ML040890017

3/26/04, Oconee, Ltr, Technical Specification Requirements Implementation

ML040890017
Person / Time
Site:	Oconee
Issue date:	03/26/2004
From:	Olshan L NRC/NRR/DLPM/LPD2
To:	Rosalyn Jones Duke Energy Corp
Olshan L N, NRR/DLPM, 415-1419
References
TAC MC2089, TAC MC2090, TAC MC2091
Download: ML040890017 (4)

Text

March 26, 2004 Mr. Ronald A. Jones Vice President, Oconee Site Duke Energy Corporation 7800 Rochester Highway Seneca, SC 29672

SUBJECT:

REVIEW OF TECHNICAL SPECIFICATIONS FOR OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (TAC NOS. MC2089, MC2090, AND MC2091)

Dear Mr. Jones:

The purpose of this memorandum is to provide you with the results of the Nuclear Regulatory Commission (NRC) staff review of the technical specifications (TS) for Oconee Nuclear Station, Units 1, 2, and 3. The NRC is conducting a comparison of its license authority file and your records to ensure that errors are identified and corrected for all three units. I have completed the comparison of the NRCs license authority file and your records, and I have found no errors in your records that need correcting.

However, I have identified a concern that could cause confusion when amendments are issued, but are not to be implemented until some later time. For example, Amendment Nos. 322, 322, and 323 for Units 1, 2, and 3, respectively, were issued on March 20, 2002. These amendments are to be implemented within 30 days of the completion of digital governor modifications on both Keowee Hydroelectric Units, which will occur several years after the issuance of the amendments. The implementation requirement is delineated in Section 3 of the license, not in the TS themselves. Thus, holders of the TS may not realize that the replacement pages issued with the amendment are not to be implemented until some future time. These holders, at the time they receive the amendments, might insert the replacement pages and remove existing pages that contain TS requirements that still would apply.

You handled another instance of future implementation in a manner we prefer. Your application for amendments dated July 18, 2000, contained proposed revisions to the TS that were not to be implemented until completion of the Automatic Feedwater Isolation System (AFIS) modification. In this case, the implementation requirements were delineated by notes on the TS pages themselves, rather than in the license. Thus, when the amendments were issued on September 26, 2001, (Amendment No. 320, 320, and 320), holders of the TS would be able insert/remove the appropriate pages at that time. Sometime after completion of the AFIS modification, you submitted, by letter dated July 10, 2003, an application for amendments to remove the implementation notes and other TS requirements that were no longer applicable.

These amendments were issued on November 5, 2003 (Amendment Nos. 336, 336, and 337).

Therefore, we recommend for future application for amendments in which implementation is to be some time after the issuance of the amendments, that the implementation requirements be provided in the TS themselves, rather than in the license.

Ronald A. Jones I have discussed this recommendation with Reene Gambrell of your staff. If you have any further questions in this matter, please call me at 301 415-1419.

Sincerely,

/RA/

Leonard N. Olshan, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287

ML040890017 NRR-106 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME LOlshan CHawes JNakoski DATE 3/25/04 3/25/04 3/26/04 Oconee Nuclear Station cc:

Ms. Lisa F. Vaughn Mr. B. G. Davenport Duke Energy Corporation Regulatory Compliance Manager Mail Code - PB05E Oconee Nuclear Site 422 South Church Street Duke Energy Corporation P.O. Box 1244 ON03RC Charlotte, North Carolina 28201-1244 7800 Rochester Highway Seneca, South Carolina 29672 Anne W. Cottingham, Esquire Winston and Strawn Ms. Karen E. Long 1400 L Street, NW Assistant Attorney General Washington, DC 20005 North Carolina Department of Justice Manager, LIS P. O. Box 629 NUS Corporation Raleigh, North Carolina 27602 2650 McCormick Drive, 3rd Floor Clearwater, Florida 34619-1035 Mr. R. L. Gill, Jr.

Manager - Nuclear Regulatory Senior Resident Inspector Issues and Industry Affairs U. S. Nuclear Regulatory Duke Energy Corporation Commission 526 South Church Street 7812B Rochester Highway Mail Stop EC05P Seneca, South Carolina 29672 Charlotte, North Carolina 28202 Mr. Henry Porter, Director Mr. Richard M. Fry, Director Division of Radioactive Waste Management Division of Radiation Protection Bureau of Land and Waste Management North Carolina Department of Environment, Department of Health and Environmental Health, and Natural Resources Control 3825 Barrett Drive 2600 Bull Street Raleigh, North Carolina 27609-7721 Columbia, South Carolina 29201-1708 Mr. Peter R. Harden, IV Mr. Michael A. Schoppman VP-Customer Relations and Sales Framatome ANP Westinghouse Electric Company 1911 North Ft. Myer Drive 6000 Fairview Road Suite 705 12th Floor Rosslyn, VA 22209 Charlotte, North Carolina 28210