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Revised Answer to Order for Additional Security Measures (Asms) and Fingerprinting for Unescorted Access for Certain Spent Fuel Storage Licensees Dated January 28, 2008 and Relaxation Request
	ML15294A073
Person / Time
Site:	Kewaunee
Issue date:	10/15/2015
From:	Clark G; Dominion, Dominion Energy Kewaunee
To:	; Document Control Desk, NRC/NMSS/SFST
References
	15-337, EA-07-195
	Download: ML15294A073 (3)
	v • d • e

Dominion Energy Kewaunee, .Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com SAFEGUARDS INFORMATION October 15, 2015 Re: 10 CFR 2.202 10 CFR 72.4 Attention: Document Control Desk Serial No.: 1t?-337 Director, Division of Spent Fuel Storage and Transportation NL&OS/MAE: RB Office of Nuclear Material Safety and Safeguards Docket No.: 50-305 Washington, D.C. 20555-0001 72-64 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION REVISED ANSWER TO ORDER FOR ADDITIONAL SECURITY MEASURES (ASMs) AND FINGERPRINTING FOR UNESCORTED ACCESS FOR CERTAIN SPENT FUEL STORAGE LICENSEES DATED JANUARY 28, 2008 AND RELAXATION REQUEST .

On January 28, 2008, the Nuclear Regulatory Commission (NRC) issued an Order (EA-07-195),

"lssuanc~ Of Order For Implementation Of Additional Security Measures And Fingerprinting For Unescorted Access For Certain Spent Fuel Storage Licensees - Kewaunee Power Station Independent Spent Fuel Storage Installation," (the Order). The prder modified the license for the proposed Kewaunee Power Station (KPS) Independent Spent Fuel Storage Installation

. (ISFSI). By letter dated February 15, 2008 (Serial No. 08-0039) Dominion Energy Kewaunee, Inc. (DEK) . consented to the Order and provided the response* to the additional security measures (ASMs) for the physical protection of the ISFSI in Attachment 1 and the response to the* ASMs for access authorization and fingerprinting at the. ISFSI *in Attachment 2. The response to the Order was based on the ISFSI being located inside an operating power reactor*

facility's p~otected area (Se~tion D of the ASMs in Attachment 1 to the Order).

DEK submitted a certification of permanent removal of the fuel from the reactor vessel to the NRC on May 14, 2013 (Serial No.13-293). Pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 li'cense no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Therefore, on October 23, 2013 (Serial No.13-554),. DEK revised the responses to ASMs 1.a, 1.b, 1.c, and 2.c of Section D of Attachment 1 to the Order to reflect the new permanently_defueled status of the plant and subsequent security program changes.

As part of the ongoing decommissioning process, DEK intends to move the spent fuel in the spent fuel pool to the ISFSI. The Post-Shutdown Decommissioning* Activities Report (PSDAR) for KPS, dated April 25, 2014, documented that DEK expects to have all spent fuel moved to the ISFSI by the end of 2016. This letter revises DEK's answer to the Order to reflect an ISFSI using dry storage that is not collocated with an operating power reactor facility as .required by Section B of the ASMs in Attachment 1 to the Order and requests relaxation of Attachment 2 to

the Order.

Classified By:

Unauthorized Disclosure Of Safeguards Information Name: Jonathan Barbier Will Be Subject To Civil And Criminal Sanctions

Title:

Coard. Nuc. *sec Programs Organization: Nuclear Protection Services Effective Date: October 1. 2015 ATTACHMENT 1 CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Serial No.15-337 Dockets 50-305 & 72-64 EA-07-195 Page 2 of 3 In accordance with Section IV of the Order and 10 CFR 2.202, DEK hereby submits its answer to the Order for an ISFSI using dry storage that is not collocated with an operating power reactor facility. Attachment 1 to this letter provides a response to each of the items stated in Section B of Attachment 1 to the Order and provides an implementation schedule for each item.

Attachment 2 to this letter provides a response to the ASMs for access authorization and fingerprinting and provides an implementation .schedule. DEK. had previously consented to the Order in the February 15; 2008 letter. *

The revised Order responses provided in Attachments 1 and 2 to this letter will be effective at the time the Kewaunee

Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0 (the Plan) that reflects an "ISFSI only" site configuration is implemented. The Plan *was submitted to the NRC for review on October 15, 2015 (Serial No.15-302),

Attachment 1 to this letter contains Safeguards Information as defined by 10 CFR 73.22 and its_

disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended.

If you have any questions or require additional information, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Gianna C. Clark Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was ack'nowledged before me, in and for the County and Commonwealth aforesaid, today by Gianna C. Clark who is Vice President - Nuclear Support Services. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

I ~1!"' /J . .

Acknowledged before me this ~day of v'eio/J(f ,2015.

Ex~ires:

~-ty!u/L My Commission 5-31-/f Notary Public ATTACHMENT 1 CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Serial No.15-337 Dockets §0-305 & 72-64 EA-07.:195

.Page 3 of 3 Attachments: 1. Response to Additional Security Measures (ASMs) for the Physical Protection of Dry Independent Spent Fuel Storage Installations, .Section B (Safeguards Information)

2. Response to Additional Security Measures (ASMs) for Access Authorization and Fingerprinting'at Independent Spent Fuel Storage Installations and Order Relaxation Request Commitments made by this letter: See ASMs 8.3.a, B.3.f, and B.3.g cc: Secretary, Office .of the Secretary of the Commission (Without Attachments)

U.S. Nuelear Regulatory Commission*

Washington, D. C. 20555-0001 ATTN: Rulemakings and Adjudications Staff Regional Administrator, Region Ill

U. S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Usie, Illinois 60532-4352 Director, Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Two White Flint North Mail Stop 4 A12 11545 Rockville Pike Rockville, MD 20852-2738 Mr. Ted H. Carter" (Without Attachments)

NRG Senior Project Manager Two White Flint North Mail Stop T-8 F5 11545 Rockville Pike Rockville, MD* 20852-2738 Dr. Pamela Longmire (Without Attachments)

NRG Project Manager Three White Flint North Mail Stop 14-C79 11601 Landsdown Street North Bethesda, MD 20852-2738 NRG Regional Inspector (Without Attachments)

Kewaunee Power Station ATTACHMENT 1 CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

SAFEGUARDS INFORMATION