ML14163A120
| ML14163A120 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/29/2014 |
| From: | Stafford J Dominion, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 14-259 | |
| Download: ML14163A120 (9) | |
Text
Dominion Dominion Energy Kewaunee, Inc.
N490 Hwy 42, Kewaunee, WI 54216 Web Address: www.dom.corn ATTN: Document Control Desk U. S. Nuclear Regulatory Commission MAY 2 9 2014 Serial No.14-259 LIC/MH/RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE. INC.
KEWAUNEE POWER STATION
SUMMARY
OF FACILITY CHANGES. TESTS AND EXPERIMENTS AND
SUMMARY
OF COMMITMENT CHANGES Pursuant to 10 CFR 50.59(d)(2), enclosed is a summary description of Facility Changes, Tests and Experiments evaluated in accordance with 10 CFR 50.59(c) and implemented at the Kewaunee Power Station (KPS) during the last reporting period, which is defined as not to exceed 24 months.
A commitment change evaluation summary for those commitment changes that occurred during the last reporting period is also enclosed.
The enclosed summary encompasses all changes that occurred in both of the stated areas since our prior submittal dated May 29, 2013 (reference 1).
If you have any questions or require additional information, please contact Ms. Mary Jo Haese, at 920-388-8277.
Very truly yours, J. T. Sfff Director Safety and Licensing, Kewaunee Power Station Commitments made by this letter: NONE
Reference:
- 1. Letter from Jeffery T. Stafford (Dominion Energy Kewaunee, Inc.) to Document Control Desk (NRC), "Summary of Facility Changes, Tests and Experiments and Summary of Commitment Changes," dated May 29, 2013.
Serial No.14-259 Page 2 of 2 cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 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 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
Serial No.14-259 ATTACHMENT 1
SUMMARY
OF FACILITY CHANGES, TESTS AND EXPERIMENTS AND
SUMMARY
OF COMMITMENT CHANGES KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
Serial No.14-259 Attachment 1 Page 1 of 6 50.59 Evaluation # 13-01-00 Activity Evaluated Updated Safety Analysis Report (USAR) revision for Chapter 14 Brief Description 10 CFR 50.59 Evaluation # 13-01-00 was performed in support of USAR Change Request KPS-UCR-2013-004 to reflect historical nature of existing accident/transient analyses to support the permanent cessation of power operations and the permanent reactor vessel defueling at Kewaunee Power Station (KPS) and update the design basis radiological accident analyses for the fuel handling accident with an analysis applicable after a period beginning 90 days beyond permanent cessation of operation.
Reason for Change USAR Change Request KPS-UCR-2013-004 was performed to revise the discussion in USAR Chapter 14 to reflect historical nature of existing accident/transient analyses to support the permanent cessation of power operations and the permanent reactor vessel defueling at KPS and to update the design basis radiological accident analyses for the fuel handling accident. ETE-NAF-2013-0041, Rev. 0 identified the accidents/transients applicable to KPS in the permanently defueled condition as a Fuel Handling Accident, Accidental Release-Recycle of Waste Liquid and the Waste Gas Decay Tank, and Volume Control Tank rupture accidents while radioactive gases and liquids are still present. Aside from these accidents/transients all other USAR Chapter 14 postulated accidents/transients are identified as HISTORICAL through the KPS-UCR-2013-004 revision as there is no possibility for these postulated accidents/transients to occur at KPS in a permanently defueled status.
The USAR Change Request also included changes to the Fuel Handling Accident dose consequences analysis. The revised fuel handling accident analysis assumes sufficient fuel decay (90 days) to offset reliance on mitigating systems except for the spent fuel pool level. The analysis takes no credit for emergency ventilation or filtration in the Control Room or elsewhere. Also, no credit is taken for Control Room atmospheric dispersion and a Control Room unfiltered inflow was chosen to maximize the Control Room dose.
