ML14009A393

Supplement 2: License Amendment Request 256, Permanently Defueled License and Technical Specifications

ML14009A393
Person / Time
Site:	Kewaunee
Issue date:	01/07/2014
From:	Mark D. Sartain Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226F
Download: ML14009A393 (9)

Text

Dominion Energy Kewatnee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Web Address: www.dom.com January 7, 2014 U. S. Nuclear Regulatory Commission Serial No. 13-226F Attention: Document Control Desk LIC/CDS/RO Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION SUPPLEMENT 2: LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant. Supplement 1 to the amendment request was submitted on October 15, 2013 (Reference 2).

The subject amendment request proposed deletion of the cyber security provisions contained in License Condition 2.C.(4). The proposed deletion of this portion of License Condition 2.C.(4) was based on DEK's conclusion that the requirements of 10 CFR 73.54, "Protection of digital computer and communications systems and networks," no longer applied to KPS. However, the NRC staff recently verbally informed DEK (Reference 3) that 10 CFR 73.54 continues to apply to facilities that were licensed to operate on November 23, 2009. November 23, 2009 was the date by which all licensees licensed to operate a nuclear power plant were required to submit a cyber security plan to the NRC for review and approval.

In response to the staffs comments, DEK is revising the originally proposed amendment request. The revised request retracts the original proposal to delete the cyber security provisions contained in License Condition 2.C.(4), which will result in this license condition remaining unchanged. Attachment 1 to this letter provides a supplement to the proposed amendment describing the revision. Attachment 2 contains the marked-up License page affected by this revision. The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this revision.

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

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

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Development COMMONWEALTH OF VIRGINIA ))

COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Development of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 7__"___ day of jv, Art$ ,2014.

My Commission Expires: Iei zid, N/otary rubbric CRAIG D SLY Notary Public Commonwealth of Virginia Reg. # 7518653 My Commission Expires December 31, 20, Attachments:-. - ... .....

1. Discussion of Change and Technical Analysis

2. Marked-up License Page 4

References:

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

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated October 15, 2013. (ADAMS Accession No. ML13294A091)

3. Teleconference between NRC staff and DEK representatives regarding applicability of 10 CFR 73.54, "Protection of digital computer and communication systems and networks," to Kewaunee Power Station, on November 13, 2013.

Serial No. 13-226F LAR 256 Supplement 2 Page 3 of 3 cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Dr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 Mr. W. C. Huffman Jr., Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

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

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

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

1.0 DESCRIPTION

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

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant. Supplement 1 to the amendment request was submitted on October 15, 2013 (Reference 2).

The subject amendment request proposed deletion of the cyber security provisions contained in License Condition 2.C.(4). The proposed deletion of this portion of License Condition 2.C.(4) was based on DEK's conclusion that the requirements of 10 CFR 73.54 no longer applied to KPS. 10 CFR 73.54 specifies requirements for protection of certain types of digital computer and communication systems and networks against cyber attack. The preamble of this regulation states that by November 23, 2009, each licensee currently licensed to operate a nuclear power plant shall submit a cyber security plan for Commission review and approval. DEK fulfilled this requirement prior to November 23, 2009, as required by the regulation. Subsequently, DEK submitted a certification of permanent removal of fuel from the reactor vessel (Reference 3) pursuant to 10 CFR 50.82(a)(1)(ii) by letter dated May 14, 2013. As a result, the 10 CFR Part 50 license for KPS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

Based on the above, DEK concluded that 10 CFR 73.54 was no longer applicable to KPS since 10 CFR 73.54 states that the requirement to submit a cyber security plan is required only for "each licensee currently licensed to operate a nuclear power plant" (DEK is no longer authorized to operate the KPS reactor). However, the NRC staff recently verbally informed DEK (Reference 4) that 10 CFR 73.54 continues to apply to facilities that were licensed to operate on November 23, 2009.

In response to the staffs comments, DEK is revising the originally proposed amendment request. The revised request retracts the original proposal to delete the cyber security provisions contained in License Condition 2.C.(4). The proposed retraction will result in this license condition remaining unchanged. Attachment 2 contains the marked-up License page affected by this proposed change to the amendment request. The conclusions of the no significant hazards consideration and

Serial No. 13-226F Attachment 1 Page 2 of 3 the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this proposed change.

2.0 PROPOSED CHANGE

The originally proposed request to delete the second paragraph of License Condition 2.C.(4), regarding cyber security provisions, is being retracted. This paragraph will be maintained unchanged as shown below.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approvedKewaunee, Millstone, North Anna, and Surry Power Stations Cyber Security Plan (CSP), including changes made pursuant to the authorityof 10 CFR 50.90 and 10 CFR 50.54(p). The CSP was approved by License Amendment No. 210.

3.0 TECHNICAL ANALYSIS

Retraction of the originally proposed change results in no change being proposed to the currently existing second paragraph of License Condition 2.C.(4), regarding cyber security provisions. License Condition 2.C.(4), "Physical Protection," is therefore being maintained unaltered in its entirety. Maintaining this license condition unchanged has no impact on the remainder of the changes proposed in LAR 256 (Reference 1).

4.0

SUMMARY

DEK proposes that License Condition 2.C.(4), "Physical Protection," be maintained unchanged.

5.0 REGULATORY ANALYSIS

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

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

Serial No. 13-226F Attachment 1 Page 3 of 3

6.0 ENVIRONMENTAL CONSIDERATION

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

7.0 REFERENCES

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

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated October 15, 2013. (ADAMS Accession No. ML13294A091)

3. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Removal of Fuel from the Reactor Vessel," dated May 14, 2013.

(ADAMS Accession No. ML13135A209)

4. Teleconference between NRC staff and DEK representatives regarding applicability of 10 CFR 73.54, "Protection of digital computer and communication systems and networks," to Kewaunee Power Station, on November 13, 2013.

Serial No. 13-226F ATTACHMENT 2 SUPPLEMENT 2:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS MARKED UP LICENSE PAGE 4 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

(4) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21 is entitled:

"Nuclear Management Company Kewaunee Nuclear Power Plant Physical Security Plan (Revision 0)" submitted by letter dated October 18, 2004, and supplemented by letter dated October 21, 2004, July 26, 2005, and May 15, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Kewaunee, Millstone, North Anna, and Surry Power Stations Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The CSP was approved by License Amendment No. 210.

(5) Deleted (6) DeletedSteam Generator

- Wow Lateral Sup..,ts The design of the steam generator upper lateral supports may be modified by reducing the number of snubbersi from four (4)to one (1)per steam

( eneDated.

(7) Deleted (8) Deleted (9) Deleted (10) Deleted M..tpat0. .

Stato. Licen.e Condition Develop and maintain strategies for addressing large fires and explosions and that finclude the following key areas:

(a) Fire fighting response strategy With the- folloingdR elements:.

1. Pre df*ined coordinated firs*Ir*epose strategy and guidan*e

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and conrol1

5. Training of response personnel Renewed Operating License DPR-43