterson
ATTN: Mr. G. R. Peterson
        Site Vice President
Site Vice President  
        Catawba Nuclear Station
Catawba Nuclear Station
4800 Concord Road
4800 Concord Road
York, SC 29745
York, SC 29745
SUBJECT:       RESPONSE TO DUKES COMMENTS ON NRC INTEGRATED INSPECTION
SUBJECT:
                REPORT 50-413/01-05, 50-414/01-05 DATED OCTOBER 22, 2001
RESPONSE TO DUKES COMMENTS ON NRC INTEGRATED INSPECTION
REPORT 50-413/01-05, 50-414/01-05 DATED OCTOBER 22, 2001
Dear Mr. Peterson:
Dear Mr. Peterson:
Thank you for your response of December 4, 2001, which provided comments for consideration
Thank you for your response of December 4, 2001, which provided comments for consideration
Line 31: Line 32:
Corrective Actions Associated with the Unit 2 Refueling Water Storage Tank (FWST) Level
Corrective Actions Associated with the Unit 2 Refueling Water Storage Tank (FWST) Level
Channel Failures, and NCV 50-413, 414/01-05-03, Failure to Identify a Condition Adverse to
Channel Failures, and NCV 50-413, 414/01-05-03, Failure to Identify a Condition Adverse to
Quality that Rendered the A Chiller Inoperable.
Quality that Rendered the A Chiller Inoperable.
Concerning the first NCV, you took exception to the NRC conclusion that the FWST
Concerning the first NCV, you took exception to the NRC conclusion that the FWST
instrumentation channels were unreliable. Your response described the reliability of the FWST
instrumentation channels were unreliable. Your response described the reliability of the FWST
level system in terms of monitoring performed by your Maintenance Rule program as required
level system in terms of monitoring performed by your Maintenance Rule program as required
by 10CFR50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear
by 10CFR50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear
Plants. You stated the performance goals are established with limits of 99.8% system
Plants. You stated the performance goals are established with limits of 99.8% system
availability and 100% system reliability and that the Unit 2 FWST level system has always met
availability and 100% system reliability and that the Unit 2 FWST level system has always met
or exceeded these goals. A review of your maintenance rule program indicated that these limits
or exceeded these goals. A review of your maintenance rule program indicated that these limits
apply to the Refueling Water (FW) risk-significant systems, structures, and components (SSC),
apply to the Refueling Water (FW) risk-significant systems, structures, and components (SSC),
and not to the performance of individual FWST level channels, which is the focus of this
and not to the performance of individual FWST level channels, which is the focus of this
violation. Our review indicated that the performance of individual FWST level channels is
violation. Our review indicated that the performance of individual FWST level channels is
monitored under a different SSC and have different monitoring criteria.
monitored under a different SSC and have different monitoring criteria.
Your response quoted the following statement from Inspection Report 50-413/01-05, 50-
Your response quoted the following statement from Inspection Report 50-413/01-05, 50-
414/01-05, The failure to implement timely corrective actions for this degraded condition had a
414/01-05, The failure to implement timely corrective actions for this degraded condition had a
credible impact on plant safety in that reliable operation of FWST level channels 1 and 3 was
credible impact on plant safety in that reliable operation of FWST level channels 1 and 3 was
not assured from 1996 to 2001. The intent of this statement was to explain the impact of the
not assured from 1996 to 2001. The intent of this statement was to explain the impact of the
NCV on plant safety. Criterion XVI of 10 CFR 50, Appendix B, requires that measures shall be
NCV on plant safety. Criterion XVI of 10 CFR 50, Appendix B, requires that measures shall be
established to assure that conditions adverse to quality, such as failures, malfunctions and
established to assure that conditions adverse to quality, such as failures, malfunctions and
deficiencies are promptly identified and corrected. This requirement applies to all safety-related
deficiencies are promptly identified and corrected. This requirement applies to all safety-related
SSC which includes each individual FWST level channel. Based on the number of level
SSC which includes each individual FWST level channel. Based on the number of level
channel deficiencies since 1996, and the absence of a root cause determination until the Fall of
channel deficiencies since 1996, and the absence of a root cause determination until the Fall of
2001, the NRC concluded that your corrective actions were inadequate, and that the FWST
2001, the NRC concluded that your corrective actions were inadequate, and that the FWST
level channels were unreliable because quality could not be assured for each channel. This
level channels were unreliable because quality could not be assured for each channel. This
was considered to have had a credible impact on safety because the system configuration that
was considered to have had a credible impact on safety because the system configuration that
existed when two FWST level channels failed on July 23, 1998, remained unchanged until
existed when two FWST level channels failed on July 23, 1998, remained unchanged until
grounding modifications were completed in June 2001. During this time, the inspectors
grounding modifications were completed in June 2001. During this time, the inspectors


