ML16028A193

Oconee, Units 1 and 2 - Notification of Compliance with Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.

ML16028A193
Person / Time
Site:	Oconee
Issue date:	01/20/2016
From:	Batson S L Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ONS-2016-003
Download: ML16028A193 (6)

Text

DUKEscott L. B.tsonVice President ENERGY Qconee Nuc/fear StationDuke EnergyONO1VP I 7800 Rochester HwySeneca, SC 29672ONS-01 6003o: 864.873.3274 ONS-206-003f.

864.873.4208 Scott.Batson~duke-energy.com January 20, 2016 10 CFR 50.4ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555Duke Energy Carolina, LLC (Duke Energy)Oconee Nuclear Station, Units 1 and 2Docket Numbers 50-269 and 50-270Renewed License Numbers DPR-38 and DPR-47

Subject:

Notification of Compliance with Order EA-1 2-051, "Order to Modify Licenses WithRegard 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 SpentFuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession No. ML12054A679.

2:- Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request forAdditional Information Regarding Overall Integrated Plan for Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),

dated November 1, 2013 (Accession No.ML1 3298A696).

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 toOrders EA-12-049 And EA-12-051 (TAC NOS. MF0782, 0783, 0784, 0785, 0786, AND0787), 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 reactorlicenses to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of theOrder. This letter, along with its enclosures, provides the notification required by Section IV.C.3of the Order that compliance with the requirements described in Attachment 2 of the Order hasbeen achieved for Oconee Nuclear Station (ONS), Units I and 2.(Note: The Order required that Unit 2 compliance be completed prior to restart from the refueling outage for end-of-cycle 27 (EOC2 7). However, since ONS has a common pool forUnits I and 2, both units were implemented concurrently.)

On November 11, 2015, Unit 2 commenced start-up from the E0C27 refueling outage, whichestablished the EA-12-051 Order compliance date for Units 1 and 2.

ONS-201 6-003January 20, 2016Page 2Attachment 1 provides a brief summary of the key elements associated with compliance toOrder 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 supportclosure.

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 withOconee Regulatory

Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct.

Executed onJanuary 20, 2016.Sincerely, Scott L. BatsonVice President Oconee Nuclear StationAttachments:

1. Oconee Nuclear Station, Units 1 and 2, Summary of Compliance Elements forOrder EA-12-051

2. Oconee Nuclear Station, Units 1 and 2, NRC Audit Report Open and Pending Items ONS-201 6-003January 20, 2016Page 3cc:Ms. Catherine Haney, Regional Administrator U.S. Nuclear Regulatory Commission

-Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257 Mr. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North11555 Rockville PikeRockville, 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-8G9ARockville, MD 20852-2746 Mr. Jeffery Whited(by electronic mail only)U.S. Nuclear Regulatory Commission 11555 Rockville PikeMail Stop O-8BIARockville, MD 20852Mr. Eddy CroweNRC Senior Resident Inspector Oconee Nuclear Station ATTACHMENT 1Oconee Nuclear Station, Units 1 and 2Summary 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."

ThisOrder was effective immediately and directed holders of operating reactor licenses to installreliable 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 commonpool for Units 1 and 2, both units were implemented concurrently.

The information providedherein demonstrates compliance for Oconee Nuclear Station, Units I and 2 related to the Order.COMPLIANCE SUMMARY FOR UNITS 1 AND 2NRC RAI, ISE, and Audit Items -CompleteAll Requests for Additional Information, ISE Open Items and Confirmatory Items, and AuditQuestions/Open Items have been addressed and are considered complete pending NRCclosure.Identification of Levels of Required Monitoring

-CompleteThe three required level indications for monitoring SEP level have been established incompliance with Order EA-12-051 for ONS, Units 1 and 2. These levels are integrated into thesite processes for monitoring SFP during Beyond Design Basis events, including response toloss of SEP inventory.

Instrument Design Features

-CompleteThe modifications to install the Spent Fuel Pool Level Instrumentation have been fullyimplemented on ONS Units 1 and 2 in accordance with the station design control process.

Thedesign 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.

Theinstruments are mounted to retain design configuration during and following the maximumexpected ground motion. The instruments are designed to be reliable at expectedenvironmental and radiological conditions including extended periods when the SEP is atsaturation.

The instruments are independent of each other and have separate and diversepower supplies.

The instruments are designed to maintain their designed accuracy following apower interruption and to allow routine testing and calibration.

The instrument display is readily accessible during postulated events and allows levelinformation to be promptly available to decision makers.Program Features

-CompleteOperating and maintenance procedures for the Spent Fuel Pool Instruments for ONS Units 1and 2 have been developed, and integrated with existing procedures.

