ML12089A035

Answer to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML12089A035
Person / Time
Site:	Kewaunee
Issue date:	03/26/2012
From:	Heacock D Dominion, Dominion Energy Kewaunee, Dominion Resources Services
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-164, EA-12-051
Download: ML12089A035 (3)

Text

Dominion Resources Services, Inc.

Innsbrook Technical Center DominioW 5000 Dominion Boulevard, 2SE, Glen Allen, VA 23060 10 CFR 2.202 March 26, 2012 EA-12-051 Attention: Document Control Desk Serial No.: 12-164 U.S. Nuclear Regulatory Commission NL&OS/MAE: R2' Washington, D.C. 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION ANSWER TO MARCH 12,2012 COMMISSION ORDER MODIFYING LICENSE WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

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 Reliable Spent Fuel Pool Instrumentation (Effective Immediately) ("Order") to, inter aria, Dominion Energy Kewaunee, Inc. (DEK). The Order states 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, the NRC is requiring additional defense-in-depth measures to address uncertainties associated with protection from beyond-design-basis events. With respect to this Order, licensees are specifically directed to provide a reliable means of remotely monitoring "wide-range spent fuel pool levels" to support effective prioritization of event mitigation and recovery actions 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 by 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.

Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, DEK hereby submits its answer to the Order. DEK consents to the Order and does not request a hearing. Based on information currently available, DEK has not identified any circumstances of the type described in Sections IV.B.I and IV.B.2 of the Order requiring relief at this time. In addition, DEK has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever is earlier. DEK 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

Serial No.12-164 Response to Order EA-12-051 Docket No. 50-305 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region I Regional Administrator 475 Allendale Road King of Prussia, PA 19406-1415 Secretary, Office of the Secretary of the Commission U. S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Staff Washington, D. C. 20555 Assistant General Counsel for Materials Litigation and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. K. D. Feintuch NRC Project Manager Kewaunee U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 H-4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station

Serial No.12-164 Response to Order EA-12-051 Docket No. 50-305 Page 2 of 3 of required work caused by the unavailability of implementing guidance until August 2012, and the impact on the ability of DEK to comply with the specific compliance deadline dates based on the probable availability of that guidance, DEK'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 IVof the Order.

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

Sincerely, David A. Hea~cock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

Commitments made by this letter: None COMMONWEALTH OF VIRGINIA )

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COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by David A. Heacock who is President and Chief Nuclear Officer of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this e_*kJay of ;'*-_rt 2012.

My Commission Expires: "/O!ZJmlw Ginger Lynn Rutherford NOTARY PUBUC Commonwealth of Virginia Notary P Reg. # 310847 My Commission Expires 4/30/2015 (SEAL)