ML20224A530

Response to the Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Wolf Creek Operating Corporation Independent Spent Fuel Storage Installation

ML20224A530
Person / Time
Site:	Peach Bottom
Issue date:	08/11/2020
From:	Benham R Wolf Creek
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
RA 20-0079
Download: ML20224A530 (4)

Text

Ron Benham Director Nuclear Regulatory Affairs August 11, 2020 RA 20-0079 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

NRC Letter dated July 22, 2020, from J. W. Lubinsky, USNRC, to C. O.

Reasoner, WCNOC

Subject:

Docket No. 72-079: Response to the Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Wolf Creek Operating Corporation Independent Spent Fuel Storage Installation

Dear Commisioners and Staff:

As directed by EA-20-091, Wolf Creek Nuclear Operating Corporation (WCNOC) hereby submits information in response to the Order for Implementation of Additional Security Measures (ASM) and Fingerprinting for Unescorted Access for WCGS Independent Spent Fuel Storage Installation (ISFSI)

(hereinafter "Order").

WCNOC consents to the Order as more fully set forth below, and specifically does not request a hearing on this Order. Upon implementation, WCNOC will be able to comply with the requirements described in Enclosure 1, Attachments 1 and 2 of the Order and implementation of the requirements will not cause WCNOC to be in violation of the provisions of any Commission regulation or the facility license. Implementation of the requirements described in Enclosure 1, Attachments 1 and 2 of the Order will not adversely impact the safe storage of spent fuel. The first movement of spent fuel to the Wolf Creek Generation Station (WCGS) ISFSI is currently scheduled to begin in Mid-September, 2021.

WCNOC recognizes that the Order requires WCGS to demonstrate compliance with certain security measures relative to WCGS's ISFSI no later than 365 days from July 22, 2020 or 90 days before the first day fuel is initially placed in the ISFSI, whichever is first. WCNOC is planning to use the TN-Orano NUHOMS Matrix HSM and EOS dry storage cannisters Storage System at WCGS. Due to uncertainties associated with the fabrication of matrix support components, construction of the WCGS ISFSI using this technology may not be to the stage that WCNOC can demonstrate compliance with the ASM by July 22, 2021. WCNOC does agree, however, to demonstrate compliance with the requirements in Attachments 1 and 2 to the Order no later than 90 days before the first day that spent fuel is initially placed in the ISFSI.

As provided for in Enclosure 1, Attachment 2 of the Order, WCNOC has chosen to comply with the NRC approved reactor access authorization program currently in place at WCGS as an alternative means to satisfy the provisions of sections B through G of Enclosure 1, Attachment 2. WCNOC will provide periodic updates of the ISFSI project status and will report to the Commission when it has achieved full compliance with the requirements described in Enclosure 1, Attachments 1 and 2 of the Order. WCNOC will achieve full compliance with the Order no later than 90 days before the first day that spent fuel is initially placed in the ISFSI.

RA 20-0079 Page 2 of 2 This letter contains one new commitment, which is described in Enclosure I to this letter. If you have any questions concerning this matter, please contact Brian Briggs at (816) 826-6219 or Ron Benham at (620) 364-4204.

Sincerely, Ron Benham RDB/rlt ENCLOSURE I: LIST OF REGULATORY COMMITMENTS CC: S. S. Lee (NRC)

S. A. Morris (NRC)

N. OKeefe (NRC)

Senior Resident Inspector (NRC)

Enclosure I to RA 20-0079 Page 1 of 2 ENCLOSURE I LIST OF REGULATORY COMMITMENTS

Enclosure I to RA 20-0079 Page 2 of 2 LIST OF REGULATORY COMMITMENTS REGULATORY COMMITMENT DUE DATE Achieve full compliance with the provisions of No later than 90 days before the first day that spent fuel Enclosure I, Attachments 1 and 2 of the NRC is initially placed in the ISFSI.

issued Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Wolf Creek Operating Corporation Independent Spent Fuel Storage Installation (EA-20-091), dated July 22, 2020)