ML13254A186

Response to Request for Additional Information Regarding License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License

ML13254A186
Person / Time
Site:	Kewaunee
Issue date:	09/05/2013
From:	Grecheck E Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13254A186 (29)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Web Address: www.dom.com September 5, 2013 U. S. Nuclear Regulatory Commission Serial No. 13-177A 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 255: DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE By application dated April 16, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS).

The proposed amendment would revise the KPS Renewed Facility Operating License by deleting License Condition 2.C.(15), "License Renewal License Conditions."

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 2). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.

Although this NRC RAI is specific to DEK's letter dated April 16, 2013, the same information is needed to address an identical licensing action contained in DEK's letter dated May 29, 2013 (as explained therein), which requests an amendment to change the KPS license and technical specifications to reflect the permanently defueled status of the KPS facility (Reference 3). Therefore, this response is applicable to and addresses both licensing actions. This response has no impact on any other aspect of these KPS License Amendment Requests.

Because the period of extended operation for KPS begins on December 22, 2013, DEK reiterates its request for approval of this proposed amendment prior to that date to avoid any confusion regarding the applicability of License Condition 2.C.(15) to a permanently shutdown and defueled plant. Once approved, the amendment will be implemented within 30 days.

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Serial No. 13-177A License Amendment Request 255 Page 2 of 3 Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Eugene S. Grecheck Vice President - Nuclear Engineering and Development COMMONWEALTH OF VIRGINIA

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COUNTY OF HENRICO

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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 &Ae.,w

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My Commission Expires: "De.vAa. 4-1, 0ol Notary Public Attachents:RAIG D SLY Attachments:

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References:

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License," dated April 16, 2013 (ADAMS Accession No. ML13113A368).

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala, Craig Sly, et al (DEK),

"MF1771 (and part of MF1952) - Kewaunee Power Station - Request for Additional Information (RAI) Re:

Deletion of License Condition 2.C.(15)," dated June 24, 2013.

3. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated May 29, 2013 (ADAMS Accession No. ML13156A037).

Serial No. 13-177A License Amendment Request 255 Page 3 of 3 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. 13-177A ATTACHMENT I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-177A Page 1 of 25 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 255 DELETION OF LICENSE RENEWAL CONDITION FOR PERMANENTLY DEFUELED LICENSE By application dated April 16, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested 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 License Condition 2.C.(15), "License Renewal License Conditions."

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 2).

The RAI questions and associated DEK responses are provided below.

Although this NRC RAI is specific to DEK's letter dated April 16, 2013, the same information is needed to address an identical licensing action contained in DEK's letter dated May 29, 2013, which requests an amendment to change the KPS license and Technical Specifications to reflect the permanently defueled status of the KPS facility (Reference 3). Therefore, this response is applicable to and addresses both licensing actions.

NRC Question Renewed Facility Operating License Condition 2.C.(15)(b) states, The USAR supplement, as revised, describes certain future activities to be completed prior to and/or during the period of extended operation. The licensee shall complete these activities in accordance with Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," dated January 2011. The licensee shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.

The license condition above requires specific actions to be accomplished by the licensee. The first action requires the completion of the activities listed in Appendix A of NUREG-1958. The second action requires notifying the NRC when the activities to be completed before the PEO [Period of Extended Operation] are complete and can be verified by inspection.

The licensee's April 16 submittal states that Renewed Facility Operating License Condition 2.C.(15)(b) is no longer relevant because the nuclear power plants that have been decommissioned in the U.S. do not contain license renewal conditions in the

Serial No. 13-177A Page 2 of 25 decommissioning license. However, the licensee does not provide a substantive basis for removing the condition. Specifically, the licensee does not explain why each of the commitments from Appendix A of NUREG-1958 do not need to be completed.

Please provide the basis for not completing each of those commitments listed in Appendix A of NUREG-1958.

Response

The purpose of DEK's request to remove Renewed Facility Operating License Condition 2.C.(15)(b) is to allow those activities (commitments) documented in NUREG-1958, Appendix A to be changed as needed to reflect the permanently defueled condition of the facility using the change process defined in 10 CFR 50.59 (or other applicable regulation).

DEK has satisfied Renewed Facility Operating License Condition 2.C.(15)(a), which requires that the USAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), shall be included in the next scheduled update to the USAR required by 10 CFR 50.71(e)(4) following the issuance of this renewed operating license. The KPS USAR has been updated to include a new Chapter 15, "Programs and Activities that Manage the Effects of Agfing."

Specifically, USAR Section 15.7, "License Renewal Commitments," contains the commitments from NUREG-1958, Appendix A.

The revised USAR was subsequently transmitted to the NRC as required by 10 CFR 50.71(e).

These actions have already satisfied the requirements of KPS Renewed Facility Operating License Condition 2.C.(15)(a).

Specifically, DEK is requesting removal of License Condition 2.C.(15)(b) to allow changes to the commitments in USAR Section 15.7 to be made in accordance with 10 CFR 50.59 (or other applicable regulation).

Use of 10 CFR 50.59 to change these commitments is appropriate considering; 1) the permanent defueled and shutdown status of the facility; 2) the commitments listed in NUREG-1958, Appendix A have been incorporated into the KPS USAR, and; 3) the appropriate process for changing the USAR is provided in 10 CFR 50.59.

Managing changes to these license renewal commitments in accordance with 10 CFR 50.59 (or other applicable regulation) is consistent with other renewed operating licenses and with License Condition 2.C.(15)(a), which intended to allow use of 10 CFR 50.59 for making such changes.

Commitments Do Not Warrant Inclusion in the Technical Specifications Managing the commitments listed in NUREG-1958, Appendix A by incorporating them into the USAR and changing them in accordance with 10 CFR 50.59 (or other applicable regulation) is consistent with the requirements of 10 CFR 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" (License Renewal Rule).

10 CFR 54.21(d) requires that the FSAR supplement must contain a summary

Serial No. 13-177A Page 3 of 25 description of the programs and activities for managing the effects of aging.

When promulgating the current license renewal rules, the NRC explained that, "The regulatory process will continue to ensure that proposed changes to programs and activities that may affect descriptions in the FSAR will receive adequate review by the licensee and, if appropriate, by the NRC." (60 FR 22483, published May 8, 1995).

Changes to the USAR are controlled under 10 CFR 50.59. 10 CFR 50.59 requires licensees to obtain a license amendment under 10 CFR 50.90 if the proposed change meets any of the criteria of 10 CFR 50.59(c)(2). Additionally, changes to procedures and programs that implement license renewal commitments are controlled by 10 CFR 50, Appendix B (as applicable). These regulatory controls ensure a documented basis for licensee initiated changes to the licensing basis, and that NRC review and approval is obtained prior to implementation if the change meets any of the criteria in 10 CFR 50.59(c)(2) or involves a change to the technical specifications.

The USAR is periodically updated to reflect such changes under the provisions of 10 CFR 50.71(e),

and an annual summary of the 50.59 evaluations and commitment changes are submitted to NRC for information.

In a memorandum titled "Assessment of Regulatory Processes that Utilize Regulatory Commitments," dated November 26, 2008, the Office of Nuclear Reactor Regulation, Division of Operating Reactors, provided an assessment of the regulatory processes that utilize regulatory commitments.

The assessment was intended to determine whether the use of commitments in licensing activities should be reduced, or eliminated and replaced with enforceable requirements, such as license conditions.

The assessment stated:

Consistent with the guidance in SECY-98-224, "Staff and Industry Activities Pertaining to the Management of Commitments Made by Power Reactor Licensees to the NRC," and the definition of "obligation" in NRR Office Instruction LIC-100, "Control of Licensing Bases for Operating Reactors," escalating a licensee commitment into a legally binding regulatory requirement should be reserved for matters that warrant: (1) inclusion in the technical specifications based on the criteria in 10 CFR 50.36; or (2) inclusion in the license based on determination by the NRC staff that the issue is of high safety or regulatory significance.

The NUREG-1958, Appendix A list of commitments does not warrant inclusion in the technical specifications based on the criteria in 10 CFR 50.36 because the list of commitments was developed, reviewed, and approved under the License Renewal Rule.

10 CFR 54.22 requires that an application for license renewal include any technical specification changes or additions necessary to manage the effects of aging during the period of extended operation.

For KPS, no such technical specification changes or additions were necessary.

The NRC documented this in their Safety Evaluation Report (SER) associated with the license renewal of KPS (Reference 5).

The SER stated, "In LRA Appendix D, the applicant stated that it had not identified any TS changes necessary for issuance of the renewed KPS operating license.

This

Serial No. 13-177A Page 4 of 25 statement adequately addresses the 10 CFR 54.22 requirement." Additionally, none of the amendments or supplements to the KPS application for License Renewal identified a need to change the KPS TS as a result of new or revised license renewal commitments.

Likewise, inclusion of the NUREG-1958, Appendix A list of commitments in the KPS license is not warranted.

License renewal activities are not considered to be of such high safety or regulatory significance as to warrant elevation of commitments associated with license renewal activities as obligations.

This is based on the statements of consideration for the License Renewal Rule. In 56 FR 64943, published December 13, 1991, the NRC staff noted:

The first principle is that, with the exception of age-related degradation unique to license renewal and possibly some few other issues related to safety only during extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provide and maintain an acceptable level of safety for operation so that operation will not be inimical to public health and safety or common defense and security.

In sum, the Commission's regulatory processes provide reasonable assurance that the discipline of a formal license renewal review.., would not add significantly to safety or common defense and security and is not needed to ensure that continued operation during the renewal term is not inimical to the public health and safety or the common defense and security.

NRR Office Instruction LIC-105, Revision 4, "Managing Regulatory Commitments Made by Licensees to the NRC," states that, "Therefore, if the NRC staff needs to rely on a regulatory commitment in an SE, then the staff must escalate the commitment to an obligation, or incorporate it into a mandated licensing basis document." Accordingly, since the NRC staff relied on the license renewal commitments in the safety evaluation (Reference 5), the incorporation of the list of license renewal commitments into the USAR (a mandated licensing basis document) is an acceptable method for escalating commitments.

Disposition of License Renewal Commitments after Removal of License Condition 2.C.(15)(b)

The table below summarizes how DEK intends to disposition each of the commitments listed in NUREG-1 958, Appendix A after License Condition 2.C.(15)(b) is removed from the KPS license.

The disposition of each commitment falls into one or more of the categories listed below.

Rather than repeating the specific disposition for each applicable commitment line item, the corresponding numerical designator of the following disposition categories is listed in the table for each applicable commitment line item.

Serial No. 13-177A Page 5 of 25

1. The Commitment has been Completed Those commitments that have already been completed are identified as such. No additional actions are required (exceptions, if any, are identified in the table).

Continuation of the commitment, if applicable, is discussed in the table.

2. The Commitment is Associated with Structures, Systems, and Components (SSCs) that No Longer Fall into Scope of the License Renewal Rule The SSC reclassification project at KPS serves to assess the safety classification of SSCs and classify them as appropriate to reflect the permanently shutdown and defueled status of the facility.

Following docketing of the certifications required by 10 CFR 50.82(a)(1), KPS is no longer authorized to operate the reactor or place or retain fuel into the reactor vessel per 10 CFR 50.82(a)(2). As a result, most of the accident scenarios postulated in the USAR are no longer applicable or even possible at KPS. This changes the safety significance of most of the SSCs at KPS.

As described in Reference 3, revised radiological analyses have been developed that show that, 90 days after shutdown, the radiological consequences of design basis accidents are acceptable without relying on structures, systems, and components (SSCs) remaining functional for accident mitigation during and following the event (the one exception to this is the continued function of the passive spent fuel pool structure).

The scope of the License Renewal Rule, 10 CFR 54, is identified in Section 54.4.

(a) Plant systems, structures, and components within the scope of this part are -

(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions --

i. The integrity of the reactor coolant pressure boundary; ii. The capability to shut down the reactor and maintain it in a safe shutdown condition; or iii. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1), § 50.67(b)(2), or § 100.11 of this chapter, as applicable.

(2) All nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii) of this section.

(3) All systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the

Serial No. 13-177A Page 6 of 25 Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61),

anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).

Those SSCs at KPS whose classification has changed from safety-related to nonsafety-related would no longer fall under the scope of Part 54, as stated in 54.4(a)(1) and 54.4(a)(2); and therefore would not be subject to aging management review. This applies to nearly all SSCs at KPS, which is a permanently shutdown and defueled facility and not authorized to operate per 10 CFR 50.82(a)(2).

Certain regulations cited under 54.4(a)(3) do not apply to reactors that are permanently shutdown and defueled per 10 CFR 50.82(a)(2).

Regulatory Guide (RG) 1.184 provides a list of regulatory requirements that are eliminated, as they are no longer necessary to protect public health and safety at a facility not authorized to operate per 10 CFR 50.82(a)(2). This includes environmental qualification (10 CFR 50.49), fracture toughness requirements for protection against pressurized thermal shock events (10 CFR 50.61), and anticipated transient without scram (ATWS) requirements (10 CFR 50.62).

The requirements of the Station Blackout Rule (10 CFR 50.63) apply to "Each light-water-cooled nuclear power plant licensed to operate under this part" (as stated in 10 CFR 50.63(a)(1)).

10 CFR 50.82(a)(2) states that upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. As such, KPS is no longer a "light-water-cooled nuclear power plant licensed to operate under this part".

Consequently, the Station Blackout Rule (10 CFR 50.63) no longer applies to KPS.

Certain programs manage the aging of a broad spectrum of systems, including fire protection systems. These programs may be assigned a basis category of "2" (no longer in scope), even though the systems that support fire protection (and compliance with 10 CFR 50.48) will remain in service. In such cases, information on managing compliance with 10 CFR 50.48 is identified in the "Additional Information" column of the Table.

3. The SSC has been or will be Abandoned and Provides No Plant Support Function The associated SSC has been or will be permanently removed from service and no longer provides a required function. As such, the related commitments are no longer warranted.

In addition to the above three specific disposition categories that are individually attributed to a specific commitment line item, none of the commitment line items

Serial No. 13-177A Page 7 of 25 documented in Appendix A of NUREG-1958 meet the criteria for inclusion in the KPS Technical Specifications per 10 CFR 50.36 and do not constitute an issue of high safety or regulatory significance. Therefore, none of these items need be considered as an obligation.

The intended disposition of the commitments listed in NUREG-1958, Appendix A is provided in the following table. For items that were completed (or completed in part), a disposition may also be provided to indicate why completion of that item would not have been necessary.

The numerical designators refer to the corresponding disposition categories provided above (i.e., disposition category 1, 2, and/or 3).

Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category 1 The ASME Code Section XI Inservice At least 2 years 1, 2, 3 Reactor vessel internals Inspection, Subsections IWB, IWC, prior to entering inspection program review request and IWD Program will be enhanced the period of submitted to NRC 12/12/2011.

to: (1) participate in the industry extended programs for investigating and operation.

NRC suspended review managing aging effects on reactor 12/21/2012.

internals; (2) evaluate and implement Completed the results of the industry programs Reactor vessel internals are being as applicable to the reactor internals; abandoned.

and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the staff for review and approval to augment the current inspections.

2 The ASME Code Section Xl Inservice At least 2 years 1, 2, 3 Reactor vessel internals Inspection, Subsections IWB, IWC, prior to entering inspection program review request and IWD Program will be enhanced the period of submitted to NRC 12/12/2011.

to include identification of the limiting extended susceptible cast austenitic stainless operation.

NRC suspended review steel (CASS) reactor vessel internal 12/21/2012.

components from the standpoint of Completed thermal aging susceptibility, neutron Reactor vessel internals are being fluence, and cracking. For each abandoned.

identified component, a plan will be developed that accomplishes aging management through either a supplemental examination or a component-specific evaluation. The plan will be submitted for staff review and approval, not less than 24 months before entering the period of extended operation.

Serial No. 13-177A Page 8 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity SchedulelStatus Disposition Additional Information Category 3

The Bolting Integrity Program will be Prior to the period 2

Upon approval of the proposed enhanced to further incorporate of extended amendment, this commitment will applicable Electric Power Research operation.

be managed under 10 CFR 50.59 Institute (EPRI) and industry bolting for continued applicability.

guidance. Topic enhancements will Not completed include proper joint assembly, torque The fire protection requirements of values, gasket types, use of 10 CFR 50.48(f) have been lubricants, and other bolting revised to require licensees who fundamentals.

have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

4 The Buried Piping and Tanks Prior to the Period 1 (in part), Upon approval of the proposed Inspection program will be enhanced of Extended 2

amendment, this commitment will to perform visual inspections of a Operation be managed under 10 CFR 50.59 representative sample of for continued applicability.

material/protective measure And combinations for in-scope buried The fire protection requirements of piping and tanks.

During the first 10 10 CFR 50.48(f) have been years of the revised to require licensees who The following materials are utilized in period of have certified permanent buried applications with the extended cessation of operations and associated protective measures:

operation removal of fuel from the reactor

" Steel (including cast iron)/coated, vessel to maintain a fire protection

" Steel/coated and wrapped, And program to address the potential

" Steel/uncoated, and for fires that could cause the

" Stainless steel/coated and wrapped During the second release or spread of radioactive 10 years of the materials, which could result in a Visual inspections of the external period of radiological hazard. Upon surfaces of the components will be extended approval of the proposed performed to identify damaged operation.

amendment, this commitment will wrapping (if present), degraded or be managed under 10 CFR damaged coating (if present), and 50.48(f) for continued applicability.

evidence of loss of material. Each piping inspection will include a The inspections As documented in DEK's letter minimum of 10 linear feet of piping.

required "Prior to dated February 26, 2013 the Period of (Reference 4), transfer of spent The following inspections will be Extended nuclear fuel to dry storage is performed:

Operation" were planned to be completed prior to

- The circulating water system 30-completed.

the end of the year 2020. This is

Serial No. 13-177A Page 9 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category inch diameter recirculation line, which is coated and wrapped carbon steel, will receive one inspection prior to the period of extended operation, and additional inspections within the first 10 years and second 10 years of the period of extended operation.

- The circulating water system recirculation line vent piping, which is coated and wrapped stainless steel, will receive one inspection prior to the period of extended operation and additional inspections within the first 10 years and second 10 years of the period of extended operation.

- The diesel generator system fuel oil piping, which includes coated and wrapped carbon steel fuel oil supply and return piping, storage tank vent piping, and day tank vent piping, will receive one inspection prior to the period of extended operation and additional inspections within the first 10 years and second 10 years of the period of extended operation. The inspections will be performed in the non-cathodically protected portion of the piping. The diesel generator system fuel oil storage tanks, which are coated carbon steel, will receive one inspection of one tank prior to the period of extended operation. An additional tank inspection will be performed within each of the first and second 10 years of the period of extended operation.

- The diesel generator system fuel oil storage tanks hold down straps, which are uncoated carbon steel, will be inspected in conjunction with the associated fuel oil storage tank inspection. One set will be inspected prior to the period of extended operation, and one set will be inspected within each of the first and second 10 years of the period of extended operation. The fire protection system piping, which is coated ductile iron, will receive three inspections prior to the period of prior to exceeding the 10 year limit. At that point this program will no longer be needed to support in scope SSCs.

Serial No. 13-177A Page 10 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category extended operation, and three additional inspections within each of the first and second 10 years of the period of extended operation.

5 The Compressed Air Monitoring Prior to the Period 2

The compressed air systems no Program will be enhanced to of Extended longer fall into the scope of the incorporate the compressed air Operation.

license renewal rule.

system testing and maintenance recommendations from the ASME Not completed OM-S/G-1998, Part 17 and the EPRI TR-108147 and to identify these documents as part of the program basis.

6 The External Surfaces Monitoring Prior to the Period 2

Monitoring of the spent fuel pool Program will be enhanced to inspect of Extended structure is performed per 10 CFR the accessible external surfaces of Operation.

50.65 Maintenance Rule, which is in-scope components, piping, a Commission regulation retained supports, structural members, and Not Completed for licensees during major structural commodities, in the (program was decommissioning activities, per infrequently accessed areas, developed but not RG 1.184.

consistent with the criteria used in implemented).

other plant areas.

Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.59 for continued applicability.

The fire protection requirements of 10 CFR 50.48(f) have been revised to require licensees who have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

7 The External Surfaces Monitoring Prior to the Period 1

The External Surfaces Monitoring Program will be enhanced to provide of Extended Program enhancements were training for operations, engineering, Operation.

completed.

and health physics personnel performing the program inspections Completed and walkdowns. The training will

Serial No. 13-177A Page 11 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category address: (1) the requirements of the External Surfaces Monitoring Program for license renewal, (2) the need to document the identified conditions with sufficient detail to support monitoring and trending the aging effects, and (3) the aging effects monitored by the program and how to identify them.

8 The Fire Protection Program will be Prior to the 3

As documented in DEK's letter enhanced to test a representative sprinkler dated February 26, 2013 sample of sprinkler heads or to heads achieving (Reference 4), transfer of spent replace all affected sprinkler heads in 50 years of nuclear fuel to dry storage is accordance with the requirements of service life.

planned to be completed prior to National Fire Protection Association the end of the year 2020. This is (NFPA) 25.

Not completed prior to sprinkler heads achieving 50 years of service life. At that point, there will be no need for the sprinkler systems and therefore, testing or replacement of sprinkler heads is not necessary.

9 The Fire Protection Program fire Prior to the Period 1

Upon approval of the proposed barrier penetration seal inspections of Extended amendment, this commitment will will be revised to include the Operation.

be managed under 10 CFR 50.59 elastomer shield building fire boots.

for continued applicability.

Completed The fire protection requirements of 10 CFR 50.48(f) have been revised to require licensees who have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

10 The Fire Protection Program Prior to the Period 1, 3 The reactor coolant pumps are inspections of the reactor coolant of Extended being abandoned.

pump oil collection system will be Operation.

revised to include additional Reactor coolant pump oil has inspection criteria for the visual Completed been removed from the pumps inspection of the system and to and their oil collection systems.

Serial No. 13-177A Page 12 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity SchedulelStatus Disposition Additional Information Category perform a one-time inspection of the internal surfaces of the reactor coolant pump oil collection tank.

11 The Fuel Oil Tank Inspections Prior to the Period 1

Performance of tank inspection Program will be enhanced to provide of Extended activities was covered under guidance for the periodic draining, Operation.

Commitment 31, which was also cleaning, and inspection activities.

completed.

Completed 12 The Inspection of Overhead Heavy Prior to the Period 1

Upon approval of the proposed Load and Refueling Handling of Extended amendment, this commitment will Systems Program will be enhanced Operation.

be managed under 10 CFR 50.59 to clarify the requirements of visual for continued applicability.

inspection of structural members, Completed including structural bolting, of the in-scope heavy load and refueling handling cranes and associated equipment.

13 The Metal-Enclosed Bus (MEB)

Prior to the Period 1 (in part), Metal-Enclosed Bus Program was Program will be enhanced to include of Extended 2

in scope for license renewal to augmented periodical visual Operation.

address station blackout recovery.

inspections of the MEB internal As previously discussed, the surfaces, bus supports, bus Thereafter, the station blackout rule does not insulation, taped joints, and boots for inspection of all apply to KPS as a permanently signs of degradation or aging.

MEB will not shutdown and defueled station.

exceed a 10-year interval and the inspection of the sample of bolted connections will not exceed a 5-year interval.

The inspections required "Prior to the Period of Extended Operation" were completed.

14 The Non-EQ Electrical Cables and Prior to the Period 1 (in part), As documented in DEK's letter Connections Program will be of Extended 2

dated February 26, 2013 established. The program will Operation.

(Reference 4), transfer of spent periodically visually inspect for nuclear fuel to dry storage is accessible electrical cables and Thereafter, the planned to be completed prior to connections installed in an adverse inspections will the end of the year 2020. This is localized equipment environment, not exceed a prior to exceeding the 10 year Should an adverse localized 10-year interval, limit. At that point, this program environment be observed, a will no longer be needed to representative sample of electrical The inspections support in scope SSCs.

Serial No. 13-177A Page 13 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category cables and connections installed required "Prior to within that environment will be the Period of visually inspected for jacket surface Extended anomalies.

Operation" were completed._

15 The Non-EQ Electrical Cable Prior to the Period 2

Upon approval of the proposed Connections Program will be of Extended amendment, this commitment will established. The program will Operation.

be managed under 10 CFR 50.59 perform a one-time inspection, on a for continued applicability.

sampling basis, to confirm the Not completed absence of loosening of bolted The fire protection requirements of connections.

10 CFR 50.48(f) have been revised to require licensees who have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

16 The Non-EQ Inaccessible Medium-Prior to the Period 2

Upon approval of the proposed Voltage Cables Program will be of Extended amendment, this commitment will established. The program will Operation.

be managed under 10 CFR 50.59 periodically inspect the in-scope for continued applicability.

manholes and pulling pit for water Thereafter, the collection and will remove water, if manholes and The fire protection requirements of required. The program will pulling pit 10 CFR 50.48(f) have been periodically perform a test on the in-inspections will be revised to require licensees who scope cables to provide an indication performed at least have certified permanent of the condition of the conductor every 2 years.

cessation of operations and insulation.

removal of fuel from the reactor And vessel to maintain a fire protection program to address the potential Thereafter, the for fires that could cause the cable testing will release or spread of radioactive be performed at materials, which could result in a least every radiological hazard. Upon 10 years.

approval of the proposed amendment, this commitment will Not completed be managed under 10 CFR 50.48(f) for continued applicability.

Serial No. 13-177A Page 14 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category 17 The Non-EQ Instrumentation Circuits Prior to the Period 1 (in part), Inspections were partially Subject to Sensitive, High-Voltage, of Extended 2, 3 completed. The applicable Low-Level Signals Program will be Operation.

nuclear instrumentation circuits established. The program will are no longer in the scope of the periodically perform a proven cable Thereafter, the license renewal rule and will be system test for detecting deterioration cable testing and abandoned.

of the insulation system for those calibration electrical cables and connections reviews will not disconnected during calibration, or exceed a 10-year will periodically review the results and interval.

findings of calibrations for those electrical cables that remain The inspections connected during the calibration required "Prior to process.

the Period of Extended Operation" were completed.

18 The Open-Cycle Cooling Water Prior to the Period 1, 2 Upon approval of the proposed System Program will be enhanced to of Extended amendment, the underwater add the applicable aging effects as Operation.

visual inspection mentioned within inspection criteria for the circulating this commitment will be reviewed water system underwater visual Completed under 10 CFR 50.59 for continued inspections.

applicability.

The fire protection requirements of 10 CFR 50.48(f) have been revised to require licensees who have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

19 The Reactor Vessel Surveillance Prior to the Period 1, 2, 3 Fuel can no longer be placed into Program will be enhanced to include of Extended the reactor vessel and the reactor the applicable limitations on Operation.

vessel will be abandoned.

operating conditions to which the Therefore, the Reactor Vessel surveillance capsules were exposed Completed Surveillance Program is no longer (e.g., neutron flux, spectrum, needed.

irradiation temperature, etc.).

Serial No. 13-177A Page 15 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category 20 The Reactor Vessel Surveillance Prior to the Period 2, 3 Fuel can no longer be placed into Program will be enhanced to include of Extended the reactor vessel and the reactor requirements for storing, and Operation.

vessel will be abandoned.

possible recovery, of tested and Therefore, the Reactor Vessel untested capsules (removed from the Not completed Surveillance Program is no longer reactor vessel after August 31, needed.

2000).

21 The Selective Leaching of Materials Prior to the Period 2

Upon approval of the proposed Program will be established. The of Extended amendment, this commitment will program will perform a one-time Operation.

be managed under 10 CFR 50.59 visual inspection and hardness for continued applicability.

measurement or qualitative Not completed examination of selected components, The fire protection requirements of within the scope of license renewal 10 CFR 50.48(f) have been for selective leaching.

revised to require licensees who have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

22 The Structures Monitoring Program Prior to the Period 1

Monitoring of the spent fuel pool will be enhanced to clearly define of Extended structure is performed under 10 structures, structural elements, and Operation.

CFR 50.65 Maintenance Rule, miscellaneous structural commodities which is a Commission regulation that are in-scope. Defined scope to Completed retained for licensees during include the MEB enclosure major decommissioning activities, assemblies, structural supports, and per RG 1.184.

enclosure seals.

23 The Structures Monitoring Program Prior to the Period 1, 2 Upon approval of the proposed will be enhanced to monitor of Extended amendment, this commitment will groundwater quality and verify that it Operation.

be managed under 10 CFR 50.59 remains non-aggressive to below-for continued applicability.

grade concrete.

Completed The fire protection requirements of 10 CFR 50.48(f) have been revised to require licensees who have certified permanent cessation of operations and removal of fuel from the reactor vessel to maintain a fire protection

Serial No. 13-177A Page 16 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item

'Activity Schedule/Status Disposition Additional Information Category program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

24 The Structures Monitoring Program Prior to the Period 1, 2 The Structures Monitoring will be enhanced to improve criteria of Extended Program was enhanced.

for the detection of aging effects for Operation.

the underwater visual inspections of the in-scope structures.

Completed 25 The Work Control Process Program Prior to the Period 2

The majority of one-time-will be established. The program will of Extended inspections were completed on perform one-time inspections as a Operation.

the required sample of in-scope verification of the effectiveness of SSCs. No significant age-related chemistry control programs. The Not completed degradation was identified.

program will also perform visual inspections of component internal Upon approval of the proposed surfaces and external surfaces of amendment, this commitment will selected components to manage the be managed under 10 CFR 50.59 effects of aging when the surfaces for continued applicability.

are made available for examination through surveillance and maintenance activities.

26 Deleted N/A 27 Deleted N/A 28 The Metal Fatigue of Reactor Prior to the Period 2, 3 Reactor coolant system is being Coolant Pressure Boundary Program of Extended abandoned.

will be enhanced to include a routine Operation.

assessment of the transient cycle count totals and fatigue usage status Not completed for monitored locations, including an action limit for the initiation of corrective action.

29 The following will be further Prior to the Period 1

Commitment completed.

evaluated as part of the applicant's of Extended ongoing performance improvement Operation.

programs:

e SAMA 160: Install Emergency Completed Diesel Generator (EDG) exhaust duct insulation.

• Concurrent implementation of

Serial No. 13-177A Page 17 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity SchedulelStatus Disposition Additional Information Category SAMAs 81,160,166, and 167.

• Implementation of temporary screenhouse ventilation.

30 Quarterly laboratory testing of fuel oil Prior to the Period 1, 2 Commitment was completed.

samples for water, sediment, and of Extended particulates will be performed on the Operation.

EDG day tanks and on the technical support center diesel generator (TSC Completed DG) day tank. The testing acceptance criteria will be consistent with the requirements specified in American Society for Testing and Materials (ASTM) D975-06b for water and sediment and ASTM D6217 for particulates.

31 The Work Control Process Program Prior to the Period 1

Commitment completed.

will be enhanced to provide for a of Extended one-time-inspection of the EDG day Operation.

tanks and the TSC DG day tank. An exterior surfaces ultrasonic test (UT)

Completed inspection will be performed to verify wall thickness of the bottom of each day tank. Based upon the UT inspections, the most limiting EDG day tank will also be drained, cleaned, and visually inspected as a leading indicator for the remaining tanks.

32 The 14 potentially cost beneficial Prior to the Period 2

One potentially cost beneficial SAMAs identified in LRA Appendix E, of Extended severe accident mitigation Attachment F, will be further Operation.

alternative was identified. Due to evaluated as part of the applicant's the permanently defueled status ongoing performance improvement Not completed of the facility, this item will be programs.

reviewed under 10 CFR 50.59 for continued applicability.

33 Develop a plan for identification and Prior to the Period 2, 3 With nuclear fuel permanently remediation of reactor refueling cavity of Extended removed from the reactor vessel liner leakage to be implemented Operation.

and no longer permitted to be during the period of extended placed into the reactor vessel, the operation.

Not completed reactor cavity liner no longer performs an in scope function.

34 At least one core bore sample will be Prior to the end of 1

Monitoring of the spent fuel pool taken from the waste drumming room 2011.

structure is performed under 10 reinforced concrete ceiling below the CFR 50.65 Maintenance Rule, spent fuel pool. The core sample Completed which is a Commission regulation location and depth will be sufficient to retained for licensees during validate the strength of the concrete major decommissioning activities,

Serial No. 13-177A Page 18 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity SchedulelStatus Disposition Additional Information Category and the extent of any degradation.

per RG 1.184.

The core sample will be tested for compressive strength and will be subject to petrographic examination.

Reinforcing steel in the core sample area will be exposed and inspected for material condition.

35 Develop an action plan for Prior to the Period N/A Monitoring of the spent fuel pool identification and remediation of of Extended structure is performed under 10 spent fuel pool (SFP) liner leakage to Operation.

CFR 50.65 Maintenance Rule, be implemented during the period of which is a Commission regulation extended operation.

Action plan retained for licensees during developed major decommissioning activities, per RG 1.184.

36 If SFP liner leakage persists during Prior to the end of N/A Monitoring of the spent fuel pool the period of extended operation, an the first 10 years structure is performed under 10 additional concrete core sample will of the Period of CFR 50.65 Maintenance Rule, be taken from the waste drumming Extended which is a Commission regulation room reinforced concrete ceiling Operation.

retained for licensees during below the spent fuel pool. The core major decommissioning activities, sample location and depth will be Not completed per RG 1.184.

sufficient to validate the strength of the concrete and the extent of any degradation. The core sample will be tested for compressive strength and will be subject to petrographic examination. Reinforcing steel in the core sample area will be exposed and inspected for material condition.

37 Perform a VT-1 visual examination of Prior to the Period 1, 2, 3 Safety injection system is being the stainless steel cladding of a of Extended abandoned.

safety injection pump for indications Operation.

of cracking or corrosion due to cladding breach.

Completed 38 The Boron Carbide Surveillance Prior to the Period 1

Upon approval of the proposed Program, which includes neutron of Extended amendment, this commitment will attenuation testing, will continue to Operation.

be managed under 10 CFR 50.59 be performed during the period of for continued applicability.

extended operation every 3 years.

Program is in place 39 A surveillance program will be Prior to 2017.

N/A Upon approval of the proposed implemented to perform verification Surveillance amendment, this commitment will that the Boral spent fuel storage rack program will be be managed under 10 CFR 50.59 neutron absorber B-10 areal density performed every for continued applicability.

is maintained within the bounds of 10 years the spent fuel pool criticality analysis. thereafter.

Alternatively, the criticality analysis

Serial No. 13-177A Page 19 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category for the spent fuel pool will be revised Not completed to eliminate credit for the Boral neutron absorber material.

40 Implement nitrate monitoring for the Prior to the Period 1, 2, 3 Component cooling water system component cooling system on a of Extended is being abandoned.

frequency consistent with the existing Operation.

monitoring for ammonia.

I_

Completed 41 Perform a fatigue analysis of the Prior to the Period 1, 2, 3 Pressurizer is being abandoned.

surge line hot leg nozzle and the of Extended charging line nozzle in accordance Operation.

with ASME Boiler and Pressure Vessel (B&PV) Code Section III, Completed Subsection NB-3200 guidance and determine the cumulative usage factor (CUF), considering the effects of the reactor coolant environment.

Confirm that CUF is less than 1.0 at the end of 60 years of plant operation.

42 For Examination Category B-J, item During each 10-2, 3 KPS power plant piping systems No. B9.21, eight ASME Class 1 year ISI are designed to USAS B31.1 small-bore circumferential welds will inspection interval requirements. All piping formerly receive volumetric and surface during the period classified as "ASME Class 1" for examinations during each 10-year ISI of extended the purpose of meeting 10 CFR inspection interval during the period operation.

50.55a inspection requirements is of extended operation.

being abandoned.

Not completed 43 Ten volumetric examinations of Four volumetric 2, 3 KPS power plant piping systems ASME Class 1 small-bore socket examinations or are designed to USAS B31.1 welds will be performed using a two destructive requirements. All piping formerly demonstrated, nuclear-industry examinations (or classified as "ASME Class 1" for endorsed, inspection methodology an equivalent the purpose of meeting 10 CFR that can detect cracking within the combination of 50.55a inspection requirements is specified examination volume, if a examinations) being abandoned.

methodology becomes available. In prior to the period the event that a demonstrated, of extended nuclear-industry endorsed, inspection operation.

methodology is not available, destructive examinations of socket Remaining welds will be substituted for examinations volumetric nondestructive within three years examinations. Each destructive weld of entering the examination will be considered period of equivalent to performing two extended volumetric weld examinations, such operation.

that a maximum of five destructive examinations will be performed.

Not completed

Serial No. 13-177A Page 20 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category 44 Core samples will be obtained from Prior to the Period 1, 2 Upon approval of the proposed the inside surface of a concrete wall of Extended amendment, this commitment will (below the groundwater table Operation.

be managed under 10 CFR 50.59 elevation) or from the foundation for continued applicability.

basemat in the vicinity of the Completed groundwater wells for which average The fire protection requirements of sampling results have exceeded the 10 CFR 50.48(f) have been chloride concentration limit of 500 revised to require licensees who ppm. The concrete core samples will have certified permanent be tested to determine if the chloride cessation of operations and content within the concrete could removal of fuel from the reactor cause degradation due to corrosion vessel to maintain a fire protection of reinforcing steel.

program to address the potential for fires that could cause the release or spread of radioactive materials, which could result in a radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

45 In the event that the chloride content Prior to the end of 2

Upon approval of the proposed in the groundwater does not the first 10 years amendment, this commitment will decrease to below 500 ppm within of extended be managed under 10 CFR 50.59 the first ten years of the period of operation.

for continued applicability.

extended operation, core samples will be obtained from the inside Not completed The fire protection requirements of surface of a concrete wall (below the 10 CFR 50.48(f) have been groundwater table elevation) or from revised to require licensees who the foundation basemat in the vicinity have certified permanent of a groundwater well for which cessation of operations and average sampling results have removal of fuel from the reactor exceeded the chloride concentration vessel to maintain a fire protection limit of 500 ppm. The concrete core program to address the potential samples will be tested to determine if for fires that could cause the the chloride content within the release or spread of radioactive concrete could cause degradation materials, which could result in a due to corrosion of reinforcing steel.

radiological hazard. Upon approval of the proposed amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

46 If the results of the core sample Prior to the Period Not See Response to Commitment testing of the waste drumming room of Extended needed Number 34.

reinforced concrete ceiling leakage Operation.

site (related to potential SFP liner Core sample testing results did leakage - Commitment 34) indicate Not completed.

not indicate degradation of the degradation of the structural integrity structural integrity of the concrete.

of the concrete, at least one core

Serial No. 13-177A Page 21 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category bore sample will be taken near at least one of the refueling cavity liner leakage indication sites. The core sample location and depth will be sufficient to validate the strength of the concrete and the extent of any degradation. The core sample will be tested for compressive strength and will be subject to petrographic examination. Reinforcing steel in the core sample area will be exposed and inspected for material condition.

47 Submit three examples of operating Within 2 years 2

See response to Commitment experience associated with the Work following Number 25.

Control Process - Internal Surfaces implementation of Monitoring Program for NRC staff the WCP aging Upon approval of the proposed review in determining the management amendment, this commitment will effectiveness of the program to program.

be managed under 10 CFR 50.59 detect and correct the effects of for continued applicability.

aging prior to the loss of function.

Not completed 48 The cathodic protection system During the Period 2,3 SSCs protected by cathodic associated with the diesel generator of Extended protection will either no longer be fuel oil storage tanks and protected Operation.

in license renewal scope or are portions of the fuel oil lines, and the being abandoned.

circulating water system recirculation Not completed piping, will each be maintained Portions of the circulating water available a minimum of 90% of the system protected by cathodic time during the period of extended protection will be taken out of operation. In addition, NACE service; diesel generator system cathodic protection system surveys will no longer be safety related will be performed at least annually and will eventually be abandoned.

during the period of extended operation.

49 Recognizing that the EPRI Steam Prior to 2023 2, 3 Steam generators are being Generator Maintenance Program abandoned.

(SGMP) resolution is still under Not completed development, Kewaunee will perform an inspection of each steam generator to assess the condition of the divider plate assembly. The examination technique(s) will be capable of detecting PWSCC in the divider plate assembly and associated welds. The steam generator divider plate inspections will be completed prior to exceeding 10 years into the period of extended operation. In addition, Dominion

Serial No. 13-177A Page 22 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity Schedule/Status Disposition Additional Information Category Energy Kewaunee, Inc., (Dominion, DEK, or the applicant) will continue to actively participate in the EPRI SGMP studies.

50 Perform an audit of the Internal Prior to the Period 2

Upon approval of the proposed Surfaces Monitoring portion of the of Extended amendment, this commitment will Work Control Process Program Operation and be managed under 10 CFR 50.59 inspections to confirm that the every 10 years for continued applicability.

components representing the leading thereafter.

indicators of aging for each of the The fire protection requirements of material/environment combinations Deliberate 10 CFR 50.48(f) have been have been inspected at least once focused revised to require licensees who during the audit period, inspections will be have certified permanent performed within cessation of operations and If any scheduled surveillance and 5 years of removal of fuel from the reactor maintenance activities which were completion of the vessel to maintain a fire protection intended to encompass components audits.

program to address the potential as leading indicators of aging in each for fires that could cause the of the material/environment Not completed release or spread of radioactive combinations have not been materials, which could result in a performed, then perform deliberate radiological hazard. Upon focused inspections of these approval of the proposed components.

amendment, this commitment will be managed under 10 CFR 50.48(f) for continued applicability.

51 DEK will perform a fatigue evaluation Prior to the Period 1, 2, 3 Pressurizer is being abandoned.

of the pressurizer lower head and of Extended surge line that is consistent with the Operation.

requirements of ASME B&PV Code,Section III, NB-3200 and will Completed determine the cumulative fatigue usage through the period of extended operation.

52 DEK will perform a review of design Prior to the Period 1, 2, 3 The reactor coolant system will be basis ASME Code Class 1 of Extended abandoned.

component fatigue evaluations to Operation.

determine whether the NUREG/CR-6260-based components that have Completed been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting components for the Kewaunee plant configuration. If more limiting components are identified, the most limiting component will be evaluated for the effects of the reactor coolant environment on fatigue usage.

Serial No. 13-177A Page 23 of 25 Disposition of License Renewal Commitments Listed in Appendix A of NUREG-1958 Item Activity SchedulelStatus Disposition Additional Information Category 53 DEK will develop a plan to address the potential for failure of the primary-to-secondary pressure boundary due to PWSCC cracking of tube-to-tubesheet welds.

The plan will consist of two resolution options:

1. Perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to:

a) Establish a technical basis which concludes that the structural integrity of the steam generator tube-to-tubesheet interface is adequately maintained with the presence of tube-to-tubesheet weld cracking, and b) Establish a technical basis which concludes that the steam generator tube-to-tubesheet welds are not required to perform a reactor coolant pressure boundary function.

-or-

2. Perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. If weld cracking is identified:

a) The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and b) An ongoing monitoring program will be established to perform routine tube-to-tubesheet inspections for the remaining life of the steam generators.

Develop a plan prior to the Period of Extended Operation.

Implement the requirements of the plan prior to 2023.

Not completed 2,3 Steam generators are being abandoned.

54 The Structures Monitoring Program Prior to the Period 1

Monitoring of the spent fuel pool will be revised to include the of Extended structure is performed under 10 evaluation criteria of ACI 349.3R-96, Operation.

CFR 50.65 Maintenance Rule, Chapter 5, as the criteria to be used which is a Commission regulation when evaluating conditions or Completed retained for licensees during findings identified during concrete major decommissioning activities, structure inspections. This will be per RG 1.184.

done prior to the performance of the next scheduled inspection, which will occur prior to the period of extended operation.

Serial No. 13-177A Page 24 of 25 Additional considerations related to deletion of License Condition 2.C.(15)(a) and allowing the associated commitments listed in NUREG-1958, Appendix A to be managed as discussed above include the following.

1. The License Renewal Rule (10 CFR 54) Applies to Operating Plants and Precedence Exists for not Applying the Rule to Permanently Shutdown Facilities The scope of the License Renewal Rule, as identified in 10 CFR 54.4, "Scope," was discussed in the Supplementary Information that was provided upon issuance of the License Renewal Rule (Federal Register Vol. 60, No. 88, May 8, 1995) Section Ill.c, "Systems, structures, and components within the scope of license renewal". The staff's discussion regarding 10 CFR 54.4(a)(1) and (a)(2), stated in part, "These two categories are meant to capture, as a minimum, automatic reactor shutdown systems, engineered safety feature systems, systems required for safe shutdown (achieve and maintain the reactor in a safe shutdown condition), and nonsafety-related systems, such as auxiliary systems, necessary for the function of safety-related systems." The scope of 10 CFR 54.4(a)(3) "was developed to ensure that important systems, structures, and components that may be considered outside the traditional definition of safety-related and outside of the first two categories in Sec.

54.4, would be included within the initial focus of license renewal.

Through evaluation of industry operating experience and through continuing regulatory analysis, the Commission has reaffirmed that systems, structures, and components required to comply with these regulations are important to safe plant operation because they provide substantial additional protection to the public health and safety or are an important element in providing adequate protection to the public health and safety."

Based on the above, the focus of the License Renewal Rule is on safe operation of the plant. Because KPS is a permanently shutdown and defueled facility and no longer licensed to operate per 10 CFR 50.82(a)(2), the aging management requirements of the License Renewal Rule should no longer be applied to KPS.

This is consistent with past precedence.

NRC has not required application of the License Renewal Rule to licensees who have permanently ceased operation and submitted certifications under 10 CFR 50.82. A few of those plants are at or beyond the end of their original license (and are continuing under 10 CFR 50.51) and, like KPS, continue to store spent nuclear fuel in spent fuel pools.

2. KPS will not enter the Period of Extended Operation NRC staff and DEK representatives discussed this request via telephone on June 25, 2013. As discussed during that call, the 10 CFR Part 50 license for KPS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel per 10 CFR 50.82(a)(2). As such, KPS has never, and can never

Serial No. 13-177A Page 25 of 25 operate during the period of extended operation. The period of extended operation for KPS would have commenced on December 22, 2013.

With the reactor permanently shutdown and defueled, the circumstances for which the renewed facility operating license was requested are no longer germane. Decommissioning of KPS is not dependent on the requirements of the License Renewal Rule. The KPS license will remain in effect throughout the decommissioning process 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.

References

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 255: Deletion of License Renewal Condition for Permanently Defueled License," dated April 16, 2013 (ADAMS Accession No. ML13113A368).

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala, Craig Sly, et al (DEK),

"MF1771 (and part of MF1952) - Kewaunee Power Station - Request for Additional Information (RAI) Re:

Deletion of License Condition 2.C.(15)," dated June 24, 2013.

3. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "License Amendment Request 256:

Permanently Defueled License and Technical Specifications," dated May 29, 2013 (ADAMS Accession No. ML13156A037).

4. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Kewaunee Power Station Post-Shutdown Decommissioning Activities Report," dated February 26, 2013 (ADAMS Accession Nos. ML130630281, ML13063A248, ML13063A249).

5. Letter from Brian E. Holian (NRC) to David A. Heacock (DEK), "Safety Evaluation Report Related to the License Renewal of Kewaunee Power Station (TAC No.

MD9408)," dated November 4, 2010.