ML12093A398

(Ons), Units 1, 2, and 3, Oconee Nuclear Station'S Answer to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML12093A398
Person / Time
Site:	Oconee
Issue date:	03/29/2012
From:	Gillespie T Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051
Download: ML12093A398 (3)

Text

T. PRESTON GILLESPIE, JR.

Vice President Energy. Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Hwy.

Seneca, SC 29672 864-873-4478 864-873-4208 fax T.Gillespie@duke-energy.corn March 29, 2012 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Oconee Nuclear Station's Answer to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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

("Order") to, inter alia, Duke Energy Carolinas, LLC (Duke Energy). 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 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 the overall integrated plan by 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.

www.duke-energy.con)

U. S. Nuclear Regulatory Commission March 29, 2012 Page 2 Pursuant to 10 CFR 2.202 and the terms specified in the Order, Duke Energy hereby submits its answer to the Order. Duke Energy consents to the Order and does not request a hearing. Based on information currently available, Duke Energy 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, Duke Energy 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. Duke Energy 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 Duke Energy to comply with the specific compliance deadline dates based on the probable availability of that guidance, Duke Energy'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.

If you have any questions regarding this confirmation of receipt, please contact David Haile of the Oconee Nuclear Station, Regulatory Compliance Group at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 29, 2012.

Sincerely, T. P. Gillespie Jr., Vice President, Oconee Nuclear Station

U. S. Nuclear Regulatory Commission March 29, 2012 Page 3 cc:

Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. John Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555 E.J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 13-H16M 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Andy Sabisch Senior Resident Inspector Oconee Nuclear Site