ONS-2015-099, Fifth 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)

Fifth 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)

ML15247A069
Person / Time
Site:	Oconee
Issue date:	08/26/2015
From:	Batson S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ONS-2015-099
Download: ML15247A069 (7)

Text

DUKEScott, Batson Vice President ENEGY°Oconee Nuclear Stetion Duke Energy ONO1VP I 7800 Rochester Hwy ONS-201 5-099 Seneca, SC 29672 o: 864.873.3274

f. 864.873. 4208 Scott.Batson~duke-energy.com August 26, 2015 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, 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:

Fifth 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

,OrderModifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (Accession No. ML13086A095).

3. Duke Energy Letter, 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-12-05 1), dated August 26, 2013 (Accession No. ML13242A009).

4. 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-12-05 1),

dated November 1, 2013 (Accession No. ML13298A696).

5. 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 (Order Number EA-12-05 1), dated February 28, 2014 (Accession No. ML14064A197).

6. 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).

7. Duke Energy Letter, 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-12-05 1), dated August 27, 2014 (Accession No. ML14245A019).

8. Duke Energy Letter, Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolI' Instrumentation (Order Number EA-12-051), dated February 27, 2015 (Accession No. ML15063A028)., ,.

ONS-201 5-099 August 26, 2015 Page 2 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 directed Duke Energy to have 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 status reports at six-month intervals.

Duke Energy has thus far submitted the OIP (Reference 2), and four six-month reports (References 3, 5, 7 and 8) for Oconee Nuclear Station. By letter dated November 1, 2013 the NRC staff provided an Interim Staff Evaluation (ISE) and Request for Additional Information (RAI) (Reference 4) regarding the OIP. By letter dated March 26, 2014 (Reference 6), the NRC directed licensees not to formally submit their RAI responses on the docket but instead to make their responses and supporting information available on their e-Portals. All RAI responses are to be available on the e-Portals by the date identified in the ISE.

The purpose of this letter is to provide the fifth six-month status report. The enclosure provides updates related to OIP changes, if any, during the January 29, 2015 to July 28, 2015 update period. Responses to the RAIs were placed on the Oconee Nuclear Station ePortal by March 31, 2015 as specified in the ISE, and thus 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 26, 2015.

Vice President Oconee Nuclear Station

Enclosure:

1. Oconee Nuclear Station Fifth Six Month Status Report for Order EA-1 2-051 (SFPI),

Units 1, 2 and 3.

ONS-201 5-099 August 26, 2015 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. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike 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. Jeffery Whited (by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8B1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ONS-201 5-099 August 26, 2015 Page 4 bxc:

T.P. Gillespie (EC07H)

T.D. Ray (ON01 VP)

J. E. Burchfield (ON01 VP)

C.T. Dunton (ON01 VP)

T.L. Patterson (ON01 VP)

0. C. Jones (ON01EI)

D. M. Hubbard (ON03PC)

C.J. Wasik (ON03RC)

D.C. Haile (ON03RC)

M.C. Nolan (EC05P)

C.J. Thomas (EC01iT)

D.H. Llewellyn (EC09E)

G.D. Robison (EC09E)

P. F. Guill (EC01T)

ONS Master File (ON02DM, File OS 801.01)

ELL (EC2ZF)

ENCLOSURE 1 Oconee Nuclear Station (ONS)

Fifth Six Month Status Report for the Implementation of Order EA-12-051 (SFPI)

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

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

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

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 required that update reports on progress or change to the OIP 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, February 28, 2014, August 27, 2014 and February 27, 2015 (Reference E5, E6, El 0 and El11). The OIP and six-month status reports follow the guidance of NEI 12-02 (as endorsed by the NRC).

This report constitutes the fifth 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, 2015 to July 28, 2015 (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 placed 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. Note: Some responses were revised in response to the July 2015 NRC Onsite Audit.

2Milestone Accomplishments At the end of the update period, physical installation of all four channels (2 channels in U1/U2 shared pool and 2 channels in U3 pool) was completed.

3Milestone Schedule Status There are no changes to the schedule as reported in the OIP (Reference E4). Testing and operational turnover is expected to be completed within the next update period.

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

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

6Open 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 RAl responses.

Endl. Page 2 of 3

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

(Note: The referencesfor this Enclosure are listed in Section 8) 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 EA-l12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (Accession No. ML120554A679).

E2. NRC Interim Staff Guidance JLD-ISG-201 2-03, Compliance with Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, dated August 29, 2012, (Accession No. ML12221A339).

E3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-1 2-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", Revision 1, dated August 2012 (Accession No. ML12240A307).

E4. 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 (Order Number EA-1 2-051 ), dated February 28, 2013 (Accession No. ML13086A095).

E5. Duke Energy Letter, 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, 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. ML1317A301 ).

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-12-051) 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).

El0. Duke Energy Letter, 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 ), dated August 27, 2014 (Accession No. ML14245A019).

El 1. Duke Energy Letter, Fourth 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 27, 2015 (Accession No. ML15063A028).

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