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2015-02-06
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Text
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 1 of 4 ITS NRC Questions Id 1661 NRC Question ALK-012 Number Category Technical ITS Section 1.0 ITS Number 1.0 DOC Number A-5 JFD Number JFD Bases Number Page Att 1, V.3, page 20 of 64 Number(s)
NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC In Attachment 1, Volume 3, page 20 of 64, DOC A05 uses the term available Question when discussing electrical power in relation to the definition of OPERABLE-OPERABILITY. The CTS and ITS definitions of OPERABLE-OPERABILITY use the term capable rather than available. Because availability has maintenance rule and performance indicator implications, please rewrite this DOC to be consistent with the CTS/ITS definitions (i.e., use capable instead of available).
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Audrey Klett Date Modified Modified By Date Added 2/18/2010 9:51 AM Notification NRC/LICENSEE Supervision Audrey Klett Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 1 of 4 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1661 06/02/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 2 of 4 Licensee Response/NRC Response/NRC Question Closure Id 2261 NRC Question ALK-012 Number Select Licensee Response Application
Response
2/25/2010 10:15 AM Date/Time Closure Statement Response The intent of using the term available was simply to shorten the Statement description of the sources' requirements. While KPS does not believe that use of the term "available" in this context has any implications to the maintenance rule, KPS will revise the DOC to alleviate this concern. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment ALK-012 Markup.pdf (705KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Audrey Klett Added By David Mielke Date Added 2/25/2010 10:20 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 2 of 4 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2261 06/02/2010
Attachment 1, Volume 3, Rev. 0, Page 20 of 64 Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 3 of 4 DISCUSSION OF CHANGES ITS 1.0, USE AND APPLICATION used. These changes are designated as administrative because they eliminate defined terms that are no longer used.
A04 The CTS 1.0.e definition of OPERABLE-OPERABILITY requires a system or component to be capable of performing its "intended" function and all necessary support systems to also be capable of performing their "intended" function. The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires the system, subsystem, train, component, or device to be capable of performing the "specified safety" function(s), and requires all necessary support systems that are required for the system, subsystem, train, component, or device to perform its "specified safety" function(s) to also be capable of performing their related support functions. This changes the CTS by altering the requirements to be able to perform "intended" functions to a requirement to be able to perform "specified safety" functions.
The purpose of the CTS and ITS definitions of OPERABLE-OPERABILITY is to ensure that the safety analysis assumptions regarding equipment and variables in the CTS and ITS are valid. This change is acceptable because the intent of both the CTS and ITS definitions is to address the safety function(s) assumed in the accident analysis and not encompass other non-safety functions a system may also perform. These non-safety functions are not assumed in the safety analysis and are not needed in order to protect the public health and safety. This change is consistent with the current interpretation and use of the terms OPERABLE and OPERABILITY. This change is designated as administrative as it does not change the current use and application of the Technical capable of performing Specifications. their related support function AOS The CTS 1.0.e definition of OPERABLE-OPERABILITY requires that all necessary normal and emergency electrical power sources be for the system or component to be OPERABLE. The ITS Section 1.1 definition of OPERABLE-OPERABILITY will replace the phrase "normal and emergency electrical power sources" with "normal or emergency electrical power." This changes the CTS definition of OPERABLE-OPERABILITY by allowing a device to be considered OPERABLE with either normal or emergency power a¥t:tH""ftbt'f!.
The OPERABILITY requirements for normal and emergency power sources are clearly addressed in CTS 3.7.c. These requirements allow only the normal or the emergency electrical power source to be OPERABLE, provided its redundant system, train, or component (redundant to the system, train, or component with an inoperable power source) is OPERABLE. This effectively changes the current "and" to an "or." The existing requirements (CTS 3.7.c) are incorporated into ITS 3.8.1 ACTIONS for when a normal (offsite) or emergency (diesel generator) power source is inoperable. Therefore, the ITS definition now uses the word "or" instead of the current word "and." This change is designated administrative since the ITS definition, in combination with ITS 3.8.1 ACTIONS, is effectively the same as the CTS definition combined with CTS 3.7.c.
A06 CTS 1.0.i.2 defines a CHANNEL FUNCTIONAL TEST as "injecting a simulated signal into the channel as close to the primary sensor as practicable to verify that it is OPERABLE, including alarm and/or trip initiating action." ITS Section 1.1 renames the definition to CHANNEL OPERATIONAL TEST (COT), and defines it Kewaunee Power Station Page 2 of 11 Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 3 of 4 Attachment 1, Volume 3, Rev. 0, Page 20 of 64
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 4 of 4 Licensee Response/NRC Response/NRC Question Closure Id 2411 NRC Question ALK-012 Number Select Application NRC Question Closure
Response
Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 3/4/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Audrey Klett Added By Audrey Klett Date Added 3/4/2010 7:46 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 3 (Chapter 1.0) Page 4 of 4 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2411 06/02/2010
