ML20059J096
| ML20059J096 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/10/1994 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401310349 | |
| Download: ML20059J096 (4) | |
Text
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DUKEPOWER January 10, 1994 U.
S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555
Subject:
Catawba Nuclear Station Dockets Nos. 50-413 and 50-414 Reply to Notice of Deviation Inspection Report Nos. 50-413/93-28 and 50-414/93-28 Attached is Duke Power's response to the deviation identified" in the Notice of Deviation of Inspection Report 50-413/93-28 and 50-414/93-28.
Very truly
- ours, D
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\\ KEN: RESP 93.28 xc:
S.
D.
Ebneter Regional Administrator, Region II R.
E. Martin, ONRR i
R.
J.
Freudenberger Senior Resident Inspector
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9401310349 94011o
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION
-REPLY TO NOTICE OF DEVIATION 413,414/93-28-01 Notice of Deviation During an NRC inspection conducted on_ November 1-5,
- 1993, a
deviation of written commitments was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C,-the deviation is listed below:
Duke Power Company (DPC) correspondence dated February 16, 1992, provided a commitment date of December 31, 1992 to complete additional analysis and to address some recommendations for several i
items, which would complete actions necessary for compliance with 10 CFR Part 50.63, Station Blackout Rule for the-Catawba Nuclear i
Facility Units 1 and 2.
These items were identified in the'NRC j
Station Blackout Safety Evaluation Report for the Catawba Nuclear Station, Units 1 and 2, dated January 10, 1992.
Contrary to the above, the licensee had not completed the required analysis or fully addressed the recommendations of the NRC Safety Evaluation Report.
Specifically, the licensee had not completed the analysis of the Class 1E Vital I&C Battery Loads for Station Blackout loading for comparison to test data.
Additionally, the evaluation of the manual operation of SBO equipment and the j
habitability of the mechanical penetration room had not been-a completed.
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF DEVIATION 413,414/93-28-01
RESPONSE
1.
Reason For Deviation During revisions to the calculations for the 125 VDC Vital I&C l
Batteries and the 125 VDC Diesel Generator Batteries to resolve SBO issues, problems were identified.
The' degree of conservatism in both battery loading data and the calculation model indicated that the batteries would not meet acceptance criteria for a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> coping duration.
The options' were weighed and determined it would be necessary to either evaluate the load data further to reduce some conservatism or to identify loads that could be stripped.
Catawba Nuclear l
Station Electrical Engineering made the decision to spend i
additional time evaluating the load data since stripping loads-1 would require changes to station procedures and would be inconsistent with what had been documented in the SBO SER.
The additional work scope required additional time to complete and thus exceeded the original commitment date.
It was Electrical Engineering's interpretation of the June 16, 1992 letter from R. E. Martin to M. S. Tuckman regarding Catawba's Supplemental Safety Evaluation for SBO that Catawba had until June, 1994 (two years of receipt of letter) to be in. - f ull compliance and thus it was decided to. proceed with our corrective actions by this date.
Although the preliminary calculation results did not provide satisfactory conclusions, Electrical Engineering had obtained additional battery test data since the SBO SER was issued which supported continued operability of the vital batteries for SBO.
Catawba Nuclear Station did not formally seek clarification of the June 16, 1992, letter from the NRC or ask for discussion on feasibility of alternative approaches.
In addition, an adequate mechanism to track audit commitments had not been fully implemented during the initial SBO audit.
The responsibility for tracking had not been adequately' established between the General Office and Catawba Nuclear Station.
This resulted in an unclear determination of responsibilities and misunderstandings of the actual
'l commitment dates.
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF DEVIATION 413,414/93-28-01 3
2.
Corrective Actions Taken And Results Achieved The appropriate process for requesting additional time-necessary for completion of commitments to the NRC has been reviewed with Engineering personnel.
The Problem Investigation Process (PIP) was enhanced in October, 1993, to track NRC commitments. The process now documents the background history of the commitment, as well as the individual who is responsible for the commitment and the committed due date.
For this specific SBO audit, the evaluation of the SBO equipment was satisfactorily completed.
This is documented in Sections 2.2 and 2.5 of NRC Inspection Report 50-413, 414/93-28.
The mechanical penetration room habitability analysis was revised during this NRC Inspection.
This revision removed heat loads from the analysis that would not be present during an SBO event.
The resulting maximum temperature of 122 F was determined to be acceptable.
3.
Corrective Actions To Be Taken To Avoid Further Deviations The revised mechanical penetration room habitability i
analysis will be formally documented in calculation CNC-
^
1211.00-00-0111, by March 01, 1994.
[ Assigned to MNE]
Completion of all calculations to support implementation I
of the SBO Rule will be addressed in a letter to be provided to the NRC by February 10, 1994.
[ Assigned to IEE) 4.
Date Of Full Compliance
.)
Duke Power Company is now in full compliance.
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