WM 12-0008, Operating Corporation'S Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Event (Order Number EA-12-049)

Operating Corporation'S Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Event (Order Number EA-12-049)

ML12102A034
Person / Time
Site:	Wolf Creek
Issue date:	04/02/2012
From:	Matthew Sunseri Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, WM 12-0008
Download: ML12102A034 (3)

Text

WCREEK NUCLEAR OPERATING CORPORATION Matthew W. Sunseri President and Chief Executive Officer April 2, 2012 WM 12-0008 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

Reference:

Letter dated 3/12/2012 from USNRC to M. W. Sunseri, WCNOC

Subject:

Docket No. 50-482: Wolf Creek Operating Corporation's Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Event (Order Number EA-12-049)

Gentlemen:

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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately) ("Order") to, inter alia, Wolf Creek Nuclear Operating Corporation (WCNOC). The Orders state 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 is requiring additional defense-in-depth measures at licensed nuclear power reactors to address uncertainties associated with protection from beyond-design-basis events. Licensees are specifically directed by the Order to develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling in the event of a beyond-design-basis external event. 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.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 4isI An Equal Opportunity Employer M/F/HC/VET U "u7

WM 12-0008 Page 2 of 3 implementation of its requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, WCNOC hereby submits its answer to the Order. WCNOC consents to the Order and does not request a hearing. Based on information currently available, WCNOC 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, WCNOC 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.

WCNOC will provide further responses as required by Section IV.C. in accordance with the specified deadlines. However, given the uncertainties associated with the ultimate scope of required work caused by the unavailability of implementing guidance until August 2012, and the impact on the ability of WCNOC to comply with the specific compliance deadline dates based on the probable availability of that guidance, WCNOC'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.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4008, or Mr. Gautam Sen at (620) 364-4175.

Sincerely, Matthew W. Sunseri MWS/rlt cc: E. E. Collins (NRC)

J. R. Hall (NRC)

E. J. Leeds (NRC)

N. F. O'Keefe (NRC)

Senior Resident Inspector (NRC)

WM 12-0008 Page 3 of 3 STATE OF KANSAS )

SS COUNTY OF COFFEY )

Matthew W. Sunseri, of lawful age, being first duly sworn upon oath says that he is President and Chief Executive Officer of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

Matthew W. Sunseri President and Chief Executive Officer SUBSCRIBED and sworn to before me this 0 day of ,2012.

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