ML13113A368

License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License

ML13113A368
Person / Time
Site:	Kewaunee
Issue date:	04/16/2013
From:	Grecheck E Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-177
Download: ML13113A368 (17)

Text

Dominion Energy Kewawnee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Dominionf Web Address: www.dom.com April 16, 2013 U. S. Nuclear Regulatory Commission Serial No.13-177 Attention: Document Control Desk LIC/CDS/RO Washington, DC 20555 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST 255: DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE 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 (KPS).

The proposed amendment would revise the Renewed Facility Operating License by deleting a license condition associated with license renewal.

On February 25, 2013, DEK submitted a certification to the NRC indicating its intention to permanently cease power operations at KPS (Reference 1) pursuant to 10 CFR 50.82(a)(1)(i).

The certification states that DEK has decided to permanently cease power operation of KPS on May 7, 2013. On February 26, 2013, DEK submitted both a Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 2), and an updated Irradiated Fuel Management Plan (Reference 3). After fuel is removed from the reactor vessel and DEK dockets a certification of permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii), the 10 CFR Part 50 license for KPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). As a result, DEK plans to propose revisions to the KPS license and associated Technical Specifications (TS) to comport to the permanently shutdown and defueled condition of the facility in accordance with 10 CFR 50.36(c)(6).

However, DEK is submitting this license amendment request in advance of the planned license and TS revisions discussed above.

This license amendment request would delete KPS Renewed Facility Operating License Condition 2.C.(15), "License Renewal License Conditions."

Because DEK will permanently cease operation of KPS prior to the start of the period of extended operation of the renewed facility operating license, the requirements of License Condition 2.C.(15) are no longer relevant. If not deleted, this license condition will remain applicable after the reactor is permanently defueled, and could be construed to require performance of certain activities that are not necessary for safe storage and management of irradiated fuel onsite. Deletion of this license condition will allow for elimination of activities that are not necessary for the safe storage and management of

'A'I?

Serial No.13-177 License Amendment Request 255 Page 2 of 3 irradiated fuel and thereby allow DEK to dedicate the resources needed to perform these activities towards decommissioning activities. to this letter contains a description, technical analysis, significant hazards determination, and environmental considerations evaluation for the proposed amendment. Attachment 2 contains a marked-up Renewed Facility Operating License page.

The KPS Facility Safety Review Committee has reviewed the proposed amendment and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91(b).

Because the period of extended operation for KPS begins on December 22, 2013, DEK requests approval of this proposed amendment prior to that date to avoid any confusion regarding the applicability of this license condition to a permanently defueled plant.

Once approved, the amendment will be implemented within 30 days.

Please contact Mr. Craig Sly at 804-273-2784 if you have any questions or require additional information.

Sincerely, Eugene S. Grecheck Vice President - Nuclear Engineering and Development VICKI L. HULL Notary Public Commonwealth of Virginia

]

~140542r COMMONWEALTH OF VIRGINIA

)

My Commission Expires May 31, 2014 COUNTY OF HENRICO

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, 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 that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this

& -day of t 2013.

My Commission Expires:

3 m?

2

//..,

Notary 15ubli6

Serial No.13-177 License Amendment Request 255 Page 3 of 3 Attachments:

1. Discussion of Change, Technical Analysis, Significant Hazards Determination and Environmental Considerations

2. Marked-up Renewed Facility Operating License Page

References:

1. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Cessation of Power Operations," dated February 25, 2013 (ADAMS Accession No. ML13058A065).

2. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Post-Shutdown Decommissioning Activities Report," dated February 26, 2013 (ADAMS Accession No. ML13063A248).

3. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Update to Irradiated Fuel Management Plan Pursuant to 10 CFR 50.54(bb)," dated February 26, 2013 (ADAMS Accession No. ML13059A028).

cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No.13-177 ATTACHMENT 1 LICENSE AMENDMENT REQUEST 255:

DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE DISCUSSION OF CHANGE, TECHNICAL ANALYSIS, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.13-177 Page 1 of 11 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE DISCUSSION OF CHANGE, TECHNICAL ANALYSIS, SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS

1.0 DESCRIPTION

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 (KPS).

The proposed amendment would revise the Renewed Facility Operating License by deleting a license condition associated with license renewal.

On February 25, 2013, DEK submitted a certification to the NRC indicating its intention to permanently cease power operations at KPS (Reference 1) pursuant to 10 CFR 50.82(a)(1)(i).

The certification states that DEK has decided to permanently cease power operation of KPS on May 7, 2013. On February 26, 2013, DEK submitted both a Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 2), and an updated Irradiated Fuel Management Plan (Reference 3). After fuel is removed from the reactor vessel and DEK dockets a certification of permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii), the 10 CFR Part 50 license for KPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). As a result, DEK plans to propose revisions to the KPS license and associated Technical Specifications (TS) to comport to the permanently shutdown and defueled condition of the facility in accordance with 10 CFR 50.36(c)(6).

However, DEK is submitting this license amendment request in advance of the planned license and TS revisions discussed above. This license amendment request would delete KPS Renewed Facility Operating License Condition 2.C.(15), "License Renewal License Conditions."

Because DEK will permanently cease operation of KPS prior to the start of the period of extended operation of the renewed facility operating license, the requirements of License Condition 2.C.(15) are no longer relevant. If not deleted, this license condition will remain applicable after the reactor is permanently defueled, and could be construed to require performance of certain activities that are not necessary for safe storage and management of irradiated fuel onsite. Deletion of this license condition will allow for elimination of activities that are not necessary for the safe storage and management of irradiated fuel and thereby allow DEK to dedicate the resources needed to perform these activities towards decommissioning activities.

This proposed amendment is preconditioned on a timeline where the amendment receives NRC approval after DEK submits a certification of permanent removal of fuel

Serial No.13-177 Page 2 of 11 from the reactor vessel pursuant to 10 CFR 50.82(a)(1), at which time the 10 CFR Part 50 license for KPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. There are no existing license amendment requests currently docketed for KPS.

Therefore, no disposition of other license changes, as they relate to this license amendment request, is needed.

2.0 PROPOSED CHANGE

The proposed amendment would modify the KPS license by deleting License Condition 2.C.(15), License Renewal License Conditions.

License Condition 2.C.(15) 2.C.(15) License Renewal License Cenditiens (a) The UJSAR supplement, as, revised, submitted purculant to 10 CFR 54.21 (d), hl be included in the next scheduled update to the USAR required by 10 CFR 60.71(e)(4) following the issuance Of this renewed operating license.

Until that update is co*plete, the i*ensee may make changes, to the pro*grm*s and activities described in the supplement without priorComsso

approal, provided that the licensee evaluates such changes pursuant to the criteria set forth *in 10 CFR 50.59 and otheie comples With the reurmnts in that (b) The USAR supplement, as revised, desc-ribes c~ertafin; future activities tob completed prior to and/or during the period of ekdend-ed-operation. The Iliensee shall complete these ac-tivities6 in accor~dance with Appendix A of NUREG 1958, "Safety Eivaluation Report Related to the Kewaunee Powe~r Station," dated janua~y 2011. The iGensee shall notify the NRC in winghen activities to be completed prior to th proofeendoperation are comnplete and can be verified by NRC inspection (r.)

All capsules in the reac~tor vessel that are removed and-tested-Must mqeet the tcs procedures and reporting requirements of Ameirican Society for Testing and Materials (AST-M) E= 1 85 82-to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule Withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation.

All capsules placed in storage must be mainRtained for: future nerin Any changes to storage requirements must be approved by the NRC.

The revised section will read as follows.

2.C.(15) Deleted.

Serial No.13-177 Page 3 of 11

3.0 TECHNICAL ANALYSIS

3.1 General Analysis Applicable to Proposed Change Section 14 of the KPS Updated Safety Analysis Report (USAR) describes the design basis accident (DBA) scenarios that are applicable to KPS during power operations.

