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{{Adams
#REDIRECT [[BSEP 15-0009, 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-12-051)]]
| number = ML15075A024
| issue date = 02/27/2015
| title = Brunswick, Units 1 and 2, 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-12-051)
| author name = Gideon W R
| author affiliation = Duke Energy Progress, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person =
| case reference number = BSEP 15-0009, EA-12-051
| document type = Letter
| page count = 8
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:William R. GideonVice PresidentENERGY, Brunswick Nuclear PlantP.O. Box 10429Southport, NC 28461o: 910.457.3698February 27, 2015Serial: BSEP 15-0009U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
 
==Subject:==
Brunswick Steam Electric Plant, Unit Nos. 1 and 2Renewed Facility Operating License Nos. DPR-71 and DPR-62Docket Nos. 50-325 and 50-324Fourth Six-Month Status Report in Response to March 12, 2012, CommissionOrder Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051)
 
==References:==
: 1. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Issuance ofOrder to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,dated March 12, 2012, Agencywide Documents Access and Management System(ADAMS) Accession Number ML1 2054A6792. 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 No. ML12221A3393. NEI 12-02, Industry Guidance for Compliance with NRC Order EA- 12-051, "ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation",Revision 1, dated August 2012, ADAMS Accession No. ML12240A3074. Duke Energy Letter, Carolina Power & Light Company and Florida PowerCorporation's Initial Status Report in Response to March 12, 2012, CommissionOrder Modifying Licenses with Regard to Requirements for Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051), dated October 29, 2012, ADAMSAccession No. ML12307A0205. Duke Energy Letter, Carolina Power and Light Company's Overall Integrated Plansin Response to March 12, 2012, Commission Order Modifying Licenses with Regardto Requirements for Reliable Spent Fuel Pool Instrumentation (Order NumberEA- 12-051), dated February 28, 2013, ADAMS Accession No. ML13086A0966. Duke Energy Letter, First Six-Month Status Reports in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA- 12-05 1), dated August 26, 2013, ADAMSAccession No. ML13242A010 U.S. Nuclear Regulatory CommissionPage 2 of 37. Duke Energy Letter, Second Six-Month Status Report in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Reliable Spent FuelPool Instrumentation (Order Number EA- 12-05 1), dated February 27, 2014, ADAMSAccession No. ML14073A0638. Duke Energy Letter, Third Six-Month Status Report in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051), dated August 28, 2014, ADAMSAccession No. ML14254A176Ladies 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 immediatelyeffective and directs Duke Energy to have a reliable indication of water level in associated spentfuel 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 thefinal interim staff guidance (i.e., Reference 2) and an Overall Integrated Plan (OIP) pursuant toSection 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 Duke Energy initial status report regarding spent fuel poolinstrumentation. Reference 5 provided the Duke Energy OIP.Reference 1 required submission of a status report at six-month intervals following submittal ofthe OIP. Reference 3 provides direction regarding the content of the status reports.References 6, 7, and 8 provided the first, second, and third 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 fourth six-month status report pursuant to Section IV,Condition C.2, of Reference 1. The enclosed report provides an update of milestoneaccomplishments since the last status report, including any changes to the compliance method,schedule, or need for relief and the basis, if any.This letter contains no new regulatory commitments.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 February 27, 2015.SinceWilliam R. Gideon
 
