RNP-RA/15-0015, Fourth Six-Month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Fourth Six-Month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML15082A016
Person / Time
Site:	Robinson
Issue date:	02/23/2015
From:	Glover R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RNP-RA/15-0015, TAC MF0793
Download: ML15082A016 (6)

Text

~ENERGY, R. Michael Glover H. B. Robinson Steam Electric Plant Unit 2 Site Vice President Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0: 843 857 1701 F: 843 857 1319 Mike.Glover@duke-energy.com 10 CFR 50.4 Serial: RNP-RA/15-0015 February 23, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/ RENEWED LICENSE NO. DPR-23

Subject:

Fourth Six-Month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A679)

2. NRCJnterim 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. ML12221A339)

3.

NEI 12-02, Industry Guidance for Compliance with.NRC Order EA-12-051, "To Modify Licenses with Regardto Reliablet Spent Fuel Pool Instrumentation",- Revision 1, dated August 20.12 (ADAMS Accession. No. ML12240A307) :

4. Duke Energy Letter, Carolina Power & Light. Company and. Florida Power Corporation's Initial Status Report in Response to March. 1.2, 2012, Commission Order, Modifying Licenses with Regard to Requirements for Reliable.:Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 29, 2012 (ADAMS Accession No. ML12307A020)

5. Duke Energy Letter, Carolina Power & Light Company's Overall Integrated Plans in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-05 1),

dated February-28, 2013.(ADAMS,Accession No. ML13086A096)

6. NRC Letter,.,H. B. Robinson Steam Electric Plant, Unit 2 -Interim Staff Evaluation and Request for Additional Information. Regarding the Overall Integrated Plan.for Implementation, of Order EA-12-05.1, Reliable. Spent Fuel Pool Instrumentation (TAC NO.

MF0793), Dated November 19, 2013 (ADAMS Accession No. ML13273A481)

7. NRC -Letter, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel;Pool Instrumentation Order EA-12-05.1;,, Dated March 26, 2014 (ADAMS Accession No. ML14083A620).

. i"

U.S. Nuclear Regulatory Commission Serial: RNP-RA/15-0015 Page 2 of 3 Ladies and Gentlemen, On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to Duke Energy Progress, Inc.. Reference 1 was immediately effective and directs Duke Energy to have a reliable indication of water level in associated spent fuel 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 the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the Duke Energy initial status report regarding spent fuel pool instrumentation.

Reference 5 provided the Duke Energy OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports.

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 milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

By Letter dated November 19, 2013 (Reference 6), the NRC provided an Interim Staff Evaluation (ISE) which included a Request for Additional Information (RAI) to H. B. Robinson Steam Electric Plant, Unit No. 2. In accordance with Reference 7, NRC advised each licensee participating in the audit not to formally submit their RAI responses on the docket but instead, put their responses and any other supporting information on their ePortals by the date identified in their ISE to support the staffs review process. Duke Energy's response to the H. B.

Robinson RAI's was placed in the ePortal by September 30, 2014.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact Mr. Richard Hightower, Manager, Nuclear Regulatory Affairs at (843) 857-1329.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on "02I/OI5" Sincerely, R. Michael Glover Site Vice President

U.S. Nuclear Regulatory Commission Serial: RNP-RA/15-0015 Page 3 of 3

Enclosure:

Fourth Six-Month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) cc:

Ms. M. C. Barillas, NRC Project Manager, NRR Mr. K. M. Ellis, NRC Senior Resident Inspector Mr. V. M. McCree, NRC Region II Administrator

Enclosure to Serial: RNP-RA/15-0015 Page 1 of 3 ENCLOSURE H. B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 Renewed License No. DPR-23 Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

Enclosure to Serial: RNP-RAI15-0015 Page 2 of 3 1

Introduction H. B. Robinson Steam Electric Plant, Unit No. 2 developed an Overall Integrated Plan (OIP)

(Reference 1), documenting the requirements to install reliable spent fuel pool level instrumentation in response to NRC Order EA-12-051(Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the third 6-month update, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any that occurred during the period from July 31, 2014 to January 28, 2015 (hereafter referred to as "the update period").

2 Milestone Accomplishments No new milestones were completed during the update period.

3 Milestone Schedule Status There are no changes to the schedule as reported in Reference 1.

4 Changes to Compliance Method No changes were made during the update period.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation H. B. Robinson Steam Electric Plant, Unit No. 2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation There are no open items documented in the OIP or in the Interim Staff Evaluation (ISE). The ISE (Reference 3) included a Request for Additional Information (RAI). Reference 4 instructs that responses to the RAI do not need to be formally submitted on the docket but instead to place the response in the H. B. Robinson ePortal. Response to the RAI has been placed in the H. B. Robinson Steam Electric Plant, Unit No. 2 ePortal.

Enclosure to Serial: RNP-RA/15-0015 Page 3 of 3 7

References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Duke Energy Letter, Carolina Power & Light Company's Overall Integrated Plans in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February 28, 2013

2. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012

3. NRC Letter, H. B. Robinson Steam Electric Plant, Unit 2 -Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO.

MF0793), Dated November 19, 2013 (ADAMS Accession No. ML13273A481)

4. NRC Letter, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, Dated March 26, 2014 (ADAMS Accession No. ML14083A620)