ML15294A072

Request for Approval of the Kewaunee Power Station Security Plan

ML15294A072
Person / Time
Site:	Kewaunee
Issue date:	10/15/2015
From:	Clark G Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
15-302
Download: ML15294A072 (3)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com

• Safeguards Information October 15, 2015 U.S. Nuclear Regulatory Commission Serial No.: 15-302 Attention: Document Control Desk NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket Nos.: 50-305 72-64 DOMINION ENERGY KEWAUNEE, INC. .License No.: DPR-43 KEWAUNEE POWER STATION REQUEST FOR APPROVAL OF THE KEWAUNEE POWER STATION SECURITY PLAN In accordance with the provisions of 10 CFR 50.4 and 50.90, Dominion Energy Kewaunee, Inc. (DEK) is submitting a request for an amendment to the Operating License (OL) for

• Kewaunee Power Station. Specifically, this proposed license amendment requests NRG approval of the Kewaunee Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (the Plan) and removal of the Cyber Security requirements from the OL. The Plan will supersede the current Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan at KPS. The Plan addresses the protection .of material on site that is licensed by the KPS Operating License. The protection of material subject to the requirements of 10 CFR 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material," is addressed in a separate plan. The future site configuration that is reflected in the Plan assumes that the remaining spent fuel in the spent fuel pool has been moved to the ISFSI and that there is no requirement to return spent fuel to the spent fuel pool ("ISFSI only" status). Spent fuel movement to the ISFSI is currently scheduled to be completed by the end of 2016.

AREVA Inc. (AREVA) is the holder of Certificate of Compliance (CoC) 1004 for the Standardized NUHOMS System, which is used to store spent fuel at the KPS ISFSI.

Currently the technical specifications associated with this CoC require that under certain circumstances the cask must be returned to the spent fuel pool for inspection. AREVA submitted an application to revise this CoC on August 24, 2015 to remove this requirement.

AREVA has requested approval of the CoC by October 2016. Once the CoC is revised, there will rio longer be a requirement to return spent fuel to the spent fwel pool. In addition, in a September 14, 2015 letter (Serial No.15-185), DEK submitted an OL amendment request that would clarify that spent fuel will not be stored in the spent fuel pool.

An evaluation of the proposed license amendment is provided in Enclosures 1 and 2. The Plan is provided in Enclosure 3. Enclosure 4 contains the assumptions used in developing

.the Plan. Pursuant to 10 CFR 73.55(r), alternative measures which have been incorporated into the proposed Plan are discussed in Enclosure 5.

Classified By:

Name: _Jonathan R. Barbier

Title:

SECURITY COMPLIANCE COORD Unauthorized Disclosure Of Safeguards Information Will Be Organization: Nuc. Protection Services/ DEK Subiect To Civil And Criminal Sanctions Effective Date: October 1 2015 NOTE: ENCLOSURE 1 TO THIS LEITER CONTAINS "SECURITY-RELATED INFORMATION" AND ENCLOSURES 3, 4, and 5 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION." THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

Safeguards Information *k-\ ~ssc?l.o

~DO\

Safeguards Information Serial No.15-302 Docket Nos.: 50-305, 72-64 Page 2 of 3 In order to support site transition to "ISFSI only" status, DEK is requesting NRG approval of this proposed license amendment by October 1, 2016. DEK requests an implementation period of 60 days following DEK's submittal of written notification to the NRG that the remaining spent fuel assemblies have been transferred from the spent fuel pool to the ISFSL In addition, this license amendment will not be implemented if there is a requirement to returnr spent fuel from. the ISFSI to the spent fuel pool.

I DEK requests that Enclosure 1, which contains Security-:-Related Information, be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosures 3, 4, and 5 contain Safeguards Information as defined by 10 CFR 73.22 and their disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended.

If you have any questions regarding this submittal, please contact Ms. Margaret A. Earle at (804) 273-2768.

Sincerely, Gianna C. Clark Vice President - Nuclear Support Services Commitments made in this letter: None COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County an_d Commonwealth aforesaid, today by Gianna C. Clark, who is Vice President - Nuclear Support Services, of Dominion Energy Kewaunee, Inc. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of this Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this / S~ay of tlt'ObfY ,2015.

5 -3 J- /'f If&-;{~

My Commission Expires:

Notary Public : Evaluation of Proposed Changes (Security-Related Information) : Evaluation of Proposed Changes (Uncontrolled) : Kewaun_ee Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (Safeguards Information) : Programmatic Assumptions for ISFSI Only Sites (Safeguards Information) : Evaluations of Proposed Alternative Measures (Safeguards Information)

NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SECURITY-RELATED INFORMATION" AND ENCLOSURES 3, 4, and 5 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION."

THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

Safeguards Information

Safeguards Information Serial No.15-302 Dock.et Nos.: 50-305, 72-64 Page 3 of 3.

cc: U. S. Nuclear Regulatory Commission Region Ill*

Regional Administrator 2443 Warrenville Road Suite 210

_ Lisle, Illinois 60532-4352 Public Service Commission of Wisconsin (w/o Enclosures)

Electric Divisiori P. 0. Box 7854 Madison, WI 53707 Mr. T. H Carter (w/o Enclosures)

NRC Senior Project Manager Kewaunee U. S. Nuclear Regulatory Commission Mail Stop T-8 F5 Two White Flint North 11545 Rockville Pike Rockville, MD .20852-2738 Dr. P. Longmire (w/o Enclosures)

NRC Project Manager U. S. Nuclear Regulatory Commission Mail Stop 14-C79 Three White Flint North .

11601 Landsdown Street Rockville, MD 20852-2738 NRC Regional Inspector (w/o Enclosures)

Kewaunee Power Station NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SECURITY-RELATED INFORMATION" AND ENCLOSURES 3, 4, and 5 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION."

THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

Safeguards Information

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com

• Safeguards Information October 15, 2015 U.S. Nuclear Regulatory Commission Serial No.: 15-302 Attention: Document Control Desk NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket Nos.: 50-305 72-64 DOMINION ENERGY KEWAUNEE, INC. .License No.: DPR-43 KEWAUNEE POWER STATION REQUEST FOR APPROVAL OF THE KEWAUNEE POWER STATION SECURITY PLAN In accordance with the provisions of 10 CFR 50.4 and 50.90, Dominion Energy Kewaunee, Inc. (DEK) is submitting a request for an amendment to the Operating License (OL) for

• Kewaunee Power Station. Specifically, this proposed license amendment requests NRG approval of the Kewaunee Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (the Plan) and removal of the Cyber Security requirements from the OL. The Plan will supersede the current Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan at KPS. The Plan addresses the protection .of material on site that is licensed by the KPS Operating License. The protection of material subject to the requirements of 10 CFR 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material," is addressed in a separate plan. The future site configuration that is reflected in the Plan assumes that the remaining spent fuel in the spent fuel pool has been moved to the ISFSI and that there is no requirement to return spent fuel to the spent fuel pool ("ISFSI only" status). Spent fuel movement to the ISFSI is currently scheduled to be completed by the end of 2016.

AREVA Inc. (AREVA) is the holder of Certificate of Compliance (CoC) 1004 for the Standardized NUHOMS System, which is used to store spent fuel at the KPS ISFSI.

Currently the technical specifications associated with this CoC require that under certain circumstances the cask must be returned to the spent fuel pool for inspection. AREVA submitted an application to revise this CoC on August 24, 2015 to remove this requirement.

AREVA has requested approval of the CoC by October 2016. Once the CoC is revised, there will rio longer be a requirement to return spent fuel to the spent fwel pool. In addition, in a September 14, 2015 letter (Serial No.15-185), DEK submitted an OL amendment request that would clarify that spent fuel will not be stored in the spent fuel pool.

An evaluation of the proposed license amendment is provided in Enclosures 1 and 2. The Plan is provided in Enclosure 3. Enclosure 4 contains the assumptions used in developing

.the Plan. Pursuant to 10 CFR 73.55(r), alternative measures which have been incorporated into the proposed Plan are discussed in Enclosure 5.

Classified By:

Name: _Jonathan R. Barbier

Title:

SECURITY COMPLIANCE COORD Unauthorized Disclosure Of Safeguards Information Will Be Organization: Nuc. Protection Services/ DEK Subiect To Civil And Criminal Sanctions Effective Date: October 1 2015 NOTE: ENCLOSURE 1 TO THIS LEITER CONTAINS "SECURITY-RELATED INFORMATION" AND ENCLOSURES 3, 4, and 5 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION." THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

Safeguards Information *k-\ ~ssc?l.o

~DO\

Safeguards Information Serial No.15-302 Docket Nos.: 50-305, 72-64 Page 2 of 3 In order to support site transition to "ISFSI only" status, DEK is requesting NRG approval of this proposed license amendment by October 1, 2016. DEK requests an implementation period of 60 days following DEK's submittal of written notification to the NRG that the remaining spent fuel assemblies have been transferred from the spent fuel pool to the ISFSL In addition, this license amendment will not be implemented if there is a requirement to returnr spent fuel from. the ISFSI to the spent fuel pool.

I DEK requests that Enclosure 1, which contains Security-:-Related Information, be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosures 3, 4, and 5 contain Safeguards Information as defined by 10 CFR 73.22 and their disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended.

If you have any questions regarding this submittal, please contact Ms. Margaret A. Earle at (804) 273-2768.

Sincerely, Gianna C. Clark Vice President - Nuclear Support Services Commitments made in this letter: None COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County an_d Commonwealth aforesaid, today by Gianna C. Clark, who is Vice President - Nuclear Support Services, of Dominion Energy Kewaunee, Inc. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of this Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this / S~ay of tlt'ObfY ,2015.

5 -3 J- /'f If&-;{~

My Commission Expires:

Notary Public : Evaluation of Proposed Changes (Security-Related Information) : Evaluation of Proposed Changes (Uncontrolled) : Kewaun_ee Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (Safeguards Information) : Programmatic Assumptions for ISFSI Only Sites (Safeguards Information) : Evaluations of Proposed Alternative Measures (Safeguards Information)

NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SECURITY-RELATED INFORMATION" AND ENCLOSURES 3, 4, and 5 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION."

THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

Safeguards Information

Safeguards Information Serial No.15-302 Dock.et Nos.: 50-305, 72-64 Page 3 of 3.

cc: U. S. Nuclear Regulatory Commission Region Ill*

Regional Administrator 2443 Warrenville Road Suite 210

_ Lisle, Illinois 60532-4352 Public Service Commission of Wisconsin (w/o Enclosures)

Electric Divisiori P. 0. Box 7854 Madison, WI 53707 Mr. T. H Carter (w/o Enclosures)

NRC Senior Project Manager Kewaunee U. S. Nuclear Regulatory Commission Mail Stop T-8 F5 Two White Flint North 11545 Rockville Pike Rockville, MD .20852-2738 Dr. P. Longmire (w/o Enclosures)

NRC Project Manager U. S. Nuclear Regulatory Commission Mail Stop 14-C79 Three White Flint North .

11601 Landsdown Street Rockville, MD 20852-2738 NRC Regional Inspector (w/o Enclosures)

Kewaunee Power Station NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SECURITY-RELATED INFORMATION" AND ENCLOSURES 3, 4, and 5 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION."

THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

Safeguards Information