ONS-2014-117, Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

ML14245A019
Person / Time
Site:	Oconee
Issue date:	08/27/2014
From:	Batson S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-015, ONS-2014-117
Download: ML14245A019 (6)

Text

Scott L.Batson

~DUKE Vc rsdn Oconee Nuclear Station t ENERGY. Duke Energy ONOIVP 17800 Rochester Hwy Seneca, SC 29672 ONS-2014-117 o: 864.873.3274

f. 864.873. 4208 Scott.Batson@duke-energy.com August 27, 2014 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55

Subject:

Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, (Accession No. ML12054A679)

2. Duke Energy Letter, Overall Integrated Plans in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), dated February 28, 2013, (Accession No. ML13086A095)

3. Duke Energy Letter, Second Six-month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-05 1), Dated February 28, 2014, (Accession No. ML14064A197)

4. NRC Letter to Oconee Nuclear Station, Interim Staff Evaluation And Request For Additional Information-Oconee Nuclear Station, Units 1,2 And 3 Regarding Overall IntegratedPlan For Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051) DatedNovember 1, 2013 (Accession No. ML13298A696)

5. NRC Letter, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, Dated March 26, 2014 (Accession No. ML14083A620)

Ladies and Gentlemen, On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to Duke Energy which was immediately effective and directs Duke Energy to develop a reliable indication of water level in associated spent fuel storage pools. The Order required that, following NRC's issuance of its final Interim Staff Guidance (ISG), Duke Energy would submit an Overall Integrated Plan (OIP), followed by a status report at six-month intervals.

ONS-2014-117 August 27, 2014 Page 2 Duke Energy has thus far submitted the OIP (Reference 2) and two six-month update reports (Reference 3) for Oconee Nuclear Station. The purpose of this letter is to provide the third six-month status report. The enclosure provides updates related to OIP changes, if any, for the six-months following the second six-month reporting period.

By letter dated March 26, 2014 the NRC issued an Audit Plan for the 0IP (Reference 5) which directed licensees not to submit RAI responses as previously directed by the Interim Staff Evaluation (ISE) (Reference 4) but instead, to provide responses for staff review by the date identified in their ISE, using the ePortal. Accordingly, no RAI responses are included in this report.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact David Haile with Oconee Regulatory Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 27, 2014.

Sincerely, Scott L. Batson Vice President Oconee Nuclear Station

Enclosure:

1. Oconee Nuclear Station Third Six Month Status Report for Order EA-12-051 (SFPI),

Units 1, 2, and 3 Encl. Page - 2

ONS-2014-117 August 27, 2014 Page 3 cc:

Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. Daniel Dorman, (Acting) Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, 11555 Rockville Pike, M/S 13-H16M Rockville, MD 20852-2738 Mr. James R. Hall, Project Manager (ONS)

(by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike, M/S O-8G9A Rockville, MD 20852-2746 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station Encl. Page - 3

ENCLOSURE

[3 pages, including cover]

Oconee Nuclear Station (ONS)

Third Six Month Status Report for Order EA-12-051 (SFPI),

Units 1, 2, and 3 Encl. Page - 1

ENCLOSURE:ONS THIRD SIX-MONTH STATUS REPORT - ORDER EA- 12-051 (SFPI)

(Note: The references for this Enclosure are listed in Section 8)

1. Introduction On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference El) to Duke Energy directing them to develop a reliable indication of water level associated with spent fuel storage pools. The Order required each plant to issue an Overall Integrated Plan (OIP) pursuant to the NRC's Interim Staff Guidance (ISG) (Reference E2) which endorsed, with clarifications and exceptions, the industry guidance document, NEI 12-02 (Reference E3). The Order also requires that an update report on OIP progress or changes be submitted every six months.

Oconee Nuclear Station (ONS) developed and submitted an Overall Integrated Plan on February 28, 2013 (Reference E4), describing how compliance with the requirements in the Order would be achieved. The required six-month update reports were submitted on August 26, 2013 and on February 28, 2014 (Reference E5 and E6). The OIP and six-month reports follow the guidance of NEI 12-02 (as endorsed by the NRC)

This report constitutes the third six-month report, it provides updates, if any, of milestones, changes to the compliance method or schedule, or a basis for relief/relaxation. The report addresses the period from January 29, 2014 to July 28, 2014 (hereafter referred to as "the update period").

The NRC issued ONS a Request for Additional Information (RAI) dated June 21, 2013 (Reference E7) related to the Order. Subsequently the NRC issued ONS an Interim Staff Evaluation (ISE) of the OIP on November 1, 2013 (Reference E8) and included a Request for Additional Information (RAI) which superseded the previous RAI. This RAI requested that responses be included in subsequent six-month reports. Most recently the NRC issued an Audit Plan for the Order on March 26, 2014 (Reference E9) which directed licensees not to formally submit their RAI responses on the docket but instead, put their responses and supporting information on the ePortals for staff review, by the date identified in their ISE. Accordingly, ONS will place the RAI responses on the ePortal by March 31, 2015 as specified in the ISE, and thus no RAI responses are included in this report.

2. Milestone Accomplishments No milestones were completed during the update period.

3. Milestone Schedule Status There are no changes to the schedule as reported in the OIP (Reference El).

4. Changes to Compliance Method No changes were made during the update period.

5. Need for Relief/Relaxation and Basis for the RelieflRelaxation ONS expects to comply with the order implementation date and no relief/relaxation is required at this time.

Encl. Page - 2

ENCLOSURE:ONS THIRD SIX-MONTH STATUS REPORT - ORDER EA-12-051 (SFPI)

(Note: The references for this Enclosure are listed in Section 8)

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation There are no open items documented in the Overall Integrated Plan or in the Interim Staff Evaluation (ISE). This six-month status report contains no RAI responses.

7. Potential Interim Staff Evaluation Impacts No potential impacts to the Interim Staff Evaluation have been identified.

8. References The following support the updates to the Overall Integrated Plan described in this enclosure:

El. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, (Accession No. ML 120554A679).

E2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated August 29, 2012, (Accession No. ML12221A339).

E3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", Revision 1, dated August 2012, (Accession No. ML12240A307).

E4. Duke Energy Letter, Duke Energy Carolinas, LLC, (Duke Energy) Overall Integrated Plans in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013, (Accession No. ML13086A095).

E5. Duke Energy Letter, Duke Energy Carolinas, LLC, (Duke Energy), First Six-month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

Dated August 26, 2013, (Accession No. ML13242A009).

E6. Duke Energy Letter, Duke Energy Carolinas, LLC, (Duke Energy), Second Six-month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

Dated February 28, 2014, (Accession No. ML14064A197).

E7. NRC letter, Oconee Nuclear Station, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated June 21, 2013 (Accession No. ML 1317A301).

E8. NRC Letter, Oconee Nuclear Station, Interim Staff Evaluation and Request for Additional Information-Oconee Nuclear Station, Units 1, 2 and 3 Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA 051) Dated November 1, 2013, (Accession No. ML13298A696).

E9. NRC Letter, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, Dated March 26, 2014 (Accession No. ML14083A620)

Encl. Page - 3