ML092440371

License Amendment Request 249, Conversion to Improved Technical Specifications

ML092440371
Person / Time
Site:	Kewaunee
Issue date:	08/24/2009
From:	Hartz L Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-491, LIC/GOR/R0, TAC ME02467
Download: ML092440371 (6)

Text

Dominion Energy Kewaunee, Inc. Dominio 5000 Dominion Boulevard, Glen Allen, VA 23060 PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 August 24, 2009 ATTN: Document Control Desk Serial No.09-491 U. S. Nuclear Regulatory Commission LIC/GOR/RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST 249: KEWAUNEE POWER STATION CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS (TAC NO. ME02467)

Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (Kewaunee). This amendment request would revise Kewaunee's current Technical Specifications (CTS) to Improved Technical Specifications (ITS) consistent with the Improved Standard Technical Specifications (ISTS) described in NUREG 1431, "Standard Technical Specifications - Westinghouse Plants," Revision 3.0. The guidance of Nuclear Energy Institute (NEI) NEI 96-06, "Improved Technical Specifications Conversion Guidance," dated August 1996, and Nuclear Regulatory Commission (NRC)

Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications," dated October 9, 1996, were used in preparing this submittal. The detailed descriptions and justifications to support the proposed changes are provided in the volumes attached to this letter (Attachment 1).

This submittal also contains Attachments 2, 3, 4, and 5. Attachments 2, 3, and 4 provide the evaluations DEK performed to justify adoption of changes associated with reactor protection system and engineered safety feature actuation system completion times, bypass times, and surveillance test interval extensions consistent with NRC approved WCAP-10271, WCAP-14333, and WCAP-15376. Attachment 5 contains the commitments made in this submittal. The commitments contained in this submittal are only those contained in Attachment 5.

The following enclosures are also included to assist the NRC in the review of this submittal:

• Enclosure 1, "Contents of the Kewaunee Power Station Improved Technical Specifications (ITS) Submittal," describes the organization and content of the submittal, including each of the volumes in Attachment 1.

ATTACHMENT CONTAINS PROPRIETARY INFORMATION Attachment 3 contains information to be withheld from public disclosure in accordance with 10 CFR 2.390. Upon removal of Attachment 3, this letter is decontrolled.

/4-001

Serial No.09-491 Page 2 of 6

• Enclosure 2, "Beyond Scope Changes," provides a list and description of the changes included in the ITS submittal that are beyond the scope of the ISTS as described in NUREG-1431, Revision 3.0, and also beyond the scope of the CTS.

" Enclosure 3, "Disposition of Generic Changes to NUREG-1431, Revision 3.0,"

lists the NRC approved changes to NUREG-1431, Revision 3.0, as of August 13, 2009, and summarizes the disposition of each of these changes in the Kewaunee license amendment request.

Enclosure 4, "Disposition of Existing License Amendment Requests," provides the disposition of other, currently docketed license amendment requests for Kewaunee, as they relate to this license amendment request.

Enclosure 5 is the Westinghouse Affidavit for Withholding, Proprietary Information Notice, and Copyright Notice associated with Attachment 3. contains information proprietary to Westinghouse Electric Corporation (Westinghouse). Accordingly, it is requested that this information be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4) of the Commission's regulations. This request is supported by an affidavit (Enclosure 5), signed by Westinghouse, that sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations-listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. Attachment 4 is a redacted version of this information.

Included in Attachment 1 are bases for the proposed ITS. These bases are a summary statement of the bases or reasons for such specifications. However, the basis are not a part of the technical specifications but are maintained consistent with the Kewaunee Updated Safety Analysis Report (USAR).

Kewaunee was originally designed and licensed as a "Hot Shutdown Plant" (i.e.,

reaching hot shutdown status (reactor sub-critical with reactor coolant temperature 540°F to 547 0F)js sufficient (reference 1)). The current technical specifications for Kewaunee generally require that prior to criticality most structures, systems, and components are operable. Similarly, the CTS often only requires that the reactor be shutdown (i.e., sub-critical) when structures, systems, or components (SSCs) are made or found to be inoperable. Included in Attachment 1 are Kewaunee ITS bases that cover specifications requiring the same SSCs to be operable in ITS Modes 1, 2, and 3 or Modes 1, 2, 3, and 4. In many cases the wording in the Kewaunee ITS bases supports placing the plant in cold shutdown, yet the ITS bases were not changed unless the wording was specifically incorrect or inconsistent with the Kewaunee USAR.

Therefore, although included in the ITS Bases, this proposed amendment is not intended to change Kewaunee's licensing basis requirements to include postulating design basis events not previously considered.

Serial No.09-491 Page 3 of 6 DEK requests approval of the proposed amendment by August 31, 2010 to support implementation prior to the 2011 spring outage. Once approved, the amendment shall be implemented within 180 days.