DEC                                               2
2
concluded that the FWST level channels were more vulnerable to lightning induced failures.
DEC
concluded that the FWST level channels were more vulnerable to lightning induced failures.
After further review of this issue, and consideration of your comments regarding FWST level
After further review of this issue, and consideration of your comments regarding FWST level
channel reliability, we concluded that the inspection report accurately describes your FWST
channel reliability, we concluded that the inspection report accurately describes your FWST
corrective actions and the impact on plant safety.
corrective actions and the impact on plant safety.
You also took exception to the list of Problem Investigation Process (PIP) reports listed in the
You also took exception to the list of Problem Investigation Process (PIP) reports listed in the
inspection report on pages 4 and 5, and stated that this list may provide the incorrect perception
inspection report on pages 4 and 5, and stated that this list may provide the incorrect perception
that all the events were instrument failures. With only a few exceptions, all the PIPs listed in
that all the events were instrument failures. With only a few exceptions, all the PIPs listed in
the report described actual degraded equipment conditions associated with the Unit 2 FWST
the report described actual degraded equipment conditions associated with the Unit 2 FWST
level channels that occurred between July 1996 and August 2000. The report did not intend to
level channels that occurred between July 1996 and August 2000. The report did not intend to
imply that all these documented events were actual instrument failures, unless identified as
imply that all these documented events were actual instrument failures, unless identified as
such in the PIP description column of the table.
such in the PIP description column of the table.
Regarding the second NCV, you commented that previously issued NRC Inspection Report 50-
Regarding the second NCV, you commented that previously issued NRC Inspection Report 50-
413/01-04, 50-414/01-04, dated July 23, 2001, documented a licensee identified violation for
413/01-04, 50-414/01-04, dated July 23, 2001, documented a licensee identified violation for
the same May 3, 2001, chiller event referenced in the second NCV. Your response contended
the same May 3, 2001, chiller event referenced in the second NCV. Your response contended
that this event, if significant enough to warrant multiple violations, should be credited as a
that this event, if significant enough to warrant multiple violations, should be credited as a
licensee identified finding as originally documented in the July 23, 2001, report. Our review
licensee identified finding as originally documented in the July 23, 2001, report. Our review
indicated that these NCVs identified two different performance deficiencies, both of which
indicated that these NCVs identified two different performance deficiencies, both of which
warranted an individual NCV. The first performance deficiency resulted in NCV 50-413,414/01-
warranted an individual NCV. The first performance deficiency resulted in NCV 50-413,414/01-
04-02 and involved your failure to develop appropriate written procedures or documented
04-02 and involved your failure to develop appropriate written procedures or documented
instructions for maintenance activities on the A YC chiller. The second NCV identified a
instructions for maintenance activities on the A YC chiller. The second NCV identified a
performance deficiency involving the failure of licensed operators to perform an adequate
performance deficiency involving the failure of licensed operators to perform an adequate
operability review of the A YC chiller during the May 3, 2001 event. This NCV was identified
operability review of the A YC chiller during the May 3, 2001 event. This NCV was identified
through the baseline inspection program during the review and closure of Licensee Event
through the baseline inspection program during the review and closure of Licensee Event
Report (LER) 50-413/2001-002. NRC Inspection Manual Chapter 0610*, Power Reactor
Report (LER) 50-413/2001-002. NRC Inspection Manual Chapter 0610*, Power Reactor
Inspection Reports, requires that when closing LERs, the NRC should identify any more-than-
Inspection Reports, requires that when closing LERs, the NRC should identify any more-than-
minor findings or violations of regulatory requirements, and document these accordingly when
minor findings or violations of regulatory requirements, and document these accordingly when
closing the LER.
closing the LER.  
After further review of this issue, and consideration of your comments, we agree that this
After further review of this issue, and consideration of your comments, we agree that this
violation should also have been credited as a licensee-identified NCV. Consequently, we plan
violation should also have been credited as a licensee-identified NCV. Consequently, we plan
to update the Plant Issues Matrix and the Reactor Oversight Process web page to reflect this
to update the Plant Issues Matrix and the Reactor Oversight Process web page to reflect this
NCV as being licensee identified.
NCV as being licensee identified.  
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web site at
(ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
                                              Sincerely,
Sincerely,
                                              /RA/
/RA/
                                              Victor M. McCree, Acting Director
Victor M. McCree, Acting Director
                                              Division of Reactor Projects
Division of Reactor Projects
Docket Nos.: 50-413, 50-414
Docket Nos.: 50-413, 50-414
License Nos.: NPF-35, NPF-52
License Nos.: NPF-35, NPF-52


