ML14008A297

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Issuance of Amendment No. 213 - Deletion of License Conditions Associated with Extended Operations
ML14008A297
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 06/23/2014
From: Gratton C
Plant Licensing Branch IV
To: Heacock D
Dominion Energy Kewaunee
Benney B
References
TAC MF1771
Download: ML14008A297 (42)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 23, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

lnnsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

KEWAUNEE POWER STATION- ISSUANCE OF AMENDMENT TO RENEWED FACILITY OPERATING LICENSE RELATED TO LICENSE CONDITIONS ASSOCIATED WITH EXTENDED OPERATION (TAC NO. MF1771)

Dear Mr. Heacock:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 213 to Renewed Facility Operating License No. DPR-43 for.the Kewaunee Power Station.

The amendment revises the Renewed Facility Operating License in response to your application dated April 16, 2013, as supplemented by letters dated September 5, October 14, 2013, and March 19, 2014.

The amendment revises the Renewed Facility Operating License by removing the license conditions associated with license renewal and the period of extended operation. The amendment also adds a license condition that requires Dominion Energy Kewaunee, Inc. to submit a spent fuel pool storage rack neutron absorber material surveillance program for inclusion in its technical specifications if all spent fuel is not removed from the spent fuel pool by the end of 2017.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerer!LJI- *~

Christopher Gratton, Senior Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosures:

1. Amendment No. 213 to License No. DPR-43
2. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DOMINION ENERGY KEWAUNEE, INC.

DOCKET NO. 50-305

. KEWAUNEE POWER STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 213 License No. DPR-43

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Dominion Energy Kewaunee, Inc. dated April 16, 2013, as supplemented by letters dated September 5, October 14, 2013, and March 19, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, *and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; i,

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, Renewed Facility Operating License No. DPR-43 is amended as indicated in the attachment to this license amendment. In addition, paragraph 2.C.(2) of the Renewed Facility Operating License No. DPR-43 is hereby amended to read as follows:

Enclosure 1

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(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 213, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear .Reactor Regulation

Attachment:

Changes to the Renewed Facility

. Operating License Date of Issuance: June 23, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 213 RENEWED FACILITY OPERATING LICENSE NO. DPR-43 DOCKET NO. 50-305 Replace the following pages of the Renewed Facility Operating License No. DPR-43. with the attached revised pages. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

  • Renewed Facility Operating License Remove Page 3 Page 3 Page 6 Page 6

(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess

  • and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1 :*

(1) Part 20, Sec.tion 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and (2) is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and (3) is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is *authorized to operate the facility at steady-state reactor core power levels not in excess of 1772 megawatts (thermal).

- (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through

'Amendment No. 213, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection The licensee shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the licensee's Fire Plan, and as referenced in the Updated Safety Analysis Report (USAR), and as approved in the Safety Evaluation Reports, dated November 25, 1977, and December 12, 1978 (and supplement dated February 13, 1981),subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission, only if those changes would not adversely affect ttie ability to achieve and maintain safe shutdown in the event of a fire.

Renewed Operating License DPR-43 Amendment No. 213

(13} Removed Details and Requirements Relocated to Other Controlled '

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

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

(15) Deleted (16) Spent Fuel Pool Neutron Absorber Material Surveillance Programs If all spent fuel assemblies have not been removed from the spent fuel pool by December 31, 2017, the licensee shall request, prior to that date, an amendment to the license, pursuant to 10 CFR 50.90, to incorporate boron carbide and Boral surveillance programs (specified as Items 38 and 39 in Appendix A of NUREG-1958, "Safety Evaluation Report Related to the License Renewal of Kewaunee Power Station," dated January 2011) into the Technical Specifications.

Renewed Operating License DPR-43 Amendment No. 213

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO AMENDMENT NO. 213 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEE POWER STATION DOCKET NO. 50-305

1.0 INTRODUCTION

By letter dated February 25, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13058A065), Dominion Energy Kewaunee, Inc. (DEK, the licensee) submitted a certification to the U.S. Nuclear Regulatory Commission (NRC) indicating that it would permanently cease power operations at Kewaunee Power Station (KPS) on May 7, 2013.

On May 7, 2013, DEK permanently ceased power operations at KPS. On May 14, 2013, DEK certified that it had permanently defueled the KPS reactor vessel (ADAMS Accession No. ML13135A209).

By application dated April 16, 2013 (ADAMS Accession No. ML13113A368), as supplemented by letters dated September 5, 2013, October 14, 2013, and March 19, 2014 (ADAMS Accession Nos. ML13254A186, ML13294A028, and ML14079A507, respectively), DEK requested an amendment to delete renewed facility operating license conditions (LC) 2.C.(15)(a), (b), and (c) and proposed a new license condition related to the KPS spent fuel pool storage rack neutron absorber material surveillance program. LC 2.C.(15)(a) requires the incorporation of the updated safety analysis report (USAR) supplement, submitted pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 54.21 (d), into the USAR. LC 2.C.(15)(b) is related to the implementation and/or completion of license renewal programs and activities-before the period of extended operation (PEO). LC 2.C.(15)(c) is related to the testing, withdrawal, and storage of reactor vessel surveillance capsules in the reactor vessel. The proposed new license condition would require KPS to submit a spent fuel pool storage rack neutron abso.rber material surveillance program for inclusion in its technical specifications if all spent fuel is not removed from the spent fuel pool by the end of 2017.

The supplemental application letters dated September 5, 2013, October 14, 2013, and March 19, 2014, provided additional information that clarified the application, proposed a new liyense condition related to two of the original 54 renewal-related inspection activities, and did Enclosure 2

not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 20, 2013 (78 FR 51223).

2.0 REGULATORY EVALUATION

By application dated August 12, 2008 (ADAMS Accession No. ML082341020), DEK requested renewal of the KPS operating license in accordance with 10 CFR Part 54 for a period of

. 20 years beyond its December 21, 2013, expiration date. The NRC's review of the license renewal application (LRA) is contained in NUREG-1958, "Safety Evaluation Report Related to the License Renewal of Kewaunee Power Station," dated January 2011 (ADAMS Accession Nos. ML110340149 and ML110340148). Appendix A of NUREG-1958 contains a list of 54 commitments made by DEK as part of the license renewal review. These commitments are related to specific license renewal-related inspection activities, and the modification or enhancement of aging management programs (AMPs) that manage the aging effects of systems, structures, and components (SSCs) prior to and during the PEO. The NRC issued the renewed operating license for KPS on February 24, 2011 (ADAMS Accession No. ML110100575), with specific conditions related to license renewal.

LC 2.C.(15)(a) states:

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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. Until that update is complete, the licensee may make changes to the programs and activities described in the supplement without prior Commission approval, provided that the licensee evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

LC 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.

LC 2.C.(15)(c) states:

All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation. All capsules placed in storage must*be maintained for future insertion. Any changes to storage requirements must be approved by the NRC.

The first LC above requires the licensee to update the USAR with the USAR supplement that vilas provided and updated during the LRA review. The USAR supplement contains the 54 commitments listed in Appendix A of NUREG-1958. Once those commitments are incorporated into the USAR, changes may be evaluated in accordance with 10 CFR 50.59 or submitted to NRC for prior approval.

The second LC requires completion of the license renewal AMPs and activities listed in the USAR supplement in accordance with Appendix A of NUREG-1958. This LC also requires the licensee to notify the NRC when such,activities are completed.

The third LC relates to 10 CFR Part 50, Appendix H, requirements; The design of the reactor vessel surveillance capsule program and withdrawal schedule must meet the requirements in the version of ASTM Standard Practice E 185 that is current on the issue date of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) to which the reactor pressur.e vessel (RPV) was purchased. This LC requires the licensee to perform testing of the test specimens in the remaining RPV surveillance capsules in a manner that is consistent with the test procedures and reporting requirements in ASTM Standard Procedure E 185-82 to the extent practicable for the design basis and configuration of the test specimens in the surveillance capsules.

Based on the permanently shutdown and defueled status of KPS, the staff referred to Regulatory Guide (RG) 1.184, "Decommissioning of Nuclear Power Reactors," dated July 2000, for additional guidance concerning the regulatory evaluation of this LAR. As noted in RG 1.184, a permanently shutdown and defueled reactor no longer needs to maintain the functionality and operability of a majority of the plant systems. Examples provided in RG 1.184, dated July 2000, included:

  • Combustible gas control requirements (1 0 CFR 50.44)
  • Environmental qualification of electrical equipment (1.0 CFR 50.49)
  • Fracture toughness requirements for protection against pressurized thermal shock events (10 CFR 50.61)

Systems that continue to be required for the protection of public health and safety and the environment during reactor decommissioning include those systems that support spent fuel pool operation; the fire protection system; and systems for radiation monitoring and protection.

RG 1.184 also refers to other operating reactor regulations that extend to licensees that have permanently shutdown and defueled. These regulatory areas include:

Technical Specifications....:.

The NRC regulations explicitly extend requirements for specific parts of the technical specifications that will cover decommissioning activities. Decommissioning technical specifications will be developed on a case-by-case basis as stated in 10 CFR 50.36(c)(6).

The licensee will review the operational technical specifications and determine which specifications are no longer applicable and which should remain. in force. The licensee will make the appropriate submittals to request changes to the technical specifications as required by the regulations.

The Maintenance Rule -.

The regulations in 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," require monitoring the performance or condition of certain SSCs that could affect safety. For licensees that have submitted the certifications for

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cessation of operation and for permanent fuel removal specified in 10 CFR 50.82(a)(1 ), this .

section applies only to the extent the licensee monitors the performance or condition of the SSCs associated with the storage, control, and maintenance of spent fuel in a safe condition.

  • Fire Protection Requirements -

The regulations in 10 CFR 50.48(f) require licensees that have certified the permanent cessation of operations and the removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could result in a radiological hazard. The objectives of the fire protection program, delineated in 10 CFR 50.48(f)(1 ),

are to (1) reasonably prevent such fires from occurring, (2) rapidly detect, control, and extinguish fires that could result in a radiological hazard, and (3) minimize the risk of fire-induced radiological hazards to the public, environment, and plant personnel.

Maintenance of the Final Safety Analysis Report (FSAR) -

"The FSAR, or other comparable document, provides a licensing basis document for the evaluation of licensee activities under 10 CFR 50.59. This licensing basis will have to be updated to cover decommissioning activities. According to 10 CFR 50.71 (e)(4),

subsequent revisions updating the licensing basis must be filed with the NRC at least every 24 months by nuclear power facilities that have submitted certifications for permanently ceasing operations and for permanent.removal of fueL ... "

" ... during decommissioning, general updates to the FSAR to reflect the currentcondition of SSCs that were in the operating plant version of the FSAR are needed to maintain an overall understanding of the configuration basis of the plant as systems are decontaminated, inactivated, moth-balled for later use, or reconfigured to support changes to their previous functions. Even though SSCs may no longer have a safety function, there is an overall safety benefit to documenting the status or design function of these SSCs while the plant is in a decommissioning phase .... "

"As a minimum, the FSAR should be maintained at a lever of detail that provides the status of all the operating licensing-basis SSCs until the systems are no longer mechanically or electrically active, are no longer radioactively contaminated; have no fluid content or other materials that require special handling considerations, or have been physically removed during the dismantlement process."

  • According to RG 1.184, the FSAR should be updated during decommissioning to describe the structure, functions, and responsibilities of the onsite organization established to decommission the facility including the:
  • Facility description
  • Licensee organization
  • Radioactive waste management
  • Radiation protection *

~ Conduct of operations

  • Site characteristics o Any sections of the FSAR that could affect ttTe safe storage of fuel or could directly affect the design basis of the facility should be updated.
  • AcCident analysis o Any new or different design-basis accidents identified during a 10 CFR 50.59 evaluation of a planned change should be evaluated and included if appropriate.

Changes to the USAR, the KPS document comparable to an FSAR, must continue to be evaluated in accordance with 10 CFR 50.59 or submitted to NRC for prior approval throughout the decommissioning process. The 10 CFR 50.59 change process will ensure that any changes to the facility, procedures, testing methods, or analyses described in the USAR are evaluated via a structured and disciplined approach.

In an ongoing review by the staff of a separate DEK-requested license amendment to revise its Renewed Operating License Technical Specifications to Permanently Defueled Technical Specifications, dated May 29, 2013 (ADAMS Accession No. ML13156A037), the staff questioned whether two of the original 54 license renewal-related inspection activities should be elevated to a technical specification rather than remain in the USAR to be controlled under the 10 CFR 50.59 process. Specifically, the staff provided a regulatory basis for including spent fuel pool storage rack neutron absorber material into the technical specifications. The staff

  • requested additional information in an RAI dated November 11, 2013 (ADAMS Accession No. ML13312A242). The licensee's response and the staff's evaluation are documented in the assessment of commitments 38 and 39 of Section 3.2 of this Safety Evaluation.

3.0 TECHNICAL EVALUATION

In its April 16, 2013, license amendment request, the licensee proposed to delete LC 2.C.(15)(a), (b), and (c) for KPS because DEK intended to permanently cease operation of KPS prior to the PEO. On May?, 2013, KPS permanently ceased power operation. On May 14, 2013, DEK certified that it had permanently defueled the KPS reactor vessel. Had the licensee continued to operate, the PEO would have begun on December 21, 2013. The LC that the licensee requested to delete is specific to license renewal activities to manage the effects of aging, and also references commitments listed in Appendix A of NUREG-1958 and aging management activities for license renewal that have been incorporated as part of the USAR.

3.1 Technical Evaluation of the Request to Delete LC 2.C.(15)(a)'

Tl19 licensee proposed to delete LC 2.C.(15)(a) for KPS. This LC requires that the USAR supplement be incorporated in the USAR and that changes be managed in accordance with 10 CFR 50.59. DEK has satisfied Renewed Facility Operating License Condition 2.C.(15)(a),

which requires that the USAR supplement, as revised and 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 revised USAR was subsequently transmitted to the NRC as required by 10 CFR 50.71 (e). By letter dated September 20, 2011 (ADAMS Accession No. ML11271A044), the licensee submitted Revision 23 of the USAR which included the list of commitments from Appendix A of NUREG-1958. The KPS USAR has been updated to include a new Chapter 15, "Programs and Activities that Manage the Effects of Aging."

Specifically, USAR Section 15.7, "License Renewal Commitments," contains the commitments from NUREG-1958, Appendix A These actions satisfy the requirements of KPS Renewed Facility Operating License Condition 2.C.(15)(a). Since the license renewal commitments have been incorporated in the USAR, changes to these commitments may be evaluated in accordance with

~ 10 CFR 50.59 or submitted to NRC for prior approval. Additionally, the USAR will continue to govern aging-management activities during the decommissioning peri0d. Therefore, the NRC staff concludes that deletion of LC 2.C.(15)(a) is acceptable because the commitments from NUREG-1958, Appendix A have been incorporated in the USAR.

3.2 Technical Evaluation of the Request to Delete LC 2.C.(15)(b)

The licensee proposed to delete LC 2.C.(15)(b) for KPS. The purpose of this LC was to ensure that AMPs were implemented and inspection and testing activities were completed prior to or during the PEO.

The license renewal LCs were intended to ensure that licensees were prepared to enter and operate in the PEO. A licensee who has permanently ceased operation removes, in part, the need for the licensee to maintain certain aging management activities associated with reactor operation.

There are 54 commitments listed in Appendix A of NUREG-1958. All 54 of these commitments have previously been incorporated as part of KPS's USAR. Of the* 54 commitments listed in Appendix A of NUREG-1958, 29 were completed and 23 were not completed. The remaining two were deleted from Appendix A of NUREG-1958 due to changes to the work control process AMPs that were implemented prior to the issuance of NUREG-1958 (See Commitments 26 and 27). Of the 23 actions that have not been completed, eight are associated with SSCs that are being abandoned, five have implementation schedules that occur in the PEO, and ten involve aging managing activities that involve systems the licensee states no longer fall within the scope of license renewal considering the permanently shutdown and defueled status of KPS. For a reactor authorized to operate, the scope of license renewal includes safety-related SSCs, nonsafety-related SSCs that directly support the function of a safety-related sse or whose failure could prevent the performance of a required function of a safety-related SSC, and SSCs relied upon to meet fire protection, environmental qualification, pressurized thermal shock, anticipated transients without a scram, and station blackout.

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DEK has requested removal of License Condition 2.C.(15)(b) that obligates DEK to accomplish certain activities associated with the KPS renewed operating license when it was authorized to operate. Since KPS has been permanently shutdown and defueled, DEK has' not completed all the commitments that were to be accomplished prior to the PEO.

  • Furthermore, DEK states that many of the commitments to be accomplished during the PEO are also no longer applicable.

DEK states that removal of License Condition 2.C.(15)(b) will avoid any confusion concerning the use of the screening process set forth in 10 CFR 50.59 to managed changes to the license renewal commitments that have been incorporated into Section 15.7 of the USAR. Use of 10 CFR 50.59 to evaluate changes to these commitments is appropriate considering; 1)

  • the commitments listed in NUREG-1958, Appendix A have been incorporated into the KPS USAR, and; 2) the appropriate process for changing the USAR is provided in 10 CFR 50.59; and
3) License Condition 2.C.(15)(a) explicitly states that the licensee may make changes to the license renewal programs and activities without prior Commission approval, provided that the licensee evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59.

The licensee notes that most SSCs at the site are being reclassified to reflect the permanent shutdown and defueled status of the facility and would likely .no longer fall within the scope of the license renewal rule. The. license acknowledges SSCs associated with the safe storage of spent fuel may continue to be within scope of these commitments. In addition, the licensee has indicated that certain aspects of the aging management activities in the USAR may be required in accordance with other regulations and requirements associated with decommissioning, such as the maintenance rule (1 0 CFR 50.65) or fire protection (1 0 CFR 50.48(f)). Therefore, any changes to the AMPs and activities. associated with Appendix A of NUREG-1958 for safe storage of spent fuel or associated with other regulatory requirements applicable during decommissioning will be evaluated in accordance with 10 CFR 50.59 and dispositional as appropriate.

Below is the NRC staff's specific assessment of each commitment action listed in' Appendix A of NUREG-1958.

Commitment No. 1:

The ASME Code Section Xllnservice Inspection, Subsections IWB, IWC, and IWD Program will be enhanced to: (1) participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; 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.

Assessment for Commitment No. 1:

By letter dated September 5, 2013, the licensee stated that this action was completed.

Additionally, the reactor vessel internals are being abandoned because they will no longer be needed to provide a function* that supports* safe shutdown or design basis accident mitigation.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it doe~ not meet the conditions for management by LC or satisfy

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the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 2:

The ASME Code Section Xllnservice Inspection, Subsections IWB, IWC, and IWD Program will be enhanced to include identification of the limiting susceptible cast' austenitic stainless steel (CASS) reactor vessel internal components from the standpoint of thermal aging susceptibility, neutron fluence, and cracking. For each 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.*

Assessment for Commitment No. 2:

By letter dated September 5, 2013, the licensee stated that this action was completed.

Additionally, the reactor vessel internals are being abandoned because they will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 3:

The Bolting Integrity Program will be enhanced to further incorporate applicable Electric Power Research Institute (EPRI) and industry bolting guidance. Topic enhancements will include proper joint assembly, torque values, gasket types, use of lubricants, and other bolting fundamentals.

Assessment for Commitment No. 3:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is opt of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 4:

The Buried Piping and Tanks Inspection program will be enhanced to perform visual inspections of a representative sample of material/protective measure combinations for in-scope buried piping and tanks. The following materials are utilized in buried applications with the associated protective measures:

  • Steel (including cast iron)/coated,
  • Steel/coated and wrapped,
  • Steel/uncoated, and
  • Stainless steel/coated and wrapped Visual inspections of the external surfaces of the components will be performed to identify damaged wrapping (if present), degraded or damaged coating (if present), and evidence of loss of material. Each piping inspection will include a

,minimum of 10 linear feet of piping.

The following inspections will be performed:

  • The circulating water system 30 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 wrappec;:l 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 steelfuel 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 extended operation, and three additional inspections within each of the first and second 10 years of the period of extended operation. ,

Assessment for Commitment No. 4:

By letter dated September 5, 2013, the licensee stated that the portions of this action that were due to be completed prior to the PEO were completed. The activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 5:

The Compressed Air Monitoring Program will be enhanced to incorporate the compressed air system testing and maintenance recommendations from the ASME OM-S/G-1998, Part 17 and the EPRI TR-108147 and to identify these documents as part of the program basis.

Assessment for Commitment No. 5:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The licensee will assess the continued applicability of thjs commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 6:

The External Surfaces Monitoring Program will be enhanced to inspect the accessible external surfaces of in-scope components, piping, supports, structural members, and structural commodities, in the infrequently accessed areas, consistent with the criteria used in other plant areas.

Assessment for Commitment No. 6:

By letter dated September 5, 2013, the licensee stated that the program associated with this action was developed but not implemented. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor.

  • Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 7:

The External Surfaces Monitoring Program will be enhanced to provide training for operations, engineering, and health physics personnel performing the program inspections and walkdowns. The training will address: (1) the requirements ofthe 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.

Assessment for Commitment No. 7:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 8:

The Fire Protection Program will be enhanced to test a representative sample of sprinkler heads or to replace all affected sprinkler heads in accordance with the requirements of National Fire Protection Association (NFPA) 25.

Assessment for Commitment No. 8:

By letter dated September 5, 2013, the licensee stated that this action was not completed. Per

. NUREG-1958, the action needed to be completed "prior to the sprinkler heads achieving 50 years of service life." The 50 year period will end during the PEO. Therefore, the activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory

requirements for decommissioning reactors (such as fire protection. or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor.

Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.*

Commitment No. 9:

Assessment for Commitment No*. 9:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) anc:l any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50~36 for inclusion in technical specifications. As such, the staff considers inc.orporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 10:

The Fire Protection Program inspections of the reactor coolant pump oil collection system will be revised to include additional inspection criteria for the visual inspection of the system and to perform a one-time inspection of the internal surfaces of the reactor coolant pump oil collection tank.

Assessment for Commitment No. 10:

By letter dated September 5, 2013, the licensee stated that this action was completed.

Additionally, the reactor coolant pumps are being abandoned because they will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that chang~s may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 11:

The Fuel Oil Tank Inspections Program will be enhanced to provide guidance for the periodic draining, cleaning, and inspection activities.

Assessment for Commitment No. 11:

/

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59*.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59. -

  • Commitment No. 12:

The Inspection of Overhead Heavy Load and Refueling Handling Systems Program will be enhanced to clarify the requirements of visual inspection of struc~ural members, including structural bolting, of the in-scope heavy load and

  • refueling handling cranes and associated equipment.

Assessment for Commitment No. 12:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 13:

The Metal-Enclosed Bus (MEB) Program will be enhanced to include augmented periodical visual inspections of the MEB internal surfaces, bus supports, bus insulation, taped joints, and boots for signs of degradation or aging.

Assessment for Commitment No. 13:

By letter dated September 5, 2013, the licensee stated that the portions of this action that were due to be completed before the PEO were completed. The activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not

/

meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient

for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 14:

The Non-EO Electrical Cables and Connections Program will be established.

The program will periodically visually inspect for accessible electrical cables and connections installed in an adverse localized equipment environment. Should an adverse localized environment be observed, a representative sample of electrical cqbles and connections installed within that environment will be visually inspected for jacket surface anomalies.

Assessment for Commitment No. 14:

By letter dated September 5, 2013, the licensee stated that the portions of this action that were due to be completed before the PEO were completed. The activities in this commitment that were scheduled to be accomplished during the PEO *will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 15:

The Non-EO Electrical Cable Connections Program will be established. The program will perform a one-time inspection, on a sampling basis, to confirm the absence of loosening of bolted connections.

Assessment for Commitment No. 15:

By letter dated September 5, 2013, the licensee stated that this action was.not completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for q. permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion iri technical specifications. As. such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 16:

The Non-EO Inaccessible Medium-Voltage Cables Program will be establi$hed.

The program will periodically inspect the in.::-scope manholes and pulling pit for

water collection and will remove water, if required. The program will periodically perform a test on the in-scope cables to provide an indication of the condition of the conductor insulation.

Assessment for Commitment No. 16:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule} and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 17: .

The Non-EQ Instrumentation Circuits Subject to Sensitive, High-Voltage, Low-Level Signals Program will be established. The program will periodically perform a proven cable system test for detecting deterioration of the insulation system for those electrical cables and connections disconnected during calibration, or will periodically review the results and findings of calibrations fdr those electrical cables that remain connected during the calibration process.

Assessment for Commitment No. 17:

By letter dated September 5, 2013, the licensee stated that the portions of this action that were due to be completed before the PEO were completed. Additionally, the instrumentation circuits are being abandoned because they will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 18:

The Open-Cycle Cooling Water System Program will be enhanced to add the applicable aging effects as inspection criteria for the circulating water system underwater visual inspections.

Assessment for Commitment No. 18:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the ~ontinued applicability of this commitment for the safe storage of spent i.

fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 19:

The Reactor Vessel Surveillance Program will be enhanced to include the applicable limitations on operating conditions to which the surveillance capsules were exposed (e.g., neutron flux, spectrum, irradiation temperature, etc.).

Assessment for Commitment No. 19:

By letter dated September 5, 2013, the licensee stated that this action was completed. The staff notes that, since KPS is a permanently defueled facility, the licensee would no longer need to perform any enhancement of the Reactor Vessel Surveillance Program that would place limits on the operating temperature or radiation exposure levels for the surveillance capsules that remain in the RPV because: (a) the reactor will no longer be operating, and (b) the Reactor Vessel Surveillance Program requirements in 10 CFR Part 50, Appendix H, as amended by KPS LC 2.C.(15)(c), would no longer be needed or applicable to KPS as a defueled reactor facility (See Section 3.3).

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

  • Commitment No. 20:

The Reactor Vessel Surveillance Program will be enhanced to include requirements for storing, and possible recovery, of tested and untested capsules (removed from the reactor vessel after August 31, 2000).

Assessment for Commitment No. 20:

By letter dated September 5, 2013, the licensee indicated that this commitment had not yet been completed. The staff notes that, since KPS is a permanently defueled facility, there would no longer be any reason for the licensee to recover past tested RPV surveillance capsule specimens such that they would need to be reconstituted and installed back into the reactor vessel for future use. The staff has addressed radiological and physical protection requirements for the surveillance capsules that remain in the RPV in Section 3.1 of this safety evaluation.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the coQditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers

incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 21:

The Selective Leaching of Materials Program will be established. The program will perform a one-time visual inspection and hardness measurement or qualitative examination of selected components, within the scope of license renewal for selective leaching.

Assessment for Commitment No. 21:

By letter dated September 5, 2013, the licensee stated that this action was not completed. .

The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with

  • 1 0 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59. .

Commitment No. 22:

The Structures Monitoring Program will be enhanced to clearly define structures, structural elements, and miscellaneous structural commodities that are in-scope.

Defined scope to include the MEB enclosure assemblies, structural supports, and enclosure seals.

Assessment for Commitment No. 22:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC orsatisfy

  • the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 23:

I The Structures Monitoring Program will be enhanced to monitor groundwater quality and verify that it remains non-aggressive to below~grade concrete.

Assessment for Commitment No. 23:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment fbr the safe storage of spent fuel or other regulatory requir-ements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 24:

The Structures Monitoring Program will be enhanced to improve criteria for the.

detection of aging effects for the underwater visual inspections of the in-scope structures.

Assessment for Commitment No. 24:

By letter dated September 5, 2013, the licensee stated that this action was completed .. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

  • Commitment No. 25:

The Work Control Process Program will be established. The program will perform one-time inspections as a verification of the effectiveness of chemistry control programs. The program will also perform visl!al in~pections of component internal surfaces and external surfaces of selected components to manage the effects of aging when the surfaces are made available for examination through surveillance and maintenance activities.

Assessment for Commitment No. 25:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The Kewaunee Work Control Process program is a plant-specific AMP that manages the effects of aging through visual inspections completed during the performance of preventive and corrective

. maintenance and other routinely scheduled tasks. The Work Control Process program is credited in the Kewaunee aging management review results for confirmation of the effectiveness of plant system fluid chemistry control programs and for management of aging effects. The majority of one-time inspections were completed with no age related degradation

identified. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50:36 for inclusion in technical

  • specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria .set forth in 10 CFR 50.59. . . . .

Commitment Nos. 26 and 27:

Commitment Nos. 26 and 27 were deleted from NUREG-1958 Appendix A based on the licensee's Supplemental Information for the Review of the Kewaunee Power Station

Commitment No. 28:

The Metal Fatigue of Reactor Coolant Pressure Boundary Program will be enhanced to include a routine assessment of the transient cycle count totals and fatigue usage status for monitored locations, including an action limit for the initiation ofcorrective action.

Assessment for Commitment No. 28:

By letter dated September 5, 2013, the licensee stated this this *action was not completed.

However, the reactor .coolant system is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed ~sing the criteria set forth in 10 CFR 50.59.

Commitment No. 29:

The following will be further evaluated as part of the applicant's ongoing performance improvement programs:

  • SAMA [Severe Accident Mitigation Alternatives] 160:

Install Emergency Diesel Generator (EDG) exhaust duct insulation.

  • Concurrent implementation of SAMAs 81,160,166, and _167.
  • Implementation of temporary screenhouse ventilation.

Assessment for Commitment No. 29:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for managemenrby LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

  • Commitment No. 30:

Quarterly laboratory testing of fuel oil samples for water, sediment, and particulates will be performed on the EDG day tanks and on the technical support center diesel generator (TSC 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 06217 for particulates.

Assessment for Commitment No. 30:

By letter dated September 5, 2013, the licensee stated that this action was completed. The

. activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 31:

The Work Control Process Program will be enhanced to provide for a one-time-inspection of the EDG day tanks and the TSC DG day tank. An exterior surfaces ultrasonic test (UT) 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.

Assessment for Commitment No. 31:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or

the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and

. defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 32:

The 14 potentially cost beneficial SAMAs identified in LRA Appendix E, Attachment F, will be further evaluated as part of the applicant's ongoing performance improvement programs.

Assessment for Commitment No. 32:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or themaintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 33:

Develop a plan for identification and remediation of reactor refueling cavity liner leakage to be implemented during the period of extended, operation.

Assessment for Commitment No. 33:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

However, the reactor refueling cavity is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This

  • commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria.set forth

\

in 10 CFR 50.59.

Commitment No. 34:

At least one core bore sample will be taken from the waste drumming room reinforced concrete ceiling below the spent fuel pool. 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..

  • Assessment for Commitment No. 34:

( By letter dated September 5, 2013, the licensee stated this this action was completed and no degradation was detected. The licensee will assess the continued applicability of this*

commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 35:

Develop an action plan for identification and remediation of spent fuel pool (SFP) .

liner leakage to be implemented during.the period of extended operation.

Assessment for Commitment No. 35:

  • By letter dated September 5, 2013, the licensee stated that this action was completed. The activities in this commitment that were scheduled to be accomplished during the PEO will be

.evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 36:

If SFP liner leakage persists during the period of extended operation, an additional concrete core sample will be taken from the waste drumming room reinforced concrete ceiling below the spent fuel pool. 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.

Assessment for Commitment No. 36:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other

regulatory requirements for decommissioning reactors (such as fire protection or the .

maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59 ..J Commitment No. 37:

Perform a VT-1 visual examination of the stainless steel cladding of a safety injectiqn pump for indications of cracking or corrosion due to cladding breach.

Assessment for Commitment No. 37:

By letter dated September 5, 2013, the licensee stated that this action was completed.

However, the safety injection system is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR '50.59.

Commitment No. 38:

The Boron Carbide Surveillance Program, which includes neutron attenuation testing, will continue to be performed during the period of extended operation every 3 years .

Commitment No. 39:

A surveillance program will be implemented to perform verification that the Boral spent fuel storage rack neutron absorber B-1 0 areal density is maintained within the bounds of the spent fuel pool criticality analysis. Alternatively, the criticality analysis for the spent fuel pool will be revised to eliminate credit for the Boral neutron absorber material.

Assessment for Commitment Nos. 38 and 39:

In an ongoing review by the staff of a separate DEK-requested license. amendment to revise its Renewed Operating License Technical Specifications to Permanently Defueled Technical Specifications, the staff had questions about the spent fuel pool rack neutron absorber surveillance programs in commitments 38 and 39. The staff notes that Kewaunee has credited neutron absorbers in the spent fuel pool nuclear criticality safety analysis to help maintain

. subcriticality. In order to ensure that the neutron absorbers will remain within the assumptions used in the nuclear criticality safety (NCS) analysis of record (AOR), commitments 38 and 39 document surveillance programs (that are currently in place at Kewaunee or are planned to be

implemented in the near future) to identify and monitdr any degradation. These programs are (or will be) used to monitor the spent fuel storage rack neutron absorber material for degradation and confirm that the materials will perform as designed for in the NCS AOR.

The staff quest!oned whether the spent fuel pool rack neutron absorber surveillance programs in the KPS USAR (as detailed in aging management commitments numbers 38 and 39) are a sufficient regulatory mechanism to ensure that the program will continue to be implemented unaltered over a potential 60 years of additional storage of spent fuel in the SFP. The staff indicated that neutron attenuation testing of the boron absorber material may need to be elevated to a technical specification rather than remain in the USAR to be controlled under the 10 CFR 50.59 process. In a request for additional information (RAI) dated November 11, 2013 (ADAMS Accession No. ML13312A242), the staff provided a regulatory basis for including spent fuel pool storage rack neutron absorber material into the technical specifications.

By letter date.d March 19, 2014, the licensee stated the following about the Boron Carbide and Boral Surveillance Programs:

Boron Carbide [Commitment No. 38]: DEK currently has a Boron Carbide Surveillance Program iQ place for KPS.... Neutron absorption capability testing and physical inspection of SFP boron carbide plates, as required by the program, was last performed during September 2011 and indicated no abnormal degradation. The program requires

  • performance of this testing and inspection activity at three year intervals. *The next performance is scheduled to occur during the fall of 2014.
  • Boral [Commitment No. 39]: A requirement to implement a program prior to 2017 to "perform* verification that the Boral s'pent fuel storage rack neutron absorber B-1 0 areal density is maintained within the bounds of the spent fuel pool criticality analysis" is described in the KPS USAR as a direct result of NRC approval of the KPS License Renewal Amendment.

The Boral Surveillance Program required by Commitment No. 39 has not yet been implemented at KPS but is required prior to 2017. DEK stated*that this program will be implemented prior to 2017 if all spent fuel is not removed from the Boral racks. The licensee also stated:

Neutron absorbing materials in the spent fuel pool racks are subject to appropriate monitoring under the program and requirement described above. The program and requirement above will ensure that neutron absorber 'degradation is maintained within the assumptions in the criticality analysis of record and that the requirements of TS 4.3.1 are not challenged. The requirements for these programs 'were incorporated into the KPS USAR after issuance of the Renewed Facility Operating License for KPS. As such, changes to these program requirements can only be made subject to the provisions of 10 CFR 50.59.

Furthermore, DEK has recently accelerated the schedule for transfer of spent fuel from the KPSSFP to dry storage in the Independent Spent Fuel Storage Installation (ISFSI).

The new schedule projects that the SFP should be emptied of fuel assemblies by the end of 2016. As a result, performance of the upcoming boron carbide surveillance in the,

fall of 2014 is projected to be the final time that testing of SFP neutron absorbing materials will be required.

  • DEK noted that after the fuel has been removed from the spent fuel pool and transferred to the ISFSI, the 10 CFR 50.59 process will allow the elimination of these two programs without prior NRC approval.

In its March 19, 2014, letter, DEK also proposed the following new license condition related to license renewal Commitments 38 and 39. The proposed license condition reads as follows:

Spent Fuel Pool Neutron Absorber Material Surveillance Programs If all fuel assemblies have not been removed from the spent fuel pool by December 31, 2017, DEK shall request, prior to that date, an amendment to the license, pursuant to 10 CFR 50.90, to incorporate boron carbide and Boral surveillance programs (specified as Items 38 and 39 in Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," dated January 2011) into the Technical Specifications.

The staff has reviewed the DEK March 19, 2014, supplement to this license amendment request. DEK's proposed new license condition will incorporate the boron carbide and Boral neutron absorber monitoring programs from commitments 38 and 39 into the KPS technical specifications if all spent fuel assemblies have not been removed from the KPS spent fuel pool by the end of 2017. By requiring that these programs be incorporated into technical specifications, if necessary after 2017, the license condition would ensure that neutron attenuation testing of the spent fuel pool storage racks would be subject to a technical specification-required surveillance program and assure that any changes to implementation of the neutron absorber material surveillance throughout the period that spent fuel is stored in the spent fuel pool would require NRC approval.

The proposed license condition does not affect the design or use of the existing fuel racks, and therefore a new criticality analysis is not required. The proposed license condition also keeps intact the systems for the spent fuel pool needed to maintain the fuel in a subcritical condition until the fuel is permanently removed from the spent fuel pool. Therefore, the NRC staff concludes that the proposed license condition is acceptable.

Commitment No. 40:

Implement nitrate monitoring for the component cooling system on a frequency consistent with the existing monitoring for ammonia, Assessment for Commitment No. 40:

By letter dated September 5, 2013, the licensee stated that this action was completed.

Additionally, the component cooling water system is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently

shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in tec~nical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 41:

Perform a fatigue analysis of the surge line hot leg nozzle and the charging line nozzle in accordance with ASME Boiler and Pressure Vessel (B&PV) Code Section Ill, 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.

Assessment for Commitment No. 41:

By letter dated September 5, 2013, the licensee stated that this action was completed.

Additionally, the pressurizer is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor.

Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 42:

For Examination Category B-J, item No. B9.21, eightASME Class 1 small-bore circumferential welds will receive volumetric and surface examinations during each 10-year lSI inspection* interval during the period of extended operation.

Assessment for Commitment No. 42:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

l::lowever, all piping formerly classified as ASME Class 1 is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 43:

/.

Ten volumetric examinations of ASME Class 1 small-bore socket welds will be performed using a demonstrated, nuclear-industry endorsed, inspection methodology that can detect cracking within the specified examination volume, if a methodology becomes available. In the event that a demonstrated, nuclear-industry endorsed, inspection methodology is not available, destructive

examinations of socket welds will be substituted for volumetric nondestructive examinations. Each destructive weld examination will be considered equivalent to performing two volumetric weld examinations, such that a maximum of five destructive examinations will be performed.

Assessment for Commitment No. 43:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

However, all piping formerly classified as 'ASME Class 1 is being abandoned because it will no longer be needed to provide a*function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management .bY LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may

  • continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 44:

Core samples will be obtained from the inside surface of a concrete wall (below the groundwater table elevation) or from the foundation basemat in the vicinity of the groundwater wells for which average sampli!lg results have exceeded the chloride concentration limit of 500 ppm. The concrete core samples will be tested to determine if the chloride content within the concrete could cause degradation due to corrosion of reinforcing steel.

Assessment for Commitment No. 44:

By letter dated September 5, 2013, the licensee stated that this action was completed. The concrete core samples were taken as required by this commitment and no indication of degradation or corrosion of the reinforcing steel was found. The licensee will assess the continued applicability of. this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor.

Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 45:

In the event that the chloride content in the groundwater does not decrease to below 500 ppm within the first ten years of the period of extended operation, core

. samples will be obtained from the inside surface of a concrete wall (below the groundwater table elevation) or from the foundation basemat in the vicinity of a groundwater well for which average sampling results have exceeded the chloride concentration limit of 500 ppm. The concrete core samples will be tested to

determine if the chloride content within the concrete could cause degradation due to corrosion of reinforcing steel.

Assessment for Commitment No. 45:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. *Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 46:

If the results of the core sample testing of the wa.ste drumming room reinforced concrete ceiling leakage site (related to potential SFP liner leakage-Commitment 34) indicate degradation of the structural integrity of the concrete, at least one core 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.

Assessment for Commitment No. 46:

By letter dated September 5, 2013, the licensee stated that because core sample testing performed in response to commitment 34 did not indicate degradation of the structural concrete, the action for this commitment was not required and, therefore, was not completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and,any changes will be evaluated in accordance with 10 CFR 50.59.

This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed .using the criteria set forth in 10 CFR 50.59.

Commitment No. 47:

Submit three examples of operating experience associated with the Work Control Process- Internal Surfaces Monitoring Program for NRC staff review in determining the effectiveness of the program to detect and correct the effects of aging prior to the loss of function.

Assessment for Commitment No. 47:

By letter dated September 5, 2013, the licensee stated that this action was not completed. The Kewaunee Work Control Process program is a plant-specific AMP that manages the effects of aging through visual inspections completed during the performance of preventive and corrective maintenance and other routinely scheduled tasks. The Work Control Process program is credited in the Kewaunee aging management review results for confirmation of the effectiveness of plant system fluid chemistry control programs and for management of aging effects. The majority of one-time inspections were completed with no age related degradation identified. The-~

licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers

  • incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 48:

/ The cathodic protection system associated with the diesel generator fuel oil storage tanks and protected portions of the fuel oil lines, and the circulating water system recirculation piping, will each be maintained available a minimum bf 90%

of the time during the period of extended operation. In addition, NACE cathodic protection system sui"Veys will be performed at least annually during the period of extended operation.

Assessment for Commitment No. 48:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

However the SSCs described in this action will eventually be abandoned and no longer provides functions that support plant operation or shutdown. The activities in this commitment that were scheduled to be accomplished during the PEO will be evaluated for continued applicability in relation to the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 49:

Recognizing that the EPRI Steam Generator Maintenance Program (SGMP) resolution is still under 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 [primary water stress corrosion cracking] 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 Energy Kewaunee, Inc., (Dominion, DEK, or the applicant) will continue to actively participate in the EPRI SGMP studies.

Assessment for Commitment No. 49:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

However, steam generators are being abandoned because they will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers '

incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 50:

Perform an audit of the Internal Surfaces Monitoring portion of the Work Control Process Program inspections to confirm that the components representing the leading indicators of aging for each of the material/environment combinations have been inspected at least once during the audit period.

  • If any scheduled surveillance and maintenance activities which were intended to enGompass components as-leading indicators of. aging in each of the material/environment combinations have not been performed, then perform deliberate fOCl.JSed inspections of these components.

Assessment for Commitment No. 50:

By letter dated September 5,* 2013, the licensee stated that this action was not completed. The Kewaunee Work Control Process program is a plant-specific AMP that manages the effects of, aging through visual inspections completed during the performance of preventive and corrective maintenance and other routinely scheduled tasks. The Work Control Process program is credited in the Kewaunee aging management review results for confirmation of the effectiveness of plant system fluid chemistry control programs and for management of aging effects. The majority of one-time inspections were completed with no age related degradation identified. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 51:

DEK will perform a fatigue evaluation of the pressurizer lower head *and surge line that is consistent with the requirements of ASME B&PV Code, Section Ill, NB-3200 and will determine the cumulative fatigue usage through the period of extended operation.

Assessment for Commitment No. 51:

By letter dated September 5, 2013, the licensee stated that this .action was completed.

Additionally, the pressurizer is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor.

Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 52:

DEK will perform a review of design basis ASME Code Class 1 component fatigue evaluations to determine whether the NUREG/CR-6260-based components that have 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.

)

Assessment for Commitment No. 52:

By letter dated September 5, 2013, the licensee stated that this action was completed.

Additionally, all piping formerly classified as ASME Class 1 is being abandoned because it will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 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:

~ 32-

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.

Assessment for Commitment No. 53:

By letter dated September 5, 2013, the licensee stated that this action was not completed.

However, the steam generators are being abandoned b.ecause. they will no longer be needed to provide a function that supports safe shutdown or design basis accident mitigation. This commitment is not of high safety or regulatory significance for a permanently shutdown and

  • defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and that changes may continue to be managed using the criteria set forth in 10 CFR 50.59.

Commitment No. 54: .

The Structures Monitoring Program will be revised to include the evaluation criteria of ACI [American Concrete Institute] 349.3R-96, Chapter 5, as the criteria to be used when evaluating conditions or findings identified during concrete structure inspections. This will be dorie prior to the performance of the next scheduled inspection,* which will-occur prior to the period of extended operation.

Assessment for.Commitment No. 54:

By letter dated September 5, 2013, the licensee stated that this action was completed. The licensee will assess the continued applicability of this commitment for the safe storage of spent fuel or other regulatory requirements for decommissioning reactors (such as fire protection or the maintenance rule) and any changes will be evaluated in accordance with 10 CFR 50.59.

J This commitment is not of high safety or regulatory significance for a permanently shutdown and defueled reactor. Therefore, it does not meet the conditions for management by LC or satisfy the criteria of 10 CFR 50.36 for inclusion in technical specifications. As such, the staff considers incorporation into the USAR sufficient for this commitment and thate changes may continue to be

. managed using the criteria set forth in 10 CFR 50.59.

3.3 Technical Evaluation of the Request to Delete LC 2.C.(15)(c)

  • In DEK's license amendment request, the licensee proposed to delete LC 2.C.(15)(c) for KPS because DEK will have permanently ceased operation of KPS prior to the PEO. LC 2.C.(15)(c) has a direct impact on the licensee's activities for implementing its Reactor Vessel Surveillance Program, which is the AMP that is based on the 10 CFR Part 50, Appendix H, requirements and is used (in part) to manage loss of fracture toughness due to neutron irradiation embrittlement in RPV components that are made from ferritic steel materials (i.e., carbon steel or alloy steel materials).

In NUREG-1958, the NRC staff approved the KPS Reactor Vessel Surveillance Program based on verification that the AMP, when coupled to the licensee's time-limited aging analys~s (TLAAs) for RPV neutron irradiation embrittlement, 1 would adequately manage the loss of fracture,toughness due to neutron irradiation embrittlement in RPV components made from ferritic steel materials.

When the NRC staff issued Renewed Operating License DPR-43 in February 24, 2011, the staff included LC 2.C.(15)(c) in order to impose some additional RPV surveillance capsule storage, testing, and reporting requirements that were deemed necessary for extended operation of the reactor (i.e., during uie 20 years of additional licensed power operations). Specifically, the NRC staff determined that LC 2.C.(15)(c) was necessary because the staff had determined that: (a)

ASTM Standard Practice E 185-82, as invoked by the 10 CFR Part 50, Appendix H rule, was limited to a 40-year licensed operating life, and (b) the additional LC requirements were necessary to er:1sure that the intent of the ASTM requirements would continue to be implemented as part of the Reactor Vessel Surveillance Program during the additional 20 years of licensed operations at power. However, the NRC staff imposed LC 2.C.(15)(c) on theassumption that DEK would be operating the KPS facility for an additional 20 years (i.e., to and inclusive of December 21, 2033) and would not be proposing to end power operations of the facility prior to that date.

The requirements in 10 CFR Part 50, Appendix H are only relevant to those U.S. nuclear plants that are authorized to operate in the reactor-critical operating mode because: (a) this is the plant operating mode that produces high energy neutrons as a result of the reactor's nuclear fission process, and (b) the requirements are set in place to provide assurance that the RPV will maintain adequate levels of fracture toughness throughout the operating life of the reactor. This basis also is valid for KPS LC 2.C.(15)(c) because the LC was imposed to modify the requirements that would be applicable to the licensee's implementation of its Reactor Vessel Surveillance Program and to ensure that the intent of 10 CFR Part 50, Appendix H,. would be met for the PEO.

These TLAAs include the licensee's TLAAs for:

(a) protecting the RPV against postulated pressurized thermal shock (PTS) events, as mandated by the requirements in 10 CFR 50.61,

. (b) ensuring that the RPV will have adequate Charpy-impact upper shelf enE)rgy (USE) during the

.period of extended operation, as mandated .by the requirements in 10 CFR Part 50, Appendix G, and (c) ensuring that the licensee's pressure-temperature (P-T) limit curves and setpoints for activating the Low Temperature Overpressure Protection (LTOP) System will have adequate safety margins, as mandated by the requirements in 10 CFR Part 50, Appendix G.

The NRC staff has determined that continued implementation of the applicable surveillance capsule testing and reporting requirements in LC 2.C.(15)(c) is no longer necessary for KPS because:

(a) the licensee ceased power operations of KPS, and (b) from a fracture toughness perspective, the KPS RPV will cease to be exposed to further irradiation by high energy neutrons or be subjected to any high thermal stress environments, as induced by operating the RCS at an elevated temperature. 2 Instead, the staff notes that physical and radiological control of the remaining surveillance capsules that are located in the RPV will be managed in accordance with the applicable radiological control requirements of 10 CFR Part 20 and 10 CFR Part 30 and with any applicable security or physical protection requirements for components in either 10 CFR Part 37 or 10 CFR Part 73.

Thus, the NRC staff concludes that the removal, testing, reporting, and storage requirements for reactor vessel surveillance cap$ules and their test specimens in LC 2.C.(15)(c) do not need to be implemented further since the licensee has permanently ceased power operations of the KPS reactor. At this point, there is no longer any need to remove the remaining surveillance capsules from the RPV or perform material testing of the test specimens in those capsules. As such, the NRC staff concludes that LC 2.C.(15)(c) may be deleted from Renewed Operating License DPR-43.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Wisconsin State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20, or changes a surveillance requirement. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding, which was published in the Federal Register on August 20, 2013

  • (78 FR 51223). Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment. *

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations/ and (3) the issuance of this 2 For power operations of Westinghouse-designed PWRs, the RCS hot-leg temperature is in excess of 600 °F

amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: H. Jones, NRR/DLR/RSRG J. Medoff, NRR/DLR/RARB D. Cunanan, NRR/DSS/SRXB Date: June{ 23, 2014

..* ML14008A297 *via memorandum OFFICE NRRILPL4-2/PM NRR/LPL4-2/PM NRRILPL4-2/LA NRR!DLR/RSRS/BC** NRR/DLR/RARB/BC NAME WHuffman CGratton MHenderson BPham* DMorey*

DATE 03/25/14 02/11/14 02/04/14 12/16/13 12/30/13 OFFICE NRR!DSS/SRXB OGC I NLO NRR/LPL4-2/BC NRR/LPL4-2/PM NAME CJackson JWachutka DBroaddus CGratton DATE 03/28/14 04/03/14 06/23/14 06/23/14

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