ML072880289

License Amendment Regarding Relocation of Technical Specifications Requirements

ML072880289
Person / Time
Site:	Kewaunee
Issue date:	10/31/2007
From:	Milano P NRC/NRR/ADRO/DORL/LPLIII-1
To:	Christian D Dominion Energy Kewaunee
Milano P, NRR/DORL/LPLIII-1, 415-1457
Shared Package
ML072880065	List: ML072880289
References
TAC MD3989
Download: ML072880289 (13)

Text

October 31, 2007 Mr. David A. Christian President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

KEWAUNEE POWER STATION - ISSUANCE OF AMENDMENT REGARDING RELOCATION OF TECHNICAL SPECIFICATIONS REQUIREMENTS (TAC NO. MD3989)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 193 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 December 15, 2006.

The amendment incorporates changes to the TSs associated with several previously approved industry initiatives. Specifically, the amendment relocates the TS for Safety Limit Violation, currently located in the administrative controls TS section, to the safety limit TS section and deletes the notification requirements, as approved by TS Task Force (TSTF) Change Traveler TSTF-05-A, "Deletion of Safety Limit Violation Notification Requirements." The amendment also incorporates generic position titles, as approved by TSTF-65-A, "Use of Generic Titles for Utility Positions," and incorporates items approved by NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance."

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

Sincerely,

/RA/

Patrick D. Milano, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosures:

1. Amendment No. 193 to License No. DPR-43

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

ML072880289, Package: ML072880065, TS: ML073 OFFICE LPL3-1/PM LPL3-1/LA SRXB/BC EQVA/BC ITSB/BC OGC/NLO LPL3-1/(A)BC NAME PMilano THarris SM for DThatcher TKobetz MLoftus CMunson GCranston DATE 10/18/07 10/18/07 10/18/07 10/19/07 10/ /07 10/25/07 10/31/07 Kewaunee Power Station cc: Ms. Lillian M. Cuoco, Esq.

Senior Counsel Resident Inspectors Office Dominion Resources Services, Inc.

U.S. Nuclear Regulatory Commission 120 Tredegar Street N490 Hwy 42 Riverside 2 Kewaunee, WI 54216-9510 Richmond, VA 23219 Ms. Leslie N. Hartz Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N 490 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. 193 License No. DPR-43

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

A. The application for amendment by Dominion Energy Kewaunee, Inc. dated December 15, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. 193, are hereby incorporated in the license. The licensees 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/

Clifford G. Munson, Acting Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: October 31, 2007

ATTACHMENT TO LICENSE AMENDMENT NO. 193 FACILITY OPERATING LICENSE NO. DPR-43 DOCKET NO. 50-305 Replace the following page of the Facility Operating License No. DPR-43 with the attached revised page. The changed area is identified by a marginal line.

REMOVE INSERT Page 3 Page 3 Page 4 Page 4 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 INSERT iv iv 2.1-1 2.1-1 2.2-1 2.2-1 6.1-1 6.1-1 6.2-1 6.2-1

--- 6.2-2 6.3-1 6.3-1 6.7-1 6.7-1 6.8-1 6.8-1 6.10-1 6.10-1 6.10-2 ---

6.13-1 6.13-1 6.17-1 6.17-1 6.18-1 6.18-1

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR, Chapter 1: (1) Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70, (2) is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and (3) is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady-state reactor core power levels not in excess of 1772 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, are hereby incorporated in the license. The licensee shall operate the facility In accordance with the Technical Specifications.

(3) Fire Protection The licensee shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the licensee's Fire Plan, and as referenced in the Updated Safety Analysis Report, and as approved in the Safety Evaluation Reports, dated November 25, 1977, and December 12, 1978 (and supplement dated February 13, 1981) subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission, only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(4) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: ANuclear Management Company Kewaunee Nuclear Power Plant Physical Security Plan (Revision 0)" submitted by letter dated October 18, as supplemented by letter dated October 21, 2004.

(5) Fuel Burnup The maximum rod average burnup for any rod shall be limited to 60 GWD/MTU until completion of an NRC environmental assessment supporting an increased limit.

Amendment No. 193 3

(6) Steam Generator Upper Lateral Supports The design of the steam generator upper lateral supports may be modified by reducing the number of snubbers from four (4) to one (1) per steam generator.

(7) Deleted (8) Operator Actions The auxiliary feedwater system local manual operator actions as described in the License Amendment Request submitted May 5, 2005, and supplemented on June 9, 2005, shall be eliminated no later than completion of Kewaunee refueling outage R-29.

(9) Surveillance Test Interval Relaxation In lieu of the specified frequencies, Dominion Energy Kewaunee, Inc. may complete the surveillance requirements noted in Table 2.C.(9) on page 5a during the fall 2006 refueling outage, but not later than October 7, 2006.

(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Amendment No. 193 4

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO AMENDMENT NO. 193 TO FACILITY OPERATING LICENSE NO. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION DOCKET NO. 50-305

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated December 15, 2006, Dominion Energy Kewaunee, Inc. (the licensee), requested changes to the technical specifications (TSs) for the Kewaunee Power Station (KPS). The proposed amendment would incorporate changes to the TSs associated with previously approved industry initiatives. The first change would relocate the TS for Safety Limit Violation, currently located in the administrative controls TS section, to the safety limit (SL) TS section and would delete the notification requirements, as approved by TS Task Force (TSTF) Change Traveler TSTF-05-A, "Deletion of Safety Limit Violation Notification Requirements." The second change would incorporate generic position titles, as approved by TSTF-65-A, "Use of Generic Titles for Utility Positions," and incorporate items approved by NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance."

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The Commissions regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.36, Technical Specifications. Additional information regarding NRC policies on TSs is contained in the NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors (58 FR 39132), dated July 22, 1993.

Under the NRC TS Improvement Program, an improved set of standard TSs (STS) were issued in 1992, for each of the licensed nuclear steam supply systems and associated balance-of-plant systems. Since the STS were issued, numerous STS changes have been made through a joint NRC-industry STS change process, involving travelers initiated by the industry-sponsored TSTF, which are subsequently reviewed and approved by the NRC staff before incorporation into subsequent STS revisions. NUREG-1431, Revision 3 contains the current STS for Westinghouse Plants. In accordance with 10 CFR 50.36(c)(2)(iii), adoption of STS by plants licensed before August 18, 1995, is voluntary and STS provisions may be partially adopted without adopting the improved format.

Two STS changes, applicable to the proposed amendment, have been approved and incorporated into NUREG-1431. TSTF-05-A, approved June 11, 1996, deletes the notification, reporting, and restart requirements that duplicate or are required to comply with other regulations. TSTF-65-A, approved December 2, 1997, allows the use of generic position titles as provided by American National Standards Institute/American Nuclear Society (ANSI/ANS)

Standard ANSI/ANS 3.1, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, in lieu of plant-specific position titles. Consistent with the NRC staffs approval of TSTF-65-A, compliance details relating to the plant-specific titles fulfilling the duties of the generic positions are defined, established, documented, and updated in a plant controlled document.

Administrative Letter (AL) 95-06 provides guidance for relocating administrative controls from the TSs to licensee quality assurance program descriptions; specific guidance is provided in the areas of procedures, records and record retention. The licensees quality assurance (QA) program is described in Dominion Topical Report DOM-QA-1.

3.0 TECHNICAL EVALUATION

3.1 Relocation of Safety Limit Violation Technical Specifications 3.1.1 Background The reactor core SLs should not be exceeded during steady state operation, normal operation, operational transients, and anticipated operational occurrences. The restrictions of the reactor core SLs prevent overheating of the fuel and cladding, as well as possible cladding perforation, that would result in the release of fission products to the reactor coolant. Overheating of the fuel is prevented by maintaining the steady-state peak linear heat rate below the level at which fuel centerline melting occurs. Overheating of the fuel cladding is prevented by restricting fuel operation to within the nucleate boiling regime where the heat transfer coefficient is large and the cladding surface temperature is slightly above the coolant saturation temperature.

The reactor coolant system (RCS) serves as a barrier for preventing radionuclides contained in the reactor coolant from reaching the atmosphere. In the event of a fuel cladding failure, the RCS is the primary barrier against the release of fission products. By establishing a system pressure limit, the continued integrity of the RCS is ensured.

3.1.2 Current TS 6.7, Safety Limit Violation In the event a SL is violated, TS 6.7 requires that (a) the reactor be shut down and operation not be resumed until authorized by the Commission, and (b) a report be prepared in accordance with 10 CFR 50.72 and 10 CFR 50.73.

3.1.3 Proposed TS Change The licensee proposed to relocate the SL TS from the Administrative TS Section TS 6.7 to the SL TS Section TS 2.1. Specifically, the licensee proposed to:

a. Add a new TS 2.1.d to provide required actions if one or more of the reactor core SLs are violated.

b. Designate the RCS pressure SL as TS 2.2.a and add a new TS 2.2.b to provide required actions if the RCS pressure SL is violated.

c. Delete TS 6.7.

