PLA-6829, Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)

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

ML12093A365
Person / Time
Site:	Susquehanna
Issue date:	03/31/2012
From:	Rausch T Susquehanna
To:	Leeds E Office of Nuclear Reactor Regulation
References
EA-12-051, PLA-6829
Download: ML12093A365 (2)

Text

Timothy 5. Rausch PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 tsrausch @pplweb.com MAR 3 1 2012 Mr. Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint North- Mail Stop 13H16M Rockville, MD 20852 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (EA-12-051) Docket Nos. 50-387 PLA-6829 and 50-388 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an immediately effective order in the captioned matter entitled Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) ("Order") to, inter alia, PPL Susquehanna, LLC (PPL). 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 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

Document Control Desk PLA-6829 requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, PPL hereby submits its answer to the Order. PPL consents to the Order and does not request a hearing. Based on information currently available, PPL 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, PPL 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. PPL 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 PPL to comply with the specific compliance deadline dates based on the probable availability of that guidance, PPL' 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 Mr. John L. Tripoli, Manager, Nuclear Regulatory Affairs, at (570) 542-3100.

This letter contains no commitments.

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

Executed on 2\":,\ '2012.

T. s. Rauscrc.

Senior Vice *aent & Chief Nuclear Officer Copy: Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. R. R. Janati, DEP/BRP Mr. B. K. Vaidya, NRC Project Manager Administrator, NRC Region I