ML14155A040

NRR E-mail Capture - Summarry of Kewaunee Mitigation Strategy Phone Call Last Week

ML14155A040
Person / Time
Site:	Kewaunee
Issue date:	04/07/2014
From:	Huffman W Plant Licensing Branch IV
To:	Eric Bowman Office of Nuclear Reactor Regulation
References
MF1952
Download: ML14155A040 (3)

Text

NRR-PMDAPEm Resource From: Huffman, William Sent: Monday, April 07, 2014 7:44 AM To: Bowman, Eric; Casto, Greg; Jones, Steve; Purdy, Gary; Cervera, Margaret; Anderson, Joseph; Norris, Michael; Wasem, Michael; Gratton, Christopher; Kim, James Cc: Wastler, Sandra; Broaddus, Doug

Subject:

Summarry of Kewaunee Mitigation Strategy Phone Call Last Week Please take a look at the conference call summary for last weeks Mitigation Strategy License Condition at Kewaunee.

Any corrections, improvements or requests for clarifications would be appreciated.

Bill Huffman Project Manager NRR/DORL/LPL4-2 U.S. Nuclear Regulatory Commission (301) 415-2046 Date: 04/02/2014 Time: 1000 EDT

Participants:

NRC DEK Eric Bowman - Mitigating Strategies, NRR Jack Gadzala - Decommissioning Licensing Greg Casto - BC, Plant Systems, NRR Rick Repshas - Licensing Steve Jones - Plant Systems (SFP), NRR Ethan Treptow - EP Gary Purdy - Material Securities, NSIR David Lohman - Engineering Projects Margaret Cervera - Material Securities, NSIR Brian Koehler - Engineering (FP)

Joe Anderson - Branch Chief, EP NSIR Michael Sortwell - Decommissioning Mike Norris - EP, NSIR Tim Olson - Assistant Plant Manager Mike Wasem - EP, NSIR Jeff Stafford - Director Safety Licensing Chris Gratton - NRR PM, Crystal River Craig Sly - Corp Licensing Jim Kim - NRR PM, Vermont Yankee Margaret Earle - Corp Licensing (Security)

Bill Huffman - NRR PM, KPS Topic: Mitigating Strategy License Condition Conference Call

References:

1. License Amendment (and safety evaluation), License Condition 2.C.(10), dated August 2, 2007

2. Permanently Defuel Tech Specs, dated May 29, 2013

3. NRC RAI dated April 1, 2014 Main Points of Discussion:

The NRC staff requested additional information (RAI) from Kewaunee Power Station (KPS) from the NRC regarding a proposal in its Permanently Defuel Tech Specs amendment request to delete License Condition 2.C.(10), Mitigating Strategy License Condition. The RAI requested additional justification for removing each of 1

the 14 elements in License Condition 2.C.(10); or maintaining the elements in effect. This conference call served to clarify that RAI and provide NRC staff with general information about mitigating strategies at KPS.

The NRC staff discussed its basis for issuing the RAI and provided further background on the statements contained within the RAI. The staffs primary point was that measures needed to maintain public health and safety and common defense and security specifically related to Mitigation Strategies should remain in place while fuel remained in the spent fuel pool (SFP).

Dominion Energy Kewaunee (DEK) staff discussed an alternative approach to the RAI (i.e., maintaining the elements of License Condition 2.C.(10) in effect). DEK premised this discussion on the ability to make changes to the underlying implementing details of License Condition 2.C.(10), as described in the NRC safety evaluation (SE) that issued this license condition. DEK noted that the required strategies for all phases would be covered by the license condition and all implementing details would be managed by NEI 99-04 [commitment management process].

DEK noted that the 34 measures that underlie the 14 elements of the license condition could be changed using the NEI 99-04 commitment management process. As such, this process could be used to eliminate those measures that are no longer needed to reflect the permanently defueled status of the facility (e.g., measures to provide alternative water for core cooling, containment isolation, starting AFW without DC power, etc.).

DEK also discussed a potential change to the introductory sentence for License Condition 2.C.(10) to clarify its applicability as being to the period when spent fuel assemblies are stored in the spent fuel pool; and that its current focus being the threat to the spent fuel pool.

The NRC staff did not note any objections to DEKs proposal. A point was made by the staff that any change to the license condition (other than a complete retraction of the originally proposed change) would necessitate a safety evaluation of that change. Additionally, the staff expressed interest in being kept abreast in a timely manner of commitment changes associated with this license condition. The staff also indicated their desire for DEK to coordinate proposed changes in this area with other decommissioning facilities.

A follow up discussion involved information regarding response capability and strategies for loss of spent fuel pool inventory that was described in the various submittals provided to NRC. This discussion included DEKs description of an external makeup strategy (using the diesel driven portable pump) that had been demonstrated to be capable of being deployed within two hours; and how this strategy related to other response strategies that discussed different time frames.

Actions:

DEK:

1) Supplement the Permanently Defuel Tech Specs, dated May 29, 2013, as discussed above.

2) Decide whether to change the introductory sentence in the license condition.

3) Coordinate the change with other decommissioning facilities.

2

Hearing Identifier: NRR_PMDA Email Number: 1334 Mail Envelope Properties (William.Huffman@nrc.gov20140407074400)

Subject:

Summarry of Kewaunee Mitigation Strategy Phone Call Last Week Sent Date: 4/7/2014 7:44:29 AM Received Date: 4/7/2014 7:44:00 AM From: Huffman, William Created By: William.Huffman@nrc.gov Recipients:

"Wastler, Sandra" <Sandra.Wastler@nrc.gov>

Tracking Status: None "Broaddus, Doug" <Doug.Broaddus@nrc.gov>

Tracking Status: None "Bowman, Eric" <Eric.Bowman@nrc.gov>

Tracking Status: None "Casto, Greg" <Greg.Casto@nrc.gov>

Tracking Status: None "Jones, Steve" <Steve.Jones@nrc.gov>

Tracking Status: None "Purdy, Gary" <Gary.Purdy@nrc.gov>

Tracking Status: None "Cervera, Margaret" <Margaret.Cervera@nrc.gov>

Tracking Status: None "Anderson, Joseph" <Joseph.Anderson@nrc.gov>

Tracking Status: None "Norris, Michael" <Michael.Norris@nrc.gov>

Tracking Status: None "Wasem, Michael" <Michael.Wasem@nrc.gov>

Tracking Status: None "Gratton, Christopher" <Christopher.Gratton@nrc.gov>

Tracking Status: None "Kim, James" <James.Kim@nrc.gov>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 5519 4/7/2014 7:44:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: