ML101380399

License Amendment Request 249: Conversion to Improved Technical Specifications (TAC No. ME02467) - Request to Change Proposed Service Water and Main Steam Isolation Valve Specifications

ML101380399
Person / Time
Site:	Kewaunee
Issue date:	05/12/2010
From:	Price J Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME02467
Download: ML101380399 (24)

Text

JFDo~i niio Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 May 12, 2010 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Serial No. 09-491C LIC/GOR/RO Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST 249:

KEWAUNEE POWER STATION CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS (TAC NO. ME02467)

REQUEST TO CHANGE PROPOSED SERVICE WATER AND MAIN STEAM ISOLATION VALVE SPECIFICATIONS Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (Kewaunee) (reference 1). This amendment request would revise Kewaunee's current Technical Specifications (CTS) to Improved Technical Specifications (ITS) consistent with the Improved Standard Technical Specifications (ISTS) described in NUREG 1431, "Standard Technical Specifications - Westinghouse Plants," Revision 3.0.

This supplemental letter requests changes to the proposed Technical Specifications 3.7.8, "Service Water (SW) System," and 3.7.2, "Main Steam Isolation Valves (MSIVs)."

The requested supplemental change to proposed Technical Specification 3.7.8, "Service Water (SW) System," adds the word "necessarily" to the Note contained in proposed surveillance requirement (SR) 3.7.8.1. The proposed SR 3.7.8.1 Note states; "Isolation of SW System flow to individual components does not render the SW System inoperable." DEK proposes to modify this proposed SR Note to state; "Isolation of SW System flow to individual components does not necessarily render the SW System inoperable."

The requested supplemental change to proposed Technical Specification 3.7.2, "Main Steam Isolation Valves (MSIVs)," revises the Note associated with proposed SR 3.7.2.1. The proposed SR requires verification that each MSIV isolation time is within limits while the Note states that the verification is only required to be performed in Modes 1 and 2. DEK proposes to change the Note to state that the verification of MSIV isolation time is; "Not required to be performed in Modes 2 and 3 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are open." of this letter contains a discussion and justification for these proposed changes. Attachment 2 contains the proposed changes to the Discussion of Changes (DOCs), proposed Technical Specification changes, and Justification for Deviations A-oi/

Serial No. 09-491C Page 2 of 4 (JFDs) as submitted in Reference 1. These chalnges will be reflected in the supplement to this section of the ITS conversion amendment!.

Dominion continues to request approval ofi the proposed amendment and an implementation period as stated in Reference 11. In addition, the changes proposed in this supplement do not alter the conclusions of the no significant hazards consideration determination contained in Reference 1.

A copy of this supplement has been provided to the State of Wisconsin in accordance with 10 CFR 50.91(b).

If you have any questions or require additional information, please contact Mr. Gerald 0. Riste at (920) 388-8424.

Very truly yours, J. An rice Vic,-'esident - Nuclear Engineering VICKI L. HULL COMMONWEALTH OF VIRGINIA

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My Commission Expires May 31. 2014 COUNTY OF HENRICO h

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. Alan Price, who is Vice President - Nuclear Engineering of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoin'g document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this !

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ý-4 2010.

My Commission expires:A,,z&

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Serial No. 09-491C Page 3 of 4 Attachments

1. Evaluation of Proposed Change

2. Modified. Discussion of Changes (DOCs), Proposed Technical Specifications, and Justification for Deviations (JFDs)

Reference

1. Letter from Leslie N. Hartz (DEK) to Document Control Desk (NRC), "License

, Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications (TAC NO. ME02467)," dated August 24, 2009. [ADAMS Accession No's ML092440371, ML092440416 through ML092440435, and ML092440441]

Commitments made by this letter: None

Serial No. 09-491C Page 4 of 4 cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. P. S. Tam Sr. Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. V. G. Cusumano NRC KPS ITS Conversion Lead U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-7 C2A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 09-491C ATTACHMENT 1 LICENSE AMENDMENT REQUEST 249: KEWAUNEE POWER STATION CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS (TAC NO. ME02467)

- REQUEST TO CHANGE PROPOSED SERVICE WATER AND MAIN STEAM ISOLATION VALVE SPECIFICATIONS EVALUATION OF PROPOSED CHANGE KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 09-491C Docket No. 50-305 Page 1 of 9 Table of Contents 1.0 S U M M A RY D ESC R IPTIO N..........................................

I...........................................

2-2.0 DETAILED DESCRIPTION.........................................

