ML13312A920

Kewaunee Power Station - Response to Request for Additional Information Regarding License Amendment Request 256. Permanently Defueled License and Technical Specifications

ML13312A920
Person / Time
Site:	Kewaunee
Issue date:	11/07/2013
From:	Sartain M D Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226E
Download: ML13312A920 (10)

Text

1Domi nionDominion Energy Kewaunee, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060v, Web Address:

www.dom.com November 7, 2013U. S. Nuclear Regulatory Commission Attention:

Document Control DeskWashington, DC 20555-0001 DOMINION ENERGY KEWAUNEE, INC.Serial No. 13-226ELIC/CDS/RO Docket No. 50-305License No. DPR-43KEWAUNEE POWER STATIONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 256. PERMANENTLY DEFUELED LICENSEAND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to Renewed Facility Operating License for KewauneePower Station (KPS). The proposed amendment would revise the Operating Licenseand associated Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the facility.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request foradditional information (RAI) regarding the proposed amendment (Reference 2). TheRAI questions and associated DEK response are provided in Attachment 1 to this letter.The June 1, 2014 requested approval date for the submittal remains unchanged.

Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or requireadditional information.

Sincerely, t-jlh4Q~j4-Mark D. SartainVice President

-Nuclear Engineering and Develol~menLt

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...0.Rb ----w w -COMMONWEALTH OF VIRGINIACOUNTY OF HENRICO)))!CRAIG D SLYNotary PublicCommonwealth of VirginiaReg. # 7518653My Commission Expires December 31, 2016The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, todayby Mark D. Sartain, who is Vice President

-Nuclear Engineering and Development of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of thatCompany, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this _ _h day of *kJvt,- ,It" r 2013.Mv Commissinn Fynires:

I t. 2.1--/ 1 otbiryrublic Auc~(L(WL Serial No. 13-226ERAI Response License Amendment Request 256Page 2 of 2

Attachment:

1. Response to Request for Additional Information

References:

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"

dated May 29, 2013 (ADAMS Accession No. ML13156A037).

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 -KewauneeDefueled License and TS LAR Request for Additional Information MF1952-RAII-AHPB-Keefe-001 to -003," dated October 9, 2013.Commitments made by this letter: Nonecc: Regional Administrator, Region IIIU. S. Nuclear Regulatory Commission 2443 Warrenville RoadSuite 210Lisle, IL 60532-4352 Dr. K. D. Feintuch, Project ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D1511555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power StationPublic Service Commission of Wisconsin Electric DivisionP.O. Box 7854Madison, WI 53707 Serial No. 13-226EATTACHMENT 1RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-226EAttachment 1Page 1 of 7RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to the KPS Renewed Facility Operating License forKewaunee Power Station (KPS). The proposed amendment would revise the Operating License and associated Technical Specifications (TS) to Permanently DefueledTechnical Specifications (PDTS) consistent with the permanently defueled status of thefacility.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request foradditional information (RAI) regarding the proposed amendment (Reference 2). TheRAI questions and associated DEK responses are provided below.NRC Question MF1952-RAII-AHPB-Keefe-001-2013-10-09 Section 5.1 addresses Responsibilities.

Technical Specification 5.1.2 states that theshift manager shall be responsible for the shift command function.

NUREG-1625, "Proposed Standard Technical Specifications for Permanently DefueledWestinghouse Plants,"

dated March, 1998 provides specific criteria with regard toresponsibility, specifically with regard to the shift supervisor being absent from thecontrol room.Please describe personnel responsibility when the Shift Supervisor is absent from thecontrol room.Response:

NUREG-1625 states that the proposed TS contained therein were based on theImproved STS for Westinghouse Plants (i.e., NUREG-1431).

The KPS TS are alsobased on NUREG-1431.

However, they are based on a later version of NUREG-1431 than was used for development of NUREG-1625.

KPS converted from a custom TSformat to the Improved STS format via Amendment 207. KPS Amendment 207 wasapproved by NRC in a safety evaluation dated February 2, 2011 (Reference 3). Thesafety evaluation states that "the NRC staff's conclusion

[is] that the ITS are consistent with the KPS current licensing basis (CLB) and the requirements of 10 CFR 50.36."The "Regulatory Evaluation" contained in the NRC safety evaluation states the following regarding the required contents of Technical Specifications.

