RA-12-015, Carolina Power & Light Company'S Answer to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Carolina Power & Light Company'S Answer to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

ML12102A015
Person / Time
Site:	Brunswick
Issue date:	04/02/2012
From:	Duncan R Carolina Power & Light Co, Progress Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-050, RA-12-015
Download: ML12102A015 (2)

Text

~JProgress Energy 10 CFR 50.4 411 Fayetteville Street Mall Raleigh NC 27602 Serial: RA-12-015 April 2, 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 CAROLINA POWER & LIGHT COMPANY'S ANSWER TO MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS (ORDER NUMBER EA-12-050)

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an immediately effective order in the captioned matter entitled Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Effective Immediately) ("Order") to, inter alia, Carolina Power & Light Company (CP&L). The orders state that, as a result of the NRC's evaluation of the lessons learned from the accident at Fukushima Dai-ichi in March 2011, the NRC has decided to direct nuclear power plant licensees and construction permit holders to take certain actions. Specifically with respect to this Order, the NRC has decided to require 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 Station Blackout (SBO). Specific requirements for reliable hardened vents are outlined in Attachment 2 to the Order.

The Order requires submission of an overall integrated plan, including a description of how compliance with the requirements described in Attachment 2 will be achieved, to the NRC for review by February 28, 2013. In addition, the Order requires submission of an initial status report 60 days following issuance of the final interim staff guidance and at six month intervals following submittal of an overall integrated plan on February 28, 2013. The Order states that the NRC intends to issue the interim staff guidance containing specific details on implementation of the requirements of this order in August 2012. Finally, the order requires full implementation of its requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

The Order also states that the Commission also intends to decide, after receipt of a Policy Paper from the NRC staff, whether to also require installation of filtration systems on these hardened vent systems. Order at Section II, p. 5. The Policy Paper is scheduled to be delivered by July 2012. The full extent of work necessary to implement this Order cannot be known until after Commission action after review of the staff's July 2012 Policy Paper.

Pursuant to 10 CFR 2.202 and the terms specified in the Order, CP&L hereby submits its answer to the Order. CP&L consents to the Order and does not request a hearing. Based on information currently available, CP&L has not identified any circumstances of the type kb "14.

United States Nuclear Regulatory Commission RA-12-015 Page 2 described in Sections IV.B. 1 and IV.B.2 of the Order requiring relief at this time. In addition, CP&L has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the integrated plan, or December 31, 2016, whichever is earlier.

CP&L will provide further responses as required by Section IV.C. in accordance with the specified deadlines. However, given the uncertainties associated with the ultimate scope of required work caused by the unavailability of implementing guidance until August 2012, and the impact on the ability of CP&L to comply with the specific compliance deadline dates based on the probable availability of that guidance, CP&L'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.

This letter contains no new commitments.

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

I declare under the penalty of perjury that the foregoing is true and correct. Executed on April 2, 2012.

Sincerely, Robert J. Duncan II Vice President - Nuclear Operations Progress Energy, Inc.

DBM cc: USNRC Region II USNRC Director, Office of Nuclear Reactor Regulation USNRC Resident Inspector - BSEP, Unit Nos. 1 and 2 F. Saba, NRR Project Manager - BSEP, Unit Nos. 1 and 2; CR3