ML15085A050

Catawba, Units 1 and 2 - Commitment Change Evaluation Report for 2014

ML15085A050
Person / Time
Site:	Catawba
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)

Text

( ENERGY.Kelvin Henderson Vice President Catawba Nuclear StationDuke EnergyCN01VP 1 4800 Concord RoadYork, SC 29745o:803.701.4251 f: 803.701.3221 CNS-15-031 March 24, 2015U.S. Nuclear Regulatory Commission Attention:

Document Control DeskWashington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke)Catawba Nuclear Station, Units 1 and 2Docket Nos.: 50-413 and 50-414Commitment Change Evaluation Report for 2014Attached is a summary of commitment change evaluations completed during the 2014calendar year for Catawba Nuclear Station.

These evaluations and subsequent commitment changes were made based on the guidance defined in NEI 99-04, Guidelines for ManagingNRC Commitments, and have no adverse effect on compliance with NRC rules andregulations.

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

Sincerely, elvin Henderson Vice President, Catawba Nuclear StationAttachment F)www.duke-energy.com aU. S. Nuclear Regulatory Commission March 24, 2015Page 2xc:V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1257 G. Edward MillerNRC Project ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-G9A11555 Rockville PikeRockville, MD 20852-2738 G. A. HuttoSenior Resident Inspector CN01NC Catawba Nuclear StationAnnual Commitment Change Summary Report for 2014Docket Nos. 50-413 and 50-414NRCNotification Number Source Document Original Commitment Modified Commitment RequiredYes2014-C-001 NRC Generic Letter Response(November 27,1997) andCommitment Change #2002-C-005The intake and pit inspections willbe performed on a three yearfrequency commencing from thelast RN intake and Train B pump pitinspection conducted on 4/24/02.Defer the inspection of Nuclear ServiceWater (RN) Pump Pit A to no later than11/20/2014.

This is a one-time deferral.

The inspection of the A train RN Pump Pitis due 07/07/2014.

This inspection wasscheduled for March of 2014 but could notbe performed due to issues with providing adequate isolation of the pit. In order tominimize safety system unavailability, thisinspection will be performed duringscheduled valve maintenance which willrequire A train of RN to be removed fromservice.The most recent A train pit inspection wasperformed during refueling outage1EOC17, October, 2010. No structural issues were identified with the condition ofthe pit and associated structures, asdocumented in the work order completion comments.

The A and B train pits are operated in thesame manner. Therefore, the condition ofthe B train pit is considered to beindicative of the condition of the A pit.The latest inspection of the B pit wasperformed in February, 2012. The resultsof that inspection concluded that nostructural issues were present withrespect to concrete, structural steel or theintake screens.

As noted in theCorrective Action Program, the pit was invery good condition (C-12-1403).

Thisindicates the A pit is also in a similarPage 1 NRCNotification Number Source Document Original Commitment Modified Commitment Requiredcondition.

Therefore, deferring the next committed Atrain pump pit inspection by four months(11/30/14) to minimize safety systemunavailability will not result in anypotential challenge of the A train of theRN system from being capable of meetingits design basis requirements.

This deferral is only applicable to thissingle occurrence.

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

Catawba willevaluate the resolution of TS issues Duke Energy's evaluation of TSTF-523 iswith respect to the changes continuing.

Additional time is needed tocontained 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 aapproval of the TSTF. schedule for submittal of an LAR byOctober 15, 2014. Duke Energy believesthat the actions completed in response toGeneric Letter 2008-01 provideconfidence that safety will be preserved during the extended evaluation period thatthe revised regulatory commitments afford.Yes 2014-C-003 Letter from Bill Pitesa, Duke Implementation Milestone 8 of the Revise Implementation Milestone 8Energy, to NRC dated April 15, Cyber Security Plan is to Complete completion date of June 30, 2015, to2011, "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 Asset2015. (CDA) assessment activities wassubstantially underestimated by DukePage 2 NRCNotification Number Source Document Original Commitment Modified Commitment RequiredEnergy. The Milestone 8 completion datewas established prior to any significant work being performed on programimplementation; therefore, the scope ofthe assessment activities was not fullyappreciated.

The scope of the CDAassessment activities was alsosubstantially underestimated by theindustry in general, as evidenced by theneed for additional industry guidance.

Therefore, Duke Energy (DEC) is revisingthe commitment for Milestone 8completion date of June 30, 2015, toDecember 31, 2017. Milestone 8 pertainsto the date that complete operational andmanagement

controls, as provided inNuclear Energy Institute 08-09, Revision6, Appendix E, will be achieved.

Basedon the status of the cyber securityprogram, Duke Energy believes thatsafety will be preserved during theapproval period that the revisedregulatory commitments afford.Page 3