Serial No. 13-226EAttachment 1Page 2 of 7In 10 CFR 50.36, the Commission established its regulatory requirements related tothe content of TS. In doing so, the Commission placed emphasis on those mattersrelated to the prevention of accidents and the mitigation of accident consequences.

As recorded in the Statements of Consideration, "Technical Specifications for FacilityLicenses; Safety Analysis Reports" (33 FR 18610, December 17, 1968), theCommission noted that applicants were expected to incorporate into their TS "thoseitems that are directly related to maintaining the integrity of the physical barriersdesigned to contain radioactivity."

The certification for permanent removal of fuel from the reactor vessel pursuant to 10CFR 50.82(a)(1)(ii) that was submitted to NRC on May 14, 2013, did not authorize performance of any new activities at KPS that were not previously allowed.

No newaccidents or accident sequences were created as a result of DEK permanently shuttingdown and defueling KPS. The integrity of the remaining necessary physical barriersdesigned to contain radioactivity also remains unchanged in the permanently defueledcondition.

As such, the requirements of the existing TS are bounding on the defueledfacility and no new requirements are considered necessary.

The NRC did not consider it necessary to require specific criteria regarding the shiftsupervisor (shift manager) being absent from the control room, when approving the KPSImproved TS for KPS as an operating plant. Therefore, no such new criteria are beingproposed for KPS as a permanently defueled plant.The shift manager does not need to be in the control room to be responsible for andfulfill the shift command function.

The location of the command center is functionally where the shift manager is located.

As discussed in the response to NRC QuestionMF2370-RAII-AHPB-Lapinsky-007 (Reference 4), control of activities may be performed either remotely from the control room or locally in the plant. Spent fuel handlingactivities are performed locally at the SFP. Accordingly, the shift manager isresponsible for directing response to abnormal situations from either the control room,or locally at the SFP, in accordance with applicable response procedures.

Being absentfrom the control room does not relieve the shift manager of responsibility for the shiftcommand function.

Procedure OP-KW-100, "Conduct of Operations,"

establishes uniform standards andexpectations associated with operational activities and provides the framework forstandards and expectations required to conduct operations in a consistent manner.This procedure specifies the requirements for the shift manager and for staffing thecontrol room. Per this procedure, the normal control room complement (except for shortduration reductions),

consists of two personnel, one of which is either the shift manageror the on-shift supervisor.

The shift manager maintains the shift command functionwhen absent from the control room. The control room complement is maintained toallow implementation of the Emergency Plan. The existing administrative requirements in Procedure OP-KW-100.

are considered adequate for specifying the responsibility of Serial No. 13-226EAttachment 1Page 3 of 7the shift manager, and thus no new Technical Specifications regarding absence of theshift manager from the control room are being proposed.

NRC Question MF1952-RAII-AHPB-Keefe-002-2013-10-09 Section 5.1.1 of NUREG-1625 states that the Plant manager or designee, inaccordance with approved administrative procedures, shall approve each proposed test,fuel movement, load movement, or experiment prior to implementation and shallapprove modification to structures, systems or equipment that affect safe storage ofirradiated fuel.In Section 5.1.1 of the submittal dated March 29, 2013, there is no discussion ofapproval of fuel movement or load movement.

Were these intended to be left out of the responsibilities of the plant manager?Please describe who is responsible for approval of fuel or load movement.

Response

The previous response to Question 1 above regarding inclusion of requirements intoplant Technical Specifications, including the guidance contained in NUREG-1625, isalso applicable to this question.

The requirements contained in the existing TS arebounding on the defueled facility and no new requirements have been proposedregarding approval of spent fuel movement or heavy load movement.

As discussed in the response to NRC Question MF2370-RAII-AHPB-Lapinsky-003 (Reference 4), movement of spent fuel or heavy loads that could affect the safehandling and storage of nuclear fuel would be approved by the shift manager.

Inaccordance with proposed TS 5.1.2, the shift manager will retain the overall shiftcommand and control function.

