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NRR-PMDAPEm Resource

From: Feintuch, KarlSent: Wednesday, January 30, 2013 10:41 AMTo: Feintuch, KarlCc: Wharton, RaynardSubject: FW: Conference Call Attendees - and presentation PowerPoint (attached)Attachments: Kewaunee Power Station Decom Plan Mtg.pdf

The agenda of this meeting was to discuss the attached PowerPoint. Participants are identified below. Cc Wharton is FYI for NMSS

From: Jack Gadzala [mailto:jack.gadzala@dom.com] Sent: Wednesday, January 30, 2013 8:25 AM To: Feintuch, Karl; Craig D Sly Cc: Krsek, Robert; Smith, Theodore Subject: RE: Conference Call Attendees - and presentation PowerPoint (attached) Region III participants were: Rob Krsek Christine Lipa Rhex Edwards Jack

From: Feintuch, Karl [mailto:Karl.Feintuch@nrc.gov] Sent: Tuesday, January 29, 2013 6:31 PM To: Jack Gadzala (Generation - 4); Craig D Sly (Generation - 6) Cc: Krsek, Robert; Smith, Theodore Subject: RE: Conference Call Attendees - and presentation PowerPoint (attached) NRC Headquarters participation for 1/29/2013, 1:00 – 3:30 PM conference call Name Affiliation (functional interest) Karl Feintuch NRR/DORL (licensing PM) Beth Mizuno OGC (legal) Sean Currie NRR/DIRS/IOLB (operator licensing) Russell Allwein NRR/DIRS/IFIB (financials) Michael Dusaniwskyj NRR/DIRS/IFIB (financials) Howard Benowitz OGC (legal) George Lapinsky NRR/DRA/AHPB (human factors) Mike Norris NSIR (emergency planning) Jack, are you able to acquire Region 3 participation?

From: Jack Gadzala [mailto:jack.gadzala@dom.com] Sent: Tuesday, January 29, 2013 4:21 PM To: Feintuch, Karl Subject: Conference Call Attendees Karl,

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Below is a list of Dominion participants in today’s teleconference to discuss Decommissioning activities. Jack Gadzala KPS Site Licensing Craig Sly Corp Licensing Dave Sommers Corp Licensing Manager Stewart Yuen KPS Decommissioning Director Tom Huber Corp Director Licensing & Ops Support Dan Meekhoff Corp Generation Project Manager Rick Anderson Corp Finance Manager Bill Zipp KPS Decommissioning Team

Jack Dominion KPS Licensing 920-388-8604

CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and/or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

Hearing Identifier: NRR_PMDA Email Number: 600 Mail Envelope Properties (4FFCA0F0F7657F428D1AF69C06EB598B0A7A45B308) Subject: FW: Conference Call Attendees - and presentation PowerPoint (attached) Sent Date: 1/30/2013 10:40:53 AM Received Date: 1/30/2013 10:40:00 AM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients: "Wharton, Raynard" <Raynard.Wharton@nrc.gov> Tracking Status: None "Feintuch, Karl" <Karl.Feintuch@nrc.gov> Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 3253 1/30/2013 10:40:00 AM Kewaunee Power Station Decom Plan Mtg.pdf 4862130 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

January 29, 2013

Kewaunee Power Station Decommissioning

Summary, Plans, and Activities

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Dominion Participants

� Stew Yuen - Decommissioning Project Director � Bill Zipp - Engineering � Dan Meekhoff - Nuclear Project Support � Mike Sortwell - Engineering � Bill Swanson - Operations � Brian Presl - Security/Safety � Jesse Arcand - Maintenance � Doug Zweerink - Outage and Planning � Tom Brunelli - QA/QC � Rick Anderson - Finance � Mike Bennett - Nuclear Site Services � Jack Gadzala - Site Licensing � Craig Sly - Corporate Licensing

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KPS Design and History

� Located on 908 acres on West shore of Lake Michigan near Green Bay, Wisconsin.

� Single unit two-loop PWR (Westinghouse design).

� Originally licensed to 1650 MWt. Power uprates increased license power output to current 1772 MWt.

� On-site ISFSI (Standardized NUHOMS®) constructed under a C of C. Currently ten HSMs in place. Eight DSC’s loaded, containing a total of 256 fuel assemblies.

� Low source term plant.

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KPS License History

� Construction Permit: August 6, 1968

� Operating License (OL): December 21, 1973

� Commercial Operation: June 16, 1974

� Renewed OL: February 24, 2011

� Initial OL Expiration : December 21, 2013

� Renewed OL expires December 21, 2033

� Final Reactor Operation: mid-2013

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Background

� October 22, 2012: Public announcement of intention to permanently shutdown and decommission Kewaunee.

� November 2, 2012: Notified NRC of intention to permanently cease power operations (NRC treating as unofficial notification because no specific shutdown date given).

� Kewaunee Decommissioning Team established.

� Shutdown date pending MISO grid stability study (required within 6 months of announcement).

� After MISO results, letter certifying intention to shutdown will be submitted with a planned shutdown date.

� After defuel, certification letter will be submitted per 50.82 (a)(1)(ii). Per 50.82(a)(2) the plant no longer authorized to operate.

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Decommissioning Method

� Three options evaluated in NUREG-0586 (NRC Generic GEIS for decommissioning nuclear facilities): DECON, SAFSTOR, ENTOMB.

� Dominion is pursuing a SAFSTOR option. � After defuel, facility is left intact and placed in a safe and stable

condition and maintained in that state for extended period. � Allows time for radioactive decay; reduces dose and quantity of

contaminated materials that must be disposed of. � After safe storage period, plant is dismantled and wastes

classified and disposed of properly. � License termination plan must be submitted for approval at least

two years prior to termination. � Final site characterization is performed and preparations made

for transition to unrestricted use.

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Post-Shutdown Decommissioning Activities Report (PSDAR) � Developed using RG 1.185 (and Draft RG DG-1272). � Submit February 2013 � High level summary of planned activities, general timing,

schedules, cost estimates, and bounding environmental evaluation.

� Discussion of spent fuel management plan. � After submittal, NRC has 90 days conduct public stakeholder

meetings. � After 90 days, DEK will have access to additional 20% of

decommissioning funds (total 23%). Funds can be used for decommissioning activities (initial 3% can be used for planning only).

� Submit LAR to change the license and TS in May 2013.

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Decommissioning Cost Estimate

� Decommissioning (50.75(f)) and fuel management (50.54(bb)) cost estimates last submitted in December 2008.

� Site specific cost estimate will be submitted with PSDAR. � Site specific cost estimate developed using RG 1.202,

AIF/NESP-036, and NUREG-1713, “SRP for Decommissioning Cost Estimates.”

� Decommissioning trust fund is a “commingled fund” (i.e. license termination, spent fuel management and site restoration are in the same trust fund).

� Clear relationship between license termination/fuel management activities and cost estimate for clarity.

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Spent Fuel Management Plan

� 50.54(bb) report will be submitted as standalone document at same time as PSDAR.

� Exemption from 50.82 (a)(8)(i) appears to be needed to allow use of funds for spent fuel management activities even though both activities are fully funded.

� After defuel: 1079 assemblies in the spent fuel pool and 256 assemblies in the ISFSI.

� Spent fuel pool cooling system modifications will be implemented to ensure a safe and stable configuration after the plant is shutdown.

� Fuel transfer to the ISFSI complete sometime around 2020. � Expand existing ISFSI pad, construct additional HSMs, and

procure MPCs to accommodate spent fuel and expected GTCC wastes.

� ISFSI will be decommissioned with the site after spent fuel and GTCC waste is transferred to DOE for permanent disposal.

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Near Term Licensing Activities

� Clear docket of remaining unnecessary licensing actions. � Submit permanent cessation/defuel certification letters. � Submit PSDAR (with DCE), 50.54(bb) update letter, and exemption

request (February 2013).� Submit LAR to change operating license and TS to reflect defueled

status (May 2013).� Determine and submit other necessary exemptions.