A 10 CFR 50.59 Evaluation was performed in support of the USAR revision and concluded that a License Amendment was not required. The Evaluation determined that removing credit for the Control Room ventilation isolation and recirculation, coupled with modeling an unfiltered Control Room air inflow, would have significantly increased the Control Room dose consequences. However, when the analytical input was revised to reflect a stored spent fuel decay time exceeding 90 days after reactor shutdown, the change resulted in increases to the dose consequences that were less than 10% of the margin to the 10 CFR 50.67 limits for the Control Room, Exclusion Area Boundary (EAB), and Low Population Zone (LPZ). Removing analytical credit for atmospheric dispersion to the Control Room ventilation intake was also evaluated and determined that it resulted in a conservative increase in the Control Room dose consequence and the results remain within the 10 CFR 50.67 and Standard Review Plan limits. The changes to the EAB and LPZ dose consequences were determined to be less than a fraction of a mRem and thus are essentially the same as the dose consequences prior to changing the element of the methodology.
The 50.59 Evaluation concluded that the revisions to the Fuel Handling Accident analysis input parameters did not result in more than a minimal increase in the consequences of an accident previously evaluated in the USAR. It was also concluded that not crediting atmospheric dispersion to the Control Room ventilation intake did not constitute a departure from a method of evaluation.
Serial No.14-259 Attachment 1 Page 2 of 6 Summary 10 CFR 50.59 Evaluation # 13-01-00 was performed in support of USAR Change Request KPS-UCR-2013-004 that reflected the historical nature of existing accident/transient analyses to support the permanent cessation of power operations and the permanent reactor vessel defueling at Kewaunee Power Station (KPS) and updated the design basis radiological accident analysis for the fuel handling accident with an analysis applicable beyond 90 days after reactor shutdown. The 50.59 Evaluation concluded that the revision to the Fuel Handling Accident analysis does not result in more than a minimal increase in the consequences of an accident previously evaluated in the USAR and does not constitute a departure from a method of evaluation.
Commitment Change Evaluation Summary Document(s) Evaluated:
NRC Bulletin 2003-01, Potential Impact of Debris Blockaae on Emeraency Sump Recirculation at Pressurized Water Reactors
- 1. NRC Bulletin 2003-001, dated June 9, 2003.
- 6. Letter from D.A. Jaffe (USNRC) to D.A. Christian dated December 15, 2005.
Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
- 1. Generic Letter 2004-02 dated September 13, 2004.
- 7. Letter to Holders of Licenses-PWR from C. Hane (USNRC) dated March 28, 2006.
- 8. Letter to Holders of Licenses-PWR from C. Hane (USNRC) dated January 4, 2007.
Serial No.14-259 Attachment 1 Page 3 of 6 Brief
Description:
The purpose of NRC Bulletin 2003-01 was to:
- 1. Inform addressees of the results of NRC-sponsored research identifying the potential susceptibility of pressurized-water reactor (PWR) recirculation sump screens to debris blockage in the event of a high-energy line break (HELB) requiring recirculation operation of the emergency core cooling system (ECCS) or containment spray system (CSS).
- 2. Inform addressees of the potential for additional adverse effects due to debris blockage of flow paths necessary for ECCS and CSS recirculation and containment drainage.
- 3. Request that, in light of these potentially adverse effects, addressees confirm their compliance with 10 CFR 50.46(b)(5) and other existing applicable regulatory requirements, or describe any compensatory measures implemented to reduce the potential risk due to post-accident debris blockage as evaluations to determine compliance proceed.
- 4. Require addressees to provide the NRC a written response in accordance with 10 CFR 50.54(f).
The purpose of Generic Letter 2004-02 was to:
- 1. Request that addressees perform an evaluation of the emergency core cooling system (ECCS) and containment spray system (CSS) recirculation functions in light of the information provided in this letter and, if appropriate, take additional actions to ensure system function. Additionally, addressees are requested to submit the information specified in this letter to the NRC. This request is based on the identified potential susceptibility of pressurized-water reactor (PWR) recirculation sump screens to debris blockage during design basis accidents requiring recirculation operation of ECCS or CSS and on the potential for additional adverse effects due to debris blockage of flow paths necessary for ECCS and CSS recirculation and containment drainage.
- 2. Require addressees to provide the NRC a written response in accordance with 10 CFR 50.54(f).
