ML13277A359

Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications

ML13277A359
Person / Time
Site:	Kewaunee
Issue date:	09/23/2013
From:	Grecheck E Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226A
Download: ML13277A359 (14)

Text

- I Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 ~Dominioin Web Address: www.dom.com September 23, 2013 U. S. Nuclear Regulatory Commission Serial No. 13-226A Attention: Document Control Desk LIC/CDS/R0 Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the facility.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 2). The RAI questions and associated DEK response are provided in Attachment 1 to this letter.

The June 1, 2014 requested approval date for the submittal remains unchanged.

Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Eugene S. Grecheck Vice President - Nuclear Engineering and Development CRAIG D SLY Notary Public COMMONWEALTH OF VIRGINIA ) Commonwealth of Virginia

) Reg. # 7518653 COUNTY OF HENRICO My Cormission Expires December 31, 20' The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, who is Vice President - Nuclear Engineering and Development 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 that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this _A¶_day of -. e'*e.,k 2013.

My Commission Expires: 112 l3 Ih Notary Public: _ _ _ _ _

I

Serial No. 13-226A License Amendment Request 256 RAI Response Page 2 of 2 Attachments:

1. Response to Request for Additional Information

References:

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated May 29, 2013 (ADAMS Accession No. ML13156A037)

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (Defueled License and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are being prepared - see attached drafts", dated August 8, 2013 cc: Regional Administrator, Region III

.U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Dl 5 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 13-226A ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-226A Attachment 1 Page 1 of 11 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the facility.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 2). The RAI questions and associated DEK responses are provided below.

NRC Question MF2370-RAII-AHPB-Lapinsky-001 In the first sentence of proposed TS 5.1.1, the term "plant operation" is used. To be consistent with the other proposed TSs, shouldn't that phrase be replaced with a phrase like "the safe handling and maintenance of nuclear fuel" to reflect the major function of a defueled plant? TS 5.2.1.b has a similar problem where "safe operation" should be changed simply to "safety".

Response

Whereas the distinction in the wording presented in this question is understood, the proposed wording was made for consistency with previous precedent and NUREG-1431. The terms "plant" and "facility" are used interchangeably throughout NUREG-1431, "Standard Technical Specifications," and throughout the regulations in Part 50.

These terms refer to the collection of systems, structures, and components that make up KPS.

10 CFR 50.36(c)(5) "Administrative controls," states: "Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner" (emphasis added).

The terms "plant operation" and "safe operation," as used within this context, are generic terms consistent with NRC guidance in NUREG-1431 and related NRC requirements in Part 50. Additionally, similar phrases were used and approved for the Millstone 1 and Zion Permanently Defueled Technical Specifications. Because the originally proposed phrases are consistent with past precedent and present guidance and remain appropriate for adequately controlling the underlying administrative requirements, DEK requests that the originally proposed phrases remain unchanged.

Serial No. 13-226A Attachment 1 Page 2 of 11 NRC Question MF2370-RAII-AHPB-Lapinsky-002 In the second sentence of proposed TS 5.1.1, the term "nuclear safety" is used.

Shouldn't that phrase also be replaced with a phrase like "the safe handling and maintenance of nuclear fuel" as was proposed in TS 5.2.1.b later in the submittal.

There is a similar problem with the use of "nuclear safety" and "operating" in TS 5.2.1.c.

Response

Consistent with the response to Question MF2370-RAII-AHPB-Lapinsky-001 above, no change is being proposed to the second sentence of TS 5.1.1.

This TS was approved by NRC in Amendment 207 (Reference 3) as part of the conversion to KPS Improved Technical Specifications. TS 5.1.1 is applicable at all times. The verbiage in TS 5.1.1 was appropriate for controlling the underlying administrative requirements with the reactor defueled prior to the permanent cessation of operation and remains appropriate for controlling these same requirements with the reactor permanently defueled.

Likewise, no change is being proposed to the existing terms "nuclear safety" and "operating" in TS 5.2.1.c. The term, "safe handling and maintenance of nuclear fuel" is analogous to the term "nuclear safety" for a permanently defueled facility like KPS.

The term "operating," as used herein, is consistent with the requirement of 10 CFR 50.36(c)(5) as discussed in the response to Question MF2370-RAII-AHPB-Lapinsky-001 above.

Similar phrases (e.g., "safe operation" and "overall plant nuclear safety") were approved for the corresponding Millstone 1 Permanently Defueled Technical Specifications.

Because the originally proposed phrases remain appropriate for adequately controlling the underlying administrative requirements, DEK requests that the originally proposed phrases remain unchanged.

NRC Question MF2370-RAII-AHPB-Lapinsky-003 Prior to their performance, who approves fuel moves and heavy load moves that could affect the safe handling and storage of nuclear fuel?

Response

Fuel moves and heavy load moves that could affect the safe handling and storage of nuclear fuel would be approved by the shift manager. In accordance with proposed TS 5.1.2, the shift manager will retain the overall shift command and control function.

Proposed TS 5.2.2 requires the shift manager to be a Certified Fuel Handler.

Serial No. 13-226A Attachment 1 Page 3 of 11 NRC Question MF2370-RAII-AHPB-Lapinsky-004 In TS 5.2.2.b, it is stated: "Shift crew composition may be less than the minimum requirement of Table 5.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, except in severe weather conditions." It is conceivable that under severe weather conditions, neither of the two minimum crew members would show up; and under severe weather conditions, the time limit of two hours is not applicable. Are on-shift crew members held over until their relief comes in? If no, how is the above situation (no minimum crew for one or more shifts) avoided? If there is a strategy to avoid the above situation, describe the strategy, and where and how it is documented.

Response

On-shift crew members are held over until relieved. Procedure OP-KW-100, "Conduct of Operations," specifies that the off-going watchstander remains responsible until properly relieved, and does not relinquish the watch until satisfied that the on-coming watchstander is fully briefed and prepared. This 2-hour allowance is consistent with NUREG-1431 and was approved by NRC in Amendment 207 (Reference 3) as part of the conversion to KPS Improved Technical Specifications.

While it is conceivable that neither of the two minimum crew members would (or could) arrive onsite under severe weather conditions, such conditions would also be expected to prevent the onshift crew members from departing the site. Regardless, barring extreme circumstances, appropriate onshift staffing is required to be retained on site under such situations (i.e., personnel are held over until relief staff arrives).

Thus, DEK proposes no change to the 2-hour allowance contained in TS 5.2.2.b.

NRC Question MF2370-RAII-AHPB-Lapinsky-005 Proposed TS 5.2.2.c. does not define "qualified individual". Clarify, so that the TS users can understand the level of qualification required.

Response

TS 5.2.2.c is proposed to state, "All fuel handling operations shall be directly supervised by a qualified individual." The "qualified individual" referred to in proposed TS 5.2.2.c is a Certified Fuel Handler. Certified Fuel Handlers are responsible for handling of nuclear fuel, as stated in the "Shift Manager / Certified Fuel Handler Training Program Guide."

This document also explicitly requires that Certified Fuel Handlers be trained to supervise fuel movement as part of their qualification process. Additionally, proposed TS 5.1.2 places overall responsibility for facility shift operation with the shift manager, who is required to be a Certified Fuel Handler per proposed TS 5.2.2.d.

Serial No. 13-226A Attachment 1 Page 4 of 11 Station procedures require that plant staff verify their qualifications in accordance with the qualification documents. This process provides appropriate understanding of qualification level requirements for the job function. Furthermore, the proposed statement is identical to the requirement approved by NRC for the currently existing Millstone 1 TS 5.2.2.e.

Thus, DEK concludes that the TS do not need the suggested additional level of detail.

NRC Question MF2370-RAII-AHPB-Lapinsky-006 Can any control actions related to the Spent Fuel Pool or that could affect the safe handling and storage of nuclear fuel, be taken from the control room? If yes, describe actions that could be taken.

Response

There are activities that could be performed from the control room that have the potential to affect forced cooling of nuclear fuel. These activities include starting and stopping spent fuel cooling pumps and service water pumps, as well as changing the electrical power distribution system alignment.

In accordance with proposed TS 5.1.2, the shift manager retains the overall shift command and control function. Shift manager functions may be performed either remotely from the control room or locally in the plant. All spent fuel handling activities are performed locally at the SFP. Indications and/or alarms are also received in the control room that would be indicative of SFP abnormalities. The shift manager is responsible for directing response to those abnormalities, from either the control room or local to the SFP, in accordance with applicable response procedures.

NRC Question MF2370-RAII-AHPB-Lapinsky-007 Will the Control Room remain the center of the command function? If not, where will the command center be?

Response

The control room is initially expected to remain the physical center of the command function. Any subsequent changes to that arrangement would be made in accordance with the requirements of 10 CFR 50.59.

However, since control of activities may be performed either remotely from the control room or locally in the plant, the location of the command center is functionally where the shift manager is located.

Serial No. 13-226A Attachment 1 Page 5 of 11 NRC Question MF2370-RAII-AHPB-Lapinsky-008 Describe how a Fuel Handling Accident with serious, open-wound, personnel injuries would be identified and mitigated. Focus on the alarms, displays, and other cues that would allow identification of the problem, how the chain of command would communicate, time constraints, and reporting responsibilities.

Response

No change to the station's response to a fuel handling accident is being proposed in this submittal. Because 90 days have elapsed since the reactor was permanently shut down, reactor fuel has sufficiently decayed such that the radiological consequences of a fuel handling accident remain within limits without relying on structures, systems, and components (SSCs) remaining functional for accident mitigation during or following the event (provided the spent fuel pool water level requirement of TS 3.7.13 is met). As such, the occurrence of an injury during a fuel handling accident would not adversely impact the resultant radiological consequences of that event.

Station procedures require additional staffing during fuel handling evolutions, beyond the minimal shift staffing requirements specified in TS. Since a fuel handling accident can only occur during fuel handling, this additional staff would be available to respond to both a fuel handling event as well as a concurrent injury.

Occurrence of a fuel handling accident would be observed by the individuals involved in moving fuel assemblies (the same as would have occurred when the plant was operating). Radiation monitors would also provide indication of such an event. The response to such an event would be in accordance with plant response procedures for such an event.

Although occurrence of a serious, open-wound, personnel injury during a fuel handling accident is not a postulated event, the additional staffing that is required to be present during fuel handling activities is expected to be sufficient to address such a situation.

KPS has processes in place to address injuries (regardless of when they occur).

Alarms and displays do not factor into the discovery of an injury. Rather, an injury would be identified by personal observation and communicated to the shift manager.

Uninjured staff involved in the activity would summon additional assistance from both onsite and offsite resources, as needed, using the plant-wide announcing system and personal communication devices. Since there are no pertinent time constraints associated with the fuel handling accident; addressing the injury would be performed as quickly as feasible commensurate with the severity of the injury. The existing administrative chain of command would be used during the response for both reporting and for command and control, which is under the direction of the shift manager.

Serial No. 13-226A Attachment 1 Page 6 of 11 NRC Question MF2370-RAII-AHPB-Lapinsk¥-009 In its submittal, the licensee stated that Emergency Operating Procedures will not be used or maintained. Are there procedures that provide guidance to personnel regarding a) Fuel Handling Accidents? b) Spent fuel pool events, such as level control problems, dilution? c) External events, such as explosions, flooding, high winds, snow, ice, and extreme cold, and seismic events? If yes, identify the appropriate procedures by Title and Number and procedure type, e.g. normal operating procedure, abnormal, off-normal, EOP, SAMG, EDMG, etc.

Response

As stated in the submittal, TS 5.4, "Procedures," provides requirements regarding administration of written procedures. TS 5.4 will remain germane with the reactor permanently defueled. As such, it is being retained and revised to reflect the permanently defueled condition of KPS.

Only TS 5.4.1.b is being deleted because the emergency operating procedures discussed therein are no longer required. These emergency operating procedures pertained only to events resulting from reactor operation. Therefore, they are no longer needed with the reactor in the permanently defueled condition.

