Text

License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool
	ML21050A189
Person / Time
Site:	Duane Arnold
Issue date:	02/19/2021
From:	Hansen P; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	NG-20-0094
	Download: ML21050A189 (96)
	v • d • e

{{#Wiki_filter:NEXTera. ENERGY~ DUANE ARNOLD February 19, 2021 NG-20-0094 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool Pursuant to 10 CFR 50.90, NextEra Energy Duane Arnold, LLC (NEDA) is submitting a request for an amendment to the Facility License (FL) and Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC). The proposed changes will revise the FL and TS to reflect removal of all spent nuclear fuel from the Spent Fuel Pool (SFP) and its transfer to dry cask storage within the DAEC Independent Spent Fuel Storage Installation (ISFSI). The proposed changes include the relocation of administrative controls from the DAEC TS to the DAEC Quality Assurance Topical Report (QATR). By letter dated August 27, 2020 (Accession No. ML20240A067), NEDA certified permanent cessation of power operations at the DAEC. By letter dated October 12, 2020 (ML20286A317), NEDA certified permanent defueling of the reactor at DAEC. Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for DAEC no longer authorizes operations of the reactor or emplacement or retention of fuel into the reactor vessel. The transfer of all spent fuel to the ISFSI is expected to be completed in 2022. In support of this condition, a revision to the DAEC FL and TS is proposed to comport with the requirements for a facility configuration with all spent nuclear fuel in dry storage within an ISFSI. The Enclosure to this letter provides NEDA's evaluation of the proposed change. Attachment 1 to the enclosure provides markups of the FL and TS showing the proposed changes, and Attachment 2 provides the clean FL and TS pages containing the proposed TS changes. The TS Bases will be eliminated since the corresponding TS Sections are proposed for deletion. NEDA requests approval of the proposed license amendment by December 1, 2021. Once approved, the amendment will be implemented within 60 days following NEDA notification to the NRC that all spent nuclear fuel has been transferred out of the SFP and placed within the ISFSI. NextEra Energy Duane Arnold , LLC, 3277 DAEC Road , Palo , IA 52324

Document Control Desk NG-20-0094 Page 2 of :2 In accordance with 10 CFR 50.91, a copy of this application with enclosure is being provided to the designated State of Iowa official. As discussed in the Enclosure, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. The DAEC Onsite Review Group has reviewed the proposed license amendment. This letter contains the following regulatory commitments. Prior to implementation of this 5.1.1 "Responsibility" proposed amendment, the 5.2.1 "Onsite and Offsite Organization" requirements in the following 5.3.1 "Facility Staff Qualifications" Technical Specification Sections will 5.4.1 "Procedures" be relocated to the QATR as 5.5.1 "Offsite Dose Assessment Manual" described in Section 3.0 of the 5.5.4 "Radioactive Effluent Controls Program" Enclosure to this submittal. 5.6.2 "Annual Radiological Environmental Operating Report" 5.6.3 "Radioactive Material Release Report" Prior to implementation of this 5.5.8 "Storage Tank Radioactivity Monitoring proposed amendment, the Program" requirements in the following Technical Specification Section will be relocated to a licensee-controlled document as described in Section 3.0 of the Enclosure to this submittal. If you have any questions or require additional information, please contact Michael Davis, Licensing Manager, at 319-851-7032. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 19, 2021 Paul Hansen Decommissioning Director NextEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region Ill, Project Manager, USNRC, Duane Arnold Energy Center Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)

Enclosure NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER NG-20-0094 LICENSE AMENDMENT REQUEST (TSCR-189) DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 2 of 29 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER License Amendment Request (TSCR-189): Application to Revise Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool EVALUATION OF PROPOSED CHANGE 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions 5.0 Environmental Considerations - Proposed Facility License and Technical Specification Changes (Mark-Up) - Revised Facility License and Technical Specification Pages (Clean, with Proposed Changes)

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 3 of 29 1.0

SUMMARY

DESCRIPTION NextEra Energy Duane Arnold, LLC (NEDA) requests an amendment to the Duane Arnold Energy Center (DAEC) Facility License (FL) and Technical Specifications (TS). The proposed changes will revise the DAEC TS Chapter 1.0, "USE AND APPLICATION," Chapter 3.0, "APPLICABILITY," Chapter 4.0, "DESIGN FEATURES" and Chapter 5.0, "ADMINISTRATIVE CONTROLS." The proposed changes will revise the FL and TS to reflect removal of all spent nuclear fuel from the Spent Fuel Pool (SFP) and its transfer to dry cask storage within the DAEC Independent Spent Fuel Storage Installation (ISFSI). The proposed changes include the relocation of administrative controls from the DAEC TS to the DAEC Quality Assurance Topical Report (QATR). By letter dated August 27, 2020 (Accession No. ML20240A067), NEDA certified permanent cessation of power operations at the DAEC. By letter dated October 12, 2020 (ML20286A317), NEDA certified permanent defueling of the reactor at DAEC. Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for DAEC no longer authorizes operations of the reactor or emplacement or retention of fuel into the reactor vessel. The transfer of all spent fuel to the ISFSI is expected to be completed in 2022. In support of this condition, a revision to the DAEC FL and TS is proposed to comport with the requirements for a facility configuration with all spent nuclear fuel in dry storage within an ISFSI. The proposed changes would be implemented within 60 days following NEDA notification to the NRC that all spent nuclear fuel has been transferred out of the SFP and placed within the ISFSI. Pending Licensing Actions under NRC Review There are two other pending licensing actions currently under NRC review that involve proposed changes to the Facility License. A general description of these separate licensing actions is provided below. License Amendment Request (TSCR-185): Application to Revise Operating License to Remove Cyber Security Plan Requirements (ML20136A374). This license amendment request proposes the removal of the existing Cyber Security Plan (CSP) requirements contained in License Condition 2.C(5). License Amendment Request (TSCR-188): Proposed Change to the Physical Security Plan for the Post-Shutdown and Permanently Defueled Condition. This license amendment request, dated October 29, 2020, proposes revisions to the DAEC Physical Security Plan to align the defensive strategy with the post-shutdown and permanently defueled condition.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 4 of 29 2.0 DETAILED DESCRIPTION The proposed amendment would modify the DAEC FL and TS to comport with the condition of all irradiated fuel in dry storage within the onsite ISFSI at DAEC using casks certified for use under a general 10 CFR Part 72 license. The amendment would also revise the DAEC 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 SFP to the ISFSI. The proposed changes to the TS also involve relocating administrative controls from Section 5, "Administrative Controls," to the DAEC QATR, and subsequently controlling them in accordance with 10 CFR 50.54(a). This relocation is being proposed pursuant to the criteria contained in 10 CFR 50.36 and in accordance with the recommendations and guidance contained in NRC Administrative Letter 95-06 (ADAMS Legacy Library No. (AL) 9512060318). The proposed changes delete the TS sections associated with TS Bases that currently remain in the post-shutdown TS. The TS Bases currently exist only for B 3.0, "LCO Applicability" and B3.7.8, "Spent Fuel Storage Pool Water Level." Since the corresponding TS Sections are proposed for deletion, their Bases sections can also be deleted. Therefore, the Bases will be deleted in their entirety upon implementation of this change. Specific changes to the FL and TS are discussed in the tables of Section 3.0 and the regulatory basis for each change is given. provides the marked-up version of the DAEC FL and TS. The following administrative changes are not shown in the marked-up FL and TS pages because they do not affect the technical content of the FL and TSs:

Reformatting (margins, font, tables, line spacing, etc.) content to create a continuous electronic file;
Renumbering of pages, where appropriate, to condense and reduce the number of pages; and
Revisions to the TS Table of Contents. provides the re-typed Renewed Facility License and TS.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 5 of 29

3.0 TECHNICAL EVALUATION

The proposed amendment would modify the DAEC FL and TS by deleting requirements that are no longer applicable to a facility with no spent nuclear fuel stored in the SFP, while modifying the remaining portions to comport with the condition of all spent nuclear fuel stored within an ISFSI. The proposed changes involve the relocation of certain administrative controls from the TS to the DAEC QATR. This amendment is proposed to be implemented within 60 days following NEDA's notification to the NRC that all spent fuel assemblies have been transferred out of the SFP and placed in dry storage within the ISFSI, therefore implementation of the approved amendment is predicated on this condition. NEDA plans to use a decommissioning method 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 to the FL and TS 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 consistent with the schedule described in the Post-Shutdown Decommissioning Activities Report (PSDAR) (ML21036A160). NEDA will submit an Irradiated Fuel Management Program via separate letter, that will include a schedule for when stored spent fuel will be shipped offsite. Updates of the Irradiated Fuel Management Program will be submitted to the NRC in accordance with 10 CFR 50.54(bb). During decommissioning, with all spent fuel in dry storage within an ISFSI, no previously installed plant systems are relied upon for the safe storage of spent fuel. In this condition there are no credible accidents whose prevention or mitigation would need to be addressed by facility TSs. The spent fuel storage casks and canisters used in the ISFSI are subject to their own Certificate of Compliance and associated TSs. Chapter 15 of the DAEC Updated Final Safety Analysis Report (UFSAR) describes the post-shutdown design basis accident as a fuel handling accident in the SFP. This postulated accident is predicated on spent fuel being stored in the SFP. With the removal of the spent fuel from the SFP, 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.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 6 of 29 10 CFR 50.2 defines safety-related structures, systems, and components (SSCs) as those that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant 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. The first two criteria 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, there are no longer any SSCs at DAEC that are required to be relied upon for accident prevention or mitigation. The only design basis accident described in the current DAEC UFSAR Chapter 15 involves a fuel handling accident (FHA) analyzed using Alternate Source Term methodology and the applicable guideline exposures specified in§ 50.67(b)(2). Since the FHA is predicated on spent fuel stored in the SFP, it is no longer applicable as a design basis accident once all spent fuel is offloaded from the SFP and transferred to dry storage within the ISFSI. Therefore, there are no SSCs at DAEC that meet the definition of a safety-related SSC as defined in § 50.2. Consequently, the proposed deletion of requirements from the TS does not involve any SSCs credited in any accident analysis at DAEC after the complete offload of the SFP and transfer of spent fuel to the ISFSI. 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 a plant's Technical Specifications. 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 4.1 of this submittal. In a permanently defueled condition with all spent fuel in dry storage within an ISFSI, the scope of equipment and parameters that need be included in the DAEC TS is limited to a description of the design features and high radiation area administrative controls. The proposed changes related to the relocation of certain administrative controls 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.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 7 of 29 The following tables identify each section that is proposed to be changed, the proposed changes and the basis for each change. Changes to the FL are listed first followed by changes to the TS. See also, Attachment 1, which provides the marked-up version of the DAEC FL and TS. FACILITY LICENSE Facility License Item 2.C(8) Current Proposed The licensee is authorized to revise the Deleted. Updated Final Safety Analysis Report by deleting the footnote for Section 9.1.4.4.5 which states "*The NRC has not endorsed the reactor building crane as single-failure proof (Reference 9)," and by deleting Reference 9 of the references for Section 9.1. Basis License Item 1.8 is proposed for deletion in its entirety. After all spent fuel is stored within the ISFSI, the reactor building crane license condition is no longer required. In 1985, NEDA modified the reactor 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. The NRC endorsed the reactor building crane as single-failure-proof in License Amendment 251. License Condition 2.C(8) was added to the DAEC license via License Amendment 251 on October 20, 2003, to reflect this NRC endorsement. After all spent fuel is removed from the spent fuel pool and stored within the ISFSI, 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 ISFSI, the reactor building crane will no longer be required and this license condition may be deleted. Facility License Item 2.C(9) Current Proposed Mitigation Strategy License Condition Deleted Develop and maintain strategies for addressing large fires and explosions and that include the following key areas: (a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 8 of 29 fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

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

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

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

1. Water spray scrubbing

2. Dose to onsite responders Basis License Item 2.C(9) is deleted in its entirety. After all spent fuel is stored within the ISFSI, the mitigation strategies are no longer required. The license condition incorporated the requirements for Section B.5.b mitigation strategies of the Interim Compensatory Measures (ICM) Order EA-02-026 dated February 25, 2002 (ML020500299). Subsequently, 10 CFR 50.54(hh) became effective on May 26, 2009.