Scope:
Rescind the commitments associated with NRC Bulletin 2003-01 and NRC Generic Letter 2004-02 at KPS due to our permanent cessation of operations and permanent removal of fuel from the reactor (NRC Letters SN 13-107 and SN 13-293).
Basis for Change:
KPS USAR Section 14.0.1 has been revised to state in part:
With the permanent cessation of power operations at the Kewaunee Power Station (KPS) and the permanent removal of the fuel from the reactor core, the accident/transient initial conditions/initial reactor power level of the reactor core cannot be achieved and, as such, most of the accident/transient scenarios are not possible. Therefore, the postulated USAR Chapter 14 accidents/transients involving failure or malfunction of the reactor, RCS or secondary system are no longer applicable. USAR Chapter 14 accidents/transients that are applicable include:
Fuel Handling Accident (FHA), Accidental Release-Recycle of Waste Liquid (which is bounded by the Waste Gas Decay Tank accident analysis) and Waste Gas Decay Tank (WGDT) and
Serial No.14-259 Attachment 1 Page 4 of 6 Volume Control Tank (VCT) rupture accidents while radioactive gases and liquids are still present.
Furthermore, NRC Letter SN 13-232, dated May 13, 2013, which provided KPS's final response to Generic Letter 2004-02, states, "...all GSI-191 resolution activities have been discontinued and open commitments associated with GSI-191 activities are considered closed."
Summary:
The actions implemented and committed to, in response to NRC Bulletin 2003-01 and NRC Generic Letter 2004-02 are no longer required for KPS due to our permanent cessation of operations and permanent removal of fuel from the reactor (NRC Letters SN 13-107 and SN 13-293).
Commitment Change Evaluation Summary Document(s) Evaluated:
NRC Generic Letter 89-08, Erosion/Corrosion Induced Pipe Wall Thinning
- 1. NRC Generic Letter 89-09, dated May 2, 1989
- 2. Letter from C.R. Steinhardt (WPS) to Document Control Desk (USNRC) dated July 21, 1989.
Brief
Description:
GL 89-08, Erosion/Corrosion Induced Pipe Wall Thinning, was issued to all holders of Operating Licenses or Construction Permits for nuclear power plants due to concerns over whether the affected plants continue to meet their licensing basis when erosion/corrosion degrades the pressure boundary to below the applicable code design value. GL 89-08 notes that main feed water systems, as well as other power conversion systems, are important to safe operation and that piping failures in these systems can result in undesirable challenges to plant safety systems required for safe shutdown and accident mitigation. Piping failures can also result in complex challenges to the plant and its operating staff because of potential system interactions of high-energy steam and water with other systems, such as electrical distribution, fire protection, and security.
Scope:
Kewaunee plant procedures for the Pipe Thinning Program were developed in response to NRC GL 89-08, Erosion/Corrosion Induced Pipe Wall Thinning. Currently this commitment is implemented using fleet procedures for the Flow Accelerated Corrosion Program (FAC) (ER-AA-FAC-10 and ER-AA-FAC-1001 through 1004). It has been determined that the FAC program is no longer needed or required at KPS due to our permanent cessation of operations and permanent removal of fuel from the reactor (NRC Letters SN 13-107 and SN 13-293).
GL 89-08, Erosion/Corrosion Induced Pipe Wall Thinning, was issued to all holders of Operating Licenses or Construction Permits for nuclear power plants due to concerns over whether the affected plants continue to meet their licensing basis when erosion/corrosion degrades the pressure boundary to below the applicable code design value. GL 89-08 notes that main feed water systems, as well as other power conversion systems, are important to safe operation and that piping failures in these systems can result in undesirable challenges to plant safety systems required for safe shutdown and accident mitigation. Piping failures can also result in complex challenges to the plant and its operating staff because of potential system interactions of high-energy steam and water with other systems, such as electrical distribution, fire protection, and security.
Serial No.14-259 Attachment 1 Page 5 of 6 Note: Engineering Evaluation ETE-KW-201 0-0001, Kewaunee Power Station Flow Accelerated Corrosion System Susceptibility Evaluation, determined that portions of the Heating Steam System are susceptible to FAC. However, the heating steam system is not part of the KPS design basis, and therefore it is not within the scope of our original commitment made in response to the GL 89-08.
