NG-12-0135, Nextera Energy Duane Arnold, LLC - Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Reliable Hardened Containment Vents (Order Number EA-12-050)

Nextera Energy Duane Arnold, LLC - Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Reliable Hardened Containment Vents (Order Number EA-12-050)

ML12090A490
Person / Time
Site:	Duane Arnold
Issue date:	03/30/2012
From:	Wells P NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-050, NG-12-0135
Download: ML12090A490 (2)

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NEXTera M ENERGY~

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ARNOLD March 30, 2012 NG-12-0135 10 CFR 2.202 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 NEXTERA ENERGY DUANE ARNOLD, LLC'S ANSWER TO MARCH 12,2012 COMMISSION ORDER MODIFYING LICENSE WITH REGARD TO REQUIREMENTS FOR RELIABLE HARDENED CONTAINMENT VENTS (ORDER NUMBER EA-12-050)

On March 12,2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an immediately effective order in the captioned matter entitled "Order Modifying License with Regard to Reliable Hardened Containment Vents (Effective Immediately)" ("Order") to, inter alia, NextEra Energy Duane Arnold. 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 has decided to direct nuclear power plant licensees and construction permit holders to take certain actions. Specifically with respect to this Order, the NRC has decided to require Boiling Water Reactors (BWRs) with Mark I and Mark II containments to take certain actions to ensure the operability of a reliable hardened vent system to remove decay heat and maintain control of containment pressure following events that result in loss of active containment heat removal capability or prolonged Station Blackout (SBO). SBO-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 NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-12-0135 Page 2 of 2 cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

The Order also states that the Commission also intends to decide, after receipt of a Policy Paper from the NRC Staff, whether to also require installation of filtration systems on these hardened vent systems. (Order at Section II, p. 5) The Policy Paper is scheduled to be delivered by July 2012. The full extent of work necessary to implement this Order cannot be known until after Commission action after review of the Staff's July 2012 Policy Paper.

Pursuant to 10 CFR §2.202 and the terms specified in the Order, NextEra Energy Duane Arnold hereby submits its answer to the Order. NextEra Energy Duane Arnold consents to the Order and does not request a hearing. Based on information currently available, NextEra Energy Duane Arnold 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, NextEra Energy Duane Arnold has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever is earlier. NextEra Energy Duane Arnold 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 NextEra Energy Duane Arnold to comply with the specific compliance deadline dates based on the probable availability of that guidance, NextEra Energy Duane Arnold'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.

This letter makes no new commitments or changes to any existing commitments.

If you have any questions or require additional information, please contact Ken Putnam at 319-851-7238.

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

Exec e n Mar 30,2012 Peter Wells Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC