View source for ONS-2016-003, Notification of Compliance with Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.

{{Adams
| number = ML16028A193
| issue date = 01/20/2016
| title = Notification of Compliance with Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.
| author name = Batson S
| author affiliation = Duke Energy Carolinas, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000269, 05000270
| license number = DPR-038, DPR-047
| contact person = 
| case reference number = EA-12-051, ONS-2016-003
| document type = Letter type:ONS
| page count = 6
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Vice President ENERGYDUKEscott                                                                            L.B.tson Qconee Nuc/fear Station Duke Energy ONO1VP I 7800 Rochester Hwy Seneca, SC 29672 ONS-01               6003o:                                               864.873.3274 ONS-206-003f.                                                            864.873.4208 Scott.Batson~duke-energy.com January 20, 2016                                                   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 and 2 Docket Numbers 50-269 and 50-270 Renewed License Numbers DPR-38 and DPR-47

==Subject:==
Notification of Compliance with Order EA-1 2-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" for Oconee Nuclear Station, Units 1 and 2

==References:==
: 1. NRC Order Number EA-12-051, Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession No. ML12054A679.
2:- Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated November 1, 2013 (Accession No. ML13298A696).
: 3. Oconee Nuclear Station, Units 1, 2, and 3 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 And EA-12-051 (TAC NOS. MF0782, 0783, 0784, 0785, 0786, AND 0787), dated October 6, 2015 (Accession No. ML15259A387).
Ladies and Gentlemen On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051,.
"Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" (Reference 1). This Order was effective immediately and directed holders of operating reactor licenses to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of the Order. This letter, along with its enclosures, provides the notification required by Section IV.C.3 of the Order that compliance with the requirements described in Attachment 2 of the Order has been achieved for Oconee Nuclear Station (ONS), Units I and 2.
(Note: The Order required that Unit 2 compliance be completed priorto restartfrom the refueling outage for end-of-cycle 27 (EOC27). However, since ONS has a common pool for Units I and 2, both units were implemented concurrently.)
On November 11, 2015, Unit 2 commenced start-up from the E0C27 refueling outage, which established the EA-12-051 Order compliance date for Units 1 and 2.

ONS-201 6-003 January 20, 2016 Page 2  provides a brief summary of the key elements associated with compliance to Order EA-12-051 for ONS Units 1 and 2. Open and pending items from the NRC Audit Report (Reference 3) are provided in Attachment 2 with a summary response for each item to support closure. As such, Duke Energy considers these items complete, pending NRC closure.
This letter contains no new or revised 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 January 20, 2016.
Sincerely, Scott L. Batson Vice President Oconee Nuclear Station Attachments:
: 1. Oconee Nuclear Station, Units 1 and 2, Summary of Compliance Elements for Order EA-12-051
: 2. Oconee Nuclear Station, Units 1 and 2, NRC Audit Report Open and Pending Items

ONS-201 6-003 January 20, 2016 Page 3 cc:
Ms. Catherine Haney, 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-8BIA Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ATTACHMENT 1 Oconee Nuclear Station, Units 1 and 2 Summary of Compliance Elements for Order EA-12-051 BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation." This Order was effective immediately and directed holders of operating reactor licenses to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of the Order. For Oconee, the Order requires Unit 2 compliance prior to plant startup from the end-of-cycle 27 (EOC27) outage. On November 11, 2015, Unit 2 commenced start-up from the E0C27 refueling outage, which established the Order Compliance date for Unit 2. However, since ONS has a common pool for Units 1 and 2, both units were implemented concurrently. The information provided herein demonstrates compliance for Oconee Nuclear Station, Units I and 2 related to the Order.
COMPLIANCE 

