WM 20-0006, (WCGS) - License Amendment Request for Change to Owner Licensee Names

(WCGS) - License Amendment Request for Change to Owner Licensee Names

ML20310A201
Person / Time
Site:	Wolf Creek
Issue date:	11/04/2020
From:	Reasoner C Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WM 20-0006
Download: ML20310A201 (23)

Text

Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer November 4, 2020 WM 20-0006 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

Letter dated March 12, 2018, from B. K. Singal, USNRC, to A. C. Heflin, WCNOC, Wolf Creek Generating Station, Unit 1 - Order Approving Indirect Transfer of Control of Renewed Facility Operating License No.

NPF-42 (CAC No. MG0235, EPIC L-2017-LLM-0005)

Subject:

Docket No. 50-482: License Amendment Request for Change to Owner Licensee Names Commissioners and Staff:

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR Part 50.90), Application for amendment of license, construction permit, or early site permit, Wolf Creek Nuclear Operating Corporation (WCNOC), acting on behalf of itself and the owner licensees of the Wolf Creek Generating Station (WCGS), is submitting a request for an amendment to Renewed Facility Operating License No. NPF-42. The proposed administrative amendment would modify Renewed License No. NPF-42 to reflect a corporate name change for the owner licensee names for Kansas Gas and Electric Company to Evergy Kansas South, Inc.

and Kansas City Power & Light Company to Evergy Metro, Inc.

The Reference issued an NRC order for the indirect transfer of control resulting from the combination of the parent companies of two separate 47% owners of WCGS. Together, the combined parent (Holdco in the Reference), presently named Evergy, Inc. holds 94% of the ownership of both WCGS and the voting stock of WCNOC, the NRC licensed operator of the generating station.

Attachment I provides a detailed description of the proposed operating license changes, a technical analysis of the proposed changes, a determination that the proposed changes do not involve a significant hazard consideration, a regulatory analysis of the proposed changes, and an environmental evaluation. Attachment II provides markups of the affected pages of the WCGS operating license. Attachment III provides a clean copy of the affected pages of the WCGS operating license, as amended.

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

WM 20-0006 Page 2 of 3 WCNOC requests approval of this license amendment request by September 16, 2021. The license amendment, as approved, will be effective upon issuance and will be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, Section (b)(1),

a copy of this amendment application, with Attachments, is being provided to the designated Kansas State official.

There are no regulatory commitments contained in this submittal. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Ron Benham at (620) 364-4204.

Sincerely, Cleveland Reasoner COR/rlt Attachments: I Evaluation of the Proposed Change II Proposed Operating License Changes (Mark-up)

III Revised Operating License Pages cc: S. S. Lee (NRC), w/a S. A. Morris (NRC), w/a N. OKeefe (NRC), w/a K. S. Steves (KDHE), w/a Senior Resident Inspector (NRC), w/a

WM 20-0006 Page 3 of 3 STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Cleveland Reasoner, of lawful age, being first duly sworn upon oath says that he is Chief Executive Officer and Chief Nuclear Officer of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer SUBSCRIBED and sworn to before me this 4 ' 3/4ay of (\ou-ef'A.,be r , 2020.

RHONDA L. TIEMEYER CJ.,tOzuia Notary Public cP d@tl2e1:fl0 Notary Public, State of Kansas MY Appointment Expires

. I .

Expiration Dat~OOUIMf( / /1 dt2J:J

Attachment I to WM 20-0006 Page 1 of 6 EVALUATION OF THE PROPOSED CHANGE

Subject:

License Amendment Request for Change to Owner Licensee Names 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

6.0 REFERENCES

Attachment I to WM 20-0006 Page 2 of 6 EVALUATION 1.0

SUMMARY

DESCRIPTION The proposed amendment would modify Renewed Facility Operating License No. NPF-42 to change the owner licensee names for Kansas Gas and Electric Company to Evergy Kansas South, Inc. and Kansas City Power & Light Company to Evergy Metro, Inc.

2.0 DETAILED DESCRIPTION In Reference 6.1, Wolf Creek Nuclear Operating Corporation (WCNOC) submitted a request for consent to indirect transfer of control of Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS) as a result of the proposed merger of two of the indirect owners of WCNOC and WCGS, Great Plains Energy Incorporated (Great Plains) and Westar Energy, Inc. (Westar). In Reference 6.2, the Nuclear Regulatory Commission (NRC) issued an order approving the proposed indirect ownership transfer. WCNOC submitted an updated request (Reference 6.3) for consent to indirect transfer of control as a result of the Kansas Corporation Commission declining to approve the transaction.

The NRC issued an order (Reference 6.4) providing its consent for the indirect transfer of control resulting from the combination of the parent companies of two separate 47% owners of WCGS.

Together, the combined parent (Holdco in Reference 6.4), presently named Evergy, Inc., holds 94% of the ownership of both WCGS and the voting stock of WCNOC, the NRC licensed operator of WCGS. As a result of the same transaction, WCNOC became part of the larger Evergy group of companies (i.e., Evergy Metro, Inc., Evergy Kansas Central, Inc., and Evergy Kansas South, Inc.). WCNOC notified the NRC that the completion of the merger occurred on June 4, 2018 (Reference 6.5). Figure 1 below provides a simplified organizational chart post completion of the merger.

Figure 1

Attachment I to WM 20-0006 Page 3 of 6 Consistent with obtaining the efficiencies of the combined ownership, on January 1, 2020 (Reference 6.6) Evergy transitioned WCNOC workers to employees of Evergy Kansas Central, Inc. (f/k/a Westar Energy, Inc), which is the 100% owner of Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company), a 47% owner of WCNOC. Figure 2 below provides an Evergy WCNOC simplified organizational chart.

Figure 2 Consistent with the integration of the combined companies, the Renewed Facility Operating License No. NPF-42 is being revised to reflect the new names of the owner licensees Kansas Gas and Electric Company to Evergy Kansas South, Inc. and Kansas City Power & Light Company to Evergy Metro, Inc. The effect of this proposed change for the WCGS operating license is shown on the attached markups in Attachment II. Attachment III provides clean copies of those same pages.

3.0 TECHNICAL EVALUATION

The personnel reorganization described in Section 2.0 above, allows Evergy to realize the economic advantages of the benefits of its combined size. Evergy Kansas Central, Inc. is an intermediate parent of WCNOC and will continue to provide operating services (specifically, the same WCNOC personnel) to WCNOC under the Wolf Creek General Support Services Agreement.

The proposed changes to the operating license are administrative in nature. There will be no change to the Board of Directors or officers or management of WCNOC as a result of this reorganization. Officers and senior managers of WCNOC who currently exercise ultimate decision-making authority over decisions involving nuclear safety or security at WCNOC will retain

Attachment I to WM 20-0006 Page 4 of 6 their positions and authority at WCNOC while also becoming employees of Evergy Kansas Central, Inc. This dual hatting of the Chief Executive Officer/Chief Nuclear Officer and other officers ensures that decisions exercised by those licensee officials may not be modified, overruled, or reversed except by the WCNOC licensee. The proposed changes will not result in any physical changes or changes to the operation of WCGS. The makeup of the WCGS site organization will remain unchanged and continue to operate according to the operating licensee's Appendix B programs and procedures. The owner licensee name changes do not result in a functional change to the operating organization, its technical qualifications, the facility, or the plant technical specifications. WCNOC will continue as the licensed operator of WCGS.

4.0 REGULATORY ANALYSIS

This section addresses the standards of 10 CFR 50.92, Issuance of amendment, as well as the applicable regulatory requirements and acceptance criteria.

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether the applicable regulations and requirements, noted below, continue to be met.

This request is being submitted to the NRC pursuant to 10 CFR 50.90 only for the purpose of updating the affected portions of the WCGS operating license. The proposed change does not alter any technical content of the WCGS facility operating license or any technical content of the Technical Specifications requirements, nor does it have any effect on the Quality Assurance Program description.

Under 10 CFR 50.80, Transfer of licenses, no license or control of a license for a utilization facility may be transferred, directly or indirectly, to any entity unless the NRC consents in writing.

However, licensee name changes do not, by themselves, constitute license transfers. The NRC issued an order (Reference 4) providing its consent for the indirect transfer of control resulting from the combination of the parent companies of two separate 47% owners of WCGS. Together, the combined parent ("Holdco" in Reference 4), presently named Evergy, Inc., holds 94% of the ownership of both WCGS and the voting stock of WCNOC.

4.2 No Significant Hazards Consideration Determination The proposed amendment would modify Renewed Facility Operating License No. NPF-42 to change the owner licensee names for Kansas Gas and Electric Company to Evergy Kansas South, Inc. and Kansas City Power & Light Company to Evergy Metro, Inc.

Wolf Creek Nuclear Operating Corporation (WCNOC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 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

Attachment I to WM 20-0006 Page 5 of 6 The proposed amendment changes the name of the owner licensees. The proposed change is administrative in nature. The proposed changes do not result in a functional change to the operating organization, its technical qualifications, the facility, or the plant technical specifications. WCNOC will continue as the licensed operator of the Wolf Creek Generating Station (WCGS). The proposed changes do not adversely affect accident initiators or precursors, and do not alter the design assumptions, conditions, or configuration of the plant or the manner in which the plant is operated and maintained.

The ability of structures, systems, and components to perform their intended safety functions in not altered or prevented by the proposed changes, and the assumptions used in determining the radiological consequences of previously evaluated accidents are not affected.

Therefore, the proposed change 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 change is administrative in nature. The proposed changes do not result in a functional change to the operating organization, its technical qualifications, the facility, or the plant technical specifications. WCNOC will continue as the licensed operator of the WCGS. These changes do not involve any physical alteration of the plant (i.e., no new or different type of equipment will be installed), and installed equipment is not being operated in a new or different manner. Thus, no new failure modes are introduced.

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

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

Response: No The proposed change is administrative in nature. The proposed changes do not result in a functional change to the operating organization, its technical qualifications, the facility, or the plant technical specifications. WCNOC will continue as the licensed operator of the WCGS. The proposed changes do not alter the manner in which safety limits, limiting safety system settings, of limiting conditions of operation are determined. There are no changes to setpoints at which protective actions are initiated, and the operability requirements for equipment assumed to operate for accident mitigation are not affected.

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

Attachment I to WM 20-0006 Page 6 of 6 4.4 Conclusion Based on the considerations discussed herein, (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.

5.0 ENVIRONMENTAL CONSIDERATION

WCNOC has reviewed the proposed amendment against the criteria of 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, for environmental considerations.

The proposed changes do not involve a significant hazards consideration, nor does it significantly change the types or significantly increase individual the amounts of effluent that may be released offsite. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion from environmental assessments or environmental impact statements set forth in 10 CFR 51.22(c)(10)(iii) (exempting any license amendment that only Changes the licensees or permit holders name, phone number, business or e-mail address). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1. WCNOC letter WM 16-0013, Request for Consent to Indirect Transfer of Control, July 22, 2016. ADAMS Accession No. ML16208A250.

6.2 Letter from B. K. Singal, USNRC, to A. Heflin, WCNOC, Wolf Creek Generating Station, Unit 1 - Order Approving Indirect Transfer of Control of Renewed Facility Operating License No. NPF-42 (CAC No. MF8168), April 7, 2017. ADAMS Accession No. ML17037D120.

6.3. WCNOC letter WM 17-0021, Updated Request for Consent to Indirect Transfer of Control, September 5, 2017. ADAMS Accession No. ML17255A222.

6.4 Letter from B. K. Singal, USNRC, to A. C. Heflin, WCNOC, Wolf Creek Generating Station, Unit 1 - Order Approving Indirect Transfer of Control of Renewed Facility Operating License No. NPF-42 (CAC No. MG0235; EPID L-2017-LLM-0005), March 12, 2018. ADAMS Accession No. ML18040A666.

6.5 WCNOC letter WM 18-0036, Notice of Closing, June 5, 2018. ADAMS Accession No. ML18163A125.

6.6 WCNOC letter RA 19-0151, Wolf Creek Generating Station, Unit 1 - Entry int. Wolf Creek General Support Services Agreement with Evergy Inc. entities, December 10, 2019.

ADAMS Accession No. ML19352E138.

Attachment II to WM 20-0006 Page 1 of 7 ATTACHMENT II PROPOSED OPERATING LICENSE CHANGES (MARK-UP)

Attachment II to WM 20-0006 Page 2 of 7 EVERGY KANSAS SOUTH, INC.

EVERGY METRO, INC.

KANSAS GAS AND ELECTRIC COMPANY KANSAS CITY POWER & LIGHT COMPANY KANSAS ELECTRIC POWER COOPERATIVE, INC.

WOLF CREEK NUCLEAR OPERATING CORPORATION DOCKET NO. 50-482 WOLF CREEK GENERATING STATION, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE Renewed License No. NPF-42

1. The Nuclear Regulatory Commission (the Commission), having previously made the findings set forth in License No. NPF-42, has now found that:

A. The application for a renewed operating License No. NPF-42 filed by Wolf Creek Nuclear Operating Corporations* (WCNOC), complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the rules and regulations of the Commission as set forth in Title 10, Chapter I, CFR, and all required notifications to other agencies or bodies have been duly made; B. Construction of the Wolf Creek Generating Station, Unit 1 (the facility) has been substantially completed in conformity with Construction Permit No. CPPR-147 and the application, as amended, the provisions of the Act, and the regulations of the Commission; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission, (except as exempted from compliance in Section 2.D below);

D. There is reasonable assurance: (i) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I, (except as exempted from compliance in Section 2D below);

E. Wolf Creek Nuclear Operating Corporation* is technically qualified to engage in the activities authorized by this license in accordance with the Commission's regulations set forth in 10 CFR Chapter I;

• Wolf Creek Nuclear Operating Corporation is authorized to act as agent for the Kansas Gas and Electric Company, Kansas City Power & Light Company, and Kansas Electric Power Cooperative, Inc., and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company), Evergy Renewed License No. NPF-42 Metro, Inc. (f/k/a Kansas City Power & Light Company)

Historic reference to the Kansas Gas and Electric Company and the Kansas City Power & Light Company is not changed.

Attachment II to WM 20-0006 Evergy Kansas South, Inc. (f/k/a Kansas Gas and Page 3 of 7 Electric Company), Evergy Metro, Inc. (f/k/a Kansas City 3 Power & Light Company)

A. This renewed operating license applies to the Wolf Creek Generating Station, Unit No. 1, a pressurized water nuclear reactor and associated equipment (the 1

facility), owned by Kansas Gas and Electric Company , Kansas City Power &

Light Company, and Kansas Electric Power Cooperative, Inc., and operated by the Wolf Creek Nuclear Operating Corporation. The facility is located in Coffey County, Kansas, approximately 28 miles east-southeast of Emporia, Kansas, and is described in the licensee's "Final Safety Analysis Report," as supplemented and amended, and in the licensees' Environmental Report, as supplemented and amended.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Wolf Creek Nuclear Operating Corporation (the Operating Corporation), Kansas Gas and Electric Company (KG&E), Kansas City Power &

Light Company (KCPL), and Kansas Electric Power Cooperative, Inc. (KEPCO):

(1) Pursuant to Section 103 of the Act and 10 CFR Part 50 "Domestic Licensing of Production and Utilization Facilities," the Operating Corporation, to possess, use and operate the facility at the designated location in Coffey County, Kansas, in accordance with the procedures and Evergy Kansas South, Inc., limitations set forth in this license; Evergy Metro, Inc.

(2) KG&E, KCPL and KEPCO to possess the facility at the designated location in Coffey County, Kansas, in accordance with the procedures and limitations set forth in this license; (3) The Operating Corporation, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; 1

Kansas Gas and Electric Company, which owns a 47% undivided interest in the Wolf Creek Nuclear Operating Corporation and a 47% undivided interest in a possession-only license for the Wolf Creek Generating Station, has merged with and into a wholly owned subsidiary of The Kansas Power and Light Company. This subsidiary, originally named KCA Corporation, was renamed "Kansas Gas and Electric Company" upon consummation of the merger. Accordingly, the name "Kansas Gas and Electric Company" as it appears in this license refers to the post-merger Kansas Gas and Electric Company and not the former entity of the same name.

Renewed License No. NPF-42

Attachment II to WM 20-0006 Page 4 of 7 4

(5) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The Operating Corporation is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100%

power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions Evergy Kansas South, Inc. and Evergy Metro, Inc. Kansas Gas & Electric Company and Kansas City Power & Light Company shall comply with the antitrust conditions delineated in Appendix C to this license.

(4) Environmental Qualification (Section 3.11, SSER #4, Section 3.11, SSER #5)*

Deleted per Amendment No. 141.

• The parenthetical notation following the title of many license conditions denotes the section of the supporting Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-42 Amendment No. 223

Attachment II to WM 20-0006 Page 5 of 7 APPENDIX B TO FACILITY OPERATING LICENSE NO. NPF-42 EVERGY KANSAS SOUTH, INC.

EVERGY METRO, INC. KANSAS GAS AND ELECTRIC COMPANY KANSAS CITY POWER & LIGHT COMPANY KANSAS ELECTRIC POWER COOPERATIVE, INC.

WOLF CREEK GENERATING STATION UNIT 1 DOCKET NO. 50-482 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)

Attachment II to WM 20-0006 Page 6 of 7 APPENDIX C WOLF CREEK, UNIT 1 EVERGY KANSAS SOUTH, INC.

ANTITRUST CONDITIONS FOR KANSAS GAS AND ELECTRIC COMPANY Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company)

1. As used herein:

(a) Licensee means Kansas Gas and Electric Company.

(b) Licensees Service Area means those counties located in whole or in part within the area certificated to Licensee and Western Resources KPL division by the appropriate state regulatory commission. Evergy Kansas Central, Inc. (f/k/a Westar Energy, Inc.)

(c) Bulk Power means the electric power, and any attendant energy, supplied or made available at transmission or subtransmission voltage by one entity to another.

(d) Emergency support is capacity and energy as available from one system, and as needed by another system to replace capacity and energy made unavailable due to forced outages of generating equipment or transmission facilities.

(e) Maintenance support is capacity and energy planned by one system to be made available to another system to replace capacity and energy made unavailable due to forced maintenance of generating equipment or transmission facilities.

(f) Entity means a financially responsible private or public corporation, governmental agency or authority, municipality, cooperative, or lawful association of any of the foregoing, owning, contractually controlling, or operating, or in good faith proposing to own, contractually control, or operate, facilities for the generation and transmission of electricity for bulk power supply which meets each of the following criteria: (1) its existing or proposed facilities are technically feasible of interconnection with those of Licensee; (2) with the exception of municipalities, cooperatives, government agencies or authorities it is, or upon commencement of operations will be, a public utility subject to regulation with respect to rates and services under the laws of Kansas.

(g) KEC refers to Kansas Electric Cooperatives, Inc. or Kansas Electric Power Cooperative, Inc. insofar as it shall become a successor in interest.

(h) KEPCo refers to Kansas Electric Power Cooperative, Inc. as the successor in interest to KEC.

(i) KEPCo Members in Licensees Service Area refers to all KEPCo Member rural electric cooperatives with facilities in the combined service area of Western Resources KPL division and Kansas Gas and Electric Company.

(j) Power Requirements of the KEPCo Members in Licensees Service Area refers to the sum for all such KEPCo Members of the delivery point contributions to Western Resources KPL divisions greatest one hour net load for the month.

Evergy Kansas Central, Inc.

Amendment No. 147 Evergy Kansas Central, Inc. (f/k/a Westar Energy, Inc.) and Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company).

Attachment II to WM 20-0006 Page 7 of 7 APPENDIX C EVERGY METRO, INC.

WOLF CREEK, UNIT 1 ANTITRUST CONDITIONS FOR KANSAS CITY POWER & LIGHT COMPANY Evergy Metro, Inc.

1. As used herein:

(a) Licensee means Kansas City Power & Light Company.

(b) Licensees Service Area means those portions of the States of Missouri and Kansas, which are certificated, to Licensee by the respective state regulatory commissions. An entity shall be deemed to be in the Licensees Service Area if it has electric power generation, transmission or distribution facilities located in whole or in part in or adjacent to the above-described area or in counties served in part at retail by Licensee.

(c) Bulk Power means the electric power, and any attendant energy, supplied or made available at transmission or subtransmission voltage by one entity to another.

(d) Entity means person, a private or public corporation, a municipality, a cooperative, a joint stock association, business trust or a lawful association of any of the foregoing constituting, a separate legal entity owning, operating or proposing to own or operate equipment or facilities for the generation, transmission, or distribution of electricity, provided that, except for municipalities and cooperatives, an entity is restricted to those which are or will be a public utility under the laws of the state in which the entity transacts business or under the Federal Power Act and are or will be providing electric service under a contract or rate schedule on file with and subject to the regulation of a state regulatory commission or the Federal Power Commission.

(d) Cost means any and all operating, maintenance, general and administrative expenses, together with any and all ownership costs, which are reasonably allocable to the transaction consistent with industry practices. Cost shall include a reasonable return on Licensees investment. The

Attachment III to WM 20-0006 Page 1 of 7 ATTACHMENT III REVISED OPERATING LICENSE PAGES

EVERGY KANSAS SOUTH, INC.

EVERGY METRO, INC.

KANSAS ELECTRIC POWER COOPERATIVE, INC.

WOLF CREEK NUCLEAR OPERATING CORPORATION DOCKET NO. 50-482 WOLF CREEK GENERATING STATION, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE Renewed License No. NPF-42

1. The Nuclear Regulatory Commission (the Commission), having previously made the findings set forth in License No. NPF-42, has now found that:

A. The application for a renewed operating License No. NPF-42 filed by Wolf Creek Nuclear Operating Corporations* (WCNOC), complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the rules and regulations of the Commission as set forth in Title 10, Chapter I, CFR, and all required notifications to other agencies or bodies have been duly made; B. Construction of the Wolf Creek Generating Station, Unit 1 (the facility) has been substantially completed in conformity with Construction Permit No. CPPR-147 and the application, as amended, the provisions of the Act, and the regulations of the Commission; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission, (except as exempted from compliance in Section 2.D below);

D. There is reasonable assurance: (i) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I, (except as exempted from compliance in Section 2D below);

E. Wolf Creek Nuclear Operating Corporation* is technically qualified to engage in the activities authorized by this license in accordance with the Commission's regulations set forth in 10 CFR Chapter I;

• Wolf Creek Nuclear Operating Corporation is authorized to act as agent for the Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company), Evergy Metro, Inc. (f/k/a Kansas City Power & Light Company), and Kansas Electric Power Cooperative, Inc., and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility. Historic reference to the Kansas Gas and Electric Company and the Kansas City Power

& Light Company is not changed.

Renewed License No. NPF-42

3 A. This renewed operating license applies to the Wolf Creek Generating Station, Unit No. 1, a pressurized water nuclear reactor and associated equipment (the facility),

owned by Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company),

Evergy Metro, Inc. (f/k/a Kansas City Power & Light Company), and Kansas Electric Power Cooperative, Inc., and operated by the Wolf Creek Nuclear Operating Corporation. The facility is located in Coffey County, Kansas, approximately 28 miles east-southeast of Emporia, Kansas, and is described in the licensee's "Final Safety Analysis Report," as supplemented and amended, and in the licensees' Environmental Report, as supplemented and amended.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Wolf Creek Nuclear Operating Corporation (the Operating Corporation), Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company), Evergy Metro, Inc. (f/k/a Kansas City Power & Light Company), and Kansas Electric Power Cooperative, Inc. (KEPCO):

(1) Pursuant to Section 103 of the Act and 10 CFR Part 50 "Domestic Licensing of Production and Utilization Facilities," the Operating Corporation, to possess, use and operate the facility at the designated location in Coffey County, Kansas, in accordance with the procedures and limitations set forth in this license; (2) Evergy Kansas South, Inc., Evergy Metro, Inc. and KEPCO to possess the facility at the designated location in Coffey County, Kansas, in accordance with the procedures and limitations set forth in this license; (3) The Operating Corporation, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; Renewed License No. NPF-42

4 (5) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The Operating Corporation is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100%

power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions Evergy Kansas South, Inc. and Evergy Metro, Inc. shall comply with the antitrust conditions delineated in Appendix C to this license.