3.1.4 Staff Evaluation The incorporation of the actions required, should a SL be violated, into TS Sections 2.1 and 2.2, places the required actions in the TS sections that are associated with SLs, and thus, is more appropriate. The NRC staff finds the addition of the action completion times to restore compliance and to place the plant in the appropriate shutdown condition to be acceptable. The allowed completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the reactor core SL recognizes the importance of bringing the unit to a MODE of operation where this SL is not applicable, and reduces the probability of fuel damage. Thus, the NRC staff finds it acceptable. The allowable completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the RCS pressure SL also recognizes the importance of reducing power level to a MODE of operation where the potential for challenges to safety systems is minimized. If the RCS pressure SL is exceeded in the Hot, Intermediate, or Cold Shutdown Modes or the Refueling Mode, RCS pressure must be restored to within the SL value within 5 minutes. Exceeding the RCS pressure SL in these modes is more severe than exceeding this SL in Operating and Hot Standby MODEs since the reactor vessel temperature may be lower and the vessel material, consequently, less ductile. As such, pressure must be reduced to less than the SL within 5 minutes. The action does not require reducing MODES, since this would require reducing temperature, which would compound the problem by adding thermal gradient stresses to the existing pressure stress.

Therefore, the NRC staff finds the proposed changes acceptable.

The removal of the notification, reporting, and plant startup requirements from the TSs is an administrative change because the current requirements duplicate what is already contained in 10 CFR 50.72 and 10 CFR 50.73. NRC authorization to restart operation following a SL violation is required by 10 CFR 50.36(c)(1)(i)(A). Because the licensee is still required to meet these regulations, repetition of the requirements in the TSs is not needed. Additionally, these changes are consistent with TSTF-05-A, Revision 1, as incorporated in NUREG-1431. The removal of the statements from TSs is an administrative change, does not change the technical content, intent, or interpretation of these TSs, and does not relieve the licensee of any obligations for reporting violations. Thus, the NRC staff finds the proposed removal of redundant notification, reporting, and plant startup requirements from the KPS TSs is acceptable.

3.2 Dominion QA Program Description Associated TS Changes 3.2.1 Proposed TS Changes

a. Modify TS 6.1.1 and 6.1.b to change Manager - Kewaunee Plant to the generic position title of plant manager.

b. Modify TS 6.2.a and TS 6.2.b to change Operational Quality Assurance Program Description to quality assurance program.

c. Modify TS 6.2.b.1, TS 6.2.b.3, and 6.2.b.7, to change plant-specific titles to generic position titles: Shift Manager to shift manager, Reactor Operators to reactor operators, Nuclear Auxiliary Operators to nuclear auxiliary operators, Shift Technical Advisor to shift technical advisor, and Radiation Technologist to radiation technologist.

d. Designate current TS 6.2.c, Organizational Changes, as TS 6.2.d.

e. Add a new TS 6.2.c, Plant Specific Titles, to designate that plant-specific titles for those fulfilling the responsibilities of generic position titles in the TS shall be maintained in appropriate administrative documents.

f. Modify TS 6.3.a.1 and TS 6.3.b to change plant-specific titles to generic position titles: Radiation Protection Manager to radiation protection manager, Shift Technical Advisor to shift technical advisor.

g. Modify TS 6.8, Procedures, to remove the reference to ANSI N18.7-1976 and add a reference to the quality assurance program.

h. Delete TS 6.10, Record Retention.

I. Modify TS 6.13.a.3 and TS 6.13.b to change plant-specific titles to generic position titles: Health Physicist to health physicist, and Shift Manager to shift manager.

j. Modify TS 6.17.b.1 and TS 6.18.b.1 reference to TS 6.10 to reference the quality assurance program for record retention requirements.

3.2.2 Staff Evaluation AL 95-06 provides guidance to licensees to relocate TS administrative controls for record requirements and processes related to procedures to QA programs. The licensee has implemented the NRC-approved Dominion fleet QA program. The QA program addresses procedural provisions (Section 5) and record requirements (Section 17). Based on the relocations allowed by AL 95-06, the NRC staff finds acceptable the deletion of the procedural (TS 6.8) and record requirements from the TSs (TS 6.10, TS 6.17.b.1, TS 6.18.b.1).

Replacement of the plant-specific titles with generic position titles does not eliminate any of the qualifications, responsibilities or requirements for these positions, since the plant-specific position titles are identified in license documents (TS 6.2.c). The NRC staff finds the use of generic position titles, as specified above, to be consistent with TSTF-65-A, as incorporated in NUREG-1431. The use of the generic term quality assurance program for Operational Quality Assurance Program Description is unambiguous and consistent with the use of generic position titles and is also acceptable. The TS 6.8 reference to ANSI N18.7-1976 is redundant to commitments addressed by the QA program and therefore can be deleted. Therefore, the NRC staff finds the proposed changes acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Wisconsin State official was notified of the proposed issuance of the amendment. The State official had no comment.

5.0 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 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 (72 FR 11386). 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.

6.0 CONCLUSION

The 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 Commission's 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: K. Heck, NRO J. Patel, NRR Date: October 31, 2007