Text

Attachment 1, Volume 13, Kewaunee Power Station Improved Technical Specifications Conversion, ITS Section 3.8 Electrical Power Systems, Revision 1
	ML102371140
Person / Time
Site:	Kewaunee
Issue date:	08/18/2010
From:	; Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
References
	10-457, TAC ME2139
	Download: ML102371140 (287)
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Attachment 1, Volume 13, Rev. 1, Page i of i Summary of Changes ITS Section 3.8 Change Description Affected Pages The changes described in the KPS response to Pages 104, 105, 107, 108 (DOC A05 deleted), 109, question GMW-004 have been made. This change 110, 111 (DOC L03 deleted), 113, 114, 115, 117, deletes the starting air requirements from ITS 3.8.3. 118, 119, 120, 121, 122, 123, 124, 125, and 127 The changes described in the KPS response to Pages 131, 136, 138, 140, 145, 212, 213, 215, 219, question MEH-009 have been made. This change 246, 247, 249, 252, 253, 255, 257, and 261 adds allowances for the electrical components to be inoperable for a short period of time due to the associated room cooler being non-functional.

The changes described in the KPS response to Pages 139, 140, 150, and 151 question GMW-013 have been made. This change deletes the allowance to perform portions of SR 3.8.4.3 in MODE 1, 2, 3, or 4.

The changes described in the KPS response to Pages 149, 150, 151, 152, 189, 191, 192, 198, 199, question GMW-007 have been made. This change and 203 makes minor changes to be consistent with the latest TSTF-500 revision. In addition, a new Bases JFD 11 for ITS 3.8.6 has been added to justify the changes. This was not included in the original draft GMW-007 Markup provided on the website.

Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page i of i

Attachment 1, Volume 13, Rev. 1, Page 1 of 286 ATTACHMENT 1 VOLUME 13 KEWAUNEE POWER STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Revision 1 Attachment 1, Volume 13, Rev. 1, Page 1 of 286

Attachment 1, Volume 13, Rev. 1, Page 2 of 286 LIST OF ATTACHMENTS

1. ITS 3.8.1

2. ITS 3.8.2

3. ITS 3.8.3

4. ITS 3.8.4

5. ITS 3.8.5

6. ITS 3.8.6

7. ITS 3.8.7

8. ITS 3.8.8

9. ITS 3.8.9

10. ITS 3.8.10 Attachment 1, Volume 13, Rev. 1, Page 2 of 286

, Volume 13, Rev. 1, Page 3 of 286 ATTACHMENT 1 ITS 3.8.1, AC SOURCES - OPERATING , Volume 13, Rev. 1, Page 3 of 286

, Volume 13, Rev. 1, Page 4 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 4 of 286

Attachment 1, Volume 13, Rev. 1, Page 5 of 286 ITS ITS 3.8.1 A01 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries.

OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features.

SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are LCO 3.8.1 satisfied: Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System LA01 LCO 3.8.1.a 1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

3. The 4160-V buses 1-5 and 1-6 are both energized.

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their See ITS respective station service transformers. 3.8.9

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

See ITS

6. Both station batteries and both DC systems are OPERABLE, except during testing 3.8.4, 3.8.6, and and surveillance as described in TS 4.6.b. 3.8.9 LCO 3.8.1.b

7. Both diesel generators are OPERABLE and each diesel generator shall have:

SR 3.8.1.4 A. Day tanks containing a minimum volume of 1000 gallons; B. An underground storage tank and corresponding day tanks containing a See ITS minimum volume of 32,888 gallons of useable fuel; 3.8.3 SR 3.8.1.6 C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:

LA02 A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 6 Attachment 1, Volume 13, Rev. 1, Page 5 of 286

Attachment 1, Volume 13, Rev. 1, Page 6 of 286 A01 ITS ITS 3.8.1 Add proposed ACTION Note A02 ACTION F b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, 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 MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months M01 ACTION A 1. Either auxiliary transformer may be out of service for a period not exceeding 7 days L02 provided the other auxiliary transformer and both diesel generators are OPERABLE. L03 Add proposed Required Action A.1 ACTION B 2. One diesel generator may be inoperable for a period not exceeding 7 days provided M02 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either: Add proposed Required Action B.1 A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator.

3. One battery may be inoperable for a period not exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the See ITS other battery and two battery chargers remain OPERABLE with one charger 3.8.4 and 3.8.6 carrying the d-c supply system.

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE.

LA02

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for See ITS 3.8.9 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the redundant bus and its loads remain OPERABLE.

ACTION E 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Required Actions c. When its normal or emergency power source is inoperable, a system, train or A.2, B.2 and C.1 component may be considered OPERABLE for the purpose of satisfying the requirements of its applicable LIMITING CONDITION FOR OPERATION, provided:

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for proposed Required Action A.2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for proposed Required Action B.2 L01 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for proposed Required Action C.1 Add proposed ACTION C L02 Add proposed ACTION D L03 Add proposed ACTION G A03 Amendment No. 194 TS 3.7-2 02/07/2008 Page 2 of 6 Attachment 1, Volume 13, Rev. 1, Page 6 of 286

Attachment 1, Volume 13, Rev. 1, Page 7 of 286 ITS ITS 3.8.1 A01 4.6 PERIODIC TESTING OF EMERGENCY POWER SYSTEM APPLICABILITY Applies to periodic testing and surveillance requirements of the emergency power system.

OBJECTIVE To verify that the emergency power sources and equipment are OPERABLE.

SPECIFICATION The following tests and surveillance shall be performed:

a. Diesel Generators SR 3.8.1.2 Note 1, Note 1: All diesel generator starts may be preceded by an engine pre-lube period and SR 3.8.1.16, Note 1 followed by a warm-up period before required loading.

SR 3.8.1.2 Note 2 Note 2: A modified diesel generator start involving idling and gradual acceleration to synchronous speed may be used as recommended by the manufacturer for TS 4.6.a.1.A.

SR 3.8.1.3 Note 2 Note 3: Momentary transients outside the diesel generator load range do not invalidate these tests.

A04

1. Monthly each diesel generator shall be tested by:

Add steady state voltage and frequency limits.

Add proposed Note 1 to SR 3.8.1.3 SR 3.8.1.2 A. Manually starting each diesel generator from a standby condition verifying that M03 each diesel generator achieves steady state voltage and frequency.

Add proposed Notes 3 and 4 to SR 3.8.1.3 M04 SR 3.8.1.3 B. Loading the diesel generator to at least 2600 KW (nominal) for a period of at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Add proposed Note 2 to SR 3.8.1.16 M05 SR 3.8.1.16 2. Automatic start of each diesel generator, load shedding, and restoration to energize permanently operation of particular vital equipment, all initiated by a simulated loss of all normal connected loads in a-c station service power supplies together with a simulated safety injection signal. L04 10 seconds and energizes auto-connected loads This test will be conducted at each REFUELING interval to assure that each diesel through time delay relays generator will start and assume required loads to the extent possible within M03 1 minute, and operate for 5 minutes while loaded with the emergency loads.

Add steady state voltage and frequency limits L05

3. Each diesel generator shall be inspected at each major REFUELING outage. LA03 SR 3.8.1.11 4. Diesel generator load rejection test in accordance with IEEE 387-1977, Section 6.4.5, shall be performed at least once per 18 months.

Add test acceptance criteria Add proposed Note 1 to SR 3.8.1.11 M05 M07 and DG load range.

Add proposed Note 2 to SR 3.8.1.11 M06 Amendment No. 194 TS 4.6-1 02/07/2008 Page 3 of 6 Attachment 1, Volume 13, Rev. 1, Page 7 of 286

Attachment 1, Volume 13, Rev. 1, Page 8 of 286 ITS A01 ITS 3.8.1 SR 3.8.1.13 5. Each diesel generator shall be operated for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months every operating cycle:

Note 1 Momentary transients outside the load and power factor ranges do not invalidate this test.

Note 2 This Surveillance shall not normally be performed in the OPERATING or HOT STANDBY MODE. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this surveillance requirement.

Note 3 If performed with the diesel generator synchronized with offsite power, it shall be performed at a power factor 0.89. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

A. For 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded to 2860 KW (nominal) and, B. For the remaining hours of the test loaded to 2700 KW (nominal).

6. Safeguard bus undervoltage and safeguard bus second level undervoltage relays See ITS shall be calibrated at least once per operating cycle. 3.3.5

b. Station Batteries

1. The voltage of each cell shall be measured to the nearest hundredth volt each month. An equalizing charge shall be applied if the lowest cell in the battery falls

< 2.13 volts. The temperature and specific gravity of a pilot cell in each battery shall be measured.

2. The following additional measurements shall be made quarterly: the specific gravity and height of electrolyte in every cell and the temperature of every fifth cell. See ITS 3.8.6

3. All measurements shall be recorded and compared with previous data to detect signs of deterioration.

4. The batteries shall be subjected to a load test during the first REFUELING and once every 5 years thereafter. Battery voltage shall be monitored as a function of time to establish that the battery performs as expected during heavy discharge and that all electrical connections are tight.

Add proposed SR 3.8.1.1, SR 3.8.1.5, SR 3.8.1.6, SR 3.8.1.8, SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.12, SR 3.8.1.14, and SR 3.8.1.15 M08 Amendment No. 191 TS 4.6-2 05/01/2007 Page 4 of 6 Attachment 1, Volume 13, Rev. 1, Page 8 of 286

A01 ITS 3.8.1 TABLE TS 4.1-1 MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS CHANNEL DESCRIPTION CHECK CALIBRATE TEST REMARKS

24. Turbine First Stage Each shift Each refueling cycle Monthly See ITS Pressure 3.3.1

25. Deleted

26. Protective System Logic Not applicable Not applicable Monthly Includes auto load sequencer SR 3.8.1.7 Channel Testing

27. Deleted See ITS 3.3.1 and 3.3.2

28. Deleted

29. Seismic Monitoring Each refueling Each refueling cycle Not applicable See ITS System cycle 3.3.3

30. Fore Bay Water Level Not applicable Each refueling cycle Each refueling See ITS cycle 3.7.8

31. AFW Flow Rate (a) Each refueling cycle Not applicable (a) Flow rate indication will be checked at each unit startup and shutdown

32. PORV Position Indication Monthly Each refueling cycle Not applicable

a. Back-up Monthly Each refueling cycle Not applicable (Temperature)

33. PORV Block Valve Monthly Each refueling cycle Not applicable Position Indicator See ITS 3.3.3 , Volume 13, Rev. 1, Page 9 of 286 Attachment 1, Volume 13, Rev. 1, Page 9 of 286 Amendment No. 182 Page 5 of 7 04/06/2005 Page 5 of 6

Attachment 1, Volume 13, Rev. 1, Page 10 of 286 ITS TABLE TS 4.1-3 A01 ITS 3.8.1 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS A05 EQUIPMENT TESTS(1) TEST FREQUENCY

1. Control Rods Rod drop times of all full Each REFUELING outage length rods Quarterly when at or above HOT See ITS Partial movement of all STANDBY 3.1.4 rods not fully inserted in the core 1a. Reactor Trip Breakers Independent test(2) shunt Monthly and undervoltage trip attachments See ITS 1b. Reactor Coolant Pump Breakers- OPERABILITY Each REFUELING outage 3.3.1 Open-Reactor Trip 1c. Manual Reactor Trip Open trip reactor(3) trip and Each REFUELING outage bypass breaker

2. Deleted

3. Deleted See ITS

4. Containment Isolation Trip OPERABILITY Each REFUELING outage 3.6.3

5. Refueling System Interlocks OPERABILITY Prior to fuel movement each See CTS REFUELING outage 3.8.a.11

6. Deleted See ITS

7. Deleted 3.4.15

8. RCS Leak Detection OPERABILITY Weekly(4)

SR 3.8.1.4 9. Diesel Fuel Supply Fuel Inventory(5) Weekly 31 days L06

10. Deleted See ITS 4.0

11. Fuel Assemblies Visual Inspection Each REFUELING outage See ITS

12. Guard Pipes Visual Inspection Each REFUELING outage 3.6.1

13. Pressurizer PORVs OPERABILITY Each REFUELING cycle See ITS (6) 3.4.11

14. Pressurizer PORV Block Valves OPERABILITY Quarterly See ITS

15. Pressurizer Heaters OPERABILITY(7) Each REFUELING cycle 3.4.9

16. Containment Purge and Vent OPERABILITY(8) Each REFUELING cycle See ITS Isolation Valves 3.6.3 (1)

Following maintenance on equipment that could affect the operation of the equipment, tests A05 should be performed to verify OPERABILITY.

(2)

Verify OPERABILITY of the bypass breaker undervoltage trip attachment prior to placing breaker into service.

(3) See ITS Using the Control Room push-buttons, independently test the reactor trip breakers shunt trip 3.3.1 and undervoltage trip attachments. The test shall also verify the undervoltage trip attachment on the reactor trip bypass breakers. See ITS (4)

When reactor is at power or in HOT SHUTDOWN condition. 3.4.15 (5)

Inventory of fuel required in all plant modes. A06 (6)

Not required when valve is administratively closed. See ITS 3.4.11 (7)

Test will verify OPERABILITY of heaters and availability of an emergency power supply.

(8) See ITS This test shall demonstrate that the valve(s) close in 5 seconds. 3.4.9 See ITS Amendment No. 125 Page 1 of 1 3.6.3 08/07/96 Page 6 of 6 Attachment 1, Volume 13, Rev. 1, Page 10 of 286

Attachment 1, Volume 13, Rev. 1, Page 11 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 The ITS 3.8.1 ACTIONS include a Note that states LCO 3.0.4.b is not applicable to the diesel generators (DGs). The CTS does not include this Note. This changes the CTS by including the ACTION Note.

The purpose of the ITS 3.8.1 ACTIONS Note is to prohibit entry into the Applicability of LCO 3.8.1 with an inoperable DG. Currently, CTS 3.7.a precludes making the reactor critical when the DG is inoperable. ITS LCO 3.0.4 has been added in accordance with the Discussion of Changes for ITS Section 3.0, DOC L01. Changes to the Applicability are discussed in DOC M01. This LCO allows entry into a MODE or other specified condition in the Applicability under certain conditions when a Technical Specification required component is inoperable.

ITS LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability of a Specification if a risk assessment is performed, that determines it is acceptable to enter the Applicability, and appropriate risk management actions are established. The addition of this restriction (LCO 3.0.4.b is not applicable) is acceptable because there is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG, and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.7.a does not currently allow this option. This change is considered administrative because it does not result in technical changes to the CTS.

A03 CTS 3.7.b does not contain an Action for more than one offsite circuit inoperable concurrent with two DGs inoperable. Thus, having more than one offsite circuit inoperable concurrent with two DGs inoperable requires entering CTS 3.0.c. ITS 3.8.1 ACTION G requires entering LCO 3.0.3 immediately if three or more AC sources are inoperable. Changes related to two inoperable offsite circuits are discussed in DOC L03. This changes the CTS by adding a specific ACTION requiring entry into LCO 3.0.3 when three offsite circuits are inoperable.

This change is acceptable because the CTS Actions for three or more AC sources inoperable are the same as the ITS ACTIONS. This change is necessary due to the format of ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A04 CTS 4.6.a.1.B requires the DG to be loaded for 60 minutes. ITS SR 3.8.1.3 requires a similar test, but includes Note 1, which states that DG loading may include gradual loading as recommended by the manufacturer. This changes the CTS by adding an explicit Note that states DG loadings may include gradual loading as recommended by the manufacturer.

Kewaunee Power Station Page 1 of 11 Attachment 1, Volume 13, Rev. 1, Page 11 of 286

Attachment 1, Volume 13, Rev. 1, Page 12 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING CTS 4.6.a.1.B requires the load to be greater than or equal to a specific value for 60 minutes. The Note 1 allowance simply states that prior to entering the load range of the test, the EDG can be gradually loaded. This is currently allowed by the CTS since there is no explicit requirement precluding this operation, nor does the CTS specify a finite time to attain the required load. This change is acceptable because Note 1 to SR 3.8.3.1 simply clarifies how the DG can be loaded prior to entering the load range for the test. This change is designated as administrative because it does not result in a technical change to the CTS.

A05 CTS Table TS 4.1-3 Equipment Test 9 requires a Fuel Inventory check on the DG fuel supply. The test is modified by Note 1, which states that following maintenance on equipment that could affect the operation of the equipment, tests should be performed to verify OPERABILITY. ITS SR 3.8.1.4 requires a similar verification on the day tanks, but is not modified by a similar Note. This changes the CTS by deleting the Note requirement.

The purpose of this type of Note is to ensure the Surveillance is performed after maintenance prior to calling the affected equipment OPERABLE. However, CTS 4.0.a and ITS SR 3.0.1 state that failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillances, shall be failure to meet the OPERABILITY requirements for the LCO. Thus, if the diesel fuel oil inventory in the day tanks is not within limits due to maintenance, the appropriate ACTIONS would have to be entered and remain entered until the Surveillance is performed and met. Thus, there is no reason to state this requirement individually; it applies to all Surveillances in the Technical Specifications. This change is designated as administrative since it does not result in any technical changes.

A06 CTS Table TS 4.1-3, Note 5, requires verification of diesel fuel inventory in all plant modes. CTS 3.7.a.7.A requires fuel oil inventory in the day tanks to support DG OPERABILITY. ITS SR 3.8.1.4 requires the day tanks stored fuel oil level to be within limits when the associated DG is required OPERABLE (i.e., MODES 1, 2, 3, and 4 for ITS LCO 3.8.1 and MODES 5, 6, and during movement of irradiated fuel for ITS LCO 3.8.2. This changes the CTS by removing a potential conflict between two CTS statements.

This change is acceptable because the potential conflict within the CTS would be resolved by applying the requirements of CTS 4.0.a. CTS 4.0.a requires surveillance requirements to be met during the operational MODES specified in the LCO. Diesel fuel oil is a support system for each DG. The CTS and ITS maintain this relationship between the DGs and the diesel fuel oil system without any changes in the technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.a requires the AC sources to be OPERABLE when the reactor is critical.

In addition, CTS 3.7.b provides actions when an offsite circuit and diesel generators are inoperable during power operation or recovery from an Kewaunee Power Station Page 2 of 11 Attachment 1, Volume 13, Rev. 1, Page 12 of 286

Attachment 1, Volume 13, Rev. 1, Page 13 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING inadvertent trip. When the restoration times of CTS 3.7.b.1, 2. or 7 are not met, CTS 3.7.b requires the unit to be in HOT STANDBY (ITS MODE 2) in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ITS LCO 3.8.1 requires the AC sources to be OPERABLE in MODES 1, 2, 3 and 4. Thus ITS 3.8.1 ACTIONS A, B and E (as applicable) must be entered if an offsite circuit or diesel generators are inoperable in MODES 1, 2, 3, and 4.

This changes the CTS by requiring the AC sources to be OPERABLE in MODES 3 and 4 and commensurate ACTIONS to cover the new Applicability.

The purpose of CTS 3.7.a, in part, is to ensure the AC sources are OPERABLE to mitigate the consequences of a transient or design basis accident. The AC sources are required to be OPERABLE in MODES 1, 2, 3 and 4 when an accident may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODES 3 and 4 the reactor is not critical, however the reactor coolant temperature is above 200°F and there is considerable energy in the reactor core and the electrical power distribution systems must be available to support equipment necessary to mitigate the consequences of a loss of coolant accident. Therefore, it is necessary and acceptable to require the AC sources to be OPERABLE. Furthermore, the requirement to be in HOT STANDBY (ITS MODE 2) in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months has been deleted and replaced with a requirement to be in MODE 3 within the same period of time.

Since the times are the same and MODE 3 is a lower condition, deletion of the MODE 2 requirement is acceptable. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M02 CTS 3.7.b.1 allows one offsite circuit to be inoperable for 7 days provided one offsite circuit is OPERABLE, but does not provide any specific requirement to determine how the other offsite circuit is OPERABLE nor how often to perform the determination. CTS 3.7.b.2 covers the condition for one inoperable DG but does not provide any Surveillance Requirement to determine whether the offsite circuits are OPERABLE. ITS 3.8.1 Required Action A.1 requires the performance of SR 3.8.1.1 (the offsite circuit verification) for the OPERABLE offsite circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter when an offsite circuit is inoperable. ITS 3.8.1 Required Action B.1 requires the performance of SR 3.8.1.1 for the OPERABLE offsite circuit(s) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter when a DG is inoperable. This changes the CTS by adding a specific method and time to perform the offsite circuit verification when an offsite circuit or DG is inoperable.

The purpose of ITS 3.8.1 Required Actions A.1 and B.1 is to ensure availability and proper circuit continuity of the OPERABLE offsite circuit(s) when an AC source is inoperable. This change is acceptable because it provides additional assurance that the OPERABLE offsite circuit(s) is capable of performing its function. This change is designated as more restrictive because it adds new Required Actions to the CTS.

M03 CTS 4.6.a.1.A, in part, requires a manual start of the DGs and CTS 4.6.a.2 requires verification of DG performance when simulating a loss of offsite power in conjunction with a safety injection signal. While CTS 4.6.a.1.A requires steady state voltage and frequency to be achieved, neither of the Surveillance Requirements specify the steady state voltage and frequency values that must Kewaunee Power Station Page 3 of 11 Attachment 1, Volume 13, Rev. 1, Page 13 of 286

Attachment 1, Volume 13, Rev. 1, Page 14 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING be achieved by the DG. ITS SR 3.8.1.2 and ITS SR 3.8.1.16 require, in part, that each DG achieve a steady state voltage of 4000 V and 4400 V and frequency of 60.0 Hz and 60.7 Hz. This changes the CTS by providing explicit steady state voltage and frequency limits.

The purpose of CTS 4.6.a.1.A, in part, is to ensure that each DG can achieve steady state voltage and frequency conditions so that they can supply the emergency loads. The purpose of CTS 4.6.a.2, in part, is to ensure that each DG can start under accident conditions and assume its emergency loads. This change is acceptable because the added steady state values for voltage and frequency help to ensure the DGs will be capable of supplying the emergency loads when required. This change is designated as more restrictive because it adds specific limits to the CTS where none previously existed.

M04 CTS 4.6.a.1.B requires each DG to be loaded and operated for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS SR 3.8.1.3 requires a similar test; however two additional Notes have been added that place restrictions on the test. Notes 3 and 4 modify the CTS requirements by stating that the SR shall be conducted on only one DG at a time and the SR shall be preceded by and immediately follow, without a shutdown of the DG, a successful performance of ITS SR 3.8.1.2 or ITS SR 3.8.1.8. This changes the CTS by adding a restriction when performing this test.

The purpose of CTS 4.6.a.1.B is to ensure the DG can supply the emergency loads. This change is acceptable because CTS 4.6.a.1.B is normally conducted on one DG at a time. In addition, the loading of a DG is usually conducted without shutdown after a successful start during performance of CTS 4.6.a.1.B.

This change is designated as more restrictive because explicit restrictions are added to the DG load test.

M05 CTS 4.6.a.2 requires verification of DG performance when simulating a loss of offsite power in conjunction with a safety injection signal. CTS 4.6.a.4 requires performance of a DG load rejection test. ITS SR 3.8.1.16 and ITS SR 3.8.1.11, respectively, require similar tests, however ITS SR 3.8.1.16 includes a Note (Note 2) and ITS SR 3.8.1.11 includes a Note (Note 1), which state the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4 or MODE 1 or 2, respectively. The Notes also state that the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. The Notes further state that credit may be taken for unplanned events that satisfy the SR. This changes the CTS by allowing the Surveillances to be performed in MODE 1, 2, 3, or 4 or MODE 1 or 2, respectively, only as long as an assessment is performed or provided that it is an unplanned event that satisfies the requirements of the SR.

The purpose of CTS 4.6.a.2 and CTS 4.6.a.4 are to confirm the OPERABILITY of the DGs. This change is acceptable because CTS 4.6.a.2 and CTS 4.6.a.4 are normally performed during plant shutdown conditions. This change is designated as more restrictive because explicit restrictions are added to the DG automatic start and load rejection tests.