(4) Environmental Qualification (Section 3.11, SSER #4, Section 3.11, SSER

1. 5)*

Deleted per Amendment No. 141.

• The parenthetical notation following the title of many license conditions denotes the section of the supporting Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-42 Amendment No.

APPENDIX B TO FACILITY OPERATING LICENSE NO. NPF-42 EVERGY KANSAS SOUTH, INC.

EVERGY METRO, INC.

KANSAS ELECTRIC POWER COOPERATIVE, INC.

WOLF CREEK GENERATING STATION UNIT 1 DOCKET NO. 50-482 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)

APPENDIX C WOLF CREEK, UNIT 1 ANTITRUST CONDITIONS FOR EVERGY KANSAS SOUTH, INC.

1. As used herein:

(a) Licensee means Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company).

(b) Licensees Service Area means those counties located in whole or in part within the area certificated to Licensee and Evergy Kansas Central, Inc. (f/k/a Westar Energy, Inc.) by the appropriate state regulatory commission.

(c) Bulk Power means the electric power, and any attendant energy, supplied or made available at transmission or subtransmission voltage by one entity to another.

(d) Emergency support is capacity and energy as available from one system, and as needed by another system to replace capacity and energy made unavailable due to forced outages of generating equipment or transmission facilities.

(e) Maintenance support is capacity and energy planned by one system to be made available to another system to replace capacity and energy made unavailable due to forced maintenance of generating equipment or transmission facilities.

(f) Entity means a financially responsible private or public corporation, governmental agency or authority, municipality, cooperative, or lawful association of any of the foregoing, owning, contractually controlling, or operating, or in good faith proposing to own, contractually control, or operate, facilities for the generation and transmission of electricity for bulk power supply which meets each of the following criteria: (1) its existing or proposed facilities are technically feasible of interconnection with those of Licensee; (2) with the exception of municipalities, cooperatives, government agencies or authorities it is, or upon commencement of operations will be, a public utility subject to regulation with respect to rates and services under the laws of Kansas.

(g) KEC refers to Kansas Electric Cooperatives, Inc. or Kansas Electric Power Cooperative, Inc. insofar as it shall become a successor in interest.

(h) KEPCo refers to Kansas Electric Power Cooperative, Inc. as the successor in interest to KEC.

(i) KEPCo Members in Licensees Service Area refers to all KEPCo Member rural electric cooperatives with facilities in the combined service area of Evergy Kansas Central, Inc.

(f/k/a Westar Energy, Inc.) and Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company).

(j) Power Requirements of the KEPCo Members in Licensees Service Area refers to the sum for all such KEPCo Members of the delivery point contributions to Evergy Kansas Central, Inc. greatest one hour net load for the month.

Amendment No.

APPENDIX C WOLF CREEK, UNIT 1 ANTITRUST CONDITIONS FOR EVERGY METRO, INC.

1. As used herein:

(a) Licensee means Evergy Metro, Inc.

(b) Licensees Service Area means those portions of the States of Missouri and Kansas, which are certificated, to Licensee by the respective state regulatory commissions. An entity shall be deemed to be in the Licensees Service Area if it has electric power generation, transmission or distribution facilities located in whole or in part in or adjacent to the above-described area or in counties served in part at retail by Licensee.

(c) Bulk Power means the electric power, and any attendant energy, supplied or made available at transmission or subtransmission voltage by one entity to another.

(d) Entity means person, a private or public corporation, a municipality, a cooperative, a joint stock association, business trust or a lawful association of any of the foregoing constituting, a separate legal entity owning, operating or proposing to own or operate equipment or facilities for the generation, transmission, or distribution of electricity, provided that, except for municipalities and cooperatives, an entity is restricted to those which are or will be a public utility under the laws of the state in which the entity transacts business or under the Federal Power Act and are or will be providing electric service under a contract or rate schedule on file with and subject to the regulation of a state regulatory commission or the Federal Power Commission.

(d) Cost means any and all operating, maintenance, general and administrative expenses, together with any and all ownership costs, which are reasonably allocable to the transaction consistent with industry practices. Cost shall include a reasonable return on Licensees investment. The