ML14029A053

License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme

ML14029A053
Person / Time
Site:	Kewaunee
Issue date:	01/16/2014
From:	Mark D. Sartain Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-495A
Download: ML14029A053 (5)

Text

Dominion Energy Kewaunee, Inc. 1'I Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 DominEoN Web Address: www.dom.com January 16, 2014 U. S. Nuclear Regulatory Commission Serial No. 13-495A Attention: Document Control Desk LIC/JG/RO Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST 257, PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS) by letter dated December 11, 2013 (Serial Number 13-495). The proposed amendment would revise the emergency plan and emergency action level (EAL) scheme. Due to legibility issues with some of the supporting calculation pages, the original submittal was not able to be docketed by the NRC. Therefore, DEK is hereby resubmitting the original request. For convenience, this new submittal replaces the original submittal in its entirety, and the original submittal is hereby retracted. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR 50, Appendix E, Section IV.B.2.

By letter dated May 14, 2013, DEK submitted a certification of permanent removal of fuel from the reactor vessel (Reference 1). Consequently, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for KPS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Since KPS is in a permanently defueled condition, the number and severity of potential radiological accidents is significantly less than when the plant was operating. Therefore, DEK is proposing a new EAL scheme and corresponding emergency plan changes to reflect the currently defueled status of the plant.

The proposed emergency plan does not meet all the standards of 10 CFR 50.47(b) and requirements of 10 CFR 50, Appendix E. DEK previously submitted requests for exemptions from the portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, Section IV that the proposed emergency plan does not meet, by letter dated July 31, 2013 (Reference 2). The proposed emergency plan revisions are predicated on approval of the exemption requests. to this letter contains a description, technical analysis, significant hazards determination, and environmental considerations evaluation for the proposed amendment. Attachment 2 contains a matrix that compares the proposed EALs to the corresponding information in Nuclear Energy Institute 99-01, "Methodology for Development of Emergency Action Levels," Revision 6, implementation guidance.

Enclosures 1, 2, and 3 to this letter provide the proposed KPS Emergency Plan, the frfA

Serial No. 13-495A License Amendment Request 257 Page 2 of 5 proposed EAL scheme, EAL bases document, and supporting calculations, respectively.

The supporting calculations in Enclosure 4 are being provided to the Document Control Desk in two forms, hard-copy and electronic copy on a digital video disc. The supporting calculations in Enclosure 4 are being provided to the other recipients of this letter (listed in the "carbon copy" list below) by electronic copy on a digital video disc only.

The KPS Facility Safety Review Committee has reviewed the proposed amendment and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91(b).

DEK requests approval of this proposed amendment by October 31, 2014. Once approved, the amendment will be implemented within 60 days.

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

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Development COMMONWEALTH OF VIRGINIA )

)

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 ____day of UA4"LuLOLj ,2014.

My Commission Expires: IZ2431 Notdry PubliV CRAIG DSLY Notary Public Commonwealth of Virginia Reg.Expires MY Commission # 7518653 December 31, 2041

Serial No. 13-495A License Amendment Request 257 Page 3 of 5

References:

1. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Removal of Fuel from the Reactor Vessel," dated May 14, 2013. (ADAMS Accession No. ML13135A209)

2. Letter from A. J. Jordan (DEK) to NRC Document Control Desk, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," dated July 31, 2013.

Attachments:

1. Discussion of Change, Technical Analysis, Significant Hazards Determination and Environmental Considerations

2. Comparison Matrix for Permanently Defueled EALs Based Upon NEI 99-01, "Methodology for Development of Emergency Action Levels," Revision 6

Enclosures:

1. Permanently Defueled Emergency Plan

2. Permanently Defueled Emergency Action Level Scheme

3. Permanently Defueled Emergency Action Level Bases Document

4. Digital Video Disc - Supporting Evaluations and Calculations Commitments made in this letter: None.

Serial No. 13-495A License Amendment Request 257 Page 4 of 5 Enclosed with this letter is a digital video disk (DVD) which contains this submittal's , labeled:

Dominion Energy Kewaunee, Inc.

Kewaunee Power Station LAR 257: Permanently Defueled Emergency Plan and Emergency Action Level Scheme Enclosure 4 Supporting Evaluations and Calculations Serial No. 13-495A Docket No.: 50-305 License No.: DPR-43 The enclosed DVD contains the following files:

File Name Description File Size Sensitivity 001 001 Calculation Calculation RA-0028, Kewaunee 782 KB publicly RA-0028 RO Fuel Handling Accident Post- available Cessation of Operations 002 002 Calculation Calculation RA-0044, Dose Rate at 722 KB publicly RA-0044 R1 the KPS Site Boundary Following a available Complete Draindown of the Spent Fuel Pool 003 003 Calculation Calculation 2013-07050, Maximum 586 KB publicly 2013-07050 R2 Cladding Temperature Analysis for available an Uncovered Spent Fuel Pool with No Air Cooling 004 004 Evaluation Evaluation ETE-NAF-20130072, 124 KB publicly ETE-NAF-20130072 RO Kewaunee Spent Fuel Pool available Zirconium Fire Parameter Comparison 005 005 Calculation Calculation RA-0049, Kewaunee 1.63 MB publicly RA-0049 R1 Emergency Action Levels for Post- available Cessation of Power Operations 006 006 Calculation Calculation RA-0050, Kewaunee 210 KB publicly RA-0050 RO Resin Cask Drop Dose available Consequence Analysis 007 007 S&L Calculation Sargent & Lundy Calculation 2013- 15.8 MB publicly 2013-11284 RO 11284, Maximum Cladding and available Fuel Temperature Analysis for Uncovered Spent Fuel Pool

Serial No. 13-495A License Amendment Request 257 Page 5 of 5 cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. W. C. Huffman, Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Brian Benney, Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Cl 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Theodore Smith, Project Manager U.S. Nuclear Regulatory Commission Two White Flint North, Mail Stop 8-E5 11545 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, Wl 53707