DEC                                 3
3
DEC
cc w/encl:
cc w/encl:
Regulatory Compliance Manager         Richard P. Wilson, Esq.
Regulatory Compliance Manager
Duke Energy Corporation               Assistant Attorney General
Duke Energy Corporation
Electronic Mail Distribution          S. C. Attorney General's Office
Electronic Mail Distribution
                                      Electronic Mail Distribution
Lisa Vaughn
Lisa Vaughn
Legal Department (PB05E)             Vanessa Quinn
Legal Department (PB05E)
Duke Energy Corporation               Federal Emergency Management Agency
Duke Energy Corporation
422 South Church Street               Electronic Mail Distribution
422 South Church Street
Charlotte, NC 28242
Charlotte, NC 28242
                                      North Carolina Electric
Anne Cottingham
Anne Cottingham                       Membership Corporation
Winston and Strawn
Winston and Strawn                   Electronic Mail Distribution
Electronic Mail Distribution
North Carolina MPA-1
Electronic Mail Distribution
Electronic Mail Distribution
                                      Peggy Force
North Carolina MPA-1                  Assistant Attorney General
Electronic Mail Distribution          N. C. Department of Justice
                                      Electronic Mail Distribution
Henry J. Porter, Assistant Director
Henry J. Porter, Assistant Director
Div. of Radioactive Waste Mgmt.       County Manager of York County, SC
Div. of Radioactive Waste Mgmt.
S. C. Department of Health           Electronic Mail Distribution
S. C. Department of Health
and Environmental Control
  and Environmental Control
Electronic Mail Distribution          Piedmont Municipal Power Agency
Electronic Mail Distribution
                                      Electronic Mail Distribution
R. Mike Gandy
R. Mike Gandy
Division of Radioactive Waste Mgmt.   Manager
Division of Radioactive Waste Mgmt.
S. C. Department of Health and       Nuclear Regulatory Licensing
S. C. Department of Health and
Environmental Control                Duke Energy Corporation
  Environmental Control
Electronic Mail Distribution          526 S. Church Street
Electronic Mail Distribution
                                      Charlotte, NC 28201-0006
Richard P. Wilson, Esq.
Assistant Attorney General
S. C. Attorney General's Office
Electronic Mail Distribution
Vanessa Quinn
Federal Emergency Management Agency
Electronic Mail Distribution
North Carolina Electric
  Membership Corporation
Electronic Mail Distribution
Peggy Force
Assistant Attorney General
N. C. Department of Justice
Electronic Mail Distribution
County Manager of York County, SC
Electronic Mail Distribution
Piedmont Municipal Power Agency
Electronic Mail Distribution
Manager
Nuclear Regulatory Licensing
Duke Energy Corporation
526 S. Church Street
Charlotte, NC 28201-0006


