ML12251A010

NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) Supplement 1 to LAR 2012-09, License Amendment Request for Revision to License Condition 3.D, Transition...

ML12251A010
Person / Time
Site:	Oconee
Issue date:	09/05/2012
From:	Gillespie T Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12251A010 (3)

Text

Duke SEnergy T. PRESTON GILLESPIE, JR.

Vice President Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Hwy.

Seneca, SC 29672 864-873-4478 864-873-4208 fax T.Gillespie@duke-energy.corn 10 CFR 50.90 September 5, 2012 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station Units 1, 2, and 3 Docket Numbers 50-269, 50-270 and 50-287 NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

Supplement 1 to LAR 2012-09, License Amendment Request for Revision to License Condition 3.D, Transition License Conditions #1 and #2 Pursuant to 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy) proposes to amend Renewed Facility Operating License Nos. DPR-38, -47, and -55. This License Amendment will result in a revised completion date for the Implementation Items and Protected Service Water (PSW) Modification in License Condition 3.D, Transition License Conditions #1 and #2, respectively.

By letter dated December 29, 2010, Duke Energy received Amendments 371, 373, and 372, allowing the licensee to maintain a fire protection program in accordance with 10 CFR 50.48(c) for the Oconee Nuclear Station, Units 1, 2, and 3 (ONS), and changed the license and technical specifications accordingly. The Amendments contained a new license condition 3.D that cited Transition License Conditions #1 and #2 pertaining to implementation items in Table 2.9-1 and modifications in Table 2.8.1-1.

Transition License Conditions regarding Table 2.9-1, Implementation Items and Table 2.8.1-1,

'Committed Plant Modifications', Item 1, PSW Modification, require date revisions due to administrative and technical issues associated with completing the PSW modification. Duke Energy requested that the completion dates for these items be revised from January 1, 2013 to December 31, 2014. Specific details and justification for the implementation items and modification changes were provided in a submittal dated July 31, 2012. These changes were discussed with the NRC in a public meeting on July 19, 2012, and a conference call on July 24, 2012.

www. duke-energy. comr

U. S. Nuclear Regulatory Commission September 5, 2012 Page 2 In a follow-up conference call on August 20, 2012, the NRC requested additional information concerning the number of implementation items that will remain open beyond January 1, 2013 and the reasons for extension. Duke Energy has identified three implementation items that will remain open as a result of PSW implementation. The implementation items and reasons for extension are provided as follows:

Item # Implementation Item Description Reasons

23. Complete the analysis of NPO fire PSW is utilized to maintain certain Key impacts for fire zones following Safety Functions. Since the PSW installation of the NFPA 805 modification will not be implemented by committed modifications. After December 31, 2012, this implementation implementation, update Oconee Site item cannot be completed and requires Calculation (OSC)-9313 and its NPO extension until after full implementation of recommendations for affected fire PSW.

zones.

32. Incorporate the PSW modification Since the PSW modification will not be into FPP site documents after the implemented by December 31, 2012, this modification is implemented. implementation item cannot be completed and requires extension until after full implementation of PSW.

43. Confirm that the risk decrease from Since the PSW modification will not be the as-built PSW continues to bound implemented by December 31, 2012, the as-the cumulative VFDR transition risk built configuration will be unknown; once the PSW modifications are therefore, this implementation item cannot installed. be completed and requires extension until after full implementation of PSW.

Given the risk benefit of the PSW System, Duke Energy will continue to provide timely updates to the NRC regarding progress of the PSW project.

Should you have any questions regarding this information, please call David Goforth at (864) 382-2659.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 5, 2012.

Sincerely, T. Preston Gillespie, Vice President Oconee Nuclear Station

U. S. Nuclear Regulatory Commission September 5, 2012 Page 3 cc:

Mr. Victor M. McCree, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. John Boska, Project Manager (electronic copy only)

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8 G-9A Washington, DC 20555 Mr. Paul Lain Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-11 All1 Washington, DC 20555 Senior Resident Inspector Oconee Nuclear Site Ms. Susan Jenkins, Manager, Infectious and Radioactive Waste Management Section 2600 Bull Street Columbia, SC 29201