KPS has other procedures in addition to emergency operating procedures. Those procedures that are needed to control activities associated with the permanently defueled facility will continue to be used and maintained. These procedures include normal and abnormal operating procedures, alarm response procedures, etc.

A representative list of procedures that provide guidance to personnel regarding: a) fuel handling accidents; b) spent fuel pool events; and, c) external events, include the following.

a) Fuel Handling Accidents

• Procedure OP-KW-AOP-FH-002, "Dropped or Damaged Fuel Assembly."

b) Spent Fuel Pool Events

• Procedure OP-KW-AOP-SFP-001, "Abnormal Spent Fuel Pool Cooling and Cleanup System Operation."

c) External Events

• Procedure OP-KW-AOP-GEN-004, "Response to Natural Events."

Serial No. 13-226A Attachment 1 Page 7 of 11 NRC Question MF2370-RAII-AHPB-Lapinsky-010 Is anyone in the chain-of-command above the Shift Manager required to be a Certified Fuel Handler (CFH) or to attend equivalent training?

Response

The KPS management structure will not require positions above the shift manager to be a Certified Fuel Handler or to attend equivalent training. DEK has determined that based on the permanently shutdown and defueled status of the plant, and the time available to mitigate credible events, that operational activities/responses are less complex than that of an operating plant. As such, management oversight of the plant can be performed by individuals meeting the applicable requirements of ANSI N18.1-1971 (as required by TS 5.3.1) and need not be qualified as Certified Fuel Handlers.

NRC Question MF2370-RAII-AHPB-Lapinsky-01 I How many people in the organization will be Certified Fuel Handlers?

Response

Per proposed TS 5.2.2.d the shift manager is required to be a Certified Fuel Handler.

Each operations shift will have one Certified Fuel Handler. There will be a sufficient number of individuals qualified as Certified Fuel Handlers to staff the plant 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week.

NRC Question MF2370-RAII-AHPB-Lapinsky-012 What are the qualifications for Kewaunee personnel who will fill the following positions:

a. Specified corporate officer? (5.2.1.c)

b. Plant Manager?

c. Shift Manager?

d. Certified Fuel Handler?

e. Non-certified Operator?

f. CFH Instructor?

g. Operations Manager?

h. Training Coordinator?

Serial No. 13-226A Attachment 1 Page 8 of 11

Response

The qualifications for KPS personnel are identified in TS 5.3.1. As stated therein, each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions. An exception is made for the Radiation Protection Manager, who shall meet or exceed the recommendation of Regulatory Guide 1.8, Revision 1-R, September 1975, or their equivalent as further clarified in to the NRC Safety Evaluation Report enclosed with Amendment No. 46, dated July 12, 1982.

The qualifications requirements for personnel who will fill the listed positions are described below.

a. Specified Corporate Officer (5.2.1.c)

This individual is designated by the licensee as specified in the quality assurance plan (Dominion Topical Report DOM-QA-1, "Nuclear Facility Quality Assurance Program Description"). This position has no qualification requirements beyond the applicable requirements established in ANSI N18.1-1971.

b. Plant Manager This individual is designated by the licensee as specified in the quality assurance plan (Dominion Topical Report DOM-QA-1, "Nuclear Facility Quality Assurance Program Description"). This position has no qualification requirements beyond the applicable requirements established in ANSI N18.1-1971.

c. Shift Manager Qualified as a shift manager per the Shift Manager / Certified Fuel Handler Training Program required by proposed TS 5.3.2 (which includes the applicable requirements of a supervisor as established in ANSI N18.1-1971).

d. Certified Fuel Handler Qualified as a certified fuel handler per the Shift Manager / Certified Fuel Handler Training Program required by proposed TS 5.3.2 (which includes the applicable requirements of a supervisor as established in ANSI N18.1-1971).

e. Non-certified Operator Qualified as a plant operator in accordance with plant qualification requirements and consistent with the applicable requirements established in ANSI N18.1-1971.

Serial No. 13-226A Attachment 1 Page 9 of 11

f. CFH Instructor CFH instruction is an ancillary job function performed by subject matter experts and qualified mentors who meet the applicable requirements established in ANSI N18.1-1971.

g. Operations Manager This individual is designated by the licensee as specified in the quality assurance plan (Dominion Topical Report DOM-QA-1, "Nuclear Facility Quality Assurance Program Description"). This position has no qualification requirements beyond the applicable requirements established in ANSI N18.1-1971.

h. Training Coordinator This is a designated ancillary job function with no specific qualification requirements beyond those established in ANSI N18.1-1971.

NRC Question MF2370-RAII-AHPB-Lapinsky-013 In Section 5.4 of the proposed TSs, "Procedures", no mention is made of security procedures or emergency planning and preparedness procedures. Confirm that these areas will continue to be controlled by procedure.

Response

Activities involving security and emergency planning and preparedness will continue to be controlled by procedure.

Security and emergency preparedness activities are required to be maintained and controlled in accordance with 10 CFR 73 and 10 CFR 50.47, respectively. Additionally, TS 5.4.1 continues to require that the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, be maintained, which includes security and emergency preparedness.

The only change being requested to TS Section 5.4 is deletion of TS 5.4.1.b, regarding emergency operating procedures, because these specific emergency operating procedures pertained only to events resulting from reactor operation. Therefore, they are not needed with the reactor in the permanently defueled condition.

All other procedure requirements of TS Section 5.4 are being retained. Specifically, those procedures that are needed to control activities associated with the permanently defueled facility will continue to be used and maintained. This TS Section is consistent with NUREG-1431 and was approved by NRC in Amendment 207 (Reference 3) as part of the conversion to KPS Improved Technical Specifications.

Serial No. 13-226A Attachment 1 Page 10 of 11 NRC Question MF2370-RAII-AHPB-Lapinsky-014 Will relevant procedures, drawings, and instructions continue to be controlled per 10 CFR 50, Appendix B, Criterion VI, "Document Control" requirements?

Response

Yes.

NRC Question MF2370-RAII-AHPB-Lapinsky-015 Describe a fully staffed shift. Will the facility be fully staffed 24/7? If not, describe the work schedule and the staffing plan.

Response

As per proposed TS 5.2.2 and associated Table 5.2.2-1, the minimum staffing requirements are one Certified Fuel Handler and one plant operator. The facility is staffed for coverage 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week. Additional on-shift staffing is provided to satisfy applicable Security, Fire Protection, and Emergency Preparedness requirements.

NRC Question MF2370-RAII-AHPB-Lapinskv-016 Will a qualified Radiation Protection Manager be required to be on shift? Who will provide RP technical oversight for fuel handling activities?

Response

The Radiation Protection Manager is not required to be on shift. Rather, the Radiation Protection Manager is part of the normal facility staff. Per proposed TS 5.2.2 and Table 5.2.2-1, there is no requirement for a qualified radiation protection manager to be a part of the minimum shift crew.

Radiation protection (RP) technical oversight during fuel handling activities is provided by facility or supplemental RP personnel as specified in applicable RP and fuel handling procedures.

Serial No. 13-226A Attachment 1 Page 11 of 11 NRC Question MF2370-RAII-AHPB-Lapinsky-017 TS 5.3.2 requires that a CFH training program be maintained. Who manages the CFH training program? Will that person be a CFH or have equivalent qualifications?

Response

The Manager Nuclear Operations manages the CFH training program. This manager may be, but is not required to be, a CFH. The Manager Nuclear Operations assigns a Department Training Coordinator to assist in the implementation and delivery of the program. DEK intends for the Department Training Coordinator to typically be a CFH.

Proposed TS 5.3.2 is identical to the requirement approved by NRC for the currently existing Millstone 1 TS 5.4.1.

References

1. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (Defueled License and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are being prepared - see attached drafts," dated August 8, 2013.

2. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated May 29, 2013 (ADAMS Accession No. ML13156A037).

3. Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 207 to Facility Operating License No. DPR-43, Dominion Energy Kewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2, 2011.