==SUMMARY==
FOR UNITS        1 AND 2 NRC RAI, ISE, and Audit Items - Complete All Requests for Additional Information, ISE Open Items and Confirmatory Items, and Audit Questions/Open Items have been addressed and are considered complete pending NRC closure.
Identification of Levels of Required Monitoring - Complete The three required level indications for monitoring SEP level have been established in compliance with Order EA-12-051 for ONS, Units 1 and 2. These levels are integrated into the site processes for monitoring SFP during Beyond Design Basis events, including response to loss of SEP inventory.
Instrument Design Features       - Complete The modifications to install the Spent Fuel Pool Level Instrumentation have been fully implemented on ONS Units 1 and 2 in accordance with the station design control process. The design complies with the requirements specified in the order and as described in NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-1 2-051" (Reference Al10).
The instruments are arranged to provide reasonable protection against missiles. The instruments are mounted to retain design configuration during and following the maximum expected ground motion. The instruments are designed to be reliable at expected environmental and radiological conditions including extended periods when the SEP is at saturation. The instruments are independent of each other and have separate and diverse power supplies. The instruments are designed to maintain their designed accuracy following a power interruption and to allow routine testing and calibration.
The instrument display is readily accessible during postulated events and allows level information to be promptly available to decision makers.
Program Features - Complete Operating and maintenance procedures for the Spent Fuel Pool Instruments for ONS Units 1 and 2 have been developed, and integrated with existing procedures. These procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the Spent Fuel Pool Instruments are maintained at their design accuracy.
Training for ONS, Units 1 and 2 has been completed using the ONS Systematic Approach to Training (SAT) as recommended in NEI 12-02, Revision 1, Section 4.1.
ONS-201 6-003                                                                          Page 1 of 2

ATTACHMENT 1 Oconee Nuclear Station, Units 1 and 2 Summary of Compliance Elements for Order EA-12-051 REFERENCES Al. NRC Order Number EA-l12-051, Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, (Accession No. ML12054A679).
A2. Oconee Nuclear Station's 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).
A3. Oconee Nuclear Station 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 29, 2013 (Accession No. ML13242A009).
A4. Oconee Nuclear Station 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).
A5. Oconee Nuclear Station 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).
A6. Oconee Nuclear Station Fourth Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2015 (Accession No. ML15063A028).
A7. Oconee Nuclear Station 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 ), dated August 26, 2015 (Accession No. ML15247A069).
A8. Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014 (Accession No. ML14083A620).
A9. I10CFR50.54(f), "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident", Recommendation 9.3, dated March 12, 2012, (Accession No. ML12053A340)
A10. NEI 12-02, Revision 1 "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."'
Al11. Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated November 1, 2013 (Accession No. ML13298A696).
ONS -20 16-003Pae2f2                                                                   Page 2 of 2

ATTACHMENT 2 Oconee Nuclear Station Units 1 and 2, NRC Audit Report Open and Pending Items Duke Energy contends that ONS, Units I and 2 is in full compliance with Order EA-12-051 as demonstrated by the docketed correspondences concerning this order. Briefly, the Request for Additional Information (RAI) items provided in the Spent Fuel Pool Level Instrumentation (SEPLI) ISE are complete for ONS, Units I and 2, pending NRC closure.
Duke Energy provides the following response for the Audit Report Open and Pending Items and considers them to be complete with respect to establishing compliance for ONS Units I and 2:
Item    " I           Description =*         .. .; ",       .-    .       ..    .,Summary Response, ,     i ::*  ,*!,i. -. ,*,iI    i:*
SEPI RAI-8-D     Please provide the results for The SAT report was uploaded to the e-portal on 10/1/15 and the NRC has reviewed the the selected methods, tests report and found it satisfactory and closed item SRAI-8-D. See copy of email below.
and analyses used to                      Sent: Tue 10/13/2015 11:40 AM demonstrate the qualification             From: Boska, John <John.Boska~nrc.gov>
and reliability of the installed          To:    Jones, Dana Chandler; Haile, David Guill, Paul F equipment in accordance                   Dana, with the order requirements.              We have reviewed the SFPI SAT report. We found it satisfactory and closed item SRAI-8-D in the SE Tracker file.
John Boska Mitigation Strategies & SEP Instrumentation Project Manager, NRRIJLD/JOMB U.S. Nuclear Regulatory Commission 0NS-2016-003Pae1o1                                                                                                            Page 1 of 1

Vice President ENERGYDUKEscott                                                                            L.B.tson Qconee Nuc/fear Station Duke Energy ONO1VP I 7800 Rochester Hwy Seneca, SC 29672 ONS-01               6003o:                                               864.873.3274 ONS-206-003f.                                                            864.873.4208 Scott.Batson~duke-energy.com January 20, 2016                                                   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 and 2 Docket Numbers 50-269 and 50-270 Renewed License Numbers DPR-38 and DPR-47

==Subject:==
Notification of Compliance with Order EA-1 2-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" for Oconee Nuclear Station, Units 1 and 2

==References:==
: 1. NRC Order Number EA-12-051, Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession No. ML12054A679.
2:- Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated November 1, 2013 (Accession No. ML13298A696).
: 3. Oconee Nuclear Station, Units 1, 2, and 3 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 And EA-12-051 (TAC NOS. MF0782, 0783, 0784, 0785, 0786, AND 0787), dated October 6, 2015 (Accession No. ML15259A387).
Ladies and Gentlemen On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051,.
"Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" (Reference 1). This Order was effective immediately and directed holders of operating reactor licenses to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of the Order. This letter, along with its enclosures, provides the notification required by Section IV.C.3 of the Order that compliance with the requirements described in Attachment 2 of the Order has been achieved for Oconee Nuclear Station (ONS), Units I and 2.
(Note: The Order required that Unit 2 compliance be completed priorto restartfrom the refueling outage for end-of-cycle 27 (EOC27). However, since ONS has a common pool for Units I and 2, both units were implemented concurrently.)
On November 11, 2015, Unit 2 commenced start-up from the E0C27 refueling outage, which established the EA-12-051 Order compliance date for Units 1 and 2.

ONS-201 6-003 January 20, 2016 Page 2  provides a brief summary of the key elements associated with compliance to Order EA-12-051 for ONS Units 1 and 2. Open and pending items from the NRC Audit Report (Reference 3) are provided in Attachment 2 with a summary response for each item to support closure. As such, Duke Energy considers these items complete, pending NRC closure.
This letter contains no new or revised 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 January 20, 2016.
Sincerely, Scott L. Batson Vice President Oconee Nuclear Station Attachments:
: 1. Oconee Nuclear Station, Units 1 and 2, Summary of Compliance Elements for Order EA-12-051
: 2. Oconee Nuclear Station, Units 1 and 2, NRC Audit Report Open and Pending Items

ONS-201 6-003 January 20, 2016 Page 3 cc:
Ms. Catherine Haney, 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-8BIA Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ATTACHMENT 1 Oconee Nuclear Station, Units 1 and 2 Summary of Compliance Elements for Order EA-12-051 BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation." This Order was effective immediately and directed holders of operating reactor licenses to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of the Order. For Oconee, the Order requires Unit 2 compliance prior to plant startup from the end-of-cycle 27 (EOC27) outage. On November 11, 2015, Unit 2 commenced start-up from the E0C27 refueling outage, which established the Order Compliance date for Unit 2. However, since ONS has a common pool for Units 1 and 2, both units were implemented concurrently. The information provided herein demonstrates compliance for Oconee Nuclear Station, Units I and 2 related to the Order.
COMPLIANCE 

==SUMMARY==
FOR UNITS        1 AND 2 NRC RAI, ISE, and Audit Items - Complete All Requests for Additional Information, ISE Open Items and Confirmatory Items, and Audit Questions/Open Items have been addressed and are considered complete pending NRC closure.
Identification of Levels of Required Monitoring - Complete The three required level indications for monitoring SEP level have been established in compliance with Order EA-12-051 for ONS, Units 1 and 2. These levels are integrated into the site processes for monitoring SFP during Beyond Design Basis events, including response to loss of SEP inventory.
Instrument Design Features       - Complete The modifications to install the Spent Fuel Pool Level Instrumentation have been fully implemented on ONS Units 1 and 2 in accordance with the station design control process. The design complies with the requirements specified in the order and as described in NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-1 2-051" (Reference Al10).
The instruments are arranged to provide reasonable protection against missiles. The instruments are mounted to retain design configuration during and following the maximum expected ground motion. The instruments are designed to be reliable at expected environmental and radiological conditions including extended periods when the SEP is at saturation. The instruments are independent of each other and have separate and diverse power supplies. The instruments are designed to maintain their designed accuracy following a power interruption and to allow routine testing and calibration.
The instrument display is readily accessible during postulated events and allows level information to be promptly available to decision makers.
Program Features - Complete Operating and maintenance procedures for the Spent Fuel Pool Instruments for ONS Units 1 and 2 have been developed, and integrated with existing procedures. These procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the Spent Fuel Pool Instruments are maintained at their design accuracy.
Training for ONS, Units 1 and 2 has been completed using the ONS Systematic Approach to Training (SAT) as recommended in NEI 12-02, Revision 1, Section 4.1.
ONS-201 6-003                                                                          Page 1 of 2

ATTACHMENT 1 Oconee Nuclear Station, Units 1 and 2 Summary of Compliance Elements for Order EA-12-051 REFERENCES Al. NRC Order Number EA-l12-051, Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, (Accession No. ML12054A679).
A2. Oconee Nuclear Station's 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).
A3. Oconee Nuclear Station 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 29, 2013 (Accession No. ML13242A009).
A4. Oconee Nuclear Station 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).
A5. Oconee Nuclear Station 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).
A6. Oconee Nuclear Station Fourth Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2015 (Accession No. ML15063A028).
A7. Oconee Nuclear Station 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 ), dated August 26, 2015 (Accession No. ML15247A069).
A8. Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014 (Accession No. ML14083A620).
A9. I10CFR50.54(f), "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident", Recommendation 9.3, dated March 12, 2012, (Accession No. ML12053A340)
A10. NEI 12-02, Revision 1 "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."'
Al11. Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated November 1, 2013 (Accession No. ML13298A696).
ONS -20 16-003Pae2f2                                                                   Page 2 of 2

ATTACHMENT 2 Oconee Nuclear Station Units 1 and 2, NRC Audit Report Open and Pending Items Duke Energy contends that ONS, Units I and 2 is in full compliance with Order EA-12-051 as demonstrated by the docketed correspondences concerning this order. Briefly, the Request for Additional Information (RAI) items provided in the Spent Fuel Pool Level Instrumentation (SEPLI) ISE are complete for ONS, Units I and 2, pending NRC closure.
Duke Energy provides the following response for the Audit Report Open and Pending Items and considers them to be complete with respect to establishing compliance for ONS Units I and 2:
Item    " I           Description =*         .. .; ",       .-    .       ..    .,Summary Response, ,     i ::*  ,*!,i. -. ,*,iI    i:*
SEPI RAI-8-D     Please provide the results for The SAT report was uploaded to the e-portal on 10/1/15 and the NRC has reviewed the the selected methods, tests report and found it satisfactory and closed item SRAI-8-D. See copy of email below.
and analyses used to                      Sent: Tue 10/13/2015 11:40 AM demonstrate the qualification             From: Boska, John <John.Boska~nrc.gov>
and reliability of the installed          To:    Jones, Dana Chandler; Haile, David Guill, Paul F equipment in accordance                   Dana, with the order requirements.              We have reviewed the SFPI SAT report. We found it satisfactory and closed item SRAI-8-D in the SE Tracker file.
John Boska Mitigation Strategies & SEP Instrumentation Project Manager, NRRIJLD/JOMB U.S. Nuclear Regulatory Commission 0NS-2016-003Pae1o1                                                                                                            Page 1 of 1}}