ML14079A507

And Response to Request for Additional Information: License Amendment Request 255, Deletion of License Renewal Condition for Permanently Defueled License

ML14079A507
Person / Time
Site:	Kewaunee
Issue date:	03/19/2014
From:	Mark D. Sartain Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-177C
Download: ML14079A507 (15)

Text

Dominion Energy Kewaunee, Inc.

0 5000 Dominion Boulevard, Glen Allen, VA 23060 iO mil IOB Web Address: www.dom.com March 19, 2014 U. S. Nuclear Regulatory Commission Serial No. 13-177C 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 SUPPLEMENT 1 AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION: LICENSE AMENDMENT REQUEST 255, DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) 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 plant.

In advance of the planned license and TS revisions discussed above, DEK requested an amendment to revise the Operating License by deleting a license condition associated with license renewal (Reference 2).

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding spent fuel pool neutron absorber testing (Reference 3).

The RAI question and associated DEK response are provided in to this letter.

Based on discussions with NRC staff regarding the RAI, a new license condition regarding testing programs for spent fuel pool neutron absorber materials is proposed.

Although the RAI was directed towards KPS LAR 256 (Reference 1), the newly proposed license condition is primarily germane to LAR 255 (Reference 2). Attachment 2 to this letter provides a supplement to the proposed amendment request that adds that new license condition.

This new license condition would remain in effect upon approval of the LAR 256 as well.

The conclusions of the no significant hazards consideration and the environmental considerations contained in References 1 and 2 are not affected by, and remain applicable to, this supplement. Attachment 3 provides a markup of the Operating License reflecting the proposed new license condition.

The June 1, 2014 requested approval date for LAR 255 remains unchanged.

AD)5ý

Serial No. 13-177C LAR 255 RAI Response Page 2 of 3 Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, VICKI L. HULL J

Notary Public Mark D. Sartain Noar ubi Commonwealth of Virginia Vice President - Nuclear Engineering 140542 3

My Commission Expires May 31, 2014 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 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 be of his knowledge and belief.

Acknowledged before me this!

7 day of J

/',F, 3

2014.

l My Commission Expires:

5 -/14 exc 1, Y 15b LL Notary Pub"ic Attachments:

1. Response to Request for Additional Information

2. Discussion of Change and Technical Analysis

3. Marked Up Operating License

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 [TAC MF1952] (ADAMS Accession No. ML13156A037)

2. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License," dated April 16, 2013 [TAC MF1771]

3. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "MF1952-RAII-SRXB-Cunana-002-2011-11-08, Request for additional information," dated November 7, 2013.

Commitment made by this letter: None

Serial No. 13-177C LAR 255 RAI Response Page 3 of 3 cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. W. C. Huffman Jr., Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Christopher Gratton, Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 13-177C ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-177C Page 1 of 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) 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 plant. In advance of the planned license and TS revisions discussed above, DEK requested an amendment to revise the Operating License by deleting a license condition associated with license renewal (Reference 2).

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding spent fuel pool neutron absorber testing (Reference 3). The RAI question and associated DEK response is provided below.

NRC Question MFI952-RAII-SRXB-Cunana-002-2011-11-08 In the spent fuel pool (SFP), the spent fuel stored in the racks must comply with the regulations to remain subcritical. In the case of Kewaunee, they are licensed under 10 CFR 50.68, "Criticality Accident Requirements." This regulation states that:

If no credit for soluble boron is taken, the k-effective of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percent probability, 95 percent confidence level, if flooded with unborated water.

To demonstrate compliance with the regulation, the licensee has performed a nuclear criticality safety (NCS) analysis of record (AOR). In this NCS AOR, Kewaunee has credited neutron absorbers in the analysis to help maintain subcriticality.

In order to ensure that the neutron absorbers will remain within the assumptions used in the NCS AOR, a Surveillance Program to identify and monitor any degradation is in place or is planned to be implemented in the near future. These programs will confirm that the materials will perform as designed for in the NCS AOR.

The staff questions the amount of information described in Kewaunee's proposed Technical Specifications in regard to the neutron absorbing materials and its Surveillance Programs. In particular:

1. Neutron absorbing materials need to be monitored and degradation mitigated in the SFP to ensure that the assumptions in the criticality analysis of record and thereby the TS 4.3.1 are not challenged. Since the materials are integral to the

Serial No. 13-177C Page 2 of 4 compliance of the TS 4.3.1 and the regulations, the areal density of the neutron absorbers and the details of the neutron absorber surveillance programs should be reflected in the TS.