These procedures havebeen 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 aremaintained at their design accuracy.

Training for ONS, Units 1 and 2 has been completed using the ONS Systematic Approach toTraining (SAT) as recommended in NEI 12-02, Revision 1, Section 4.1.ONS-201 6-003 Page 1 of 2 ATTACHMENT 1Oconee Nuclear Station, Units 1 and 2Summary of Compliance Elements for Order EA-12-051 REFERENCES Al. NRC Order Number EA-l12-051, Order to Modify Licenses With Regard To Reliable SpentFuel Pool Instrumentation, dated March 12, 2012, (Accession No. ML12054A679).

A2. Oconee Nuclear Station's Overall Integrated Plans in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements for Reliable SpentFuel 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 PoolInstrumentation (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 PoolInstrumentation (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 PoolInstrumentation (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),

datedFebruary 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 PoolInstrumentation (Order Number EA-12-051

), dated August 26, 2015(Accession No. ML15247A069).

A8. Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent FuelPool 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 FederalRecommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights fromthe 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,

'ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."'

Al11. Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request forAdditional Information Regarding Overall Integrated Plan for Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),

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

ONS -20 16-003Pae2f2 Page 2 of 2 ATTACHMENT 2Oconee Nuclear Station Units 1 and 2, NRC Audit Report Open and Pending ItemsDuke Energy contends that ONS, Units I and 2 is in full compliance with Order EA-12-051 as demonstrated by the docketedcorrespondences concerning this order. Briefly, the Request for Additional Information (RAI) items provided in the Spent Fuel PoolLevel 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 withrespect to establishing compliance for ONS Units I and 2:Item " I Description

=* .. .; ", .- ... .,Summary

Response,

, 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 thethe 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 AMdemonstrate the qualification From: Boska, John <John.Boska~nrc.gov>

and reliability of the installed To: Jones, Dana Chandler; Haile, David Guill, Paul Fequipment in accordance Dana,with the order requirements.

We have reviewed the SFPI SAT report. We found it satisfactory and closeditem SRAI-8-D in the SE Tracker file.John BoskaMitigation Strategies

& SEP Instrumentation Project Manager, NRRIJLD/JOMB U.S. Nuclear Regulatory Commission 0NS-2016-003Pae1o1 Page 1 of 1 DUKEscott L. B.tsonVice President ENERGY Qconee Nuc/fear StationDuke EnergyONO1VP I 7800 Rochester HwySeneca, SC 29672ONS-01 6003o: 864.873.3274 ONS-206-003f.

864.873.4208 Scott.Batson~duke-energy.com January 20, 2016 10 CFR 50.4ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555Duke Energy Carolina, LLC (Duke Energy)Oconee Nuclear Station, Units 1 and 2Docket Numbers 50-269 and 50-270Renewed License Numbers DPR-38 and DPR-47

Subject:

Notification of Compliance with Order EA-1 2-051, "Order to Modify Licenses WithRegard 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 SpentFuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession No. ML12054A679.

2:- Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request forAdditional Information Regarding Overall Integrated Plan for Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),

dated November 1, 2013 (Accession No.ML1 3298A696).

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 toOrders EA-12-049 And EA-12-051 (TAC NOS. MF0782, 0783, 0784, 0785, 0786, AND0787), 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 reactorlicenses to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of theOrder. This letter, along with its enclosures, provides the notification required by Section IV.C.3of the Order that compliance with the requirements described in Attachment 2 of the Order hasbeen achieved for Oconee Nuclear Station (ONS), Units I and 2.(Note: The Order required that Unit 2 compliance be completed prior to restart from the refueling outage for end-of-cycle 27 (EOC2 7). However, since ONS has a common pool forUnits I and 2, both units were implemented concurrently.)

On November 11, 2015, Unit 2 commenced start-up from the E0C27 refueling outage, whichestablished the EA-12-051 Order compliance date for Units 1 and 2.

ONS-201 6-003January 20, 2016Page 2Attachment 1 provides a brief summary of the key elements associated with compliance toOrder 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 supportclosure.

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 withOconee Regulatory

Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct.

