ML052150428

Issuance of License Amendment 186 Regarding Technical Specification Changes for Radioactive Effluents Control Program and Off-Site Dose Calculation Manual

ML052150428
Person / Time
Site:	Kewaunee
Issue date:	10/04/2005
From:	Stang J NRC/NRR/DLPM/LPD3
To:	Christian D Dominion Energy Kewaunee
Stang JF, NRR/DLPM, 415-1345
References
TAC MC5900
Download: ML052150428 (13)

Text

October 4, 2005 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

KEWAUNEE POWER STATION - ISSUANCE OF AMENDMENT RE: TECHNICAL SPCIFICATION CHANGES FOR RADIOACTIVE EFFLUENTS CONTROL PROGRAM AND OFF-SITE DOSE CALCULATION MANUAL (TAC NO. MC5900)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 186 to Facility Operating License No. DPR-43 for the Kewaunee Power Station. This amendment revises the Technical Specifications (TSs) in response to your application dated February 3, 2005.

The amendment revises TS 6.16.b.1, Radioactive Effluent Controls Program, and TS 6.18, Off-site Dose Calculation Manual (ODCM), to be consistent with Title 10 of the Code of Federal Regulations (10 CFR) Part 20 and NUREG-1431, Standard Technical Specifications Westinghouse Plants.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next regular biweekly Federal Register notice.

Sincerely,

/RA/

John F. Stang, Senior Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosures:

1. Amendment No. 186 to License No. DPR-43

2. Safety Evaluation cc w/encls: See next page

ML052150428 (Letter)

ML052790644 (TS)

ML052150439 (Package)

OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/PM IROB/SC IPSB/SC OGC PDIII-1/SC NAME DBeaulieu PCoates for JStang TBoyce SKlementowicz DFruchtes LRaghavan THarris DATE 8/10/05 8/10/05 9/23/05 8/22/05 8/25/05 9/19/05 9/23/05 Kewaunee Power Station cc:

Resident Inspectors Office Ms. Lillian M. Cuoco, Esq.

U.S. Nuclear Regulatory Commission Senior Counsel N490 Hwy 42 Dominion Resources Services, Inc.

Kewaunee, WI 54216-9510 Millstone Power Station Building 475, 5th Floor Regional Administrator Rope Ferry Road Region III Waterford, CT 06385 U.S. Nuclear Regulatory Commission 801 Warrenville Road Plant Manager Lisle, IL 60532-4351 Kewaunee Power Station N490 Highway 42 David Zellner Kewaunee, WI 54216-9511 Chairman - Town of Carlton N2164 County B Kewaunee, WI 54216 Jeffery Kitsembel Electric Division Public Service Commission of Wisconsin PO Box 7854 Madison, WI 53707-7854 Mr. Michael G. Gaffney Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Thomas L. Breene Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216

DOMINION ENERGY KEWAUNEE, INC.

DOCKET NO. 50-305 KEWAUNEE POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 186 License No. DPR-43

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nuclear Management Company, LLC (the former licensee), dated February 3, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-43 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 186, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: October 4, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 186 FACILITY OPERATING LICENSE NO. DPR-43 DOCKET NO. 50-305 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages TS 6.16-1 TS 6.16-1 TS 6.16-2 TS 6.16-2 TS 6.18-1 TS 6.18-1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO AMENDMENT NO. 186 TO FACILITY OPERATING LICENSE NO. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION DOCKET NO. 50-305

1.0 INTRODUCTION

By application to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated February 3, 2005 (Agencywide Document Access and Management System (ADAMS)

Accession Number ML050450372), Nuclear Management Company, LLC (the former licensee),

proposed an amendment to the Technical Specifications (TSs) for the Kewaunee Nuclear Power Plant (Kewaunee). On July 5, 2005, the NRC issued Amendment No. 185 that reflected the transfer of the license to Dominion Energy Kewaunee, Inc., and the change in the facility name to Kewaunee Power Station.

The proposed changes would revise TS 6.16.b.1, Radioactive Effluent Controls Program, and TS 6.18, Off-site Dose Calculation Manual, to be consistent with Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection Against Radiation, and NUREG-1431, Revision 3, Standard Technical Specifications [STS] Westinghouse Plants.

