Text

Response to Request for Additional Information Related to License Amendment Request 197 to the Kewaunee Nuclear Power Plant Technical Specifications
	ML041480158
Person / Time
Site:	Kewaunee
Issue date:	05/18/2004
From:	Coutu T; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-04-061, TAC MB9944
	Download: ML041480158 (11)
	v • d • e

NuEl Kewaunee Nuclear Power Plant Committed to Nuclear Excess~ Operated by Nuclear Management Company, LLC May 18, 2004 NRC-04-061 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Kewaunee Nuclear Power Plant Docket 50-305 License No. DPR-43 Response To Request For Additional Information Related To License Amendment Request 197 To The Kewaunee Nuclear Power Plant Technical Specifications References 1) Letter from Thomas Coutu (NMC) to Document Control Deck (NRC),

'License Amendment Request 197 To The Kewaunee Nuclear Power Plant Technical Specifications, 3.3.e, Service Water System", dated July 7, 2003.

2) Letter from John G. Lamb, (NRC) to Thomas Coutu (NMC),

"Kewaunee Nuclear Power Plant - Request For Additional Information For Proposed Amendment Request to Revise Technical Specification 3.3.E, "Service Water System" (TAC NO. MB9944)," dated January 21, 2004.

During a phone conference on April 5,2004, the Nuclear Regulatory Commission (NRC) staff requested clarifying changes to the Technical Specifications (TS) submitted in Reference 1. This letter is NMC's response to the NRC's requested changes.

Enclosure I contains the agreed upon changes to Technical Specification pages: TS 3.3-7 and TS 3.3-8. Enclosure 2 contains the marked up Technical Specification pages as revised: TS 3.3-7 and TS 3.3-8. Enclosure 3 contains the affected Technical Specification pages as revised: TS 3.3-7 and TS 3.3-8.

N490 Highway 42

Kewaunee, Wisconsin 54216-9511 Telephone: 920.388.2562 Jyc5DI

Docket 50-305 NRC-04-061 May 18, 2004 Page 2 As the response does not alter the conclusions reached in NMC's reference 1 submittal, the safety analysis, significant hazards determination, and the environmental considerations statements contained in reference 1 are still applicable and support the changes contained herein. This submittal contains no new commitments.

NMC requests approval of this license amendment request in accordance with the date specified in reference 1. If you have any questions concerning this submittal please contact Mr. Ted Maloney at (920) 388-8863.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 18, 2004.

Thomas Coutu Site Vice-President, Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosures (3) cc: Administrator, Region l1l, USNRC Project Manager, Kewaunee Nuclear Power Plant, USNRC Senior Resident Inspector, Kewaunee Nuclear Power Plant, USNRC Electric Division, PSCW

ENCLOSURE 1 NUCLEAR MANAGEMENT COMPANY, LLC, LATEST REVISIONS TO TS FOR LICENSE AMENDMENT REQUEST 197 TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305 Latest Revisions to Submitted TS Pages:

TS 3.3-7 TS 3.3-8 2 Pages to Follow

e. Service Water System

1. The reactor shall not be made critical unless the following conditions are satisfied, except for LOW POWER PHYSICS TESTS and except as provided by TS 3.3.e.2.

A. TWO service water trains are OPERABLE with each train consisting of:

1. TWO service water pumps

2. An OPERABLE flow path consisting of all valves and piping associated with the above train of components and required to function during accident conditions. This flow path shall be capable of taking a suction from the forebay and supplying water to the redundant safeguards headers.

B. The Forebay Water Level Trip System is OPERABLE.

2. During power operation or recovery from an inadvertent trip, ONE service water train may be inoperable for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If OPERABILITY is not restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to:

- Achieve HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

- Achieve and maintain Reactor Coolant System Tavg less than 3500 F by use of alternate heat removal methods within an additional 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

3. Turbine Building Service Water Header Isolation Logic is only required to function for the service water train aligned to the turbine building header during a design basis accident. Therefore, the operability of the service water train not aligned to the turbine building header is independent of the operability of the isolation logic.

A. IF one train of Isolation Logic is inoperable and the affected train of service water is NOT aligned to the turbine building header, the following action shall be taken:

1. Administratively control the alignment of the service water train to prevent its alignment to the turbine building header.

B. IF one train of Isolation Logic is inoperable and the affected train of service water is aligned to the turbine building header, the following action shall be taken immediately:

1. Declare that train of Service Water inoperable, and The following actions shall be comploted within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s:

fip-. Align the opposite train of service water to the turbine building header, or l2-T Restore the Isolation Logic train to OPERABLE status.

LAR 197 TS 3.3-7 05/18/2004

C. If two trains of Isolation Logic are declared inoperable, the following actions shall be taken immediately:

1. An otherwise OPERABLE train of service water shall be de-selected as the supply for the turbine building header, and

2. Declare the train of service water aligned to the turbine building header inoperable-.and Tho following actions shall be cempleted within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s:

Ho4-. One train of Isolation Logic shall be restored to OPERABLE status, and fijl-j An OPERABLE train of service water with an OPERABLE train of Isolation Logic shall be aligned to the turbine building header.

D. If Valve SW-4A or SW-4B is inoperable and open, declare the associated train of service water inoperable and complete the following restore the inoperable valve to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s-.

1. Align the opposite train of service water to the turbine building header, or

2. Restoro the inoperable valve to OPERABLE status.

E. If both SW-4A and SW-4B are inoperable, perform the following:

1. Declare the service water train with the open valve inoperable, and

2. Restore one valve to OPERABLE status and open it within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Clos the INOPERABLE valve.

F. If the conditions described in A, B, C, D, and E cannot be met, commence Plant Shutdown in accordance with TS 3.3.e.2.

LAR 197 TS 3.3-8 05/18/2004

ENCLOSURE 2 NUCLEAR MANAGEMENT COMPANY, LLC, MARKED UP TS PAGES FOR LICENSE AMENDMENT REQUEST 197 TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305 Marked Up TS Pages:

TS 3.3-7 TS 3.3-8 2 Pages to Follow

e. Service Water System

1. The reactor shall not be made critical unless the following conditions are satisfied, except for LOW POWER PHYSICS TESTS and except as provided by TS 3.3.e.2.

A. TWO service water trains are OPERABLE with each train consisting of:

1. TWO service water pumps

2. An OPERABLE flow path consisting of all valves and piping associated with the above train of components and required to function during accident conditions. This flow path shall be capable of taking a suction from the forebay and supplying water to the redundant safeguards headers.

B. The Forebay Water Level Trip System is OPERABLE.

2. During power operation or recovery from an inadvertent trip, ONE service water train may be inoperable for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If OPERABILITY is not restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to:

- Achieve HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

- Achieve and maintain Reactor Coolant System Tavg less than 3500 F by use of alternate heat removal methods within an additional 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

3. Turbine Building Service Water Header Isolation is only required to function for the service water train aligned to the turbine building header during a design basis accident. Therefore, the operability of the service water train not aligned to the turbine building header is independent of the operability of the isolation logic.

A. IF one train of Isolation Logic is inoperable and the affected train of service water is NOT aligned to the turbine building header, the following action shall be taken:

1. Administratively control the alignment of the service water train to prevent its alignment to the turbine building header.

B. IF one train of Isolation Logic is inoperable and the affected train of service water is aligned to the turbine building header, the following action shall be taken immediately:

1. Declare that train of Service Water inoperable, and within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s:

(i) Align the opposite train of service water to the turbine building header. or (ii) Restore the Isolation Logic train to OPERABLE status.

LAR 197 TS 3.3-7 05/21/2004

C. If two trains of Isolation Logic are declared inoperable, the following actions shall be taken immediately:

1. An otherwise OPERABLE train of service water shall be de-selected as the supply for the turbine building header. and

2. Declare the train of service water aligned to the turbine building header inoperable and within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s:

(i) One train of Isolation Logic shall be restored to OPERABLE status, and (iGOAn OPERABLE train of service water with an OPERABLE train of Isolation Logic shall be aligned to the turbine building header.

D. If Valve SW-4A or SW-4B is inoperable and open. declare the associated train of service water inoperable and restore the inoperable valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , E. If both SW-4A and SW-4B are inoperable, perform the following:

1. Declare the service water train with the open valve inoperable, and

2. Restore one valve to OPERABLE status and open it within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Close the INOPERABLE valve.

F. If the conditions described in A, B. C, D, and E cannot be met. commence Plant Shutdown in accordance with TS 3.3.e.2.

LAR 197 TS 3.3-8 05/21/2004

ENCLOSURE 3 NUCLEAR MANAGEMENT COMPANY, LLC, AFFECTED TS PAGES FOR LICENSE AMENDMENT REQUEST 197 TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305 Affected TS Pages: