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{{#Wiki_filter:Dominion Energy Kewatnee, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060 DominionWeb Address:
www.dom.com January 7, 2014U. S. Nuclear Regulatory Commission Serial No. 13-226FAttention:
Document Control Desk LIC/CDS/RO Washington, DC 20555-0001 Docket No. 50-305License No. DPR-43DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATIONSUPPLEMENT 2: LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) toPermanently Defueled Technical Specifications (PDTS), consistent with thepermanently defueled status of the plant. Supplement 1 to the amendment request wassubmitted on October 15, 2013 (Reference 2).The subject amendment request proposed deletion of the cyber security provisions contained in License Condition 2.C.(4).
The proposed deletion of this portion of LicenseCondition 2.C.(4) was based on DEK's conclusion that the requirements of 10 CFR73.54, "Protection of digital computer and communications systems and networks,"
nolonger applied to KPS. However, the NRC staff recently verbally informed DEK(Reference
: 3) that 10 CFR 73.54 continues to apply to facilities that were licensed tooperate on November 23, 2009. November 23, 2009 was the date by which alllicensees licensed to operate a nuclear power plant were required to submit a cybersecurity plan to the NRC for review and approval.
In response to the staffs comments, DEK is revising the originally proposedamendment request.
The revised request retracts the original proposal to delete thecyber security provisions contained in License Condition 2.C.(4),
which will result in thislicense condition remaining unchanged.
Attachment 1 to this letter provides asupplement to the proposed amendment describing the revision.
Attachment 2 containsthe marked-up License page affected by this revision.
The conclusions of the nosignificant hazards consideration and the environmental considerations contained inReference 1 are not affected by, and remain applicable to, this revision.
The June 1, 2014 requested approval date for the submittal remains unchanged.
Serial No. 13-226FLAR 256 Supplement 2Page 2 of 3Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or requireadditional information.
Sincerely, Mark D. SartainVice President
-Nuclear Engineering and Development COMMONWEALTH OF VIRGINIACOUNTY OF HENRICO))The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, todayby Mark D. Sartain, who is Vice President
-Nuclear Engineering and Development of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of thatCompany, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this 7__"___ day of jv, Art$ ,2014.My Commission Expires:
zid, IeiN/otary rub bricCRAIG D SLYNotary PublicCommonwealth of VirginiaReg. # 7518653My Commission Expires December 31, 20,Attachments:-.
-... .....1. Discussion of Change and Technical Analysis2. Marked-up License Page 4
==References:==
: 1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"
dated May 29, 2013. (ADAMS Accession No. ML1 3156A037)
: 2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1and Response to Request for Additional Information Regarding LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"
dated October 15, 2013. (ADAMS Accession No. ML13294A091)
: 3. Teleconference between NRC staff and DEK representatives regarding applicability of 10 CFR 73.54, "Protection of digital computer and communication systems and networks,"
to Kewaunee Power Station, on November 13, 2013.
Serial No. 13-226FLAR 256 Supplement 2Page 3 of 3cc: Regional Administrator, Region IIIU. S. Nuclear Regulatory Commission 2443 Warrenville RoadSuite 210Lisle, IL 60532-4352 Dr. K. D. FeintuchProject ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D1511555 Rockville PikeRockville, MD 20852-2738 Mr. W. C. Huffman Jr., Project ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D1511555 Rockville PikeRockville, MD 20852-2738 Public Service Commission of Wisconsin Electric DivisionP.O. Box 7854Madison, WI 53707 Serial No. 13-226FATTACHMENT 1SUPPLEMENT 2:LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSISKEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.
Serial No. 13-226FAttachment 1Page 1 of 3SUPPLEMENT 2LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS1.0 DESCRIPTION By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) toPermanently Defueled Technical Specifications (PDTS), consistent with thepermanently defueled status of the plant. Supplement 1 to the amendment request wassubmitted on October 15, 2013 (Reference 2).The subject amendment request proposed deletion of the cyber security provisions contained in License Condition 2.C.(4).
The proposed deletion of this portion of LicenseCondition 2.C.(4) was based on DEK's conclusion that the requirements of 10 CFR73.54 no longer applied to KPS. 10 CFR 73.54 specifies requirements for protection ofcertain types of digital computer and communication systems and networks againstcyber attack. The preamble of this regulation states that by November 23, 2009, eachlicensee currently licensed to operate a nuclear power plant shall submit a cybersecurity plan for Commission review and approval.
DEK fulfilled this requirement priorto November 23, 2009, as required by the regulation.
Subsequently, DEK submitted acertification of permanent removal of fuel from the reactor vessel (Reference 3)pursuant to 10 CFR 50.82(a)(1)(ii) by letter dated May 14, 2013. As a result, the 10CFR Part 50 license for KPS no longer authorizes operation of the reactor oremplacement or retention of fuel into the reactor vessel, as specified in 10 CFR50.82(a)(2).
Based on the above, DEK concluded that 10 CFR 73.54 was no longer applicable toKPS since 10 CFR 73.54 states that the requirement to submit a cyber security plan isrequired only for "each licensee currently licensed to operate a nuclear power plant"(DEK is no longer authorized to operate the KPS reactor).
: However, the NRC staffrecently verbally informed DEK (Reference
: 4) that 10 CFR 73.54 continues to apply tofacilities that were licensed to operate on November 23, 2009.In response to the staffs comments, DEK is revising the originally proposedamendment request.
The revised request retracts the original proposal to delete thecyber security provisions contained in License Condition 2.C.(4).
The proposedretraction will result in this license condition remaining unchanged.
Attachment 2contains the marked-up License page affected by this proposed change to theamendment request.
The conclusions of the no significant hazards consideration and Serial No. 13-226FAttachment 1Page 2 of 3the environmental considerations contained in Reference 1 are not affected by, andremain applicable to, this proposed change.2.0 PROPOSED CHANGEThe originally proposed request to delete the second paragraph of License Condition 2.C.(4),
regarding cyber security provisions, is being retracted.
This paragraph will bemaintained unchanged as shown below.The licensee shall fully implement and maintain in effect all provisions of theCommission-approved
: Kewaunee, Millstone, North Anna, and Surry Power StationsCyber Security Plan (CSP), including changes made pursuant to the authority of 10CFR 50.90 and 10 CFR 50.54(p).
The CSP was approved by License Amendment No. 210.3.0 TECHNICAL ANALYSISRetraction of the originally proposed change results in no change being proposed to thecurrently existing second paragraph of License Condition 2.C.(4),
regarding cybersecurity provisions.
License Condition 2.C.(4),
"Physical Protection,"
is therefore beingmaintained unaltered in its entirety.
Maintaining this license condition unchanged hasno impact on the remainder of the changes proposed in LAR 256 (Reference 1).4.0 SUMMARYDEK proposes that License Condition 2.C.(4),
"Physical Protection,"
be maintained unchanged.
5.0 REGULATORY ANALYSIS5.1 No Significant Hazards Consideration The conclusions of the no significant hazards consideration contained in Reference 1are not affected by, and remain applicable to, this proposed change.5.2 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements/criteria contained in Reference 1 are notaffected by, and remain applicable to, this proposed change.
Serial No. 13-226FAttachment 1Page 3 of 36.0 ENVIRONMENTAL CONSIDERATION The conclusions of the environmental considerations contained in Reference 1 are notaffected by, and remain applicable to, this proposed change.
==7.0 REFERENCES==
: 1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"
dated May 29, 2013. (ADAMS Accession No. ML13156A037)
: 2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications,"
datedOctober 15, 2013. (ADAMS Accession No. ML13294A091)
: 3. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Certification of Permanent Removal of Fuel from the Reactor Vessel,"
dated May 14, 2013.(ADAMS Accession No. ML13135A209)
: 4. Teleconference between NRC staff and DEK representatives regarding applicability of 10 CFR 73.54, "Protection of digital computer and communication systems andnetworks,"
to Kewaunee Power Station, on November 13, 2013.
Serial No. 13-226FATTACHMENT 2SUPPLEMENT 2:LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS MARKED UP LICENSE PAGE 4KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.  (4) Physical Protection The licensee shall fully implement and maintain in effect all provisions ofthe Commission-approved physical
: security, training and qualification, andsafeguards contingency plans including amendments made pursuant toprovisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of10 CFR 50.90 and 10 CFR 50.54(p).
The combined set of plans, whichcontains Safeguards Information protected under 10 CFR 73.21 is entitled:
"Nuclear Management Company Kewaunee Nuclear Power Plant PhysicalSecurity Plan (Revision 0)" submitted by letter dated October 18, 2004, andsupplemented by letter dated October 21, 2004, July 26, 2005, andMay 15, 2006.The licensee shall fully implement and maintain in effect all provisions ofthe Commission-approved
: Kewaunee, Millstone, North Anna, and SurryPower Stations Cyber Security Plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
The CSPwas approved by License Amendment No. 210.(5) Deleted(6) DeletedSteam
-Generator Wow Lateral Sup..,tsThe design of the steam generator upper lateral supports may be modifiedby reducing the number of snubbersi from four (4) to one (1) per steam( eneDated.
(7) Deleted(8) Deleted(9) Deleted(10) Deleted M.. tpat0. Stato. .Licen.e Condition Develop and maintain strategies for addressing large fires and explosions and that finclude the following key areas:(a) Fire fighting response strategy With the- folloingdR elements:.
: 1. Pre coordinated strategy and 2. Assessment of mutual aid fire fighting assets3. Designated staging areas for equipment and materials
: 4. Command and conrol15. Training of response personnel Renewed Operating License DPR-43}}

Revision as of 04:58, 3 July 2018

Kewaunee Power Station, Supplement 2: License Amendment Request 256, Permanently Defueled License and Technical Specifications
ML14009A393
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 01/07/2014
From: Sartain M D
Dominion Energy Kewaunee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226F
Download: ML14009A393 (9)
v • d • e


Text

Dominion Energy Kewatnee, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060 DominionWeb Address:

www.dom.com January 7, 2014U. S. Nuclear Regulatory Commission Serial No. 13-226FAttention:

Document Control Desk LIC/CDS/RO Washington, DC 20555-0001 Docket No. 50-305License No. DPR-43DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATIONSUPPLEMENT 2: LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) toPermanently Defueled Technical Specifications (PDTS), consistent with thepermanently defueled status of the plant. Supplement 1 to the amendment request wassubmitted on October 15, 2013 (Reference 2).The subject amendment request proposed deletion of the cyber security provisions contained in License Condition 2.C.(4).

The proposed deletion of this portion of LicenseCondition 2.C.(4) was based on DEK's conclusion that the requirements of 10 CFR73.54, "Protection of digital computer and communications systems and networks,"

nolonger applied to KPS. However, the NRC staff recently verbally informed DEK(Reference

3) that 10 CFR 73.54 continues to apply to facilities that were licensed tooperate on November 23, 2009. November 23, 2009 was the date by which alllicensees licensed to operate a nuclear power plant were required to submit a cybersecurity plan to the NRC for review and approval.

In response to the staffs comments, DEK is revising the originally proposedamendment request.

The revised request retracts the original proposal to delete thecyber security provisions contained in License Condition 2.C.(4),

which will result in thislicense condition remaining unchanged.

Attachment 1 to this letter provides asupplement to the proposed amendment describing the revision.

Attachment 2 containsthe marked-up License page affected by this revision.

The conclusions of the nosignificant hazards consideration and the environmental considerations contained inReference 1 are not affected by, and remain applicable to, this revision.

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

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

Sincerely, Mark D. SartainVice President

-Nuclear Engineering and Development COMMONWEALTH OF VIRGINIACOUNTY OF HENRICO))The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, todayby Mark D. Sartain, who is Vice President

-Nuclear Engineering and Development of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of thatCompany, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this 7__"___ day of jv, Art$ ,2014.My Commission Expires:

zid, IeiN/otary rub bricCRAIG D SLYNotary PublicCommonwealth of VirginiaReg. # 7518653My Commission Expires December 31, 20,Attachments:-.

-... .....1. Discussion of Change and Technical Analysis2. Marked-up License Page 4

References:

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"

dated May 29, 2013. (ADAMS Accession No. ML1 3156A037)

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1and Response to Request for Additional Information Regarding LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"

dated October 15, 2013. (ADAMS Accession No. ML13294A091)

3. Teleconference between NRC staff and DEK representatives regarding applicability of 10 CFR 73.54, "Protection of digital computer and communication systems and networks,"

to Kewaunee Power Station, on November 13, 2013.

Serial No. 13-226FLAR 256 Supplement 2Page 3 of 3cc: Regional Administrator, Region IIIU. S. Nuclear Regulatory Commission 2443 Warrenville RoadSuite 210Lisle, IL 60532-4352 Dr. K. D. FeintuchProject ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D1511555 Rockville PikeRockville, MD 20852-2738 Mr. W. C. Huffman Jr., Project ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D1511555 Rockville PikeRockville, MD 20852-2738 Public Service Commission of Wisconsin Electric DivisionP.O. Box 7854Madison, WI 53707 Serial No. 13-226FATTACHMENT 1SUPPLEMENT 2:LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSISKEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-226FAttachment 1Page 1 of 3SUPPLEMENT 2LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS1.0 DESCRIPTION By application dated May 29, 2013 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to Renewed Facility Operating License Number DPR-43 (Operating License) for Kewaunee Power Station (KPS). The proposed amendment would revise the KPS Operating License and Technical Specifications (TS) toPermanently Defueled Technical Specifications (PDTS), consistent with thepermanently defueled status of the plant. Supplement 1 to the amendment request wassubmitted on October 15, 2013 (Reference 2).The subject amendment request proposed deletion of the cyber security provisions contained in License Condition 2.C.(4).

The proposed deletion of this portion of LicenseCondition 2.C.(4) was based on DEK's conclusion that the requirements of 10 CFR73.54 no longer applied to KPS. 10 CFR 73.54 specifies requirements for protection ofcertain types of digital computer and communication systems and networks againstcyber attack. The preamble of this regulation states that by November 23, 2009, eachlicensee currently licensed to operate a nuclear power plant shall submit a cybersecurity plan for Commission review and approval.

DEK fulfilled this requirement priorto November 23, 2009, as required by the regulation.

Subsequently, DEK submitted acertification of permanent removal of fuel from the reactor vessel (Reference 3)pursuant to 10 CFR 50.82(a)(1)(ii) by letter dated May 14, 2013. As a result, the 10CFR Part 50 license for KPS no longer authorizes operation of the reactor oremplacement or retention of fuel into the reactor vessel, as specified in 10 CFR50.82(a)(2).

Based on the above, DEK concluded that 10 CFR 73.54 was no longer applicable toKPS since 10 CFR 73.54 states that the requirement to submit a cyber security plan isrequired only for "each licensee currently licensed to operate a nuclear power plant"(DEK is no longer authorized to operate the KPS reactor).

However, the NRC staffrecently verbally informed DEK (Reference
4) that 10 CFR 73.54 continues to apply tofacilities that were licensed to operate on November 23, 2009.In response to the staffs comments, DEK is revising the originally proposedamendment request.

The revised request retracts the original proposal to delete thecyber security provisions contained in License Condition 2.C.(4).

The proposedretraction will result in this license condition remaining unchanged.

Attachment 2contains the marked-up License page affected by this proposed change to theamendment request.

The conclusions of the no significant hazards consideration and Serial No. 13-226FAttachment 1Page 2 of 3the environmental considerations contained in Reference 1 are not affected by, andremain applicable to, this proposed change.2.0 PROPOSED CHANGEThe originally proposed request to delete the second paragraph of License Condition 2.C.(4),

regarding cyber security provisions, is being retracted.

This paragraph will bemaintained unchanged as shown below.The licensee shall fully implement and maintain in effect all provisions of theCommission-approved

Kewaunee, Millstone, North Anna, and Surry Power StationsCyber Security Plan (CSP), including changes made pursuant to the authority of 10CFR 50.90 and 10 CFR 50.54(p).

The CSP was approved by License Amendment No. 210.3.0 TECHNICAL ANALYSISRetraction of the originally proposed change results in no change being proposed to thecurrently existing second paragraph of License Condition 2.C.(4),

regarding cybersecurity provisions.

License Condition 2.C.(4),

"Physical Protection,"

is therefore beingmaintained unaltered in its entirety.

Maintaining this license condition unchanged hasno impact on the remainder of the changes proposed in LAR 256 (Reference 1).4.0 SUMMARYDEK proposes that License Condition 2.C.(4),

"Physical Protection,"

be maintained unchanged.

5.0 REGULATORY ANALYSIS5.1 No Significant Hazards Consideration The conclusions of the no significant hazards consideration contained in Reference 1are not affected by, and remain applicable to, this proposed change.5.2 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements/criteria contained in Reference 1 are notaffected by, and remain applicable to, this proposed change.

Serial No. 13-226FAttachment 1Page 3 of 36.0 ENVIRONMENTAL CONSIDERATION The conclusions of the environmental considerations contained in Reference 1 are notaffected by, and remain applicable to, this proposed change.

7.0 REFERENCES

1. Letter from Eugene S. Grecheck (DEK) to NRC Document Control Desk, "LicenseAmendment Request 256, Permanently Defueled License and Technical Specifications,"

dated May 29, 2013. (ADAMS Accession No. ML13156A037)

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications,"

datedOctober 15, 2013. (ADAMS Accession No. ML13294A091)

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

dated May 14, 2013.(ADAMS Accession No. ML13135A209)

4. Teleconference between NRC staff and DEK representatives regarding applicability of 10 CFR 73.54, "Protection of digital computer and communication systems andnetworks,"

to Kewaunee Power Station, on November 13, 2013.

Serial No. 13-226FATTACHMENT 2SUPPLEMENT 2:LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS MARKED UP LICENSE PAGE 4KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC. (4) Physical Protection The licensee shall fully implement and maintain in effect all provisions ofthe Commission-approved physical

security, training and qualification, andsafeguards contingency plans including amendments made pursuant toprovisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of10 CFR 50.90 and 10 CFR 50.54(p).

The combined set of plans, whichcontains Safeguards Information protected under 10 CFR 73.21 is entitled:

"Nuclear Management Company Kewaunee Nuclear Power Plant PhysicalSecurity Plan (Revision 0)" submitted by letter dated October 18, 2004, andsupplemented by letter dated October 21, 2004, July 26, 2005, andMay 15, 2006.The licensee shall fully implement and maintain in effect all provisions ofthe Commission-approved

Kewaunee, Millstone, North Anna, and SurryPower Stations Cyber Security Plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The CSPwas approved by License Amendment No. 210.(5) Deleted(6) DeletedSteam

-Generator Wow Lateral Sup..,tsThe design of the steam generator upper lateral supports may be modifiedby reducing the number of snubbersi from four (4) to one (1) per steam( eneDated.

(7) Deleted(8) Deleted(9) Deleted(10) Deleted M.. tpat0. Stato. .Licen.e Condition Develop and maintain strategies for addressing large fires and explosions and that finclude the following key areas:(a) Fire fighting response strategy With the- folloingdR elements:.

1. Pre coordinated strategy and 2. Assessment of mutual aid fire fighting assets3. Designated staging areas for equipment and materials
4. Command and conrol15. Training of response personnel Renewed Operating License DPR-43
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