Executed onJanuary 20, 2016.Sincerely, Scott L. BatsonVice President Oconee Nuclear StationAttachments:

1. Oconee Nuclear Station, Units 1 and 2, Summary of Compliance Elements forOrder EA-12-051

2. Oconee Nuclear Station, Units 1 and 2, NRC Audit Report Open and Pending Items ONS-201 6-003January 20, 2016Page 3cc:Ms. Catherine Haney, Regional Administrator U.S. Nuclear Regulatory Commission

-Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257 Mr. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North11555 Rockville PikeRockville, 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-8G9ARockville, MD 20852-2746 Mr. Jeffery Whited(by electronic mail only)U.S. Nuclear Regulatory Commission 11555 Rockville PikeMail Stop O-8BIARockville, MD 20852Mr. Eddy CroweNRC Senior Resident Inspector Oconee Nuclear Station ATTACHMENT 1Oconee Nuclear Station, Units 1 and 2Summary 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."

ThisOrder was effective immediately and directed holders of operating reactor licenses to installreliable 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 commonpool for Units 1 and 2, both units were implemented concurrently.

The information providedherein demonstrates compliance for Oconee Nuclear Station, Units I and 2 related to the Order.COMPLIANCE SUMMARY FOR UNITS 1 AND 2NRC RAI, ISE, and Audit Items -CompleteAll Requests for Additional Information, ISE Open Items and Confirmatory Items, and AuditQuestions/Open Items have been addressed and are considered complete pending NRCclosure.Identification of Levels of Required Monitoring

-CompleteThe three required level indications for monitoring SEP level have been established incompliance with Order EA-12-051 for ONS, Units 1 and 2. These levels are integrated into thesite processes for monitoring SFP during Beyond Design Basis events, including response toloss of SEP inventory.

Instrument Design Features

-CompleteThe modifications to install the Spent Fuel Pool Level Instrumentation have been fullyimplemented on ONS Units 1 and 2 in accordance with the station design control process.

Thedesign 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.

Theinstruments are mounted to retain design configuration during and following the maximumexpected ground motion. The instruments are designed to be reliable at expectedenvironmental and radiological conditions including extended periods when the SEP is atsaturation.

The instruments are independent of each other and have separate and diversepower supplies.

The instruments are designed to maintain their designed accuracy following apower interruption and to allow routine testing and calibration.

The instrument display is readily accessible during postulated events and allows levelinformation to be promptly available to decision makers.Program Features

-CompleteOperating and maintenance procedures for the Spent Fuel Pool Instruments for ONS Units 1and 2 have been developed, and integrated with existing procedures.

These procedures havebeen 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 aremaintained at their design accuracy.

Training for ONS, Units 1 and 2 has been completed using the ONS Systematic Approach toTraining (SAT) as recommended in NEI 12-02, Revision 1, Section 4.1.ONS-201 6-003 Page 1 of 2 ATTACHMENT 1Oconee Nuclear Station, Units 1 and 2Summary of Compliance Elements for Order EA-12-051 REFERENCES Al. NRC Order Number EA-l12-051, Order to Modify Licenses With Regard To Reliable SpentFuel Pool Instrumentation, dated March 12, 2012, (Accession No. ML12054A679).

A2. Oconee Nuclear Station's Overall Integrated Plans in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements for Reliable SpentFuel 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 PoolInstrumentation (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 PoolInstrumentation (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 PoolInstrumentation (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),

datedFebruary 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 PoolInstrumentation (Order Number EA-12-051

), dated August 26, 2015(Accession No. ML15247A069).

A8. Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent FuelPool 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 FederalRecommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights fromthe 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,

'ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."'

Al11. Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation and Request forAdditional Information Regarding Overall Integrated Plan for Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),

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

ONS -20 16-003Pae2f2 Page 2 of 2 ATTACHMENT 2Oconee Nuclear Station Units 1 and 2, NRC Audit Report Open and Pending ItemsDuke Energy contends that ONS, Units I and 2 is in full compliance with Order EA-12-051 as demonstrated by the docketedcorrespondences concerning this order. Briefly, the Request for Additional Information (RAI) items provided in the Spent Fuel PoolLevel 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 withrespect to establishing compliance for ONS Units I and 2:Item " I Description

=* .. .; ", .- ... .,Summary

Response,

, 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 thethe 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 AMdemonstrate the qualification From: Boska, John <John.Boska~nrc.gov>

and reliability of the installed To: Jones, Dana Chandler; Haile, David Guill, Paul Fequipment in accordance Dana,with the order requirements.

We have reviewed the SFPI SAT report. We found it satisfactory and closeditem SRAI-8-D in the SE Tracker file.John BoskaMitigation Strategies

& SEP Instrumentation Project Manager, NRRIJLD/JOMB U.S. Nuclear Regulatory Commission 0NS-2016-003Pae1o1 Page 1 of 1