Please describe how this will be achieved.

Note:

In justification for having a neutron absorbers and its surveillance programs in TS, please see 10 CFR 50.36 (c)(2)(ii)(B), where it states:

Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Furthermore 10 CFR 50.36(c)(2)(ii)(C) states:

Criterion 3. A structure, system, or component that is 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.

DEK Response:

KPS License Amendment Requests 255 and 256 proposed no changes to TS 4.3.1.1 (neither deletions nor new requirements).

As such, DEK provided no justification for maintaining the existing TS 4.3.1.1 requirements unchanged. DEK believes the existing TS 4.3.1 requirements for SFP spent fuel storage racks remain acceptable.

DEK proposes that TS 4.3.1.1 remain unchanged and as approved by NRC in Amendment 207 in 2011 (Reference 4). Amendment 207 was related to the conversion of KPS TS to Improved Technical Specifications based on NUREG-1431. The accompanying NRC Safety Evaluation for KPS Amendment 207, did not identify a need for a new neutron absorbing material surveillance program to routinely verify compliance with TS 4.3.1.1 during the renewed operating period. Accordingly, there is no change in physical status of the spent fuel storage racks when entering the permanently defueled condition that would suggest reconsideration of that position during the existing period prior to offloading fuel to the ISFSI.

Instead, DEK currently has the following program and requirements in place for neutron absorbing materials in the KPS spent fuel pool which are documented in the USAR:

Boron Carbide DEK currently has a Boron Carbide Surveillance Program in place for KPS, as discussed in our September 5 and October 14, 2013 RAI responses for KPS License Amendment Request 255 (References 5 and 6). Neutron absorption capability

Serial No. 13-177C Page 3 of 4 testing and physical inspection of SFP boron carbide plates, as required by the program, was last performed during September 2011 and indicated no abnormal degradation.

The program requires performance of this testing and inspection activity at three year intervals. The next performance is scheduled to occur during the Fall of 2014.

Boral A requirement to implement a program prior to 2017 to "perform verification that the Boral spent fuel storage rack neutron absorber B-10 areal density is maintained within the bounds of the spent fuel pool criticality analysis" is described in the KPS USAR. This requirement was added to the KPS USAR as a direct result of NRC approval of the KPS License Renewal Amendment (Reference 7).

Neutron absorbing materials in the spent fuel pool racks are subject to appropriate monitoring under the program and requirement described above.

The program and requirement above will ensure that neutron absorber degradation is maintained within the assumptions in the criticality analysis of record and that the requirements of TS 4.3.1 are not challenged. The requirements for these programs were incorporated into the KPS USAR after issuance of the Renewed Facility Operating License for KPS (Reference 7). As such, changes to these program requirements can only be made subject to the provisions of 10 CFR 50.59.

Furthermore, DEK has recently accelerated the schedule for transfer of spent fuel from the KPS SFP to dry storage in the Independent Spent Fuel Storage Installation (ISFSI).

The new schedule projects that the SFP should be emptied of fuel assemblies by the end of 2016. As a result, performance of the upcoming boron carbide surveillance in the Fall of 2014 is likely to be the final time that testing of SFP neutron absorbing materials will be required. Consequently, incorporating new neutron absorber program requirements into the KPS Technical Specifications would serve no purpose, since initial performance of the associated TS surveillance requirements would likely not be required until after the SFP is empty. Since TS surveillance requirements do not have to be performed for equipment that is not operable, the new surveillance requirements would likely never be performed.

Therefore, based on discussions with NRC staff regarding this RAI, a new license condition regarding testing programs for spent fuel pool neutron absorber materials is being proposed. The new license condition would state that if all spent fuel assemblies have not been removed from the KPS spent fuel pool by the end of 2017, DEK will submit a license amendment request, prior to that date, to incorporate the boron carbide and Boral neutron absorber monitoring programs into the KPS TS. The amendment would require one or both programs, as necessary to ensure that the associated neutron absorbing material for all spent fuel remaining in the respective spent fuel pool regions would be addressed by a TS required program. As discussed with NRC staff,

Serial No. 13-177C Page 4 of 4 the new license condition will provide for enforcement of the above statement. proposes to add this statement as a condition to the Operating License.