� 73.55 (radiological sabotage - evaluate) � 73.54 (cyber security)

� Resolve Orders (relax or rescind). � Revise and submit (as necessary) QA, EP, and Security, Fire Protection

program plan changes (and any associated exemptions that may be needed).

� Review and disposition regulatory commitments.

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SAFSTOR: License Termination Periods (50.75(c)) Unit Shutdown and Defueled: 2013

Period 1: SAFSTOR Planning, Preparations and Deactivation: 2013-14

Period 2: SAFSTOR Preparations Delay During Wet Fuel Storage: 2014-20

Period 3: Completion of SAFSTOR Preparations: 7/2020-12/2020

Period 4: Dormancy with Dry Storage: 2020-2050

Period 5: Dormancy Only: 2050-2067

Period 6: Decommissioning Planning During Dormancy: 2067-2069

Period 7: Dismantlement Site Modifications and Preparations: 2069-2070

Period 8: Systems Removal: 2070-2071

Period 9: Site Decontamination: 2071-2072

License Termination: 2073 60 Year License Termination Limit: 2073

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SAFSTOR: Spent Fuel Management Periods (50.54(bb))

Period 1: Spent Fuel Planning, Cooling, and Transfer to Dry Storage: 2013-20

Period 2: Dry Storage During Completion of SAFSTOR Preparations: 1/2020 - 12/2020

Period 3: Dry Storage During Dormancy: 2020-2050

Period 4: ISFSI Demolition: 2073

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Site Restoration Periods (Non-Radiological)

Period 1: Clean Building Demolition: 2072-2073

Period 2: Site Restoration: 2073

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Cost Estimate Totals (Costs in Millions 2012 dollars)

License Termination (50.75(c)) $549

Spent Fuel Management (50.54 (bb)) $353

Site Restoration (Non-Rad.) $35

Total $937

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Current Challenges

� Abbreviated pre-planning window.

� First plant in many years to decommission. Rules and guidance have changed.

� Decommissioning a single unit site is a new experience for our staff.

� Handling of Orders.

� EP and Security program changes.

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SAFSTOR Planning, Preparations and Deactivation � Using EPRI TR 1003025, “Decommissioning Pre-planning Manual,” and

EPRI TR 1003010, “Decommissioning Planning - Experiences from US Utilities.”

� Approach: Identify key decisions and tasks, establish ordered relationships and dependencies, identify key disciplines for support.

� 65 decommissioning planning activities are consolidated into 32 pre-planning tasks or “Decommissioning Task Outlines” (DTO’s).

� DTO’s do not replace NRC requirements. Rather, they provide valuable industry OE for planning decommissioning activities. Most DTO’s reference the applicable regulatory requirements and guidance.

� DTO’s are assigned organizationally (i.e. engineering, licensing, finance, QA, training, protection services) and sequenced into a roadmap for decommissioning planning.

� Benchmarking conducted with Zion, Millstone 1, and Big Rock Point.

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Priority Items

� Submit cessation letters. Prepare for plant shutdown and defuel. � Prepare and submit PDSAR (DTO-10).

� Prepare decommissioning schedule (DTO-2) � Update decommissioning and fuel management cost studies (DTO-1)

� Submit exemption letters (DTO-7). � Address staffing and organization issues (DTO-5). � Address spent fuel storage (DTO-11). � Prepare revised accident analysis (DTO-12). � Prepare systems identification and reclassification (DTO-22). � Prepare and submit defuel Technical Specifications (DTO-13). � Prepare USAR (DTO-20). � Identify and implement program changes (DTO-23). � Plan disposal of low level liquid, solid, and mixed rad. waste (DTO-31). 17

DTO-1 :Cost Estimate and Funding Assurance

� Demonstrate the adequacy of decommissioning funding based on site specific cost estimate.

� Activities: � Decommissioning Cost Estimate � Spent Fuel Management Costs � Funding Assurance � Tax Status Modification

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DTO-2: Summary Level Schedule

� Prepare summary level schedule of task necessary for decommissioning.

� Tasks for key decision making, process, plans and program revisions.

� Several schedules developed including � DTO schedule. � Long-term decommissioning schedules.

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DTO-3: Management Issues

� Management guidance for development of strategies for transitioning organization and culture from power to decommissioning operations.

� Activities: � Management Structure � Decommissioning Oversight � Cultural Transition � Decommissioning Performance Indicators

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DTO-4: Pre-Shutdown Recommended Practices

� Facilitate decommissioning through initiation of good practices essential to efficient decommissioning project.

� Maintain internal/external stakeholder relationships.

� Establish employee retention plan. � Establish/maintain knowledge base for efficient

decontamination of SSCs. � Lay foundations for characterization of site, LLW,

mixed waste, spills, fuel integrity.

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DTO-5: Organization and Staffing Plan

� Prepare decommissioning organization and staffing necessary for decommissioning operations.

� Activities: � Decommissioning organization and staffing. � Employee retention and release policies.

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DTO-6: Community Relations and Stakeholder Communications

� Establish appropriate structure to assure effective communication with key public stakeholders during pre-planning and execution of decommissioning activities.

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DTO-7: Certifications, Exemption Requests and Fee Relief Identify and submit decommissioning related

regulatory submittals. � Certification of Cessation of Operations and

Defuel. � Exemption Requests

– 50.82(a)(8): Use decommissioning funds for spent fuel management.

� Relief from operational fees, insurance and financial protection requirements.

� CLB, DB, accident analysis revisions.

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DTO-8: Exposure Estimate

� Identify issues that influence integrated dose and assure expected dose bounded by GEIS and SEIS. (Input to PSDAR)

� No issues of special interest identified at this point.

� Consideration of chemical decontamination of primary system. (KPS has determined not required).

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DTO-9: Environmental Assessment

� Identify activities required to demonstrate decommissioning activities are enveloped by GEIS and SEIS.

� Radiological and non-radiological environmental impacts considered. Categories taken from GEIS.

� Using NUREG 0586, Supplement 1 and KPS License Renewal SEIS for reviews.

� Input to PSDAR.

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DTO-10: PSDAR

� PSDAR Preparation and Submittal � General overview of proposed decommissioning

activities (including Spent Fuel Management) � Introduction � Description of Activities � Schedule of Activities � Cost Estimates � Environmental Impacts � Detailed site specific cost study attached

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DTO-11: Spent Fuel Storage

� Spent fuel storage strategy.

� Spent fuel island studies.

� Planned modifications.

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DTO-12: Accident Analysis & Spent Fuel Heat-up Calculation

� Develop new accident analyses applicable to decommissioning and fuel storage activities.

� Accident analysis revisions support revisions to the E-plan, drills, and safety system de-classification and insurance premiums.

� Heat-up calculations support spent fuel pool isolation strategy.

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DTO-13: Defueled Technical Specifications

� Submit license amendment to modify OL and TS to reflect permanently defueled plant. � Modify Operating License. � TS/LCO significantly reduced. � TS Section 5 programs: Some eliminated,

some modified. � TRM changes processed in parallel.

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DTO-14: Occupational Safety

� Identify and process changes to the Occupational Safety program to reflect broadened and different types of work activities associated with decommissioning.

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DTO-15: Vendor Assessment and Selection Recommendations

� Address activities necessary to competitively bid selected decommissioning work that is beyond the capability of current workforce.

� Determine “best value” methods and contract as appropriate.

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DTO-16: Project Controls

� Develop Guidance on project control functions, directed at planning, monitoring, and controlling decommissioning.

� Transition from operations-based to project-based cost management structure.

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DTO-17: Historical Site Assessment

� Collect existing information concerning site and its surroundings. Identify potential areas where contamination may exist.

� Permits efficient planning for scoping surveys, remediation, site characterization, and final status survey.

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DTO-18: Site Characterization

� Collect data concerning site and surroundings to permit efficient planning for remediation.

� Data also used for final status survey for license termination and for compliance with hazardous material regulations.

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DTO-19: Federal/State/Local Regulatory Compliance

� Identify specific compliance issues associated with Federal State and local requirements pertinent to facility decommissioning activities. � Federal and local permits. � State compliance. � Occupational safety requirements (DTO-14). � Transportation of large components over local

routes.