This license condition provides mitigation strategies and other requirements for loss of large areas of the plant due to large fires and explosions. However, as stated in § 50.54(hh)(2), this section of the regulation does not apply to a permanently defueled reactor that has submitted the certifications under § 50.82(a) for permanent cessation of operations and permanent removal of fuel from the reactor vessel, which have been submitted for DAEC and docketed (ML20240A067 and ML20286A317). By letter dated November 28, 2011 (ML111220447), the NRG rescinded Item 8.5.b of the ICM Order. Therefore, neither the ICM Order nor § 50.54(hh) continue to apply to DAEC. Additionally, 10 CFR 50.155, "Mitigation of Beyond-Design-Basis Events," provides quidance on mitiqating capabilities at permanently shut down and defueled reactors.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 9 of 29 Specifically, § 50.155(a)(2)(iv) states, "Holders of operating licenses or combined licenses for which the certifications described in § 50.82(a)(1) or§ 52.11 O(a) of this chapter have been submitted need not meet the requirements of this section once all irradiated fuel has been permanently removed from the spent fuel pool(s)." DAEC will implement this FL change once all spent fuel has been moved to dry cask storage within the ISFSI, therefore, § 50.155 will no longer apply to DAEC. APPENDIX B to Facility License, ADDITIONAL CONDITIONS* Current Proposed NextEra Energy Duane Arnold, LLC is Deleted. authorized to relocate certain requirements included in Appendix A to licensee-controlled documents. Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's application dated October 30, 1996, as supplemented and consolidated in its March 31, 1998, submittal. These relocations were evaluated in the NRG staff's Safety Evaluation enclosed with this amendment. Basis This License Condition is proposed for deletion in its entirety. This License Condition was added upon implementation of Amendment 223 which transitioned the DAEC TS to the standard Technical Specification format of NUREG-1433. At that time, information the appeared in the DAEC custom TS, but was not part of the standard TS, was approved by the NRG for relocation to licensee-controlled documents. NEDA has completed the relocations allowed by Amendment 223 and this relocation allowance is no lonqer needed. Therefore, this license condition may be deleted.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 10 of 29 TECHNICAL SPECIFICATIONS Chapter 1.0 "USE AND APPLICATION" Chapter 1.0 "USE AND APPLICATION," will be deleted. Discussion of the deletions is discussed below. Deletion of Sections 1.1, 1.3 and 1.4 result in deletion of Chapter 1.0 in its entirety. TS SECTION 1.1, DEFINITIONS TS 1.1, "Definitions," provides an explanatory NOTE and defined terms that are applicable throughout the TS and TS Bases. These terms no longer apply to the ISFSI Only TS (IOTS). With the elimination of all remaining definitions, the explanatory NOTE is no longer required. Therefore, TS 1.1 will be deleted. ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times. CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with provisions of the Certified Fuel Handler training program required by Technical Specification Section 5.3.2. NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is an individual who complies with the provisions of Technical Specifications Section 5.3.1. Basis The purpose of the definitions is to provide uniform interpretation of frequently used terms in the TS. The proposed changes to other TS sections either eliminate or relocate the information that references these terms. Since the terms are no longer needed after the spent fuel has been removed from the SFP and transferred to the ISFSI, it is acceptable to delete this section in its entirety with no impact on continued safe storage and maintenance to spent fuel in the ISFSI. TS Section 1.3 COMPLETION TIMES TS 1.3 establishes the Completion Time convention and provides guidance for its use. This section is proposed for deletion. Basis The proposed changes to other TS sections eliminate the use of COMPLETION TIMES for required ACTIONS. Since COMPLETION TIMES for required ACTIONS are no longer needed after the spent fuel has been removed from the SFP and transferred to the ISFSI, it is acceptable to delete this section in its entirety with no impact on continued safe storaQe and maintenance to spent fuel in the ISFSI.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 11 of 29 TS Section 1.4 FREQUENCY TS 1.4 defines the proper use and application of Frequency requirements. This section is proposed for deletion. Basis The proposed changes to other TS sections eliminate the use of FREQUENCY for Surveillance Requirements. Since FREQUENCY for Surveillance Requirements are no longer needed after the spent fuel has been removed from the SFP and transferred to the ISFSI, it is acceptable to delete this section in its entirety with no impact on continued safe storage and maintenance to spent fuel in the ISFSI. Chapter 3.0 Chapter 3.0 establishes general requirements applicable to all Specifications. Amendment 311 eliminated all of Chapter 3 with the exceptions of Sections 3.0 and 3.7.8. The proposed changes delete these remaining sections as discussed below. Consequently, Chapter 3.0 will be deleted in its entirety. TS Section 3.0 "LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY" TS Section 3.0 "LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY" provides guidance and requirements for use of TS LCOs. This section is proposed for deletion. Basis The proposed changes to other TS sections eliminate all LIMITING CONDITIONS FOR OPERATION (LCOs). Since LCOs are no longer needed after the spent fuel has been removed from the SFP and transferred to the ISFSI, it is acceptable to delete this section in its entirety with no impact on continued safe storage and maintenance to spent fuel in the ISFSI. TS Section 3.0 "SURVEILLANCE REQUIREMENT (SR) APPLICABILITY" TS Section 3.0 "SURVEILLANCE REQUIREMENT (SR) APPLICABILITY" provides guidance and requirements for use of TS LCOs. This section is proposed for deletion. Basis The proposed changes to other TS sections eliminate all SURVEILLANCE REQUIREMENTS (SRs). Since SRs are no longer needed after the spent fuel has been removed from the SFP and transferred to the ISFSI, it is acceptable to delete this section in its entirety with no impact on continued safe storage and maintenance to spent fuel in the ISFSI. TS Section 3. 7 .8 "Spent Fuel Storaqe Pool Water Level" TS Section 3.7.8 requires the spent fuel storage pool water level to be;:: 36 feet during movement of irradiated fuel assemblies in the spent fuel storage pool. The associated LCO requires suspension of movement of irradiated fuel assemblies in the spent fuel storage pool if level is not ;:: 36 feet. The associated Surveillance Requirement verifies

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 12 of 29 the spent fuel storage pool water level is ~ 36 feet in accordance with the Frequency Control Program of Technical Requirements Manual (TRM) Section 4.0. TS 3.7.8 will be deleted is in its entirety. Basis The requirements in this section are related to assuring the ability to safely store spent fuel in the SFP. TS Section 3.7.8 does not apply when there is no spent fuel stored in the SFP. Without any nuclear fuel in the SFP, SFP water level has no impact on the continued safe storage and maintenance of spent fuel in the ISFSI. Chapter 4.0, "DESIGN FEATURES" Changes to Chapter 4.0, "DESIGN FEATURES" are presented below. Section 4.3, "Fuel Storage" Section 4.3 provides design and maintenance requirements for fuel storage in the DAEC SFP. Specifically, criticality limits, drainage requirements and SFP capacity limits are specified in this Section. These requirements for spent fuel storage will be deleted. This section will be revised to state: "Spent fuel shall not be stored in the spent fuel pool." The requirements for spent fuel storage listed in Section 4.3 will be deleted. Basis Section 4.3 describes design features associated with fuel storage in the SFP. After all spent fuel is removed from the SFP, the existing requirements of Section 4.3 are no longer applicable and may be deleted. A new design feature for the SFP is proposed to state that spent fuel shall not be stored in the SFP, which reflects the condition upon which this proposed amendment is predicated. Chapter 5.0, "ADMINISTRATIVE CONTROLS" Changes to Chapter 5.0, "ADMINISTRATIVE CONTROLS" are presented below. Section 5.1, "Responsibility" will be deleted. Section 5.1.1 states the following:

"The plant manager shall be responsible for overall facility operation and shall designate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect safe storage and maintenance of spent nuclear fuel."

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 13 of 29 The requirements of Section 5.1.1 will be relocated to the QATR. Basis TS Section 5.1.1 provides a description and requirements regarding certain key operational management responsibilities. The proposed change is to delete these sections from the TS and relocate them to the DAEC QATR administrative controls verbatim with the exception that references to the "plant manager" position will be revised to "manager responsible for overall operational activities" in order to conform to the description of the corresponding management position in Section A, "Management," of the existing DAEC QATR. This does not change any requirements, qualifications, or responsibilities of the individual in this position, and is strictly an administrative change. NRG Administrative Letter 95-06 (AL9512060318) provides a discussion concerning the relocation of Technical Specification administrative controls to a quality assurance (QA) program. The NRG considers relocating these requirements to the quality assurance program acceptable because of the controls imposed by Appendix B to 10 CFR Part 50, the existence of an NRG approved quality assurance program, and the quality assurance program change control process in§ 50.54(a). After these administrative controls are incorporated into the DAEC QATR, any future changes are controlled in accordance with § 50.54(a). This will provide adequate control for the facility with all spent fuel located within the ISFSI. Therefore, the proposed relocation is acceptable. Section 5.1.2 states the following:

"The Operations Shift Manager shall be responsible for the shift command function."

This statement will be deleted. Basis Existing TS 5.1.2 requires the shift supervisor to be responsible for the shift command function. This requirement is proposed to be eliminated. As described in the existing TS Sections 5.1.2 and 5.2.2, the shift command function is focused on operations involving the storage or movement of spent nuclear fuel within the SFP. After all of the spent fuel is permanently removed from the SFP, the need for the shift supervisor and shift command function for spent fuel management no longer exists. The position of shift supervisor 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 dry fuel storage system utilized within the ISFSI or with respect to the decommissioning of the former power generation facility, the shift supervisor position and shift command function are no longer required, and the proposed deletion of TS 5.1.2 is acceptable.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 14 of 29 Section 5.2, "Organization" will be deleted. Section 5.2.1, "Onsite and Offsite Organization," states the following: "Onsite and offsite organizations shall be established for facility staff 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 facility organization positions. These relationships shall be documented and updated, as appropriate, in organizational descriptions. These organizational descriptions shall be documented in the UFSAR or QA Program Description;

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

c. The corporate officer shall have responsibility for the overall facility safety and shall take measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of spent nuclear fuel.

d. The individuals who train the CERTIFIED FUEL HANDLERS and those who carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions."

The requirements for onsite and offsite organizations will be relocated to the DAEC QATR. Basis The administrative controls describe organizational lines of authority, responsibilities, and requirements for organizational freedom for certain personnel including those performing health physics or quality assurance functions are provided sufficient organizational freedom. The proposed change is to delete TS 5.2.1 from the TS and relocate them to the DAEC QATR administrative controls, without altering these basic administrative controls. Providing onsite and offsite organization descriptions in the QATR is consistent with NRG Administrative Letter 95-06 (AL9512060318), which provides a discussion concerning the relocation of Technical Specification administrative controls to a quality assurance (QA) program. The NRG considers relocating these requirements to

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 15 of 29 the quality assurance program acceptable because of the controls imposed by Appendix B to 10 CFR Part 50, the existence of an NRC approved quality assurance program, and the quality assurance program change control process in§ 50.54(a). After these administrative controls are incorporated into the DAEC QATR, any future changes are controlled in accordance with § 50.54(a). This will provide adequate control for the facility with all spent fuel located within the ISFSI. Therefore, the proposed relocation is acceptable. The administrative controls provided in the existing TS 5.2.1 will be incorporated in the DAEC QATR verbatim, with the following exceptions:

Section 5.2.1 reference to "plant manager" will be revised to "manager responsible for overall operational activities" in order to conform to the description of the corresponding management position in Section A, "Management," of the existing DAEC QATR. This does not change any requirements, qualifications, or responsibilities of the individual in this position, and is strictly an administrative change.
Section 5.2.1 reference to individuals who "train the Certified Fuel Handlers" will not be incorporated into the DAEC QATR. After all fuel is stored within the ISFSI and storage of spent fuel in the SFP is prohibited, there will no longer be an organizational need for Certified Fuel Handlers or associated training program, therefore this change will have no impact on continued safe storage and maintenance of spent fuel stored in the ISFSI, and is acceptable.

Section 5.2.2, "Facility Staff" requires the facility organization meet the following:

"a. Each on-duty shift shall include at least the following shift staffing:

One (1) Operation Shift Manager (see f below); and
Two (2) NON-CERTIFIED OPERATORS (see g below)

b. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements. During such absences, no fuel movement or movement of loads over the spent fuel shall be permitted. This provision does not permit any shift crew position to be unmanned upon shift change due to an incoming shift crew member being late or absent.

c. At times when nuclear fuel is stored in the spent fuel pool, at least one (1) person qualified to stand watch in the Control Room (NON-CERTIFIED

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 16 of 29 OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the Control Room.

d. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

e. A person qualified to implement radiation protection procedures shall be on site during movement of fuel and during movement of loads over the fuel.

f. The Operations Shift Manager shall be a CERTIFIED FUEL HANDLER.

g. The position of NON-CERTIFIED OPERATOR may be filled by a CERTIFIED FUEL HANDLER."

The requirements for Facility Staff will be deleted. Basis TS 5.2.2 is proposed to be deleted in its entirety, and to not be relocated to the DAEC QATR. These administrative controls pertain to the facility staff organizations and requirements when spent fuel is stored or moved within the SFP. Once all spent fuel is located within the ISFSI and spent fuel storage in the SFP is prohibited, it is not necessary for QATR administrative controls to include these requirements. Therefore, the deletion of Section 5.2.2 after the fuel has been moved from the SFP to the ISFSI will have no impact on the safe storage and maintenance of spent fuel in the ISFSI and is acceptable. Section 5.3, "Facility Staff Qualifications" will be deleted. Section 5.3.1 states the following:

"Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions in ANSI/ANS 3.1-1978. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975."

The requirements of Section 5.3.1 will be relocated to the QATR. Basis Section 5.3.1 will be relocated, verbatim to the QATR administrative controls. NRG Administrative Letter 95-06 (AL9512060318) provides a discussion concerning the relocation of Technical Specification administrative controls to a quality assurance (QA) program. The NRG considers relocating these requirements to the quality assurance program acceptable because of the controls imposed by Appendix B to 10 CFR Part 50, the existence of an NRG approved quality assurance program, and the quality assurance program change control process in~ 50.54(a).

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 17 of 29 After these administrative controls are incorporated into the DAEC QATR, any future changes are controlled in accordance with§ 50.54(a). This will provide adequate control for the facility with all spent fuel located within the ISFSI. Providing the requirements for facility staff qualifications in the QATR is consistent with Administrative Letter 95-06 and will have no impact on safe storage and maintenance of spent fuel in the ISFSI, therefore the proposed relocation is acceptable. Section 5.3.2 states the following:

"The CERTIFIED FUEL HANDLER shall be qualified to the NRG-approved training and retraining program for CERTIFIED FUEL HANDLERS. The NRG-approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained."

The requirements of Section 5.3.2 will be deleted. Basis Section 5.3.2 specifies that Certified Fuel Handler training programs shall be maintained. As described in the existing TS Sections 5.1.2 and 5.2.2, the shift command function is focused on operations involving the storage or movement of spent nuclear fuel within the SFP. Following the transfer of all spent fuel to the ISFSI, storage of spent fuel in the SFP will be prohibited upon implementation of this amendment, thus there will no longer be a need for Certified Fuel Handlers or the associated training programs. Therefore, this proposed deletion will have no impact on safe storage and maintenance of spent fuel in the ISFSI and is acceptable. Section 5.4, "Procedures" will be deleted. Section 5.4.1 states the following:

"Written procedures shall be established, implemented, and maintained covering the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978;

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and to NUREG-0737, Supplement 1, as stated in Generic Letter 82-33;

c. Quality assurance for effluent and environmental monitoring;

d. [Deleted]; and

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 18 of 29

e. All programs specified in Specifications 5.5."

The requirements of Section 5.4.1 will be relocated to the QATR Basis TS 5.4 requires written procedures to be established, implemented, and maintained for certain activities. The proposed change is to delete TS 5.4 in its entirety, and to relocate the requirements to the DAEC QATR administrative controls with the exception of TS 5.4.1 (d) which is deleted. As discussed above, following the transfer of the spent fuel to the ISFSI, the proposed change to TS 4.3 will prohibit the storage of spent fuel in the SFP. After these administrative controls are incorporated into the DAEC QATR, any future changes are controlled in accordance with§ 50.54(a). This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for procedures to the QATR is consistent with NRC Administrative Letter 95-06 (AL9512060318) and will have no impact on safe storage and maintenance of spent fuel in the ISFSI, and therefore is acceptable. Section 5.5, "Programs and Manuals" will be deleted Section 5.5 describes the programs that shall be established, implemented and maintained. The deletion or relocation of each program is discussed below. Section 5.5.1 Offsite Dose Assessment Manual will be relocated to the QATR Section 5.5.4 Radioactive Effluent Controls Program will be relocated to the QATR. Basis The requirement to establish, implement and maintain an Offsite Dose Assessment Manual (ODAM) is described in Section 5.5.1. This change proposes deleting Section 5.5.1 and relocating these requirements to the DAEC QATR. The requirements will be relocated to the DAEC QATR verbatim with the exception of the references to TS 5.6.2 and 5.6.3, which will be deleted. Deletion of the TS references is an administrative change since these will no longer reside in the TS once relocated to the DAEC QATR, and the references are not necessary to describe the ODAM requirements. TS Section 5.5.4 specifies Radioactive Effluent Controls Program requirements for the program to control radioactive effluents, and for maintaining doses to the public to within the specified limits. The proposed change is to delete 5.5.4 from the TS and relocate the requirements to the DAEC QATR with the following exceptions:

References to iodine-131 and iodine-133 in 5.5.4.g.2 and 5.5.4.i will not be relocated to the QAPM due to the radioactive decay and short half-lives (approximately 8 days and 20.83 hours, respectively) and time since

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 19 of 29 permanent cessation of reactor operation. This is consistent with changes to the DAEC QATR implemented under 10 CFR 50.59.

5.5.4.g.1 and 5.5.4.h will not be relocated to the DAEC QATR since after all spent fuel is transferred to the ISFSI and contained within dry storage casks, there will no longer be a requirement to monitor for noble gases released from the facility. This is consistent with changes to the DAEC QATR implemented under 10 CFR 50.59.

After these ODAM and Radioactive Effluent Controls Program requirements are incorporated into the DAEC QATR, any future changes are controlled in accordance with § 50.54(a). This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of ODAM and Radioactive Effluent Controls Program requirements to the QATR is consistent with NRC Administrative Letter 95-06 (AL9512060316) and will have no impact on safe storage and maintenance of spent fuel in the ISFSI, and therefore is acceptable. Section 5.5.8 Storage Tank Radioactivity Monitoring Program will be relocated to the Technical Requirements Manual. Basis Section 5.5.8, "Storage Tank Radioactivity Monitoring Program", currently provides controls for the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. NEDA 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 and SR 3.0.3 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 and SR 3.0.3 are 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. Section 5.5.10 Technical Specifications (TS) Bases Control Program will be deleted. Section 5.5.14 Surveillance Frequency Control Program will be deleted. Section 5.5.15 Spent Fuel Pool Neutron Absorber MonitorinQ ProQram will be deleted. Basis TS 5.5.10 describes the TS Bases Control Program and is proposed to be deleted in its entirety from the TS. As described in this table and shown in Attachment 1 to this letter, all of the Bases in the existing TS are being eliminated with the proposed chanQes to the correspondinQ sections. Since all the Bases will be deleted, there will

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 20 of 29 no longer be a need for a TS Bases control program. Therefore, the proposed deletion of TS 5.5.10 is acceptable. TS 5.5.14 describes the Surveillance Frequency Control Program (SFCP) which ensures that Surveillance Requirements specified in the TS are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. The program allows changes to Surveillance frequencies to be made in accordance with NEI 04-10, "Risk Informed Method for Control of Surveillance Frequencies," Revision

1. As described earlier, once all spent fuel has been removed from the SFP and stored within the ISFSI, the DAEC Technical Specifications will not contain any LCOs or SRs. Therefore, the ability to change surveillance frequencies in accordance with the SFCP is no longer needed. Therefore, the proposed deletion of TS 5.5.14 is acceptable.

TS 5.5.15 describes the routine monitoring and actions required to ensure that the condition of Baral in the spent fuel pool racks maintains the attenuation capability described in the criticality safety analysis. The purpose is to maintain any spent fuel in the spent fuel pool racks remains subcritical. Once all the spent fuel has been removed from the SFP and stored within the ISFSI, the potential for criticality in the SFP is eliminated. Therefore, the proposed deletion of TS 5.5.15 is acceptable. Section 5.6, "Reportinq Requirements" will be deleted Section 5.6 describes the reports that shall be submitted in accordance with 10 CFR 50.4. The relocation of each reporting requirement is discussed below. Section 5.6.2 Annual Radiological Environmental Operating Report will be relocated to the QATR. Section 5.6.3 Radioactive Material Release Report will be relocated to the QATR. Basis Section 5.6.2 describes requirements for reporting in accordance with the DAEC ODAM and 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C. Section 5.6.3 describes requirements for reporting in accordance with the DAEC ODAM and 10 CFR 50, Appendix I, Section IV.B.1. The proposed change is to delete both Section 5.6.2 and 5.6.3 from the TS and relocate these requirements verbatim to the DAEC QATR. After these reporting requirements are incorporated into the DAEC QATR, any future changes are controlled in accordance with § 50.54(a). This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for reporting requirements to the DAEC QATR is consistent with NRC Administrative Letter 95-06 (AL9512060318) and will have no impact on safe storage and maintenance of the spent fuel in the ISFSI, and therefore, is acceptable.

Duane Arnold Energy Center Docket No. 50-331 License, Amendment Request Enclosure to NG-20-0094 Page 21 of 29

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 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 10 CFR, 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§ 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. 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

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 22 of 29 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 Federal Regulations (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 the certifications of§ 50.82(a)(1) have been docketed for DAEC, under

         § 50.82(a)(2) the DAEC 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, therefore 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 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, design features, or operating restrictions that involve an initial condition assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. Since DAEC is no longer licensed to operate, and the existing design basis accident is a fuel handling accident predicated on the storage of spent fuel in the SFP, with all spent fuel stored in the ISFSI, there are no remaining design basis accidents which are credible, and therefore 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 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 (including consideration of the single failure criterion), so that the plant response to

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 23 of 29 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 SFP at the DAEC 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 DAEC 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 Topical Report, 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 including § 50.59 and Appendix B to 10 CFR Part 50 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. Administrative Letter (AL) 95-06 The Quality Assurance Topical Report is an appropriate candidate for relocations of administrative controls due to the controls imposed by such

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 24 of 29 regulations as Appendix B to 10 CFR Part 50, the existing NRG-approved QA plans and commitments to industry QA standards, and the established QA program change control process of 10 CFR 50.54(a). NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance" (AL9512060318), provides guidance to licensees requesting amendments that relocate administrative controls to NRG-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 relocation actions 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). This proposed amendment deletes the portions of the existing DAEC TS that are no longer applicable to a permanently defueled facility with all irradiated fuel in dry storage within an ISFSI, while modifying the remaining portions to correspond to the SAFSTOR decommissioning condition. 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 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

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 25 of 29 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." The proposed changes are consistent with the above regulatory guidance and regulation. 4.2 Precedent The proposed amendment is consisted with recently approved Amendments issued for Kewaunee Power Station (DPR-43), for which an amendment was issued on June 7, 2017(ML17123A028 and 029), Vermont Yankee Nuclear Power Station (DPR-28), for which an amendment was issued on August 15, 2018(ML18156A180 and 181) and Fort Calhoun Station (DPR-40), for which an amendment was issued on December 9, 2019(ML19297D674). 4.3 No Significant Hazards Consideration NextEra Energy Duane Arnold, LLC (NEDA}, pursuant to 50.90, requests an amendment to the Duane Arnold Energy Center (DAEC) Facility License (FL) and Technical Specifications (TS}. The proposed changes will revise the DAEC TS Chapter 1.0, "USE AND APPLICATION," Chapter 3.0, "APPLICABILITY," Chapter 4.0, "DESIGN FEATURES" and Chapter 5.0, "ADMINISTRATIVE CONTROLS." The proposed changes will revise the FL and TS to reflect removal of all spent nuclear fuel from the Spent Fuel Pool (SFP) and its transfer to dry cask storage within the DAEC Independent Spent Fuel Storage Installation (ISFSI). The proposed changes include the relocation of administrative controls from the DAEC TS to the DAEC Quality Assurance Topical Report (QATR). By letter dated August 27, 2020 (Accession No. ML20240A067), NEDA certified permanent cessation of power operations at the DAEC. By letter dated October 12, 2020 (ML20286A317), NEDA certified permanent defueling of the reactor at DAEC. Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for DAEC no longer authorizes operations of the reactor or emplacement or retention of fuel into the reactor vessel. The transfer of all spent fuel to the ISFSI is expected to be completed in 2022. The TS requirements being changed would be applicable once it has been certified that all fuel has been permanently removed from the DAEC SFP and is stored in dry storage casks within the ISFSI.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 26 of 29 permanently removed from the DAEC SFP and is stored in dry storage casks within the ISFSI. NEDA has evaluated the proposed change against the criteria of 10 CFR 50.92(c) and concludes that the proposed changes do not involve any significant hazards, since the proposed changes satisfy the criteria of 10 CFR 50.92(c). The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

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

Response: No The proposed amendment would modify the DAEC Facility License (FL) and Technical Specifications (TS) by deleting the portions of the FL and TS that are no longer applicable to a facility with no spent nuclear fuel stored in the SFP, while modifying the remaining portions to correspond to all nuclear fuel stored within an ISFSI. This amendment will be implemented within 60 days following NEDA's notification to the NRC that all spent fuel assemblies have been transferred out of the SFP and placed in dry storage within the 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 function al 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 50.34(a)(1) or 100.11. The first two criteria 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 DAEC are required to be relied on for accident mitigation. Therefore, none of the SSCs at DAEC meet the definition of a safety-related SSC stated in 10 CFR 50.2. The proposed deletion of

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 27 of 29 requirements in the TS does not affect systems credited in any accident analysis at DAEC. Chapter 15 of the DAEC Updated Final Safety Analysis Report describes the design basis accident, a fuel handling accident (FHA), related to the SFP. This postulated accident is predicated on spent fuel being stored in the SFP. With the removal of the spent fuel from the SFP, 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. Therefore, the proposed changes do not involve an increase in the probability or consequences of a previously evaluated accident.

2. Does the proposed change 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 SFP and relocate certain administrative controls to the Quality Assurance Technical Requirements (QATR) or other licensee-controlled process. After the removal of the spent fuel from the SFP and transfer to the ISFSI, there are no spent fuel assemblies that remain in the SFP. Coupled with a prohibition against storage of fuel in the SFP, 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.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 28 of 29

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

Response: No The removal of all spent nuclear fuel from the SFP into storage in casks within an ISFSI, coupled with a prohibition against future storage of fuel within the SFP, removes the potential for fuel related accidents. The design basis and accident assumptions within the DAEC UFSAR and the TS relating to safe management and safety of spent fuel in the SFP 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 removed from the DAEC 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, NEDA concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, and, accordingly, a finding of "no significant hazards consideration" is justified. 4.4 Conclusions 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.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-20-0094 Page 29 of 29

5.0 ENVIRONMENTAL CONSIDERATION

S The proposed amendment involves revising the DAEC TS by adding definitions described in Section 1.1 and deleting and/or modifying certain portions of the administrative controls described in Section 5.0 in support of proposed decommissioning efforts to reflect the permanently shut down and defueled condition at DAEC. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) because it does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. In addition, the proposed changes involve changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment. LIST OF ATTACHMENTS Proposed Facility License and Technical Specification Changes (Mark-Up) Revised Facility License and Technical Specification Pages (Clean, with Proposed Changes)

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request NG-20-0094 Enclosure, Attachment 1 Page 1 of 48 ATTACHMENT 1 PROPOSED FACILITY LICENSE AND TECHNICAL SPECIFICATION CHANGES (MARK-UP)

NEXTERA ENERGY DUANE ARNOLD. LLC CENTRAL IOWA POWER COOPERATIVE CORN BELT POWER COOPERATIVE DOCKET 50-331 DUANE ARNOLD ENERGY CENTER RENEWED FACILITY LICENSE Renewed License No. DPR-49

1. The Nuclear Regulatory Commission (the Commission) having found that:

A. The application for license filed by FPL Energy Duane Arnold, LLc,* Central Iowa Power Cooperative and Corn Belt Power Cooperative (the licensees) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I and all required notifications to other agencies or bodies have been duly made; B. Deleted; C. The facility will be maintained in conformity with the application, as amended; the provisions of the Act; and the rules and regulations of the Commission; D. There is reasonable assurance: (i) that the activities authorized by this renewed 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 rules and regulations of the Commission; E. NextEra Energy Duane Arnold, LLC is technically qualified and NextEra Energy Duane Arnold, LLC, Central Iowa Power Cooperative and Corn Belt Power Cooperative are financially qualified to engage in the activities authorized by this renewed license in accordance with the rules and regulations of the Commission; F. The licensees have satisfied the applicable provisions of 10CFR Part 140, "Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this renewed license will not be inimical to the common defense and security or to the health and safety of the public; H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental costs and considering available alternatives, the issuance of renewed Facility License No. DPR-49 is in accordance with 10 CFR Part 50, Appendix D, of the Commission's regulations and all applicable requirements of said Appendix D have been satisfied;

on April 16, 2009, the name "FPL Energy Duane Arnold, LLC" was changed to "NextEra Energy Duane Arnold, LLC."

Renewed License No. DPR-49 Amendment 311

I. Deleted.

2. Renewed Facility License No. DPR-49 is hereby issued to NextEra Energy Duane Arnold, LLC, Central Iowa Power Cooperative (CIPCO) and Corn Belt Power Cooperative (Corn Belt) to read as follows:

A. This renewed license applies to the Duane Arnold Energy Center, a permanently defueled boiling water reactor and associated equipment (the facility), owned by NextEra Energy Duane Arnold, LLC, Central Iowa Power Cooperative and Corn Belt Power Cooperative and operated by NextEra Energy Duane Arnold, LLC. The facility is located on NextEra Energy Duane Arnold, LLC's, Central Iowa Power Cooperative's and Corn Belt Power Cooperative's site near Palo in Linn County, Iowa. This site consists of approximately 500 acres adjacent to the Cedar River and is described in the "Final Safety Analysis Report" as supplemented and amended (Amendments 1 through 14) and the Environmental Report as supplemented and amended (Supplements 1 through 5). B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses: (1) NextEra Energy Duane Arnold, LLC, pursuant to Section104b of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," to possess and use the facility as required for nuclear fuel storage; and CIPCO and Corn Belt to possess the facility at the designated location in Linn County, Iowa, in accordance with the procedures and limitations set forth in this license; (2) NextEra Energy Duane Arnold, LLC, pursuant to the Act and 10 CFR Part 70, to possess at any time special nuclear material that was used as reactor fuel, in accordance with the limitations for storage, as described in the Updated Final Safety Analysis Report, as supplemented and amended as of June 1992 and as supplemented by letters dated March 26, 1993, and November 17, 2000. (3) NextEra Energy Duane Arnold, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source or sealed sources for radiation monitoring equipment calibration, and to possess any byproduct, source and special nuclear material as sealed neutron sources previously used for reactor startup or reactor instrumentation; and fission detectors; (4) NextEra Energy Duane Arnold, LLC, 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 radioactive apparatus components; (5) NextEra Energy Duane Arnold, LLC, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear materials that were produced by the operation of the facility. Renewed License No. DPR-49 Amendment 311

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I; Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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) Deleted (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.~. are hereby incorporated in the license. NextEra Energy Duane Arnold, LLC shall maintain the facility in accordance with the Permanently Defueled Technical Specifications. (3) Deleted (4) Deleted. (5) Physical Protection NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, Renewed License No. DPR-49 Amendment~

and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73. 55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans , which contains Safeguards Information protected under 10 CFR 73.21 , is entitled: "Duane Arnold Energy Center Physical Security Plan," submitted by letter dated May 16, 2006.

NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved Duane Arnold Energy Center/NextEra Energy Duane Arnold , LLC Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Duane Arnold Energy Center/NextEra Energy Duane Arnold , LLC CSP was approved by License Amendment No. 278, as supplemented by changes approved by license
Amendment No . 284 and Amendment 291 .

(6) Deleted (7) Additional Conditions Deleted Develop and R'laintain strate§ies foraddFOssin§ laF§e fires and explosions and that inol1:1de the followin§ 1<<3y aFOas : (a) P"iFO fi§ htin§ FOsponse strate§y with the followin§ elefflents:

1. PFC defined ooordinated fire FOsponse strate§y and §l:lidanoe

2. /\ssessfflent of R'11:Jt1:1al aid fire fi§htin§ assets

d. Desi§nated sta§in§ aFOas for eq1:1 ipR'lent and R'laterials

4. Go R'lffland and oontrol

5. Trainin§ of response personnel (b) Operations to R'liti§ate f1:1el daffla§e oonsiderin§ the followin§ :

1. Proteotion and 1:1se of personnel assets

2. GoR'lR'll:lnioations

d. Minifflizin§ fiFO spread

4. Prosed 1:1res for iR'lpleR'lentin§ inte§rated fiFO FOsponse strate§y

5. ldentifioation of readily avail able pFO sta§ed eq1:1ipR'lent

         @. Trainin§ on inte§rated fiFO FOsponse strate§y

7. Spent f1:1el pool R'liti§ation R'leas1:1res (o) /\otions to R'linifflize FOlease to inol1:1de oonsideration of:

1. Water spray sor1:1bbin§

2. Dose to onsite responders (10) The licensee shall implement and maintain all Actions required by Attachment2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan , as appropriate.

Renewed License No . DPR-49 Amendment ~

(11) Deleted. (12) Deleted. (13) Deleted. D. This license is effective as of the date of issuance and is effective until the Commission notifies the licensee in writing thatthe license is terminated. FOR THE NUCLEAR REGULATORY COMMISSION Original signed by Eric J. Leeds Eric J. Leeds, Director Office of Nuclear Reactor Regulation

Enclosures:

1. AppendixATechnical Specifications

2. Appendix BAdditional Conditions Date of Issuance: December 16, 2010 Renewed License No. DPR-49 Amendment 312

APPENDIX B ADDITIONAL CONDITIONS LICENSE NO. DPR-49 NextEra Energy Duane Arnold, LLC (the term licensee in Appendix B refers to NextEra Energy Duane Arnold , LLC or prior license holders) shall comply with the following conditions on the schedule noted below: Amendment Number Additional Conditions Implementation Date 223 NextEra Energy Duane Arnold , LLC is This amendment is 275 .-ID_E_L_E_T_E_D_____, .____ _ _ _ _ ___, J authoriz:ed to relooate oertain requirements inoluded in Appendix

                             /\to lioensee oontrolled doouments.

Implementation of this amendment shall inolude the relooation of these effeotive immediately and shall be implemented within 180 days of the date of this amendment. requirements to the appropriate doouments, as desoribed in the lioensee's applioation dated Ootober 30 , 1 QQ6 , as supplemented and oonsolidated in its Maroh 31 , 1 QQ8 , submittal. These relooations were evaluated in the NRG staff's Safety Evaluation enolosed with this amendment. 260 (1) NextEra Energy Duane Arnold shall take all This amendment is 275 necessary steps to ensure that the external trust effective immediately fund is established at the time of the closing of and shall be implemented the transfer of the license from Interstate Power within 30 days of the date (IPL) to FPLE Duane Arnold is maintained in of this amendment. accordance with the requirements of the December 23, 2005 order approving the license transfer, NRC regulations, and consistentwith the safety evaluation supporting the order. The trust agreement shall be in a form acceptable to the NRC. 260 (2) DELETED 279 260 (3) DELETED Amendment ~

                       .       tDeleted                                          Definitions 44 1.0 USE /\ND APPLICATION 1.1 Definitions The defined terms of this seotion appear in oapitalized type and are applioable throughout these Teohn ioal Speoifioations and Bases.
 +efm                              Definition
  /\CTIONS                         ACT I O~JS   shall be that part of a Speoifioation that presoribes Requ ired /\otions to be taken under designated Conditions w ith in speo ified Completion Times.

CERTIFIED FUEL 19/\~J DLER A CERTIFIED FUEL 19/\NDLER is an individual who oomplies w ith prov isions of the Certified Fuel 19andler train ing program required by Teohn ioal Speo ifioation Seotion 5.d.2. NON CERTIFIED OPERATOR /\ NO~J CERTIFIED OPERATOR is an individual who somplies with the provisions of Teshn isal Speoifisations Seotion 5.d.1. DAEC 1.1-1 Amendment 644 -f

1.0 USE AND APPLIGAT I O~J 1.2 DELETED DAEG Amendment 311

1 *:g:;c:o:f i~pl~et~io~n= Ti:f i~e~s~ ~: : : : : : : =:=~~~~~~~~~~~1.d M - n PPblGA+IQN co ... pl0ti0A Ti ... es TAe purpose of ti.... section . ise I~ to establisA tAe

            -:::-~----~~==*:~g:u:1s~alflnee PURPOSE                        eon11enfHIS

ion ans to pro" for its Goffi pletion Tiffie BAGKGROLJNg use.

                    ....      Li  ffiHng "t"     Gond*t*
                                                                        "'a1AIB1AIA~                ~: 1-Y 6

fae111t~ re EtLIIFCffients aos .* t:111ons for saffo 0 * .. ' LGO elyrperation o s) spe "f . . IA~ 0eiateS wi!A IA "'1"i"'u tAe ... a . an LGO stat e Y* "... e AGTIQNS Ti ffi

                                                                  !.:'e~u1~"'eAls t=el~~irpisally_SeseriBe S ". ys IA wAieA                                 e G0ASili0A

~--==-~e-1_o_n_T_1f--i e~s(=s=)---o-n-s1-t1-on-~a~re~~R e~u1reS c:::i1e!S wilA eaeA al

                                                                   .                                           AslioAisl aA! .
                                                                                                         . ean fail to be ffi t 9ESGRIPTIG~'                  TAC Goffipletion Tiffi .

O?ffipleting a Re . e IS tAC affiount 0 . s1seoverv of a .tEtu1res Aetion It *i f t1ffie allov.:es for wilA" * '. uali0A _ ~ e. ~ : s relereAs es to IAe u... e al e~u1p,.,eAI G0A~.;.aF1aBle ol" IA 1_1... 115) IAat re" 51 .* IAOperaBle

                                  .. 0rw1s0 sp . . , uires eA!eriA                                              o , .

states iA IA;e.s1l1eS, proviSiAB tA! f "". AG_TIQNS I~" Roi

                             ~o,..plelioAP;:.!"                 1:e ellpirati0A e ReEtuires /\ t: n n ACTIONS G sf~heRe~uif0S so,..pleleS '.'ppllsaBilily of IAe bG a011ily is iA a spesif
                                                                                             . ~peo1f1es   Astio~~     ~oA!SilioA UAl0ss us be

{ IA e f ~eilily ' is ROI ** wil;i;~:

                                                             -10As   a    I ey LGG      !Ae  c8A~i1;;:"'*iAS 0AS1l10A UAlil Applioability    . no longer iA effesl mcists BASor IMME9l 11 TE                  V'/Aen 11 _ "lffiffi es*1ately"

G n ,"'"""er.

                                 ,et1on SAouls be pursues          is uses      as uaI G w1tA0      Sclay    ans o"'plel10A. inTi"'e , IA e ReEtwres OMPLETIO~'                                                                                             a oontrolles .
+JM..E

1.0 USE A~JD APPLICATION 1.4 Freq1:10Rey PURPOSE The _p1:1r_ pose of this seetioR is to defiRe the proper 1:1se aRd appheat10R of Freq1:10Rey req1:1ireffl0Rts. DESCRIPTION ~aeh _s1:1rveillaRee _ Req1:1ireffl0Rt (SR) has a speeified i;req1:10Rey IA 'v'lh1eh the S1:1rve1llaRee ffll:lst be fflet iR order to ffleet the assoeiat~~ LCO . AR l:lRderstaRdiRg of the eorreet applieatioR of the spee1f1ed i;req1:10Roy is Reoessary for eofflpliaRee with the SR The "speeified Freq1:10Rey" ooRsists of the req1:1ireffl0Rts of the -l-Freq1:10Rey eoll:lfflR of eaeh SR, as well as eertaiR ~Jatos iR the S1:1rveillaRGO ooll:lfflR that fflOdify perforfflaRGO req1:1irOfflORts. The ~~e of "ffl_et" or "perforffled" iR these iRstaRoes ooRveys speo1f10 fflearnRgs. A S1:1rveillaRee is "fflet" ORiy wheR the aoeeptaRoe eriteria are satisfied. KROWR fail1:1re of the req1:1irOfflORts of a Sl:lF\'OillaROO, OVOR witho1:1t a S1:1rveillaROO Speoifioally beiRg "perforff!Od ," GORStitl:ltOS a Sl:lF\'OillaRGO ROt "P erf orffla.~ee " refers ORiy to the req1:1ireffl0Rt to speeifieally "fflO t ." _ deterffllRO the ab1hty to ffleet the aooeptaRoe eriteria. (eoRtiRl:lOd) DAEC AffleRdffleRt a11

F"requenoy 4-4 44 Frequenoy (oontinued) EXAMPLE The follm.ving mcamp l ~ !llustrates

                                          .          the manner in 'Nhioh F"requenoies are speo1f1ed .

EXAMPLE 1.4 1 eURVe l LLA~JGE ReQU I ReMe~ng eURVelLLANGe FRE:QUE:NGY Pe rf arm Gl=l 11

                                " ~J~ffLGl=leGK.                 12 hours
                                                 . of eR most often enoo~~tered in DAeG                                                                     Amendment 311

DELETED LGO Applioability

3.0 LIMITING GONDITIO~J FOR OPER/\TIO~J (LGO) APPLICABILITY LGO a.0.1 LGOs shall be Rlet d1:1riRg the speoified ooRditioRs iR the

                 /\pplioability , mcoept as provided iR LGO a.0.2.

LGO 3.0.2 Leo a.a.a Deleted . LGO a.0.4 Deleted. LGO a.0.6 Deleted . LGO 3.0.6 Deleted . LGO a.0.7 Deleted . LGO 3.0.8 Deleted. LGO a.O.Q Deleted. DAEC 3.0-1 Amendment 344

eR Applioability

UIREME~JT (eR) APPLICABILITY SURVE'ILLANGE REQ .. iA tAe ApplisaBility { SR @.0.1

                                                                                 ~~
                                                . tl'le speeified eond1t1?n\e SR . l=ailu.re to
                                    ~FO~

SRs sAall Be "'el ""::ress elAeFWis* . slale8 leFieAsea ElYflA§ fer iA8i*i8Yal iA~

                                                " *AetAeF sYsA fail":'       :.eel
                                                                             ~~

perteF"'aAses el y

                                                                "'"ii~

FReel a 8YR1e1 aAsl SYrveillaAse OF e LGO. FailYFe le IAe perteFFRaAse e Rall Be lailYre le FreqYeAsy sAall Be 1

                                    "'f~lla~~'i:J ~~~weillaAses ?.*,~:: 9;v.;"lsi8e 1 IAe 8YR1e1llaAse, s                  "'IAiA IAe spes1 ie                A " e le Be
               ;;;rterFRtoamee~

failure S" e ble equipment or va spesifie8 perteFFRe8 SA IA0pera . flffHts.:.

                        .                                              .       I if tAe 8YweillaAse is TAe      spee1l1e~ ~' 'f
                               . . d i;: equeney for ea el'l SR isI me eified in tl'le 26 liFRes tAe iAte"'a: spe rterFRaRse er as .

l=req1mney , as m:a~ime a speeified eond1t1on o perte'"'"" w1IA1A . "'"" IFe"' tAe pFeY10"s pe I IAe Fmq"eAsy is

              "'""s"rea !Fe"' I e                                                                           . A met, For i;:requeno1es    . sp eeified as "onee," IAe aBeve iAteFYal eMleAs10                          ......J,.-

I Sees A01 appl'f. . . SR @.0.3

                           . "          d tl'lat a Surve1lla~ee
                                                           .        ...as not 1111;.,.            rf or med witl'l1n A tl'leperequiremeno      t t its II ii is 81ss0. ere            . IAeA ee.,,phaAee wll I                  tAe tiffie el spesilie8 Freq"*A::i* FR el FRay Be 8elaye8: r;:. speeilie8 8eslare tAe LGO 24 Ae"FS er "P le IAe 11,,,11 *. eFie8 is peF,,,itte8 le 8isseyeri<, "P le * " er is §realer. TA1s *:lay:a" alYalieA sAall Be FmqYeAey, wA1sA v I IAe 8YR10illaAse. ' ' FIS t ' 1AaA 24 AeYFS aA8 allmv performane? ~urveillanee delayed grea er perts'"'"" leF *A't B "'aAa§e8.                                                       . A
              ;Re risk iffipasl sAall - *                       "'IA'A IAe Salay peno8, 1- e 1

LGO must immediately be If tl'le eurveillanoe. .is n? t performedieelared 1iVnot d 1 met, an d tl'le appheable Gondition(s) must be entere ~ ed ... *1tl'lin tl'le delay pebriod and

              ;~:':;'"rveillaAse is~~ 1::~:~~eaBle GeA8ilieA~s)
              \II '       tl'le Surveillanee *is pe- orm     LGO
                                                              - ..must imme d"iately - e deolared not met, a                                                            "'" 51 Be entered.

(oontinued) Amendment a11

SR. Applioability

                                                                                                    &:G
~   SR APPLICABILITY (oontinucd)

SR 3.0.4 Entry into a spceified eonditio . A

LCO sl:iall only be 1Ttad '"'A n in tt:ic n pplleability of an L-B e " 0R the LGG's S *11 'f ccn ITICt witl:iin tl:icir s T u r v c 1 anocs t:iavc SR 3.0.3. pcOI icd Frcqucney, mcocpt as provided by This ~revisieR shall Rel reve ,. ..

tt:ie Applieability tt:iat ar:rcqui~!:~tF) into spc~1f1cd eonditions in 1 o eolTlply 'N1tl:i ACTIONS . ~ DAEC l'c1Ttcnd1Ttcnt ~H 1

3.1 DE:H:TE:D AmeRdmeRt 311

3.2 DE LETED D/\EG Amendment 311

a.a DELETED Amendment 311

3.4 DELEHO:D DAEG Amendment 311

3.5 DELETED D/\EG Amendment 311

a.s DELETED DAEG Amendment d11

3.7 PLA~H SYSTEMS a.7.1 Deleted DAEG Amendment a11

3.7 PL/\NT SYSTEMS 3.7.2 Deleted

-+-

DAEG Amendment 311

3.7 PLANT SYSTEMS 3.7.3 Deleted DAEG Amendment 311

3.7 PLANT SYSTE:MS a.7 .4 Deleted

3.7 PLA~JT SYSTEMS a.7.5 Deleted Amendment a11

3.7 PL/\NT SYSTEMS 3.7.6 Deleted O/\EG Amendment 311

3.7 PLANT eYeTEMe 3.7.7 Deleted DAEC Amendment 311

Spent Fuel Storage Pool \/l/ater Level

3.7 PLANT SYSTEMS 3.7.8 Spent Fuel Storage Pool Water Level LCO 3.7.8 Tt:le spent fue l storage pool water level st:lall be ~ .ae--#:- APPLICABI LITY: During movement of irrad iated fuel assemblies in tt:le spent fue l storage pool. ACTIONS CO~JD I T I O~J REQU IRE:D ACTION COMPLETION TIME Spent fue l storage M Suspend movement of Immed iately pool water level not irrad iated fuel witt:l in limit. assemblies in tt:le spent f1:1el storage pool. SURV EI LL/\~J CE REQU I RE M E~JTS SURVEILLANCE FREQUE~JCY SR 3.7.8 .1 Verify tt:le spent fue l storage pool water In aeeordanee witA level is ~ ~ tt:le Surveillanee Frequeney Control Program DAEC Amendment 311

6.7 PLA~H SYSTEMS 6.7.0 Deleted D/\EG /\mendment a11

3.8 DELETED DAEG /\mendment 311

a.o DELETED DAEG Amendment 311

d.10 DELETED D/\EG d.10 1 , Amendment d11

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The plant site, which consists of approximately 500 acres, is adjacent to the Cedar River approximately 2.5 miles northeast of the Village of Palo, Iowa. The boundary of the exclusion area defined in 10 CFR 100 is delineated by the property lines. The distance to the outer boundary of the low population zone is 6 miles. The plan of the site is shown on UFSAR Figures 1.2-1 and 1.2-2. 4.2 Deleted 4.3 Fuel Storage 4.2.1 Criticality The spent fuel storage raclrn are designed and shall be maintained \Nith: ,f a:- Fuel assemblies having the following limits for maximum k infinity in the normal reactor core configuration at cold conditions and maximum lattice average U 225 enrichment weight pereent:

                                                                                *--9e Spent fuel shall not                  ~      7><7 and 8><8 pin arrays           ~ 4-:-29 be stored in the                                (Legaoy Fuel Assemblies only; spent fuel pool.                                  l=loltec and PaR rael(s) ii)   10><10 pin arrays (l=lolteo and PaR racks)
                               &.   -k-eff ~ 0.95 if fully flooded with unborated water, whioh inoludes an allowance for uncertainties as described in 0.1 of the UFSAR; and
                               &:-  A nominal 6.060 inches for l=IOLTEG designed and 6.625 inohes for PaR designed center to center distance between fuel assemblies placed in the storage racks.

4 The Baral neutron absorber shall have a 10 B areal density greater than or equal to 0.0162 grams 10 B/cm 2 with an unoertainty of 0.0012 grams 10 B/om 2 . (oontinued) DAEC 4.0-1 Amendment ~

Design i=eatures 4:G 4.0 DeSIGN i=e/\TUn D eS (eontinued) 4 3 2 Drainage The spent fuel st era ~* ~99*

I . designed and sha II Be .

                                                . ISof the pool belo'lv* e. le..
                                                                                     "'aiA!aiAe~

1i at10A o2 1 66, ft 2 3/4 .in . le pre*1en-t 1

                           *nad"11 ertent draining 4.3.3 Gapae1tv
               .                                   I *s designed and shae     11 8 fmaintained I

s~eAI I I s!aFa~e ~eaite~'

                                                               "'"re_ ;

tRaA 2663 "" I stara~e s~.~~isal iRsl*~~*~.:. TRe * **-----s ily Ii"' ta Ra "'are !Ra A 162 l*e in a ~ .in the oask pit in aooor a w itR a arieAtatiaA, witR YFSA R assemshes store assemslies seotion 0.1. DAeG r/\emendment 311

Responsibility

                                                                                       &.4 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility ~<:..-----_;lo-e-le-te-d----~
&.44        The plant 1T1anager shall be .responsible for overall facility operation          {

and shall delegate in writing the succession to this responsibility during his absence. The plant ITlanager or his designee shall approve, prior to i1T1ple1T1entation , each proposed test, mcperi1T1ent or 1T1odification to systelTls or equiplTlent that affect safe storage and 1T1aintenance of spent nuclear fuel. f The Operations Shift Manager shall be responsible for the shift co1T11T1and function . DAEC 5.0-1 Amendment ~

Organization

                                                                                            &+/-

5.0 ADMINISTRATIVE CONTROLS L---------,IDeleted 5.2 Organization -< ~------~

~           Onsite and Offsite Organizations Onsite and offsite organizations shall be established for faeility staff           -1 and eorporate management, respeetively . The onsite and offsite organizations shall incl1:1de the positions for aetivities affeeting safety of the n1:1elear f1:1el.                                                              ~

Lines of a1:1thority , responsibility , and eomm1:1nieation shall be defined and established thro1:1gho1:1t highest management levels, intermediate le'o'els, and all faeility organization positions. These relationships shall be doe1:1mented and 1:1pdated, as appropriate , in organizational deseriptions. These organizational deseriptions shall be doe1:1mented in the Ul=SAR or QA Program Deseription; The plant manager shall be responsible for overall safe operation of the faeility and shall have eontrol O\'er those onsite aetivities neeessary for safe storage and maintenanee of spent n1:1elear

The corporate officer shall have responsibility for the overall facility safety and shall take meas1:1res needed to ens1:1re aeeeptable performanee of the staff in operating , maintaining , and providing teehnieal s1:1pport to the faeility to ens1:1re safe management of spent n1:1elear fl:lel. The individ1:tals \\'ho train the GERTll=IED FUEL ~ANDLERS and those who earry 01:1t health physies, or perform q1:1ality ass1:1ranee f1:1netions may report to the appropriate onsite manager; however, these individ1:1als shall have s1:1ffieient organizational freedom to ens1:1re their ability to perform their assigned f1:1netions . (eontin1:1ed) DAEC 5.0-2 Amendment ~

Organization

6.2 Organization (eontinued) Faeility Staff The faeility organization shall meet the following: a:- E:aeh on duty shift shall inelude at least the following shift staffing:

One (1) Operation Shift Manager (see f belm.v) ; and
Two (2) ~JO~J CE:RTIFIE:D OPE:RATORS (see g below)

Shift erev1 composition may be .1e;s ~ht~~~hneot~~n=~~ed 2 hours t requirement of 6.2.2.a for a peno tod absenee of on duty shift in order to aoeommodate unmcpee e . . th erew members provided immediate a~t1.on is take~ to restoree shift erew eomposition to within the minimum re~~1rem~nt: .1 ds Durin sueh absenees, no fuel movemen~ or m~11 .em en o oa ever lie speAI f"el skall Be per,,,iHeO. n1s preY1s1eR Bees ~el ermit any shift erev1 position to be unma~ned upon shift e ange

ue to an ineoming shift erew member being late or absent.

At times when nuelear fuel is stored in the sp~nt fuel pool,I a~

                   ~~a~t~Jo~~~f1~~~si~~u:~~c;;o~ ::~E~TtHE:D n                           rf* d t t d " *ateh 1n the Centro oom FUE:L HANDLER) shall be present in the Control Room .

Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER A person qualified to implement radiation proteet!on proeeduret f }

                  ;kall Be "" site   ""'i"~ FflB\lelfleAl ef f"el aAB """"~ "'"YelfleA e ,   I loads over the fuel.

The Operations Shift Manager shall be a CERTIFIED FUEL HANDLER The position of ~JO~J CE:RTIFIE:D OPE:RATOR may be filled by a CE:RTIFIED FUEL HA~JDLE:R . DAE:C Amendment aog

Unit Staff Qualifieations

5.0 ADMINISTRATIVE CONTROLS 5.3 Faeility Staff Qualifieations +-(----i_ID_e_le_t_ed_ _ _ ___.

~             EaeA AleAlber of tAe faeility staff sAall Aleet or m<eeed tAe AliniAlUAl qualifieations refereneed for GOAlparable positions in A~JSl/A~JS a.1 1978. TAe radiation proteetion Alanager sAall Al Cot or mweed tAe qualifieations of Regulatory Guide 1.8, SepteAlber 1975.
~             TAe CERTIFIED FUEL FIA~JDLER sAall be qualified to tAe ~JRG approved training and retraining prograAl for GE:RTIFIED FUEL FIA~JDLERS . TAe NRG approved training and retraining prograAl for CERTIFIED FUEL FIA~JDH:RS sAall be Alaintained .

DAEC 5.0-4 Amendment 34 1-

ProceduFes e4 5.0 ADMINISTRATIVE CONTROLS 5.4 Prooedurns ~<:--------L_ID_e_le_t_ed_ _ _ ___.

.§44       VI/Fitten procedurns sl9all be establisl9ed , iR1pleR1ented , and Rlaintained coveFing tl9e follo*.ving activities:

a-: Tl9e applicable procedurns FecOR1R1ended in Regulatory Guide 1.66, Revision 2, Appendi>< A , l=ebFUary 1978;

           &.-     Tl9e effleFgency opemting pmcedurns rnquirnd to iR1pleR1ent tl9e rnquiFORlents of ~JU REG 0767 and to ~JUREG 0767, 8uppleR1ent 1, as stated in GeneFiG LetteF 82 aa;
           &.      Quality assumnce foF effluent and environfflental RlonitOFing; 4       [Deleted]; and e:-     All pmgmffls specified in Specifications 9.9.

DAEC 5.0-5 Amendment ~ f

Programs and Manuals

                                                                                          &.a 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals       ~<-----.._ID_e_le_t_ed_ _ _ __,

The following programs shall be established , implemented and maintained.

&.64          Offsite Dose Assessment Manual (ODAM)
             &. The OD/\M shall eontain the methodology and parameters used in the ealeulation of offsite doses resulting from radioaeti11e gaseous and liquid effluents, in the ealeulation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the eonduet of the radiologieal en11ironmental monitoring program; and
             &. The ODAM shall also eontain the radioaeti11e effluent eontrols and radiologieal en11ironmental monitoring aeti11ities and deseriptions of the information that should be ineluded in the Annual Radiologioal En11ironmental Operating Report and Radioaeti11e Material Release Report required by Speeifieation 5.6.2 and Speoifioation 5.6.a.
             &. Lieensee initiated ehanges to the ODAM :
                    +.-   Shall be dooumented and reeords of re11ie'NS performed shall be retained . This dooumentation shall oontain:
                          &. Sufficient information to support the ehange(s) together \Vith the appropriate analyses or e11aluations justifying the ehange(s) , and
                          &. A determination that the ehange(s) maintain the le11els of radioacti11e effluent eontrol required by 10 GFR 20.1ao2, 40 GFR 190, 10 cr;R 50.a6a, and 10 cr;R 50, Appendix I, and not ad11ersely impaot the aeouraoy or reliability of effluent dose or setpoint ealeulations;
                    ~    Shall beeome effeeti11e after the appro11al of the plant manager; and
                    &-   Shall be submitted to the ~'RC in the form of a oomplete, legible eopy of the entire ODAM as a part of or ooneurrent with the Radioaetive Material Release Report for the period of the report in whieh any ehange in the ODAM was made. Eash ehange shall be identified by markings in the margins of the affeeted pages, elearly indieating the area of the page that was ehanged, and shall indicate the date (i.e.,

month and year) the ehange was implemented . (eontinued) DAEC 5.0-6 Amendment ~ -{

Programs and Manuals

                                                                                                                      &.-6

.§:..§ Programs and ~4* anuals (continued) Radioaetive Effluent Controls p rogFam

                                            ~AO                               'aase~

Thi~ program , eonfoFmin md1oaetive effluents g to 10 GFR 60.@ea pFo"id P" Blis fro FR ra8 ieaefr lar "'aiAlaiA iAg Ille les lar Ille eaAlral al

e':~~~A~8 iA 8 sAa~*9:*~!p~sAievaBle.

prograFR sAall B ve .*fll"eAls as law as rea e FReFRBers al Ille prose8"res, aAOe Ille ODAM , Tile tile pragraFR liFRits a" e re1Re8ial aelieAs ta B eFReAte8 By lallawiAg ele ments:are e*eee8e8. Tile pre gmm shall e takeA inoludewlleA**er the

sea"s FROAilariAg iAslrnFRe~;~-Mly al raOiaastiya li~"i8

             &. Limitations on the rfun o-1onal   t"      sap 13T aAEI
                           ~~~~Al
                               ' " ' OelerFRiAaliaA iA ass~':..:ABO              " n~~~llAs"PJeillaAsa 61 8 IA:
                      .                                                                                      tests iA Ille 1Relll08alegy
             &.     ~1m itations hquid effluents  on thefro 6 oneen~rat1ons of radioaeti"e                 .

leA liFRas (10lc) IA"' tile site ta ""restriete8 .; FRalenal releases iA Gal""'" 2 ta 10 G~~*;*eAlraliaAs 0.1001 20.2402" liste8 iA n* :pas,;aAlarFRiAg en I)( B, Tal31e le 2, MonitOFing , sampling and . ,

                     ~*!~:~~

1 p~rs""":~=~~sc~Rra2~*rtive 1;~";"

                                    *fll."e"ts                                                         """
                      .             agy """ paraFReters iA tile OD ' ' <102 aAO wilA tile
             <!,    LIFR itatiOAS OR Ille BA                                    n ,'I '

oom~itment to a me'::~Fa;d quartm~y doses OF dose matenals in liquid effluents f tlhe pul3ho from radioaoti" e saAlaFffl iAg le 10 GFR liO , n.reppendl>C ease.a la1* "AreslrislaO . :.,. s, e:- Detmmin_ation of eumulati"e a . , z:::~:~*:~:F I~~ ~~~*:::.~:::.~eAlriB"liaAS

                                                                                                 ~"arler e.fll"eAI; lar aAO paraFRel              .year IA assar8aAsa "*ilA IA                                  aA8 eFS IA the OD/' M at             "'          e methodologv 1v      1east e**ec"U Fj '2 o 1i -days;       '

(oontinued) Amendment 311

Programs and Manuals

&.a

&.a Programs and Manuals &.&.4 Radioaotive Effluent Controls Program (oontinued)

            ~     Limitations on the funotional oapability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems which were used to establish compliance with the design objeotives in 10 CF"R 50, /\ppendi>< I, Section II be used when specified to provide reasonable assurance that releases of radioacti*1e material in liquid and gaseous effluents be kept as lm.v as reasonably achievable;
            §":'  Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the site boundary shall be limited to the follo'4ving :
                   +. For noble gases: less than or equal to a dose rate of 600 mrem/yr to the whole body and less than or equal to a dose rate of aooo mrem/yr to the skin, and
                   ~    For iodine 131 , iodine 1aa , tritium , and for all radionuclides in particulate fo rm with half lives ;:.. 8 days: less than or equal to a dose rate of 1500 m rem/yr to any organ; fl:. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary , oonforming to 10 CF"R 50 , /\ppendi>< I;
            ~    Limitations on the annual and quarterly doses to a member of the public from iodine 1a1 ' iodine 1aa, tritium ' and all radionuclides in partioulate form with half lives ;:.. 8 days in gaseous effluents released to areas beyond the site boundary , conforming to 10 CFR 50 , Appendix I; and

t. 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 sourees, conforming to 40 CFR 190.

The provisions of SR a.0.2 and SR a.a.a are applioable to the Radioactive Effluent Controls Program surveillance frequency . (oontinued) D/\EC

Prograffis and Manuals

&:a

&.-& Prograffis and Manuals (eontinued) Deleted ~ Deleted Deleted Storage Tani< Radioaetivity Monitoring Prograffi This prograffi provides eontrols for the quantity of radioaetivity eontained in unproteeted outdoor liquid storage tanks. The liquid radwaste quantities shall be deterffiined in aeeordanee \Nith Standard 1 Review Plan , Section 1e.7.a, "Postulated Radioactive Release due to Tani< l=ailures". The prograffi shall include a surveillanee prograffi to ensure that the ----r quantity of radioaetivity contained in all outdoor liquid rad*waste tanlrn that are not surrounded by liners, dilrns, or walls, capable of holding the tanl<s' oontents and that do not have tanl< overflows and surrounding area drains eonneoted to the Liquid Radwaste Treatffient Systeffi is ~ 60 euries, mcoluding tritiuffi and dissolved or entrained noble gases. The liquid radwaste storage tanks in the Low Level Radwaste Proeessing and Storage l=aeility are eonsidered unproteeted outdoor tanks. The provisions of SR a.0.2 and SR a.a.a are applieable to the Storage Tank { ' Radioaotivity Monitoring Prograffi surveillanoe frequenoies. Deleted 5.5.10 Teohnioal Speoifieations (TS) Bases Control Prograffi This prograffi provides a ffieans for proeessing ehanges to the Bases of these Teohnieal Speoifieations. a:- Changes to the Bases of the TS shall be ffiade under appropriate adffiinistrative eontrols and revim.vs.

            &.      Lieensees ffiay ffialrn ehanges to Bases 1Nithout prior NRG approval provided the ohanges do not require either of the following:
                    +.      A ehange in the TS inoorporated in the lioense; or (eontinued)

DAEG Affiendffient a11

Programs and Manuals e:-0 e:-0 Programs and Manuals 5.5.10 Tcohnioal epcoifioations (Te) Bases Control p rogram (eont1nucd) .

                    ~       A ehangc to the UFSAR or Bas pursuant to 10 GFR 50.59.

cs that requires ~JRG appro'val The Bases Control Program shall . .. the Bases arc maintained eonsistc:~:!:~: f::v~s~~n;:~~ ensure that Proposed ehangcs that me t th . .

                    ?bovc shall be reviewed an~c e~~tcna ~f Spceifieation 5.5.10b implementation. Changes to ~:pr:vcd ~'.t the ~JRG prior to
                    ~JRG_ approval shall be providcdc to ~::s~;~~lcmcntcd without prior eonS1stcnt with 10 GFR 50 _71 (c) .                on a frcqucney 5.5.11       Deleted 5.5.12       Deleted 5.5.1a       Deleted 5.5.14       Survcillanec Frcqucne"r Control Program This program pro'vidcs eontrols fo s .

program shall ensure that Su . *11 ruri. Clllan_ ec P"rcqucneics. The Tcehnieal Spceifieations arc ri.c: anec Rc~uircmcnts spceificd in the the assoeiatcd Limiting Gond~* or~cd at int~rvals suffieicnt to assure I ions or Operation arc met.

a. The Suri.*cillanec Frcqucney Go t I P

Frcqucneics of those Sur" elnan:eroRrowam shall eontain a list of Frcqucney is eontrollcd b; th cqu1rcmcnts for whieh the c program .

b. Changes to the P"rcqucneics listed in th g .

Control Program shall be _ curvC1llanec F"rcqucney Informed Method for Cont:~:~ ~n a.0~1frdanoc with N~I 04 10, "Risk

                          . .                        uri.01 anec F"rcqucne1cs," Revision 1.

csta~~:~:mdc~ts t:.0.2 an~ a.a.a arc

e. The prov1s1ons of Survcillanec Re .

applieablc to the Frcqucneics 0 Frcqucney Control Program . in c Survc1llanec (continued) DAEG 6.0 10 Amendment a11

Programs and Manuals

                                                                                               &.a Programs and Manuals (eontinued) 5.5.15       Spent Fuel Po oeutron IN           Absorber Monitoring Program
            ~eA81l1eA et Baral iA IAe speAI IH!i"'"""i"~

Tl:iis .program

                     .        prov1
                                 *"des routine m       *t

aA8 .aelieAs le eASHFC IAal IAe sat;~ ""a 1~ :S " ~"~~~ :~~"alieA eapabiHIY ;:s:Jb:*i:~;ea pre~ra"' sAall iAelH8e Ille0lellew;~: eel1eA "'aiAlaiAe8. Tile e o ensure ttmt tl:ie B poo rael<s 1s approp
t 1 1

eriliealily 9.1 is performed at a frequeney of t g for tl:ie Pa~ rael~~< I, eeotion IV.B.1. ~ DELETED ~ DELETED &.&.+ DELETED DAEG 5.0 1 d Amendment a11~~

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request NG-20-0094 Enclosure, Attachment 2 Page 1 of 17 ATTACHMENT 2 REVISED FACILITY LICENSE AND TECHNICAL SPECIFICATION PAGES (CLEAN, WITH PROPOSED CHANGES)

~~NEXTERA ENERGY DUANE ARNOLD. LLC CENTRAL IOWA POWER COOPERATIVE CORN BELT POWER COOPERATIVE DOCKET 50-331 DUANE ARNOLD ENERGY CENTER RENEWED FACILITY LICENSE Renewed License No. DPR-49~~

~~1. The Nuclear Regulatory Commission (the Commission) having found that:~~
A. The application for license filed by FPL Energy Duane Arnold, LLC,* Central Iowa Power Cooperative and Corn Belt Power Cooperative (the licensees) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I and all required notifications to other agencies or bodies have been duly made; B. Deleted; C. The facility will be maintained in conformity with the application, as amended; the provisions of the Act; and the rules and regulations of the Commission; D. There is reasonable assurance: (i) that the activities authorized by this renewed 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 rules and regulations of the Commission; E. NextEra Energy Duane Arnold, LLC is technically qualified and NextEra Energy Duane Arnold, LLC, Central Iowa Power Cooperative and Corn Belt Power Cooperative are financially qualified to engage in the activities authorized by this renewed license in accordance with the rules and regulations of the Commission; F. The licensees have satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this renewed license will not be inimical to the common defense and security or to the health and safety of the public; H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental costs and considering available alternatives, the issuance of renewed Facility License No. DPR-49 is in accordance with 10 CFR Part 50, Appendix D, of the Commission's regulations and all applicable requirements of said Appendix D have been satisfied;
~~on April 16, 2009, the name "FPL Energy Duane Arnold, LLC" was changed to "NextEra Energy Duane Arnold, LLC."~~
Renewed License No. DPR-49 Amendment 311
I. Deleted.
~~2. Renewed Facility License No. DPR-49 is hereby issued to NextEra Energy Duane Arnold, LLC, Central Iowa Power Cooperative (CIPCO) and Corn Belt Power Cooperative (Corn Belt) to read as follows:~~
A This renewed license applies to the Duane Arnold Energy Center, a permanently defueled boiling water reactor and associated equipment (the facility), owned by NextEra Energy Duane Arnold, LLC, Central Iowa Power Cooperative and Corn Belt Power Cooperative and operated by NextEra Energy Duane Arnold, LLC. The facility is located on NextEra Energy Duane Arnold, LLC's, Central Iowa Power Cooperative's and Corn Belt Power Cooperative's site near Palo in Linn County, Iowa. This site consists of approximately 500 acres adjacent to the Cedar River and is described in the "Final Safety Analysis Report" as supplemented and amended (Amendments 1 through 14) and the Environmental Report as supplemented and amended (Supplements 1 through 5). B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses: (1) NextEra Energy Duane Arnold, LLC, pursuant to Section104b of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," to possess and use the facility as required for nuclear fuel storage; and CIPCO and Corn Belt to possess the facility at the designated location in Linn County, Iowa, in accordance with the procedures and limitations set forth in this license; (2) NextEra Energy Duane Arnold, LLC, pursuant to the Act and 10 CFR Part 70, to possess at any time special nuclear material that was used as reactor fuel, in accordance with the limitations for storage, as described in the Updated Final Safety Analysis Report, as supplemented and amended as of June 1992 and as supplemented by letters dated March 26, 1993, and November 17, 2000. (3) NextEra Energy Duane Arnold, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source or sealed sources for radiation monitoring equipment calibration, and to possess any byproduct, source and special nuclear material as sealed neutron sources previously used for reactor startup or reactor instrumentation; and fission detectors; (4) NextEra Energy Duane Arnold, LLC, 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 radioactive apparatus components; (5) NextEra Energy Duane Arnold, LLC, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear materials that were produced by the operation of the facility. Renewed License No. DPR-49 Amendment 311
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I; Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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) Deleted (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. , are hereby incorporated in the license. NextEra Energy Duane Arnold, LLC shall maintain the facility in accordance with the Permanently Defueled Technical Specifications. (3) Deleted (4) Deleted. (5) Physical Protection NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, Renewed License No. DPR-49 Amendment
I I and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73. 55 (51 FR 27817 I and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans , which contains Safeguards Information protected under 10 CFR 73.21, is entitled : "Duane Arnold Energy Center Physical Security Plan," submitted by letter dated May 16, 2006. NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved Duane Arnold Energy Center/NextEra Energy Duane Arnold , LLC Cyber Security Plan (CSP), including changes made pursuant tci the authority of 10 CFR 50.90 and 10 CFR 50.54(p ). The Duane Arnold Energy Center/NextEra Energy Duane Arnold, LLC CSP was approved by License Amendment No. 278, as supplemented by changes approved by license Amendment No . 284 and Amendment 291 . (6) Deleted (7) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No . 279, are hereby incorporated into this license. NextEra Energy Duane Arnold, LLC shall operate the facilrry in accordance with the Addrrional Condrrions. (8) Deleted (9) Deleted (10) The licensee shall implement and maintain all Act ions required by Attachment2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan , contingency plan, emergency plan and/or guard training and qualification plan , as appropriate. Renewed License No . DPR-49 Amendment
(11) Deleted. ( 12) Deleted. (13) Deleted. D. This license is effective as of the date of issuance and is effective until the Commission notifies the licensee in writing thatthe license is terminated. FOR THE NUCLEAR REGULATORY COMMISSION Original signed by Eric J. Leeds Eric J. Leeds, Director Office of Nuclear Reactor Regulation
~~Enclosures:~~
1. AppendixATechnical Specifications

2. Appendix BAdditional Conditions Date of Issuance: December 16, 2010 Renewed License No. DPR-49 Amendment 312
APPENDIX B ADDITIONAL CONDITIONS LICENSE NO. DPR-49 NextEra Energy Duane Arnold, LLC (the term licensee in Appendix B refers to NextEra Energy Duane Arnold, LLC or prior license holders) shall comply with the following conditions on the schedule noted below: Amendment Number Additional Conditions Implementation Date 223 DELETED 275 260 (1) NextEra Energy Duane Arnold shall take all This amendment is 275 necessary steps to ensure that the external trust effective immediately fund is established at the time of the closing of and shall be implemented the transfer of the license from Interstate Power within 30 days of the date (IPL) to FPLE Duane Arnold is maintained in of this amendment. accordance with the requirements of the December 23, 2005 order approving the license transfer, NRC regulations, and consistent with the safety evaluation supporting the order. The trust agreement shall be in a form acceptable to the NRC. 260 (2) DELETED 279 260 (3) DELETED-Amendment
1.0 DELETED DAEC 1.1-1 Amendment
2.0 DELETED DAEC 2.0-1 Amendment 311
3.0 DELETED DAEC 3.0-1 Amendment
Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The plant site, which consists of approximately 500 acres, is adjacent to the Cedar River approximately 2.5 miles northeast of the Village of Palo, Iowa. The boundary of the exclusion area defined in 10 CFR 100 is delineated by the property lines. The distance to the outer boundary of the low population zone is 6 miles. The plan of the site is shown on UFSAR Figures 1.2-1 and 1.2-2. 4.2 Deleted 4.3 Fuel Storage Spent fuel shall not be stored in the spent fuel pool. DAEC 4.0-1 Amendment
5.0 ADMINISTRATIVE CONTROLS 5.1 Deleted DAEC 5.0-1 Amendment
5.0 ADMINISTRATIVE CONTROLS 5.2 Deleted DAEC 5.0-2 Amendment
5.0 ADMINISTRATIVE CONTROLS 5.3 Deleted DAEC 5.0-3 Amendment
5.0 ADMINISTRATIVE CONTROLS 5.4 Deleted DAEC 5.0-4 Amendment
5.0 ADMINISTRATIVE CONTROLS 5.5 Deleted DAEC 5.0-5 Amendment
5.0 ADMINISTRATIVE CONTROLS 5.6 Deleted DAEC 5.0-6 Amendment}}

v t e Letter Sequence Request
EPID:L-2021-LLA-0029, Supplement Information to Technical Specification Amendment Application (Approved, Closed)
Initiation Request, Request Acceptance Supplement Administration Questions Answers Results Approval Other:
MONTHYEAR2022-01-21 [Table View]

NG-20-0094, License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool

Text

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

Enclosures:

Enclosures:

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