M06 CTS 4.6.a.4 requires verification that the DG is capable of rejecting a full load.

This Surveillance does not specify that a DG shall be tested at a specific power Kewaunee Power Station Page 4 of 11 Attachment 1, Volume 13, Rev. 1, Page 14 of 286

Attachment 1, Volume 13, Rev. 1, Page 15 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING factor. ITS SR 3.8.1.11 requires a similar verification but includes a Note (Note 2) that states if the test is performed with the DG synchronized with offsite power, it shall be performed within the power factor limit ( 0.89), unless grid conditions otherwise dictate the power factor be maintained as close to the limit as practicable. This changes the CTS requirement by specifying a power factor limit requirement if the testing is conducted by synchronizing with the offsite sources.

The purpose of CTS 4.6.a.4 is to ensure the DG does not trip upon loss of a full load. This change is acceptable because the testing should be conducted as close to the design basis conditions as possible. The power factor limit is specified in the ITS Bases as 0.89, and is representative of the actual inductive loading a DG would see under design basis accident conditions. Therefore, testing of the DG for a loss of full load within the power factor limit, if applicable, is acceptable. This change is designated as more restrictive because the testing required by the CTS does not currently contain the limitation.

M07 CTS 4.6.a.4 requires a DG load rejection test be performed in accordance with IEEE 387-1977, Section 6.4.5. IEEE 387-1977 specifies the DG shall be capable of rejecting the maximum rated load without exceeding speed or voltages which will cause tripping, mechanical damage, or harmful overstresses. ITS SR 3.8.1.11 requires verification that each DG can reject a load of 2860 kW without exceeding speeds or voltages that will cause tripping, mechanical damage, or harmful overstresses. This changes the CTS by including the actual load value and includes the acceptance criteria specified in IEEE 387-1977, Section 6.4.5.

The purpose of CTS 4.6.a.4 is to ensure the DG will not trip upon loss of full load.

The change is acceptable since the new acceptance criteria are more specific than the current criteria and will ensure the DG will be available for future use following a full load rejection. This change is designated as more restrictive because it adds more stringent testing criteria in the ITS than is in the CTS.

M08 ITS SR 3.8.1.1 requires verification that each required offsite source is correctly aligned and indicated power is available every 7 days. ITS SR 3.8.1.5 requires that each day tank be checked for accumulated water and to remove any accumulated water every 31 days. ITS SR 3.8.1.6 requires verification that each fuel transfer system operates to automatically transfer fuel oil from the storage tank to the associated day tanks every 31 days. ITS SR 3.8.1.8 requires verification that each DG can be started from standby conditions and achieve within 10 seconds voltage > 3952 V and frequency > 59.0 Hz and achieve steady state voltage 4000 V and 4400 V and frequency 60.0 Hz and 60.7 Hz every 184 days. ITS SR 3.8.1.9 requires verification of automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit every 18 months. ITS SR 3.8.1.10 requires verification that the frequency of each DG does not go above the specified limit during the rejection of the largest post-accident load every 18 months. ITS SR 3.8.1.12 requires the performance of a loss of offsite power initiation signal test every 18 months.

ITS SR 3.8.1.14 requires a DG hot restart test every 18 months. ITS SR 3.8.1.15 requires verification that each DG can synchronize with an offsite power source while loaded with emergency loads upon a simulated restoration of offsite power, Kewaunee Power Station Page 5 of 11 Attachment 1, Volume 13, Rev. 1, Page 15 of 286

Attachment 1, Volume 13, Rev. 1, Page 16 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING and return to ready-to-load operation every 18 months. This changes the CTS by adding these Surveillance Requirements to the Technical Specifications.

The purpose of these additional Surveillance Requirements is to ensure the DGs and the qualified circuits are OPERABLE. This change is acceptable because it provides additional assurance that the DGs and the qualified circuits remain OPERABLE to perform their safety function. This change is designated as more restrictive because it adds Surveillance Requirements to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.a.1 and CTS 3.7.a.2 require two offsite power sources to be fully operational and energized to carry power to the plant 4160 V AC buses and provides details of what constitutes offsite power sources. ITS 3.8.1 requires two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System to be OPERABLE, but the details of what constitutes OPERABLE qualified circuits is contained in the ITS Bases. This changes the CTS by moving the details of what constitutes OPERABLE qualified circuits to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.1 still retains the requirement for two qualified circuits to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, or ISI Program) CTS 3.7.a.8 requires, in part, at least one pair of transmission lines be OPERABLE.

CTS 3.7.b.4 and CTS 3.7.b.5 provide actions to be taken when the requirements of CTS 3.7.a.8 are not met. ITS 3.8.1 does not include any requirements for the transmission lines that provide power to the onsite transformers (i.e., the qualified offsite circuits). This changes the CTS by relocating the LCO and Actions for the transmission lines to the Technical Requirements Manual (TRM).

The removal of this LCO and Action from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and Kewaunee Power Station Page 6 of 11 Attachment 1, Volume 13, Rev. 1, Page 16 of 286

Attachment 1, Volume 13, Rev. 1, Page 17 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING safety. ITS 3.8.1 still retains requirements for the OPERABILITY of the two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System. This will ensure adequate offsite power is available to the Class 1E AC Electrical Power Distribution System.

Also, this change is acceptable because the LCO and Action will be adequately controlled in the TRM. The TRM is incorporated by reference into the USAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LA03 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, or ISI Program) CTS 4.6.a.3 requires each diesel generator be inspected each major refueling outage. The ITS does not include this DG inspection requirement. This changes the CTS by moving the explicit DG inspection Surveillance from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 4.6.a.3 is to ensure that each DG is inspected in accordance with the manufacturers recommendations. The other DG Surveillances will ensure the DG is capable of performing its safety function. This requirement is proposed to be relocated to the TRM since the requirement is not needed to ensure that the DG remains OPERABLE. This change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the USAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.7.c allows a system, train, or component to be considered OPERABLE with an inoperable emergency or normal power source, provided its corresponding normal or emergency power source is OPERABLE and its redundant system, train, or component is OPERABLE. Conversely, if the requirements of CTS 3.7.c are not met, the equipment would immediately be declared inoperable and the associated CTS actions for the inoperable equipment would be required to be taken. ITS 3.8.1 Required Action A.2 (which applies when one offsite source is inoperable) requires the declaration of required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). ITS 3.8.1 Required Action B.2 (which applies when one required DG is inoperable) requires the declaration of required feature(s), supported by the inoperable DG, inoperable when the required redundant feature(s) are inoperable 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s). ITS 3.8.1 Kewaunee Power Station Page 7 of 11 Attachment 1, Volume 13, Rev. 1, Page 17 of 286

Attachment 1, Volume 13, Rev. 1, Page 18 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Required Action C.1 (which applies when two offsite circuits are inoperable) requires the declaration of required feature(s) inoperable when the redundant required feature(s) are inoperable 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition C concurrent with inoperability of redundant required feature(s). This changes the CTS by allowing more time to restore inoperable AC sources prior to declaring the associated equipment inoperable.

The purpose of CTS 3.7.c is to ensure adequate power is available to required equipment so that the equipment can perform its safety function(s) during DBAs and transients. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. This change allows more time to restore inoperable equipment when required AC Sources are inoperable concurrent with inoperabilities of redundant required features. By declaring the affected supported equipment inoperable, and as a result, taking the Technical Specifications ACTIONS of the affected supported equipment, unit operation is maintained within the bounds of the Technical Specifications and approved ACTIONS. Since the AC Sources support the OPERABILITY of the affected equipment, it is appropriate that the proper action, in this condition, would be to declare that affected supported equipment inoperable. CTS 3.7.c is overly restrictive, in that if the associated supported equipment were inoperable for other reasons and the redundant equipment was also inoperable, a restoration time is sometimes provided, in other CTS sections. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time when one offsite circuit is inoperable is acceptable because: a) the redundant counterpart to the inoperable required feature is still OPERABLE although single failure protection may have been lost; b) the capacity and capability of the remaining AC Sources is still available; c) a reasonable time for repairs is provided for restoration before the unit is subjected to transients associated with a shutdown; and d) the low probability of a DBA occurring during this period. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time when two offsite circuits are inoperable is acceptable because Regulatory Guide 1.93 allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two offsite circuits inoperable. When a concurrent redundant required function is inoperable, a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time with one DG inoperable takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature and is considered to be less of a risk than subjecting the unit to transients associated with shutdown. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC Sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. This change is designated as less restrictive because additional time is allowed to restore equipment to OPERABLE status.

L02 (Category 4 - Relaxation of Required Action) CTS 3.7.b.1, in part, allows 7 days to restore an inoperable offsite circuit to OPERABLE status provided the other offsite circuit is OPERABLE. Thus, the CTS does not allow two offsite circuits to be inoperable and does not include Actions to take if two offsite circuits are inoperable. Therefore the shutdown requirements of CTS 3.0.c would apply.

ITS 3.8.1 ACTION C covers the condition of two offsite circuits inoperable and Kewaunee Power Station Page 8 of 11 Attachment 1, Volume 13, Rev. 1, Page 18 of 286

Attachment 1, Volume 13, Rev. 1, Page 19 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING requires the restoration of one offsite circuit to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by providing some time to restore an inoperable offsite circuit prior to requiring a plant shutdown when two offsite circuits are inoperable.

The purpose of CTS 3.7.b is to limit the time the unit can remain operating with offsite circuits inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore one of two inoperable offsite circuits to OPERABLE status when both are inoperable.

With both of the offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.7.b.1, in part, allows 7 days to restore an inoperable offsite circuit to OPERABLE status provided both DGs are OPERABLE. Thus, the CTS does not allow one offsite circuit and one DG to be simultaneously inoperable. Therefore, the shutdown requirements of CTS 3.0.c would apply. ITS 3.8.1 ACTION D covers the condition of one offsite circuit and one DG inoperable and requires the restoration of either the offsite circuit or the DG to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In addition, a Note is included that requires entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating," when Condition D is entered with no AC power source to any division. This changes the CTS by allowing some time to restore an AC power source prior to requiring a plant shutdown when one offsite source and one DG are inoperable.

The purpose of CTS 3.7.b.1 is to limit the time the unit can remain operating with AC sources inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore the inoperable required offsite circuit or the DG before requiring a shutdown. With one offsite circuit and one DG inoperable, sufficient AC sources are available to Kewaunee Power Station Page 9 of 11 Attachment 1, Volume 13, Rev. 1, Page 19 of 286

Attachment 1, Volume 13, Rev. 1, Page 20 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING maintain the unit in a safe shutdown condition in the event of a DBA or transient.

Furthermore, if the associated 4.16 kV ESF bus is de-energized, the Note to ITS 3.8.1 ACTION D requires entry into applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." During the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period, the 4.16 kV ESF bus is energized and can perform its design function during a LOCA event, assuming no loss of offsite power. If the associated 4.16 kV ESF bus is de-energized, ITS 3.8.9 ACTION A will require it to be re-energized within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Thus, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time provides a period of time to effect restoration of an AC source commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.a.2 requires verification of DG performance following a "simulated" loss of offsite power in conjunction with a "simulated" safety injection signal. ITS SR 3.8.1.16 performs a similar test, but specifies that each signal may be from either an "actual" or "simulated" signal. This changes the CTS by explicitly allowing the use of an actual signal for the test.

The purpose of CTS 4.6.a.2 is to ensure that the DG operates correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L05 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.a.2 requires, in part, that on a loss of all offsite power coincident with a safety injection signal, each DG be verified to start and assume required loads to the extent possible within 1 minute. ITS SR 3.8.1.16 requires a similar test, but specifies the permanently connected loads be verified energized in 10 seconds and that auto-connected loads are energized through the time delay relays. This changes the CTS by removing the requirement to verify all loads are energized "within 1 minute."

The purpose of CTS 4.6.a.2 is to ensure that the DG operates correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that this Surveillance Requirement acceptance criterion is not necessary for verification that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Each DG will continue to be tested in a manner to ensure the safety analyses assumptions will be met. Changes to the auto-connected loads will be controlled and evaluated by the design change Kewaunee Power Station Page 10 of 11 Attachment 1, Volume 13, Rev. 1, Page 20 of 286

Attachment 1, Volume 13, Rev. 1, Page 21 of 286 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING control process to ensure the DG is not overloaded. Furthermore, SR 3.8.1.7 verifies the intervals between the various load blocks are within limits.

SR 3.8.1.7 also helps to ensure a failure of a time delay relay is recognized. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L06 (Category 7 - Relaxation of Surveillance Frequency) CTS Table TS 4.1-3 Equipment Test 9 requires the diesel fuel oil inventory to be verified within limits weekly (every 7 days). ITS SR 3.8.1.4 requires the verification to be performed every 31 days. This changes the CTS by extending the Surveillance interval from 7 days to 31 days.

The purpose of the Surveillance is to verify that there is sufficient diesel fuel oil to operate the associated DG for approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The change is acceptable since the DG is normally only required to be run every 31 days. Therefore, the 31 day check of the diesel fuel oil level is sufficient. Furthermore, a low level alarm is provided and the operators would be aware of any large use of diesel fuel oil during this period. This change is designated as less restrictive because a Surveillance will be performed less frequently under the ITS than under the CTS.

Kewaunee Power Station Page 11 of 11 Attachment 1, Volume 13, Rev. 1, Page 21 of 286

Attachment 1, Volume 13, Rev. 1, Page 22 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 22 of 286

Attachment 1, Volume 13, Rev. 1, Page 23 of 286 CTS All changes are 1 AC Sources - Operating 3.8.1 unless otherwise noted 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

3.7.a.1, a. Two qualified circuits between the offsite transmission network and 3.7.a.2 the onsite Class 1E AC Electrical Power Distribution System, 11

and 3.7.a.7 b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s), and

[ c. Automatic load sequencers for Train A and Train B. ] 4 3.7.a APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

NOTE-----------------------------------------------------------

DOC A02 LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME 3.7.b.1 A. One [required] offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. [required] OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND WOG STS 3.8.1-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 23 of 286

Attachment 1, Volume 13, Rev. 1, Page 24 of 286 CTS All changes are 1 AC Sources - Operating unless otherwise noted 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.7.b.1 A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE 7 days 2 status.

3.7.b.2 B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. [required] offsite circuit(s).

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B required redundant concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours DG(s) is not inoperable due 3 to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s). 3 AND B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status. 7 days 2

WOG STS 3.8.1-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 24 of 286

Attachment 1, Volume 13, Rev. 1, Page 25 of 286 CTS All changes are 1 AC Sources - Operating 3.8.1 unless otherwise noted ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L02 C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required features AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

DOC L03 D. One [required] offsite --------------------NOTE-------------------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any train.

inoperable. ------------------------------------------------

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

3.7.b.7 E. Two [required] DGs E.1 Restore one [required] DG 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable. to OPERABLE status.

WOG STS 3.8.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 25 of 286

Attachment 1, Volume 13, Rev. 1, Page 26 of 286 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

REVIEWERS NOTE----- F.1 Restore [required] [12] hours ]

This Condition may be [automatic load sequencer]

deleted if the unit design is to OPERABLE status.

such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss 4 of offsite power independent of, or coincident with, a Design Basis Event.

F. [ One [required]

[automatic load sequencer] inoperable.

3.7.b G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 4 associated Completion F Time of Condition A, B, AND F C, D, E, or [F] not met.

G.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months or 4 1 DOC A03 H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

G G SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M08 SR 3.8.1.1 Verify correct breaker alignment and indicated 7 days power availability for each [required] offsite circuit. 1 WOG STS 3.8.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 26 of 286

Attachment 1, Volume 13, Rev. 1, Page 27 of 286 CTS All changes are 1 AC Sources - Operating unless otherwise noted 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.2 ------------------------------NOTES-----------------------------

4.6.a 1. All DG starts may be preceded by an engine Note 1 prelube period and followed by a warmup period prior to loading.

4.6.a [ 2. A modified DG start involving idling and gradual Note 2 acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met. ] 14 8

4.6.a.1.A Verify each DG starts from standby conditions and 31 days achieves steady state voltage [3740] V and 4400

[4580] V, and frequency [58.8] Hz and 4000

[61.2] Hz. 60.0 60.7 SR 3.8.1.3 ------------------------------NOTES-----------------------------

DOC A04 1. DG loadings may include gradual loading as recommended by the manufacturer.

4.6.a

2. Momentary transients outside the load range do Note 3 not invalidate this test.

DOC M04 3. This Surveillance shall be conducted on only one DG at a time.

DOC M04 4. This SR shall be preceded by and immediately follow without shutdown a successful 8 14 performance of SR 3.8.1.2 or SR 3.8.1.7.

4.6.a.1.B Verify each DG is synchronized and loaded and 31 days operates for 60 minutes at a load [4500] kW and 12

[5000] kW. 2600 3.7.a.7.a, s for each DG Table TS SR 3.8.1.4 Verify each day tank [and engine mounted tank] 31 days 4.1-3 contains [220] gal of fuel oil.

Test 9 1000 WOG STS 3.8.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 27 of 286

Attachment 1, Volume 13, Rev. 1, Page 28 of 286 CTS All changes are 1 AC Sources - Operating unless otherwise noted 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M08 SR 3.8.1.5 Check for and remove accumulated water from each [31] days day tank [and engine mounted tank].

each 3

3.7.a.7.c, SR 3.8.1.6 Verify the fuel oil transfer system operates to the [92] days DOC M08

[automatically] transfer fuel oil from storage tank[s]

31 Move SR 3.8.1.7 to the day tank [and engine mounted tank]. 3 here from page associated s 3.8.1.-14 14 DOC M08 SR 3.8.1.7 ------------------------------NOTE-------------------------------

8 All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and 184 days achieves: 3952

a. In [10] seconds, voltage [3740] V and frequency 58.8] Hz and 4000 4400 11 59.0 ;

b. Steady state voltage [3740] V and [4580] V, and frequency [58.8] Hz and [61.2] Hz.

60.0 60.7 14 DOC M08 SR 3.8.1.8 ------------------------------NOTE-------------------------------

9 [ This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify [automatic [and] manual] transfer of AC power [18] months ]

sources from the normal offsite circuit to each alternate [required] offsite circuit. the WOG STS 3.8.1-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 28 of 286

Attachment 1, Volume 13, Rev. 1, Page 29 of 286 CTS All changes are 1 AC Sources - Operating unless otherwise noted 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M08 SR 3.8.1.9 ------------------------------NOTES----------------------------- 14 10 [1. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2. If performed with the DG synchronized with offsite power, it shall be performed at a power 0.89 factor [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]

Verify each DG rejects a load greater than or equal [18] months to its associated single largest post-accident load, and:

a. Following load rejection, the frequency is

[63] Hz, .

66.75

b. Within [3] seconds following load rejection, the voltage is [3740] V and [4580] V, and 5

c. Within [3] seconds following load rejection, the frequency is [58.8] Hz and [61.2] Hz.

WOG STS 3.8.1-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 29 of 286

Attachment 1, Volume 13, Rev. 1, Page 30 of 286 CTS All changes are 1 AC Sources - Operating 3.8.1 unless otherwise noted SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 14 SR 3.8.1.10 ------------------------------NOTES-----------------------------

DOC M05 11 [ 1. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

DOC M06 2. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ]

4.6.a.4 Verify each DG does not trip and voltage is [18] months maintained [5000] V during and following a load 13 rejection of [4500] kW and [5000] kW. 12 can reject a load of 2860 kW without exceeding speeds or voltages that will cause tripping, mechanical damage, or harmful overstresses.

WOG STS 3.8.1-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 30 of 286

Attachment 1, Volume 13, Rev. 1, Page 31 of 286 CTS All changes are 1 AC Sources - Operating unless otherwise noted 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 14 DOC M08 SR 3.8.1.11 ------------------------------NOTES-----------------------------

12 1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power [18] months signal:

a. De-energization of emergency buses,

b. Load shedding from emergency buses,

c. DG auto-starts from standby condition and:

1. Energizes permanently connected loads in [10] seconds, ; 11 time delay relays 4

2. Energizes auto-connected shutdown loads through [automatic load sequencer], ; 11

3. Maintains steady state voltage

[3740] V and [4580] V, ; 11 4000 4400

4. Maintains steady state frequency

11

[58.8] Hz and [61.2] Hz, and 60.0 60.7

5. Supplies permanently connected [and auto-connected] shutdown loads for 5 minutes.

WOG STS 3.8.1-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 31 of 286

Attachment 1, Volume 13, Rev. 1, Page 32 of 286 AC Sources - Operating CTS 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 ------------------------------NOTES-----------------------------

[ 1. All DG starts may be preceded by prelube period.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Engineered Safety [18] months ] 6 Feature (ESF) actuation signal each DG auto-starts from standby condition and:

a. In [10] seconds after auto-start and during tests, achieves voltage [3740] V and frequency [58.8] Hz,

b. Achieves steady state voltage [3740] V and

[4580] V and frequency [58.8] Hz and

[61.2] Hz,

c. Operates for 5 minutes,

d. Permanently connected loads remain energized from the offsite power system, and

e. Emergency loads are energized [or auto-connected through the automatic load sequencer] from the offsite power system.

WOG STS 3.8.1-10 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 32 of 286

Attachment 1, Volume 13, Rev. 1, Page 33 of 286 AC Sources - Operating CTS 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.13 ------------------------------NOTE-------------------------------

[ This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for 7

unplanned events that satisfy this SR. ]

Verify each DG's noncritical automatic trips are [18] months bypassed on [actual or simulated loss of voltage signal on the emergency bus concurrent with an actual or simulated ESF actuation signal].

WOG STS 3.8.1-11 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 33 of 286

Attachment 1, Volume 13, Rev. 1, Page 34 of 286 CTS All changes are 1 AC Sources - Operating 3.8.1 unless otherwise noted SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.6.a.5 SR 3.8.1.14 13 ------------------------------NOTES----------------------------- 7

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

3. If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.89

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: [18] months

11

a. For [2] hours loaded [5250] kW and 12

[5500] kW and 2860

b. For the remaining hours of the test loaded 2700 [4500] kW and [5000] kW. 12 WOG STS 3.8.1-12 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 34 of 286

Attachment 1, Volume 13, Rev. 1, Page 35 of 286 CTS All changes are 1 AC Sources - Operating 3.8.1 unless otherwise noted SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M08 SR 3.8.1.15 ------------------------------NOTES----------------------------- 7

1. This Surveillance shall be performed within 14 5 minutes of shutting down the DG after the DG has operated [2] hours loaded [4500] kW 12 and [5000] kW. 2600 Momentary transients outside of load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves: 3952 [18] months

a. In [10] seconds, voltage [3740] V and frequency [58.8] Hz and 4000 4400 11 59.0 ;

b. Steady state voltage [3740] V, and [4580] V and frequency [58.8] Hz and [61.2] Hz.

60.0 60.7 DOC M08 SR 3.8.1.16 ------------------------------NOTE------------------------------- 7 This Surveillance shall not normally be performed in 15 MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG: [18] months

a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power, ;

11

b. Transfers loads to offsite power source, and

c. Returns to ready-to-load operation.

WOG STS 3.8.1-13 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 35 of 286

Attachment 1, Volume 13, Rev. 1, Page 36 of 286 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.17 ------------------------------NOTE-------------------------------

[ This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

8 Verify, with a DG operating in test mode and [18] months ]

connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:

a. Returning DG to ready-to-load operation and

b. [Automatically energizing the emergency load from offsite power].

