ML050380396

License Amendment Request 205a to the Kewaunee Nuclear Power Plant Technical Specifications (Ts), Change to Accumulator Completion Time and Deletions of Items from Table TS 4.1-1

ML050380396
Person / Time
Site:	Kewaunee
Issue date:	01/27/2005
From:	Lambert C Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-05-011
Download: ML050380396 (9)

Text

GoM Y

to Pimmftte Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC January 27, 2005 NRC-05-011 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 License Amendment Request 205a To The Kewaunee Nuclear Power Plant Technical Specifications, Change to Accumulator Completion Time and Deletions of Items from Table TS 4.1-1

References:

1) Letter from T Coutu (NMC) to Document Control Desk (NRC),

"LAR 205 to the Kewaunee Nuclear Power Plant Technical Specifications, Change to Accumulator Completion Time and Deletions of Items from Table TS 4.1-1," dated July 6, 2004.

2) Letter from CF Lyon (NRC) to T Coutu (NMC), "Kewaunee Nuclear Power Plant - Issuance of Amendment Re: Accumulator Completion Time (TAC NO. MC3771)," dated October 5,2004.

Pursuant to 10 CFR 50.90, the Nuclear Management Company, LLC, (NMC) is submitting this supplement to License Amendment Request (LAR) 205 to the Kewaunee Nuclear Power Plant (KNPP) Technical Specifications (TS). The LAR 205 originally deleted Table TS 4.1-1, Item 22, "Accumulator Level and Pressure," in its entirety.

However, the NMC wishes to retain the surveillance to perform a check each shift as listed in Table TS 4.1-1, Item 22. Therefore, this supplement will restore Table TS, Item 22, and relocate only its calibration requirements to plant procedures. This change does not affect the regulatory safety analysis or the environmental considerations evaluation submitted in reference 1.

The original LAR also proposed to extend the completion time in the KNPP TS 3.3.a.2.B and to relocate Table TS 4.1-1, Item 25, "Portable Radiation Survey Instruments," to the Technical Requirements Manual. The NRC issued a safety evaluation (SE) on October 5, 2004 (reference 2), approving the change to TS 3.3.a.2.B for the accumulator completion time. This supplemental LAR does not change any information related to the accumulator completion time that has already been approved or to the proposed change to portable radiation survey instruments that is currently under review.

N490 Highway 42 . Kewaunee, Wisconsin 54216-9511 Telephone: 920.388.2560

Document Control Desk Page 2 Enclosure I to this letter contains an evaluation of the proposed change to Table TS 4.1-1, Item 22. Enclosure 1 does not include a regulatory analysis nor an environmental considerations evaluation, as the original evaluations of LAR 205 remain unchanged. Enclosure 2 contains the marked up TS pages and Enclosure 3 contains the affected (revised) TS pages. Note that Table TS 4.1-1, page 4 of 7, is affected by LAR 204, which is currently on the docket.

No new commitments are made as a result of this supplemental LAR. Once approved, the amendment will be implemented within 60 days. If you have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424. A complete copy of this submittal has been transmitted to the State of Wisconsin as required by 10 CFR 50.91(b)(1).

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

Executed on January 27, 2005.

LamLAL4 Craig W. be Site Vice President, Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosures (3) cc: Administrator, Region l1l, USNRC Resident Inspector, Kewaunee, USNRC Project Manager, Kewaunee, USNRC Public Service Commission of Wisconsin

ENCLOSURE I NUCLEAR MANAGEMENT COMPANY, LLC, EVALUATION OF LICENSE AMENDMENT REQUEST 205a TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305

1.0 DESCRIPTION

The Nuclear Management Company (NMC), LLC, proposes to supplement a license amendment request (LAR) made to amend the Kewaunee Nuclear Power Plant (KNPP) operating license DPR-43, Appendix A, 'Technical Specifications." The LAR 205 (reference 1) originally deleted Technical Specification (TS) Table TS 4.1-1, Item 22, "Accumulator Level and Pressure," in its entirety. However, the NMC wishes to retain the surveillance to perform a check each shift as listed in Table TS 4.1-1, Item 22.

Therefore, this supplemental LAR (LAR 205a) will restore Item 22 and relocate only the 18 month calibration listed in Table TS 4.1-1, Item 22, "Accumulator Level and Pressure," from the TS to plant procedures. This change does not affect the outcome of the regulatory safety analysis or the environmental considerations submitted in reference 1.

The original LAR also proposed to extend the accumulator completion time in the KNPP TS 3.3.a.2.B and to relocate Table TS 4.1-1, Item 25, 'Portable Radiation Survey Instruments." The NRC issued a safety evaluation (SE) on October 5, 2004 (reference 2), approving the change to TS 3.3.a.2.B for the accumulator completion time. This supplemental LAR does not change any information related to the approved accumulator completion time that has already been approved and also does not change any information related to the portable radiation survey instrument change that is currently under NRC review.

2.0 PROPOSED CHANGE

The following change is proposed in this supplemental LAR. The marked up and the affected TS page showing the proposed change are located in Enclosures 2 and 3, respectively.

1. Restore Table TS 4.1-1, Item 22, "Accumulator Level and Pressure," in its entirety. Delete only the calibration requirement from Table TS 4.1-1, Item 22, "Accumulator Level and Pressure." The calibration requirement will be relocated to plant procedures.

3.0 BACKGROUND

In December 1992, the NRC completed a comprehensive examination of surveillance requirements in TS that require testing during power operation. The effort was part of the NRC Technical Specification Improvement Program (TSIP). The results were reported in NUREG-1 366, "Improvements to Technical Specification Surveillance Requirements," (reference 3). On September 27, 1993, the NRC issued Generic Letter (GL) 93-05, 'Line-Item Technical Specification Improvements to Reduce Surveillance Requirements for Testing During Power Operation," (reference 4). This correspondence provided licensees with guidance for implementing the recommendations of NUREG-1366.

Page 1 of 3

In the reference 1 submittal, the NMC removed the entire contents of Table TS 4.1-1, Item 22. However, after further review of the GL 93-05, the NMC recognized that the checks performed each shift as required by this TS line item should have been retained.

The checks each shift are used to confirm accumulator operability. Generic Letter 93-05 specifically stated that the only surveillance that should be retained is that required to confirm that the parameters defining accumulator operability are within their specified limits. Additionally, the GL text describes removing the analog channel operational test and channel calibrations from TS to existing plant procedures. Therefore, the NMC proposes to restore Item 22 of Table TS 4.1-1 and relocate only the calibration requirements. There is no analog channel operational test specified in KNPP TS. The relocation of the calibration requirements of Table TS 4.1-1, Item 22, "Accumulator Level and Pressure," to plant procedures is consistent with and implements the recommendations of GL 93-05.

4.0 TECHNICAL ANALYSIS

This change relocates the accumulator water level and pressure calibrations from TSs to plant procedures. This change is consistent with industry recognition that accumulator instrumentation operability is not directly related to the capability of the accumulators to perform their safety function. This proposed change implements GL 93-05, Item 7.4, "Accumulator Water Level and Pressure Channel Surveillance Requirements (PWR)."

5.0 REGULATORY SAFETY ANALYSIS This proposed change does not affect the original regulatory safety analysis submitted in reference 1. Please refer to the original regulatory safety analysis in reference 1.

6.0 ENVIRONMENTAL CONSIDERATION

S This proposed change does not affect the original environmental considerations review submitted in reference 1. Please refer to the original environmental considerations review in reference 1.

7.0 REFERENCES

1. Letter to Document Control Desk (NRC) from T Coutu (NMC), "LAR 205 to the Kewaunee Nuclear Power Plant Technical Specifications, Change to Accumulator Completion Time and Deletions of Items from Table TS 4.1-1,"

dated July 6, 2004.

2. Letter from CF Lyon (NRC) to T Coutu (NMC), "Kewaunee Nuclear Power Plant-Issuance of Amendment Re: Accumulator Completion Time (TAC NO. MC3771)," dated October 5, 2004.

3. NUREG-1366, "Improvements to Technical specification Surveillance Requirements," dated December 1992.

Page 2 of 3

4. Generic Letter (GL) 93-05, "Line-item Technical Specification Improvements to Reduce Surveillance Requirements for Testing During Power Operation," dated September 27, 1993.

Page 3 of 3

ENCLOSURE 2 NUCLEAR MANAGEMENT COMPANY, LLC, MARKED UP TS PAGES FOR LICENSE AMENDMENT REQUEST 205a TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305 Marked Up TS Pages:

Table TS 4.1-1, Page 4 of 7 I page follows

TABLE TS 4.1-1 MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS CHANNEL DESCRIPTION CHECK CALIBRATE TEST REMARKS

18. a. Containment Each shift Each refueling cycle Monthly(a) (a) Isolation Valve Signal Pressure (SIS signal)

b. Containment Each shift(a) Each refueling cycle(a) Monthly(a) (a) Narrow range containment pressure Pressure (-3.0, +3.0 psig excuded)

(Steamline Isolation) __3_0__ _3_0___ _ __ __ _ __ __ _

c. Containment Each shift Each refueling cycle Monthly Pressure (Containment Spray Act) _

d. Annulus Pressure Not applicable Each refueling cycle Each refueling (Vacuum Breaker) cycle

19. Radiation Monitoring Daily (a,b) Each refueling cycle (a) Quarterly (a) (a) Includes only channels R1 1 thru R1 5, R1 9, System R21, and R23 l_ . (b) Channel check required in all plant modes

20. Deleted

21. Containment Sump Level Not applicable Not applicable Each refueling l_ cycle

22. Accumulator Level and Each shift EaGh refueling Not applicable Pressure GyleDleted__

23. Steam Generator Each shift Each refueling cycle Monthly Pressure Amendment No. 151LAR 205a I Page 4 of 7 02412/2004

ENCLOSURE 3 NUCLEAR MANAGEMENT COMPANY, LLC, AFFECTED TS PAGES FOR LICENSE AMENDMENT REQUEST 205a TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305 Affected TS Pages:

Table TS 4.1-1, Page 4 of 7 I page follows

. hi TABLE TS 4.1-1 MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS CHANNEL DESCRIPTION CHECK CALIBRATE TEST REMARKS 3

18. a. Containment Each shift Each refueling cycle Monthly(a) (a) Isolation Valve Signal Pressure (SIS signal) l

b. Containment Each shift(a) Each refueling cycle(a) Monthly(a) (a) Narrow range containment pressure Pressure (-3.0, +3.0 psig excluded)

(Steamline Isolation) l

c. Containment Each shift Each refueling cycle Monthly Pressure (Containment Spray Act) . .

d. Annulus Pressure Not applicable Each refueling cycle Each refueling (Vacuum Breaker) cycle

19. Radiation Monitoring Daily (a,b) Each refueling cycle (a) Quarterly (a) (a) Includes only channels R11 thru R15, R19, System R21, and R23 (b) Channel check required in all plant modes

20. Deleted

21. Containment Sump Level Not applicable Not applicable Each refueling cycle

22. Accumulator Level and Each shift Deleted Not applicable Pressure I

23. Steam Generator Each shift Each refueling cycle Monthly Pressure Page 4 of 7 I