RA-12-037, Company, LLCs Answer to March 12, 2012 Commission Order Modifying License with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)
| ML12093A062 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Limerick, Quad Cities, LaSalle (DPR-016, DPR-019, DPR-025, DPR-029, DPR-030, DPR-044, DPR-056, NPF-011, NPF-018, NPF-039, NPF-085) |
| Issue date: | 03/30/2012 |
| From: | Jury K Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-050, RA-12-037, RS-12-051 | |
| Download: ML12093A062 (3) | |
Text
Nuclear Exelon Generation Company, LLC www.exeloncorp.com 4300 Winfield Road Warrenville, IL 60555 Order No. EA-12-050 RS-12-051 RA-1 2-037 March 30, 2012 U.S. Nuclear Regulatory Commission ATfN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR -29 and DPR-30 NRC Docket Nos. 50-254 and 50-265
Subject:
Exelon Generation Company, LLC's Answer to March 12, 2012 Commission Order Modifying License with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)
Reference:
Letter from Eric J. Leeds, U.S. Nuclear Regulatory Commission, to All Operating Boiling-Water Reactor Licensees with Mark I and Mark II Containments -
"Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012.
U.S. Nuclear Regulatory Commission 20-Day Response to Order No. EA-12-050 March 30, 2012 Page 2 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 Hardened Containment Vents (Effective Immediately) ("Order") to, inter alia, Exelon Generation Company, LLC (Exelon). 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 with respect to this Order, the NRC has decided to require BWRs with Mark I and Mark II containments to take certain actions to ensure the operability of a reliable hardened vent system to remove decay heat and maintain control of containment pressure following events that result in loss of active containment heat removal capability or prolonged Station Blackout (SBO). 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.
The Order also states that the Commission also intends to decide, after receipt of a Policy Paper from the NRC staff, whether to also require installation of filtration systems on these hardened vent systems (Order,Section II, p. 5). The Policy Paper is scheduled to be delivered by July 2012. The full extent of work necessary to implement this Order cannot be known until after Commission action after review of the staff's July 2012 Policy Paper.
Pursuant to 10 CFR 2.202 and the terms specified in the Order, Exelon hereby submits its answer to the Order. Exelon consents to the Order and does not request a hearing. Based on information currently available, Exelon 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, Exelon 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. Exelon will provide further responses as required by Section IV.C., in accordance with the specified deadlines. Given the uncertainties associated with the ultimate scope of required work caused by the unavailability of implementing guidance until August 2012, however, and the impact on the ability of Exelon to comply with the specific compliance deadline dates based on the probable availability of that guidance, Exelon'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 contained in this letter.
U.S. Nuclear Regulatory Commission 20-Day Response to Order No. EA-12-050 March 30, 2012 Page 3 If there are any questions concerning this letter, then please contact David P. Helker at (610) 765-5525.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of March 2012.
Respectfully, Keith R. Jury Vice President, Licensing and Regulatory Affairs Exelon Generation Company, LLC cc:
Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland R. R. Janati, Commonwealth of Pennsylvania