CP-201100828, 30-Day Response to NRC Bulletin 2011-01, Mitigation Strategies
| ML11168A076 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/08/2011 |
| From: | Flores R Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP-201100828, TXX-11074 | |
| Download: ML11168A076 (4) | |
Text
Rafael Flores Luminant Power 0_1 Senior Vice President P 0 Box 1002
& Chief Nuclear Officer 6322 North FM 56 Lum inant rafael.flores@Luminant.com Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201100828 Ref: 10 CFR 50.54(hh)(2)
TXX-11074 June 8, 2011 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 30-DAY RESPONSE TO NRC BULLETIN 2011-01, MITIGATION STRATEGIES
REFERENCE:
NRC Bulletin 2011-01, "Mitigating Strategies," dated May 11, 2011
Dear Sir or Madam:
Pursuant to 10 CFR 50.54(f), this letter provides the Luminant Generation Company LLC (Luminant Power) 30-day response to NRC Bulletin 2011-01, "Mitigating Strategies," dated May 11, 2011. The bulletin was issued to confirm continued compliance with 10 CFR 50.54(hh)(2) and request information regarding the mitigation strategies programs.
The NRC identified the following three objectives:
- 1. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),
- 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima Daiichi facility in order to determine if 1) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and
- 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).
NRC Bulletin 2011-01 requested that within 30 days, licensees submit a response to questions to confirm continued compliance with 10 CFR 50.54(hh)(2) and requested within 60 days that licensees provide information regarding mitigation strategies programs required by 10 CFR 50.54(hh)(2). Luminant Power's 30-day response is provided in the attachment.
U.S. Nuclear Regulatory Commission Page 2 TXX-11074 06/08/2011 This communication contains no new licensing basis commitments regarding Comanche Peak Units 1 and 2.
Should you have any questions, please contact Dennis Buschbaum at (254) 897-5851, or dennis.buschbaum@luminant.com.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 8, 2011.
Sincerely, Luminant Generation Company LLC Rafael Flores 0-Day Response to Bulletin 2011-01 c- E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak
Attachment to TXX-11074 Page 1 of 2 30-Day Response to Bulletin 2011-01 Comanche Peak Nuclear Power Plant Units 1 and 2 On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "MitigatingStrategies." The NRC is issuing this bulletin to achieve the following objectives:
- 1. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code ofFederalRegulations (10 CFR)
Section 50.54(hh)(2),
- 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if 1) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and
- 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).
The Bulletin requested that within 30 days of the date of this Bulletin, licensees provide information on their NRC mitigating strategies programs. The NRC questions related to the 30-day response are restated below followed by the Luminant Power, response for the Comanche Peak Units 1 and 2.
- 1. Is the equipment necessary to execute the mitigatingstrategies,as described in your submittals to the NRC, availableand capable ofperforming its intendedfunction?
Response
Comanche Peak inspected and verified the availability of the equipment necessary to execute the mitigating strategies required by 10 CFR 50.54 (hh)(2) and as described in CPNPP submittals to the NRC. In addition, the portable pump required for some of the strategies was tested to ensure it was capable of performing its intended function with respect to the mitigation strategies. Letters of Agreement/Memorandums of Understanding with offsite organizations were also re-validated.
Luminant Power has confirmed that the equipment necessary to execute the mitigating strategies is available and capable of performing its intended function at Comanche Peak Units 1 and 2.
Attachment to TXX-11074 Page 2 of 2
- 2. Are the guidance and strategies implemented capable of being executed consideringthe currentconfiguration ofyourfacility and currentstaffing andskill levels of the stafj?.
Response
10 CFR 50.54 (hh)(2) requires licensees to implement guidance and strategies under the circumstances associated with loss of large areas of the plant due to explosions or fire, in the following areas:
(i) Fire fighting; (ii) Operations to mitigate fuel damage; and (iii) Actions to minimize radiological release.
Comanche Peak verified that the mitigation strategies associated with large area fires and explosions are implemented and capable of being performed as described in the Mitigation Strategy License Condition. Each procedure implementing the required mitigation strategies was walked down to ensure the procedures are in place and capable of being executed. The staffing and skill levels required to implement the mitigation strategies were also considered.
Luminant Power has confirmed that the guidance and strategies being implemented at Comanche Peak Units 1 and 2 are capable of being executed considering the current configuration of the facilities and current staffing and skill levels of the Comanche Peak personnel.
Reference:
Comanche Peak Steam Electric Station, Units 1 and 2 Conforming License Amendments to Incorporate the Mitigation Strategies Required by Section B.5.b of Commission Order EA-02-026 (TAC NOS. MD4522 AND MD4523) dated July 26, 2007