RC-12-0049, 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)

ML12090A543
Person / Time
Site:	Summer
Issue date:	03/28/2012
From:	Gatlin T South Carolina Electric & Gas Co
To:	Martin R Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RC-12-0049
Download: ML12090A543 (2)

Text

Thomas D. Gatlin Vice President,Nuclear Operations 803.345.4342 A SCANA COMPANY March 28, 2012 RC-12-0049 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Attn: Robert E. Martin

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY'S ANSWER TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSE WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

Dear Sir:

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 Spent Fuel Pool Instrumentation (Effective Immediately)" ("Order") to, inter alia, South Carolina Electric & Gas Company (SCE&G). 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 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. 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.

Virgil C.Summer Station . Post Office Box 88 - Jenkinsville, SC

. 29065 . F(803) 345-5209

Document Control Desk Order Number EA-12-051 RC-12-0049 Page 2 of 2 Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, SCE&G hereby submits its answer to the Order. SCE&G consents to the Order and does not request a hearing. Based on information currently available, SCE&G 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, SCE&G 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.

SCE&G 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 SCE&G to comply with the specific compliance deadline dates based on the probable availability of that guidance, SCE&G'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 about this letter, please contact Mr. Bruce L. Thompson at (803) 931-5042.

I certify under penalty of perjury that the forgoing is true and correct.

3) 2~02'2.. Z___________

txecuted on Thomas D. Gatlin JMWITDG/wm c: K. B. Marsh S. A. Byrne J. B. Archie N. S. Carns J. H. Hamilton R. J. White W. M. Cherry E. J. Leeds V. M. McCree R. E. Martin K. M. Sutton NRC Resident Inspector RTS (CR-12-01070)

File (815.07)

PRSF (RC-12-0049)