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

ML12089A082
Person / Time
Site:	Diablo Canyon
Issue date:	03/28/2012
From:	Conway J Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-12-049, EA-12-049
Download: ML12089A082 (2)

Text

Pacific Gas and John Conway 77 Beale Street, B32 Electric Company Senio r Vice President San Francisco, CA 94105 Energy Supply and Chief Nuclear Officer 415.973.3336 Fax: 415.973.2313 Internet: jtc h@pge.com March 28, 2012 PG&E Letter DCL-12-027 u.s. Nuclear Regulatory Commission 10 CFR 50.4 ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Pacific Gas and Electric Company's Answer to March 12, 2012, Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)

Dear Commissioners and Staff:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an immediately-effective order in the captioned matter entitled Order Modifying License with Regard to-Requirements for Mitigation Strategies for Beyond---Design-Basis External Events (Effective Immediately) ("Order") to, inter alia, Pacific Gas and Electric Company (PG&E). The Orders state 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 with respect to this Order, the NRC is requiring additional defense-in-depth measures at licensed nuclear power reactors to address uncertainties associated with protection from beyond-design-basis external events. Licensees are specifically directed by the Order to develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling 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 additio'n, the Order requires submission of an initial status report 60 days following issuance of the final interim staff guidance and at 6-month intervals following submittal of an overall integrated plan on February 28, 2013. The Order states that the NRC intends to issue the interim s1aff guidance containing specific details onimplHmentation of the requirements of this Order in August 2012. Finally, the Order requires full implementation -of its requirements no tater than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

A member_ of the STARS (Strategic Teaming and Resource Sharing) _ Alliance Call a way

• Com a n c h e Pea k

• D i a b l 0 Can yon

• Palo Ve r de. San 0 n 0 (r e

• Sou t h T e x asP r 0 j e c t . W 0 l fer e e k

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Document Control Desk March 28, 2012

& Page 2 PG&E Letter DCL-12-027 Pursuant to 10 CFR 2.202 and the terms specified in the Order, PG&E hereby submits its answer to the Order. PG&E consents to the Order and does not request a hearing. Based on information currently available, PG&E 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, PG&E 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 comes first. PG&E 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 PG&E to comply with the specific compliance deadline dates based on the probable availability of that guidance, PG&E'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.

PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter.

This letter includes no revisions to existing regulatory commitments.

If you have any questions, or require additional information, please contact Mr. Jearl Strickland at (805) 781-9785.

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

Executed on March 28, 2012.

Sincerely, n T. Conway S nior Vice President - Energy S gwh2/SAPN 50466122 cc: Diablo Distribution Elmo E. Collins, NRC Region IV Eric J. Leeds, NRC Director, Office of Nuclear Reactor Regulation Michael S. Peck, NRC, Senior Resident Inspector Joseph M. Sebrosky, NRR Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek