JAFP-12-0036, Entergy Nuclear Operations, Incorporateds - 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)

Entergy Nuclear Operations, Incorporateds - 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)

ML12090A498
Person / Time
Site:	FitzPatrick
Issue date:	03/30/2012
From:	Michael Colomb Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, JAFP-12-0036
Download: ML12090A498 (3)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-349-6024 Fax 315-349-6480 Michael J. Colomb Site Vice-President - JAF JAFP-12-0036 March 30, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Entergy Nuclear Operations, Incorporateds 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)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

Reference:

Nuclear Regulatory Commission Order, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, EA-12-049, dated 03/12/12.

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 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately) (Order) to, inter alia, Entergy Nuclear Operations, Inc. (Entergy). The Orders state that, as a result of the NRCs 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.

JAFP-12-0036 Page 2 of 3 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, Entergy hereby submits its answer to the Order. Entergy consents to the Order and does not request a hearing. Based on information currently available, Entergy 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, Entergy has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the plan, or December 31, 2016, whichever is earlier. Entergy 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 Entergy to comply with the specific compliance deadline dates based on the probable availability of that guidance, Entergy'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.

There are no commitments contained in this letter.

If you have any questions regarding this answer, please contact, please contact Mr.

Joseph Pechacek, Licensing Manager, at (315) 349-6766.

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

Executed on the 30 th day of March 2012.

Sincerely,

.~

Michael J. Colomb Site Vice President MC:ed cc: Next Page

JAFP-12-0036 Page 3 of 3 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspectors Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Bhalchandra Vaidya, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2A Washington, DC 20555-0001 Ms. Bridget Frymire New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Francis J. Murray Jr., President New York State Energy and Research Development Authority 17 Columbia Circle Albany, NY 12203-6399