Text

License Amendment Request 260, Proposed Changed to License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pool
	ML15261A236
Person / Time
Site:	Kewaunee
Issue date:	09/14/2015
From:	Clark G; Dominion, Dominion Energy Kewaunee
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	15-185
	Download: ML15261A236 (53)
	v • d • e

A! Dominion EnryKewaunee, Inc.

-'500omiionBoulevard, Glen Allen, VA 23060 Domnio omn n Web Address: www.dom.com September 14, 2015 ATTN: Document Control Desk Serial No. 15-1 85 U. S. Nuclear Regulatory Commission LIC/JG/R0 Washington, DC 20555-0001 Docket Nos. 50-305; 72-64 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST 260. PROPOSED CHANGES TO LICENSE AND TECHNICAL SPECIFICATIONS TO REFLECT PERMANENT REMOVAL OF SPENT FUEL FROM SPENT FUEL POOL Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the Operating License and associated Technical Specifications (TS) to reflect removal of all KPS spent nuclear fuel from the spent fuel pool and its transfer to dry cask storage within an Independent Spent Fuel Storage Installation (ISFSI).

By letter dated May 14, 2013 (Reference 1), DEK submitted a certification of permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii). Therefore, 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. The Post-Shutdown Decommissioning Activities Report (PSDAR) for KPS dated April 25, 2014 (Reference 2), documented that DEK expects to have all spent fuel transferred to the ISFSI by the end of 2016. In support of this condition, the KPS license and associated TS are being proposed for revision to comport to facility configuration with all spent nuclear fuel in dry storage within an ISFSI.

Attachment 1 to this letter contains a description, technical analysis, significant hazards determination, and environmental considerations evaluation for the proposed amendment. Attachment 2 contains marked-up TS pages (TS sections that are deleted in their entirety are identified as such, but the associated deleted pages are not included in Attachment 2). There are no TS Bases pages associated with the proposed TS.

As discussed in this submittal, the remaining design basis accidents and transients analyzed in Chapter 14 of the KPS Updated Safety Analysis Report (USAR) are no longer applicable for the condition where all spent nuclear fuel is transferred to dry cask storage within an ISFSI.

The KPS Facility Safety Review Committee has reviewed the proposed amendment and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91(b). *** *=

Serial No.15-185 License Amendment Request 260 Page 2 of 3 DEK requests approval of the proposed amendment by August 31, 2016. Once approved, the amendment will be implemented within 60 days following DEK's submittal of a written certification to the NRC that all spent nuclear fuel assemblies have been transferred out of the spent fuel pool and placed in storage within the ISFSI.

Please contact Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Gianna C. Clark l

4*

-Vtcki-L.-Huil

'OTARYPUBLIC

'" I Vice President - Nuclear Support Services 4 ommonweaith of Virginia COMOWALHOFVRGNI ~ M Cr Reg. # -140542 M omission Expires May 31, 2018

)

COUNTY OF HENRICO)

The foregoing document was acknowledged before me, in and for the county and Commonwealth aforesaid, today by Gianna C. Clark, who is Vice President - Nuclear Support Services of Dominion Energy Kewaunee, Inc. She has affirmed before me that she is duly authorized to execute and file the foregoing document on behalf of that Company, and that the statements in the document are true to the b st of her knowledgeanbeif Acknowledged before me this

ay o **1. ¢* .

My Commission Expi res:____ -- t**

Notary Public Attachments:

1. Discussion of Change, Technical Analysis, Significant Hazards Determination and Environmental Considerations

2. Marked-up Technical Specifications Pages

References:

1. 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].

2. Letter from D. G. Stoddard (DEK) to NRC Document Control Desk, "Revision to Post-Shutdown Decommissioning Activities Report," dated April 25, 2014. [ADAMS Accession No. ML14118A382]

-.. ,,:*,"Serial No.15-185

--License Amendment Request26 Page 3 of 3 Commitments made in this letter: None cc: Regional Administrator, Region Ill U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Ted H. Carter, Senior Project Manager U.S. Nuclear Regulatory Commission Two White Flint North, Mail Stop T-8F5 11545 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 15-1 85 ATTACHMENT 1 LICENSE AMENDMENT REQUEST 260 PROPOSED CHANGES TO LICENSE AND TECHNICAL SPECIFICATIONS TO REFLECT PERMANENT REMOVAL OF SPENT FUEL FROM SPENT FUEL POOL DISCUSSION OF CHANGE, TECHNICAL ANALYSIS, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 15-1 85 SAttachment 1 Table of Contents Table of Contents

1.0 DESCRIPTION

............................................................................I

2.0 PROPOSED CHANGE

.................................................................. 2 2.1 Technical Specifications .............................................................. 5 2.2 Renewed Facility Operating License ................................................ 6

3.0 TECHNICAL ANALYSIS

................................................................ 10 4.0

SUMMARY

.............................................................................. 10 fr TS SECTION 1.0, USE AND APPLICATION 4 ......................................... 11 fr TS SECTION 3.0, LIMITING CONDITION FOR OPERATION APPLICABILITY 4 ..15

r TS SECTION 3.7, PLANT SYSTEMS 4 .................................................. 19 fr TS SECTION 4.0, DESIGN FEATURES 4 ............................................... 22 fr TS SECTION 5.0, ADMINISTRATIVE CONTROLS 4 .................................. 25

5.0 REGULATORY ANALYSIS

............................................................ 35

6.0 ENVIRONMENTAL CONSIDERATION

............................................... 44

7.0 REFERENCES

.......................................................................... 45

Serial No. 15-1 85 Attachment 1 Page 1 of 45 PROPOSED CHANGES TO LICENSE AND TECHNICAL SPECIFICATIONS TO REFLECT PERMANENT REMOVAL OF SPENT FUEL FROM SPENT FUEL POOL DISCUSSION OF CHANGE, TECHNICAL ANALYSIS, SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the Operating License and associated Technical Specifications (TS) to reflect removal of all KPS spent nuclear fuel from the spent fuel pool (SEP) and its transfer to dry cask storage within the onsite Independent Spent Fuel Storage Installation (ISFSI).

By letter dated May 14, 2013 (Reference 1), DEK submitted a certification of permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii). Therefore, 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. The Post-Shutdown Decommissioning Activities Report (PSDAR) for KPS dated April 25, 2014 (Reference 2), documented that DEK expects to have all spent fuel transferred to the ISF5I by the end of 2016. Transfer of fuel out of the SFP supports decommissioning of KPS, which involves the eventual dismantlement of the SFP. In support of this condition, the KPS license and associated TS are being proposed for revision, in accordance with 10 CFR 50.36(c)(6), to comport to a facility configuration with all spent nuclear fuel in dry storage within the onsite ISFSI at KPS using casks certified for use under a general 10 CFR 72 license.

The existing KPS TS contain Limiting Conditions for Operation (LCOs) that provide for appropriate functional capability of equipment required for safe storage and management of irradiated fuel with fuel stored in a spent fuel pool (SFP). As such, the existing TS provide a level of control in excess of that needed for safe storage and management of irradiated fuel with fuel stored in an ISFSI. The majority of the existing TS are only applicable when irradiated fuel assemblies are within the SFP. Once all spent fuel assemblies have been transferred to the ISFSI, all remaining LCOs (and associated Surveillance Requirements (SRs)) will no longer be applicable and are being proposed for deletion. The TS being proposed reflect the removal of all spent fuel from the SFP. The proposed changes will result in TS that will be applicable to KPS after the last spent fuel assembly has been removed from the SFP and placed within the ISFSI.

There are no other pending license amendment requests associated with Technical Specifications currently docketed for KPS. Therefore, no disposition of other Technical Specifications changes, as they relate to this license amendment request, is needed.

Serial No.15-185 Attachment 1 Page 2 of 45

2.0 PROPOSED CHANGE

The proposed amendment would modify the KPS license to comport to the condition of all irradiated fuel in dry storage within the onsite Independent Spent Fuel Storage Installation (ISESI) at KPS using casks certified for use under a general 10 CFR 72 license. The amendment would also revise KPS Technical Specifications (TS) to eliminate operational requirements and certain design requirements involving storage of spent fuel that will no longer be applicable following the transfer of the last spent fuel assembly from the spent fuel pool (SFP) to the ISESI.

A new TS design requirement is being added that prohibits storage of spent fuel in the SEP.

The proposed changes to the TS also involve relocating administrative requirements to either the Dominion Quality Assurance Topical Report (DOM QA-1) or to the Technical Requirements Manual (TRM), and subsequently controlling them in accordance with 10 CFR 50.54(a) and 10 CFR 50.59, respectively. This relocation is being proposed pursuant to the criteria contained in 10 CFR 50.36 and in accordance with recommendations contained in NRC Administrative Letter 95-06.

The proposed changes to the Facility Operating License are as follows:

Eliminate License Condition 2.C.(1O) related to mitigation strategy.

Eliminate License Condition 2.C.(11) related to the seismic analysis methodology for the auxiliary building crane.

Eliminate License Condition 2.C.(12) related to implementation of new and revised surveillance requirements associated with conversion to Improved Standard TS.

Eliminate License Condition 2.C.(13) related to removal of details and requirements that were relocated to other controlled documents (associated with conversion to Improved Standard TS).

Eliminate License Condition 2.C.(16), related to spent fuel pool neutron absorber material surveillance programs.

General Analysis Applicable to Proposed Change DEK is in the process of decommissioning KPS. In support of this activity, the spent fuel is being transferred from the spent fuel pool to the ISFSI. The proposed changes to the KPS TS reflect the removal of all the spent fuel from the spent fuel pool. With no spent fuel in the spent fuel pool, the design bases for spent fuel storage in the pool and the design basis accident for fuel handling are no longer applicable.

The KPS Updated Safety Analysis Report (USAR), Section 14, Safety Analysis, currently addresses the design basis accidents (DBA) and transient scenarios applicable to KPS in the permanently defueled condition with irradiated fuel stored in the spent fuel pool (SFP). These postulated accidents are predicated on spent fuel being

Serial No. 15-1 85 Attachment I Page 3 of 45 stored in the spent fuel pool. However, upon transfer of all irradiated fuel to storage in the ISFSI, the accident scenarios postulated in the USAR are no longer possible. The ISFSI is a passive system that does not rely on electrical power for heat transfer. With removal of the spent fuel from the spent fuel pool, there are no remaining spent fuel assemblies to be monitored and there are no credible fuel related accidents that require actions of a Certified Fuel Handler, Shift Supervisor, or a Non-certified Operator to prevent occurrence or mitigate the consequences.

DEK plans to use a decommissioning method called SAFSTOR, in which most fluid systems are drained and the plant is left in a stable condition until final dismantlement.

Administrative controls that are required to be in place when decontamination or dismantling activities of radioactive systems, structures, and components are being performed are designed to minimize the likelihood of an off-normal or accident event, and thereby the consequences of .such an event. The proposed changes do not have an adverse impact on the remaining decommissioning activities or any of their postulated consequences.

The spent fuel will be stored in the ISFSI until it is shipped off site in accordance with the schedules described in the PSDAR and updated Irradiated Fuel Management Plan.

During decommissioning (with all spent fuel in dry storage within an ISFSI), no plant systems are relied upon for spent fuel storage. In this condition there are no credible accidents whose prevention or mitigation would need to be addressed by plant TS. The spent fuel storage canisters used in the ISFSI are subject to their own Certificate of Compliance and associated storage canister TS.

A list of the USAR Chapter 14 DBAs is provided in Section 5.2, "Applicable Regulatory Requirements/Criteria," of this submittal. There are no accident scenarios that apply to the condition with all spent fuel stored in dry casks within an ISFSI. Therefore, no analyzed accidents remain applicable to KPS in the condition with all spent fuel stored in dry casks within an ISESI.

The definition of safety-related structures, systems, and components (SSCs) in 10 CFR 50.2, "Definitions," states that safety-related SSCs are those relied on to remain functional during and following design basis events to assure:

1. The integrity of the reactor coolant boundary;

2. The capability to shutdown the reactor and maintain it in a safe shutdown condition; or,

3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.43(a)(1) or 100.11.

The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled

~Serial No.15-185 Attachment 1 Page 4 of 45 condition. The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits. However, after all spent fuel assemblies have been transferred to the ISFSI, there are no longer any SSCs at KPS that are required to be relied upon for accident mitigation. Therefore, with no fuel stored in the spent fuel pool, none of the SSCs at KPS meet the definition of a safety-related SSC as stated in 10 CFR 50.2.

10 CFR 50.36, "Technical specifications," promulgates the regulatory requirements related to the content of Technical Specifications. As detailed in subsequent sections of this proposed amendment, this regulation lists four criteria to define the scope of equipment and parameters that must be included in TS. A discussion of the applicability of these four criteria in the permanently defueled condition with all fuel removed from the spent fuel pool is provided in Section 5.2, "Applicable Regulatory Requirements/Criteria," of this submittal. In a permanently defueled condition with all spent fuel in dry storage within an ISESI, the scope of equipment and parameters that need be included in the KPS TS is limited to a description of the design features and high radiation area administrative controls.

4 Serial No. 15-1 85 Attachment 1 Page 5 of 45 2.1 Technical Specifications The following table provides a summary of which TS are being deleted in their entirety and which TS are being revised consistent with a plant configuration where all spent fuel is located within the onsite ISFSI. The details of, and justification for, the proposed changes follow in subsequent sections (arranged by TS Section).

}: TSii Bein Deleted ::!: TS Being Revised/Maintained 1.0 USE AND APPLICATION 1.:2: Logical~connectors':'!i :' i 'i=

1.i:3 Completion Time's:* :

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.'0 L

uIMTING: CONDITION FOR i l

!:.::!,OPREATION (LCO) APPLICABILITY _________________

i: (.*S.R:)APPLICABILITY! ii: I________________

3.7 PLANT SYSTEMS i3:.7.13 Sp*:!ent Fuel:pool Water Level

3.:7.1 Spent :Fuell Pool Sorangeoncent'r~tion~oo Spent:

4.0 DESIGN FEATURES

ii~, :i~ii!,1

,,::iii, :, :,* 4.1 Site Location

i:: ::::ii[4.3 Fuel Storage 5.0 ADMINISTRATIVE CONTROLS

,5.1f: f: Responlsibilt

5.2 *::,:: :Orga&nization' } ;i :!*i :: :

5. Unit ;Staff QualificatiOns:;:I :;;:ii{: :

,5.6.:: :Repor-ting Requirements:: i :' : :

__________;____"___________________._____ 5.7 High Radiation Area The TS Table of Contents is being revised accordingly.

The corresponding TS Bases are also being deleted to reflect the proposed changes.

Serial No. 15-1 85 Attachment 1 Page 6 of 45 2.2 Renewed Facility Operating License This section describes the proposed changes to the KPS Renewed Facility Operating License and the justification for each change.

License Section 1, Commission Findings Section 1 of the license contains historical conclusions determined by the Commission during past licensing activities that are informational in nature. Therefore, no changes are being proposed to this section of the license.

License Condition 2.C.(10)

I 2.C.(1 0) KptInjtlpn k~trE,*nn~, I ~npflpp r *~%flr4ItutI, an thatm incilude the foillowllin Icy areas:

2. As. ,es,mentof. mutual ai firefihnga et 3.Dsgae"tgigaesfreupmn1n aeil 1,. ,Command and+*... f cont r eol. e+',,;~ .."*.. .. +' ;*. rso +,- .*"--*..

6. Trinngo integrated...... fir response. srategy.v*.*

7. SeTir;..... fue*poo mitigationl measu*v*,res ~,*

(e)\ ..TIonn to minnmizo relzme o in niu,,e nnolnorucrmnn nl-

1. v ater spa scruDD* l

~. unse to DflSITC resoonacre -w--r This section is proposed for deletion in its entirety. After all spent fuel is stored within the ISFSI, the mitigation strategy license condition is no longer required.

The NRC issued this license condition on August 2, 2007, to incorporate the requirements for the Interim Compensatory Measures (ICM) Order EA-02-026, Section B.5.b mitigation strategies (dated February 25, 2002). Subsequently, 10 CFR 50.54(hh)(2) became effective on May 26, 2009. This section provides mitigation strategies and response procedure requirements for loss of large areas of the plant due to explosions or fire. However, as stated in 10 CFR 50.54(hh)(3), this section does not

Serial No.15-185 Attachment 1 Page 7 of 45 apply to a defueled reactor that has submitted the certification for permanent removal of fuel under 10 CFR 50.82(a).

On November 28, 2011, the NRC issued a letter that rescinded Item B.5.b of the ICM Order EA-02-26. Therefore, neither the ICM Order nor 10 CFR 50.54(hh) continue to apply to KPS.

This paragraph will read as follows.

2.C.(10) Deleted.

License Condition 2.0.(11)

The(11 ei~mcen hAl~l' usethedseismc~ Anxalyiar meuodolnq C ubrttdnb This section is proposed for deletion in its entirety. After all spent fuel is stored within the ISFSI, the auxiliary building crane license condition is no longer required.

DEK had modified the auxiliary building crane to incorporate a single-failure-proof design such that it could be used for spent fuel cask loading operations in the spent fuel pool. In KPS License Amendment 205 NRC approved the seismic analysis methodology for the crane. License Condition 2.C.(1 1) was added to the KPS license in License Amendment 205 on April 30, 2009, to require use of this methodology. After all spent fuel is removed from the spent fuel pool and stored within the ISESI, spent fuel cask loading operations in the spent fuel pool will no longer be necessary. Therefore, after the final spent nuclear fuel assembly has been transferred out of the spent fuel pool and placed in storage within the ISESI, the auxiliary building crane will no longer be required and this license condition may be deleted.

This paragraph will read as follows.

2.C.(11) Deleted.

License Condition 2.C.(12) 2C (a2) Fmlmettor Sur Neilnle'ie Requirements(SsthtacnwiAmdet

'-'e!ance

Serial No.15-185 Attachment 1 Page 8 of 45 (b) For SRs that, ex.istcd, prior. to. ^,mcnd,,,cnt. No,.,207 ,.hose*. inte.+ l

of.

(c; For.S...tat.e.i.te prior to.Amendm. nt.No...207.th..t.ha.e.modified.

acceptance. criteria0,4 the fis. performance4 subject.... to, the. modified ,,

acceptance....criteri...i...due.at..the..end.of..the..su.veillance...inte...al..th.t prior...

toth.implmentaion

... of.that.ame.dment... I--..-..

This section is proposed for deletion in its entirety. With all irradiated fuel stored within the ISESI, there are no applicable Surveillance Requirements (SRs). Therefore, as discussed later in this submittal, all the TS that use or refer to SRs are to be deleted.

Without any reference to SRs, there is no need for a license condition that specifies their implementation. Therefore, this license condition is no longer required.

This paragraph will read as follows.

2.C.(12) Deleted.

License Condition 2.0.(13)

Deeuments i,,nclude, relocation of these requirements. to"the specified documents.....

License Amendment 207 was implemented on February 12, 2011, as documented in a letter from DEK to NRC dated February 12, 2011 [ADAMS Accession ML110530159].

Relocation of the requisite items to licensee-controlled documents was completed as required by the implementation process. The relocated items subsequently became subject to the change process of the documents wherein they become located.

Therefore, License Condition 2.C.(13) has fulfilled its purpose and is no longer needed.

Hence, it may be deleted.

This paragraph will read as follows.

2.C.(13) Deleted.

Serial No. 15-1 85 Attachment 1 Page 9 of 45 License Condition 2.0.(16)

After thfeal spent pol fuel s embladed have alpnot been remsoved fromi the fuelroo bs ISpent no eincton thnieurnasorepruanteiln toh1 spe50.0nto incorporlate born carbidenend for a netrnabobe mtrilsurveillance program. seiid Ies3 andhrmre 39 Appendi hin e ofnUitio wasrediatePowe statint " dulassmled snua2011)into t theTehnicalmSpecifitonhespetfe pool by December 31, 2017. Because this proposed amendment will not become effective until as of the date that the transfer of spent fuel from the spent fuel pool to the ISFSI is complete (and prior to December 31, 2017), License Condition 2.C.(16) may be deleted.

This paragraph will read as follows.

2.C.(16) Deleted.

Serial No. 15-1 85 Attachment 1 Page 10 of 45

3.0 TECHNICAL ANALYSIS

and 4.0

SUMMARY

The following portion of this license amendment request contains a summary and technical justification for the proposed changes to Technical Specifications (TS)

Sections 1, 3, 4 and 5 (TS Section 2 was previously deleted).

A combined chapter, containing a separate description, the proposed change, technical analysis, and summary of the change is provided separately for each TS section.

These individual chapters combine to constitute Parts 3.0 and 4.0 of this license amendment request.

For grouping purposes the description, proposed change, technical analysis, and summary of the change for each TS section is labeled as follows.

Txx. 1 Description Txx.2 Proposed Change Txx.3 Technical Analysis Txx.4 Summary For the labels above, the numerical suffix "1"' corresponds to "Description," the suffix "2" corresponds to "Proposed Change," the suffix "3" corresponds to "Technical Analysis,"

and the suffix "4 corresponds to "Summary."~

The "xx"~ is a numerical designator that corresponds to the associated TS section (e.g.,

T3.1 would correspond to the "Description" for TS Section 3, whereas T37.3. would correspond to the "Technical Analysis" for TS Section 3.7).

The "General Analysis Applicable to Proposed Change" documented in Section 2.0, "Proposed Change," above, is also applicable to the following proposed TS changes.

Serial No.15-185 Attachment 1 Page 11 of 45

TS SECTION 1.0, USE AND APPLICATION 4 TI.1 DESCRIPTION The existing TS Section 1.0, "Use and Application," contains the rules of usage for the TS. This section is divided into the following four subsections.

1.1 Definitions - Defines terms used and applicable throughout the TS and Bases.

1.2 Logical Connectors - An explanation of the logical connectors used to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies.

1.3 Completion Times - Establishes the Completion Time convention and provides guidance for its use.

1.4 Frequency - Defines the proper use and application of Frequency requirements.

Because storage of fuel in an ISFSI does not rely on plant systems or activities addressed by TS, the requirements of this section will no longer apply (as discussed below) and are being proposed for deletion in their entirety.

TI.2 PROPOSED CHANGE TS Section 1.0, USE AND APPLICATION All TS in Section 1.0 are being deleted in their entirety, as identified in the table below.

Justification for deletion of these TS are as further described below and shown in .

There are no corresponding TS Bases sections associated with this TS section.

Serial No. 15-1 85 Attachment 1 Page 12 of 45 T

1.3 TECHNICAL ANALYSIS

TS Section 1.1, Definitions TS 1.1, "Definitions," provides defined terms that are applicable throughout the TS and TS Bases. After transfer of spent fuel from the spent fuel pool to the ISFSI is complete, there will no longer be any applicable Limiting Conditions for Operation (LCOs) or Surveillance Requirements (SRs) in the KPS TS. As such, the definitions described below will no longer be needed. Therefore, deleting these definitions from the TS effective after the spent fuel transfer from the SFP to the ISFSI is acceptable. The following definitions are being proposed for deletion because they will no longer have relevance to the plant TS after all fuel is removed from the spent fuel pool and stored in the onsite ISFSI.

Definitions Being Deleted Term Definition Beinq Deleted (summarized)

Actions ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

Actuation Logic Test An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output.

Certified Fuel Handler A CERTIFIED FUEL HANDLER is an individual who complies with provisions of the CERTIFIED FUEL HANDLER training program required by TS 5.3.2.

Channel Calibration A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors.

Channel Check A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation.

Channel Operational A COT shall be the injection of a simulated or actual signal into the Test (COT) channel to verify OPERABILITY of all devices in the channel required for channel OPERABILITY.

Operable - Operability A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant equipment are also capable of performing their related support function(s).

Serial No. 15-1 85 Attachment 1 Page 13 of 45 Staggered Test Basis A STAGGERED TEST BASIS consists of testing one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

Trip Actuating Device A TADOT shall consist of operating the trip actuating device and Operational Test verifying the OPERABILITY of all devices in the channel required for (TADOT) trip actuating device OPERABILITY. The TADOT shall include adjustment, as necessary.

TS Section 1.2, Logical Connectors TS 1.2, "Logical Connectors," contains an explanation of the logical connectors used to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies throughout the TS.

TS Section 1.2 is being proposed for deletion in its entirety because all TS sections that contain Conditions, Required Actions, Completion Times, Surveillances, and Frequencies are also being deleted. As such, logical connectors will no longer appear in the TS and the section that describes them may be deleted.

TS Section 1.3, Completion Times TS 1.3, "Completion Times," establishes the Completion Time convention throughout the TS and provides guidance for its use. The Completion Time is the amount of time allowed for completing a Required Action.

TS Section 1.3 is being proposed for deletion in its entirety because all TS sections that contain Required Actions and Completion Times are also being deleted. As such, Completion Times will no longer appear in the TS and the section that describes them may be deleted.

TS Section 1.4, Frequency TS 1.4, "Frequency," defines the proper use and application of Frequency requirements throughout the TS. Each Surveillance Requirement has a specified Frequency, in which the Surveillance must be met in order to meet the associated LCO.

TS Section 1.4 is being proposed for deletion in its entirety because all TS sections that contain Surveillances and Frequencies are also being deleted. As such, Frequency will no longer appear in the TS and the section that describes it may be deleted.

Serial No. 15-1 85 Attachment 1 Page 14 of 45 T1 .4

SUMMARY

Current Permanently Defueled Condition with Fuel in the Spent Fuel Pool TS Section 1.0, "Use and Application," does not contain applicability requirements. As such, all parts of this section can be conservatively defined as being applicable at all times.

All Irradiated Fuel Stored in an Independent Spent Fuel Storage installation Since TS Section 1.0 does not apply in the condition where all spent fuel being is removed from the spent fuel pool and stored in the onsite ISESI, the individual TS contained therein are not needed. As such, they may be deleted in their entirety with no impact on continued safe storage and maintenance of spent fuel in the ISFSI.

Conclusion Deleting all TS in Section 1.0 is acceptable.

Serial No. 15-1 85 Attachment 1 Page 15 of 45

TS SECTION 3.0, LIMITING CONDITION FOR OPERATION APPLICABILITY 4 SURVEILLANCE REQUIREMENT APPLICABILITY T

3.1 DESCRIPTION

The existing TS Section 3.0, "Limiting Condition for Operation (LCO) Applicability," and "Surveillance Requirement (SR) Applicability," contains general requirements applicable to all Specifications.

Because storage of spent fuel in an ISFSI does not rely on plant systems or activities addressed by TS, all TS sections that contain LCOs and SRs are being deleted. As such, the requirements of this section will no longer apply and are being proposed for deletion in their entirety.

T

3.2 PROPOSED CHANGE

TS Section 3.0, LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY; SURVEILLANCE REQUIREMENT (SR) APPLICABILITY All TS in Section 3.0 are being deleted in their entirety, as identified in the table below.

Proposed deletion of these TS (including the LCOs being deleted) are as further described below and shown in Attachment 2.

iiI*ii ii** TSi*:i Being Delietedi *!; TS Being Revised 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

3.10 L:

=:EIMITING CON DiTION FOR:* = ,.:;

:' :(SR) APPLICABILITY _______ _______ _______ ______

The corresponding TS Bases sections are also being deleted to reflect this change.

Serial No. 15-1 85 Attachment I Page 16 of 45 T

3.3 TECHNICAL ANALYSIS

TS 3.0, LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY TS 3.0, "Limiting Condition for Operation (LCO) Applicability," consists of LCO 3.0.1 through LCO 3.0.5 (with the exception of LCO 3.0.3, which was previously deleted).

These LCOs establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any applicable Limiting Conditions for Operation (LCOs) or Surveillance Requirements (SRs). As such, the LCOs described below will no longer be needed.

Therefore, deleting these LCOs from the TS effective after the spent fuel transfer from the SFP to the ISESI is acceptable. The following LCOs are being proposed for deletion because they no longer have relevance to the plant TS after all spent fuel is removed from the spent fuel pool and stored in the onsite ISESI.

LCOs Being Deleted

LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the Modes or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met.

LCO 3.0.4 establishes limitations on changes in Modes or other specified conditions in the Applicability when an LCO is not met.

LCO 3.0.5 establishes an allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

LCOs 3.0.1, 3.0.2, 3.0.4, and 3.0.5 are being proposed for deletion in their entirety.

These four LCOs are no longer needed since all remaining TS to which they apply are being proposed for deletion. Therefore, the proposed deletion of LCOs 3.0.1, 3.0.2, 3.0.4, and 3.0.5 is acceptable.

Serial No. 15-1 85 Attachment 1 Page 17 of 45 TS 3.0, SURVEILLANCE REQUIREMENT (SR) APPLICABILITY TS 3.0, "Surveillance Requirement (SR) Applicability," consists of SR 3.0.1 through SR 3.0.4. SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any applicable Limiting Conditions for Operation (LCOs) or Surveillance Requirements (SRs). As such, the SRs described below will no longer be needed.

Therefore, deleting these SRs from the TS effective after the spent fuel is transfered from the SFP to the ISFSI is acceptable. The following SRs are being proposed for deletion because they no longer have relevance to the plant TS after all spent fuel is removed from the spent fuel and stored in the ISFSI.

SRs Being Deleted

SR 3.0.1 establishes the requirement that SRs must be met during the Modes or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits.

SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per. .. " interval.

SR 3.0.3 provides the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a surveillance requirement has not been completed within the specified Frequency.

SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a Mode or other specified condition in the Applicability.

SRs 3.0.1, 3.0.2, 3.0.3, and 3.0.4 are being proposed for deletion in their entirety.

These four SRs are no longer needed since all remaining TS to which they apply are being proposed for deletion. Therefore, the proposed deletion of SRs 3.0.1, 3.0.2, 3.0.3, and 3.0.4 is acceptable.

Serial No. 15-1 85 Attachment 1 Page 18 of 45 T3.4

SUMMARY

Current Permanently Defueled Condition with Fuel in the Spent Fuel Pool TS Section 3.0, "Limiting Condition for Operation (LCO) Applicability," and "Surveillance Requirement (SR) Applicability," does not contain applicability requirements. As such, all parts of this section can be conservatively defined as being applicable at all times.

All Spent Fuel Stored in an Independent Spent Fuel Storage Installation TS Section 3.0 does not apply in the condition where all spent fuel has been removed from the spent fuel pool and is stored in an ISESI. Since the TS to which TS section 3.0 applies are being proposed for deletion, the TS Section 3.0 requirements are no longer needed. As such, they may be deleted in their entirety with no impact on continued safe storage and maintenance of spent fuel in the ISESI.

Conclusion Deleting all TS in Section 3.0 is acceptable.

Serial No. 15-1 85 Attachment 1 Page 19 of 45 fr TS SECTION 3.7, PLANT SYSTEMS 4 T

37.1 DESCRIPTION

The existing TS in Section 3.7, "Plant Systems" (TS 3.7.13, 3.7.14, and 3.7.15), contain Limiting Conditions for Operation (LCOs) that provide for appropriate functional capability of plant equipment required for safe maintenance and storage of fuel assemblies in the spent fuel pool.

After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any spent fuel assemblies in the spent fuel pool. As such, TS 3.7.13, 3.7.14, and 3.7.15 (along with their respective LCOs) will no longer be applicable. Therefore, deleting these TS effective after all spent fuel has been transferred from the SFP to the ISFSI is acceptable. All TS in Section 3.7 are being proposed for deletion because they have no relevance to, and no longer apply to, the storage of spent fuel assemblies in an ISFSI.

T

37.2 PROPOSED CHANGE

TS Section 3.7, Plant Systems All TS in Section 3.7 are being deleted in their entirety, as identified in the table below (Note: TS Sections 3.7.1, 3.7.2, 3.7.3, 3.7.4, 3.7.5, 3.7.6, 3.7.7, 3.7.8, 3.7.9, 3.7.10, 3.7.11, 3.7.12 and 3.7.16 were previously deleted).

TS Being DeletedTS Being Revised 3.7 PLANT SYSTEMS The corresponding TS Bases sections are also being deleted to reflect this change.

T

37.3 TECHNICAL ANALYSIS

Section 3.7 TS That Are Not Applicable When All Fuel Stored in ISFSI TS 3.7.13, 3.7.14, and 3.7.15 do not currently apply when no fuel assemblies are in the spent fuel pool.

Serial No. 15-1 85 Attachment 1 Page 20 of 45 After all spent fuel has been removed from the spent fuel pool, there is no need to maintain spent fuel water level, verification of boron concentration, or spent fuel pool cooling. Safe load paths over the spent fuel pool are no longer necessary.

TS 3.7.13, "Spent Fuel Pool Water Level," specifies requi'rements to ensure that the minimum water level in the spent fuel pool (the north pool, south pool, and canal pool) meets the iodine decontamination factor assumptions used in the fuel handling accident (FHA) analysis of record. The specified water level shields and minimizes the general area dose when the storage racks are filled to their maximum capacity. The water also provides shielding during the movement of spent fuel. TS 3.7.13 is applicable during movement of irradiated fuel assemblies in the spent fuel pool.

TS 3.7.14, "Spent Fuel Pool Boron Concentration," specifies requirements to ensure that the spent fuel pool boron concentration is _> 240 ppm. The specified concentration of dissolved boron in the spent fuel pool preserves the assumptions used in the analyses of the potential criticality accident scenarios. This concentration of dissolved boron is the minimum required for fuel assembly storage and movement within the spent fuel pool. TS LCO 3.7.14 applies whenever fuel assemblies are stored in the spent fuel pool, until a complete spent fuel pool verification has been performed following the last movement of fuel assemblies in the spent fuel pool.

TS 3.7.15, "Spent Fuel Pool Storage," specifies restrictions on the placement of fuel assemblies within the spent fuel pool, in accordance with Figure 3.7.15-1 in the accompanying LCO to ensure the keff of the spent fuel pool will always remain < 0.95, assuming the pool to be flooded with unborated water. Irradiated fuel assemblies discharged prior to or during the 1984 refueling outage with a combination of burnup and initial nominal enrichment in the Acceptable Domain of Figure 3.7.15-1 are allowed to be stored in the transfer canal spent fuel pool or the north and south combined spent fuel poois. New fuel assemblies, irradiated fuel assemblies discharged after the 1984 refueling outage, or spent fuel assemblies not in the Acceptable Domain of Figure 3.7.15-1 shall be stored in the north and south pools (combined). TS LCO 3.7.15 applies whenever any fuel assembly is stored in the spent fuel pool.

T37.4

SUMMARY

Current Permanently Defueled Condition with Fuel in the Spent Fuel Pool TS 3.7.13, 3.7.14, and 3.7.15 are related to assuring the appropriate functional capability of plant equipment required for safe storage and maintenance of spent fuel stored in the spent fuel pooi. TS 3.7.13, 3.7.14, and 3.7.15 are applicable when fuel assemblies are stored or moved in the spent fuel pool.

Serial No. 15-1 85 Attachment 1 Page 21 of 45 All Irradiated Fuel Stored in an Independent Spent Fuel Storage Installation TS 3.7.13, 3.7.14, and 3.7.15 do not apply when all spent fuel assemblies are removed from the spent fuel pool and stored in an ISESI. Therefore, these three TS will no longer be needed following the transfer of all fuel assemblies from the spent fuel pool to the ISFSI. As such, these three TS may be deleted in their entirety with no impact on continued safe storage and maintenance of irradiated fuel in an ISESI at KPS.

LCOs that provide for appropriate functional capability of facility equipment required for safe maintenance and storage of fuel assemblies in the ISESI are specified in the applicable ISESI TS.

Conclusion Deleting TS 3.7.13, 3.7.14, and 3.7.15 in Section 3.7 is acceptable.

Serial No. 15-1 85 Attachment 1 Page 22 of 45 I* TS SECTION 4.0, DESIGN FEATURES 41 T

4.1 DESCRIPTION

The existing TS Section 4.0, "Design Features," contains descriptions and requirements for those features of the facility such as materials of construction and geometric arrangements which, if altered or modified, would have a significant effect on safety of the spent fuel pool and are not covered in the previous sections of the TS.

After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any fuel assemblies in the spent fuel pool. As such, certain design features will have no relevance to, and no longer apply to, the storage of fuel assemblies in an ISFSI.

Therefore, deleting these TS effective after the last fuel transfer from the SFP to the ISFSI is acceptable.

Since this proposed amendment is premised on spent fuel no longer being stored in the spent fuel pool, a new design feature specification is being proposed stating that spent fuel shall not be stored in the spent fuel pool.

T

4.2 PROPOSED CHANGE

TS Section 4.0, Design Features TS being retained and revised are 4.1 and 4.3 as further described below and shown in (the currently existing design features description in TS 4.3 is being deleted and replaced with a new design feature specification).

Note: TS 4.2 was previously deleted.

4.0 DESIGN FEATURES 4.1 Site Location 4.3 Fuel Storage There are no corresponding TS Bases sections associated with this TS section.

Serial No. 15-1 85 Attachment 1 Page 23 of 45 T

4.3 TECHNICAL ANALYSIS

TS 4.1, Site Location TS 4.1, "Site Location," provides a description of the location of KPS. This TS section is being retained and revised to reflect the permanently defueled condition of the plant with all fuel assemblies stored in an ISESI. A description regarding the minimum distance from the center line of the reactor containment to the site exclusion radius is being deleted.

The minimum distance from the center line of the reactor containment to the site exclusion radius is based on requirements contained in 10 CFR 100.3 regarding reactor accident dose analyses. Because the KPS Part 50 license no longer authorizes emplacement or retention of fuel in the reactor vessel, this design feature is no longer needed. As such, its description may be deleted.

TS 4.3, Fuel Storage TS Section 4.3, "Fuel Storage," provides a description and requirements regarding prevention of criticality of spent fuel in the spent fuel pool storage racks, prevention of spent fuel pool drainage, and spent fuel capacity limitations. All currently existing requirements in TS Section 4.3 are being deleted in their entirety.

After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any fuel assemblies in the pool. Therefore, the design features associated with fuel storage in the spent fuel pool is no longer applicable and may be deleted.

Since this proposed amendment is premised on spent fuel no longer being stored in the spent fuel pool, a new design feature specification is being proposed to be added to TS Section 4.3 stating that spent fuel shall not be stored in the spent fuel pool.

The new specification will read:

Spent fuel shall not be stored in the spent fuel pool.

Reactor spent fuel stored in dry canisters within the ISFSI is subject to the TS applicable to the associated storage canister system. One of the storage canister types used at KPS is the Transnuclear Model NUHOMS-32PT under NRC Certificate of Compliance (CoC) No. 1004. The associated TS for this storage canister require (for assurance that the spent fuel will continue to meet the requirements for storage) that the reactor spent fuel in the canister be returned to the reactor spent fuel pool for inspection of the DSC and transfer cask (IC) in the event of a canister drop during handling. A discussion of this capability (returning the fuel to the spent fuel pool) appears in the Updated Final Safety Analysis Report (UFSAR) for the NUHOMS storage system.

Serial No.15-185 Attachment 1 Page 24 of 45 The UFSAR for the NUHOMS storage system, Section 5.1.1.9 "Removal of Fuel from the DSC" (and several other sections), states the following.

"If it becomes necessary to remove fuel from the DSC [dry shielded canister] prior to off-site shipment, there are two basic options available at the ISFSI or reactor site.

The fuel assemblies could be removed and reloaded into a shipping cask using dry transfer techniques, or if the applicant so desires, the initial fuel loading sequence could be reversed and the plant's spent fuel pool utilized."

To address the inconsistency with the requirements of NUHOMS CoC 1004 regarding return of the fuel to the spent fuel pool, a licensing action regarding these requirements is being separately requested. The certificate holder of CoC No. 1004, AREVA, Inc.,

submitted a proposed change to the storage canister TS on August 24, 2015 (Reference 4). The proposed change submitted by AREVA, Inc. would eliminate the requirement to return the fuel to the spent fuel pool and therefore eliminate the need for the spent fuel pool to be available to meet the storage canister TS requirement.

T4.4

SUMMARY

Current Permanently Defueled Condition with Fuel in the Spent Fuel Pool TS Section 4.0, "Design Features," does not contain applicability requirements. As such, all parts of this section are conservatively assumed to be applicable at all times.

All Irradiated Fuel Stored in an Independent Spent Fuel Storage Installation TS 4.1 will remain germane with the spent fuel pool emptied of fuel assemblies. As such, this TS section is being retained and revised to reflect the condition of all fuel assemblies stored in an ISFSI.

The existing TS Section 4.3 describes design features associated with fuel storage in the spent fuel pool. After all spent fuel is removed from the spent fuel pool the existing information in TS Section 4.3 is no longer applicable and may be deleted. Adding a new design feature stating that spent fuel shall not be stored in the spent fuel pool documents the premise on which this proposed amendment is based (i.e., spent fuel no longer being stored in the spent fuel pool).

Conclusion Retaining TS 4.1, as revised, and adding the proposed design feature specification (regarding prohibition on spent fuel storage in the spent fuel pool) to TS 4.3, ensures appropriate requirements for the associated design features.

Deleting the currently existing (no longer applicable) design features in TS Section 4.3 is acceptable.

Serial No. 15-1 85 Attachment 1 Page 25 of 45

TS SECTION 5.0, ADMINISTRATIVE CONTROLS 41 T

5.1 DESCRIPTION

The existing TS Section 5.0, "Administrative Controls," contains provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any fuel assemblies in the spent fuel pool. As such, the associated administrative controls will have no relevance to and no longer apply to the storage of fuel assemblies in an ISESI. Therefore, deleting the associated TS effective after the last fuel transfer from the SFP to the ISFSI is acceptable.

T

5.2 PROPOSED CHANGE

TS Section 5.0, Administrative Controls All TS in Section 5.0, with the exception of TS 5.7, High Radiation Area, are being deleted in their entirety, as identified in the table below and as further described and as shown in Attachment 2. Pertinent information being deleted from TS is being relocated to either the Quality Assurance Program Description (QAPD) or the Technical Requirements Manual (TRM). TS 5.7 is being retained unchanged.

ii. :i~* TS Beinig Deleted * ~*!!!ili [i! TS Being Revised 5.0 ADMINISTRATIVE CONTROLS

5.1 :i; *.,Responsibility_____________________

ii5.2. Organization, - ::, .... (-

5.3," *,Unit Staff Qualifications 5.4 Procedures -'

5.5 Programs and .Man~uals 5.6 : Reporting Requirements .............. _____________

_____________________________5.7 High Radiation Area There are no corresponding TS Bases sections associated with this TS section.

T

5.3 TECHNICAL ANALYSIS

NRC Administrative Letter 95-06 provides a discussion concerning the relocation of Technical Specification administrative controls to a quality assurance (QA) program.

Serial No.15-185 Attachment 1 Page 26 of 45 The NRC considers relocating these requirements to the quality assurance program acceptable because of the controls imposed by 10 CFR 50, Appendix B, the existence of an NRC approved quality assurance program, and the quality assurance program change control process in 10 CFR 50.54(a). The KPS quality assurance program is described in the Quality Assurance Program Description (QAPO)

The TRM is part of the Updated Safety Analysis Report (USAR) and therefore subject to the requirements of 10 CFR 50.59. Maintaining relocated requirements in accordance with the change control process in 10 CFR 50.59 provides adequate control based on the ISFSI-only status of the facility. With the transfer of the spent fuel to the ISFSI, the administrative controls pertaining to the safe storage of spent fuel within the spent fuel pool are no longer needed or applicable.

TS 5.1, Responsibility TS 5.1, " ""Responsibility,"

provides a description and requirements regarding certain key operational management responsibilities.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety.

5.. h hf aae hl ersonil o h hf omn ucin DEK is proposing to delete TS 5.1.2 in its entirety. The Shift Manager requirements in TS 5.1.2 are being eliminated. The requirements of TS 5.1.1 are being deleted from Technical Specifications and relocated to the QAPD.

With removal of all of the spent fuel from the spent fuel pool, a need for the shift manager for spent fuel management no longer exists. The position of shift manager described in TS 5.1.2 is a holdover from the control room function of supervising multiple functions of an operating nuclear power plant. With the limited requirements for supervision of the passive fuel storage at the ISFSI or with respect to the decommissioning of the former power generation facility, the shift manager position is no longer required and the proposed deletion of TS 5.1.2 is acceptable. Therefore, Section 5.1.2, which provides a description of responsibility of the shift manager will be deleted from the TS.

The remaining requirements of Section 5.1.1 related to the responsibilities of the plant manager will be deleted from the TS and relocated to the QAPD. Relocating these

Serial No. 15-1 85 Attachment 1 Page 27 of 45 responsibilities to the QAPO is consistent with NRC Administrative Letter 95-06.

Therefore, the proposed deletion of TS 5.1 is acceptable.

TS 5.2, Organization TS 5.2, "Organization," provides a description and requirements regarding onsite and offsite organizations and facility staffing. Descriptions include lines of authority and staff responsibilities. Requirements include the associated TS Table 5.2.2-1, which specifies a minimum shift crew composition staffing requirement for Certified Fuel Handlers and Non-Certified Operators. TS 5.2 also specifies requirements for fuel handling operations and supervision.

Onsite and offsite organizations shall be established for plant and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the quality assurance program. The plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be maintained in appropriate plant documents.

b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel.

c. A specified corporate officer shall have corporate responsibility for overall

. ~ plant nuclear safety and shall take any measures needed to ensure/

acceptable performance of the staff in operating, maintaining, and providing/

technical support to the plant to ensure safe management of nuclear fuel.,

I~ d. The individuals who train CERTIFIED FUEL ,HANDLERS, carry out health Iphysics 7 or perform quality assurance functions may report to thel I. appropriate onsite manager; however, these individuals shall have sufficientl Iorganizational freedom to ensure their ability to perform their assigned l functions. I r* .. i ~r~~~r t.. (A I

Serial No. 15-1 85 Attachment I Page 28 of 45 5.2.2 FailJ.,it÷y St÷aff I flC T~CiiitV CI~1T organization shall include the following:

-rl-_ L----."I:L. _J__t*

a. .'.arnonm-aui .....

tvl j

sni.n'l-'

sn i DC.1comoos-ca~,..L#- OT au."tica-'*cl tne'l mi...nimull.'lmn.i' sl-nirtl creIA oral n *

i BB

A A A composition snown in I aDle 522 1.

I Am Ifi I I .. ..

fl ~ifliTt

---.-----.-.. crew comntYition m~w re ir~t5~ tWin I---.-.-.....-J-----------....--1-..-...-..--.- the minimum mrliiimment oteathe. I iNc

......... for .a.perio' fti enttoe ce

..... 2....hours... except......in.. e. ere...

condvitini order~mtovm accomumodate*~ *vunem pectedmabenc ofI onV duty~ shift

r.;All fue-hndIn

oprtoshllbdietyupr ed yaquifd iidi*1duall

--I ...... I----II l ....

c..-n niimuli ouinli~ri in* raaalimon orrotectin orcrourm ros cnain DC on sie P l I I I

,4,,,;, Sfuel flandlinQ operations l or movements of ioads over storage racks Gen4aR~ng4ueb T-able 5.. 1 (page*-,,,* t of-, "1)

Minimu Shift C rew'- Compoitio l SITIO lMllll INIMUM STAFF INGlIN1 CERTIFIED FUEL HANDLER 41-Non peraoi"1- ertiied uporator pocition ma'; bo filled by a CERTIFIED FUEL HANDLER.

1_*_. -rL_ kl___ h-- *!*---- J *--

r~oie: i nO i'~on ~erti~iep DEK is proposing to delete TS 5.2.2 in its entirety. The associated Table 5.2.2-1 is also being deleted. The requirements of TS 5.2.1 are being deleted from Technical Specifications and relocated to the QAPD, with the exception of the certified fuel handler trainer requirements in TS 5.2.1.d, which are being eliminated.

Section 5.2.1, "Onsite and Offsite Organizations," provides a general discussion of the site organization which assures safe facility operations and safety of the nuclear fuel.

Section 5.2.1.d provides requirements for organizational freedom of the certified fuel handler trainers, and the health physics and quality assurance personnel. DEK proposes to eliminate the portion of Section 5.2.1.d pertaining to certified fuel handler trainers. Following the transfer of all spent fuel to the ISESI, and the new TS 4.3 prohibition from storing fuel in the spent fuel pool, there will no longer be a need for certified fuel handlers; therefore this proposed deletion is acceptable.

Serial No. 15-1 85 Attachment I Page 29 of 45 The remainder of section 5.2.1 will be deleted from the Technical Specifications and relocated to the QAPD to provide an equivalent description of the requirements for organizational freedom of the health physics and quality assurance personnel.

Providing onsite and offsite organization descriptions in the QAPD is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation are acceptable.

Section 5.2.2, "Facility Staff', currently specifies the organizations and positions for activities affecting the safe storage of irradiated fuel in the spent fuel pool. The QAPD addresses the necessary organizational requirements for KPS after all spent fuel has been transferred to ISFSI. Therefore, the deletion of TS 5.2.2 after the fuel has been moved from the spent fuel pool to the ISFSI will have no impact and is acceptable.

TS 5.3, Facility Staff Qualifications TS 5.3, "Facility Staff Qualifications," provides a description and requirements regarding qualifications of the facility staff. It also specifies that an NRC approved training and retraining program for the Certified Fuel Handlers (CFH) shall be maintained.

a. The radiation protection manager who shall meet or exceed the recommendation of Regulatory Guide 1.8, Revision l-R, September 1975, or their equivalent as further clarified in Attachment 1 to the NRC Safety

~Evaluation Report enclosed with Amendment No. 46, dated July 12, 1982.

5.3.2 R ,A

^,P,~,... apoe tr.aining .. nd retraining,,., pr..gr.m for, th,, CERIFIDT - FUEL,-

HANDLER shall be,,,.u ma

,inta*ined.

DEK is proposing to delete TS 5.3.2 in its entirety. The requirements of TS 5.3.1 are being deleted from Technical Specifications and relocated to the QAPD.

TS 5.3.2 specifies requirements for a certified fuel handler training program. Following the transfer of all spent fuel to the ISFSI, and the new TS 4.3 prohibition from storing spent fuel in the spent fuel pool, there will no longer be a need for certified fuel handlers, which obviates the need for the associated training program. Therefore, this proposed deletion is acceptable.

Serial No.15-185 Attachment 1 Page 30 of 45 TS 5.4, Procedures TS 5.4, "Procedures," provides a description and requirements regarding administration of written procedures.

a.TcPpialrocedures Retiecommenidon relocatedto; GuiDe.3 5.4.1 W~reision 2rocedurendisha, Fberesablse,' 1078; tdadmananeovrn

b. Deleted;

c. Quality assurance for effluent and environmental monitoring;

d. Fire Protection Program implementation; and

e. All programs specified in Specification 5.5.

DEK is proposing to relocate the requirements of TS 5.4, "Procedures," to the QAPD, except for TS 5.4.1.a, specifying procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February, 1978, which is to be eliminated.

The transfer of the administrative controls in TS 5.4 is consistent with the guidance in AL 95-06, and therefore, is acceptable.

The guidance in Regulatory Guide 1.33, Revision 2, Appendix A, addresses safety-related activities carried out during the operation phase of nuclear power plants, including wet storage of nuclear fuel in a spent fuel pool. Following the transfer of all spent fuel to the ISFSI, the spent fuel pool will no longer be used for spent fuel storage.

Additionally, as discussed above, DEK is adding a limitation in TS 4.3, which prohibits storage of spent fuel in the spent fuel pool. After spent fuel storage is no longer allowed in the spent fuel pool, the specifications included in TS 5.4.1.a., would no longer be needed, so the proposed deletion is acceptable.

TS 5.5, Programs and Manuals TS 5.5, "Program and Manuals," provides a description and requirements regarding programs and manuals that are to be established, implemented, and maintained.

Serial No. 15-1 85 Attachment 1 Page 31 of 45 5.5 Programs and Manuals I Requirements Manual Relocated to Technical I The following programs shall be established, implemented, and maintaine~'J.

5.5.1 Offsite Dose Calculation Manual (0ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from...

3. Shall be submitted to the NRC .... the change was implemented.

5*5*3 Radioactive Effluent Controls Proqram This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses...

j. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CER 190.

P A* A A A I A* A A A li

II dI I h~ provisions ot ~ i.U.2 and ~ :i.u.:i are appileaDie to tfle ~adioactivc Effluen Cont P*rols Program4Sur;eillance. Frequencic.-.*

(%5.10 Storagqe Tank Radioactivity Monitoringq Progqram I Requirements Manual Relocated to Technical This program provides controls for the quantity of radioactivity contained in I>

unprotected outdoor liquid storage tanks*...

a. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid .... release of the tanks' contents.

The provisions of SR 3.0.2 3 re appI:caDie 4ehe-S4e~agRad~a~tMty Monitoring Program Sur:eill:~nce i-rcauencies.

5.5.12 Technical Specifications (TS) Bases Control Program This pro~gram pro..ides d-fH~H~ for*processing; chne to..the Bases of..thes

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

Serial No. 15-1 85 Attachment 1 Page 32 of 45

2. A ch-ange to-the, updated*÷,- USIAR o-r Baseso that* requires-* NRCDapprova..'l pursuant to' 10 FR*50.59.n

.. The. Bae Control+" Program shall, containprviostenuehath DEK is proposing to relocate TS 5.5, "Programs and Manuals," to the Technical Requirements Manual (TRM), except for TS 5.5.12, "Technical Specification (TS) Bases Control Program," which is to be eliminated.

TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)", currently specifies how to document, review, and approve changes to the ODCM. DEK proposes to delete this requirement from the Technical Specifications and relocate it to the TRM. This requirement will be maintained in accordance with 10 CFR 50.59. Since the intent of this section is to ensure that the ODCM continues to meet the requirements of 40 CFR 190, 10 CFR 20, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, and since this requirement will be maintained in the TRM, the relocated requirement will continue to be subject to regulatory controls. This change is consistent with similar relocations approved by NRC of former TS requirements into a TRM (including KPS License Amendment 215, Permanently Defueled TS, approved by NRC on February 13, 2013).

Therefore, the proposed deletion and relocation of the requirement are acceptable.

TS 5.5.3, "Radioactive Effluent Controls Program", currently specifies requirements for the control of radioactive effluents and for maintaining doses to the public from effluents as low as reasonably achievable (ALARA). DEK proposes to delete this requirement from the Technical Specifications and relocate it to the TRM, except for the last sentence, "The provisions of SR 3.0.2 and SR 3.0.3 are applicable to Radioactive Effluent Controls Program Surveillance Frequencies." This sentence will be deleted from the Technical Specifications and not relocated to the TRM. Since SR 3.0.2 and SR 3.0.3 are being deleted, as described above, this sentence is no longer germane.

The requirement for a Radioactive Effluent Controls Program will be maintained in accordance with 10 CFR 50.59. Since the intent of this section is to ensure that the Radioactive Effluent Controls Program continues to meet the requirements of 40 CFR 190, 10 CFR 20, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, and since this requirement will be maintained in the TRM, the relocated requirement will continue to be subject to regulatory controls. This change is consistent with similar relocations approved by NRC of former TS requirements into a TRM. Therefore, the proposed deletion and relocation of the requirement are acceptable.

Serial No. 15-1 85 Attachment 1 Page 33 of 45 Section 5.5.10, "Storage Tank Radioactivity Monitoring Program", currently provides controls for the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. DEK proposes to delete these requirements from the Technical Specifications and relocate them to the TRM, except for the last sentence, "The provisions of SR 3.0.2 are applicable to the Storage Tank Radioactivity Monitoring Program Surveillance Frequencies." This sentence will be deleted from the Technical Specifications and will not be relocated to the TRM. Since SR 3.0.2 is being deleted, as described above, this sentence is no longer germane. The requirement for a Storage Tank Radioactivity Monitoring Program will be maintained in accordance with 10 CFR 50.59. Since this requirement will be maintained in the TRM, the relocated requirement will continue to be subject to regulatory controls. This change is consistent with similar relocations approved by NRC of former TS requirements into a TRM. Therefore, the proposed deletion and relocation of the requirement are acceptable.

TS 5.5.12, specifies the process for changes to the TS Bases. Currently, the TS Bases are all related to storage of spent fuel in the spent fuel pool, specifically the requirements in TS 4.3, which are being deleted as described above. Following transfer of all spent fuel to the ISFSI, the spent fuel pool will no longer be used for spent fuel storage. Since all the TS Bases will be deleted, there will no longer be a need for a TS Bases Control Program. Therefore, the proposed deletion of TS 5.5.12 is acceptable.

TS 5.6, Reporting Requirements TS 5.6, "Reporting Requirements," provides a description and requirements regarding reports that are to be submitted in accordance with 10 CFR 50.4.

DEK is proposing to delete TS 5.6, "Reporting Requirements", from the Technical Specifications and relocate the requirements to the Technical Requirements Manual in their entirety. The two requirements are TS 5.6.1, "Annual Radiological Environmental Operating Report", and TS 5.6.2, "Radioactive Effluent Release Report". The TRM is part of the USAR and therefore subject to the requirements of 10 CFR 50.59.

Maintaining these relocated requirements in accordance with 10 CFR 50.59 provides adequate control based on the ISFSI-only status of the facility. Therefore, the proposed deletion and relocation of the requirements are acceptable.

TS 5.7, High Radiation Area TS 5.7, "High Radiation Area," provides a description and requirements regarding controls applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR 20 (as provided in paragraph 20.1601(c) of 10 CFR 20).

TS 5.7 will remain germane with all spent fuel stored in the ISFSI. As such, it is being retained as-is with no changes being proposed.

Serial No. 15-1 85 Attachment 1 Page 34 of 45 T5.4

SUMMARY

Current Permanently Defueled Condition with Fuel in the Spent Fuel Pool TS Section 5.0, Administrative Controls, does not contain applicability requirements. As such, all parts of this section are conservatively as assumed to be applicable at all times.

All Irradiated Fuel Stored in an Independent Spent Fuel Storage Installation TS Section 5.0 describes administrative controls associated with fuel storage in the spent fuel pool. After the transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any fuel assemblies in the spent fuel pool. However, there may continue to be high radiation areas in the facility. Therefore, with the exception of TS 5.7, "High Radiation Area," this TS section is no longer required and may be deleted.

Pertinent requirements will be relocated to either the Quality Assurance Program Description (QAPD) or the Technical Requirements Manual (TRM) and controlled in accordance with 10 CFR 50.54(a) and 10 CFR 50.59, respectively. Appropriate administrative controls for spent fuel storage within an ISESI are specified in the applicable ISFSI storage system TS.

TS 5.7 will remain applicable following the complete transfer of spent fuel from the spent fuel pool to the ISFSI because high radiation areas may continue to exist in the facility.

As such, it is being retained unchanged.

Conclusion Deleting TS 5.1, 5.2, 5.3, 5.4, 5.5, and 5.6 in their entirety and relocating the pertinent requirements discussed above to either the QAPD or TRM is acceptable.

Retaining TS 5.7, unchanged, continues to ensure appropriate requirements for high radiation areas.

Serial No. 15-1 85 Attachment 1 Page 35 of 45

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards'Consideration Pursuant to 10 CER 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the Operating License and associated Technical Specifications (TS) to reflect removal of all KPS spent nuclear fuel from the spent fuel pool and its transfer to dry cask storage within an Independent Spent Fuel Storage Installation (ISFSI).

By letter dated May 14, 2013, DEK submitted a certification of permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii). Therefore, 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. The Post-Shutdown Decommissioning Activities Report (PSDAR) for KPS dated April 25, 2014, documented that DEK expects to have all spent fuel transferred to the ISFSI by the end of 2016. Transfer of fuel out of the SEP supports decommissioning of KPS, which involves the eventual dismantlement of the SFP. In support of this condition, the KPS license and associated TS are being proposed for revision, in accordance with 10 CER 50.36(c)(6), to comport to facility possession with all spent nuclear fuel in dry storage within an ISESI at KPS using casks certified for use under a general 10 CFR 72 license.

The existing KPS TS contain Limiting Conditions for Operation (LCOs) that provide for appropriate functional capability of equipment required for safe storage and management of irradiated fuel with fuel stored in a spent fuel pool (SFP). As such, the existing TS provide a level of control in excess of that needed for safe storage and management of irradiated fuel with fuel stored in an ISESI. The majority of the existing TS are only applicable when irradiated fuel assemblies are within the SEP. Once all spent fuel assemblies have been transferred to the ISESI, all remaining LCOs (and associated Surveillance Requirements (SRs)) will no longer be applicable and are being proposed for deletion (along with deletion and relocation of certain design requirements and administrative requirements that are also no longer needed). The changes being proposed reflect the removal of all spent fuel from the SFP. The proposed changes will result in TS that will be applicable to KPS after the last spent fuel assembly has been removed from the SEP and placed within the ISESI.

DEK has evaluated the proposed amendment to determine if a significant hazards consideration is involved by focusing on the three standards set forth in 10 CER 50.92, "Issuance of Amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

Serial No. 15-1 85 Attachment 1 Page 36 of 45 The proposed amendment would modify the KPS renewed facility operating license and TS by deleting the portions of the license and TS that are no longer applicable to a facility with no spent nuclear fuel stored in the spent fuel pool, while modifying the remaining portions to correspond to all nuclear fuel stored within an ISFSI. This amendment becomes effective upon removal of all spent nuclear fuel from the KPS spent fuel pool and its transfer to dry cask storage within an ISFSI.

The definition of safety-related structures, systems, and components (SSCs) in 10 CFR 50.2 states that safety-related SSCs are those relied on to remain functional during and following design basis events to assure:

1. The integrity of the reactor coolant boundary;

2. The capability to shutdown the reactor and maintain it in a safe shutdown condition; or

3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.43(a)(1) or 100.11.

The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled condition. The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits. However, after all nuclear spent fuel assemblies have been transferred to dry cask storage within an ISFSI, none of the SSCs at KPS are required to be relied on for accident mitigation. Therefore, none of the SSCs at KPS meet the definition of a safety-related SSC stated in 10 CFR 50.2. The proposed deletion of requirements in the TS does not affect systems credited in any accident analysis at KPS.

Section 14 of the KPS Updated Safety Analysis Report (USAR) described the design basis accidents (DBAs) related to the spent fuel pool. These postulated accidents are predicated on spent fuel being stored in the spent fuel pool. With the removal of the spent fuel from the spent fuel pool, there are no remaining spent fuel assemblies to be monitored and there are no credible accidents that require the actions of a Certified Fuel Handler, Shift Manager, or a Non-certified Operator to prevent occurrence or mitigate the consequences of an accident.

The proposed changes do not have an adverse impact on the remaining decommissioning activities or any of their postulated consequences.

The proposed changes related to the relocation of certain administrative requirements do not affect operating procedures or administrative controls that have the function of preventing or mitigating any accidents applicable to the safe management of irradiated fuel or decommissioning of the facility.

Serial No.15-185 Attachment 1 Page 37 of 45 Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes eliminate the operational requirements and certain design requirements associated with the storage of the spent fuel in the spent fuel pool, and relocate certain administrative controls to the Quality Assurance Program Description.

After the removal of the spent fuel from the spent fuel pool and transfer to the ISESI, there are no spent fuel assemblies that remain in the spent fuel pool.

Coupled with a prohibition against storage of fuel in the spent fuel pool, the potential for fuel related accidents is removed. The proposed changes do not introduce any new failure modes.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The removal of all spent nuclear fuel from the spent fuel pool into storage in casks within an ISFSI, coupled with a prohibition against future storage of fuel within the spent fuel pool, removes the potential for fuel related accidents.

The design basis and accident assumptions within the KPS USAR and the TS relating to safe management and safety of spent fuel 'in the spent fuel pool are no longer applicable. The proposed changes do not affect remaining plant operations, systems, or components supporting decommissioning activities.

The requirements for systems, structures, and components (SSCs) that have been deleted from the KPS TS are not credited in the existing accident analysis for any applicable postulated accident; and as such, do not contribute to the margin of safety associated with the accident analysis.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, Dominion Energy Kewaunee, Inc. concludes that the proposed amendment presents no significant hazards consideration under the standards set forth

Serial No.15-185 Attachment I Page 38 of 45 in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria General Design Criteria The US Atomic Energy Commission (AEC) issued their Safety Evaluation (SE) of the Kewaunee Power Station (KPS) on July 24, 1972 with supplements dated December 18, 1972 and May 10, 1973. The SE, Section 3.1, "Conformance with AEC General Design Criteria," described the conclusions the AEC reached associated with the General Design Criteria in effect at the time. The AEC stated:

"The Kewaunee plant was designed and constructed to meet the intent of the AEC's General Design Criteria, as originallyproposed in July 1967. Construction of the plant was about 50% complete and the Final Safety Analysis Report (Amendment No. 7) had been filed with the Commission before publication of the revised General Design Criteria in February 1971 and the present version of the criteria in July 1971. As a result, we did not require the applicant to reanalyze the plant or resubmit the FSAR.

However, our technical review did assess the plant against the General Design Criteria now in effect and we are satisfied that the plant design generally conforms to the intent of these criteria."

These General Design Criteria (GDC) are discussed in detail in the KPS USAR.

Design Basis Accidents (DBAs)

Chapter 14 of the KPS USAR described the safety analysis aspects of the plant that were evaluated to demonstrate that the plant could be decommissioned safely and that radiological consequences from postulated accidents do not exceed the guidelines of 10 CFR 50.67. The analyzed accidents were based on the four categories of plant conditions classified by the American Nuclear Society (ANS) in accordance with the anticipated frequency of occurrence and potential radiological consequences to the public (Normal Operation, Incidents of Moderate Frequency, Infrequent Incidents, and Limiting Faults).

USAR Chapter 14 currently contains descriptions of design basis safety analysis accidents that pertain to the permanently defueled condition with fuel stored in the spent fuel pool. With the station permanently shut down, with spent fuel stored within the spent fuel storage pool, only a single condition (Limiting Faults (Condition IV)) retains a design basis accident within its scope.

Serial No. 15-1 85 Attachment 1 Page 39 of 45

Condition IV, Limiting Faults Condition IV occurrences are faults that are not expected to occur but are postulated because their consequences would include the potential for the release of significant amounts of radioactive material. Condition IV faults are the most drastic, which must be designed against, and thus represent the limiting design cases.

Design Requirements Condition IV faults shall not cause a release of radioactive material that results in an undue risk to public health and safety exceeding the guidelines of 10 CFR 50.67. A single Condition IV fault shall not cause a consequential loss of required functions of systems needed to cope with the fault including those of the RCS and the Reactor Containment System.

Safety Analyses are analyses performed to satisfy regulatory requirements. The safety analyses are integral to the plant's design and licensing basis. The safety analyses demonstrate the capability to prevent or mitigate the consequences of accidents.

Systems, structures, and components (SSC) that perform design basis functions are credited in the safety analyses for the purpose of mitigating the transient or accident.

Chapter 14 of the KPS USAR described the design basis accident (DBA) scenarios that were applicable with spent nuclear fuel stored in the spent fuel pool. However, with all spent fuel stored in dry casks within the ISFSI, the fuel handling accident scenario postulated in USAR Chapter 14 is no longer applicable. The postulated accidents applicable with spent nuclear fuel stored in the spent fuel pool are listed in the following table (including the USAR section they are described in), with a statement whether or not they are applicable in the condition of all spent nuclear fuel stored within an ISFSI.

USAR Chapter 14 Postulated Accidents or Transients Aplicblitye withIF Standby Safety Features Analysis Fuel Handling Accident (FHA) (14.2.1) no USAR Section 14.2.1 describes the fuel handling accident. With all spent fuel stored in dry casks within the ISFSI, the fuel handling accident scenario postulated in USAR Chapter 14 is no longer possible and therefore no longer part of the licensing basis.

Serial No. 15-1 85 Attachment 1 Page 40 of 45 10 CFR 50.2, Definitions, Safety-Related Structures, Systems and Components 10 CFR 50.2 defines safety-related structures, systems, and components (SSCs) as those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

1. The integrity of the reactor coolant pressure boundary

2. The capability to shut down the reactor and maintain it in a safe shutdown condition; or

3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in § 50.34(a)(1) or § 100.11 of this chapter, as applicable.

10 CFR 50.36, Technical Specifications In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of Technical Specifications (TS). In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." (Statement of Consideration, "Technical Specification for Facility Licenses; Safety Analysis Reports," 33 FR 18610 (December 17, 1968).) Pursuant to 10 CFR 50.36, TS are required to include items in the following five categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TS.

In September 1992, the Commission issued NUREG-1431, which was developed using the guidance and criteria contained in the Commission's Interim Policy Statement.

Standard Technical Specifications (STS) were established as a model for developing improved TS for Westinghouse plants in general. STS reflect the results of a detailed review of the application of the interim policy statement criteria to generic system functions, which was published in a "Split Report" issued to the Nuclear Steam System Supplier (NSSS) Owners Groups in May 1988. STS also reflect the results of extensive discussions concerning various drafts of STS, so that the application of the TS criteria and the Writer's Guide would consistently reflect detailed system configurations and operating characteristics for all NSSS designs. As such, the generic Bases presented in NUREG-1431 provide an abundance of information regarding the extent to which the STS present requirements that are necessary to protect public health and safety.

On July 22, 1993, the Commission issued its Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, indicating that satisfying the guidance in the policy statement also satisfies Section 182a of the Atomic Energy Act of 1954, as amended (the Act), and 10 CFR 50.36 (58 FR 39132). The Final Policy

Serial No. 15-1 85 Attachment 1 Page 41 of 45 Statement described the safety benefits of the improved STS, and encouraged licensees to use the improved STS as the basis for plant-specific TS amendments, and for complete conversions to improved STS. Further, the Final Policy Statement gave guidance for evaluating the required scope of the TS and defined the guidance criteria to be used in determining which of the LCOs and associated surveillances should remain in the TS.

The final Commission Policy Statement established four criteria to define the scope of equipment and parameters to be included in the improved Standard Technical Specifications. These criteria were developed for licenses authorizing operation (i.e.,

operating reactors) and focused on instrumentation to detect degradation of the reactor coolant system pressure boundary, process variables and equipment, design features, or operating restrictions that affect the integrity of fission product barriers during design bases accidents or transients. A fourth criterion refers to the use of operating experience and probabilistic risk assessment to identify and include in the Technical Specifications structures, systems, and components (SSCs) shown to be significant to public health and safety. These criteria, which were subsequently codified in changes to Section 36 of Part 50 of Title 10 of the Code of FederalRegulations (10 CFR 50.36)

(60 FR 36953), also pertain to the Technical Specification requirements for safe storage of spent fuel. A general discussion of these considerations is provided below.

Criterion 1 of 10 CFR 50.36(c)(2)(ii)(A) states that Technical Specification limiting conditions for operation must be established for "installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary." Since KPS is no longer licensed to operate, this criterion is not applicable.

Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B) states that Technical Specification limiting conditions for operation must be established for a "process variable, design feature, or operating restriction that is an initial condition of a design basis accident [DBA] or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation.

Since KPS is no longer licensed to operate, this criterion is not applicable.

Criterion 3 of 10 CFR 50.36(c)(2)(ii)(C) states that Technical Specification limiting conditions for operation must be established for structures, systems, or components (SSCs) that are part of the primary success path and which function or actuate to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The intent of this criterion is to capture into Technical Specifications only those SSCs that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate

Serial No.15-185 Attachment 1 Page 42 of 45 (including consideration of the single failure criterion), so that the plant response to design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. Since fuel will have been removed from the spent fuel pool at the KPS facility prior to implementation of this amendment, this criterion is not applicable.

Criterion 4 of 10 CFR 50.36(c)(2)(ii)(D) states that Technical Specification limiting conditions for operation must be established for SSCs that operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The intent of this criterion is that risk insights and operating experience be factored into the establishment of Technical Specification limiting conditions for operation. Since fuel will have been removed from the spent fuel pool at the KPS facility prior to implementation of this amendment, this criterion is not applicable.

Addressing administrative controls, 10 CFR 50.36(c)(5) states that they "...are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner."

The particular administrative controls to be included in the TS, therefore, are the provisions that the Commission deems essential for the safe operation of the facility that are not already covered by other regulations. Accordingly, the NRC staff determined that administrative control requirements that are not specifically required under Section 50.36(c)(5), and which are not otherwise necessary to obviate the possibility of an abnormal situation or an event giving rise to an immediate threat to the public health and safety, may be relocated to more appropriate documents (e.g., Quality Assurance Program, Technical Requirements Manual, Security Plan, or Emergency Plan), which are subject to regulatory controls. Similarly, while the required content of TS administrative controls is specified in 10 CFR 50.36(c)(5), particular details may be relocated to licensee-controlled documents, where other regulations provide adequate regulatory control.

10 CFR 50.36(c)(6), "Decommissioning," applies only to nuclear power reactor facilities that have submitted the certifications required by § 50.82(a)(1). For such facilities, Technical Specifications involving safety limits, limiting safety system settings, and limiting control system settings; limiting conditions for operation; surveillance requirements; design features; and administrative controls will be developed on a case-by-case basis.

Quality Assurance Program Description (QAPD) and Technical Requirements Manual (TRM)

The Quality Assurance Program Description (QAPD) and Technical Requirements Manual (TRM) are appropriate candidates for relocations of administrative controls due to the controls imposed by such regulations as 10 CFR 50.59, Appendix B to 10 CFR Part 50, the existing NRC-approved QA plans and commitments to industry QA standards, and the established QA program change control process of 10 CFR

Serial No. 15-1 85 Attachment I Page 43 of 45 50.54(a). The TRM is part of the Updated Safety Analysis Report (USAR) and therefore subject to the requirements of 10 CFR 50.59.

Administrative Letter (AL) 95-06 NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," (http://www. nrc..qov/readin~q-rm/doc-collectionslqen-commladmin-letters/11995/a195006. html) provides guidance to licensees requesting amendments that relocate administrative controls to NRC-approved QA program descriptions, where subsequent changes are controlled pursuant to 10 CFR 50.54(a). AL 95-06 provides specific guidance in the areas of: (1) independent safety engineering group, (2) reviews and audits, (3) procedure review process, and (4) records and record retention.

Some relocations are specifically discussed in AL 95-06, while others are similar in nature. Relocations not specifically discussed in AL 95-06 were assessed with respect to the appropriateness of the relocation. Editorial changes are allowed without basis by 10 CFR 50.54(a)(3).

On February 2, 2011, the NRC issued Amendment No. 207 to Facility Operating License No. DPR-43 for KPS. The amendment consisted of changes to the Technical Specifications and the license conditions for KPS. As stated in the NRC safety evaluation accompanying Amendment 207, the amendment converted the previous custom TS (CTS) to the improved TS (ITS) and relocated certain requirements to other licensee-controlled documents. The KPS ITS are based on:

NUREG-1431, "Standard Technical Specifications (STS) Westinghouse Plants,"

Revision 3.0;

"NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," dated July 22, 1993 (58 FR 39132); and

10 CFR 50.36, "Technical Specifications."

This proposed amendment deletes the portions of the previous KPS TS that are no longer applicable to a permanently defueled facility with all irradiated fuel in dry storage within an Independent Spent Fuel Storage Installation (ISFSI), while modifying the remaining portions to correspond to the SAFSTOR decommissioning condition, consistent with STS.

10 CFR 50.51, Continuation of License 10 CFR 50.51(b) states "Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the

Serial No.15-185 Attachment 1 Page 44 of 45 licensee in writing that the license is terminated. During such period of continued effectiveness the licensee shall--

(1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and (2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRC regulations and the provisions of the specific 10 CFR part 50 license for the facility."

10 CFR 50.82, Termination of License 10 CFR 50.82(a)(2) states "Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel."

5.3 Precedent This proposed amendment is consistent with the license, and accompanying TS, issued to Zion Nuclear Power Station on January 14, 2015 (Reference 3), which was issued to reflect the unloaded spent fuel pool status of the plant.

5.4 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

DEK has evaluated this license amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. DEK has determined that this license amendment meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10)(ii).

This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50, that changes a requirement with

,*. SerialAttachment No. 15-185I Page 45 of 45 respect to installation or use of a facility component located within the restricted area, and changes to recordkeeping, reporting, or administrative procedures or requirements.

However, (i) the proposed amendment involves no significant hazards consideration, (ii) there is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusions set forth in 10 CFR 51.22(c)(9) and 10 CFR 5!1.22(c)(10)(ii).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. 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].

2. Letter from D. G. Stoddard (DEK) to NRC Document Control Desk, "Revision to Post-Shutdown Decommissioning Activities Report," dated April 25, 2014.

[ADAMS Accession No. ML14118A382].

3. License Amendments 188 and 175 and associated NRC safety evaluation issued to Zion Nuclear Power Station Units 1 and 2, respectively, dated January 14, 2015 [ADAMS Accession No. ML14295A716].

4. Letter from Paul Triska (Areva TN) to NRC Document Control Desk, "Application for Revision to the Standardized NUHOMS System - CoC 1004, Amendments 0 through 11 and Amendment 13, Docket 72-1004," dated August 24, 2015.

Serial No. 15-1 85 ATTACHMENT 2 LICENSE AMENDMENT REQUEST 260 PROPOSED CHANGES TO LICENSE AND TECHNICAL SPECIFICATIONS TO REFLECT PERMANENT REMOVAL OF SPENT FUEL FROM SPENT FUEL POOL MARKED UP TECHNICAL SPECIFICATIONS PAGES:

TS "TABLE OF CONTENTS" TS 4.1 "Site Location" TS 5.7 "High Radiation Area" (retained in TS unchanged; listed here as placeholder only; no__t included in this Attachment 2)

(TS not listed above are deleted in their entirety.)

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

4

,4i

1. USEIIQ-ANDl' APPLICAOT/IONl

1. einlitions ......................................... . . . . . .. . . . . . . . .. . . . . . . . ... 114 ...

,I mi i f^ l 4,* ^,^. *1 "' .1 1.3 Comleio Times.......................................................................1.3 1.-

.1. Frequency*÷;,- 1.1m* "1_

3.0 LIMITING CONDITION.........FOR PE.... TI.ON

... (LCO)...APPLICABILITY...................

.. *....3.0 1.

3. SUVEL4NEREUIEEN.SR.APICBLIY............. 14-3.7 PLNAIT" SYSTEMSkA 3.7.11 Spent Fu-.el Pool Boron Concentration ........................ 7.1 4.0 DESIGN FEATURES ...................................................................... 4.0-1 4.1 Site Location ............................................................................ 4.0-1 4.3 Fuel Storage ............................................................................ 4.0-1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibilit............................. 1 5.2 Organ.izat+ion.........................5.2..1 5.1 Procedff ures......ns................................................................. 5.1 1 5.5 Programs~ and Manuals......................................................................5.5 1 5.6 Reoring R equaioArements................................................................ 5.6-1 Kewaunee Power Station xvi xlviii mnmn No.

Amendment o

A Design Features i 4.0 4.0 DESIGN FEATURES 4.1 Site Location The Kewaunee Power Station is located on property owned by Dominion Energy Kewaunee Inc. at a site on the west shore of Lake Michigan, approximately 30 miles east-southeast of the city of Green Bay, Wisconsin.

4.2 Deleted 4.3 Fuel Storage Spent fuel shall not be stored in the spent fuel pool.

J X A J mm mP I I I I .. . . . . i with, allownce fr uncrtainies as descibe in Scio/l n 9. of th

*** ,*-lSAI.,-,R , +* *,*,,1, 1 1.3.1.2 Deleted 1.3.2 Drainsc~q The sorag pen ful pol i deigne an hll e mintiedt peven l I I I%

dl I I inanver'tent ar'in'n ot

...... te r ......... n'^'"

noni ciev"rion *1 ,r "! 'nene 'men

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se "e'"n.

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1.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1205 fuel assemblies.

Kewaunee Power Station40-AmnetNo 4.0-1 Amendment No.

ML15261A236

Text

References:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 TECHNICAL ANALYSIS

SUMMARY

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 TECHNICAL ANALYSIS

SUMMARY

1.3 TECHNICAL ANALYSIS

SUMMARY

3.1 DESCRIPTION

3.2 PROPOSED CHANGE

3.3 TECHNICAL ANALYSIS

SUMMARY

37.1 DESCRIPTION

37.2 PROPOSED CHANGE

37.3 TECHNICAL ANALYSIS

SUMMARY

4.1 DESCRIPTION

4.2 PROPOSED CHANGE

4.3 TECHNICAL ANALYSIS

SUMMARY

5.1 DESCRIPTION

5.2 PROPOSED CHANGE

5.3 TECHNICAL ANALYSIS

SUMMARY

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

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