Table TS SR 3.8.1.18 ------------------------------NOTE-------------------------------

4.1-1 Channel

[ This Surveillance shall not normally be performed Description 7 in MODE 1, 2, 3, or 4. However, this Surveillance 26 Remarks may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 14 taken for unplanned events that satisfy this SR. ]

Move to --------------------------------------------------------------------- 31 days after SR 3.8.1.6 on Verify interval between each sequenced load block [18] months page 3.8.1-6 is within +/- [10% of design interval] for each 9 emergency [and shutdown] load sequencer.

greater than or equal to minimum design load interval WOG STS 3.8.1-14 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 36 of 286

Attachment 1, Volume 13, Rev. 1, Page 37 of 286 CTS All changes are 1 AC Sources - Operating 3.8.1 unless otherwise noted SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 16 ------------------------------NOTES----------------------------- 8 4.6.a 1. All DG starts may be preceded by an engine Note 1 prelube period.

DOC M05 2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

4.6.a.2 Verify on an actual or simulated loss of offsite power [18] months signal in conjunction with an actual or simulated ESF actuation signal:

a. De-energization of emergency buses,

b. Load shedding from emergency buses, and

c. DG auto-starts from standby condition and:

1. Energizes permanently connected loads in

[10] seconds, ; 11 time delay relays 4

2. Energizes auto-connected emergency loads through load sequencer, ; 11

3. Achieves steady state voltage [3740] V and [4580] V, ;

4000 11 4400

4. Achieves steady state frequency 11

[58.8] Hz and [61.2] Hz, and 60.0 60.7

5. Supplies permanently connected [and auto-connected] emergency loads for 5 minutes.

WOG STS 3.8.1-15 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 37 of 286

Attachment 1, Volume 13, Rev. 1, Page 38 of 286 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.20 ------------------------------NOTE-------------------------------

All DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby 10 years 10 condition, each DG achieves:

a. In [10] seconds, voltage [3740] V and frequency [58.8] Hz and

b. Steady state voltage [3744] V and [4576] V, and frequency [58.8] Hz and [61.2] Hz.

WOG STS 3.8.1-16 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 38 of 286

Attachment 1, Volume 13, Rev. 1, Page 39 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

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. The ISTS 3.8.1 Required Actions A.3 and B.4 Completion Times of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months have been extended to 7 days, consistent with the Kewaunee current licensing basis, which allows 7 days to restore an inoperable offsite power or DG (CTS 3.7.b.1 and 3.7.b.2).

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

4. The bracketed items specified in ISTS LCO 3.8.1.c and ISTS 3.8.1 ACTION F have been deleted since the Kewaunee design does not include automatic load sequencers. The LCO has been modified and subsequent Conditions and Required Actions have been renumbered, as applicable. ISTS SR 3.8.1.11 (ITS SR 3.8.1.12) and ISTS SR 3.8.1.19 (ITS SR 3.8.1.16) have been revised to reflect the use of time delay relays.

5. The ISTS SR 3.8.1.9.b and c limits imposed on return to steady state frequency and voltage following a single load rejection are to be controlled by plant procedures and are not presented as specific TS requirements in ITS SR 3.8.1.10. The specific criteria referenced would not be appropriate for certain methods of performing this test, e.g., if performed while the DG was loaded only with the single largest load. Furthermore, this criteria is not included in the Kewaunee current licensing basis. In addition, due to this deletion, the load reject maximum frequency requirement has been made part of the first paragraph, instead of leaving it as part a. A similar change was approved in the ITS conversions for the Monticello Nuclear Generating Plant and the Davis-Besse Nuclear Power Plant.

6. ISTS SR 3.8.1.12 requires verification that on an actual or simulated Safety Injection actuation signal each DG auto-starts from standby conditions and achieves the specified voltage and frequency at the required time, achieves steady state voltage and frequency, operates for > 5 minutes, permanently connected loads remain energized from the offsite power system, and the emergency loads are powered from the offsite power system. ISTS SR 3.8.1.12 has not been adopted, since similar requirements are verified in ISTS SR 3.8.1.19 (ITS SR 3.8.1.16). Thus, these ISTS SR 3.8.1.12 requirements are redundant to the requirement of ISTS SR 3.8.1.19 (ITS SR 3.8.1.16). This is also consistent with the current licensing basis, since this Surveillance is not included in the CTS.

7. ISTS SR 3.8.1.13 has not been included in the Kewaunee ITS since it is not applicable to the Kewaunee DG design. The Kewaunee DG design does not include diesel generator trips that are bypassed on a loss of voltage signal on the emergency bus concurrent with an SI actuation signal. Subsequent Surveillances have been renumbered, as applicable.

Kewaunee Power Station Page 1 of 3 Attachment 1, Volume 13, Rev. 1, Page 39 of 286

Attachment 1, Volume 13, Rev. 1, Page 40 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

8. ISTS SR 3.8.1.17 is not included in the Kewaunee ITS since this feature was not included in the Kewaunee design. This SR demonstrates that with a DG operating in the test mode and connected to its bus, an SI actuation signal overrides the test mode and returns the DG to ready-to-load operation. At Kewaunee, with a DG connected to its bus, if an SI actuation signal were received, the DG would stay connected to its bus. Furthermore, the DGs do not perform any safety-related function for a LOCA event where offsite power is not lost (e.g., SI actuation) since the offsite circuits remain available. Therefore, this SR is not applicable. Subsequent Surveillances have been renumbered, as applicable.

9. ISTS SR 3.8.1.18 requires verification that the interval between each sequenced load block is within +/- 10% of design interval for each load sequence timer. The SR is proposed to be changed to not include the actual time limit and to delete the upper limit requirement, such that the interval between each load block is only required to be greater than or equal to the minimum design load interval.

As stated in the ISTS Bases, the purposes of the 10% load sequence time interval tolerance are to ensure that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding emergency safeguards equipment time delays are not violated. The first purpose is met solely by applying a lower limit. If the interval between two load blocks is greater than the minimum of the design interval, the capability of the DG to perform its function is not necessarily impacted. For the first load interval, sufficient time after energizing the first load block to allow the DG to restore frequency and voltage prior to energizing the second load block is still provided, since the minimum time needed is the minimum design interval.

Allowing more time than the design interval (e.g., plus 10%) does not negatively affect the ability of the DG to perform its intended function, with respect to the first load interval. In addition, it is recognized that if there is an additional load block following the first two described above, then allowing the load interval between the first two load blocks to be longer than the minimum design interval could impact the capability of the DG to restore frequency and voltage prior to the start of the third load block. However, the requirement that "each" load block be greater than or equal to the minimum design load interval will ensure that the time between the second and third load blocks is sufficient to ensure that the DG can restore frequency and voltage prior to energizing the third load block. The "each" requirement also ensures that all subsequent load intervals (e.g., the third, fourth, etc.) do not impact the capability of the DG to perform its intended function.

The second purpose described in the Bases for the SR is not related to the DG; it relates to the ability of the individual loads to perform their assumed functions.

Thus, if a time delay was too long, while the individual load may be inoperable, the DG is not inoperable; the DG can still perform its intended function. Thus, the upper limit should not be considered as an operability requirement for the DG. If an individual load timer is too long, only the associated load should be considered inoperable.

Furthermore, the actual values of the load interval limits (i.e., 10% of the design interval) are not included, consistent with current licensing basis. The actual Kewaunee Power Station Page 2 of 3 Attachment 1, Volume 13, Rev. 1, Page 40 of 286

Attachment 1, Volume 13, Rev. 1, Page 41 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING values will continue to be under Kewaunee control in the appropriate plant procedures.

10. ISTS SR 3.8.1.20 is not included in the Kewaunee ITS. This SR is intended to periodically verify acceptable electrical and physical independence of the DGs and associated electrical distribution systems. Adequate independence (both electrical and physical) of the DGs and associated electrical distribution systems was a requirement (and has been established in) the original plant design.

Furthermore, existing maintenance practices and configuration control practices are judged to be sufficient to ensure continued acceptable separation and independence. Thus, there is no need to periodically perform this SR to demonstrate continued acceptable independence or simultaneous start capability.

11. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

12. ISTS SR 3.8.1.3 (ITS SR 3.8.1.3), ISTS SR 3.8.1.10 (ITS SR 3.8.1.11), ISTS SR 3.8.1.14 (ITS SR 3.8.1.13), and Note 1 to ISTS SR 3.8.1.15 (ITS SR 3.8.1.14) include a maximum load value for the Surveillance. This maximum load value has not been included in the KPS ITS. The ISTS Bases for ISTS SR 3.8.1.3 and ISTS SR 3.8.1.14 state that the load band is to preclude routine overloading of the DGs, since this may result in more frequent teardown inspections. However, the CTS does not specify maximum load values. Only the minimum load values are provided for tests that include load values. The maximum load values and the requirement to prevent routine overloading are adequately controlled by KPS procedures.

13. ISTS SR 3.8.1.10, in part, requires verification that each DG does not trip and voltage is maintained [5000] V during and following a full load rejection. KPS currently performs this test in accordance with IEEE 387-1977, as stated in CTS 4.6.a.4. The KPS ITS will maintain the Surveillance Requirement in accordance with IEEE 387-1977. The specific acceptance criteria from IEEE 387-1977 is included in the proposed ITS SR 3.8.1.11, in lieu of just referencing the IEEE standard, to more closely align the proposed SR with the ITS intent (i.e., that the specific acceptance criteria for the test is stated in the actual SR). This acceptance criteria is analogous to the acceptance criteria in the ISTS, in that it still ensures the voltages and speeds do not cause mechanical damage and harmful overstresses.

14. The ISTS SR 3.8.1.18 Frequency has been changed to 31 days to match the current KPS licensing basis (CTS Table TS 4.1-1 Channel Description 26, Test and Remarks Section). Additionally, the Surveillance has been renumbered to ITS SR 3.8.1.7 to reflect the proper place where the 31 day Surveillance Frequency should be. The bracketed Note to the SR has also been deleted since the test can be performed on line. Subsequent SRs has been renumbered, as necessary, to reflect the numbering change.

Kewaunee Power Station Page 3 of 3 Attachment 1, Volume 13, Rev. 1, Page 41 of 286

Attachment 1, Volume 13, Rev. 1, Page 42 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 42 of 286

Attachment 1, Volume 13, Rev. 1, Page 43 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS The DGs are Class 1E but only portions of the offsite circuits B 3.8.1 AC Sources - Operating (supply breakers to the Class 1E buses 1-5 and 1-6) are Class 1E.

reserve auxiliary transformer and BASES tertiary auxiliary transformer BACKGROUND The unit Class 1E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and alternate(s)), and the onsite standby power sources (Train A and Train B 1A and 1B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the design of the AC electrical power system provides USAR General independence and redundancy to ensure an available source of power to Design Criteria (GDC) 39 the Engineered Safety Feature (ESF) systems.

either train The onsite Class 1E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG.

substation Offsite power is supplied to the unit switchyard(s) from the transmission four network by [two] transmission lines. From the switchyard(s), two electrically and physically separated circuits provide AC power, through

[step down station auxiliary transformers], to the 4.16 kV ESF buses. A 2 detailed description of the offsite power network and the circuits to the Class 1E ESF buses is found in the FSAR, Chapter [8] (Ref. 2).

U 1 An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF bus(es).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1E Distribution System. Within [1] minute after the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service via the load sequencer.

1B 1-5 1A The onsite standby power source for each 4.16 kV ESF bus is a 1-6 dedicated DG. DGs [11] and [12] are dedicated to ESF buses [11]

and [12], respectively. A DG starts automatically on a safety injection (SI) 2

, low main steam line pressure signal (i.e., low pressurizer pressure or high containment pressure signals) or on an [ESF bus degraded voltage or undervoltage signal]

(refer to LCO 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Offsite loss of voltage O

WOG STS B 3.8.1-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 43 of 286

Attachment 1, Volume 13, Rev. 1, Page 44 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES BACKGROUND (continued)

Instrumentation"). After the DG has started, it will automatically tie to its loss of voltage respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SI signal. The DGs will also start and operate in the standby mode without tying to the ESF bus on an SI signal alone. Following the trip of offsite power, [a sequencer/an undervoltage signal] strips nonpermanent 2 loads from the ESF bus. When the DG is tied to the ESF bus, loads are then sequentially connected to its respective ESF bus by the automatic individual time delay relays load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the DG by automatic load application. offsite In the event of a loss of preferred power, the ESF electrical loads are automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a loss of coolant accident (LOCA).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Within approximately 55 seconds [1] minute after the initiating signal is received, all loads needed to 2 recover the unit or maintain it in a safe condition are returned to service.

