ML082880171

License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change (TSC) Number 2007-09, Supplement 6

ML082880171
Person / Time
Site:	Oconee
Issue date:	10/07/2008
From:	Baxter D Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSC -2007-09, Supp 6
Download: ML082880171 (11)

Text

DAVE BAXTER Vice President Energy@

Oconee Nuclear Station Duke Energy Corporation ONOJ VP17800 Rochester Highway Seneca, SC 29672 864-885-4460 864-885-4208 fax dabaxter@dukeenergy. com October 7, 2008 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change (TSC) Number 2007-09, Supplement 6 On January 31, 2008, Duke Energy Carolinas, LLC (Duke) submitted a License Amendment Request (LAR) to address replacement of the existing Oconee Nuclear Station (ONS) analog based Reactor Protective System (RPS) and Engineered Safeguards Protective System (ESPS) with a digital computer based RPS/ESPS. Duke docketed most of the technical documents listed in Table 1-2 of the LAR in Supplement 1 dated April 3, 2008. In some cases where the documents date of availability was not known, Duke indicated the date Would be determined. During subsequent discussions with NRC Staff, Duke agreed to provide factory acceptance test procedures (Table 1-2, Item 16.a) by electronic mail as they become available and then docket within one to two weeks. Duke provided two FAT procedures by electronic mail on September 25, 2008.

These two documents are provided in Enclosure 2. The documents are classified by AREVA NP as proprietary. The appropriate affidavits from AREVA NP are provided in in accordance with the provisions of 10 CFR 2.390. to this letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390.

Upon removal of the enclosures, this letter is uncontrolled.

www. duke-energy, com

U. S. Nuclear Regulatory Commission October 7, 2008 Page 2 If there are any questions regarding this submittal, please contact Boyd Shingleton at (864) 885-4716.

Very truly yours, Dave Bax 7rVice President Oconee Nuclear Station

Enclosures:

1.

2.

AREVA NP Affidavits AREVA NP Documents to this letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390.

Upon removal of the enclosures, this letter is uncontrolled.

U. S. Nuclear Regulatory Commission October 7, 2008 Page 3 cc:

Mr. L. N. Olshan, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C. 20555 L. A. Reyes, Regional Administrator (Acting)

U. S. Nuclear Regulatory Commission - Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. G. A. Hutto Senior Resident Inspector Oconee Nuclear Station S. E. Jenkins, Manager Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 to this letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390.

Upon removal of the enclosures, this letter is uncontrolled.

U. S. Nuclear Regulatory Commission October 7, 2008 Page 4 Dave Baxter affirms that he is the person who subscribedhis name to the foregoing" statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Dave Bax/ter, Vice President Oconee Nuclear Site Subscribed and sworn to me:

Date

<1 2---6o 7 Nofary Public My Commission Expires:.

4;-

Date SEAL to this. letter contains proprietary information.

Withhold From Public Disclosure Under 10 CFR 2.390.

Upon removal of the enclosures, this letter is uncontrolled..

A

License Amendment Request No. 2007-09, Supplement 6 October 7, 2008 AREVA NP Affidavit for Enclosure 2 Documents

AFFIDAVIT COMMONWEALTH OF VIRGINIA

)

ss.

CITY OF LYNCHBURG

1.

My name is Mark J. Burzynski. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.

3.

I am familiar with the AREVA NP information provided to the NRC in support of a Duke Power Company LLC License Amendment Request for Oconee Nuclear Station, Units 1, 2, and 3 (Docket Numbers 50-269, 50-270, and 50-287) entitled Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change Number 2007-09. The following AREVA NP document is provided and referred to herein as the "Document."

AREVA NP document 63-9013142-001, FAT Procedure for Diverse Low Pressure Injection Actuation System Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information".

6.

The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:

(a)

The information reveals details of AREVA NP's research and development plans and programs or their results.

(b)

Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c)

The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c) and 6(d) above.

7.

In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me on this V-'

day of

(

2008.

NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA SHERR'Y L. MCFADME1 Notary Public Commonwealth of Virginia 7079129 E

2 My-Cvommission Exp ires sOct 31, 2011_0

AF F IDAV IT COMMONWEALTH OF VIRGINIA

)

ss.

CITY OF LYNCHBURG

)

1.

My name is Mark J. Burzynski. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.

3.

I am familiar with the AREVA NP information provided to the NRC in support of a Duke Power Company LLC License Amendment Request for Oconee Nuclear Station, Units 1, 2, and 3 (Docket Numbers 50-269, 507270, and 50-287) entitled Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification

• Change Number 2007-09. The following AREVA NP document is provided and referred to herein as the "Document."

AREVA NP document 63-9079257-000, FAT Procedure for Nuclear Instrumentation Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information".

6.

The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:

(a)

The information reveals details of AREVA NP's research and development plans and programs or their results.

(b)

Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c)

The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.

The information in this Document is considered proprietary for the reasons set forth in paragraphs L

6(b), 6(c) and 6(d) above.

7.

In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me on this 2) day of COMMONWEALTH OF2008.

NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA I SHERRY L. M01CFADEN commonwealth Of V11011i0 7079129 my commission Expires Oct 31. 2010