NL-12-0618, Answer to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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

ML12088A121
Person / Time
Site:	Farley
Issue date:	03/27/2012
From:	Ivey B Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NL-12-0618
Download: ML12088A121 (3)

Text

B. L. "Pete" Ivey Southern Nuclear Vice Pres ident Operating Company, Inc.

Regulatory AHa.i rs 40 Inverness Center Parkway Pos t Office Box 1295 Birm ingham. AL 35242 Tel 205. 992.76 19 Fax 205 .992 .5217 SOUTHERN COMPANY March 27, 2012 Docket Nos.: 50-348 NL-12-0618 50-364 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington , D. C. 20555-0001 Joseph M. Farley Nuclear Plant's Answer to March 12,2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an immediately effective Order in the captioned matter entitled "Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation" (Order), to Joseph M. Farley Nuclear Plant Units 1 and 2 (FNP). The Order states that, as a result of the NRC's evaluation of the lessons learned from the accident at Fukushima Daiichi in March 2011, the NRC has decided to direct nuclear power plant licensees and construction permit holders to take certain actions (Reference Near-Term Task Force Recommendation 7.1). 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 an 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 by December 31, 2016, whichever comes first.

U.S. Nuclear Regulatory Commission NL-12-0618 Page 2 Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, Southern Nuclear Operating Company (SNC) hereby submits its answer to the Order on behalf of FNP. SNC consents to the Order and does not request a hearing.

Based on information currently available, SNC 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, SNC has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the integrated plan, or by December 31,2016, whichever is earlier. SNC 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 SNC to comply with the specific compliance deadline dates, based on the probable availability of that guidance, SNC's future responses may include requests for schedule relief as warranted by subsequent NRC requirements, implementing guidance, or the results of engineering analyses not yet performed. Any such request will be submitted in accordance with the relaxation provision in Section IV of the Order.

If you have any questions, please contact Jack Stringfellow at (205) 992-7037.

Mr. B. L. Ivey states he is Regulatory Affairs Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

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u.s. Nuclear Regulatory Commission NL-12-0618 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. J. Adams, Vice President - Fleet Operations Ms. P. M. Marino, Vice President - Engineering Mr. M. J. Ajluni, Nuclear Licensing Director RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer