ML13294A091

Kewaunee Power Station - Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications

ML13294A091
Person / Time
Site:	Kewaunee
Issue date:	10/15/2013
From:	Sartain M D Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-226B, LAR 256
Download: ML13294A091 (19)

Text

Dominion Energy Kewaunee, Inc. i1'F D5000 Dominion Boulevard, Glen Allen, VA 23060 DominionWeb Address:

www.dom.com October 15, 2013U. S. Nuclear Regulatory Commission Serial No. 13-226BAttention:

Document Control Desk LIC/CDS/R0 Washington, DC 20555-0001 Docket No. 50-305License No. DPR-43DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATIONSUPPLEMENT I AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 256, PERMANENTLY DEFUELEDLICENSE 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.Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request foradditional information (RAI) regarding the proposed amendment (Reference 2). TheRAI questions and associated DEK response are provided in Attachment 1 to this letter.In response to the staff's comments regarding proposed changes to TS LimitingCondition for Operation (LCO) 3.0.6 (NRC Question MF1952-RAII-STSB-Grover-002),

DEK is revising the originally proposed amendment.

The revised request proposes todelete LCO 3.0.6 in its entirety.

Attachment 2 to this letter provides a supplement to theproposed amendment describing the revision.

Attachment 3 contains the marked-up TSpage affected by this revision.

The analyses provided in Reference 1 remain applicable and bounding to this proposed change. The conclusions of the no significant hazardsconsideration and the environmental considerations contained in Reference 1 are notaffected by, and remain applicable to, this revision.

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

Serial No. 13-226BLAR 256 RAI ResponsePage 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

.VICKI L. HULLJNotary PublicJ Commonwealth of VirginiaSIJ 140542COMMONWEALTH OF VIRGINIA

)My Commission Expires May 31. 2014COUNTY OF HENRICO )The foregoing document was acknowledged before me, in and for the County andCommonwealth aforesaid, today by Mark D. Sartain, who is Vice President

-NuclearEngineering and Development of Dominion Energy Kewaunee, Inc. He has affirmed before methat he is duly authorized to execute and file the foregoing document in behalf of that Company,and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this /5--'day of ,2013.My Commission Expires:.

A ".. ,Notary PublicAttachments:

1. Response to Request for Additional Information

2. Supplement 1, Discussion of Change and Technical Analysis3. Supplement 1, Marked-up Technical Specifications Page

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. Email from Dr. Karl D. Feintuch (NRC) to Jack Gadzala and Craig Sly (DEK),"MF0996, MF1952 -Draft RAI items being processed to you," dated August 16,2013 Serial No. 13-226BLAR 256 RAI ResponsePage 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-Dl 511555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power StationPublic Service Commission of Wisconsin Electric DivisionP.O. Box 7854Madison, WI 53707 Serial No. 13-226BATTACHMENT 1RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

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

Serial No. 13-226BAttachment 1Page 1 of 8RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 256PERMANENTLY 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.Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request foradditional information (RAI) regarding the proposed amendment (Reference 2). TheRAI questions and associated DEK responses are provided below.NRC Question MFI952-RAII-STSB-Grover-001 DEK is proposing to replace "operation of the unit" with "management of irradiated fuel"in TS section 1.3, "Completion Times." In the application, DEK states that sinceoperation of the unit is no longer permitted, safe management (storage and movement) of irradiated fuel is the primary objective of the permanently defueled TS.In addition, TS 5.2.1.c is being revised to replace "to ensure nuclear fuel" with "toensure safe management of nuclear fuel."Use of the term "management" in the proposed TS 1.3, "Management of irradiated fuel"and TS 5.2.1 .c, "to ensure safe management of nuclear fuel," makes the meaning of thesentences unclear and open to interpretation.

It is not clear that management meansstorage and movement of irradiated fuel. Please provide changes that clearly identifythat storage and movement of irradiated fuel is the intent.Response:

DEK considers the term "management" in reference to nuclear fuel at a permanently shutdown facility in decommissioning to apply solely to the storage and movement ofirradiated fuel. DEK believes that the term provides an appropriate level of clarity foruse in the technical specifications consistent with the regulations.

"Management of all irradiated fuel" is the terminology used in 10 CFR 50.54(bb) andwas used by DEK in the KPS updated irradiated fuel management plan sent to NRC onFebruary 26, 2013 (Reference

5) in accordance with this regulation.

As such, DEKrecommends no change to the proposed wording.

Serial No. 13-226BAttachment 1Page 2 of 8This question is similar to NRC Question MF2370-RAII-AHPB-Lapinsky-002.

That NRCquestion and DEK's response to it are provided in Reference 4.NRC Question MF1952-RAII-STSB-Grover-002 In the application, DEK is proposing to delete the sentence shown below from limitingconditions for operation (LCO) 3.0.6.In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)."

If a loss of safety functionis determined to exist by this program, the appropriate Conditions and RequiredActions of the LCO in which the loss of safety function exists are required to beentered.DEK stated that the reasoning for the deletion is that the safety function determination program is not needed in a permanently defueled condition.

The NRC staff does notagree that the safety function determination program is not needed in a permanently defueled condition.

The safety function determination program is needed wheneverthere are support and supported systems in the technical specifications.

If TSs do notcontain support and supported

systems, then both LCO 3.0.6 and its associated SafetyFunction Determination Program should be deleted, since there would be no applicable LCOs in technical specifications.

Please explain which LCOs are supported systems and which LCOs are supportsystems.

If there are no support and supported systems that remain in the proposedTS, then please explain why LCO 3.0.6 is being retained.

Response

There are no support and supported systems that remain in the proposed TS. As such,there is no longer need for a SFDP. Consequently, TS 5.5.13, SFDP, was proposed fordeletion in LAR 256 (Reference

1) to preclude the administrative burden of unnecessary maintaining the SFDP. Because the sentence in LCO 3.0.6 (quoted in Question 2above) pertains solely to TS 5.5.13, that sentence is also no longer needed and waslikewise proposed for deletion.

Deletion of LCO 3.0.6 in its entirety was not proposed in LAR 256 because the retainedportion of LCO 3.0.6 would have been rendered moot.However, to prevent the potential for confusion regarding applicability of LCO 3.0.6,DEK proposes to supplement LAR 256 by deleting LCO 3.0.6 in its entirety (in responseto this question).

The proposed supplement is provided in Attachment

2.

Serial No. 13-226BAttachment 1Page 3 of 8NRC Question MF1952-RAII-STSB-Grover-003 On page 56 of 113 the last paragraph in the technical analysis section has a sentencethat states, "However, operation of the plant or placing fuel in the reactor vessel."Please explain what is meant by this sentence.

Response

This sentence is missing the phrase "10 CFR 50.82(a)(2) prohibits" after the first word.The complete sentence should read:"However, 10 CFR 50.82(a)(2) prohibits operation of the plant or placing fuel in thereactor vessel."The above sentence, and variants

thereof, is used throughout the submittal asjustification for eliminating requirements that pertain only to reactor operation (such asthe justification for deleting all of TS Section 3.5, Emergency Core Cooling Systems(ECCS)).

This sentence appears to have been inadvertently truncated.

The sentencerefers to the requirement in 10 CFR 50.82(a)(2) that prohibits operation of the plant orplacing fuel in the reactor vessel.NRC Question MF1952-RAII-STSB-Grover-004 DEK proposes to delete paragraph c of TS 5.2.2 which states:A radiation technologist shall be on site when fuel is in the reactor.

The position maybe vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, except in severe weather conditions, in order toprovide for unexpected

absence, provided immediate action is taken to fill therequired position.

DEK stated that this paragraph is being deleted because this requirement only applieswhen fuel is in the reactor.

The NRC staff believes it is prudent to have an individual qualified in radiation protection procedures on site during fuel handling operations orduring movements of loads over storage racks containing fuel.Paragraph c of TS 5.2.2 does not require the radiation protection staff to be on-siteduring fuel handling operations or during movements of loads over storage rackscontaining fuel. Please provide a requirement that requires the radiation protection staffto be on-site during fuel handling operations or during movements of loads over storageracks containing fuel, or provide the basis for not needing one.

Serial No. 13-226BAttachment 1Page 4 of 8Response:

DEK also believes that it is prudent to have an individual qualified in radiation protection procedures on site during fuel handling operations.

DEK believes that suchrequirements are appropriately managed via licensee-controlled documents (e.g.,procedures) rather than Technical Specifications.

Accordingly, existing KPS procedures require that radiation protection staff be present for various activities that may affectradiological conditions, such as movement of irradiated fuel.Specifically, movement of heavy loads (greater than the weight of a fuel assembly) overfuel stored in the spent fuel pool is prohibited by the Technical Requirements Manual(TRM). The TRM is incorporated by reference into the Updated Safety Analysis Report(USAR). As such, changes to the TRM must be made under the requirements of 10CFR 50.59. The licensing basis analysis documented in Chapter 14 of the USAR statesthat dropping a fuel assembly onto fuel stored in the spent fuel pool will not causeexcessive damage to the stored assemblies because the buckling load on the fuel rodsis below the critical buckling load and resulting stresses in the cladding are below yieldstresses.

Therefore, the drop of a load that does not exceed the weight of a fuelassembly would also not cause excessive damage to the stored assemblies.

The TRMprohibition on movement of heavier loads over fuel stored in the spent fuel poolprecludes the potential for spent fuel damage that could result in radiological consequences beyond the design basis analyses.

Licensee-controlled documents that contain requirements related to fuel handling andmovement of loads over storage racks containing spent fuel include the following.

• Procedure RE-25, "Fuel Movement During Non-Refueling Operations,"

requiresthat fuel handling evolutions be performed in accordance with Radiation WorkPermit (RWP) instructions (which specify coverage by radiation protection staff).* Procedure MA-KW-GMP-ISF-003, "Dry Shielded Canister Loading,"

invokesProcedure RE-25 (and its associated RWP requirements) for operations involving fuel movement associated with ISFSI campaigns.

The frequent involvement ofradiation protection staff in these fuel movement evolutions necessitates that atleast one individual qualified in radiation protection procedures be on site duringfuel handling operations.

" Procedure RP-KW-001-016, "Radiation Work Permit -Preparation,

Issuance, andTermination,"

provides instructions on preparing RWPs. This procedure specifies conditions where continuous,

periodic, or intermittent coverage by an individual qualified in radiation protection would be required.

Only low-risk work is eligible forno or routine coverage by radiation protection staff.Radiation Work Permits related to ISFSI loading campaigns (which include loading,preparation, transport, and associated support activities) require that continuous coverage be provided by radiation protection staff during various evolutions suchas removing items from the spent fuel pool and movement of fuel transfer casks.

Serial No. 13-226BAttachment 1Page 5 of 8These requirements also necessitate that at least one individual qualified inradiation protection procedures be onsite during the evolution.

• TRM 8.9.1, "Spent Fuel Pool -Control of Heavy Loads," specifies that heavy loadsgreater than the weight of a fuel assembly, including its heaviest insert andhandling tool, will not be transported over or placed in either spent fuel pool whenspent fuel is stored in that pool, unless the heavy load does not traverse directlyabove spent fuel stored in the pool's spent fuel storage racks, and the loadhandling system (e.g., crane, associated lifting devices, and interfacing lift points)used for these lifts meets the single-failure-proof handling system criteria.

" TRM 8.9.4, "Radiation Monitoring During REFUELING OPERATIONS" requiresmonitoring of radiation levels in the spent fuel pool area during refueling operations to provide indication of an unsafe condition.

This TRM section is in the process ofbeing revised to address the permanently defueled condition.

The term"REFUELING OPERATIONS" is being revised to state "movement of irradiated fuelassemblies or fuel assembly components."

Therefore, the TRM is being revised torequire monitoring of radiation levels in the spent fuel pool area during movementof irradiated fuel assemblies or fuel assembly components.

The existing procedural and TRM requirements are adequate to ensure that appropriate coverage by radiation protection staff is provided during fuel handling operations andduring movement of loads over storage racks containing spent fuel.The existing paragraph c of TS 5.2.2 is consistent with NUREG-1431, StandardTechnical Specifications, which does not specify a requirement for radiation protection staff to be on-site, except when fuel is in the reactor.

Leaving TS 5.2.2.c unchanged would not alter any requirement at KPS, since this TS does not address thepermanently defueled condition of KPS. Since staffing requirements for radiation protection personnel during spent fuel handling operations and during movement ofloads over storage racks containing spent fuel are appropriately addressed via plantprocedures, TS 5.2.2.c remains proposed for deletion as stated in the original submittal.

NRC Question MFI952-RAII-STSB-Grover-005 DEK proposes to add a new requirement to TS 5.2.2.c that states, "All fuel handlingoperations shall be directly supervised by a qualified individual."

The application statesthat this new requirement ensures that movement of irradiated fuel is only performed under the direct supervision of an individual who has been trained and qualified on theprocedures, processes, requirements and standards for safe movement of irradiated fuel.The NRC staff believes it is prudent to have fuel handling operations be directlysupervised by a certified fuel handler, as defined in TS.

Serial No. 13-226BAttachment 1Page 6 of 8The term "qualified individual" is unclear.

Please explain what DEK means by "qualified individual."

In addition, please explain the difference between a "qualified individual" and a "certified fuel handler."

Response

There is no intended difference between a "qualified individual" (as referred to in TS5.2.2.c) and a Certified Fuel Hander. TS 5.2.2.c was proposed with the terminology of"qualified individual" for consistency with Millstone Unit 1 TS 5.2.2.e because Millstone and KPS are both part of the Dominion fleet. The proposed TS 5.2.2.c is identical to therequirement approved by NRC for Millstone Unit 1 in existing TS 5.2.2.e.Proposed TS 5.2.2.a will require that a Certified Fuel Handler be part of the minimumshift crew composition.

Proposed TS 5.2.2.d will require that the shift manager shall bea Certified Fuel Handler.

Proposed TS 5.1.2 will require that the shift manager shall beresponsible for the shift command function.

Finally, proposed TS 5.2.2.c will requirethat all fuel handling operations shall be directly supervised by a qualified individual.

The "qualified individual" referred to in proposed TS 5.2.2.c is a Certified Fuel Handler.These requirements, in aggregate, assure that fuel handling operations are directlysupervised by a Certified Fuel Handler.This question is similar to NRC Question MF2370-RAII-AHPB-Lapinsky-005.

That NRCquestion and DEK's response to it are provided in Reference 4.NRC Question MF1952-RAII-STSB-Grover-006 DEK has proposed to delete TS 5.5.10, "Explosive Gas and Storage Tank Radioactivity Monitoring Program,"

and states that the tanks associated with this program will bevented and removed from service and there will no longer be any source of explosive orradioactive gases generated from reactor operation.

The NRC staff agrees that this program would not be required if each tank associated with this program is empty, will no longer be used in the future, and is controlled andisolated from any use in the future. However, if the associated tanks still have contents, or will be used in the future, then it is not appropriate to delete this program.Please provide a list of all tanks that apply to this program and explain if the tanks areempty and what controls are in place to prevent any use of these tanks in the future.Response:

The tanks that apply to the "Explosive Gas and Storage Tank Radioactivity Monitoring Program" are those associated with the gaseous radioactive waste disposal system Serial No. 13-226BAttachment 1Page 7 of 8(including gas storage and offgas treatment).

These tanks are the four gas decaytanks. Liquid waste at KPS is stored in the chemical and volume control system(CVCS) liquid holdup tanks, which are located in the auxiliary building.

The liquidholdup tanks are not within the scope of this program.Subsequent to the permanent shutdown of KPS, these tanks (including the liquid holduptanks) have been drained, vented, and radiologically analyzed.

The analyses indicatethat the remaining few gallons of liquid do not contain radioactive gases with thepotential for being volatized while being stored, processed or possibly leaked.Therefore, a failure involving the radioactive liquid waste systems is not capable ofchallenging dose limits established in 10 CFR 50.67 and Regulatory Guide 1.183 or theEPA's Protective Action Guidelines (PAG).KPS is a permanently shutdown facility (with fuel stored in the spent fuel pool andISFSI). The reactor coolant system (RCS) has been drained and vented. 10 CFR50.82(a)(2) prohibits operation of the reactor or placement or retention of fuel into thereactor vessel. Consequently, there is no longer a continuing source of radioactive gases being produced to contribute to the contents of the storage tanks (which was thepurpose of this program).

There are no specific controls to prevent use of these tanksfor other purposes in the future because such use would be outside the scope of theExplosive Gas and Storage Tank Radioactivity Monitoring Program.

The requirements of 10 CFR 50.82(a)(2) prohibits reactor operation and effectively serves as a control toprevent further generation of explosive gas mixtures or radioactive gases. Therefore, no additional controls are needed.Since the tanks do not currently contain a sufficient quantity of radioactivity to exceedthe dose limits discussed above, and the reactor can no longer generate additional radioactivity, this program is no longer required.

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. Email from Dr. Karl D. Feintuch (NRC) to Jack Gadzala and Craig Sly (DEK),"MF0996, MF1952 -Draft RAI items being processed to you," dated August 16,2013.3. Safety Evaluation by the Office of Nuclear Reactor Regulation Related toAmendment No. 207 to Facility Operating License No. DPR-43, Dominion EnergyKewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2,2011.

Serial No. 13-226BAttachment 1Page 8 of 84. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (Defueled License and TS), MF2370 (Cert Fuel Handler Training Program)

RAIs are beingprepared

-see attached drafts,"

dated August 8, 2013.5. Letter from Daniel G. Stoddard (DEK) to NRC Document Control Desk, "Update toIrradiated Fuel Management Plan Pursuant to 10 CFR 50.54(bb),"

dated February26, 2013 (ADAMS Accession No. ML13059A028).

Serial No. 13-226BATTACHMENT 2SUPPLEMENT 1:LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS DISCUSSION OF CHANGE AND TECHNICAL ANALYSISKEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-226BAttachment 2Page 1 of 3SUPPLEMENT 1LICENSE 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.In response to NRC staff comments regarding proposed changes to TS LimitingCondition for Operation (LCO) 3.0.6 (NRC Question MF1952-RAII-STSB-Grover-002 ofReference 2), DEK is revising the originally proposed amendment.

The revised requestproposes to delete LCO 3.0.6 in its entirety.

A discussion and technical analysis of theproposed change is provided below. Attachment 3 contains the marked-up TS pageaffected by the proposed change. The analyses provided in Reference 1 remainapplicable and bounding to this proposed change. The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1are not affected by, and remain applicable to, this proposed change.2.0 PROPOSED CHANGEAs noted in Attachment 1, since the TS no longer contain support and supported

systems, then both LCO 3.0.6 and its associated Safety Function Determination Program should be deleted because there are no applicable LCOs in the TS.Therefore, DEK proposes to delete LCO 3.0.6 in its entirety.

Consistent with thedeletion of LCO 3.0.6, a reference to LCO 3.0.6 contained in LCO 3.0.2 is alsoproposed for deletion.

Deletion of the requirement for a Safety Function Determination Program (TS 5.5.13),was already proposed in the original submittal.

3.0 TECHNICAL ANALYSISThe technical analyses provided in the originally submitted LAR 256 (Reference 1)remain applicable to, and unaltered by, this proposed change.

Serial No. 13-226BAttachment 2Page 2 of 3The existing TS Section 3.0, "Limiting Condition for Operation (LCO) Applicability,"

contains general requirements applicable to all specifications.

Because the KPS Part50 license no longer authorizes emplacement or retention of fuel in the reactor vessel,the general requirements that do not apply with the reactor in a defueled condition arebeing proposed for deletion.

Deletion of LCO 3.0.6 in its entirety was not proposed in the original submittal of LAR256 because the retained portion of LCO 3.0.6 would have been rendered moot.However, to prevent the potential for confusion regarding this specification, DEK isproposing to delete LCO 3.0.6 in its entirety.

LCO 3.0.6As discussed in the original submittal, LCO 3.0.6 establishes an exception to LCO 3.0.2for supported systems that have a support system LCO specified in the TS.Specification 5.5.13, "Safety Function Determination Program (SFDP),"

ensures loss ofsafety function is detected and appropriate actions are taken. Upon entry intoLCO 3.0.6, an evaluation is required to determine if a loss of safety function exists. TheSFDP implements the requirements of LCO 3.0.6.LCO 3.0.6 is being proposed for deletion in its entirety in the permanently defueled TSas shown in Attachment

3. Consistent with deletion of LCO 3.0.6, a reference to LCO3.0.6 that is contained in LCO 3.0.2 is also proposed for deletion.

The TS pagesprovided in Attachment 3 replace the originally provided TS Pages 3.0-1 and 3.0-2.Because 10 CFR 50.82(a)(2) prohibits operation of the plant or placing fuel in thereactor vessel, there is no longer a need for redundant safety systems.

Therefore, therequirements of the SFDP, which directs cross train checks of multiple and redundant safety systems, no longer apply. As discussed in Section 5.2 of LAR 256 (Applicable Regulatory Requirements/Criteria),

most of the design basis accidents and transients analyzed in USAR Chapter 14 are no longer applicable in the permanently defueledcondition.

After the termination of reactor operations at KPS and the permanent removal of the fuel from the reactor vessel (following 90 days of decay time aftershutdown),

none of the systems, structures, and components (SSCs) at KPS arerequired to be relied on for accident mitigation.

Therefore, none of the SSCs at KPSmeet the definition of a safety-related SSC stated in 10 CFR 50.2 (with the exception ofthe passive spent fuel pool structure).

There are no support and supported systems that remain in the proposed TS. As such,there is no longer need for a SFDP. Consequently, TS 5.5.13, SFDP, was proposed fordeletion in LAR 256 so as to eliminate the administrative burden of maintaining anunnecessary program.

Serial No. 13-226BAttachment 2Page 3 of 3Since the requirements of the SFDP contained in TS 5.5.13 no longer apply (asdescribed in Section T5.3 of LAR 256), the allowance provided by LCO 3.0.6 is also nolonger needed and is therefore being deleted consistent with the deletion of TS 5.5.13.4.0 SUMMARYThe allowance provided by LCO 3.0.6 is not needed for KPS which is in a permanently defueled condition.

As such, it may be deleted with no impact on continued safeoperation of the facility.

Therefore, deleting LCO 3.0.6 in KPS TS Section 3.0 is acceptable.

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.6.0 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. Email from Dr. Karl D. Feintuch (NRC) to Jack Gadzala and Craig Sly (DEK),"MF0996, MF1952 -Draft RAI items being processed to you," dated August 16,2013.

Serial No. 13-226BATTACHMENT 3SUPPLEMENT 1:LICENSE AMENDMENT REQUEST 256PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS MARKED UP TECHNICAL SPECIFICATIONS PAGES:TS 3.0 (page 3.0-2), "Limiting Condition for Operation (LCO) Applicability" KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.

LCO Applicability 3.03.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or othF r specified conditions in theApplicability, except as provided in LCO 3.0.2, LCO" 3.0.7, and LC, 3.0.B .LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of theassociated Conditions shall be met, except as provided in LCO 3.0.5-apA If the LCO is met or is no longer applicable prior to expiration of thespecified Completion Time(s),

completion of the Required Action(s) is notrequired unless otherwise stated.LCO 3.0.3 DeletedWhn an L CQ is not Met and the a..ociated ACTION.S are notmet, an ass9ocated ACTION is not provided, or if diroctod by theasSOciated

ACTIONS, the unit shall be placod in a MODE or etho6pecGie codiio in .-hc the LC i not applicablo.

Action shall besinitiatod Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable,in

a. MODE 3 withiR 7 b. MODE 4 within 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />si andG. MODE 5 within 37 hoEurs.&Excptions to this Specificationi aro stated in the individual Specifications.

Whore corroctiyo moasuros aro completod that permit operation in4accordance Wi:th the9 LCO- or ACTIONS, completion; Of the; atonAR requiredbyo LCO 3.0-3 IS not required-.

LCO 20- is only applicable in MODES 1, 2, 3, and-4-.I LCO 3.0.4When an LCO is not met, entry into a MODE er eth specified condition in the Applicability shall only be made:a. When the associated ACTIONS to be entered permit continued operation in the MODE (eF et specified condition in the Applicability for an unlimited period of time;b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE Or ether specified condition in the Applicability, and establishment of risk management

actions, ifappropriate; exceptions to this Specification are stated in theindividual Specifications; orc. When an allowance is stated in the individual value, parameter, orother Specification.

I Kewaunee Power Station3.0-1Amendment No. 2W97 LCO Applicability 3.03.0 LCO Applicability I=LC 3.0.4 (contitnued)

This Specification shall not prevent entry into MODES or othnr specified conditions in the Applicability that are required to comply with ACTIONSor that .ro part of a shutdoAn of the unt.LCO 3.0.5 Equipment removed from service or declared inoperable to comply withACTIONS may be returned to service under administrative control solelyto perform testing required to demonstrate its OPERABILITY or theOPERABILITY of other equipment.

This is an exception to LCO 3.0.2 forthe system returned to service under administrative control to perform thetesting required to demonstrate OPERABILITY.

, `3.6 When a suppo.ted system. .LC` is not mot 60191y due to a support systemLCO not boin me, heCoditions and Roquirod Actions associated withthis supported system are not required_

to be enterFed.

Only the supportsystem LGCO) ACr-TIO-NS are required to be entered.

T-his is an exception to LCOQ 3.0.2 for the supported system. In thiS eVent, an evaluation shallbe performned in accordance with Specification 5.5.13, "Safety FunctionDetermination Program (SFrDP)."

if a less of safety functio(n i detefrmined to exist by this program, the appropria-te odiin and Required ActionSof the LCO inWhich the los6 of safety fucinexi-sts are required to beWhen a support system's Required Action directs a SUPPorted system tobe declared inoperable or directs entry into Conditions6 and RequieActions for a supported system, the applicable Conditions6 and RequiredActionsr shall be entered in accordanc~e with LCOG 3.0.2.IGG 3.0.7Test Exception LCOG 3.1.8 allows specified Technical Specfification (T-S)requirem~ents to be changed to peFrmit performance of special tests andoperations.

Urless Ithet ile ,pecified, all ethr T-9 rvequ*rFeFment unchanged.

ompliane

,ith Test

, is optional.

W " A ,,hen aTest Exception C i des-ir-ed to be ,et butis not met.,

ofthe Test Exce9ption LCO shall be9 Me9t. When -A Tes9t E=xception LCO is not.desired to be mcet, entry intoe a MOD o ether specified condition in; theApplicability s~hall be Made in accorda~nce w~ith the other applicabl SpeG~fGat~eR&,

I Kewaunee Power Station3.0-2Amendment No. 2407