This license amendment request incorporates changes associated with WCAP-1 0271, WCAP-14333, and WCAP-15376, which are risk informed and generically approved by the NRC. DEK has evaluated these proposed changes using the guidance in Regulatory Guide (RG)1.174, "An Approach for Using Probabilistic Risk Assessment In Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." The evaluations are provided in Attachments 2 and 3.

The Facility Safety Review Committee (on-site review) has approved the proposed change and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91 (b).

If you have any questions or require additional information, please contact Mr. Gerald

0. Riste at (920)388-8424.

Very truly yours, Leslie N. Hartz Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, 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 that Company, and the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this j2yi+/-ý?day of AVO UIV$+/- ,2009.

My Comm ission'expires: 9///3 INS .Notary Public w v

f Serial No.09-491 Page 4 of 6 Attachments:

1. Kewaunee ITS Submittal, Volumes 1 through 16

2. Background and Technical Analysis for Adoption of WCAP-1 0271, WCAP-1 4333 (TSTF-418), and WCAP-1 5376 (TSTF-411)

3. Applicability of WCAP-14333 and WCAP-15376 to Kewaunee Power Station -

(Proprietary)

4. Applicability of WCAP-14333 and WCAP-15376 to Kewaunee Power Station -

(Non-Proprietary)

5. Commitment List

Enclosures:

1. Contents of the Kewaunee Power Station (Kewaunee) Improved Technical Specifications (ITS) Submittal

2. Beyond Scope Changes

3. Disposition of Generic Changes to NUREG 1431, Revision 3.0

4. Disposition of Existing License Amendment Requests

5. Affidavit for Withholding, Proprietary Information Notice, and Copyright Notice Commitments made by this letter: See Attachment 5 Enclosed with this letter is a digital video disk (DVD), which contains this submittal's Attachments and Enclosures, labeled:

Dominion Energy Kewaunee, Inc.

Kewaunee Power Station License Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications Serial No.09-491 Docket No.: 50-305 License No.: DPR-43

Serial No.09-491 Page 5 of 6 The enclosed DVD contains the following files:

File Name File Size Sensitivity 001 Attachment 1.pdf 61,000 bytes publicly available 002 Att 1 Vol 01 (Split Report).pdf 571,000 bytes publicly available 003 Att 1 Vol 2 (Generic NSHCs).pdf 425,000 bytes publicly-available 004 Att 1 Vol 3 (Chapter 1.0).pdf 782,000 bytes publicly available 005 Att 1 Vol 4 (Chapter 2.0).pdf 413,000 bytes publicly available

,006 Att 1 Vol 5 (Section 3.0).pdf 753,000 bytes publicly available 007 Att 1 Vol 6 (Section 3.1).pdf 1,476,000 bytes publicly available 008 Att 1 Vol 7 (Section 3.2).pdf 974,000 bytes publicly available 009 Att 1 Vol 8 (Section 3.3).pdf 3,833,000 bytes publicly available 010 Att 1 Vol 9 (Section 3.4).pdf 3,126,000 bytes publicly available 011 Att 1 Vol 10 (Section'3.5).pdf 1,241,000 bytes publicly available 012 Att 1 Vol 11 (Section 3.6).pdf 2,386,000 bytes publicly available 013 Att 1 Vol 12 (Section 3.7).pdf 2,912,000 bytes publicly available 014 Att 1 Vol 13 (Section 3.8).pdf 2,062,000 bytes publicly available 015 Att 1 Vol 14 (Section 3.9).pdf 1,373,000 bytes publicly available 016 Att 1 Vol 15 (Chapter 4.0).pdf 536,000 bytes publicly available 017 Att 1, Vol 16 (Chapter 5.0).pdf 1,319,000 bytes publicly available 018 Attachment 2.pdf 169,000 bytes publicly available 019 Attachment 3 (proprietary).pdf 108,000 bytes proprietary 020 Attachment 4.pdf 104,000 bytes publicly available 021 Attachment 5.pdf 87,000 bytes publicly available 022 Enclosures 1, 2, 3, 4, and 5.pdf 717,000 bytes publicly available

Serial No.09-491 Page 6 of 6 cc: Regional Administrator, Region III (w/ one proprietary DVD copy)

U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. P. S. Tam (w/ one proprietary DVD copy)

Sr. Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. R. B. Elliott (w/ one proprietary DVD copy)

NRC IT Branch Chief U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 H4A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. V. G. Cusumano (w/ one proprietary DVD copy)

NRC KPS ITS Conversion Lead U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-7 C2A 11555 Rockville Pike Rockville, MD 20852-2738.

NRC Senior Resident Inspector (w/ one proprietary DVD copy)

Kewaunee Power Station Public Service Commission of Wisconsin (w/ one non-proprietary DVD copy)

Electric Division P.O. Box 7854 Madison, WI 53707

Reference:

1. Letter from Steven A. Varga (NRC) to D.C. Hintz (WPSC), LTOP Analysis and Modification Safety Analysis, dated September 6, 1985.