Several of the proposed changes are consistent with TS Task Force (TSTF) Change Travelers TSTF-258A, Revision 4, Changes to Section 5.0, Administrative Controls, dated July 31, 2003, and TSTF-308, Revision 1, Determination of Cumulative and Projected Dose Contribution in RECP [Radioactive Effluents Control Program], dated June 13, 2000. While TSTF-308 recommended changes for several TS administrative controls, the licensee proposed only those changes referring to the RECP for inclusion into the Kewaunee TSs.

2.0 REGULATORY EVALUATION

The TSTF process is an industry and NRC-controlled process for proposing and incorporating improvements to the STS. Several of the revisions proposed in this amendment are consistent with TSTF-258A, Revision 4, and TSTF-308, Revision 1. However, since Kewaunee has not adopted the STS, the NRC staff has made a plant-specific evaluation of the licensees application using TSTF-258A and TSTF-308 as guidance.

The applicable regulatory requirements and guidelines are:

1. NUREG-1431, Revision 3

2. TSTF-258A, Revision 4

3. TSTF-308, Revision 1

4. 10 CFR Part 20

5. 40 CFR Part 190, Environmental Standards for the Uranium Fuel Cycle

6. 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low As Is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents

7. Generic Letter (GL) 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications [RETS] in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program, dated January 31, 1989.

3.0 TECHNICAL EVALUATION

The licensees proposed changes, and NRC staffs evaluation of the changes, are discussed below.

3.1 TS 6.16.b.1 3.1.1 Proposed TS Changes Revise TS 6.16.b.1 to insert parentheses around the S in MEMBERS OF THE PUBLIC in the second line of the introductory paragraph and delete OPERATING before procedures in the fourth line of the introductory paragraph.

3.7.2 NRC Staff Evaluation Inserting parentheses around the S in MEMBERS OF THE PUBLIC makes the wording consistent with the Kewaunee TS title for definition TS 1.0.o.1. NUREG-1431, Section 1.1, Definitions, does not include a definition of member(s) of the public. Notwithstanding, NUREG-1431 and Kewaunee TS are written such that the defined terms in TS Section 1 appear identically in capitalized type throughout the TS and Bases as a means of reflecting the use of the term as TS Section 1. The NRC staff finds that this change is administrative with no impact on the safety of the unit and is therefore, acceptable.

The NRC staff finds that the deletion of the word operating in the specification introduction is administrative with no impact on the safety of the unit and is consistent with the wording in NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.2 TS 6.16.b.1.B 3.2.1 Proposed TS Change Revise TS 6.16.b.1.B to change 10 CFR Part 20, Appendix B, Table II, Column 2" to ten times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402.

3.2.2 NRC Staff Evaluation The 1994 revision to 10 CFR Part 20, Appendix B, Table 2, Column 2, incorporated a change in the dose base for the liquid effluent concentration release rate limit from 500 millirem (mrem) per year to 50 mrem per year. Therefore, in order to retain the same dose base upon which the TS 6.16.b.1.b is based (500 mrem per year), the new Appendix B, Table 2, Column 2 values are multiplied by ten. This change is intended to eliminate possible confusion or improper implementation of the revised 10 CFR 20 requirements and is consistent with TSTF-258, Revision 4 and NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.3 TS 6.16.b.1.C 3.3.1 Proposed TS Change Revise TS 6.16.b.1.C to change reference from 10 CFR 20.106 to 10 CFR 20.1302.

3.3.2 NRC Staff Evaluation The 1994 revision of 10 CFR Part 20 replaced 10 CFR 20.106 with 10 CFR 20.1302.

Subpart D, Sections 20.1301 and 20.1302 now state the requirements for dose limits for individual members of the public, and compliance with the dose limits, respectively. This change is consistent with NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.4 TS 6.16.b.1.E 3.4.1 Proposed TS Change Revise TS 6.16.b.1.E to separate out the determination of cumulative and projected dose as follows: Determination of cumulative dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days. Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days.

3.4.2 NRC Staff Evaluation This revision clarifies that determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM is required at least once every 31 days. The existing TS could be interpreted as requiring determining projected dose contribution of the current calendar quarter and current calendar year every 31 days. The NRC

staff finds that this change is administrative in nature and is consistent with TSTF-308, Revision 1, and NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.5 TS 6.16.b.1.G 3.5.1 Proposed TS Change Revise TS 6.16.b.1.G to delete current specification and insert:

Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the SITE BOUNDARY shall be limited to the following:

1. For noble gases: a dose rate <500 mrem/yr to the total body and a dose rate of

<3000 mrem/yr to the skin, and

2. For iodine-131, iodine-133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: a dose rate of <1500 mrem/yr to any organ.

3.5.2 NRC Staff Evaluation This revision maintains the same dose rate limits as referenced in the current wording for TS 6.16.b.1.G, while also maintaining consistency with the methods of the ODCM for calculating these dose rates. Recognizing that this limit is an as low as reasonably achievable (ALARA) constraint on the release rate for gaseous effluents and not an annual dose limit, reference to the 10 CFR 20, Appendix B, Table 2, Column I values is not necessary. Change traveler TSTF-258 states that the change was made to eliminate possible confusion or improper implementation of the revised 10 CFR Part 20 requirements.

The NRC staff finds that the change is administrative in nature and is consistent with TSTF-258 and NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.6 TS 6.16.1.b.J 3.6.1 Proposed TS Change Revise TS 6.16.1.b.J to insert the phrase , beyond the site boundary, immediately following MEMBER(S) OF THE PUBLIC.

3.6.2 NRC Staff Evaluation This change is made to provide clarification. The NRC staff finds that the change is administrative in nature and is in accordance with TSTF-258, NUREG-1431, and 40 CFR Part 190. On this basis, the NRC staff finds the proposed change acceptable.

3.7 Surveillance Provisions 3.7.1 Proposed TS Change Insert the following sentence immediately after TS 6.16.1.b.J: The provisions of TS 4.0.b and 4.0.c are applicable to the Radioactive Effluent Controls Program surveillance frequency.

3.7.2 NRC Staff Evaluation This change specifies that the provisions of Kewaunee TS 4.0.b and 4.0.c, which contain provisions for maximum allowable surveillance frequency extension and missed surveillances, are applicable to the RECP surveillances. TS 4.0.b permits a 25 percent extension of the interval specified in the frequency (31 days). Allowing a 25 percent extension in the frequency of performing the monthly cumulative dose and projected dose calculation for the current quarter/year will have no effect on the outcome of the calculations.

As applied to the 31-day frequency, TS 4.0.b and 4.0.c would allow up to 31 days to complete the surveillance (dose calculation) if it is discovered that the surveillance was not performed within 38 days and 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> (the specified interval plus the 25 percent extension). Allowing 31 days to complete the cumulative dose and projected dose calculation for the current quarter/year is acceptable because it will have no effect on the outcome of the calculations and has no impact on the risk associated with plant operation. In addition, operating experience has shown that the calculated dose is usually well within limits. Thus, it is considered unlikely that a potential greater time interval between dose calculations will result in inadvertent effluent releases exceeding the specified limits. Additionally, TS 6.16.b.1 requires the RECP, which is contained in the ODCM, to include remedial actions to be taken whenever program limits are exceeded.

The NRC staff finds this change is consistent with the guidance contained in GL 89-01 and NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.8 TS 6.18.b.1.B 3.8.1 Proposed TS Change Revise TS 6.18.b.1.B to change the reference from 10 CFR 20.106 to 10 CFR 20.1302.

3.8.2 NRC Staff Evaluation The 1994 revision of 10 CFR Part 20 replaced 10 CFR 20.106 with 10 CFR 20.1302.

Subpart D, Sections 20.1301 and 20.1302 now state the requirements for dose limits for individual members of the public, and compliance with the dose limits, respectively. This change is consistent with NUREG-1431. On this basis, the NRC staff finds the proposed change acceptable.

3.9 Technical Evaluation Summary The NRC staff has reviewed the licensees submittal, and based on our review discussed above, the NRC staff finds the proposed changes to be acceptable.

4.0 VERIFICATIONS AND COMMITMENTS The licensees application dated February 5, 2005, made the following plant-specific regulatory commitment:

The Kewaunee ODCM and affected plant procedures will be updated during implementation of the approved TS amendment.

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitment can be provided by the licensees administrative processes, including its commitment management program. The NRC staff has agreed that Nuclear Energy Institute 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff (see Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000). Should the licensee choose to incorporate a regulatory commitment into the final safety analysis report or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.

5.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Wisconsin State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (70 FR 15944). Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

7.0 CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the

Commissions regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: D. Beaulieu Date: October 4, 2005