RNP-RA/04-0114, Letter from J. F. Lucas to the USNRC, Subject: H.B. Robinson Steam Electric Plant, Unit No. 2 Independent Spent Fuel Storage Installation - Twenty-day Response to Order EA-03-097

Letter from J. F. Lucas to the USNRC, Subject: H.B. Robinson Steam Electric Plant, Unit No. 2 Independent Spent Fuel Storage Installation - Twenty-day Response to Order EA-03-097

ML053430101
Person / Time
Site:	Robinson, 07200003
Issue date:	09/03/2004
From:	Lucas J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
EA-03-097, FOIA/PA-2005-0047, RNP-RA/04-0114
Download: ML053430101 (3)

Text

-PRtOPMETARY-03 Progress Energy Serial: RNP-RA/04-0114 10 CFR 72 SEP 032004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCET NO. 72-3/LICENSE NO. SNM-2502 TWENTY-DAY RESPONSE TO ORDER EA-03-097, IMPLEMENTATION OF ADDITIONAL SECURITY MEASURES ASSOCIATED WITH ACCESS AUTHORIZATION FOR H. B. ROBINSON STEAM ELECTRIC PLANT. UNIT NO. 2 Ladies and Gentlemen:

On August 18, 2004, the U. S. Nuclear Regulatory Commission (NRC) issued an Order modifying the license for the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, independent spenit fuel stora.ge installation (JSFSI). In the Order, Section IELB., the NRC requires that, within 20 day', ta.obina Power and Light 'Company, now doIgbusineissll Progress Energy 'Carolinas, Inc. (PEC), notify the NRC (ii if PEC is uinabie t6'c '"lywith any of the requirements described in Attachment 1 of the Order, (2) if compliance with any of the requirements is unnecessary in PEC's specific circumnstance&, or (3) if implementation of any of the.requirements would cause PEC to be in viA61tibn of the&'prv6is sbf any Commission regulation or the facility'iien6i; PEC hasteviewed the Ord'er ati'has concridddt itiiiis'ble to comply with the requirements descr6ibedin Attac'hment iof the Order, and that conliianle with these additional security measure.s (ASMs) will not cause PEC to be in violation of any NRC regulations or.the facility lkiice.

Section M.B.2 of the Order requires PEC to notify the NRC within 20 days if implementation of any of the requirements of Attachment 1 of the Order would adversely impact the safe storage of spent fuel. PEC has reyiewed the Order and concluded that compliance with the ASMs will not adversely impact the safe.sqorage of spent.fuel.

Section III.C.1 of the Ordei recquires FEC, within 20 days, to submit to tie NRC iiche'dule for achieving compliance with' ech re4uirementr described in Attaclirient 1'of tie"Oider. Sectidn m.C.2 of the Order requires PEG to report . to bie NRC: ..

whenVfull

. en..m.6 ..

&coiplian.with

,~ t

'he t.

requirements of Attachment 1 of the Order has been achieved.'

The HBRSEP, Unit No. 2, ISFSI islocated at the samne ite as the operating power reactor,

• HBRSEP, Unit No. 2 (Docket No.50-261.LMcense No. DPR-23). Aitabhrhent f, Section A.2, of Progress Energy Carolinas, Inc.

Robinson Nulear Plant 3581 West Entrance Road Hartsville. SC29550

-PROPRITARY U. S. Nuclear Regulatory Commission Serial: RNP-RA/04-0114 Page 2 of 3 the Order allows PEC the option of implementing the compensatory measures (CMs) of Order EA-02-261, "Issuance of Order for Compensatory Measures Related to Access Authorization,"

issued January 7, 2003, as an alternate means of complying with the ASMs of Order EA-03-097.

PEC's implementation of the CMs provided in Order EA-02-261 constitutes the method of achieving compliance with the ASMs provided in Order EA-03-097. By letter dated February 3, 2004, Progress Energy, Inc., notified the NRC that BBRSEP, Unit No. 2, was in full compliance with the CMs provided in Order EA-02-261. Therefore, HBRSEP, Unit No.2, has achieved full compliance with the ASMs of Order EA-03-097.

This letter does not contain safeguards information and is not subject to 10 CFR 73.21 restrictions. However, this letter does contain information concerning physical protection for the HBRSEP, Unit No. 2, ISFS1. Therefore, PEC requests that this letter be withheld from public disclosure in accordance with 10 CFR 2.390(d)(1).

Please refer questions regarding this submittal to Mr. William Guthrie, Superintendent -

Security, at (843) 857-1241.

Sincerely, 62v,6~ 4 J. F. Lucas Manager - Support Services -Nuclear H. B. Robinson Steam Electric Plant, Unit No. 2

U. S. Nuclear Regulatory Commission Serial: RNP-RA/04-0114 Page 3 of 3 Affirmation The information contained in letter RNP-RA/04-0114 is true and correct to the best of my information, knowledge, and belief; and the sources of my information are officers, employees, contractors, and agents of Progress Energy Carolinas, Inc., also known as Carolina Power and Light Company. I declare under penalty of perjury that the foregoing is true and correct.

Executed On: 3 $ O4 H.B.resi Sent H. B. Robinson Steam Electric Plant, Unit No. 2 JMG/jmg C: Dr. W. D. Travers, NRC, Region 11 J. R. Strosnider, NRC, NMSS NRC Resident Inspector, HBRSEP C. P. Patel, NRC, NRR