Basis for Change:
The NRC concerns within GL 89-08 related to safe shutdown and accident mitigation is no longer applicable to KPS since the permanent cessation of operations and permanent removal of fuel from the reactor vessel.
KPS's commitment to GL 89-08 is no longer applicable since the systems at KPS within the design basis that are susceptible to FAC are no longer in operation.
Summary:
The actions implemented and committed to, in response to Generic Letter 89-08 are no longer required for KPS due to our permanent cessation of operations and permanent removal of fuel from the reactor (NRC Letters SN 13-107 and SN 13-293).
Commitment Change Evaluation Summary Document(s) Evaluated:
NUREG 0737 - Implementation of a Detailed Control Room Design Review (DCRDR) Including Application of Human Engineering Techniques
References:
- 1. Generic Letter 82-133, Supplement 1 to NUREG-0737 dated December 17, 1982
- 2. Letter from C.W. Giesler (WPSC) to D. G. Eisenhut (USNRC) dated April 15, 1983.
- 3. Letter from S.A. Varga (USNRC) to C.W. Giesler (WPSC) dated June 22, 1984.
- 4. Letter from D.C. Hintz (WPSC) to D.G. Eisenhut (USNRC) dated September 20, 1984.
- 5. Letter from C.W. Giesler (WPSC) to D.G. Eisenhut (USNRC) dated April 15, 1985.
- 6. Letter from D.C. Hintz (WPSC) to H.L. Thompson (USNRC) dated June 28, 1985.
- 7. Letter from D.C. Hintz (WPSC) to H.L. Thompson (USNRC) dated October 31, 1985.
- 8. Letter from D.C. Hintz (WPSC) to M.B. Fairtile (USNRC) dated June 26, 1986.
- 9. Letter from M.B. Fairtile (USNRC) to D.C. Hintz (WPSC) dated October 29, 1986.
Brief
Description:
Scope:
The letter (Reference #7., NRC-85-167) from Hintz (WPSC) to Thompson USNRC, dated 10-31-85 discusses the general methodology that Kewaunee committed to, and describes the following:
- 1. Identify need for design change through observations, maintenance and regulatory requirements.
- 2. Perform system function and task analysis which is intended to define a goal and determine information and control requirements and the human performance requirements.
- 3. Prepare alternative functional designs based on the system task analysis.
Serial No.14-259 Attachment 1 Page 6 of 6
- 4. Identify equipment that fulfills the functional requirements identified during the task analysis and incorporate human factors criteria selected for application at the Kewaunee Nuclear Power Plant (KNPP).
- 5. Incorporate the preliminary functional designs on a control board mock-up.
- 6. Using the mockup, perform design verification by performing operator walk and talk-through and determine the preferred design.
- 7. Install the selected design on the KNPP simulator.
- 8. Validate the design during operator training on the simulator. This allows an evaluation under dynamic real time conditions.
- 9. Install final design in the KNPP Control Room.
The methodology also describes input from several disciplines, and provides sufficient human factors review and operator input during the design phase prior to making any modifications to the control room panels.
Basis for Change:
Following the May 14, 2013 NRC submittal of Kewaunee Power Station (KPS) Certification of Permanent Removal of Fuel from the Reactor Vessel (NRC Letter SN-1 3-293), process changes were incorporated into current KPS procedures to address the methodology which is stated above. These process changes are as follows:
- 1. KPS has incorporated Design Review Boards with Operations and a multi-spectrum of department inputs, to ensure several disciplines and operator input are received throughout the design process.
- 2. The general design input checklist located in CM-KW-DDC-401, Design Inputs, addresses issues related to Human Factors such as system arrangement, materials, etc.
With the current and future reduced scope of modifications within the control room (due to the permanent shutdown of KPS), the incorporation of the process steps listed above are adequate to ensure operator design input is received and incorporated.
Summary:
For the above stated reasons the commitment stated in NRC Letter, NRC-85-167, Implementation of a Detailed Control Room Design Review (DCRDR) Including Application of Human Engineering Techniques, will no longer be a separate and individual process.