RA-12-039, Carolina Power & Light Company & Florida Power Corporation'S Initial Status Report in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Eve

Carolina Power & Light Company & Florida Power Corporation'S Initial Status Report in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Even

ML12307A021
Person / Time
Site:	Harris, Brunswick, Crystal River, Robinson
Issue date:	10/29/2012
From:	Waldrep B Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RA-12-039
Download: ML12307A021 (3)

Text

Benjamin C. Waldrep Duke 526 South Church Street rfEnergyo Charlotte, NC 28202 MailingAddress:

Mail Code EC07H/P.O. Box 1006 Charlotte,NC 28201-1006 704-382-8162 704-382-4541 fax 10 CFR 50.4 Serial: RA-12-039 October 29, 2012 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / RENEWED LICENSE NOS. DPR-71 AND DPR-62 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

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 MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)

REFERENCE:

1. NRC Order Number EA- 12-049, Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-Basis External Events

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012

3. Nuclear Energy Institute (NEI) Letter to NRC, Industry Initiative on Procurementof Equipmentfor the Diverse and Flexible Coping Strategy (FLEX), dated February 24, 2012

4. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Carolina Power & Light Company (CP&L) and Florida Power Corporation (FPC). Reference 1 was immediately effective and directs CP&L and FPC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, www.duke-energy.com M

United States Nuclear Regulatory Commission RA-12-039 Page 2 containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an initial status report 60 days following issuance of the final interim staff guidance. The final interim staff guidance (Reference 2) was issued August 30, 2012. The purpose of this letter is to provide the initial status report pursuant to Section IV, Condition C.2, of Reference I within 60 days following issuance of Reference 2.

This report confirms CP&L and FPC have received Reference 2 and are in the process of evaluating the guidance for the purpose of establishing mitigation strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event as described in Attachment 2 of Reference 1.

Major activities during this reporting period:

" Additional portable equipment was ordered prior to the issuance of Reference 2, as described in an NEI letter to the NRC (Reference 3).

" A site-specific evaluation is in progress to establish the coping capabilities as defined in NEI 12-06 (Reference 4).

" Resources are being identified and project plans initiated, including development of milestones, to assure compliance with Reference 1.

Planned activities for the next six months:

0 Development and submittal of the overall integrated plan.

Technical difficulties encountered that could affect the ability to provide the licensee's February 28, 2013, submittal:

9 None at this time.

Project milestones schedule through completion of installation and testing:

" A project milestones schedule will be provided with the overall integrated plan.

" Implementation of the order will be completed for the following units as indicated below.

Unit Prior to startup from Refueling Outage (RFO) or By Brunswick Steam Electric Plant, Unit Nos. 1 B 121 (Spring 2016)

Brunswick Steam Electric Plant, Unit Nos. 2 B222 (Spring 2015)

Crystal River Unit 3 Nuclear Generating Plant December 31, 2016 Shearon Harris Nuclear Power Plant, Unit No. I H 119 (Spring 2015)

H. B. Robinson Steam Electric Plant, Unit No. 2 R229 (Spring 2015)

This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact Donna Alexander, Manager, Nuclear Regulatory Affairs, at (919) 546-5357.

United States Nuclear Regulatory Commission RA-12-039 Page 3 I declare under the penalty of perjury that the foregoing is true and correct. Executed on October 29, 2012.

Sincerely, Benjamin Wa drep Vice President Corporate Governance and Operations Support DBM cc: USNRC Region HI,Regional Administrator USNRC Resident Inspector - BSEP, Unit Nos. 1 and 2 USNRC Resident Inspector - CR3 USNRC Resident Inspector - SHNPP, Unit No. I USNRC Resident Inspector - HBRSEP, Unit No. 2 USNRC Director, Office of Nuclear Reactor Regulation F. Saba, NRR Project Manager - BSEP, Unit Nos. 1 and 2; CR3 A. T. Billoch Col6n, NRR Project Manager - SHNPP, Unit No. 1; HBRSEP, Unit No. 2 Jessica A. Kratchman, NRR/JLD/PMB, NRC Eric E. Bowman, NRR/DPR/PGCB, NRC