1A and 1B are consistent with Safety Guide 9 Ratings for Train A and Train B DGs satisfy the requirements of Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG 2600 is [7000] kW with [10]% overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any 2 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The ESF loads that are powered from the 4.16 kV ESF buses are listed in Reference 2.

U APPLICABLE The initial conditions of DBA and transient analyses in the FSAR, 14 SAFETY Chapter [6] (Ref. 4) and Chapter [15] (Ref. 5), assume ESF systems are 2 ANALYSES OPERABLE. The AC electrical power sources are designed to provide 4 sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS);

and Section 3.6, Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during Accident conditions in the event of:

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Attachment 1, Volume 13, Rev. 1, Page 45 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES APPLICABLE SAFETY ANALYSES (continued)

3

a. An assumed loss of all offsite power or all onsite AC power and

b. A worst case single failure.

- Operating ies 4

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Two qualified circuits between the offsite transmission network and the onsite Class 1E Electrical Power System and separate and independent DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Qualified offsite circuits are those that are described in the FSAR and are 5 part of the licensing basis for the unit.

[ In addition, one required automatic load sequencer per train must be 2 OPERABLE. ]

Each offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the ESF buses.

[ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through 2 its normal feeder breaker. Offsite circuit #2 consists of the Startup INSERT 1 Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201, powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

Each DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage. This will be accomplished within [10] seconds. Each DG 2 must also be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby with the engine at ambient conditions.

Additional DG capabilities must be demonstrated to meet required Surveillance, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode. 6 reject full load WOG STS B 3.8.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 45 of 286

Attachment 1, Volume 13, Rev. 1, Page 46 of 286 B 3.8.1 2

INSERT 1 One qualified offsite circuit consists of the 138/4.16 kV Reserve Auxiliary Transformer, powered by the 138 kV portion of the Kewaunee Substation and normally supplying power to Bus 1-6. The other qualified offsite circuit consists of the 13.8 tertiary winding of the 345/138/13.8 Auto Transformer, powered by either the 345 kV or 138 kV portion of the Kewaunee Substation, to the 13.8/4.16 kV Tertiary Auxiliary Transformer and normally supplying power to Bus 1-5. The offsite circuits also include the supply breakers to buses 1-5 and 1-6. While each circuit has connections to each 4.16 kV ESF bus, each offsite circuit is only required to be capable of supplying one of the 4.16 kV ESF buses at a time.

Insert Page B 3.8.1-3 Attachment 1, Volume 13, Rev. 1, Page 46 of 286

Attachment 1, Volume 13, Rev. 1, Page 47 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES LCO (continued)

Proper sequencing of loads, [including tripping of nonessential loads,] is a 2 required function for DG OPERABILITY.

The AC sources in one train must be separate and independent (to the extent possible) of the AC sources in the other train. For the DGs, separation and independence are complete.

for one ESF bus For the offsite AC sources, separation and independence are to the extent practical. A circuit may be connected to more than one ESF bus, with fast transfer capability to the other circuit OPERABLE, and not In addition, day tanks fuel oil level and fuel oil transfer one violate separation criteria. A circuit that is not connected to an ESF bus is system requirements must required to have OPERABLE fast transfer interlock mechanisms to at be met for each DG.

least two ESF buses to support OPERABILITY of that circuit.

APPLICABILITY The AC sources [and sequencers] are required to be OPERABLE in 2 MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and ; 3

b. Adequate core cooling is provided and containment OPERABILITY safety and other vital functions are maintained in the event of a postulated DBA.

and other conditions in which AC sources are required 7 The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria 8

does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.

WOG STS B 3.8.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 47 of 286

Attachment 1, Volume 13, Rev. 1, Page 48 of 286 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

REVIEWERS NOTE-----------------------------------

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater 9 pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

A.2 Required Action A.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features.

and turbine driven These features are powered from the redundant AC electrical power train.

This includes motor driven auxiliary feedwater pumps. Single train 9 systems, such as turbine driven auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

3

a. The train has no offsite power supplying it loads and

b. A required feature on the other train is inoperable.

10 redundant If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable redundant required support or supported features, or both, that are associated with 10 the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because 11 it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

WOG STS B 3.8.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 48 of 286

Attachment 1, Volume 13, Rev. 1, Page 49 of 286 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) Bus 1-6 Electrical Power Bus 1-5 The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution 1 System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in 6 Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

7 day The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and 6 capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a an offsite failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is 6 inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

REVIEWERS NOTE-----------------------------------

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater 9 pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

WOG STS B 3.8.1-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 49 of 286

Attachment 1, Volume 13, Rev. 1, Page 50 of 286 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are and turbine driven designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven 9 auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

3

a. An inoperable DG exists and redundant

b. A required feature on the other train (Train A or Train B) is 10 inoperable.

If at any time during the existence of this Condition (one DG inoperable) a 11 redundant required feature subsequently becomes inoperable, this Completion Time 10 would begin to be tracked.

redundant Discovering one required DG inoperable coincident with one or more 6 inoperable required support or supported features, or both, that are 10 associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is Acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

Electrical Power 11 In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution 1 System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

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Attachment 1, Volume 13, Rev. 1, Page 51 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES ACTIONS (continued)

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary the testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on it other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will 2 continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

5 According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to 2 confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in 6 Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Electrical Power In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution 7 day System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity 6 and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a features coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of 6 redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2). The rationale for WOG STS B 3.8.1-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 51 of 286

Attachment 1, Volume 13, Rev. 1, Page 52 of 286 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of and turbine driven 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not 9 included in the list.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

3

a. All required offsite circuits are inoperable and

b. A required feature is inoperable. 10 redundant If at any time during the existence of Condition C (two offsite circuits redundant 10 inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable.

However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and 3

b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

WOG STS B 3.8.1-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 52 of 286

Attachment 1, Volume 13, Rev. 1, Page 53 of 286 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC active sources, a LOCA, and a worst case single failure were postulated as a 1 part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

According to Reference 6, with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If two offsite sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance with Condition A.

D.1 and D.2

- Operating 12 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition D are modified by a Note to indicate that when Condition D is entered with no AC source to any train, the Conditions and Required Actions for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition D to provide requirements for the loss of one offsite circuit and one DG, without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition D for a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In Condition D, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition C (loss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

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Attachment 1, Volume 13, Rev. 1, Page 54 of 286 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

E.1 both 1

With Train A and Train B DGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

According to Reference 6, with both DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

[ F.1 The sequencer(s) is an essential support system to [both the offsite circuit and the DG associated with a given ESF bus]. [Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus.]

Therefore, loss of an [ESF bus sequencer] affects every major ESF system in the [division]. The [12] hour Completion Time provides a period 6 of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Condition is preceded by a Note that allows the Condition to be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety bus during an event and thereby causes its failure. Also implicit in the Note, is that the Condition is not applicable to any train that does not have a sequencer. ]

WOG STS B 3.8.1-11 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 54 of 286

Attachment 1, Volume 13, Rev. 1, Page 55 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES ACTIONS (continued) F 6

G.1 and G.2 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems.

G 6

H.1 Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all USAR GDC 39 REQUIREMENTS important areas and features, especially those that have a standby 1 function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 8).

Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs 7 for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory consistent and the intent of IEEE 387-1977 Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), as (Ref. 8). addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency 4000 tolerances, the following is applicable. The minimum steady state output voltage of [3740] V is 90% of the nominal 4160 V output voltage. This 2 value, which is specified in ANSI C84.1 (Ref. 11), allows for voltage drop based on the degraded voltage setpoint analysis to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating. 4400 The specified maximum steady state output voltage of [4756] V is equal 2 to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating WOG STS B 3.8.1-12 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 55 of 286

Attachment 1, Volume 13, Rev. 1, Page 56 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 60.7 6

voltages. The specified minimum and maximum frequencies of the DG 60.0 are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

These values are based on plant-specific analyses.

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source, and that appropriate independence of offsite circuits is maintained. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.

8 SR 3.8.1.2 and SR 3.8.1.7 8 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition.

To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs are modified by a Note (Note 1 for 8 SR 3.8.1.2 and Note for SR 3.8.1.7) to indicate that all DG starts for these 8 Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading.

8 For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing, the DGs are 8 started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. the ed

[ In order to reduce stress and wear on diesel engines, some has manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are 2 gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only applicable when such modified start procedures are recommended by the manufacturer. ]

WOG STS B 3.8.1-13 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 56 of 286

Attachment 1, Volume 13, Rev. 1, Page 57 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 8 8

SR 3.8.1.7 requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions of the design basis LOCA analysis in the FSAR, Chapter [15] (Ref. 5). 2 U 14 4 The 10 second start requirement is not applicable to SR 3.8.1.2 (see Note 2) when a modified start procedure as described above is used. If a 8 modified start is not used, the 10 second start requirement of SR 3.8.1.7 8 applies.

8 8

Since SR 3.8.1.7 requires a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2.

In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

8 The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory 8 8

IEEE 387-1977 Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These 5 Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.

SR 3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing with DG rated load the offsite electrical system and accepting loads greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

Although no power factor requirements are established by this SR, the 85 85 DG is normally operated at a power factor between [0.8 lagging] and

[1.0]. The [0.8] value is the design rating of the machine, while the [1.0] is 2 an operational limitation [to ensure circulating currents are minimized].

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in 8 accordance with vendor recommendations in order to maintain DG OPERABILITY.

The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3).

7 WOG STS B 3.8.1-14 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 57 of 286

Attachment 1, Volume 13, Rev. 1, Page 58 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel conditions engine are minimized. Note 2 states that momentary transients, because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 shall indicates that this Surveillance should be conducted on only one DG at a 6 time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.4 s

This SR provides verification that the level of fuel oil in the day tank [and 2

engine mounted tank] is at or above the level at which fuel oil is within the required limit automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%. s approximately This value is also credited to support 7 The 31 day Frequency is adequate to assure that a sufficient supply of days of DG operation fuel oil is available, since low level alarms are provided and facility at rated load, as discussed in SR operators would be aware of any large uses of fuel oil during this period.

3.8.3.1.

SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day [and engine mounted] tanks once every [31] days eliminates 2 the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the y watertight integrity of the fuel oil system. The Surveillance Frequencies 11 is consistent with are established by Regulatory Guide 1.137 (Ref. 10). This SR is for 9

preventative maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

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Attachment 1, Volume 13, Rev. 1, Page 59 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.6 s This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its the associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a [92] day interval. The [92] day Frequency corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 11); however, the design of fuel transfer systems is consistent with the Frequency for such that pumps operate automatically or must be started manually in 2 testing the DGs order to maintain an adequate volume of fuel oil in the day [and engine in SR 3.8.1.2 and SR 3.8.1.3. mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs. ]

Move SR 3.8.1.7 8 from page 3.8.1-29 here SR 3.8.1.7 10 See SR 3.8.1.2.

9 8

[ SR 3.8.1.8 Transfer of each [4.16 kV ESF bus] power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

2 The [18 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 WOG STS B 3.8.1-16 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 59 of 286

Attachment 1, Volume 13, Rev. 1, Page 60 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.] 2 Credit may be taken for unplanned events that satisfy this SR.

10 8 SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load a response characteristics and capability to reject the largest single load without exceeding predetermined voltage and frequency and while 6 maintaining a specified margin to the overspeed trip. [For this unit, the 2 single load for each DG and its horsepower rating is as follows:] This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus, or 3

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus. 3 Consistent with Safety Guide 9 As required by IEEE-308 (Ref. 12), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

6 above synchronous speed, whichever is lower.

This corresponds to 66.75 Hz, which is 75% of the difference between synchronous speed The time, voltage, and frequency tolerances specified in this SR are and the overspeed trip setpoint. derived from Regulatory Guide 1.9 (Ref. 3) recommendations for 6

response during load sequence intervals. The 3 seconds specified is equal to 60% of a typical 5 second load sequence interval associated with WOG STS B 3.8.1-17 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 60 of 286

Attachment 1, Volume 13, Rev. 1, Page 61 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG.

