ML092320550

Supplemental Request for Additional Information for License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change Number

ML092320550
Person / Time
Site:	Oconee
Issue date:	08/10/2009
From:	Baxter D Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML092320550 (10)

Text

Duke6 DAVE BAXTER Vice President E rgy Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Highway Seneca, SC 29672 864-873-4460 864-873-4208 fax dabaxter@dukeenergy.com August 10, 2009 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Supplemental Request for Additional Information for License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change Number 2007-09, Supplement 18 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 responded to an August 20, 2008, NRC request for additional information (RAI) by letter dated September 30, 2008. Duke responded to a March 9, 2009, supplemental RAI by letter dated April 3, 2009.

On June 24, 2009, Duke advised the NRC of the need to revise responses to RAI EICB 106 and RAI 80. -This revision is provided in Enclosure 1. NRC also requested Duke to docket additional information associated with NRC Oconee Safety Evaluation Report (SER) Open Items (01) 91 and 93 related to the TELEPERM XS (TXS) Test Machine and the TXS Maintenance Laptop Computer. This information is provided in Enclosure 1. provides documents requested by the NRC Staff to resolve NRC Oconee SER Ols or to provide a docketed reference for information to be described in the SER. contains a description of design features that secure the RPS/ESPS from electronic vulnerabilities. As such, Duke considers the information in the enclosure to be security-related information and requests that it be withheld from public disclosure pursuant to 10 CFR 2.390. Information contained in Enclosure 2 is classified by AREVA NP as proprietary. The appropriate affidavits from AREVA NP are provided in Enclosure 3 in accordance with the provisions of 10 CFR 2.390.

If there are any questions regarding this submittal, please contact Boyd Shingleton at (864) 873-4716. contains Security-Related information. Enclosure 2 to this letter contains Proprietary information. Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these Enclosures this letter is uncontrolled.

kJiR www. duke-energy. corn

U. S. Nuclear Regulatory Commission August 10, 2009 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on August 10, 2009.

Sincerely, Dave Baxter, Vice President Oconee Nuclear Station

Enclosures:

1.

Additional Information - Security-Related

2.

AREVA NP Documents - Proprietary

3.

AREVA NP Affidavit contains Security-Related information. Enclosure 2 to this letter contains Proprietary information. Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these Enclosures this letter is uncontrolled.

U. S. Nuclear Regulatory Commission August 10, 2009 Page 3 cc:

Mr. J. F. Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C. 20555 Mr. L. A. Reyes, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. E. T. Riggs Senior Resident Inspector (Acting)

Oconee Nuclear Station S. E. Jenkins, Manager Infectious and Radioactive Waste Management Section 2600 Bull Street Columbia, SC 29201 contains Security-Related information. Enclosure 2 to this letter contains Proprietary information. Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these Enclosures this letter is uncontrolled.

TSC 2007-09, Supplement 18 August 10, 2009 Page 1 AREVA NP Proprietary Affidavits

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 66-5065212-004, Oconee Nuclear Station RPS/ESFAS Replacement Project Equipment Qualification Report 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 CIFR 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 _

day of

) \\AA 2009.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129 SHERRY I.. MCAM.g Notary Public Commonwealth of VirginIa 7079129 rY Com. ml10onExp.,j-Oct 31. 2010

AFFIDAVI T 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.

Iam 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 presentation entitled Discussion of TXS Maintenance Laptop 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 asecured 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 __-___tb day of

,2009.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129 SHERRY L. MCPADEN Notary PUDIlC Commonweallh of VWfainlo

~7079129 m.y Commission Expireso Oc 3. 2010