ML13161A168

Cover Letter and Attachment 2 to Kewaunee Power Station, Request for Exemptions from 10 CFR 73.55 Power Reactor Security Requirements

ML13161A168
Person / Time
Site:	Kewaunee
Issue date:	06/04/2013
From:	Blasioli P A Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
13-287
Download: ML13161A168 (6)

Text

--wDominiow Dominion Energy Kewaunee, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com Security-Related Information

-Withhold Under 10 CFR 2.390 June 4, 2013 Attention:

Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATION (KPS)REQUEST FOR EXEMPTIONS FROM 10 CFR 73.55 POWER REACTOR SECURITY REQUIREMENTS Serial No.: 13-287 NL&OS/MAE:

R2 Docket Nos.: 50-305 72-64 License No.: DPR-43 In a February 25, 2013 letter (Serial No.13-107), Dominion Energy Kewaunee, Inc.(DEK) certified to the NRC that it had decided to permanently cease power operations of KPS on May 7, 2013. On May 7, 2013 KPS was shut down. The certification of permanent removal of the fuel from the reactor vessel was submitted to the NRC on May 14, 2013 (Serial No.13-293). Therefore, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.As part of the transition from an operating station to non-operating station, DEK is requesting an exemption from 10 CFR 73.55(p)(1)(i) and 10 CFR 73.55(p)(1)(ii) related to the suspension of security measures in an emergency or during severe weather. The exemption requests are provided in Attachment 1 and the Environmental Considerations is provided in Attachment

2. Attachment 1 contains Security-Related Information and it is requested that it be withheld from public disclosure under 10 CFR 2.390.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.Sincerely, P 6 /6 Paul A. Blasioli Director Nuclear Protection Services and Emergency Preparedness for Dominion Energy Kewaunee, Inc.Attachments;

1. Exemption Requests (Security-Related Information)

2. Environmental Considerations Commitments made by this letter: Upon disposition of these exemption Physical Security Plan will be appropriate.

requests, the revised as NOTE: ATTACHMENT I TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION AND MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."~51k2 Serial No.13-287 Docket Nos.:50-305, 72-64 Security Exemption Requests Page 2 of 2 cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch (w/o Attachment 1)Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector (w/o Attachment 1)Kewaunee Power Station Serial No.13-287 Attachment 2 Environmental Considerations Kewaunee Power Station (KPS)Dominion Energy Kewaunee, Inc. (DEK)

Serial No.13-287 Environmental Consideration Attachment 2, Page 1 of 3 ENVIRONMENTAL CONSIDERATIONS The proposed exemptions meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25), because the proposed exemption involves: (i) no significant hazards consideration; (ii) no significant change in the types or significant increase in the amounts of any effluent that may be released offsite; (iii) no significant increase in individual or cumulative occupational radiation exposure; (iv) no significant construction impact; (v) no significant increase in the potential for consequences from radiological accidents; and (vi) the requirements from which the exemption is sought involve safeguards plans or other requirements of an administrative, managerial or organizational nature. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed exemptions.(i) No significant hazards consideration Dominion Energy Kewaunee, Inc. (DEK) has evaluated the proposed exemptions to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92 as discussed below: 1. Do the proposed exemptions involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed exemptions would allow as a minimum both a certified fuel handler or a licensed senior operator to suspend security measures in an emergency or during severe weather at KPS (i.e. a plant with fuel permanently removed from the reactor).

The proposed exemptions have no effect on plant structures, systems, and components (SSCs) and no effect on the capability of any plant SSC to perform its design function.

The proposed exemptions would not increase the likelihood of a malfunction of any plant SSC. The proposed exemptions would have no effect on any of the previously evaluated accidents in the KPS Updated Safety Analysis Report. The exemptions will not affect the probability of occurrence of any previously analyzed accident.Therefore, the proposed exemptions do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed exemptions create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed exemptions do not involve a physical alteration of the plant. No new or different type of equipment will be installed and there are no physical modifications to existing equipment associated with the proposed exemptions.

Similarly, the proposed exemptions would not physically change any structures, Serial No.13-287 Environmental Consideration Attachment 2, Page 2 of 3 systems, or components involved in the mitigation of any accidents.

Thus, no new initiators or precursors of a new or different kind of accident are created.Furthermore, the proposed exemptions do not create the possibility of a new accident as a result of new failure modes associated with any equipment or personnel failures.

No changes are being made to parameters within which the plant is normally operated, or in the setpoints which initiate protective or mitigative actions, and no new failure modes are being introduced.

Therefore, the proposed exemptions do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed exemptions involve a significant reduction in a margin of safety?The proposed exemptions do not alter the design basis or any safety limits for the plant. The proposed exemptions do not impact station operation or any plant SSC that is relied upon for accident mitigation.

Therefore, the proposed exemptions do not involve a significant reduction in a margin of safety.Based on the above, DEK concludes that the proposed exemptions present no significant hazards consideration, and, accordingly, a finding of "no significant hazards consideration" is justified.(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.There are no expected changes in the types, characteristics, or quantities of effluents discharged to the environment associated with the proposed exemptions.

There are no materials or chemicals introduced into the plant that could affect the characteristics or types of effluents released offsite. In addition, the method of operation of waste processing systems will not be affected by the exemptions.

The proposed exemptions will not result in changes to the design basis requirements of SSCs that function to limit or monitor the release of effluents.

All the SSCs associated with limiting the release of effluents will continue to be able to perform their functions.

Therefore, the proposed exemptions will result in no significant change to the types or significant increase in the amounts of any effluents that may be released offsite.

Serial No.13-287 Environmental Consideration Attachment 2, Page 3 of 3 (iii) There is no significant increase in individual or cumulative occupational radiation exposure.The exemptions would result in no expected increases in individual or cumulative occupational radiation exposure on either the workforce or the public. There are no expected changes in normal occupational doses. Likewise, design basis accident dose is not impacted by the proposed exemption.(iv) There is no significant construction impact.There are no construction activities associated with the proposed exemptions.(v) There is no significant increase in the potential for consequences from radiological accidents.

See the no significant hazards considerations discussion in Item 1 above.(vi) The requirements from which exemptions are sought involve safeguard plans or other requirements of an administrative, managerial or organizational nature.The purpose of the exemptions is to change the requirements in 10 CFR 73.55(p)(1)(i) and 10 CFR 73.55(p)(1)(ii) to permit a certified fuel handler to approve the suspension of security measures in an emergency or during severe weather instead of a licensed senior operator.