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 [TAC MF1952] (ADAMS Accession No. ML13156A037)

2. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License," dated April 16, 2013 [TAC MF1771]

3. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "MF1952-RAII-SRXB-Cunana-002-2011-11-08, Request for additional information,"

dated November 7, 2013.

4. Letter from K. Feintuch (NRC) to D. A. Heacock (DEK), "Kewaunee Power Station -

Issuance of Amendment for the Conversion to the improved Technical Specifications with Beyond Scope Issues (TAC Nos. ME2139, ME2419, ME2420, ME2421, ME3122, ME3460, ME3544)," dated February 2, 2011.

5. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "Response to Request for Additional Information Regarding License Amendment Request 255:

Deletion of License Renewal Condition for Permanently Defueled License," dated September 5, 2013 [TAC MF1771].

6. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Response to Request for Additional Information Regarding License Amendment Request 255:

Deletion of License Renewal Condition for Permanently Defueled License," dated October 14, 2013 [TAC MF1771].

7. NUREG-1958, Safety Evaluation Report Related to License Renewal of Kewaunee Power Station, January 2011.

Serial No. 13-177C ATTACHMENT 2 SUPPLEMENT 1:

LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-177C Page 1 of 4 SUPPLEMENT 1 LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS

1.0 DESCRIPTION

By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) 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 plant. In advance of the planned license and TS revisions discussed above, DEK requested an amendment to revise the Operating License by deleting a license condition associated with license renewal (Reference 2).

As discussed in the response to the staffs request for additional information (RAI) regarding the proposed amendment (Attachment 1), DEK is proposing a new license condition regarding controls for spent fuel pool (SFP) neutron absorber monitoring programs. The new license condition will require DEK to submit a license amendment request proposing incorporation of boron carbide and Boral neutron absorber monitoring programs into the TS if all spent fuel assemblies have not been removed from the KPS spent fuel pool by the end of 2017.

The conclusions of the no significant hazards consideration and the environmental considerations contained in References 1 and 2 are not affected by, and remain applicable to, this supplement.

2.0 PROPOSED CHANGE

The originally proposed request (Reference 2) would have modified the KPS license by deleting License Condition 2.C.(15),

License Renewal License Conditions (the corresponding request was also contained in Reference 1). This supplement continues to request the original deletion, but also proposes to replace the deleted text with a new license condition.

License Condition 2.C.(15) 2.C.(15) License Renewal License Cenditions (a) The USAR supplement, ac reviced, submitted purcuant to GFR 54.2!1(d), chall be ncldedinthe next Scheduled update to the USAR required by

Serial No. 13-177C Page 2 of 4 10- CER 59.7-1(e)(4) following the iccuance of this renewed operating licensc.

Untio that update iscomplete, the licensee mray mnake hangec to the pF, rogramr and activities described in the cupplement without prior Commission approval, provided that the licensee evaluates such changes pursuant to the criteria set foprth on 10 CFR 50.59 and otherwise comnplies with the requireents, in ta seromen.

(b) The USAR supplement, as revised, deceribec cert-ain future activitiec to e coempleted prior to andor during the perfiod of extended operation. The licensee shall complete thece actvities in accordance with Appendix A of NUREG 1958, "Safety Evaluation Report Related to the KeWAMUnee Powe9Pr S~tation," dated January 2011. The lic~ense-e s.hall! notify the NRC in writing when; activities to be completed prior to the period of extended operation are coemplete and can be verified by NRC inspection.

(G) All capsules in the reactor vessel that are remonved and tested must Meet the tes procedures and reporting requirements, of American Society for Testing and Materials, (AST-M) E 1856 812 to-thýe extent prac-ti-a-ble for the configuratio-n of the spcmns in the capsule. Any changes to the capsule withdrawal schedu Is, icuig spare capsules, mnust be approved by the NRC prior to implementation.

All capsules placed in storage must be maintained foer future-insertion. Any

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The revised section will read as follows.

2.C.(15) Spent Fuel Pool Neutron Absorber Material Surveillance Progqrams If all spent fuel assemblies have not been removed from the spent fuel pool by December 31, 2017, DEK shall request, prior to that date, an amendment to the license, pursuant to 10 CFR 50.90, to incorporate boron carbide and Boral surveillance programs (specified as Items 38 and 39 in Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," dated January 2011) into the Technical Specifications.

A mark-up of the Operating License, reflecting the proposed license condition, is provided in Attachment 3.

