BSEP 13-0064, Duke Energy'S Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

Duke Energy'S Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

ML13191A567
Person / Time
Site:	Brunswick
Issue date:	06/17/2013
From:	Hamrick G Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 13-0064, EA-13-109
Download: ML13191A567 (3)

Text

George T. Hamrick

~DUKE Vice President ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 June 17, 2013 Serial: BSEP 13-0064 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 / Renewed License Nos. DPR-71 and DPR-62 Duke Energy's Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-1 3-109)

Ladies and Gentlemen:

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an immediately effective Order to all licensees that operate boiling-water reactors (BWRs) with Mark I and Mark II containment designs, including Duke Energy Progress, Inc., formerly known as Carolina Power

& Light Company (CP&L), entitled "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Effective Immediately)." Order EA-1 3-109 rescinds an order issued by the NRC on March 12, 2012 (EA-12-050), that required all BWRs with Mark I and Mark II containments to take certain actions to ensure the operability of a reliable hardened vent system to remove decay heat and maintain control of containment pressure following events that result in loss of active containment heat removal capability or prolonged loss of AC power.

Order EA-13-109 requires Duke Energy to install hardened containment venting systems that can be maintained functional during severe accident conditions, i.e. following significant core damage. The substantive requirements of the Order are contained in Attachment 2. The Order includes two separate implementation phases. Phase 1 includes modifications to wetwell venting systems, while Phase 2 includes modifications to drywell venting systems or implementation of a reliable containment strategy that meets regulatory approval. Duke Energy is required to submit an overall integrated plan describing how compliance with Phase 1 will be achieved to the NRC by June 30, 2014, and is required to complete full implementation of Phase 1 requirements no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever is sooner. EA-13-109 also requires Duke Energy to submit an overall integrated plan describing how compliance with Phase 2 will be achieved to the NRC by December 31, 2015, and full implementation of Phase 2 requirements must be complete no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever is sooner.

The NRC states in the Order that it anticipates issuing implementation guidance for Phase 1 by October 31, 2013, and for Phase 2 by April 30, 2015. Upon issuance of the implementation guidance, Duke Energy understands that it will have twenty days to assess the impact of the guidance and notify the NRC of any challenges with implementation of the order in accordance with Paragraph IV.C of the Order.

U.S. Nuclear Regulatory Commission Page 2 of 3 Pursuant to 10 CFR 2.202(a)(2), Duke Energy hereby submits its answer to the Order. Duke Energy consents to Order EA-13-109 and does not request a hearing. However, because implementing guidance is not expected to be available until October 31, 2013, for Phase 1 and April 30, 2015, for Phase 2, there remain significant uncertainties about the scope of the work that will be required by EA-1 3-109. As a result, Duke Energy is unable to state with certainty that it will be able to meet all of the specified compliance deadlines in the Order. As such, Duke Energy's future responses may include requests for schedule relief as warranted by subsequent NRC requirements or implementing guidance or the results of engineering analyses not yet performed. Any such request would be submitted in accordance with the relaxation provision in Section IV of the Order.

Because EA-12-050 is rescinded by EA-13-109, Duke Energy understands that all implementation deadlines and submittal requirements for EA-12-050 are no longer in force. As such, Duke Energy considers the integrated plan that was submitted to the NRC on February 28, 2013, to be withdrawn, and no further action is required by Duke Energy with respect to that submittal or any other requirement specific to EA-12-050.

This letter contains no new commitments.

If you have any questions or require additional information, please contact Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on June 17, 2013.

Sincerely, George T. Hamrick PSF/psf

U.S. Nuclear Regulatory Commission Page 3 of 3 cc:

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Christopher Gratton (Mail Stop OWFN 8G9A) 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