        DEC                                                   4
4
        Distribution w/encl:
DEC
        C. Patel, NRR
Distribution w/encl:
        RidsNrrDipmlipb
C. Patel, NRR
        PUBLIC
RidsNrrDipmlipb
PUBLIC DOCUMENT (circle one):     YES     NO
PUBLIC
OFFICE             RII:DRP         RII:DRP       RII:DRP
PUBLIC DOCUMENT (circle one):       YES         NO
SIGNATURE
OFFICE
NAME               RHaag           DRoberts     MGiles
RII:DRP
DATE                   1/08/2002       1/7/2002     1/7/2002
RII:DRP
E-MAIL COPY?         YES      NO     YES     NO  YES       NO   YES     NO      YES     NO      YES     NO YES NO
RII:DRP
        OFFICIAL RECORD COPY          DOCUMENT NAME: C:\Program Files\Adobe\Acrobat 4.0\PDF Output\ResponseTo
SIGNATURE
        IR01-05.wpd
NAME
RHaag
DRoberts
MGiles
DATE
1/08/2002
1/7/2002
1/7/2002
E-MAIL COPY?
    YES
NO     YES
NO      YES
NO     YES
NO      YES
NO      YES
NO     YES
NO  
OFFICIAL RECORD COPY          DOCUMENT NAME: C:\\Program Files\\Adobe\\Acrobat 4.0\\PDF Output\\ResponseTo
IR01-05.wpd
}}
}}

Latest revision as of 01:41, 17 January 2025

Response to Dukes Comments on NRC Integrated Inspection Report 50-413/01-05, 50-414/01-05 Dated October 22, 2001
ML020090531
Person / Time
Site: Catawba  
Issue date: 01/09/2002
From: Mccree V
Division Reactor Projects II
To: Gordon Peterson
Duke Energy Corp
References
IR-01-005
Download: ML020090531 (4)
v • d • e


See also: IR 05000413/2001005

Text

January 9, 2002

Duke Energy Corporation

ATTN: Mr. G. R. Peterson

Site Vice President

Catawba Nuclear Station

4800 Concord Road

York, SC 29745

SUBJECT:

RESPONSE TO DUKES COMMENTS ON NRC INTEGRATED INSPECTION

REPORT 50-413/01-05, 50-414/01-05 DATED OCTOBER 22, 2001

Dear Mr. Peterson:

Thank you for your response of December 4, 2001, which provided comments for consideration

pertaining to non-cited violation (NCV) 50-414/01-05-01, Failure to Implement Effective

Corrective Actions Associated with the Unit 2 Refueling Water Storage Tank (FWST) Level

Channel Failures, and NCV 50-413, 414/01-05-03, Failure to Identify a Condition Adverse to

Quality that Rendered the A Chiller Inoperable.

Concerning the first NCV, you took exception to the NRC conclusion that the FWST

instrumentation channels were unreliable. Your response described the reliability of the FWST

level system in terms of monitoring performed by your Maintenance Rule program as required

by 10CFR50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear

Plants. You stated the performance goals are established with limits of 99.8% system

availability and 100% system reliability and that the Unit 2 FWST level system has always met

or exceeded these goals. A review of your maintenance rule program indicated that these limits

apply to the Refueling Water (FW) risk-significant systems, structures, and components (SSC),

and not to the performance of individual FWST level channels, which is the focus of this

violation. Our review indicated that the performance of individual FWST level channels is

monitored under a different SSC and have different monitoring criteria.

Your response quoted the following statement from Inspection Report 50-413/01-05, 50-

414/01-05, The failure to implement timely corrective actions for this degraded condition had a

credible impact on plant safety in that reliable operation of FWST level channels 1 and 3 was

not assured from 1996 to 2001. The intent of this statement was to explain the impact of the

NCV on plant safety. Criterion XVI of 10 CFR 50, Appendix B, requires that measures shall be

established to assure that conditions adverse to quality, such as failures, malfunctions and

deficiencies are promptly identified and corrected. This requirement applies to all safety-related

SSC which includes each individual FWST level channel. Based on the number of level

channel deficiencies since 1996, and the absence of a root cause determination until the Fall of

2001, the NRC concluded that your corrective actions were inadequate, and that the FWST

level channels were unreliable because quality could not be assured for each channel. This

was considered to have had a credible impact on safety because the system configuration that

existed when two FWST level channels failed on July 23, 1998, remained unchanged until

grounding modifications were completed in June 2001. During this time, the inspectors

2

DEC

concluded that the FWST level channels were more vulnerable to lightning induced failures.

