CP-201201239, Initial Status Report in Response 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)

Initial Status Report in Response 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)

ML12311A433
Person / Time
Site:	Comanche Peak
Issue date:	10/25/2012
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201201239, EA-12-049, TXX-12158
Download: ML12311A433 (3)

Text

Rafael Flores Luminant Power Luminant Senior Vice President

& Chief Nuclear Officer rafael.flores@luminant.com P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201201239 10 CFR 2.202 Log # TXX-12158 October 25, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, DOCKET NOS. 50-445 AND 50-446, Initial Status Report in Response 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)

REFERENCES:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012

3. Nuclear Energy Institute (NEI) Letter to NRC, Industry Initiative on Procurement of Equipment for the Diverse and Flexible Coping Strategy (FLEX), dated February 24, 2012

4. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an Order (Reference 1) to Luminant Generation Company, LLC. Reference I was immediately effective and directs Luminant Generation Company, LLC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an initial status report 60 days following issuance of the final interim staff guidance. The final interim staff guidance (Reference 2) was issued August 30, 2012.

The purpose of this letter is to provide the initial status report pursuant to Section IV, Condition C.2, of Reference 1 within 60 days following issuance of Reference 2. This report confirms Luminant Generation Company, LLC has received Reference 2 and is in the process of evaluating the guidance for the purpose of establishing mitigation strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event as described in Attachment 2 of Reference 1 for Comanche Peak Nuclear Power Plant (CPNPPP).

A member of the STARS Alliance Callaway

• Comanche Peak - Diablo Canyon - Palo Verde - San Onofre- South Texas Project

• Wolf Creek

U. S. Nucdear Regulatory Commission TXX-12158 Page 2 of 3 10/25/12 Major activities completed during this reporting period:

• Additional portable equipment was ordered prior to the issuance of Reference 2, as described in an NEI letter to the NRC (Reference 3).

• A site-specific evaluation is in progress to establish the coping capabilities as defined in NEI 12-06 (Reference 4).

• Resources have been identified and project plans initiated, including development of milestones, to assure compliance with Reference 1.

• A site walkdown was conducted to evaluate preliminary plant modification options for compliance with the strategies identified in Reference 4.

Planned activities for the next six months:

• Analyses and conceptual designs for modifications to demonstrate compliance with strategies indentified in Reference 4.

• Development and submittal of the overall integrated plan to the NRC by February 28, 2013, in compliance with Reference 1.

• Commencement of detailed design process to implement modifications required for compliance with strategies identified in Reference 4.

Technical difficulties encountered that could affect the ability to provide the licensee's February 28, 2013, submittal:

• None at this time.

Project milestones schedule through completion of installation and testing:

• A project milestones schedule will be provided with the overall integrated plan.

• Implementation of the order will be completed for Comanche Peak Unit I prior to startup from Refueling Outage (RFO) 1RF17 (Fall 2014).

• Implementation of the order will be completed for Comanche Peak Unit 2 prior to startup from Refueling Outage (RFO) 2RF15 (Fall 2015).

This letter contains no new regulatory commitments. If you have any questions concerning the content of this letter, please contact Dennis Buschbaum at 254-897-5851 or dennis.buschbaum@luminant.com.

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

Executed on October 25, 2012.

U. S. Nuclear Regulatory Commission TXX-12158 Page 3 of 3 10/25/12 Sincerely, Luminant Generation Company LLC Rafael Flores By: &iZ 2K22LL Fred W. Madden Director, Oversight & Regulatory Affairs c- E. J. Leeds, Director, Office of Nuclear Reactor Regulation E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak