ML12093A045

Answer to the March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML12093A045
Person / Time
Site:	Grand Gulf
Issue date:	03/30/2012
From:	Mike Perito Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051
Download: ML12093A045 (3)

Text

Entergy Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Michael Perito Vice President, Operations Grand Gulf NUclear Station Tel. (601) 437-6409 GNRO-2012/00019 March 30, 2012 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Answer to the March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

NRC letter to Entergy, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012 (GNRI-2012/00057)

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 Reliable Spent Fuel Pool Instrumentation (Effective Immediately) ("Order") to, inter alia, Grand Gulf Nuclear Station (GGNS). 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 external 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.

GNRO-2012/00019 Page 2 of 3 Pursuant to 10 CFR § 2.202 and the terms specified in the Order, GGNS hereby submits its answer to the Order. GGNS consents to the Order and does not request a hearing. Based on information currently available, GGNS 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, GGNS 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. GGNS 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 GGNS to comply with the specific compliance deadline dates based on the probable availability of that guidance, GGNS'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 new commitments contained in this submittal. If you have any questions regarding this answer, please call Christina L. Perino at 601-437-6299.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 30, 2012.

Sincerely, MP/jas cc (see next page)

GNRO-2012/00019 Page 3 of 3 cc: U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mail Stop OWFN 8 B1 Washington, DC 20555-0001 Mr. Elmo Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission Attn: Mr. A. B. Wang, NRR/DORL Mail Stop OWFN 8 B1 Washington, DC 20555-0001