During normal power operations, the forced flow of water through the reactor coolant system (RCS) removes the heat generated by the reactor core. The RCS, operating at high temperatures and pressures, transfers this heat through the steam generator tubes to the secondary system. The most severe postulated -accidents for nuclear power plants involve damage to the nuclear reactor core and the release of large quantities of fission products to the reactor coolant system. Many of the USAR accident scenarios involve failures or malfunctions of systems which could affect the reactor core.

DEK plans to decommission KPS using a SAFSTOR method in which most fluid systems are drained and the plant is left in a stable condition until final decontamination and dismantlement activities begin. The irradiated fuel will be stored in the spent fuel pool (SFP) and in the Independent Spent Fuel Storage Installation (ISFSI) until it is shipped off site sometime in the future. After the reactor is permanently defueled, the SFP and its supporting systems will be isolated and dedicated only to spent fuel storage. After the reactor is defueled, the reactor, RCS and secondary system will no longer be in operation and will have no function related to the safe storage and management of irradiated fuel.

After docketing the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a)(1), 10 CFR 50.82(a)(2) states that the 10 CFR 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. After the termination of reactor operations at KPS and the permanent removal of the fuel from the reactor vessel, the postulated accidents involving failure or malfunction of the reactor, RCS or secondary system are no longer applicable.

The postulated accident that remains applicable to KPS in the permanently shut down and defueled condition is a fuel handling accident (FHA) in the auxiliary building, where the SFP is located.

The definition of safety-related structures, systems, and components (SSCs) in 10 CFR 50.2 states that safety-related SSCs are those relied on to remain functional during and following design basis events to assure:

(1)

The integrity of the reactor coolant boundary; (2)

The capability to shutdown the reactor and maintain it in a safe shutdown condition; or (3)

The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.43(a)(1) or 100.11.

Serial No.13-177 Page 4 of 11 The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled condition. The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits.

However, after the termination of reactor operations at KPS and the permanent removal of the fuel from the reactor vessel, the only applicable postulated accident is a fuel handling accident (FHA) in the auxiliary building. The FHA analysis being developed for KPS is expected to show that, following 90 days of decay time after reactor shutdown, the dose consequences (provided the spent fuel pool water level requirements of TS 3.7.13 are met1) are acceptable without relying on any SSCs to remain functional during and following the event. Therefore, following 90 days of decay time after shutdown, there will no longer be any SSCs that are required to be classified as safety-related (with the exception of the passive spent fuel pool structure).

3.2 Specific Justification for Proposed Change License Condition 2.C.(15), "License Renewal License Conditions," was issued concurrent with the Renewed Facility Operating License on February 24, 2011.

This license condition (consisting of three parts) is described in Section 1.7, "Summary of Proposed License Conditions," of the Safety Evaluation Report (SER) for KPS dated November 4, 2010 (Reference 4). The KPS license renewal SER was subsequently published as NUREG-1958, "Safety Evaluation Report Related to the License Renewal of the Kewaunee Power Station," issued January 2011.

License Condition 2.C.(15) is proposed for deletion in its entirety.

The period of extended operation for KPS begins on December 22, 2013.

KPS is permanently ceasing operation and will permanently defuel the reactor vessel prior to the start of the period of extended operation.

After the reactor is defueled, 10 CFR 50.82(a)(2) will prohibit operation of the KPS reactor, or emplacement or retention of fuel into the reactor vessel. Therefore, KPS will not operate during the period of extended operation and none of the activities that are unique to the renewed license are needed.

Decommissioning of KPS is not dependent on the requirements of 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," for a renewed license.

License Condition 2.C.(15)(a) is a one-time requirement to update the USAR to include the USAR supplement required by 10 CFR 54.21(d) in the next USAR update as required by 10 CFR 50.71(e). This is duplicative of the existing requirements in 10 CFR 54.21(d) and 10 CFR 50.71(e)(4).

Since the USAR update required by this License Condition has been previously completed, this license condition has been satisfied and is therefore no longer needed. License Condition 2.C.(15)(a) also states that DEK may make changes to the programs and activities described in the supplement without prior 1 KPS TS 3.7.13 requires the spent fuel pool water level to be > 23 feet above the top of irradiated fuel assemblies seated in the storage racks. TS 3.7.13 is applicable during movement of irradiated fuel assemblies in the spent fuel pool.

Serial No.13-177 Page 5 of 11 NRC approval provided that the changes are made pursuant to 10 CFR 50.59 requirements.

The requirements of 10 CFR 50.59 will continue to apply to such changes after the license condition is deleted. Therefore, after deletion of this license condition, changes to these programs and activities may be made without prior Commission approval provided that DEK evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59.

License Condition 2.C.(15)(b) pertains to completion of activities described in Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station,"

dated January 2011.

The license condition states that DEK shall notify NRC when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection. Since KPS is permanently ceasing operation and defueling the reactor prior to the period of extended operation, these activities are no longer needed. DEK is not aware of the existence of such a license condition in the license of any other U.S. nuclear facility that has permanently ceased operation in accordance with 10 CFR 50.82. The provisions of 10 CFR 54.35, "Requirements during term of renewed license," ensure that all applicable Commission regulations remain in force during the extended period of the renewed license. These regulations provide sufficient requirements for ensuring the safe storage and management of irradiated fuel at a permanently defueled facility. After deletion of this license condition, changes to these activities may be made without prior Commission approval provided that DEK evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59.

The capsules referred to in License Condition 2.C.(15)(c) are not required to confirm continued safe conditions for a permanently defueled facility.

As such, this License Condition is also no longer needed.

Upon expiration of the renewed facility operating license on December 21, 2033, activities required for the safe storage and management of irradiated fuel and decommissioning of KPS will continue to be governed in accordance with 10 CFR 50.51, "Continuation of license." 10 CFR 50.51 directs that each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated.

4.0

SUMMARY

KPS will permanently cease operation and remove fuel from the reactor vessel prior to the start of the period of extended operation of the renewed facility operating license.

KPS has not operated, and will not be operated during the period of extended operation for which License Condition 2.C.(1 5) was meant to apply.

Safe storage and management of irradiated fuel at other U.S. nuclear facilities licensed under 10 CFR 50, that have permanently ceased operation in accordance with 10 CFR

Serial No.13-177 Page 6 of 11 50.82, does not rely on the programs and activities associated with 10 CFR 54. As such, the requirements specified in License Condition 2.C.(15) are not needed for assuring safe onsite storage of irradiated fuel at KPS and may be deleted.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) is requesting an amendment to Renewed Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS).

The proposed amendment would revise the KPS Renewed Facility Operating License by deleting a license condition associated with license renewal.

On February 25, 2013, DEK submitted a certification to the NRC indicating its intention to permanently cease power operations at KPS (Reference 1) pursuant to 10 CFR 50.82(a)(1)(i).

The certification states that DEK has decided to permanently cease power operation of KPS on May 7, 2013. On February 26, 2013, DEK submitted both a Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 2), and an updated Irradiated Fuel Management Plan (Reference 3). After fuel is removed from the reactor vessel and DEK dockets a certification of permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii), the 10 CFR Part 50 license for KPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). As a result, DEK plans to propose revisions to the KPS license and associated Technical Specifications (TS) to comport to the permanently shutdown and defueled condition of the facility in accordance with 10 CFR 50.36(c)(6).

However, DEK is submitting this license amendment request in advance of the planned license and TS revisions discussed above.

This license amendment request would delete KPS Renewed Facility Operating License Condition 2.C.(15), "License Renewal License Conditions."

Because DEK will permanently cease operation of KPS prior to the start of the period of extended operation of the renewed facility operating license, the requirements of License Condition 2.C.(15) are no longer relevant. If not deleted, this license condition will remain applicable after the reactor is permanently defueled, and could be construed to require performance of certain activities that are not necessary for safe storage and management of irradiated fuel onsite. Deletion of this license condition will allow for elimination of activities that are not necessary for the safe storage and management of irradiated fuel and thereby allow DEK to dedicate the resources needed to perform these activities towards decommissioning activities.

Serial No.13-177 Page 7 of 11 DEK has evaluated the proposed amendment to determine if a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment would modify the KPS renewed facility operating license by deleting a license condition that pertains to plant operation during the period of extended operation.

KPS is permanently ceasing operation and will permanently defuel the reactor vessel prior to the start of the period of extended operation.

Therefore, the probability of occurrence of previously evaluated accidents is not affected, since the original license did not contain this license condition. The license condition being deleted pertains to operation beyond the term of the original license. Additionally, the occurrence of postulated accidents associated with reactor operation is no longer credible in a permanently defueled reactor.

Since KPS is permanently ceasing operation, the generation of fission products will cease and the remaining source term will decay. This significantly reduces the consequences of the remaining applicable postulated accident.

Therefore, the proposed amendment does not involve a significant increase in the consequences of a previously evaluated accident.

2.

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

Response: No The activities and programs that were the subject of this license condition were intended to ensure that systems, structures, and components (SSCs) continue to respond properly in the event of a previously analyzed accident during the period of extended operation of the renewed facility operating license.

However, the reactor will not operate during the period of extended operation.

The proposed amendment does not involve a physical alteration of the plant. No new or different types of equipment will be installed and there are no physical modifications to existing equipment associated with the proposed amendment.

Similarly, the proposed amendment would not physically change any SSCs involved in the mitigation of any postulated accidents. Thus, no new initiators or precursors of a new or different kind of accident are created.

Furthermore, the proposed amendment does not create the possibility of a new failure mode associated with any equipment or personnel failures.

Serial No.13-177 Page 8 of 11 Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No Because the 10 CFR Part 50 license for KPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2), the occurrence of postulated accidents associated with reactor operation is no longer credible. The remaining credible accident (90 days after shutdown) is a fuel handling accident (FHA) in the auxiliary building.

The proposed amendment does not affect the inputs or assumptions of any of the design basis analyses that impact a FHA in the auxiliary building and the current design limits continue to be met for the accident of concern.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, Dominion Energy Kewaunee, Inc. concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria Pursuant to the Atomic Energy Act of 1954, as amended, and NRC regulations, operating licenses for commercial power reactors are issued for 40 years. These licenses can be renewed for up to 20 additional years. The original 40-year license term was selected on the basis of economic and antitrust considerations, rather than on technical limitations. However, some individual plant and equipment designs may have been engineered based on an expected 40-year service life.

10 CFR 54 describes the requirements for renewal of operating licenses for nuclear power plants.

Pursuant to 10 CFR 54.21, "Contents of Application - Technical Information," the NRC requires that the license renewal application contain, inter alia, a USAR supplement. 10 CFR 54.21(d) requires that the USAR supplement must have a summary description of the applicant's programs and activities for managing aging effects and the evaluation of time-limited aging analyses for the period of extended operation.

10 CFR 54.33, "Continuation of CLB and conditions of renewed license," states that each renewed license will contain such conditions and limitations, including technical

Serial No.13-177 Page 9 of 11 specifications, as the Commission deems appropriate and necessary to help ensure that systems, structures, and components subject to review in accordance with 10 CFR 54.21 will continue to perform their intended functions for the period of extended operation; and that the renewed license include those conditions to protect the environment that were imposed pursuant to 10 CFR 50.36b and that are part of the current licensing basis (CLB) for the facility at the time of issuance of the renewed license.

10 CFR 54.35, "Requirements during term of renewed license," states that during the term of a renewed license, licensees shall be subject to and shall continue to comply with all Commission regulations contained in 10 CFR parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 52, 54, 55, 70, 72, 73, and 100, and the appendices to these parts that are applicable to holders of operating licenses.

As stated in Section 1.2.1, "Safety Review," of the Safety Evaluation Report for KPS dated November 4, 2010 (Reference 4), license renewal requirements for power reactors are based on two key principles:

(1) The regulatory process is adequate to ensure that the licensing bases of all currently operating plants maintain an acceptable level of safety, with the possible exception of the detrimental aging effects on the function of certain SSCs, as well as a few other safety-related issues, during the period of extended operation.

(2)

The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.

In implementing these two principles, 10 CFR 54.4 defines the scope of license renewal as including SSCs: (1) that are safety-related, (2) whose failure could affect safety-related functions, and (3) that are relied on to demonstrate compliance with NRC regulations for fire protection, environmental qualification (EQ), pressurized thermal shock (PTS), anticipated transient without scram (ATWS), and station blackout (SBO).

5.3 Precedent This proposed amendment would align the KPS license with the existing license currently in effect for Millstone Nuclear Power Station (DPR-21), which was last substantively revised on March 31, 2001 (Reference 5).

The Millstone license amendment that was issued to reflect the permanently shutdown status of the plant on November 9, 1999 (Reference 6), did not include a license condition analogous to KPS License Condition 2.C.(15). The Millstone license was initially issued October 7, 1970, and transferred to Dominion Nuclear Connecticut, Inc. on March 31, 2001.

Millstone has been licensed in excess of 40 years withoutfneed for a license condition similar to KPS License Condition 2.C.(15).

Serial No.13-177 Page 10 of 11 This proposed amendment would also align the KPS license with the license issued to Zion Nuclear Power Station on December 30, 1999 (Reference 7), which was issued to reflect the permanently shutdown status of the plant. The Zion license, which expires November 14, 2013, was originally issued prior to the original KPS operating license.

Therefore, after November 14, 2013, Zion will have been licensed in excess of 40 years without need for a license condition similar to KPS License Condition 2.C.(15).

5.4 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.13-177 Page 11 of 11

7.0 REFERENCES

1. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Cessation of Power Operations," dated February 25, 2013 (ADAMS Accession No. ML13058A065).

2. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Post-Shutdown Decommissioning Activities Report," dated February 26, 2013 (ADAMS Accession No. ML13063A248).

3. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Update to Irradiated Fuel Management Plan Pursuant to 10 CFR 50.54(bb)," dated February 26, 2013 (ADAMS Accession No. ML13059A028).

4. NRC Safety Evaluation Report Related to the License Renewal of Kewaunee Power Station (TAC No. MD9408), dated November 4, 2010 (ADAMS Accession No. ML103000131).

5. Millstone Nuclear Power Station, Unit 1, Amendment No.109, License No. DPR-21, Date of Issuance March 31, 2001 (ADAMS Accession No. ML010920303).

6. NRC Safety Evaluation for Millstone Power Station Unit 1 in License Amendment 106 to DPR-21, dated November 9, 1999 (ADAMS Accession Nos. ML993330283 and ML993330269).

7. NRC Safety Evaluation for Zion Nuclear Station in License Amendments 180 and 167 (for Units 1 and 2 respectively (License Nos. DPR-39 and DPR-48)), dated December 30, 1999 (ADAMS Accession Nos. ML003672704 and ML003672696).

Serial No.13-177 ATTACHMENT 2 LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE MARKED-UP RENEWED FACILITY OPERATING LICENSE PAGE KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

• • (13)

Removed Details and Requirements Relocated to Other Controlled Documents License Amendment No. 207 authorizes the relocation of certain technical specifications and operating license conditions, if applicable, to other licensee-controlled documents. Implementation of that amendment shall include relocation of these requirements to the specified documents.

(14)

Deferral of Certain Technical Specification Requirements Following implementation of License Amendment No. 207, the requirement for the reactor coolant system (RCS) Hot Leg A Temperature Indication to be OPERABLE as required by technical specification (TS) 3.3.3 and TS 3.3.4 may be deferred until startup after the first outage of sufficient duration to repair the RCS Hot Leg A Temperature Indication. Specifically, TS Table 3.3.3-1, Function 3 will only require 1 channel to be OPERABLE, and TS Table B 3.3.4-1, Function 4.a will not be applicable. Following the startup after the first outage of sufficient duration to repair the RCS Hot Leg A Temperature Indication, TS Table 3.3.3-1 Function 3 and TS Table B 3.3.4-1, Function 4.a requirements will be applicable.

(15)

Deleted Renewed Operating License DPR-43