3.0 TECHNICAL ANALYSIS

The applicable technical analysis contained in References 1 and 2 is not affected by, and remains applicable to, this proposed change.

This supplement incorporates a more restrictive administrative control by adding a license condition to ensure compliance with an existing requirement.

Serial No. 13-177C Page 3 of 4 4.0

SUMMARY

Kewaunee Power Station (KPS) is a permanently defueled facility that has ceased operation and removed fuel from the reactor vessel prior to the start of the period of extended operation of the renewed facility operating license. KPS has not operated, and will not be operated during the period of extended operation for which License Condition 2.C.(1 5) was meant to apply.

Safe storage and management of irradiated fuel at other U.S. nuclear facilities licensed under 10 CFR 50, that have permanently ceased operation in accordance with 10 CFR 50.82, does not rely on the programs and activities associated with 10 CFR 54.

As such, the requirements specified in License Condition 2.C.(15) are not needed for assuring safe onsite storage of irradiated fuel at KPS and may be deleted. Adding an administrative control over spent fuel pool neutron absorption surveillance programs has no adverse impact on radiological health and safety.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The conclusions of the no significant hazards consideration contained in References 1 and 2 are not affected by, and remain applicable to, this proposed change.

5.2 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements/criteria contained in References 1 and 2 are not affected by, and remain applicable to, this proposed change.

6.0 ENVIRONMENTAL CONSIDERATION

The conclusions of the environmental considerations contained in References 1 and 2 are not affected by, and remain applicable to, this proposed change.

Serial No. 13-177C Page 4 of 4

7.0 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 [TAC MF1952] (ADAMS Accession No. ML13156A037)

2. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License," dated April 16, 2013 [TAC MF1771]

3. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "MF1952-RAII-SRXB-Cunana-002-2011-11-08, Request for additional information,"

dated November 7, 2013.

Serial No. 13-177C ATTACHMENT 3 SUPPLEMENT 1:

LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE MARKED UP OPERATING LICENSE PAGE KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

(13)

Removed Details and Requirements Relocated to Other Controlled Documents License Amendment No. 207 authorizes the relocation of certain technical specifications and operating license conditions, if applicable, to other licensee-controlled documents. Implementation of that amendment shall include relocation of these requirements to the specified documents.

(14)

Deferral of Certain Technical Specification Requirements

[NOTE: Deletion of License Condition 14 is proposed in a separate submittal (License Amendment Request 256).]

(15)

Spent Fuel Pool Neutron Absorber Material Surveillance Pro~qramsL4Ge-e Renewal Licence Conditions, If all spent fuel assemblies have not been removed from the spent fuel pool by December 31, 2017, DEK shall request, prior to that date, an amendment to the license, pursuant to 10 CFR 50.90, to incorporate boron carbide and Boral surveillance programs (specified as Items 38 and 39 in Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," dated January 2011) into the Technical Specifications.

(a)

The USAR,upplement, as reVised, submitted purl' uant t 10A C.R 54.21 (d), shall be included "f

the next scheduled update to the USAR required by 10 CteR 5,.71 (e)(4) fJllowing the issuance of this renewed operating license. Until that update ic complete, the licensee mnay make changec to the programs and activities deGcribed in the supplement without prior Comcinapproval, provided that the liensee evaluates SUch changes pursuant to the criteria set forth in 10 CER 50.59 and othep~Ase comnplies with the requirements in that (b) The USAR supplement, as revised, describes certafin future aetivitiest be completed prior to and/or dunang the period of extended operation.

The licensee shall com~plete these activities in accordance with

,Appendix A of NIUREG 1958, "Safety Evaluation Report Related to the Kewaunee Powe.Pr Station," dated January 2011. The licensee shall notify the NRC in writing when activities to-beP completed prior to the period of extended operation are GOMplete and can be verified by NRC 4

Rspeeti9-(G) All capsules in the reactor vessel that are removed and tested mus6t meet the test procGedures and reporFting requiremnents of America Society for Testing and Materials (AST-M) E= 185 82 to the extent practicable for the configuration of the specimnens in the capsule

-Any*

changes to the capsufle withdrawal Sehedule, 9n~dn sprGapsules, must be app-rved by the NRC prior tomplemenaton All apsu**

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placed in storage must be maintained for future iRi GAnychanges' 41 4-4.4 k

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-- j Renewed Operating License DPR-43