ML13302B680

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Keaunee Power Station - Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications
ML13302B680
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 10/17/2013
From: Mark D. Sartain
Dominion Energy Kewaunee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226D, LAR 256
Download: ML13302B680 (6)


Text

Dominion Energy Kewainee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 omin INo Web Address: www.dom.com October 17, 2013 U. S. Nuclear Regulatory Commission Serial No. 13-226D Attention: Document Control Desk LIC/CDS/RO 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 Renewed Facility Operating License (Operating License) Number DPR-43 for Kewaunee Power Station (KPS).

The proposed amendment would revise the 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 (References 2 and 3).

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, SVICKI L. HULL Mark D. Sartain Notary Public Vice President - Nuclear Engineering and Development Commonwealth of Virginia 140542 My Commission Expires May 31, 2014 COMMONWEALTH OF VIRGINIA

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i-COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, 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 /L7_._ay of 0e74Z)1jZ*j 2013.

My Commission Expires:

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Serial No. 13-226D LAR 256 RAI Response Page 2 of 2

Attachment:

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 and Craig Sly (DEK), "MF1952 KPS Permanently Defueled License and TS - Request for Additional Information -

MF1 952-RAII-SCVB-Heida-001 -2013-08-06," dated August 6, 2013.

3. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "Reviewer Bruce Heida has been replaced by Jerome Bettle for Branch SCVB (Containment and Ventilation)," dated September 30, 2013.

cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Dr. 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. 13-226D 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. 13-226D Page 1 of 3 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 Renewed Facility Operating License (Operating License) Number DPR-43 for Kewaunee Power Station (KPS).

The proposed amendment would revise the 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 (References 2 and 3).

The RAI questions and associated DEK responses are provided below.

NRC Question MF1952-RAII-SCVB-Heida-001-2013-08-06 Dominion Energy Kewaunee (DEK) submitted a certification to the NRC indicating its intention to permanently cease power operations at Kewaunee Power Station (KPS) pursuant to 10 CFR 50.82(a)(1)(i).

In support of this condition, DEK is requesting changes to the KPS license and associated technical specifications to reflect this permanently shut down and defueled condition in accordance with 10 CFR 50.36(c)(6).

One of the technical specification revisions is the deletion of TS 3.7.10, "Control Room Post Accident Recirculation (CRPAR) System," which specifies requirements to ensure that the CRPAR System provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity, chemicals, or toxic gas.

Title 10 CFR 50.36(c)(2)(ii) requires a technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of four criteria. Criterion 3 addresses structures, systems, of components that are part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Title 10 CFR 50 Appendix A, General Design Criteria, Criterion 19-Control room, requires that a control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Title 10 CFR 50.67(b)(2)(iii) requires adequate radiation protection be provided to permit access to and occupancy of the control room under accident conditions without

Serial No. 13-226D Page 2 of 3 personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) total effective dose equivalent (TEDE) for the duration of the accident.

In Order EA-12-051 (ADAMS Accession Number ML12056A044) the Commission determined all power reactor licensees must have a reliable means of remotely monitoring wide-range spent fuel pool levels. The order requires licensees shall have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel: (1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.

If an accident occurs at the Point Beach Nuclear Plant where evacuation is recommended for the sector where KPS is located, will KPS be evacuated?

" If KPS is evacuated, discuss how the spent fuel pool will be monitored as required by Order EA 12-051.

" If KPS is not evacuated, discuss what measures will be taken to protect operators required to monitor the KPS spent fuel pool.

Response

If an accident occurs at the Point Beach Nuclear Plant (PBNP) where evacuation is recommended for the sector where KPS is located, KPS staff needed for safe storage of irradiated fuel would not be evacuated.

In the event of a radiological emergency at PBNP, actions would be taken in accordance with abnormal operating procedures and, if warranted, the KPS Emergency Plan to protect onsite workers (including operators required to monitor the KPS spent fuel pool) and maintain dose received to as low as reasonably achievable (ALARA) while performing critical plant activities including spent fuel pool monitoring.

These actions could include evacuating non-essential staff, reducing area stay times, and providing alternate protection for essential staff. Direction for taking these actions is provided in various emergency plan implementing procedures.

Abnormal Operating Procedure (AOP) RM-001, "Abnormal Radiation Monitoring System," provides instructions for assessing abnormal radiation levels detected onsite.

Emergency Plan Implementing Procedure EPIP-AD-1 1, "Emergency Radiation Controls," provides instructions for controlling exposures to emergency workers to maintain their dose ALARA. Controls include emergency radiation work permits, time limitations on exposure, coverage by radiation protection staff, monitoring of internal and external exposure, respiratory protection equipment (e.g., self-contained breathing apparatus (SCBA)), and ingestion of stable iodine (e.g., Potassium Iodide).

This procedure also provides instructions for implementing Environmental Protection Agency

Serial No. 13-226D Page 3 of 3 (EPA) dose guidelines for emergency workers contained in EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents."

These instructions include guidance for controlling exposure to emergency workers required to perform tasks where exposure to levels greater than 10 CFR 20 occupational dose limits may occur. The Control Room Post Accident Recirculation (CRPAR) System is no longer required for the protection of operators as discussed above.

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 and Craig Sly (DEK), "MF1952 KPS Permanently Defueled License and TS - Request for Additional Information -

MF1952-RAII-SCVB-Heida-001-2013-08-06," dated August 6, 2013.

3. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "Reviewer Bruce Heida has been replaced by Jerome Bettle for Branch SCVB (Containment and Ventilation)," dated September 30, 2013.