ML093170717

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Comments on Draft NRC Safety Evaluation for Acceptance of Reactor Protective System and Engineered Safeguards Protective System Digital Upgrade
ML093170717
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 11/05/2009
From: Baxter D
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML093170717 (3)


Text

Duke DAVE BAXTER Vice President Energy.

Oconee Nuclear Station Duke Energy ONOl VP / 7800 Rochester Highway Seneca, SC 29672 864-873-4460 864-873-4208 fax dabaxter@dukeenergy.com November 5, 2009 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Duke Comments on Draft NRC Safety Evaluation for Acceptance of the Oconee Reactor Protective System and Engineered Safeguards Protective System Digital Upgrade The Nuclear Regulatory Commission (NRC) provided a draft Safety Evaluation (SE) for Acceptance of the Oconee Nuclear Station (ONS) Reactor Protective System (RPS) and Engineered Safeguards Protective System (ESPS) Digital Upgrade to Duke Energy Carolinas, LLC (Duke) by letter dated October 23, 2009. Duke submitted the License Amendment Request (LAR) associated with this SE by letter dated January 31, 2008.

The letter transmitting the draft SE states that Duke must identify any proprietary information line-by-line and define the basis pursuant to the criteria of 10 CFR 2,390 within 10 working days of the letter. Duke's review concluded that the draft.SE does not contain any business proprietary information. However, Section 3.6 of the draft SE contains security sensitive information. The enclosure identifies, line-by-line, the information contained -in Section 3.6 that is security sensitive. The information identified as security sensitive is consistent with Duke's RPS/ESPS cyber security submittal dated January 30, 2008, and associated Request for Additional Information (RAI) responses. The text identified provides details of design features that secure the RPS/ESPS from electronic vulnerabilities. As such, Duke considers the draft SE information identified in the enclosure to be sensitive information and requests that it be withheld from public disclosure pursuant to 10 CFR 2.390.

Duke will provide comments on factual errors or clarity concerns contained in the draft SE within the 20 working days allowed by the transmittal letter. Thus far, Duke has identified a sufficient number of editing and formatting errors that NRC may want to make corrections prior to placing the draft SE in the public document room.

Enclosure Contains Security Sensitive Information-Withhold under 10 CFR 2.390.

Upon removal of enclosure, this letter is uncontrolled.

A* D(

www. duke-energy. com

U. S. Nuclear Regulatory Commission November 5, 2009 Page 2 If there are any questions regarding this submittal, please contact Boyd Shingleton at (864) 873-4716.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 5, 2009.

Sincerely, D)ave Ba er, Vice President Oconee uclear Station Enclosure Enclosure Contains Security Sensitive Information-Withhold under 10 CFR 2.390.

Upon removal of enclosure, this letter is uncontrolled.

U.. S. Nuclear Regulatory Commission November 5, 2009 Page 3 cc:

Mr. J. F. Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C. 20555 Mr. L. A. Reyes, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. A. T. Sabisch Senior Resident Inspector (Acting)

Oconee Nuclear Station S. E. Jenkins, Manager Infectious and Radioactive Waste Management Section 2600 Bull Street Columbia, SC 29201 Enclosure Contains Security Sensitive Information-Withhold under 10 CFR 2.390.

Upon removal of enclosure, this letter is uncontrolled.