ML12093A340

Answer to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML12093A340
Person / Time
Site:	Pilgrim
Issue date:	03/30/2012
From:	Smith R G Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049
Download: ML12093A340 (3)

Text

SEntergy Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Robert G. Smith, RE.Site Vice President March 30, 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

REFERENCE:

1.Entergy's Answer to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 NRC letter to Entergy, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (PNPS Letter 1.12.013)LETTER NUMBER 2.12.018

Dear Sir or Madam:

On March 12, 2012, the NRC issued an immediately effective Order in Reference 1 entitled Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately)

("Order")

to, inter alia, Entergy Nuclear Operations, Inc. (Entergy).

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 to take certain actions. Specifically, with respect to this Order, the NRC is requiring additional defense-in-depth measures at licensed nuclear power reactors to address uncertainties associated with protection from beyond-design-basis external events. Licensees are specifically directed by the Order to develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling 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.

Pilgrim Letter No. 2.12.018 / Page 2 of 3 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.Pursuant to 10 CFR § 2.202 and the terms specified in the Order, Entergy hereby submits its answer to the Order. Entergy consents to the Order and does not request a hearing. Based on information currently available, Entergy 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, Entergy 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. Entergy 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 Entergy to comply with the specific compliance deadline dates based on the probable availability of that guidance, Entergy'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 regulatory commitments being made in this submittal.

Should you have any questions regarding this answer, please contact Mr. Joseph R.Lynch at (508) 830-8403.I declare under penalty of perjury that the foregoing is true and correct. Executed on March 30, 2012.Sincerely,[RGS/RMB]cc: Mr. Eric J. Leeds Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Washington, DC 20555-0001 Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Pilgrim Letter No. 2.12.018 / Page 3 of 3 Mr. Richard V. Guzman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 NRC Resident Inspector Pilgrim Nuclear Power Station