L-PI-12-022, Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML12093A044
Person / Time
Site:	Prairie Island
Issue date:	03/30/2012
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-PI-12-022, EA-12-049
Download: ML12093A044 (2)

Text

Prairie lsland Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089-9642 March 30, 2012 L-PI-12-022 10 CFR 2.202 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie lsland Nuclear Generating Plant Docket Nos. 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 Answer to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Bevond-Design-Basis External Events (Order Number EA-12-049)

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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately)" ("Order") to, inter aha, Prairie lsland Nuclear Generating Plant (ADAMs Accession No. MLI 2054A735). Specifically with respect to this Order, the NRC determined that additional requirements must be imposed to mitigate beyond-design-basis external events. These additional requirements impose guidance and strategies to be available if the loss of power, motive force and normal access to the ultimate heat sink to prevent fuel damage in the reactor and spent fuel pool affected all units at a site simultaneously. Specific requirements are outlined in Attachment 2 to the Order.

The Order requires submission of an overall integrated plan includitig a description of how compliance with the requirements described in Attachment 2 will be achieved to the NRC for review by February 28, 201 3. 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 following the 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, Prairie lsland Nuclear Generating Plant (PINGP) hereby submits its answer to the Order. PINGP consents to

' the Order and does not request a hearing. Based on information currently available, PINGP has not identified any circumstances of the type described in Sections IV.B.1

Document Control Desk Page 2 and IV.B.2 of the Order requiring relief at this time. In addition, PINGP has not identified any impediments to compliance with the Order within two refueling cycles following the submittal of the overall integrated plan, or December 31, 2016, whichever is earlier.

PINGP will provide further responses as required by Section 1V.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 PINGP to comply with the specific compliance deadline dates based on the probable availability of that guidance, PINGP1s 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.

If there are any questions or if additional information is needed, please contact Ms.

Jennie Eckholt, Licensing Engineer, at 612-330-5788.

Summarv of Commitments This letter contains no new commitments and no revisions to existing commitments.

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

MAR 3 0 2012 Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota cc: Administrator, Region Ill, USNRC Director of Nuclear Reactor Regulation (NRR), USNRC NRR Project Manager, PINGP, USNRC Senior Resident Inspector, PINGP, USNRC