BSEP 15-0064, 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)

ML15246A033
Person / Time
Site:	Brunswick
Issue date:	08/26/2015
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 15-0064, EA-12-051
Download: ML15246A033 (8)

Text

S DUKE ENERGY Brunswick ado Vice President Boxea Plant Southport, NC 28461 o: 910.457.3698 August 26, 2015 Serial: BSEP 15-0064 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 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-1 2-051)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession Number ML12054A679

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12221A339

3. 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, ADAMS Accession Number ML12240A307

4. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation'sInitial Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (OrderNumber EA- 12-05 1), dated October 29, 2012, ADAMS Accession Number ML12307A020

5. Duke Energy Letter, Carolina Power and Light Company'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-12-05 1), dated February 28, 2013, ADAMS Accession Number ML13086A096

6. Duke Energy Letter, First Six-Month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA- 12-05 1), dated August 26, 2013, ADAMS Accession Number ML13242A010

U.S. Nuclear Regulatory Commission Page 2 of 4

7. 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 27, 2014, ADAMS Accession Number ML14073A063

8. 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 28, 2014, ADAMS Accession Number ML14254A404

9. 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 (OrderNumber EA- 12-05 1), dated February 27, 2015, ADAMS Accession Number ML15075A024

10. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and OrderEA-12-051, "Orderto Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation"for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (i.e.,

Reference 1) to Duke Energy Progress, Inc. (Duke Energy). Reference 1 was immediately effective and directs Duke Energy to have a reliable indication of water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (i.e., Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (i.e., Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the initial status report regarding mitigation strategies at the Brunswick, Robinson, and Shearon Harris Nuclear Power Plants. Reference 5 provided the OIP for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports.

References 6, 7, 8, and 9 provided the first, second, third, and fourth six-month status reports, respectively, for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. This status report also includes an update to milestone accomplishments that confirms full compliance with Order EA-1 2-051, for BSEP, Unit 2 (i.e., Reference 10).

This letter contains no new regulatory commitments.

U.S. Nuclear Regulatory Commission Page 3 of 4 If you have any questions regarding this submittal, please contact Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

I declare under penalty of perjury that the foregoing is true and correct, executed on August 26, 2015.

William R. Gideon

Enclosure:

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),

Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2

U.S. Nuclear Regulatory Commission Page 4 of 4 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Aye, NE, Suite 1200 Atlanta, GA 30303-1 257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop OWEN 8B3) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

ENCLOSURE 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)

BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62 Page 1 of 4

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051) 1Introduction Note: References are provided in Section 7 of this enclosure.

Brunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)

(Reference 1), documenting the requirements to install reliable spent fuel pool level instrumentation in response to Nuclear Regulatory Commission (NRC) Order EA-12-051.

The OIP was submitted to the NRC on February 28, 2013. The first six-month update was provided to the NRC on August 26, 2013 (Reference 2). The second six-month update was provided to the NRC on February 27, 2014 (Reference 3). The third six-month update was provided to the NRC on August 28, 2014 (Reference 4). The fourth six-month update was provided to the NRC on February 27, 2015 (Reference 5). This enclosure provides an update of milestone accomplishments since submittal of the fourth six-month update, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, that occurred during the period from January 28, 2015, and July 28, 2015, (hereafter referred to as '"the update period"). This status report also includes an update to milestone accomplishments that confirms full compliance with Order EA-1 2-051, for BSEP, Unit 2 (Reference 6).

2 Milestone Accomplishments The following milestones were completed during the update period:

• Submit Fourth Six-Month Status Report

• Full compliance with Order EA-12-051, for BSEP, Unit 2 3 Milestone Schedule Status No changes were made to the schedule as reported in Section 7 of Reference 1.

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

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

Page 2 of 4

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051) 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation All open items from the OIP or the Interim Staff Evaluation (ISE) are closed.

7 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Duke Energy Letter, Carolina Power & Light Company'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-12-05 1),

dated February 28, 2013, ADAMS Accession Number ML13086A096

2. Duke Energy Letter, First Six-month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-05 1), Dated August 26, 2013, ADAMS Accession Number ML13242A010

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(Order Number EA-12-05 1), dated February 27, 2014, ADAMS Accession Number ML14073A063

4. 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 28, 2014, ADAMS Accession Number ML14254A404

5. 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-12-05 1), dated February 27, 2015, ADAMS Accession Number ML15075A024

6. Duke Energy Letter, Notification of Full Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and Order EA- 12-05 1, "Orderto Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation"for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013

7. NRC letter, Brunswick Steam Electric Plant, Units 1 and 2 - Interim Staff Evaluation and Request for Additional Information Regardingthe Overall IntegratedPlan for Implementation of OrderEA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MFO973 AND MF0974), dated November 18, 2013, ADAMS Accession Number ML13269A345 Page 3 of 4

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051)

8. Duke Energy Letter, Response to Request for Additional In formation Regarding Overall IntegratedPlan Submitted in Response to the Commission Order Modifying Licenses With Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-051), dated July 22, 2013, ADAMS Accession Number ML13219B117

9. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS)

Accession Number ML12054A679

10. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12221A339.

11. NEI 12-02, Industry Guidance for Compliance with NRC OrderEA-12-.051, "T-o Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'; Revision 1, dated August 2012, ADAMS Accession Number ML12240A307

12. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-05 1), dated October 29, 2012, ADAMS Accession Number ML12307A020 Page 4 of 4