After further review of this issue, and consideration of your comments regarding FWST level

channel reliability, we concluded that the inspection report accurately describes your FWST

corrective actions and the impact on plant safety.

You also took exception to the list of Problem Investigation Process (PIP) reports listed in the

inspection report on pages 4 and 5, and stated that this list may provide the incorrect perception

that all the events were instrument failures. With only a few exceptions, all the PIPs listed in

the report described actual degraded equipment conditions associated with the Unit 2 FWST

level channels that occurred between July 1996 and August 2000. The report did not intend to

imply that all these documented events were actual instrument failures, unless identified as

such in the PIP description column of the table.

Regarding the second NCV, you commented that previously issued NRC Inspection Report 50-

413/01-04, 50-414/01-04, dated July 23, 2001, documented a licensee identified violation for

the same May 3, 2001, chiller event referenced in the second NCV. Your response contended

that this event, if significant enough to warrant multiple violations, should be credited as a

licensee identified finding as originally documented in the July 23, 2001, report. Our review

indicated that these NCVs identified two different performance deficiencies, both of which

warranted an individual NCV. The first performance deficiency resulted in NCV 50-413,414/01-

04-02 and involved your failure to develop appropriate written procedures or documented

instructions for maintenance activities on the A YC chiller. The second NCV identified a

performance deficiency involving the failure of licensed operators to perform an adequate

operability review of the A YC chiller during the May 3, 2001 event. This NCV was identified

through the baseline inspection program during the review and closure of Licensee Event

Report (LER) 50-413/2001-002. NRC Inspection Manual Chapter 0610*, Power Reactor

Inspection Reports, requires that when closing LERs, the NRC should identify any more-than-

minor findings or violations of regulatory requirements, and document these accordingly when

closing the LER.

After further review of this issue, and consideration of your comments, we agree that this

violation should also have been credited as a licensee-identified NCV. Consequently, we plan

to update the Plant Issues Matrix and the Reactor Oversight Process web page to reflect this

NCV as being licensee identified.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Victor M. McCree, Acting Director

Division of Reactor Projects

Docket Nos.: 50-413, 50-414

License Nos.: NPF-35, NPF-52

3

DEC

cc w/encl:

Regulatory Compliance Manager

Duke Energy Corporation

Electronic Mail Distribution

Lisa Vaughn

Legal Department (PB05E)

Duke Energy Corporation

422 South Church Street

Charlotte, NC 28242

Anne Cottingham

Winston and Strawn

Electronic Mail Distribution

North Carolina MPA-1

Electronic Mail Distribution

Henry J. Porter, Assistant Director

Div. of Radioactive Waste Mgmt.

S. C. Department of Health

and Environmental Control

Electronic Mail Distribution

R. Mike Gandy

Division of Radioactive Waste Mgmt.

S. C. Department of Health and

Environmental Control

Electronic Mail Distribution

Richard P. Wilson, Esq.

Assistant Attorney General

S. C. Attorney General's Office

Electronic Mail Distribution

Vanessa Quinn

Federal Emergency Management Agency

Electronic Mail Distribution

North Carolina Electric

Membership Corporation

Electronic Mail Distribution

Peggy Force

Assistant Attorney General

N. C. Department of Justice

Electronic Mail Distribution

County Manager of York County, SC

Electronic Mail Distribution

Piedmont Municipal Power Agency

Electronic Mail Distribution

Manager

Nuclear Regulatory Licensing

Duke Energy Corporation

526 S. Church Street

Charlotte, NC 28201-0006

4

DEC

Distribution w/encl:

C. Patel, NRR

RidsNrrDipmlipb

PUBLIC

PUBLIC DOCUMENT (circle one): YES NO

OFFICE

RII:DRP

RII:DRP

RII:DRP

SIGNATURE

NAME

RHaag

DRoberts

MGiles

DATE

1/08/2002

1/7/2002

1/7/2002

E-MAIL COPY?

YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO

OFFICIAL RECORD COPY DOCUMENT NAME: C:\\Program Files\\Adobe\\Acrobat 4.0\\PDF Output\\ResponseTo

IR01-05.wpd

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