BVY 12-022, Entergys Answer to the March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Entergys Answer to the March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML12094A043
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	03/30/2012
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 12-022, EA-12-051
Download: ML12094A043 (3)

Text

Entergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 12-022 March 30, 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

REFERENCE:

Entergy's Answer to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28 (1) NRC letter to Entergy, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, NVY 12-015

Dear Sir or Madam:

On March 12, 2012, the NRC issued an immediately effective Order in Reference 1 entitled Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) ("Order") to, inter alia, Entergy Nuclear Operations, Inc. (Entergy). The Order states 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 had decided to direct nuclear power plant licensees to take certain actions. Specifically, the NRC is requiring additional defense-in-depth measures to address uncertainties associated with protection from beyond-design-basis external events. With respect to this Order, licensees are specifically directed to provide a reliable means of remotely monitoring "wide-range spent fuel pool levels" to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event.

Specific requirements 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

BVY 12-022 / Page 2 of 3 Pursuant to 10 CFR § 2.202 and the terms specified in the Order, Entergy hereby submits its answer to the Order. Entergy consents to the Order and does not request a hearing. Based on information currently available, Entergy has not identified any circumstances of the type described in Sections IV.B.1 and IV.B.2 of the Order requiring relief at this time. In addition, Entergy 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. Entergy 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 Entergy to comply with the specific compliance deadline dates based on the probable availability of that guidance, Entergy'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.

There are no new commitments contained in this submittal.

Should you have any questions regarding this answer, please contact Mr. Robert J.

Wanczyk at (802) 451-3166.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 30, 2012.

Sincerely,

[CJW/JMD]

cc:

Mr. Eric J. Leeds Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Washington, DC 20555-0001 Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555

BVY 12-022 / Page 3 of 3 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Ms. Elizabeth Miller, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601