2 2.1 D etailed D escription.......................................................................................

2 2.2 Condition Intended to Resolve.....................................................................

2 2.2.1 Specification 3.7.8, Service Water System.............................................

2 2.2.2 Specification 3.7.2, Main Steam Isolation Valves.....................................

3

3.0 TECHNICAL EVALUATION

4 3.1 Specification 3.7.8, Service Water System....................................................

4 3.1.1 Service Water System Description.........................................................

4 3.1.2 C urrent Licensing Basis..........................................................................

4 3.1.3 Technical A nalysis...................................................................................

4 3.2 Specification 3.7.2, Main Steam Isolation Valves............................................

7 3.1.1 Main Steam System Description.............................................................

7 3.1.2 Current Licensing Basis....................................

7 3.1.3 Technical A nalysis...................................................................................

7

4.0 REGULATORY EVALUATION

9

5.0 REFERENCES

9

Serial No. 09-491C Docket No. 50-305 Page 2 of 9 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating License DRP-43 for the Kewaunee Power Station (Kewaunee).

Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee (reference 1).

This amehdment request would revise Kewaunee's current Technical Specifications (CTS) to Improved Technical Specifications (ITS) consistent with the Improved Standard Technical Specifications (ISTS) described in NUREG 1431, "Standard Technical Specifications - Westinghouse Plants," Revision 3.0.

2.0 DETAILED DESCRIPTION This supplement requests changes to the proposed ITS 3.7.8, "Service Water (SW)

System," and 3.7.2, "Main Steam Isolation Valves (MSIVs)."

2.1 Detailed Description The requested change to proposed ITS 3.7.8, "Service Water (SW) System," adds the word "necessarily" to a Note contained in proposed Surveillance Requirement (SR) 3.7.8.1.

Proposed SR 3.7.8.1 Note states: "Isolation of SW System flow to individual components does not render the SW System inoperable." DEK proposes to modify this proposed SR Note to state; "Isolation of SW System flow to individual components does not necessarily render the SW System inoperable."

The requested change to proposed ITS 3.7.2, "Main Steam Isolation Valves (MSIVs),"

revises the Note associated with proposed SR 3.7.2.1.

The proposed SR requires verification that each MSIV isolation time is within limits while the Note states that the verification is; "Only required to be performed in Modes 1 and 2." DEK is proposing to change the Note to state that the verification of MSIV isolation time is; "Not required to be performed in Modes 2 and 3 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are open."

2.2 Condition Intended to Resolve 2.2.1 Specification 3.7.8, Service Water System Some components at Kewaunee require cooling or ventilation in order to perform their function. For example, pumps may require cooling water to prevent overheating and rooms housing equipment may require ventilation to maintain the room environmental conditions within the design basis of the equipment. If a cooling or ventilation system cannot perform its related support function due to some type of failure or due to intentional removal from service to perform surveillances or maintenance, the supported system may become inoperable under the definition of OPERABILITY.

If it is determined that the loss of cooling or ventilation renders the supported system

Serial No. 09-491C Docket No. 50-305 Page 3 of 9 inoperable, the appropriate Limiting Condition for Operation (LCO) Action is entered and the applicable required actions and completion times are followed.

While reviewing Kewaunee's License Amendment Request (LAR) 249 (reference 1) an undesirable condition was discovered. This undesirable condition occurs if an area fan coil unit (AFCU) is discovered or rendered unable to perform its support function for the 480 volt engineered safety feature (ESF) buses or battery room equipment. If one of these AFCUs are non-functional the minimum completion time allowed under the proposed ITS specification is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (refer to ITS 3.8.7 Condition B and ITS 3.8.9 Conditions A, B, and C). Because repairs of non-functional AFCUs are estimated to be greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, a plant shutdown would be required (e.g., ITS LCO 3.8.9, Condition A).

Inserting "necessarily" in the Note for proposed ITS SR 3.7.8.1 makes another option available.

If SW System flow is isolated to an individual component, the SW train servicing the component is declared inoperable and proposed ITS LCO 3.7.8 ACTION A entered. ITS LCO Condition A required action and completion time allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore an inoperable SW train. The second option would be to declare the individual component (e.g., a DC electrical power distribution system) inoperable and follow its associated ACTIONS (e.g., proposed ITS LCO 3.8.9, Condition C, which is a 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> completion time) entered without declaring the SW System inoperable. Thus, instead of allowing a maximum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to return an AFCU to service before commencing a plant shutdown, as much as 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> would be allowed if the SW system was declared inoperable.

2.2.2 Specification 3.7.2, Main Steam.Isolation Valves Kewaunee's Main Steam System directs steam in a 30-inch pipe from each of the two steam generators within the reactor containment through a swing-disc type isolation valve (main steam isolation valve) and a swing-disc type non-return valve to the turbine stop and control valves. When the reactor is not critical, these valves are normally closed to reduce the heat loss of maintaining the secondary system pressurized.

Current Kewaunee TS (CTS) do not have a specification for the main steam isolation valves (MSIVs) but do have specifications for the MSIV isolation circuit and for valve isolation timing. The MSIV isolation circuit is required to be operable [CTS Table TS 3.5-4, Function 2] when reactor coolant system temperature is greater than 200°F (equivalent to ITS Modes 1, 2, 3, and 4) and the MSIVs are required to close in -< 5 seconds [CTS 4.7]. The MSIV isolation circuit minimum operable channel requirements are modified by a Note, which states; "Steam Line Isolation channels are not required to be operable when both main steam isolation valves are closed and deactivated." To ensure the isolation time testing of the MSIVs is performed under operating conditions the isolation time testing is performed at the highest operating temperature of the secondary system, CTS Hot Shutdown mode (RCS Tavg 540'F to 5470F, reactor critical). The currently proposed ITS SR 3.7.2.1 Note states; "Only required to be performed in Modes 1 and 2." If Kewaunee were to adopt the currently proposed ITS

Serial No. 09-491C Docket No. 50-305 Page 4 of 9 for the MSIVs [ITS 3.7.2] the MSIV isolation time test could not be performed in the same manner.

DEK is proposing to modify the currently proposed ITS surveillance requirement (SR) 3.7.2.1 Note to allow up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are opened to perform the MSIV isolation timing test. The currently proposed ITS SR states; "Verify the isolation'time of each MSIV is within limits," and the associated Note states; "Only required to be performed in Modes 1 and 2." The proposed SR 3.7.2.1 and its associated Note would require the currently proposed SR to be performed before the reactor is critical.

Kewaunee routinely requires the reactor to be critical to provide enough heat to equalize the pressure across the MSIVs and allow them to be opened. This is because these valves are reverse seating swing check valves, air assisted to open and lift the discs above the steam flowpath. With a large differential pressure across the swing disc, the air assist cannot open the valve. Thus, to perform the isolation-timing test the MSIV needs to be opened, and to open the valves the reactor needs to be critical, but the valves cannot be opened because the SR needs to be performed before the reactor can be brought critical. In other words, these are mutually exclusive conditions.

DEK is proposing to modify the currently proposed ITS SR 3.7.2.1 Note to state that the SR is; "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are open" This modification will allow DEK to open the MSIV when the reactor is critical and < 5% RTP, and then perform the isolation timing test.

3.0 TECHNICAL EVALUATION

3.1 Specification 3.7.8, Service Water System 3.1.1 Service Water System Description The Kewaunee Service Water System is described in the Basis section of proposed ITS LCO 3.7.8 contained in Reference 1.

3.1.2 Current Licensing Basis The current licensing basis and associated acceptance criteria for the Kewaunee Service Water System are described in the Basis section of proposed ITS LCO 3.7.8 contained in Reference 1.

3.1.3 Technical Analysis Kewaunee's Current Technical Specification (CTS) for the Service Water System is TS 3.3.e, "Service Water."

CTS 3.3.e requires, in part, that the reactor shall not be made critical, except for low power physics testing, without two service water trains operable.

If, during reactor critical operations, one train of service water is made or found inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restore the inoperable train prior to taking action to shutdown the reactor.

Because the area fan coil units (AFCUs) receive

Serial No. 09-491C Docket No. 50-305 Page 5 of 9 cooling water from the service water system, their ability to perform their function must be evaluated and the operability of CTS required equipment that is supported by the AFCUs must be determined.

If it is determined that AFCUs with a degraded or inoperable service water train cannot perform their support function for CTS-required equipment, then the CTS-required equipment must be declared inoperable and the appropriate CTS LCO Action is entered.

This support/ supported determination is made in accordance with CTS 1.0.e, "Operable-Operability."

