GO2-12-049, Northwest'S Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

Northwest'S Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

ML12102A030
Person / Time
Site:	Columbia
Issue date:	04/02/2012
From:	Sawatzke B Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, GO2-12-049
Download: ML12102A030 (4)

Text

GBradley J. Sawatzke EN E ERTHS RihaP.O. Columbia Generating Station Box 968, PE08 Richland, WA 99352-0968 Ph. 509.377.4300 1F. 509.377.4150 bjsawatzke@energy-northwest.com April 2, 2012 G02-12-049 10 CFR 2.202 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397, LICENSE NO. NPF-21; ENERGY NORTHWEST'S ANSWER TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION

Reference:

Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

Dear Sir or Madam:

Pursuant to the requirements of 10 CFR 2.202(a)(2), Energy Northwest's answer to the March 12, 2012 Commission Order modifying license with regard to reliable spent fuel pool instrumentation is enclosed.

There are no commitments being made to the NRC herein. Ifyou have any questions or require additional information, please contact Mr. ZK Dunham at (509) 377-4735.

Respectfully, BJ S Vice President, Nuclear Generation & Chief Nuclear Officer

Enclosure:

As stated cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

ALL POWER REACTOR ) Docket No. 50-397 LICENSEES AND HOLDERS ) License No. NPF-21 OF CONSTRUCTION PERMITS IN ) EA-12-051 ACTIVE OR DEFERRED STATUS )

)

ENERGY NORTHWEST'S ANSWER TO ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION I.

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an immediately effective order in the captioned matter entitled Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) ("Order") to, inter alia, Energy Northwest.

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 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 statesthat 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 CFR § 2.202 and the terms specified in the Order, Energy Northwest hereby submits its answer to the Order. Energy Northwest consents to the Order and does not request a hearing. Based on information currently available, Energy Northwest 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, Energy Northwest 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. Energy Northwest 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 Energy Northwest to comply with the specific compliance deadline dates based on the probable availability of that guidance, Energy Northwest's future responses may include requests for schedule relief.

Any such request would be submitted in accordance with the relaxation provision in Section IV of the Order.

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

Respectfully submitted, Executed on: 1(