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DTO-20: USAR Update Plan

� USAR Update Plan � Revise Accident analyses. � Assess applicability of regulatory requirements. � Identify SSC’s and programs necessary for spent

fuel storage. SSC and programs required to effect decommissioning

� Process changes under 50.59 and 50.82(a)(6)

� Submit in 2014.

� Re-submit every 2 years.

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DTO-21: License Termination Plan

� Develop final plan and outline the considerations important to eventual submittal of request for termination of license.

� LTP for KPS not to be submitted for many years.

� LTP required to be submitted 2 years prior to license termination date.

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DTO-22: Systems Identification and Reclassification

� Identify SSC necessary to support decommissioning and fuel management plans.

� Develop method for reclassifying SSC’s based on decommissioning function. � Identification of support systems. � Systems reclassification. � Procedure revisions related to declassification.

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DTO-23: Programmatic Revisions

� Identify and change programs and procedures that will require modification. Early focus on:

� Withdraw licensing submittals supporting operations. � Commitment Review. � E-Plan, QA, Security, Fire Protection Program Plans. � Fuel Handler Training program. � Station blackout program. � Maintenance Rule program. � FFD program. � Safety Review (50.59) program. � Engineering Support Personnel Training program.

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DTO-24: QA Program Plan

� Reduce costs associated with application of existing QA program. Scope reduced through: � Reclassify systems. � Revisions to licensing basis and design basis. � Revised accident analyses.

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DTO-25: Work Processes and Procedure Reviews

� Change and reduce work processes and procedures to reflect fundamental changes in focus from operating plant to decommission status. � Procedure Review Plan. � Work Process Simplification.

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DTO-26: Systems and Structures Decontamination � Describe the issues and choices associated with

planning for decontamination of SSC’s prior to dismantlement.

� Pre-planning facilitates use of optimal techniques. � Objective to minimize exposure, rad. waste, and costs. � Categories to consider:

– Chemical Decontamination – Structural Material Removal – Surface Cleaning – Specialized Decontamination Facilities – Volume Reduction – Incineration – Metal Melting

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DTO-27: RPV and Large Component Removal & Shipping

� Develop strategies and options for the removal and disposal of large components: RPV, Internals, SG’s, Pzr., and Transformers. � Segmentation or intact removal � Transportation options � GTCC material; storage and disposal options

� Advance planning develops removal/disposal options and improves accuracy of cost estimates

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DTO-28: Deconstruction Power Supply

� Manage site electrical supply during decommissioning such that it supports: � Decommissioning activities as scheduled. � Isolation of spent fuel pool. � Dismantlement. � Other site SSC’s as needed to support

activities.

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DTO-29: Area Based Work Plan and Integrated Schedule

� Outline factors considered important in the development of decommissioning and incorporate into integrated schedule. � Integrated schedule. � Area based work plan. � Feeds into staffing plan.

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DTO-30: Dismantlement Major Task Sequence

� Identify the impacts, assumptions, and preliminary sequence for major decontamination and dismantlement activities. (Subset of DTO-2)

� Key Inputs: � Identification of work areas. � Ability to process and dispose of rad. wastes. � Consider impact of SF storage options. � Consider large component removal strategies and

appropriate decontamination of SSC’s for ALARA.

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DTO-31: LLW Liquids, Solids and Mixed Rad. Waste � Pre-plan activities necessary to dispose of low

level liquid, solid, and mixed rad. waste. � Develop knowledge of regulations. � Maintain cognizance of projected costs and

availability of sites. � Estimate quantities and identities. � Identify legacy waste. � Develop special considerations for large volumes

of LLRW.� Review rad. protection procedures for

enhancements.

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DTO-32: Hazardous Waste Disposal

� Pre-plan activities to dispose of hazardous wastes. � Assures that plant remains in compliance with

regulations for use and handling of non-rad. hazardous wastes (paint, asbestos, PCBs, etc).

� Minimizes use of substances requiring special disposal.

� Plan for removal and disposal of such substances.

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