ML11363A031

Request to Postpone Review of License Amendment Request 250 Adoption of NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition).

ML11363A031
Person / Time
Site:	Kewaunee
Issue date:	12/16/2011
From:	Price J Dominion, Dominion Resources Services, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
11-705, TAC ME7250
Download: ML11363A031 (3)

Text

Dominion Technical Innsbrook ResourcesCenter Services, Inc.

" 0LNEouEEEon 5000 Dominion Boulevard, 2SE, Glen Allen, VA 23060 December 16, 2011 ATTN: Document Control Desk Serial No.11-705 U. S. Nuclear Regulatory Commission LIC/CDS/R2 Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION REQUEST TO POSTPONE REVIEW OF LICENSE AMENDMENT REQUEST 250.

"ADOPTION OF NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS (2001 EDITION)"

By letter dated September 21, 2011, Dominion Energy Kewaunee (DEK) submitted a License Amendment Request (LAR 250, Reference 1) to adopt National Fire Protection Association (NFPA) Standard 805 (Reference 2) in accordance with 10 CFR 50.48(c).

The purpose of this letter is to request NRC postpone all review activity associated with LAR 250.

Dominion has publically announced that the Kewaunee Power Station is being actively marketed for sale. The expected NRC review time for LAR 250 is about 24 months.

Although no buyer has yet been announced, the plant sale is likely to occur prior to NRC completing its review of LAR 250. Since the initiation of extensive licensee and NRC resources is needed to complete the review of LAR 250 and a license transfer would likely occur during the review, Dominion believes it is inappropriate to proceed with the review without allowing the buyer of the plant to decide if continuing with the transition to NFPA 805 is in their best interest. Postponing NRC review of this LAR would also eliminate the difficulties associated with NRC interfacing with two separate licensees during the review process and provides for a less complicated transfer of ownership of the plant. Therefore, Dominion has concluded that postponing the review of this LAR at this time is appropriate and will result in more efficient use of licensee and NRC resources when compared to continuing with the present review schedule.

Once a decision regarding transitioning KPS to NFPA 805 is reached, the NRC will be informed in a timely manner.

DEK intends to continue planning and implementation of those changes to the facility identified in the LAR that provide a meaningful risk benefit. DEK also intends to maintain compensatory measures that have been established to address non-compliances with 10 CFR 50, Appendix R requirements under enforcement discretion.

Serial No.11-705 Request to Postpone Review of LAR 250 Page 2 of 3 If you have any questions or require additional information, please contact Mr. Craig Sly at (804) 273-2784.

Very truly yours, J. Price V'eesident - Nuclear Engineering

References:

1. Letter from J. A. Price to NRC Document Control Desk, "LAR 250: Adoption of NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," dated September 21, 2011.

[ADAMS Accession No. ML11277A265 and ML11277A240]

2. National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water- Reactor Electric Generating Plants,"

2001 Edition.

Attachments: None Commitments made by this letter: None

Serial No.11-705 Request to Postpone Review of LAR 250 Page 3 of 3 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