==Enclosure:==
Fourth Six-Month Status Report in Response to March 12, 2012, CommissionOrder Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 U.S. Nuclear Regulatory CommissionPage 3 of 3cc (with enclosure):U.S. Nuclear Regulatory Commission, Region IIATTN: Mr. Victor M. McCree, Regional Administrator245 Peachtree Center Ave, NE, Suite 1200Atlanta, GA 30303-1257U.S. Nuclear Regulatory CommissionATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville PikeRockville, MD 20852-2738U.S. Nuclear Regulatory CommissionATTN: Mr. Peter Bamford (Mail Stop OWFN 8B3) (Electronic Copy Only)11555 Rockville PikeRockville, MD 20852-2738U. S. Nuclear Regulatory CommissionATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector8470 River RoadSouthport, NC 28461-8869Chair -North Carolina Utilities CommissionP.O. Box 29510Raleigh, NC 27626-0510 ENCLOSUREFOURTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012,COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUELPOOL INSTRUMENTATION (ORDER NUMBER EA-12-051)BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS. 1 AND 2DOCKET NOS. 50-325 AND 50-324RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62Page 1 of 5 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051)1 IntroductionBrunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)(Reference 1 in Section 7), documenting the requirements to install reliable spent fuel pool levelinstrumentation in response to NRC Order EA-12-051. The OIP was submitted to the NRC onFebruary 28, 2013. The first six-month update was provided to the NRC on August 26, 2013(Reference 2 in Section 7). The second six-month update was provided to the NRC onFebruary 27, 2014 (Reference 3 in Section 7). The third six-month update was provided to theNRC on August 28, 2014 (Reference 4 in Section 7). This enclosure provides an update ofmilestone accomplishments since submittal of the third six-month update, including anychanges to the compliance method, schedule, or need for relief/relaxation and the basis, if anythat occurred during the period from July 28, 2014, and January 28, 2015, (hereafter referred toas "the update period").2 Milestone AccomplishmentsThe following milestones were completed during the update period:0 Submit Third Six-Month Status Report3 Schedule StatusNo changes were made to the schedule as reported in Reference 1 of Section 7.4 Changes to Compliance MethodNo changes to the compliance method were made during the update period.5 Need for Relief/Relaxation and Basis for the Relief/RelaxationBSEP expects to comply with the order implementation date and no relief/relaxation is requiredat this time.Page 2 of 5 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051)6 Open Items from Overall Integrated Plan and Interim Staff EvaluationThere are no open items documented in the OIP or in the Interim Staff Evaluation (ISE). TheISE received (Reference 9 in Section 7) included Request for Additional Information (RAI).Reference 10 instructs that responses to the RAI do not need to be formally submitted on thedocket but instead to place the response in the BSEP ePortal. Following the NRC Audit, twoRAI's remain open. Those items are:NRC Audit Open RAI's I Status1. SFPI RAI.10Please provide the following:a) A description of the capability and provisions theproposed level sensing equipment will have to enableperiodic testing and calibration, including how thiscapability enables the equipment to be tested in-situ.b) A description of how such testing and calibration willenable the conduct of regular channel checks of eachindependent channel against the other, and against anyother permanently-installed SFP level instrumentation.c) A description of how functional checks will beperformed, and the frequency at which they will beconducted. Describe how calibration tests will beperformed, and the frequency at which they will beconducted. Provide a discussion as to how thesesurveillances will be incorporated into the plantsurveillance program.d) A description of what preventive maintenance tasksare required to be performed during normal operation,and the planned maximum surveillance interval that isnecessary to ensure that the channels are fullyconditioned to accurately and reliably perform theirfunctions when needed.(This information was previously requested as RAI-8 inNRC letter dated May 23, 2013)Post response to BSEPePortal by 3/6/2015.Page 3 of 5 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051)NRC Audit Open RAI'sStatus2. SFPI RAI.13Please provide the following:a) Further information describing the maintenance andtesting program the licensee will establish andimplement to ensure that regular testing and calibrationis performed and verified by inspection and audit todemonstrate conformance with design and systemreadiness requirements. Include a description of yourplans for ensuring that necessary channel checks,functional tests, periodic calibration, and maintenancewill be conducted for the level measurement system andits supporting equipment.b) A description of how the guidance in NEI12-02section 4.3 regarding compensatory actions for one orboth non-functioning channels will be addressed.c) A description of what compensatory actions areplanned in the event that one of the non-functioninginstrument channels cannot be restored to functionalstatus within 90 days.(This information was previously requested as RAI-1 1 inNRC letter dated May 23, 2013)Post response to BSEPePortal by 3/6/2015.Page 4 of 5 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-051)7 ReferencesThe following references support the updates to the Overall Integrated Plan described in thisenclosure.1. Duke Energy Letter, Carolina Power & Light Company's Overall Integrated Plans inResponse to March 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-05 1),dated February 28, 2013, ADAMS Accession No. 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 PoolInstrumentation (Order Number EA- 12-051), Dated August 26, 2013, ADAMS AccessionNo. 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 PoolInstrumentation (Order Number EA-12-051), dated February 27, 2014, ADAMSAccession No. 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 PoolInstrumentation (Order Number EA- 12-051), dated August 28, 2014, ADAMS AccessionNo. ML14254A176.5. NRC Order Number EA-12-051, Issuance of Order to Modify Licenses with Regard toReliable Spent Fuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession No.ML12054A679.6. 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, ADAMSAccession No. ML12221A339.7. NEI 12-02, Industry Guidance for Compliance with NRC Order EA- 12-05 1, "To ModifyLicenses with Regard to Reliable Spent Fuel Pool Instrumentation"' Revision 1, datedAugust 2012, ADAMS Accession No. ML12240A307.8. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation'sInitial Status Report in Response to March 12, 2012, Commission Order ModifyingLicenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation(Order Number EA-12-05 1), dated October 29, 2012, ADAMS Accession No.ML12307A020.9. NRC letter, Brunswick Steam Electric Plant, Units 1 and 2 -Interim Staff Evaluation andRequest for Additional Information Regarding the Overall Integrated Plan forImplementation of Order EA- 12-051, Reliable Spent Fuel Pool Instrumentation (TACNos. MF0973 AND MF0974), dated November 18, 2013, ADAMS Accession No.ML13269A34510. Duke Energy Letter, Response to Request for Additional Information Regarding OverallIntegrated Plan Submitted in Response to the Commission Order Modifying LicensesWith Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), dated July 22, 2013, ADAMS Accession No. ML13219B1317Page 5 of 5}}

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