Proposed TS 5.2.2 requires the shift manager to be aCertified Fuel Handler.Existing procedural requirements are adequate for specifying who is responsible forapproving of spent fuel or heavy load movement.

Therefore, no new Technical Specification requirements regarding plant manager responsibilities or regarding approval of spent fuel or heavy load movement are being proposed.

Serial No. 13-226EAttachment 1Page 4 of 7NRC Question MF1952-RAII-AHPB-Keefe-003-2013-10-09 NUREG-1625, Proposed Standard Technical Specifications for Permanently DefueledWestinghouse Plants,"

dated March, 1998 provides specific criteria with regard to facilitystaffing.

The Kewaunee submittal only partially addressed these staffing criteria.

Please provide information on the following:

a. To accommodate unexpected absences of on duty shift crew members, the shiftcrew composition may be one less than the minimum requirements depicted in thereferenced table for no more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, provided immediate action is taken torestore the shift crew composition to within minimum requirements.

During suchabsences, no fuel movement or movement of loads over storage racks containing fuel shall be permitted.

This provision does not permit any shift crew position to beunmanned upon shift change due to the absence or tardiness of an oncoming shiftcrew member.b. At least one qualified person (non-certified operator or CERTIFIED FUELHANDLER) shall be present in the Control Room when irradiated fuel is stored inthe spent fuel pool;c. An individual qualified in radiation protection procedures shall be on site during fuelhandling operations or movement of loads over storage racks containing fuel;d. Fuel handling operations or movement of loads over storage racks containing fuelshall be directly supervised by a CERTIFIED FUEL HANDLER;e. Administrative procedures shall be developed and implemented to limit the workinghours of shift personnel who perform functions important to the safe storage ofirradiated fuel assemblies (e.g., CERTIFIED FUEL HANDLERS, non-certified operators, radiation protection personnel, and key maintenance personnel).

Response

The previous response to Question 1 above regarding inclusion of requirements intoplant Technical Specifications, including the guidance contained in NUREG-1625, isalso applicable to this question.

The requirements contained in the existing TS arebounding on the defueled facility and no new staffing requirements are considered necessary.

Specific responses to items "a" thru "e" in Question 3 above are provided below.

Serial No. 13-226EAttachment 1Page 5 of 7a. Unexpected absences of on duty shift crew membersAs discussed in the response to NRC Question MF2370-RAII-AHPB-Lapinsky-004 (Reference 4), on-shift crew members are held over until relieved.

Procedure OP-KW-1 00, "Conduct of Operations,"

specifies that the off-going watch stander remainsresponsible until properly

relieved, and does not relinquish the watch until satisfied that the on-coming watch stander is fully briefed and prepared.

This 2-hourallowance is consistent with NUREG-1431 and was approved by NRC inAmendment 207 (Reference

3) as part of the KPS conversion to Improved Technical Specifications.

While it is conceivable that neither of the two minimum crew members would (orcould) arrive onsite under severe weather conditions, such conditions would also beexpected to prevent the on-shift crew members from departing the site. Regardless, barring extreme circumstances, appropriate on-shift staffing is required to beretained on site in such situations (i.e., personnel are held over until relief staffarrives).

If spent fuel or heavy load movement were in progress when such acondition arose, actions would immediately be initiated to place the spent fuel orheavy load in a safe condition and prohibit additional movement until the condition was resolved.

Thus, DEK proposes no change to the 2-hour allowance contained in TS 5.2.2.b.b. One qualified person present in the Control RoomAs discussed in the response to Question 1 above, control of activities may beperformed either remotely from the control room or locally in the plant. Spent fuelhandling activities are performed locally at the SFP. The shift manager isresponsible for directing response to abnormal situations from either the controlroom, or locally at the SFP, in accordance with applicable response procedures.

Procedure OP-KW-100 requires that at least one qualified person be present in thecontrol room at all times. This level of detail is not needed in the TS and isadequately maintained in licensee-controlled documents.

Thus, no new TSrequirements have been proposed for control room staffing.

c. Individual qualified in radiation protection procedures As discussed in the response to NRC Question MF2370-RAII-AHPB-Lapinsky-016 (Reference

4) and in the response to NRC Question MF1952-RAII-STSB-Grover-004 (Reference 5), radiation protection staff will not be required to be on shift.Rather, they will be part of the normal facility staff. Per proposed TS 5.2.2 and Table5.2.2-1, there is no requirement for individuals qualified in radiation protection procedures to be a part of the minimum shift crew. The current TS 5.2.2 requires aradiation protection technician to be on site only when fuel is in the reactor.

Serial No. 13-226EAttachment 1Page 6 of 7Radiation protection (RP) technical oversight during fuel handling activities isprovided by facility or supplemental RP personnel as specified in applicable RP andfuel handling procedures.

Procedural and Technical Requirements Manualrequirements related to fuel handling and movement of loads over storage rackscontaining spent fuel are listed in Reference

5. The existing procedural and TRMrequirements are adequate to ensure that appropriate coverage by radiation protection staff is provided during fuel handling operations and during movement ofloads over storage racks containing spent fuel. Thus, no new TS requirements havebeen proposed for radiation protection personnel staffing.

d. Fuel handlinq or movement of loads supervised by a CERTIFIED FUEL HANDLERAs discussed in the response to NRC Question MF2370-RAII-AHPB-Lapinsky-005 (Reference

4) and in the response to NRC Question MF1952-RAII-STSB-Grover-005 (Reference 5), the "qualified individual" referred to in proposed TS 5.2.2.c is aCertified Fuel Handler.

Certified Fuel Handlers are responsible for handling ofnuclear fuel, as stated in the "Shift Manager / Certified Fuel Handler TrainingProgram Guide." This document also explicitly requires that Certified Fuel Handlersbe trained to supervise fuel movement as part of their qualification process.Additionally, proposed TS 5.1.2 places overall responsibility for facility operation withthe shift manager, who is required to be a Certified Fuel Handler per proposed TS5.2.2.d.There is no intended difference between a "qualified individual" (as referred to in TS5.2.2.c) and a Certified Fuel Hander. TS 5.2.2.c was proposed with the terminology of "qualified individual" for consistency with Millstone Unit 1 TS 5.2.2.e becauseMillstone and KPS are both part of the Dominion fleet. The proposed TS 5.2.2.c isidentical to the requirement approved by NRC for Millstone Unit 1 in existing TS5.2.2.e.Proposed TS 5.2.2.a requires that a Certified Fuel Handler be part of the minimumshift crew composition.

Proposed TS 5.2.2.d will require that the shift manager is aCertified Fuel Handler.

Proposed TS 5.1.2 will require that the shift manager isresponsible for the shift command function.

Finally, proposed TS 5.2.2.c will requirethat all fuel handling operations are directly supervised by a qualified individual.

The"qualified individual" referred to in proposed TS 5.2.2.c is a Certified Fuel Handler.These requirements, in aggregate, assure that fuel handling operations are directlysupervised by a Certified Fuel Handler.e. Administrative procedures to limit working hours who perform certain functions NUREG-1431 does not contain requirements for limiting work hours at eitheroperating reactors or shutdown reactors.

Subsequent to publishing NUREG-1625, Serial No. 13-226EAttachment 1Page 7 of 7work hour requirements were incorporated into 10 CFR 26, Subpart I -ManagingFatigue.

Therefore, Part 26 now applies and no new TS have been proposed forwork hour restrictions.

Appropriate work hour limitations are contained in licenseecontrolled procedures.

References

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "LicenseAmendment Request 256: Permanently Defueled License and Technical Specifications,"

dated May 29, 2013 (ADAMS Accession No. ML13156A037).

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 -KewauneeDefueled License and TS LAR Request for Additional Information MF1952-RAII-AHPB-Keefe-001 to -003," dated October 9, 2013.3. Safety Evaluation by the Office of Nuclear Reactor Regulation Related toAmendment No. 207 to Facility Operating License No. DPR-43, Dominion EnergyKewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2,2011.4. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "Response to Request for Additional Information Regarding License Amendment Request 256,Permanently Defueled License and Technical Specifications,"

dated September 23,2013.5. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk,"Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications,"

dated October 15, 2013.