CP-201200310, Answer to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

Answer to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

ML12102A018
Person / Time
Site:	Comanche Peak
Issue date:	04/02/2012
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201200310, EA-12-051, TXX-12050
Download: ML12102A018 (2)

Text

Rafael Flores Luminant Power Senior Vice President P0 Box 1002 Lum inant & Chief Nuclear Officer rafael.flores@luminant.com 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201200310 10 CFR 2.202 Log # TXX-12050 EA-12-051 April 2, 2012 U. S. Nuclear Regulatory Commission ATTIN: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, DOCKET NOS. 50-445 AND 50-446, ANSWER TO MARCH 12, 2012 COMMISSION ORDER TO MODIFY LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an immediately effective order in the captioned matter entitled Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) ("Order") to, inter alia, Luminant Generation Company, LLC. 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 and construction permit holders to take certain actions. Specifically, the NRC is requiring additional defense-in-depth measures to address uncertainties associated with protection from beyond-design-basis 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 comes first.

Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, Luminant Generation Company, LLC hereby submits its answer to the Order. Luminant Generation LLC consents to the Order and does not request a hearing. Based on information currently available, Luminant A4ooq

U. S. Nuclear Regulatory Commission TXX-12050 Page 2 of 2 04/02/12 Generation Company, LLC 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, Luminant Generation Company, LLC 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.

Luminant Generation Company, LLC 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 Luminant Generation Company, LLC to comply with the specific compliance deadline dates based on the probable availability of that guidance, Luminant Generation Company, LLC'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.

Should you have any questions, please contact Mr. Dennis Buschbaum at (254) 897-5851 or dennis.buschbaum@luminant.com.

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

Executed on April 2, 2012.

Sincerely, Luminant Generation Company LLC Rafael Flores By:

• B:Fred W. Madde'n /

Director, Oversight & Regulatory Affairs c- Director, Office of Nuclear Reactor Regulation E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak