ML14126A005

Supplement 4 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications

ML14126A005
Person / Time
Site:	Kewaunee
Issue date:	04/29/2014
From:	Mark D. Sartain Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226H, LAR 256, Suppl 4
Download: ML14126A005 (19)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Web Address: vwww.dom.com April 29, 2014 U. S. Nuclear Regulatory Commission Serial No. 13-226H 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 4 AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant. The application was supplemented on October 15, 2013 (Reference 2), January 7, 2014 (Reference 3), and March 13, 2014 (Reference 4).

During discussions with the Nuclear Regulatory Commission (NRC) staff (Reference 5),

the staff requested changes to certain portions of the proposed TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program." Additionally, the NRC transmitted a request for additional information (RAI) regarding DEK's proposed removal of License Condition 2.C.(10), "Mitigation Strategy License Condition" (Reference 6).

The RAI question and associated DEK response is provided in Attachment 1 to this letter. to this letter provides a supplement to the proposed amendment addressing the staffs requested changes. 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 supplement. Attachments 3 and 4 provide markups of the Operating License and TS pages, respectively, for the proposed changes.

The originally requested June 1, 2014, approval date remains unchanged.

Aoo/

Serial No. 13-226H LAR 256 Supplement 4 and RAI Response Page 2 of 3 Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering 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 of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this day of A , 204 My Commission Expires: "ecayA4er 3 I. ZZIl -

'Not~aryPuhlig Attachments: I Notary Public Commonwealth of Virginia

1. Response to Request for Additional Information Reg. # 7518653

2. Discussion of Change and Technical Analysis

3. Marked Up License Pages

4. Marked Up Technical Specifications Pages

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 I 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 Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 2: License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated January 7, 2014. (ADAMS Accession No. ML14009A393)

Serial No. 13-226H LAR 256 Supplement 4 and RAI Response Page 3 of 3

4. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 3: License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated March 13, 2014. (ADAMS Accession No. ML14084A384)

5. Teleconference between NRC staff and DEK representatives regarding final review status of certain portions of Kewaunee Power Station Permanently Defueled Technical Specifications on February 24, 2014.

6. Email from William C. Huffman, Jr. (NRC) to Jack Gadzala (DEK) et al, "Draft RAI related to Kewaunee proposed deletion of License Condition on Mitigation Strategy," dated April 1, 2014.

Commitments made by this letter: None cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. W. C. Huffman Jr., Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Dl 5 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Christopher Gratton, Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Dl 5 11555 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 13-226H ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

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

Serial No. 13-226H Attachment 1 Page 1 of 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

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

(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) to Permanently Defueled Technical Specifications (PDTS), consistent with the permanently defueled status of the plant. The application was supplemented on October 15, 2013 (Reference 2), January 7, 2014 (Reference 3), and March 13, 2014 (Reference 4).

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed removal of License Condition 2.C.(10), "Mitigation Strategy License Condition," in the amendment (Reference 5). The RAI question and associated DEK response is provided below.

NRC Question The licensee is requesting to remove License Condition 2.C.(10), "Mitigation Strategy License Condition," from the license. This License Condition requires the licensee to develop and maintain strategies for addressing large fires and explosions. As stated in the amendment request, in accordance with 10 CFR 50.54 (hh)(3), the requirements in 10 CFR 50.54(hh)(2) will not apply after both certifications have been filed under 10 CFR 50.82.

The Commission added 10 CFR 50.54(hh)(3) in the Power Reactor Security Requirements final rule in response to a comment that the requirements of 10 CFR 50.54(hh) should not apply to "reactor facilities currently in decommissioning and for which the certifications required under 10 CFR 50.82(a)(1) have been submitted" because "it is inappropriate that 10 CFR 50.54(hh) should apply to a permanently shut-down and defueled reactor where the fuel was removed from the site or moved to an

[ISFSI]." 74 Fed. Reg. 13933 (Mar. 27, 2009) (emphasis added). The NRC stated in the Statement of Considerations for the final rule that it "agree[d] with this comment and revised the final requirements in 10 CFR 50.54(hh) so they do not apply to facilities for which certifications have been filed under 10 CFR 50.82(a)(1) or 10 CFR 52.110(a)(1)."ld. The NRC staff position expressed in this Statement of Considerations does not express a conclusion that continued storage of fuel in the spent fuel pool of a reactor facility without the mitigating strategies would provide reasonable assurance that the health and safety of the public would not be endangered and would not be inimical to the common defense and security, which is necessary to conclude that amendment of License DPR-43 to remove License Condition 2.C.(10) would be appropriate.

Serial No. 13-226H Attachment 1 Page 2 of 4 While the plain language of 10 CFR 50.54(hh)(3) exempts all facilities that have submitted cessation of operation certifications without regard to whether there is still fuel onsite that is not in an ISFSI - i.e., fuel in the pool, NRR has recognized that this may not be a proper resolution of the comment to the Power Reactor Security Rulemaking and currently is considering rulemaking to affect changes to apply the 10 CFR 50.54(hh)(2) requirements to decommissioning facilities with fuel still in the spent fuel pool.

Given that the licensee must continue to provide adequate emergency response under 10 CFR 50.47, and that the spent fuel must be protected against the design basis threat of radiological sabotage under 10 CFR 73.55, for each element of the License Condition 2.C.(10), provide justification that elimination of that element will not result in operations that would endanger the health and safety of the public or be inimical to the common defense and security, or otherwise, indicate that the element will be maintained in effect:

2.C.(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

Serial No. 13-226H Attachment 1 Page 3 of 4

Response

DEK proposes that all 14 elements of License Condition 2.C.(10), "Mitigation Strategy License Condition," be maintained in effect. The proposed changes in the original application (Reference 1) included deletion of License Condition 2.C.(10). This license condition provides mitigation strategy and response procedure requirements for loss of large areas of the plant due to large area fires and explosions. The proposed deletion of this license condition was based on 10 CFR 50.54(hh)(3), which states that 10 CFR 50.54(hh) no longer applies to a permanently defueled reactor that has submitted the certifications under 10 CFR 50.82(a).

Based on 10 CFR 50.54(hh)(3), DEK concluded that 10 CFR 50.54(hh) was no longer applicable to KPS, since DEK had submitted the certifications required by 10 CFR 50.82(a). However, the statements in the NRC's RAI (Reference 5) indicate that the 50.54(hh) mitigating strategies should continue to apply to plants who have submitted the certifications under 50.82(a) but that continue to store spent fuel in the spent fuel pool. Therefore, a license condition for mitigation strategies associated with the spent fuel pool continues to be necessary because spent fuel assemblies are currently being stored in the KPS spent fuel pool.

In response to the staffs comments, DEK is retracting the originally proposed deletion of License Condition 2.C.(10). As a result, DEK proposes that License Condition 2.C.(10) remain in effect and unchanged.

The 14 elements contained in License Condition 2.C.(10) require strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities as described in the NRC safety evaluation (SE) that provided the basis for issuance of the license condition (Reference 6). For a permanently defueled facility, strategies to maintain or restore core cooling and containment capabilities are no longer required.

As discussed in the NRC RAI (Reference 5), the remaining purpose of this license condition is to require administrative controls for spent fuel pool mitigation strategy while spent fuel assemblies are stored in the spent fuel pool (consistent with the statements regarding the intent of 10 CFR 50.54(hh)).

The SE that issued License Condition 2.C.(10) (Reference 6) described the appropriate process for changes to the underlying implementing details of the required mitigating strategies. It contains, inter alia, the following two statements.

1. The required strategies for all three phases would be covered by the license condition and all implementing details would be managed by NEI 99-04

[commitment management process].

2. If the licensee makes future changes to its strategies within its commitment management program, this SE will be useful to the NRC staff in determining if the changed strategies are adequate to meet the license condition.

Serial No. 13-226H Attachment 1 Page 4 of 4 As such, those measures that are no longer necessary considering the permanently defueled status of the facility may be appropriately changed using the process described in the SE. Those mitigation strategy measures needed to protect the spent fuel pool will continue to be required by License Condition 2.C.(10). contains a supplement to the proposed amendment which requests that License Condition 2.C.(10) be maintained as it currently exists.

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 Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 2: License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated January 7, 2014.

4. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 3: License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated March 13, 2014. (ADAMS Accession No. ML14084A384)

5. Email from William C. Huffman, Jr. (NRC) to Jack Gadzala (DEK) et al, "Draft RAI related to Kewaunee proposed deletion of License Condition on Mitigation Strategy," dated April 1, 2014.

6. Letter (and enclosed Safety Evaluation) from Margaret H. Chernoff (NRC) to David A. Christian (DEK), "Kewaunee Power Station - Conforming License Amendment to Incorporate the Mitigation Strategies Required by Section B.5.b. of Commission Order EA-02-026 (TAC NO. MD4543)," dated August 2, 2007.

Serial No. 13-226H ATTACHMENT 2 SUPPLEMENT 4:

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. 13-226H Attachment 2 Page 1 of 4 SUPPLEMENT 4 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. The application was supplemented on October 15, 2013 (Reference 2), January 7, 2014 (Reference 3), and March 13, 2014 (Reference 4).

As recently discussed with NRC staff (Reference 5), and in a subsequent request for additional information (Reference 6), the staff requested changes to certain portions of the proposed Technical Specifications regarding TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program," and to the proposed license regarding License Condition 2.C.(10), "Mitigation Strategy License Condition."

This supplement to the proposed amendment addresses the staff's requested changes.

Attachments 3 and 4 provide markups of the Operating License and TS pages, respectively, reflecting the proposed changes.

2.0 PROPOSED CHANGE

License Condition 2.C.(10), "Mitigation Strategy License Condition" The originally proposed request to delete the second paragraph of License Condition 2.C.(10), regarding mitigating strategy provisions, is hereby retracted. This paragraph will be maintained unchanged as shown below.

(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting Response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

Serial No. 13-226H Attachment 2 Page 2 of 4

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders contains the marked-up License page affected by this revision.

Indicated revisions to other sections appearing on this license page in Attachment 2 are shown as previously proposed in the original request (Reference 1), as supplemented by Reference 3, and remain marked up for consistency with these previous submittals.

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.

TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program" During a discussion with NRC staff (Reference 5), the staff requested changes to certain portions of the proposed Technical Specifications. Specifically, the staff requested that portions of the Explosive Gas and Storage Tank Radioactivity Monitoring Program, currently required by TS 5.5.10, be maintained to the extent required to support storage of liquid radioactive waste that might be generated in the future.

In response to the staff's comments, DEK is revising the originally proposed amendment. Rather than deleting TS 5.5.10 in its entirety, the revised request maintains the portions of the program to the extent required to support storage of liquid radioactive waste that might be generated in the future. contains the marked-up TS pages affected by this revision. Proposed additions to the currently existing TS 5.5.10 are shown in underlined text. Deletions are shown in strikethrough text. Indicated revisions to other sections appearing in are shown as previously proposed in the original request (Reference 1) and remain marked up for consistency with previous submittals.

Serial No. 13-226H Attachment 2 Page 3 of 4 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.

3.0 TECHNICAL ANALYSIS

License Condition 2.C.(10), "Mitigation Strategy License Condition" Retraction of the originally proposed change results in no change being proposed to the currently existing License Condition 2.C.(10), "Mitigation Strategy License Condition."

License Condition 2.C.(10) is therefore being maintained as it currently exists.

Maintaining this license condition unchanged has no impact on the remainder of the changes proposed in LAR 256 (Reference 1).

TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program" The technical analysis for this revision is unchanged from that provided in LAR 256 (Reference 1). The original justification for deletion of TS 5.5.10 in its entirety remains applicable to the partial deletion being proposed herein.

KPS is a permanently shutdown facility with spent fuel stored in the spent fuel pool and independent spent fuel storage installation (ISFSI). The reactor coolant system (RCS) has been drained and vented. 10 CFR 50.82(a)(2) prohibits operation of the reactor or placement or retention of fuel into the reactor vessel. Consequently, there is no longer a continuing source of radioactive gases being produced to contribute to the contents of storage tanks (which was the purpose of this program).

Although KPS currently has no outdoor liquid radwaste tanks, maintaining the existing portions of this program that are applicable to such tanks would ensure that appropriate controls remain in place should such tanks be constructed and placed into service in the future.

4.0

SUMMARY

License Condition 2.C.(10), "Mitigation Strategy License Condition," is being maintained unchanged.

The revisions being proposed in this supplement to TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program," ensure appropriate requirements for administrative controls.

These supplemental changes have no impact on the remainder of the changes proposed in LAR 256 (Reference 1), as supplemented.

Serial No. 13-226H Attachment 2 Page 4 of 4

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 RequirementslCriteria The applicable regulatory requirements/criteria contained in Reference 1 are not affected by, and remain applicable to, this proposed change.

6.0 ENVIRONMENTAL CONSIDERATION

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

7.0 REFERENCES

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

2. 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 Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 2: License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated January 7, 2014. (ADAMS Accession No. ML14009A393)

4. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 3: License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated March 13, 2014

5. Teleconference between NRC staff and DEK representatives, regarding final review status of certain portions of Kewaunee Power Station Permanently Defueled Technical Specifications, on February 24, 2014

6. Email from William C. Huffman Jr (NRC) to Jack Gadzala (DEK) et al, "Draft RAI related to Kewaunee proposed deletion of License Condition on Mitigation Strategy," dated April 1, 2014.

Serial No. 13-226H ATTACHMENT 3 SUPPLEMENT 4:

LICENSE AMENDMENT REQUEST 256 PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS MARKED UP LICENSE PAGES 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) Deleted~t a

................. ........... p ...

The design of the steam generator upper lateral 6upportS may be modified by reducing the numnber of snubberS from four (4) to one (1) per 6etam ge*'aF INOTE: Deletion of License Condition 2.C.(6)

(7) Deleted is justified separately in LAR 256.

(8) Deleted (9) Deleted (10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting Response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. command and control

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

(b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (11) Seismic Analysis Methodology for Auxiliary Building Crane The licensee shall use the seismic analysis methodology submitted by letter dated July 7, 2008, supplemented on September 19, 2008, and March 17, 2009, and approved by the NRC staff in Amendment No. 205, for analysis of the Auxiliary Building crane. The licensee shall update the USAR to reflect this approval and in accordance with the schedule specified by 10 CFR 50.71(e).

(12) Implementation of New and Revised Surveillance Requirements (a) For Surveillance Requirements (SRs) that are new in Amendment No. 207, the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of that amendment.

(b) For SRs that existed prior to Amendment No. 207 whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of that amendment.

(c) For SRs that existed prior to Amendment No. 207 that have modified acceptance criteria, the first performance subject to the modified acceptance criteria is due at the end of the surveillance interval that began on the date the surveillance was last performed prior to the implementation of that amendment.

(d) For SRs that existed prior to Amendment No. 207 whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of that amendment.

Renewed Operating License DPR-43

Serial No. 13-226H ATTACHMENT 4 SUPPLEMENT 4:

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

4 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Ventilation Fiblter T-estingProgramn (VF=TP) (continued)

d. Demonrate foreach of the safety related systems listed below that the ppresure droap across the combined HERA filters, the prefilters, and the charcoal adserborc is,less than the value specified below when tested in accordance with ANSI N510 1975 at the system floWrate 6pecified below NOTE: Deletion of TS 5.5.9 is justified G separately in LAR 256.

Safety Related- Sste Flow Rat cm SBVS - 6.3 5700 ASV System "6.3 9000 GRPAR System 42.4 -2500-

e. Demonstrate for each of the safety related systems listed below that when tested at the system floWrato specsified below (!k 10%0,) the air distribution i uniforFm. Within A!20%.

Safety Related- S-ystem! Flow Rat cm SBVS 5700 ASV System 9000 The provIision of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP ts

1. qen~ieer.

5.5.10 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mi+xtures contained in the Gaseous Radioactive Waste Disposal System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system+ and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The gaseous rad*ioact4ivty quantities shall be deter;mied following the methodology in Branch Technical Position (3T-P) ETSB9 11 5, Pos6tulae Radio.ive Relea.se due to Was.te Gas System Leak or Failure." The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures."

The program shall include:

a. The limlits for concentrations of hydrogen and oxygen in the Gaseous Radioactive Waste Disposal System and a 6urveillance progaram to ensure the limits are mnaintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion);

Kewaunee Power Station 5.5-9 Amendment No. 207

TABLE OF CONTENTS Page Number 5.5.10 Explosive Gas and Stoagae Tank RadioactivitY MonGitoring Programn (continucd)

b. A surveillance program to ensure that the quantity of radioactivity contained ineach gas 6torage tank and fed into the effgas treatm~ent system is less than the amount that would result in a whole body exposure of . 0.51-r1m to any individual in an unr~estricted area, in the event of an uncontrolled releasse of the tank's contents; and es%-A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Waste Disposal System is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program Surveillance Frequencies.

1 5.5.11 outdooriqui inlltd~e radwste akohtae o uruddbylnrdks A diesel fuel oil testing progaram to implement required testing of both new fuel oil and stored fuel oil shall be established. The programn shall include sampling and testing requfirements, and acceptance criteria, all in accordance with applicable ASTIV Standards. The purpose of the program is to establish the following:

I I I IIIw I to suorage I I I NOTE: Deletion of TS 5.5.11 is justified i , Re r"nrior 6e4-Y to

................. ae4A +9R tRinS "'1 separately in LAR 256.

1. An API gravity or an absolute specific gravity within limits; I iI *il I im II f A* I I A* f I II P. A. tilh point and ki vi-sacosity withir Ilmits for A*TI 2D fuel 9i141" and

3. A clear and bright appearance with proper color Or a water and sediment conRtent within limits;

b. W~ithin 31 days following addition of the new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a.,

above, ae woith;in INMia ts fo-r- AST*MAA 2)D fuel o*li; a*d G. Total particulate concentration of the fuel oil is!!* 10 mng/I when tested every The prevision-*s, ofR-R 3.0.2 aRd SR 3.0.3 aro applicable to the Diesel Fuel Oil T-esting Programn test frequencies-.

I Kewaunee Power Station 5.5-10 Amendment No. 207