ML13294A091

Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications

ML13294A091
Person / Time
Site:	Kewaunee
Issue date:	10/15/2013
From:	Mark D. Sartain Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226B, LAR 256
Download: ML13294A091 (19)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 i1'F DDominion Web Address: www.dom.com October 15, 2013 U. S. Nuclear Regulatory Commission Serial No. 13-226B Attention: Document Control Desk LIC/CDS/R0 Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION SUPPLEMENT I AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant.

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 response are provided in Attachment 1 to this letter.

In response to the staff's comments regarding proposed changes to TS Limiting Condition for Operation (LCO) 3.0.6 (NRC Question MF1952-RAII-STSB-Grover-002),

DEK is revising the originally proposed amendment. The revised request proposes to delete LCO 3.0.6 in its entirety. Attachment 2 to this letter provides a supplement to the proposed amendment describing the revision. Attachment 3 contains the marked-up TS page affected by this revision. The analyses provided in Reference 1 remain applicable and bounding to this proposed change. The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this revision.

The June 1, 2014 requested approval date for the submittal remains unchanged.

Serial No. 13-226B LAR 256 RAI Response Page 2 of 3 Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Development . VICKI L.HULL JNotary Public J Commonwealth of Virginia SIJ 140542 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 Mark D. Sartain, who is Vice President - Nuclear Engineering and Development of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this / 5 -- 'day of ,2013.

My Commission Expires:. A ".. ,

Notary Public Attachments:

1. Response to Request for Additional Information

2. Supplement 1, Discussion of Change and Technical Analysis

3. Supplement 1, Marked-up Technical Specifications Page

References:

1. 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)

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

"MF0996, MF1952 - Draft RAI items being processed to you," dated August 16, 2013

Serial No. 13-226B LAR 256 RAI Response Page 3 of 3 cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Dr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Dl 5 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. 13-226B ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

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

Serial No. 13-226B Attachment 1 Page 1 of 8 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant.

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.

NRC Question MFI952-RAII-STSB-Grover-001 DEK is proposing to replace "operation of the unit" with "management of irradiated fuel" in TS section 1.3, "Completion Times." In the application, DEK states that since operation of the unit is no longer permitted, safe management (storage and movement) of irradiated fuel is the primary objective of the permanently defueled TS.

In addition, TS 5.2.1.c is being revised to replace "to ensure nuclear fuel" with "to ensure safe management of nuclear fuel."

Use of the term "management" in the proposed TS 1.3, "Management of irradiated fuel" and TS 5.2.1 .c, "to ensure safe management of nuclear fuel," makes the meaning of the sentences unclear and open to interpretation. It is not clear that management means storage and movement of irradiated fuel. Please provide changes that clearly identify that storage and movement of irradiated fuel is the intent.

Response

DEK considers the term "management" in reference to nuclear fuel at a permanently shutdown facility in decommissioning to apply solely to the storage and movement of irradiated fuel. DEK believes that the term provides an appropriate level of clarity for use in the technical specifications consistent with the regulations.

"Management of all irradiated fuel" is the terminology used in 10 CFR 50.54(bb) and was used by DEK in the KPS updated irradiated fuel management plan sent to NRC on February 26, 2013 (Reference 5) in accordance with this regulation. As such, DEK recommends no change to the proposed wording.

Serial No. 13-226B Attachment 1 Page 2 of 8 This question is similar to NRC Question MF2370-RAII-AHPB-Lapinsky-002. That NRC question and DEK's response to it are provided in Reference 4.

NRC Question MF1952-RAII-STSB-Grover-002 In the application, DEK is proposing to delete the sentence shown below from limiting conditions for operation (LCO) 3.0.6.

In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

DEK stated that the reasoning for the deletion is that the safety function determination program is not needed in a permanently defueled condition. The NRC staff does not agree that the safety function determination program is not needed in a permanently defueled condition. The safety function determination program is needed whenever there are support and supported systems in the technical specifications. If TSs do not contain support and supported systems, then both LCO 3.0.6 and its associated Safety Function Determination Program should be deleted, since there would be no applicable LCOs in technical specifications.

Please explain which LCOs are supported systems and which LCOs are support systems. If there are no support and supported systems that remain in the proposed TS, then please explain why LCO 3.0.6 is being retained.

Response

There are no support and supported systems that remain in the proposed TS. As such, there is no longer need for a SFDP. Consequently, TS 5.5.13, SFDP, was proposed for deletion in LAR 256 (Reference 1) to preclude the administrative burden of unnecessary maintaining the SFDP. Because the sentence in LCO 3.0.6 (quoted in Question 2 above) pertains solely to TS 5.5.13, that sentence is also no longer needed and was likewise proposed for deletion.

Deletion of LCO 3.0.6 in its entirety was not proposed in LAR 256 because the retained portion of LCO 3.0.6 would have been rendered moot.

However, to prevent the potential for confusion regarding applicability of LCO 3.0.6, DEK proposes to supplement LAR 256 by deleting LCO 3.0.6 in its entirety (in response to this question). The proposed supplement is provided in Attachment 2.

Serial No. 13-226B Attachment 1 Page 3 of 8 NRC Question MF1952-RAII-STSB-Grover-003 On page 56 of 113 the last paragraph in the technical analysis section has a sentence that states, "However, operation of the plant or placing fuel in the reactor vessel."

Please explain what is meant by this sentence.

Response

This sentence is missing the phrase "10 CFR 50.82(a)(2) prohibits" after the first word.

The complete sentence should read:

"However, 10 CFR 50.82(a)(2) prohibits operation of the plant or placing fuel in the reactor vessel."

The above sentence, and variants thereof, is used throughout the submittal as justification for eliminating requirements that pertain only to reactor operation (such as the justification for deleting all of TS Section 3.5, Emergency Core Cooling Systems (ECCS)). This sentence appears to have been inadvertently truncated. The sentence refers to the requirement in 10 CFR 50.82(a)(2) that prohibits operation of the plant or placing fuel in the reactor vessel.

NRC Question MF1952-RAII-STSB-Grover-004 DEK proposes to delete paragraph c of TS 5.2.2 which states:

A radiation technologist shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, except in severe weather conditions, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

DEK stated that this paragraph is being deleted because this requirement only applies when fuel is in the reactor. The NRC staff believes it is prudent to have an individual qualified in radiation protection procedures on site during fuel handling operations or during movements of loads over storage racks containing fuel.

Paragraph c of TS 5.2.2 does not require the radiation protection staff to be on-site during fuel handling operations or during movements of loads over storage racks containing fuel. Please provide a requirement that requires the radiation protection staff to be on-site during fuel handling operations or during movements of loads over storage racks containing fuel, or provide the basis for not needing one.

Serial No. 13-226B Attachment 1 Page 4 of 8

Response

DEK also believes that it is prudent to have an individual qualified in radiation protection procedures on site during fuel handling operations. DEK believes that such requirements are appropriately managed via licensee-controlled documents (e.g.,

procedures) rather than Technical Specifications. Accordingly, existing KPS procedures require that radiation protection staff be present for various activities that may affect radiological conditions, such as movement of irradiated fuel.

Specifically, movement of heavy loads (greater than the weight of a fuel assembly) over fuel stored in the spent fuel pool is prohibited by the Technical Requirements Manual (TRM). The TRM is incorporated by reference into the Updated Safety Analysis Report (USAR). As such, changes to the TRM must be made under the requirements of 10 CFR 50.59. The licensing basis analysis documented in Chapter 14 of the USAR states that dropping a fuel assembly onto fuel stored in the spent fuel pool will not cause excessive damage to the stored assemblies because the buckling load on the fuel rods is below the critical buckling load and resulting stresses in the cladding are below yield stresses. Therefore, the drop of a load that does not exceed the weight of a fuel assembly would also not cause excessive damage to the stored assemblies. The TRM prohibition on movement of heavier loads over fuel stored in the spent fuel pool precludes the potential for spent fuel damage that could result in radiological consequences beyond the design basis analyses.

Licensee-controlled documents that contain requirements related to fuel handling and movement of loads over storage racks containing spent fuel include the following.

• Procedure RE-25, "Fuel Movement During Non-Refueling Operations," requires that fuel handling evolutions be performed in accordance with Radiation Work Permit (RWP) instructions (which specify coverage by radiation protection staff).

• Procedure MA-KW-GMP-ISF-003, "Dry Shielded Canister Loading," invokes Procedure RE-25 (and its associated RWP requirements) for operations involving fuel movement associated with ISFSI campaigns. The frequent involvement of radiation protection staff in these fuel movement evolutions necessitates that at least one individual qualified in radiation protection procedures be on site during fuel handling operations.

" Procedure RP-KW-001-016, "Radiation Work Permit - Preparation, Issuance, and Termination," provides instructions on preparing RWPs. This procedure specifies conditions where continuous, periodic, or intermittent coverage by an individual qualified in radiation protection would be required. Only low-risk work is eligible for no or routine coverage by radiation protection staff.

Radiation Work Permits related to ISFSI loading campaigns (which include loading, preparation, transport, and associated support activities) require that continuous coverage be provided by radiation protection staff during various evolutions such as removing items from the spent fuel pool and movement of fuel transfer casks.

Serial No. 13-226B Attachment 1 Page 5 of 8 These requirements also necessitate that at least one individual qualified in radiation protection procedures be onsite during the evolution.

• TRM 8.9.1, "Spent Fuel Pool - Control of Heavy Loads," specifies that heavy loads greater than the weight of a fuel assembly, including its heaviest insert and handling tool, will not be transported over or placed in either spent fuel pool when spent fuel is stored in that pool, unless the heavy load does not traverse directly above spent fuel stored in the pool's spent fuel storage racks, and the load handling system (e.g., crane, associated lifting devices, and interfacing lift points) used for these lifts meets the single-failure-proof handling system criteria.

" TRM 8.9.4, "Radiation Monitoring During REFUELING OPERATIONS" requires monitoring of radiation levels in the spent fuel pool area during refueling operations to provide indication of an unsafe condition. This TRM section is in the process of being revised to address the permanently defueled condition. The term "REFUELING OPERATIONS" is being revised to state "movement of irradiated fuel assemblies or fuel assembly components." Therefore, the TRM is being revised to require monitoring of radiation levels in the spent fuel pool area during movement of irradiated fuel assemblies or fuel assembly components.

The existing procedural and TRM requirements are adequate to ensure that appropriate coverage by radiation protection staff is provided during fuel handling operations and during movement of loads over storage racks containing spent fuel.

The existing paragraph c of TS 5.2.2 is consistent with NUREG-1431, Standard Technical Specifications, which does not specify a requirement for radiation protection staff to be on-site, except when fuel is in the reactor. Leaving TS 5.2.2.c unchanged would not alter any requirement at KPS, since this TS does not address the permanently defueled condition of KPS. Since staffing requirements for radiation protection personnel during spent fuel handling operations and during movement of loads over storage racks containing spent fuel are appropriately addressed via plant procedures, TS 5.2.2.c remains proposed for deletion as stated in the original submittal.

NRC Question MFI952-RAII-STSB-Grover-005 DEK proposes to add a new requirement to TS 5.2.2.c that states, "All fuel handling operations shall be directly supervised by a qualified individual." The application states that this new requirement ensures that movement of irradiated fuel is only performed under the direct supervision of an individual who has been trained and qualified on the procedures, processes, requirements and standards for safe movement of irradiated fuel.

The NRC staff believes it is prudent to have fuel handling operations be directly supervised by a certified fuel handler, as defined in TS.

Serial No. 13-226B Attachment 1 Page 6 of 8 The term "qualified individual" is unclear. Please explain what DEK means by "qualified individual." In addition, please explain the difference between a "qualified individual" and a "certified fuel handler."

Response

There is no intended difference between a "qualified individual" (as referred to in TS 5.2.2.c) and a Certified Fuel Hander. TS 5.2.2.c was proposed with the terminology of "qualified individual" for consistency with Millstone Unit 1 TS 5.2.2.e because Millstone and KPS are both part of the Dominion fleet. The proposed TS 5.2.2.c is identical to the requirement approved by NRC for Millstone Unit 1 in existing TS 5.2.2.e.

Proposed TS 5.2.2.a will require that a Certified Fuel Handler be part of the minimum shift crew composition. Proposed TS 5.2.2.d will require that the shift manager shall be a Certified Fuel Handler. Proposed TS 5.1.2 will require that the shift manager shall be responsible for the shift command function. Finally, proposed TS 5.2.2.c will require that all fuel handling operations shall be directly supervised by a qualified individual.

The "qualified individual" referred to in proposed TS 5.2.2.c is a Certified Fuel Handler.

These requirements, in aggregate, assure that fuel handling operations are directly supervised by a Certified Fuel Handler.

This question is similar to NRC Question MF2370-RAII-AHPB-Lapinsky-005. That NRC question and DEK's response to it are provided in Reference 4.

NRC Question MF1952-RAII-STSB-Grover-006 DEK has proposed to delete TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program," and states that the tanks associated with this program will be vented and removed from service and there will no longer be any source of explosive or radioactive gases generated from reactor operation.

The NRC staff agrees that this program would not be required if each tank associated with this program is empty, will no longer be used in the future, and is controlled and isolated from any use in the future. However, if the associated tanks still have contents, or will be used in the future, then it is not appropriate to delete this program.

Please provide a list of all tanks that apply to this program and explain if the tanks are empty and what controls are in place to prevent any use of these tanks in the future.

Response

The tanks that apply to the "Explosive Gas and Storage Tank Radioactivity Monitoring Program" are those associated with the gaseous radioactive waste disposal system

Serial No. 13-226B Attachment 1 Page 7 of 8 (including gas storage and offgas treatment). These tanks are the four gas decay tanks. Liquid waste at KPS is stored in the chemical and volume control system (CVCS) liquid holdup tanks, which are located in the auxiliary building. The liquid holdup tanks are not within the scope of this program.

Subsequent to the permanent shutdown of KPS, these tanks (including the liquid holdup tanks) have been drained, vented, and radiologically analyzed. The analyses indicate that the remaining few gallons of liquid do not contain radioactive gases with the potential for being volatized while being stored, processed or possibly leaked.

Therefore, a failure involving the radioactive liquid waste systems is not capable of challenging dose limits established in 10 CFR 50.67 and Regulatory Guide 1.183 or the EPA's Protective Action Guidelines (PAG).

KPS is a permanently shutdown facility (with fuel stored in the spent fuel pool and ISFSI). The reactor coolant system (RCS) has been drained and vented. 10 CFR 50.82(a)(2) prohibits operation of the reactor or placement or retention of fuel into the reactor vessel. Consequently, there is no longer a continuing source of radioactive gases being produced to contribute to the contents of the storage tanks (which was the purpose of this program). There are no specific controls to prevent use of these tanks for other purposes in the future because such use would be outside the scope of the Explosive Gas and Storage Tank Radioactivity Monitoring Program. The requirements of 10 CFR 50.82(a)(2) prohibits reactor operation and effectively serves as a control to prevent further generation of explosive gas mixtures or radioactive gases. Therefore, no additional controls are needed.

Since the tanks do not currently contain a sufficient quantity of radioactivity to exceed the dose limits discussed above, and the reactor can no longer generate additional radioactivity, this program is no longer required.

References

1. 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).

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

"MF0996, MF1952 - Draft RAI items being processed to you," dated August 16, 2013.

3. Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 207 to Facility Operating License No. DPR-43, Dominion Energy Kewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2, 2011.

Serial No. 13-226B Attachment 1 Page 8 of 8

4. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (Defueled License and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are being prepared - see attached drafts," dated August 8, 2013.

5. 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).

Serial No. 13-226B ATTACHMENT 2 SUPPLEMENT 1:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-226B Attachment 2 Page 1 of 3 SUPPLEMENT 1 LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS

1.0 DESCRIPTION

By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant.

In response to NRC staff comments regarding proposed changes to TS Limiting Condition for Operation (LCO) 3.0.6 (NRC Question MF1952-RAII-STSB-Grover-002 of Reference 2), DEK is revising the originally proposed amendment. The revised request proposes to delete LCO 3.0.6 in its entirety. A discussion and technical analysis of the proposed change is provided below. Attachment 3 contains the marked-up TS page affected by the proposed change. The analyses provided in Reference 1 remain applicable and bounding to this proposed change. The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this proposed change.

2.0 PROPOSED CHANGE

As noted in Attachment 1, since the TS no longer contain support and supported systems, then both LCO 3.0.6 and its associated Safety Function Determination Program should be deleted because there are no applicable LCOs in the TS.

Therefore, DEK proposes to delete LCO 3.0.6 in its entirety. Consistent with the deletion of LCO 3.0.6, a reference to LCO 3.0.6 contained in LCO 3.0.2 is also proposed for deletion.

Deletion of the requirement for a Safety Function Determination Program (TS 5.5.13),

was already proposed in the original submittal.

3.0 TECHNICAL ANALYSIS

The technical analyses provided in the originally submitted LAR 256 (Reference 1) remain applicable to, and unaltered by, this proposed change.

Serial No. 13-226B Attachment 2 Page 2 of 3 The existing TS Section 3.0, "Limiting Condition for Operation (LCO) Applicability,"

contains general requirements applicable to all specifications. Because the KPS Part 50 license no longer authorizes emplacement or retention of fuel in the reactor vessel, the general requirements that do not apply with the reactor in a defueled condition are being proposed for deletion.

Deletion of LCO 3.0.6 in its entirety was not proposed in the original submittal of LAR 256 because the retained portion of LCO 3.0.6 would have been rendered moot.

However, to prevent the potential for confusion regarding this specification, DEK is proposing to delete LCO 3.0.6 in its entirety.

LCO 3.0.6 As discussed in the original submittal, LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the TS.

Specification 5.5.13, "Safety Function Determination Program (SFDP)," ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation is required to determine if a loss of safety function exists. The SFDP implements the requirements of LCO 3.0.6.

LCO 3.0.6 is being proposed for deletion in its entirety in the permanently defueled TS as shown in Attachment 3. Consistent with deletion of LCO 3.0.6, a reference to LCO 3.0.6 that is contained in LCO 3.0.2 is also proposed for deletion. The TS pages provided in Attachment 3 replace the originally provided TS Pages 3.0-1 and 3.0-2.

Because 10 CFR 50.82(a)(2) prohibits operation of the plant or placing fuel in the reactor vessel, there is no longer a need for redundant safety systems. Therefore, the requirements of the SFDP, which directs cross train checks of multiple and redundant safety systems, no longer apply. As discussed in Section 5.2 of LAR 256 (Applicable Regulatory Requirements/Criteria), most of the design basis accidents and transients analyzed in USAR Chapter 14 are no longer applicable in the permanently defueled condition. After the termination of reactor operations at KPS and the permanent removal of the fuel from the reactor vessel (following 90 days of decay time after shutdown), none of the systems, structures, and components (SSCs) at KPS are required to be relied on for accident mitigation. Therefore, none of the SSCs at KPS meet the definition of a safety-related SSC stated in 10 CFR 50.2 (with the exception of the passive spent fuel pool structure).

There are no support and supported systems that remain in the proposed TS. As such, there is no longer need for a SFDP. Consequently, TS 5.5.13, SFDP, was proposed for deletion in LAR 256 so as to eliminate the administrative burden of maintaining an unnecessary program.

Serial No. 13-226B Attachment 2 Page 3 of 3 Since the requirements of the SFDP contained in TS 5.5.13 no longer apply (as described in Section T5.3 of LAR 256), the allowance provided by LCO 3.0.6 is also no longer needed and is therefore being deleted consistent with the deletion of TS 5.5.13.

4.0

SUMMARY

The allowance provided by LCO 3.0.6 is not needed for KPS which is in a permanently defueled condition. As such, it may be deleted with no impact on continued safe operation of the facility.

Therefore, deleting LCO 3.0.6 in KPS TS Section 3.0 is acceptable.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The conclusions of the no significant hazards consideration contained in Reference 1 are not affected by, and remain applicable to, this proposed change.

5.2 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements/criteria contained in Reference 1 are not affected by, and remain applicable to, this proposed change.

6.0 ENVIRONMENTAL CONSIDERATION

The conclusions of the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this proposed change.

7.0 REFERENCES

1. 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).

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

"MF0996, MF1952 - Draft RAI items being processed to you," dated August 16, 2013.

Serial No. 13-226B ATTACHMENT 3 SUPPLEMENT 1:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS MARKED UP TECHNICAL SPECIFICATIONS PAGES:

TS 3.0 (page 3.0-2), "Limiting Condition for Operation (LCO) Applicability" KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or othFr specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO" 3.0.7, and LC, 3.0.B .

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5-apA If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 DeletedWhn an L CQ is not Met and the a..ociated ACTION.S are not met, an ass9ocated ACTION is not provided, or if diroctod by the asSOciated ACTIONS, the unit shall be placod in a MODE or etho 6pecGie codiio in the LC i not applicablo. Action shall be

.-hc sinitiatod Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable,in

a. MODE 3 withiR 7 h**ur;

b. MODE 4 within 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />si and G. MODE 5 within 37 hoEurs.

&Excptions to this Specificationi aro stated in the individual Specifications.

Whore corroctiyo moasuros aro completod that permit operation in4 accordance Wi:th the9 LCO-or ACTIONS, completion; Of the; atonAR required byo LCO 3.0-3 ISnot required-.

LCO 20- is only applicable in MODES 1, 2, 3, and-4-.

I LCO 3.0.4 When an LCO is not met, entry into a MODE er eth specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE (eFet specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE Or ether specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

I Kewaunee Power Station 3.0-1 Amendment No. 2W97

LCO Applicability 3.0 3.0 LCO Applicability I=LC 3.0.4 (contitnued)

This Specification shall not prevent entry into MODES or othnr specified conditions in the Applicability that are required to comply with ACTIONS or that

. ro part of a shutdoAn of the unt.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

, *Q `3.6 When a suppo.ted .LC`system. is not mot 60191y due to a support system LCO not boin me, heCoditions and Roquirod Actions associated with this supported system are not required_ to be enterFed. Only the support system LGCO) ACr-TIO-NS are required to be entered. T-his is an exception to LCOQ 3.0.2 for the supported system. InthiS eVent, an evaluation shall be performned in accordance with Specification 5.5.13, "Safety Function Determination Program (SFrDP)." if a less of safety functio(n i detefrmined to exist by this program, the appropria-te odiin and Required ActionS of the LCO inWhich the los6 of safety fucinexi-sts are required to be When a support system's Required Action directs a SUPPorted system to be declared inoperable or directs entry into Conditions6 and Requie Actions for a supported system, the applicable Conditions6 and Required Actionsr shall be entered in accordanc~e with LCOG 3.0.2.

IGG 3.0.7Test Exception LCOG 3.1.8 allows specified Technical Specfification (T-S) requirem~ents to be changed to peFrmit performance of special tests and operations. Urless Ithet ile ,pecified, all ethr T-9 rvequ*rFeFment Fe*mai unchanged. ompliane Test Exceptin*C

,ith , *,O is optional. W "A a

,,hen Test Exception C i des-ir-ed to be ,etbutis not met.,theAC*TIONS of the Test Exce9ption LCO shall be9 Me9t. When -A Tes9t E=xception LCO isnot.

desired to be mcet, entry intoe a MOD o ether specified condition in; the Applicability s~hall be Made in accorda~nce w~ith the other applicabl SpeG~fGat~eR&,

I Kewaunee Power Station 3.0-2 Amendment No. 2407