ML131830511

Attachment 2 - Environmental Considerations

ML131830511
Person / Time
Site:	Kewaunee
Issue date:	06/10/2013
From:	Dominion Energy Kewaunee, Dominion Resources Services
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML131830505	List: ML13165A343 ML131830511
References
13-287A
Download: ML131830511 (4)

Text

SAFEGUARDS INFORMATION Serial No. 13-287A Attachment 2 Environmental Considerations Kewaunee Power Station (KPS)Dominion Energy Kewaunee, Inc. (DEK)NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF ATTACHMENT 1, ATTACHMENT 2 IS"DECONTROLLED." SAFEGUARDS INFORMATION SAFEGUARDS INFORMATION Serial No. 13-287A Environmental Consideration Attachment 2 Page 1 of 3 ENVIRONMENTAL CONSIDERATIONS 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) 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 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: 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 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. The proposed exemption would have no effect on any of the previously evaluated accidents in the KPS Updated Safety Analysis Report as applicable to the permanently shutdown status. 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.

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

The proposed exemption does 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 exemption.

Similarly, the proposed NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF ATTACHMENT 1, ATTACHMENT 2 IS"DECONTROLLED." SAFEGUARDS INFORMATION SAFEGUARDS INFORMATION Serial No. 13-287A Environmental Consideration Attachment 2 Page 2 of 3 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 are created. Furthermore, the proposed exemption does 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 exemption does not create the possibility of a new or different kind of accident from any previously evaluated.

Does the proposed exemption involve a significant reduction in a margin of safety?The proposed exemption does not alter the 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 exemption does not involve a significant reduction in a margin of safety.Based on the above, DEK concludes that the proposed exemption presents 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 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.NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF ATTACHMENT 1, ATTACHMENT 2 IS"DECONTROLLED." SAFEGUARDS INFORMATION SAFEGUARDS INFORMATION Serial No. 13-287A Environmental Consideration Attachment 2 Page 3 of 3 (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 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 exemption.(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 exemption is sought involve safeguard plans or other requirements of an administrative, managerial or organizational nature.The purpose of the exemption is to change the requirements in 10 CFR that requires DEK to have the capability of continuous communications alarm stations and the control room to allow that communication to be alarm stations and the Shift Manager.73.55(j)(4)(ii) between the between the NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF ATTACHMENT 1, ATTACHMENT 2 IS"DECONTROLLED." SAFEGUARDS INFORMATION