NOC-AE-12002824, Answer to NRC Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation EA-12-051

Answer to NRC Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation EA-12-051

ML12097A068
Person / Time
Site:	South Texas
Issue date:	03/29/2012
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NOC-AE-12002824
Download: ML12097A068 (3)

Text

Nuclear Operating Company South Texas ProjectElectric Generatin5 Station PO.Box 289 Wadsworth. Texas 77483 ,

March 29, 2012 NOC-AE-12002824 10 CFR 50.4 10 CFR 2.202 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Answer to NRC Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation EA-12-051

Reference:

Letter, Eric Leeds to E. D. Halpin, "Issuance of Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation," March 12, 2012 (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 ("Order") to, inter alia, STP Nuclear Operating Company. The Orders state 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.

ST33417355J

NOC-AE-12002824 Page 2 of 3 Pursuant to 10 CFR 2.202 and the terms specified in the Order, STP Nuclear Operating Company (STPNOC) hereby submits its answer to the Order. STPNOC consents to the Order and does not request a hearing. Based on information currently available, STPNOC 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, STPNOC 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. STPNOC 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 STPNOC to comply with the specific compliance deadline dates based on the probable availability of that guidance, STPNOC'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 commitments in this letter.

If there are any questions regarding this letter, please contact Robyn Savage at (361) 972-7438 or me at (361) 972-7867.

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

Executed on: `"J 4 ci 2_A( ZL Chief Nuclear Officer STI33417355

NOC-AE-12002824 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio Senior Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission City Public Service P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin U. S. Nuclear Regulatory Commission Richard A. Ratliff Director of Office of Nuclear Regulation Texas Department of State Health One White Flint North (MS 13 H 16M) Services 11555 Rockville Pike Rockville, MD 20852-2738 Alice Rogers Texas Department of State Health Services STI33417355