Under NUREG 1431, Standard Technical Specifications - Westinghouse Plants, Revision 3.0 (reference 2) (ISTS), LCO 3.7.8 Condition A, if one SW System train is inoperable, action must be taken to restore the SW train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE SW system train is adequate to perform the post-accident heat removal function. However, overall reliability is reduced because a single failure in the OPERABLE SW system train could result in loss of SW system function. Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources -

Operating," should be entered if an inoperable SW system train results in an inoperable emergency diesel generator. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," should be entered if an inoperable SW system -train results in an inoperable decay heat removal train. This is an exception to ISTS LCO 3.0.6 and ensures the proper actions are taken for these components.

The 72-hour Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this period.

ISTS LCO 3.0.6 establishes an exception to ISTS LCO 3.0.2 [Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6] for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. The basis for ISTS LCO 3.0.6 states that this exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions. Thus, the design of ISTS is that the Required Actions and associated Completion Times of the directly affected SSCs are prescribed considering the indirect effects of the supported SSCs.

Additionally, the ISTS LCO 3.0.6 Bases state that when a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required

Serial No. 09-491C Docket No. 50-305 Page 6 of 9 Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.

This modification of the proposed ITS SR 3.7.8.1 Note follows this same philosophy.

Consider a condition where a Service Water System train is degraded to a point where the train is declared inoperable. The proposed ITS LCO 3.7.8 Condition A would be entered with a Required Action of, "Restore SW system train to OPERABLE status,"

within a Completion Time of "72 Hours".

The SSCs that the inoperable SW train supports would be declared inoperable. However, only the Conditions and Required Actions of the supported systems listed in the Notes contained in ITS LOC 3.7.8, Required Action a.1 would be entered. Specifically in this case the following Conditions and Required Actions would be entered: LCO 3.8.1, "AC Sources - Operating," for the emergency diesel generator made inoperable by the loss of SW and LCO 3.4.6, "RCS Loops - MODE 4," for residual heat removal loops made inoperable by the loss of SW.

Under this proposed modification, degradation of the AFCU could lead to declaring the associated SW train inoperable with the same actions followed.

ISTS SR 3.7.8.1 includes a Note that states; "Isolation of SW System flow to individual components does not render the SW System inoperable." This Note implies that if the individual component is isolated from SW flow, then the SW System cannot be declared inoperableý and the associated ACTIONS of ISTS 3.7.8 do not need to be taken.

However, this Note should not preclude declaring the SW System inoperable if the SR is not met.

Therefore,. the Note has been modified in ITS SR 3.7.8.1 to add the amplifying word "necessarily." This allows the SW System to be declared inoperable when SW System flow to a component is isolated. Thus, if SW System flow is isolated to an individual component, either the SW System is declared inoperable and ITS 3.7.8 Condition A entered, or the individual component is declared inoperable (i.e., the SW System train is not declared inoperable in this case) and its associated ITS Conditions entered.

Under the proposed modification to proposed ITS SR 3.7.8.1 Note, the option to declare the Service Water train inoperable maintains safety of the plant by requiring entry into ITS LCO 3.7.8, Condition A. ITS LCO 3.7.8, Condition A envelopes a plant condition where an entire SW train is inoperable. With an entire SW train inoperable, the AFCUs in question also cannot perform their support functions (i.e., no cooling water). Thus a Condition, Required Action, and associated Completion Time, for an entire inoperable SW train bounds the condition where an individual component Supported by the SW train is degraded or inoperable/non-functional.

In addition, when a degraded or non-functional AFCU results in declaration of an inoperable SW train, the proposed ITS LCO 3.0.6 requires that an evaluation be performed in accordance with Specification ITS 5.5.13 "Safety Function Determination Program (SFDP)." Subsequently, if a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

Serial No. 09-491C Docket No. 50-305 Page 7 of 9 3.2 Specification 3.7.2, Main Steam Isolation Valves 3.1.1 Main Steam System Description The Main Steam System is described in the Basisrsection of proposed ITS LCO 3.7.2 contained in Reference 1.

3.1.2 Current Licensing Basis The current licensing basis and current licensing basis acceptance criteria for the Kewaunee Main Steam Isolation Valves (MSIVs) are described in the Bases section of proposed ITS LCO 3.7.2 contained in Reference 1.

3.1.3 Technical Analysis Kewaunee's Current Technical Specification (CTS) 4.7 states that the MSIVs shall be tested once per operating cycle to verify a closure time of 5 seconds or less. The proposed conversion to Improved Technical Specifications (ITS) SR 3.7.2.1 (reference

1) requires a similar test, but a Note modifying ITS SR 3.7.2.1 states that the SR is only required to be performed in MODES 1 and 2.

This changes the CTS by allowing operation in MODE 3 without performing the Surveillance Requirement.

DEK is proposing to modify the proposed ITS SR 3.7.2.1 Note submitted in Reference 1 to require SR 3.7.2.1 to have been performed in Mode 1 and within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are opened in Modes 2 and 3.

The purpose of CTS 4.7 is to demonstrate that the closure time of each MSIV is within the limits assumed in the containment and accident analyses.

This test is normally conducted in MODE 2 with the unit at operating temperature and pressure. Addition of the NOTE modifying the Surveillance Requirement allows a delay in testing until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are opened in Modes 2 or 3, to establish conditions consistent with those for which the acceptance criterion was generated. The limitations contained in the Note also prevent operating in Mode 1 without a current MSIVs isolation time test.

ISTS SR 3.7.2.1 (reference 2) includes a Note that allows entry into MODE 3 without the SR being performed. This would allow performance of the SR at temperatures and pressures closer to operating temperature and pressure. Normally, the isolation time test is performed while shutting down the plant. However, if maintenance is performed on the MSIVs while shutdown, the test needs to be re-performed sometime during the startup. Following maintenance, the MSIVs are stroked prior to entering MODE 4 to ensure they will close, if required. However, the actual isolation time test of record is not performed until MODE 2.

At Kewaunee, historical performance indicates that the steam lines cannot be kept warm with the MSIVs open in MODE 3 due to limited RCS heat inputs and secondary side heat losses. Thus, the MSIVs are normally kept closed (after the initial stroke test) in MODE 3 and in MODE 2 until after the unit is critical and physics tests are complete.

Serial No. 09-491C Docket No. 50-305 Page 8 of 9 At that time, the MSIVs are opened and the isolation time test is performed. Therefore, Kewaunee is proposing to change the Note to state; "Not required to be performed in MODES 2 and 3 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are open."

This proposed Note will allow entry into both MODES 2 and 3, provided the MSIVs are closed. Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after opening the MSIVs in either MODE 2 or 3, performance of SR 3.7.2.1 will be required. This 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit minimizes the time the MSIVs are open in both MODES 2 and 3 without the SR being performed while allowing a reasonable amount of time to perform the SR, if required. The Note does not discuss any exception to MODE 1, thus ITS SR 3.7.2.1 is required to be performed prior to entry into MODE 1 consistent with the ISTS Note. Furthermore, if the unit is started up with the MSIVs open (although not normally done), the SR must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 3. The modified Note is more restrictive than the ISTS Note, since it has no time limit to perform the SR after entering MODE 3.

This change is considered acceptable because the MSIVs must remain closed to use the allowance beyond the initial 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entry into Mode 3. ITS LCO 3.7.2 does not require the MSIVs to be OPERABLE in MODES 2 and 3 if they are closed and deactivated. While the MSIVs are not required to be deactivated in the Note, the MSIVs are closed and their operation is controlled by plant procedures. In addition, although not required to be deactivated, opening of the MSIVs requires a deliberate act by the operators to equalize the pressure across these reverse seated swing check valves.

Additionally, ITS section 1.0 discusses the difference in the use of the terms "perform" and "met". It states, "Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction. The use of "met" or "performed" in these instances conveys specific meanings. A Surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met."

"Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria."

Thus, DEK proposal to modify the Note for SR 3.7.2.1 is acceptable because:

1. If no maintenance is to be performed on the MSIV, the isolation time test is performed within its prescribed frequency and the MSIV is operable,

2. If maintenance has been performed on the MSIV, the MSIV is stroked prior to entering Mode 3 and the MSIV is considered operable (SR met) when opened.

However, ITS SR 3.7.2.1 must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of opening the MSIV in order to maintain operability of the MSIV.

Serial No. 09-491C Docket No. 50-305 Page 9 of 9

4.0 REGULATORY EVALUATION

The regulatory evaluation for this proposed change is contained in Reference 1.

5.0 REFERENCES

1. Letter from Leslie N. Hartz (DEK) to Document Control Desk (NRC), "License Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications (TAC NO. ME02467)," dated August 24, 2009. (ADAMS Accession No's ML092440371, ML092440416 through ML092440435, and MIL092440441)

2. NUREG-1431, Volume 1, Rev. 3.0, "Standard Technical Specifications -

Westinghouse Plants," Published June 2004.

Serial No. 09-491C ATTACHMENT 2 LICENSE AMENDMENT REQUEST 249: KEWAUNEE POWER STATION CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS (TAC NO. ME02467)

- REQUEST TO CHANGE PROPOSED SERVICE WATER AND MAIN STEAM ISOLATION VALVE SPECIFICATIONS MODIFIED DISCUSSION OF CHANGES (DOCS), PROPOSED TECHNICAL SPECIFICATIONS, AND JUSTIFICATION FOR DEVIATIONS (JFDS)

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

, Volume 12, Rev. 0, Page 39 of 415 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs) systems, components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. Due to this change in Applicability, the shutdown action has also been modified to only require entering MODE 4, which will exit the new Applicability. The proposed time to reach MODE 4 is reasonable, based on operating experience, to reach MODE 4 from full power conditions in an orderly manner and without challenging plant systems. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L02 (Category 7-Relaxation Of Surveillance Frequency) CTS 4.7 states that the main not required to be steam isolation valves shall be tested once per operating cycle to verify a closure MODES 2 and 3 performed in MODES 2 time of 5 seconds or less. ITS SR 3.7.2.1 requires a similar test, but Note under certain and 3 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after nodifying ITS SR 3.7.2.1 allows that the SR is.nly r.ur,.. to. b p.....mad in conditions the MSlVs are open.

'MODES I and 2. This changes the CTS by allowingentry into MODout performing the Surveillance Requirement.

The purpose of CTS 4.7 is to demonstrate that the closure time of each MSIV is

,2 within the limits assumed in the containment and accident analyses. This test is normally conducted in MODE' with the unit at operating temperature and ressure. Addition of the NOTE modifying the Surveillance Requirement allows a delay in testing until M

,Itr to establish conditions consistent with those for which the acceptance criterion was generated. This change is designated as less restrictive because the ITS Surveillance Requirement is required to be performed in fewer operating conditions than in the CTS.

Once theMSIVs are opened when in MODE 2 or 3, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to perform the SR. This provides the necessary time to perform the SR, but restricts the time the SR is not performed with the MSIVs open when in these MODES.

Kewaunee Power Station Page 5 of 5, Volume 12, Rev. 0, Page 39 of 415

CTS, Volume 12, Rev. 0, Page 42 of 415 All changes are unless otherwise noted SURVEILLANCE REQUIREMENTS MSIVs 3.7.2 SURVEILLANCE FREQUENCY 4.7 SR 3.7.2.1 NOTE ---------------

l t-

- -e,-

d A

MODES I ad 2

ý.

Not required to be performed in MODES 2 and 3 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are open.

In accordance with the Inservice Testing Program 0

Verify the isolation time of each MSIV is 1inrnitsI 9

i DOC M05 SR 3.7.2.2 NOTE ---------------

Only required to be performed in MODES 1 and 2.

Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal.

1180 months WOG STS 3.7.2-2 Rev. 3.0, 03/31/04, Volume 12, Rev. 0, Page 42 of 415

, Volume 12, Rev. 0, Page 43 of 415 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

1. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

2. ISTS 3.7.2 Required Actions A.1 and C.1 provide a bracketed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore an inoperable MSIV to OPERABLE status (A.1) or to close the MSIV (C.1).

CTS 3.6.b.3.C provides the Actions for an inoperable MSIV, since the MSIVs are containment isolation valves that isolate closed system penetrations. The CTS provides a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time to either restore the inoperable MSIV or to isolate the affected penetration. This allowance was approved by the NRC in Amendment No.

155, as documented in the NRC Safety Evaluation, dated June 8, 2001 (ADAMS accession No. ML011650102). Since the currently allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is much longer than the bracketed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time in the ISTS, and to bring the Completion Time more in line with the ISTS, Dominion Energy Kewaunee (DEK) has decided to reduce the Completion Time to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, consistent with the containment isolation valves associated with non-closed system penetrations.

3.

ISTS SR 3.7.2.1 includes a Note that allows entry into MODE 3 without the SR being performed.

This allows the SR to be performed at temperatures and pressures closer to operating temperature and pressure, in order to more closely match the conditions under which the MSIVs need to be closed within the 5 second time limit. Normally, the stroke time test is performed during a shutdown.

However, if maintenance is performed on the MSIVs, the test needs to be re-performed sometime during the startup. Following maintenance, the MSIVs are stroked prior to entering MODE 3 to ensure they are OPERABLE and will close if required. However, the actual stroke time test of record is not performed until MODE 2. At KPS, the steam lines cannot be kept warm with the MSIVs open in MODE 3. Thus, the MSIVs are normally kept closed (after the initial stroke test) in MODE 3 and in MODE 2 until after the unit is critical in MODE 2 and physics tests are complete. At that time, the MSIVs are opened and the timing test is performed. Therefore, KPS is changing the Note to state "Not required to be performed in MODES 2 and 3 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs are open." This proposed Note will allow entry into both MODES 2 and 3, provided the MSIVs are closed. Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after opening the MSIVs in either MODE 2 or 3, SR 3.7.2.1 will be requiredto be performed.

This 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limits the time the MSIVs are open in both MODES 2 and 3 without the SR being performed. The Note also does not discuss any exception to MODE 1, thus the SR is required to be performed prior to entry into MODE 1, consistent with the ISTS Note. Furthermore, if the unit is started up with the MSIVs open (which while not normally done, can be done this way), the SR must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 3. This is actually more restrictive than the ISTS Note, since it has no time limit to perform the SR after entering MODE 3. This change is acceptable since the MSIVs must remain closed to use the allowance. The LCO does not require the MSIVs to be OPERABLE in MODES 2 and 3 if they are closed and deactivated. While the MSIVs are not required to be deactivated in the Note, the MSIVs are closed and their operation is closely controlled by plant procedures.

Kewaunee Power Station Page 1 of I ; Volume 12, Rev. 0, Page 43 of 415

, Volume 12, Rev. 0, Page 51 of 415 MSIVs B 3.7.2 BASES ACTIONS (continued)

D.1 and D.2 If the MSIVslcannot be restored Jo-OPERABLE status orlare not closed within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the.unit must be placed at least in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

0 SURVEILLANCE REQUIREMENTS SR 3.7.2.1

[tof each MSV wiin the limit given in Reference 4 and is within that This SR verifie th closure time is < 4.

1assumed in the accident and containment analyses..This f-ue is normally performed upon returning the unit to operation following a refueling outage. The MSIVs should not be tested at power, since even a part stroke exercise increases the risk of a valve closure when the unit is generating power. As the MSIVs are not tested at power, they are exempt from the ASME Code (Ref. 5), requirements during operation in MODE 1 or 2.

[ This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. }

The Frequency is in accordance with the Inservice Testing Program.

This test is conducted #4AGQE4 with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and S2and3 operation in Mf&E 3 prior to performing the SR.* This allows a delay of testing unti f,

to establish conditions consistent with those under 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the MSIVs which the acceptance criterion was generated., provided the MSIVs are closed.

are opened in MODE 2 or MSIVs are opened in MODE 2 o must be performed within 12 hot if the MSIVs are open when ente SR 3.7.2.2 then the SR must be performed after entering MODE 3.

This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage. The Frequency of MSIV testing is every M1 81 months. The M1 8Mj month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the M1 8M month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

0

• Once the r 3, the SR irs. In addition, iring MODE 3, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 0

0 WOG STS B 3.7.2-5 Rev. 3.1, 12/01/05, Volume 12, Rev. 0, Page 51 of 415

, Volume 12, Rev. 0, Page 189 of 415 CTS 3.7 PLANT SYSTEMS 3.7.8 Service Water'System All changes are unless otherwise noted 3.7.8 3.3.e.1.A LCO 3.7.8 3.3.e.1 APPLICABILITY:

Two SWV trains shall be OPERABLE.

MODES 1, 2, 3, and 4.

3.3.e.2 3.3.e.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SW[train A.1 NOTES Conditions inoperable.

1. Enter applicabletand Required Actions of LCO 3.8.1, "AC Sources - Operating,"

for emergency diesel generator made inoperable by S

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops

- MODE 4," for residual heat removal loops made inoperable by S

-- F.Sy-stem.-

Restore SW~ltrain to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

B. Required Action and B.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Q

WOG STS 3.7.8-1 Rev. 3.0, 03/31/04, Volume 12, Rev. 0, Page 189 of 415

, Volume 12, Rev. 0, Page 190 of 415 CTS I

All changes are unless otherwise noted 9 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M03 DOC M03 DOC M03 SR. 3.7.8.1 E-----------------------N E

System Isolation of SW' flow to individual components does no render the SVVV inoperable.

Inecessarily Verify each SWImanua, power operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

0 31 days

,NSERT 1 System SR 3.7.8.2 Verify each SW automatic valve in the flow path 1181 months that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.7.8.3 Verify each SW pump starts automatically on an 1181 months actual or simulated actuation signal.

00 0

"*INSERT 2}

WOG STS 3.7.8-2 Rev. 3.0, 03/31/04, Volume 12, Rev. 0, Page 190 of 415

, Volume 12, Rev. 0, Page 192 of 415 JUSTIFICATION FOR DEVIATIONS ITS 3.7.8, SERVICE WATER (SW) SYSTEM

1. Changes are made (additions, deletions, and/or changes) to the ISTS Specification which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. Note 1 of Required Action A.1 is missing the word "Conditions". The correct titles of the ACTIONS Table Headers are "CONDITION" and "REQUIRED ACTION".

The word "Conditions" is inserted in the Note at the applicable place. This change is considered a typographical error of the ISTS.

3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

4. A new Surveillance Requirement (SR 3.7.8.4) has been added to perform a CHANNEL CALIBRATION in the Forebay Water Level instrumentation. The new Surveillance serves as a means to prove that the Forebay Water Level instrumentation is OPERABLE, consistent with the current licensing requirements.

Additionally, a new Surveillance Requirement (SR 3.7.8.5) has been added to ensure the Circulating Water pump breakers.trip on an actual or simulated Forebay Water Level Low-Low signal. The new SR serves as a means to prove the operability of the Forebay Water Level Trip System, consistent with the current licensing requirements.

5. ISTS SR 3.7.8.2 has been modified by a Note that allows the turbine building header isolation valve actuation to not be required provided the valve is closed and deactivated. This is consistent with the CTS 3.3.e.l.A.3 allowance and is acceptable since with the valve in the closed position, it is in its accident condition.

6. ISTS SR 3.7.8.1 includes a Note that states isolation of SW System flow to individual components does not render the SW System inoperable. This Note implies that if the individual component is isolated from SW flow, then the SW System cannot be declared inoperable and the associated ACTIONS of ITS 3.7.8 taken. However, this Note should not preclude the licensee from declaring the SW System inoperable if the SR is not met, in lieu of considering the SW System OPERABLE. Therefore, the Note has been modified to add the amplifying word "necessarily." This allows the licensee to decide whether or not to declare the SW System inoperable when SW System flow to a component is isolated.

Kewaunee Power Station Page 1 of I, Volume 12, Rev. 0, Page 192 of 415

b, Volume 12, Rev. 0, Page 197 of 415 I

PTON1 All changes are unless otherwise noted B 3.7.8 BASES ACTIONS (continued)

LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period.

B.1 and B.2 If the SWJtrain cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE REQUIREMENTS SR 3.7.8.1 This SR is modified by a Note indicating that the isolation of the SW0 I

components or systems may render those components inoperable, but nsarily Idoes no affect the OPERABILITY of the SW system That is, if SW System flow Verifying the correct alignment for manual, power operated, and is isolated to an individual component, either the SW automatic valves in the SW flow path provides assurance that the System System is declared proper flow paths exist for SWroperation. This SR does not apply o0 inoperable and ACTION A valves that are locked, sealed, or otherwise secured in position, since entered, or the individual they are verified to be in the correct position prior to being locked, sealed, component is declared or secured. This SR does not require any testing or valve manipulation; inoperable and its associated ACTIONS rather, it involves verification that those valves capable of being entered (i.e., the SW mispositioned are in the correct position. This SR does not apply to System is not declared valves that cannot be inadvertently misaligned, such as check valves.

inoperable in this case).

The 31 day Frequency is based on engineering judgment, is consistent With the procedural controls governing valve operation, and ensures correct valve positions.

WOG STS B 3.7.8-3 Rev. 3.0, 03/31/04, Volume 12, Rev. 0, Page 197 of 415

, Volume 12, Rev. 0, Page 200 of 415 JUSTIFICATION FOR DEVIATIONS ITS 3.7.8 BASES, SERVICE WATER (SW) SYSTEM

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

3. A new Surveillance Requirement (SR 3.7.8.4) has been added to ensure the Circulating Water System pumps trip on an actual or simulated Forebay Water Level Low-Low signal. The CTS requires the Forebay Water Level Trip System be OPERABLE however there is no Surveillance Requirement to prove operability. The new SR serves as a means to prove the operability of the Forebay Water Level Trip System.

4. The term "safety related function" has been change to "safety function" to be consistent with terminology in the definition of OPERABLE - OPERABILITY.

5. Changes made to reflect changes made to the Specifications.

6. Changes have been made to be consistent with changes made to the ISTS. Specifically, the word "necessarily" has been added to the Note to ISTS SR 3.7.8.1, and an explanation of how the Note is to be applied has been added.

Kewaunee Power Station Page 1 of I, Volume 12, Rev. 0, Page 200 of 415-