ML111990111
| ML111990111 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 07/15/2011 |
| From: | Price J Dominion, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 11-333 | |
| Download: ML111990111 (4) | |
Text
Dominion Energy Kewaunee, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060 July 15, 2011 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Serial No.11-333 L1C/CDS/RO Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION COMMITMENT TO 10 CFR SOA8ee) LICENSE AMENDMENT REQUEST SUBMITTAL DATE AND REQUEST FOR EXTENSION OF ENFORCEMENT DISCRETION The purpose of this letter is to inform the NRC that Dominion Energy Kewaunee (DEK) is providing a commitment to submit a LAR for transition of Kewaunee Power Station (KPS) to 10 CFR 50.48(c) by September 29, 2011.
In addition this letter requests NRC approval of a corresponding additional period of enforcement discretion of two months.
10 CFR 50.48(c) in conjunction with NFPA 805 (Reference 1), provides an alternate, performance-based method to comply with NRC fire protection requirements. The NRC has encouraged licensees to consider the benefits of transitioning plant fire protection programs from their current prescriptive requirements to the new NFPA 805 standard.
The overall benefit of NFPA 805 is in ensuring optimum focus on enhancing plant safety through the use of performance-based standards and risk informed decision-making techniques.
By letter dated July 21, 2008 (Reference 2), DEK informed the NRC of its intention to adopt NFPA 805 at KPS in accordance with 10 CFR 50.48(c).
DEK also informed the NRC that it would take approximately 36 months to develop and submit a License Amendment Request (LAR) to adopt NFPA 805, as required by 10 CFR 50.48(c).
In response to Reference 2, the NRC granted a period of enforcement discretion of 36 months, beginning in July 2008 and ending in July 2011 (Reference 3). In addition, the enforcement discretion would continue past the 36-month period while the NRC staff reviews the LAR fortransitioning to 10 CFR 50.48(c).
On April 29, 2011, the NRC issued SECY-11-0061 (Reference 4).
This document proposed a revision to the enforcement policy for licensees transitioning to NFPA 805 as necessary to support a staggered schedule approach for LAR submittals across the industry. With the exception of the first group of licensees scheduled to submit around July 1, 2011, SECY-11-0061 requires each licensee to submit a letter to the NRC specifying a commitment date for submitting an LAR for transitioning to NFPA 805.
Serial No.11-333 Request for Extension of Enforcement Discretion Page 2 of 4 Therefore, in accordance with SECY-11-0061 as approved by the Commission per Staff Requirements Memorandum SECY-11-0061 (Reference 5), DEK commits to submit the KPS LAR for transitioning to NFPA 805 by September 29,2011.
The above commitment constitutes a change to the schedule originally submitted in Reference 2
and requires an extension to the previously approved period of enforcement discretion for KPS.
Specifically, the date of September 29, 2011 is two months beyond the 36-month schedule originally proposed by DEK and approved by the NRC staff.
Therefore, consistent with the commitment above, DEK also requests approval of a two-month extension to the existing enforcement discretion period for KPS (from 36 months to 38 months).
Consistent with SECY-11-0061, once the LAR is submitted, enforcement discretion would continue until the NRC dispositions the LAR to transition to 10 CFR 50.48(c).
DEK believes that the proposed submittal date of September 29, 2011 and additional two months of enforcement discretion are justified based on the following:
The KPS LAR is nearly complete, but additional time is needed to permit a thorough technical and management review and ensure the final document is properly verified as complete and accurate.
The additional two months of enforcement discretion will not compromise plant safety or increase plant risk.
Three findings related to compliance with 10 CFR 50.48(b) had previously been identified at KPS for which enforcement discretion is being exercised.
These findings have been entered into the KPS corrective action program, appropriate interim compensatory measures are in place, and they are of less than high safety significance (i.e., less than Red).
The additional two months of enforcement discretion will not change the current status of these findings nor the manner in which they are being addressed.
DEK understands that the enforcement discretion does not apply to risk-significant findings (findings evaluated as Red under the Reactor Oversight Process) or findings that would be categorized as Severity Level I.
In addition, DEK understands that findings eligible for enforcement discretion must be documented in the KPS corrective action program and appropriate interim compensatory measures implemented until compliance is either restored per 10 CFR 50.48(b) or achieved per 10 CFR 50.48(c).
Serial No.11-333 Request for Extension of Enforcement Discretion Page 3 of 4 If you have any questions or require additional information, please contact Mr. Craig D.
Sly at (804) 273-2784.
Very truly yours,
References:
- 1. National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants,"
2001 Edition.
2.
Letter from G. T. Bischoff (DEK) to NRC Document Control Desk, "Letter of Intent to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition," dated July 21, 2008.
[ADAMS Accession No. ML082040111]
3.
Letter from J. G. Giitter (NRC) to D. A. Christian (DEK), "Response to Letter of Intent to Adopt National Fire Protection Standard 805," dated October 6, 2008
[ADAMS Accession No. ML082710001].
4.
SECY-11-0061, "A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," dated April 29, 2011. [ADAMS Accession No. ML11117A291]
5.
Staff Requirements Memorandum SECY-11-0061, "Staff Requirements - SECY-11-0061 - A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," dated June 10, 2011.
[ADAMS Accession No. ML111610616]
Attachments: None Commitments made by this letter:
- 1. DEK commits to submit the KPS LAR for transitioning to 10 CFR 50.48(c) by September 29,2011.
Serial No.11-333 Request for Extension of Enforcement Discretion Page 4 of 4 cc:
Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707