ML13294A031

Attachment 2 - Environmental Considerations

ML13294A031
Person / Time
Site:	Kewaunee
Issue date:	10/08/2013
From:	Dominion, Dominion Energy Kewaunee
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML13294A033	List: ML13290A153 ML13294A031
References
13-287D
Download: ML13294A031 (4)

Text

SAFEGUARDS INFORMATION Serial No. 13-287D Docket Nos.:50-305, 72-64 Security Exemption Request Attachment 2 Environmental Consideration Kewaunee Power Station Dominion Energy Kewaunee, Inc.

NOTE: ATTACHMENT I TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF ATTACHMENT 1, THIS ATTACHMENT IS "DECONTROLLED."

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Serial No. 13-287D Docket Nos.:50-305, 72-64 Security Exemption Request Environmental Consideration Attachment 2, Page 1 of 3 ENVIRONMENTAL CONSIDERATION The proposed exemption meets 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)(F) the requirements from which the exemption is sought involve safeguard plans. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed exemption.

(i) No significant hazards consideration Dominion Energy Kewaunee, Inc. (DEK) has evaluated the proposed exemption 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. Does the proposed exemption involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed exemption has no effect on the operation of plant structures, systems, and components (SSCs) and no effect on the capability of any plant SSC to perform its design function. The proposed exemption would not increase the likelihood of a malfunction of any plant SSC. Minor modifications, which do not affect the operation of the SFP or the ability to mitigate any accidents previously identified, will be installed. The proposed exemption would have no effect on any of the previously evaluated accidents in the KPS Updated Safety Analysis Report. The exemption will not affect the probability of occurrence of any previously analyzed accident.

Therefore, the proposed exemption does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

NOTE: ATTACHMENT I TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF ATTACHMENT 1, THIS ATTACHMENT IS "DECONTROLLED."

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Serial No. 13-287D Docket Nos.:50-305, 72-64 Security Exemption Request Environmental Consideration Attachment 2, Page 2 of 3 The proposed exemption does not involve a physical alteration to plant equipment that is involved with the operation of plant systems. No new or different type of plant operating equipment will be installed and there are no physical modifications to existing operating equipment associated with the proposed exemptions. Similarly, the proposed exemption would not physically change any structures, systems, or components involved in the mitigation of any accidents. Thus, no new initiators or precursors of a new or different kind of accident will be 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. Does the proposed exemption involve a significant reduction in a margin of safety?

The proposed exemption does not alter the safety design basis or any safety limits for the plant. The proposed exemption does 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 exemption presents a 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 exemption.

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 NOTE: ATTACHMENT I TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF ATTACHMENT 1, THIS ATTACHMENT IS "DECONTROLLED."

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Serial No. 13-287D Docket Nos.:50-305, 72-64 Security Exemption Request Environmental Consideration Attachment 2, Page 3 of 3 operation of waste processing systems will not be affected by the exemption. The proposed exemption 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 exemption will result in no significant change to the types or significant increase in the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The exemption 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 dose. . Likewise, design basis accident dose is not impacted by the proposed exemption.

(iv) There is no significant construction impact.

There are only minor construction activities within existing structures associated with the proposed exemption.

(v) There is no significant increase in the potential for consequences from radiological accidents.

See the no significant hazards considerations discussion in item i above.

(vi)(F) The requirements from which exemption are sought involve safeguard plans.

The purpose of the exemptions is to change the requirements in 10 CFR 73.55(k)(5)(ii) as discussed in Attachment 1.

NOTE: ATTACHMENT I TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF ATTACHMENT 1, THIS ATTACHMENT IS "DECONTROLLED."

SAFEGUARDS INFORMATION