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while 6 SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. The

[18 month] Frequency is consistent with the recommendation of 2 takes into consideration unit conditions required to perform Regulatory Guide 1.108 (Ref. 9). 1 the Surveillance, and is intended to be consistent with expected fuel cycle lengths. This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of [0.9].

This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain 0.89 conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to [0.9] results in voltages on the emergency busses that are too high. 1 0.89 2 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the 1 excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to 0.89

[0.9] without exceeding the DG excitation limits.

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Attachment 1, Volume 13, Rev. 1, Page 62 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 9

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

11 , in accordance with IEEE 387-8 SR 3.8.1.10 1977 (Ref. 8, Section 6.4.5),

exceeding speeds or voltages 1 that will cause tripping, This Surveillance demonstrates the DG capability to reject a full load mechanical damage, or without overspeed tripping or exceeding the predetermined voltage limits. 8 harmful overstresses The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

takes into consideration unit The [18 month] Frequency is consistent with the recommendation of 2 conditions required to perform Regulatory Guide 1.108 (Ref. 9) and is intended to be consistent with 1 the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

expected fuel cycle lengths.

This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbation to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety WOG STS B 3.8.1-19 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 62 of 286

Attachment 1, Volume 13, Rev. 1, Page 63 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite 0.89 power, testing should be performed at a power factor of [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high. 0.89 2 0.89 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

REVIEWERS NOTE----------------------------

The above MODE restrictions may be deleted if it can be demonstrated to 9

the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

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a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the 9

electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.11 12 1.9 7 c.2.2.4 8 Consistent with As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The DG autostart time of [10] seconds is derived from requirements of the 2 accident analysis to respond to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved.

The requirement to verify the connection and power supply of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain some circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or high pressure injection systems are not 6 capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

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The Frequency of [18 months] is consistent with the recommendations of 2 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge

, 2, 3, or 4 safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the 6 Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced , 2, 3, or 4 when portions of the Surveillance are performed in MODE 1 or 2. Risk 6 insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.12 This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time

([10] seconds) from the design basis actuation signal (LOCA signal) and operates for 5 minutes. The 5 minute period provides sufficient time to 8 demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.

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Attachment 1, Volume 13, Rev. 1, Page 66 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of [18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month]

Frequency. Therefore, the Frequency was concluded to be acceptable 8 from a reliability standpoint.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. ]

Credit may be taken for unplanned events that satisfy this SR.

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Attachment 1, Volume 13, Rev. 1, Page 67 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic trips are all automatic trips except:

a. Engine overspeed;

b. Generator differential current;

[ c. Low lube oil pressure;

d. High crankcase pressure; and

e. Start failure relay.]

The noncritical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with 8 sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The [18 month] Frequency is based on engineering judgment, taking into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DG from service. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk WOG STS B 3.8.1-24 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 67 of 286

Attachment 1, Volume 13, Rev. 1, Page 68 of 286 All changes are 1 AC Sources - Operating B 3.8.1 unless otherwise noted BASES SURVEILLANCE REQUIREMENTS (continued) insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or 8 component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

13 SR 3.8.1.14 8 Consistent with IEEE 387-1977 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires (Ref. 8), this Surveillance demonstrates demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

[2] hours of which is at a load equivalent to 110% of the continuous duty 2 rating and the remainder of the time at a load equivalent to the continuous that bounds the maximum post-accident load of duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in 8 accordance with vendor recommendations in order to maintain DG OPERABILITY.

2 The [18 month] Frequency is consistent with the recommendations of IEEE 387-1977, (Ref. 8, paragraph 6.6.2)

Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor WOG STS B 3.8.1-25 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 68 of 286

Attachment 1, Volume 13, Rev. 1, Page 69 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite 0.89 power, testing should be performed at a power factor of [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 3 allows the Surveillance to be conducted as a power at 11 factor other than [0.9]. These conditions occur when grid voltage is 0.89 high, and the additional field excitation needed to get the power factor to 11

[0.9] results in voltages on the emergency busses that are too high. 0.89 2 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be 11 such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the 11 excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained close as practicable to [0.9]

without exceeding the DG excitation limits. 0.89 14 SR 3.8.1.15 8 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within

[10] seconds. The [10] second time is derived from the requirements of 2 the accident analysis to respond to a design basis large break LOCA.

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Attachment 1, Volume 13, Rev. 1, Page 70 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) takes into consideration unit conditions required to perform The [18 month] Frequency is consistent with the recommendations of 2 the Surveillance, and is Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5).

intended to be consistent with expected fuel cycle lengths.

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to 8 avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least [2] hours at full load 2 conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

15 1.9 7 c.2.2.11 SR 3.8.1.16 8 Consistent with As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored. It also ensures that the autostart logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at rated speed and voltage, the time delay relays output breaker is open and can receive an autoclose signal on bus undervoltage, and the load sequence timers are reset.

The Frequency of [18 months] is consistent with the recommendations of 2 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), and takes into and is intended to be consideration unit conditions required to perform the Surveillance.

consistent with the expected fuel cycle lengths This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 6 is further amplified to allow the Surveillance to be performed for the , 2, 3, or 4 purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with WOG STS B 3.8.1-27 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 70 of 286

Attachment 1, Volume 13, Rev. 1, Page 71 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk 6 insights or deterministic methods may be used for this assessment.

, 2, 3, or 4 Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.17 Demonstration of the test mode override ensures that the DG availability under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.6(2).

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total 8 steps so that the entire connection and loading sequence is verified.

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated WOG STS B 3.8.1-28 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 71 of 286

Attachment 1, Volume 13, Rev. 1, Page 72 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of 8 the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. ] Credit may be taken for unplanned events that satisfy this SR.

7 8

SR 3.8.1.18 concurrent with time delay relays Under accident [and loss of offsite power] conditions loads are sequentially connected to the bus by the [automatic load sequencer]. The 2 sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The [10]% load sequence time interval tolerance ensures that Move to after SR 3.8.1.6 on sufficient time exists for the DG to restore frequency and voltage prior to page B 3.8.1-16 applying the next load and that safety analysis assumptions regarding 8 ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses. 31 days is based on operating experience The Frequency of [18 months] is consistent with the recommendations of 2 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(2), takes into 1 consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 8 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

WOG STS B 3.8.1-29 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 72 of 286

Attachment 1, Volume 13, Rev. 1, Page 73 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 9

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

16 8

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

This Surveillance demonstrates the DG operation, as discussed in the 1 Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of [18 months] takes into consideration unit conditions 2 required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of [18 months].

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally WOG STS B 3.8.1-30 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 73 of 286

Attachment 1, Volume 13, Rev. 1, Page 74 of 286 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) , 2, 3, or 4 6

performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1

, 2, 3, or 4 or 2. Risk insights or deterministic methods may be used for the 6 assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.20 This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.

6 The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9).

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

WOG STS B 3.8.1-31 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 74 of 286

Attachment 1, Volume 13, Rev. 1, Page 75 of 286 All changes are 1 AC Sources - Operating unless otherwise noted B 3.8.1 BASES USAR, Section 8.1.1.2, GDC 39, REFERENCES 1. 10 CFR 50, Appendix A, GDC 17. "Emergency Power."

U

2. FSAR, Chapter [8]. 2

3. Safety Guide 9, March 10, 1971.

7 3. Regulatory Guide 1.9, Rev. 3.

4. FSAR, Chapter [6].

U 14 2 4 5. FSAR, Chapter [15].

6. Regulatory Guide 1.93, Rev. 0, December 1974.

5 7. Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.

8. 10 CFR 50, Appendix A, GDC 18.

8 9. Regulatory Guide 1.108, Rev. 1, August 1977. IEEE 387-1977 1

9 10. Regulatory Guide 1.137, Rev. [ ], [date]. October 1979

11. ASME Code for Operation and Maintenance of Nuclear Power Plants.

12. IEEE Standard 308-1978.

WOG STS B 3.8.1-32 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 75 of 286

Attachment 1, Volume 13, Rev. 1, Page 76 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES - OPERATING

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. These punctuation corrections have been made consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes are made to be consistent with the name of the Specification.

5. This statement has been deleted since the LCO requirements for the qualified offsite circuits are described in the third paragraph of the LCO Section.

6. Changes are made to be consistent with the Specification.

7. This change is made to be consistent with the Applicability of LCO 3.8.2.

8. Changes are made to the Bases that reflect changes made to the Specification.

9. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal. The words in Actions A.2, B.2, and C.1 and C.2 have been modified since a single motor driven auxiliary feedwater (AFW) pump does not provide 100% of the required AFW flow at 100% RTP. Thus, the check must include the status of the turbine driven AFW pump.

10. Editorial change made to be consistent with similar statements in other places in the Bases.

11. Typographical/grammatical error corrected.

12. The proper title is provided for ITS 3.8.9, Distribution Systems - Operating.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 76 of 286

Attachment 1, Volume 13, Rev. 1, Page 77 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 77 of 286

Attachment 1, Volume 13, Rev. 1, Page 78 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 78 of 286

, Volume 13, Rev. 1, Page 79 of 286 ATTACHMENT 2 ITS 3.8.2, AC SOURCES - SHUTDOWN , Volume 13, Rev. 1, Page 79 of 286

, Volume 13, Rev. 1, Page 80 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 80 of 286

, Volume 13, Rev. 1, Page 81 of 286 ITS 3.8.2 Add proposed ITS LCO 3.8.2 L01 Add proposed ACTIONS A and B M01 Add proposed SR 3.8.2.1 M02 Page 1 of 1 , Volume 13, Rev. 1, Page 81 of 286

Attachment 1, Volume 13, Rev. 1, Page 82 of 286 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 CTS 3.7 does not contain any explicit Action requirements for qualified circuits and diesel generators (DGs) when these AC Sources are required to support equipment required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies. However, the CTS 1.0.e definition of OPERABLE requires that, for all equipment required to be OPERABLE, "all necessary attendant ... normal and emergency electrical power sources... that is required for the system or component to perform its intended function is also capable of performing their related support functions." Furthermore, CTS 3.7.c states, When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE ... provided its corresponding normal or emergency power source is OPERABLE and its redundant system, train, or component is OPERABLE. ITS 3.8.2 ACTIONS A and B have been added to cover the situation when the qualified offsite circuit or DG is inoperable, respectively. If the required offsite circuit is inoperable, ITS 3.8.2 ACTION A requires either the declaration that affected required feature(s) with no offsite power available are inoperable, or to suspend certain activities (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration) and to initiate action to restore required offsite power circuit to OPERABLE status. If the required DG is inoperable, ITS 3.8.2 ACTION B requires the immediate suspension of certain activities (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration) and to initiate action to restore required DG to OPERABLE status. In addition, a Note that states LCO 3.0.3 is not applicable has been added. This change adds compensatory actions for the inoperable required AC Source.

The purpose of ITS 3.8.2 ACTIONS A and B is to restrict performance of certain activities (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration) with an inoperable AC Source. CTS 3.7.c would allow these activities with an inoperable AC source as long as its corresponding normal or emergency power source is OPERABLE and all redundant required features are OPERABLE. The proposed change is acceptable because ITS 3.8.2 will require immediate action when the required AC source is inoperable regardless of the status of the other source (qualified offsite circuit or DG) or status of the redundant equipment. If the required offsite circuit is inoperable, ITS 3.8.2 ACTION A requires either declaring the affected required feature(s) with no offsite power available inoperable, or suspending certain activities (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration) and initiating action to restore the required offsite power circuit to OPERABLE status. If the required DG is inoperable, ITS 3.8.2 ACTION B requires the immediate suspension of certain activities (movement of irradiated fuel assemblies and Kewaunee Power Station Page 1 of 4 Attachment 1, Volume 13, Rev. 1, Page 82 of 286

Attachment 1, Volume 13, Rev. 1, Page 83 of 286 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN operations involving positive reactivity additions that could result in loss of required SDM or boron concentration) and initiation of action to restore the required DG to OPERABLE status. These ACTIONS are more restrictive than the current requirements; however they ensure measures are taken to limit the time certain activities (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration) are allowed to take place with any required AC source inoperable. This change also adds a Note that states LCO 3.0.3 is not applicable. This Note is necessary because if moving irradiated fuel assemblies when in MODE 5 or 6, LCO 3.0.3 would not specify any specific action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. In either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. This change is designated as more restrictive because when a required AC source is inoperable, immediate action must be taken instead of allowing an AC source to be inoperable indefinitely as long as the corresponding normal or emergency power source is OPERABLE and all redundant required features are OPERABLE.

M02 CTS 4.6 does not contain any specific Surveillance Requirements for qualified circuits and DGs when these AC Sources are required to support equipment required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies. ITS SR 3.8.2.1 requires the SRs of Specification 3.8.1, except SR 3.8.1.9 and SR 3.8.1.16 to be applicable. The Surveillance includes a Note allowing certain Surveillances to not be performed to preclude requiring the OPERABLE DG from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of the SR, or to preclude de-energizing a required 4.16 kV essential bus or disconnecting a required offsite circuit during performance of the SR. This changes the CTS by adding explicit Surveillances for the AC Sources required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies.

The purpose of ITS SR 3.8.2.1 is to ensure the AC Sources are OPERABLE.

The proposed Surveillances are consistent with those requirements that apply while the unit is operating, except for the requirements to transfer from the normal offsite circuit to the alternate offsite circuit (SR 3.8.1.9) and verification on loss of offsite power, in conjunction with a SI signal that the emergency buses de-energize and shed load, and each DG auto starts and energizes loads (SR 3.8.1.16). The Surveillance includes a Note allowing certain Surveillances to not be performed to preclude requiring the OPERABLE DG from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of the SR, and to preclude de-energizing a required 4.16 kV ESF bus or disconnecting a required offsite circuit during performance of the SR. The change is acceptable because the proposed Surveillance Requirements will help ensure the AC Sources are OPERABLE. This change is designated as more restrictive because some operating AC Sources Surveillances have been made applicable during shutdown conditions.

Kewaunee Power Station Page 2 of 4 Attachment 1, Volume 13, Rev. 1, Page 83 of 286

Attachment 1, Volume 13, Rev. 1, Page 84 of 286 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.7 does not contain any specific OPERABILITY requirements for the qualified offsite circuits and DGs during shutdown conditions. However, the CTS 1.0.e definition of OPERABLE requires that, for all equipment required to be OPERABLE, "all necessary attendant ... normal and emergency electrical power sources... that is required for the system or component to perform its intended function is also capable of performing their related support functions." Furthermore, CTS 3.7.c states, "When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE ... provided its corresponding normal or emergency power source is OPERABLE and its redundant system, train, or component is OPERABLE." New requirements were added as ITS LCO 3.8.2.a and LCO 3.8.2.b. ITS LCO 3.8.2.a requires one qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems -

Shutdown," and ITS LCO 3.8.2.b requires one DG capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10. ITS 3.8.2 is required in MODES 5 and 6 and during the movement of irradiated fuel assemblies. This changes the CTS by adding an explicit LCO for an offsite circuit and DG during MODES 5 and 6 and during the movement of irradiated fuel assemblies.

The purpose of ITS LCO 3.8.2 is to ensure that all required equipment has a source of normal power and at least one train has an emergency source of power (i.e., DGs). This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses. However, unlike the CTS 1.0.e definition, which could require both DGs to be capable of performing its related support function (depending upon what equipment is required OPERABLE), the ITS only requires one DG to be OPERABLE as long as it supplies required equipment in one train. This requirement is less restrictive since it eliminates the requirement to declare supported equipment inoperable when its associated DG is inoperable and redundant equipment is inoperable. In other words, when all required equipment of a given safety function is powered from a single electrical power distribution subsystem (i.e., the same train), the ITS does not necessarily require a DG to be OPERABLE to supply power to this required equipment. The OPERABLE DG may be the DG that is supplying power to the other train, provided equipment powered from the other train is required OPERABLE. As long as a source of AC power is available, the equipment is considered OPERABLE. This change is acceptable since; in general, when the unit is shut Kewaunee Power Station Page 3 of 4 Attachment 1, Volume 13, Rev. 1, Page 84 of 286

Attachment 1, Volume 13, Rev. 1, Page 85 of 286 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN down the Technical Specification requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required, as stated in the ISTS 3.8.2 Bases. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences.

These deviations from DBA analysis assumptions and design requirements during shutdown conditions are therefore allowed by this LCO. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

Kewaunee Power Station Page 4 of 4 Attachment 1, Volume 13, Rev. 1, Page 85 of 286

Attachment 1, Volume 13, Rev. 1, Page 86 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 86 of 286

Attachment 1, Volume 13, Rev. 1, Page 87 of 286 AC Sources - Shutdown CTS 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown DOC L01 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown" and 1

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

DOC L01 APPLICABILITY: MODES 5 and 6, During movement of [recently] irradiated fuel assemblies. 2 ACTIONS

NOTE-----------------------------------------------------------

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. One required offsite -------------------NOTE--------------------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR WOG STS 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 87 of 286

Attachment 1, Volume 13, Rev. 1, Page 88 of 286 AC Sources - Shutdown CTS 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A.2.1 Suspend CORE Immediately ALTERATIONS.

TSTF-471-A AND 1

A.2.2 Suspend movement of Immediately 2

[recently] irradiated fuel assemblies.

AND 2

TSTF-471-A A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND 3 TSTF-471-A A.2.4 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

DOC M01 B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

TSTF-471-A AND 1

B.2 Suspend movement of Immediately 2

[recently] irradiated fuel assemblies.

AND 2

TSTF-B.3 Suspend operations Immediately 471-A involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND WOG STS 3.8.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 88 of 286

Attachment 1, Volume 13, Rev. 1, Page 89 of 286 AC Sources - Shutdown CTS 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3

DOC M01 TSTF-B.4 Initiate action to restore Immediately 471-A required DG to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M02 SR 3.8.2.1 ------------------------------NOTE------------------------------

SR 3.8.1.7, and The following SRs are not required to be performed: 10 SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and 15

[SR 3.8.1.18].

3 For AC sources required to be OPERABLE, the SRs In accordance 9

of Specification 3.8.1, "AC Sources - Operating," with applicable 16 except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17, SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable. and WOG STS 3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 89 of 286

Attachment 1, Volume 13, Rev. 1, Page 90 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

1. These punctuation corrections have been made consistent with the Writers Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

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. The proper SR numbers have been used, based on changes made in ITS 3.8.1.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 90 of 286

Attachment 1, Volume 13, Rev. 1, Page 91 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 91 of 286

Attachment 1, Volume 13, Rev. 1, Page 92 of 286 AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY and during movement of [recently] irradiated fuel assemblies ensures 1 ANALYSES that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

5

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

5

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, AC electrical power is only required to mitigate fuel handling 1 accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a WOG STS B 3.8.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 92 of 286

Attachment 1, Volume 13, Rev. 1, Page 93 of 286 AC Sources - Shutdown B 3.8.2 BASES BACKGROUND (continued) significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b. Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.

d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

- Shutdown The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 2 ies LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems -

Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with a distribution system train required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 1

recently irradiated fuel]).

The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safety Feature (ESF) bus(es).

Qualified offsite circuits are those that are described in the FSAR and are 3 part of the licensing basis for the unit.

WOG STS B 3.8.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 93 of 286

Attachment 1, Volume 13, Rev. 1, Page 94 of 286 AC Sources - Shutdown B 3.8.2 BASES LCO (continued)

[ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through INSERT 1 its normal feeder breaker. The second offsite circuit consists of the 4 Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

The DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage. This sequence must be accomplished within [10] seconds. 1 The DG must be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

[ In addition, proper sequencer operation is an integral part of offsite circuit 1 OPERABILITY since its inoperability impacts on the ability to start and maintain energized loads required OPERABLE by LCO 3.8.10. ]

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of [recently] irradiated fuel assemblies provide 1 assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core, ; 5

b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 1 critical reactor core within the previous [X] days)] are available,

5

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and

5 WOG STS B 3.8.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 94 of 286

Attachment 1, Volume 13, Rev. 1, Page 95 of 286 B 3.8.2 4

INSERT 1 One qualified offsite circuit consists of the 138/4.16 kV Reserve Auxiliary Transformer, powered by the 138 kV portion of the Kewaunee Substation and normally supplying power to Bus 1-6. The other qualified offsite circuit consists of the 13.8 kV tertiary winding of the 345/138 kV Auto Transformer, powered by either the 345 kV or 138 kV portion of the Kewaunee Substation, to the 13.8/4.16 kV Tertiary Auxiliary Transformer normally supplying power to Bus 1-5. The offsite circuits also include the supply breakers to buses 1-5 and 1-6. While each circuit has connections to each 4.16 kV bus, each circuit is only required to be capable of supplying one of the 4.16 kV buses at a time. However, if only one offsite circuit is used to meet the LCO requirement, then it must be supplying both buses 1-5 and 1-6.

Insert Page B 3.8.2-3 Attachment 1, Volume 13, Rev. 1, Page 95 of 286

Attachment 1, Volume 13, Rev. 1, Page 96 of 286 AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with offsite power available may be capable of supporting TSTF-sufficient required features to allow continuation of CORE ALTERATIONS 471-A and [recently] irradiated fuel movement. By the allowance of the option to 1 declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

3 TSTF-A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 471-A With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, TSTF-therefore, required to suspend CORE ALTERATIONS, movement of 471-A 1

[recently] irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron WOG STS B 3.8.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 96 of 286

Attachment 1, Volume 13, Rev. 1, Page 97 of 286 AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued) concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for 6 minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to 6 continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in 6 order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for 9 ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 16 3, and 4. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.12 and SR 3.8.1.19 are is not required to be met because the ESF actuation signal is not required to be OPERABLE. SR 3.8.1.17 is not required to be met because the 7

required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DG(s) that is not required to be operable.

WOG STS B 3.8.2-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 97 of 286

Attachment 1, Volume 13, Rev. 1, Page 98 of 286 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES None.

WOG STS B 3.8.2-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 98 of 286

Attachment 1, Volume 13, Rev. 1, Page 99 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES - SHUTDOWN

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. Changes are made to be consistent with the name of the Specification.

3. This statement has been deleted since the LCO requirements for the qualified offsite circuits are described in the remaining sentences of the paragraph.

4. 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.

5. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

6. Typographical/grammatical error corrected.

7. Changes made to be consistent with changes made to the Specifications.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 99 of 286

Attachment 1, Volume 13, Rev. 1, Page 100 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 100 of 286

Attachment 1, Volume 13, Rev. 1, Page 101 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 101 of 286

Attachment 1, Volume 13, Rev. 1, Page 102 of 286 ATTACHMENT 3 ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL AND STARTING AIR Attachment 1, Volume 13, Rev. 1, Page 102 of 286

, Volume 13, Rev. 1, Page 103 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 103 of 286

Attachment 1, Volume 13, Rev. 1, Page 104 of 286 ITS A01 ITS 3.8.3 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries.

OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features.

SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are satisfied:

1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

See ITS 3.8.1

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

3. The 4160-V buses 1-5 and 1-6 are both energized.

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their See ITS 3.8.9 respective station service transformers.

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

See ITS 3.8.4, 3.8.6,

6. Both station batteries and both DC systems are OPERABLE, except during testing and 3.8.9 and surveillance as described in TS 4.6.b.

Add proposed LCO 3.8.3 fuel oil requirement A02

7. Both diesel generators are OPERABLE and each diesel generator shall have:

See ITS A. Day tanks containing a minimum volume of 1000 gallons; 3.8.1 LCO 3.8.3 B. An underground storage tank and corresponding day tanks containing a SR 3.8.3.1 minimum volume of 32,888 gallons of useable fuel; See ITS C. An OPERABLE diesel fuel oil transfer pump. 3.8.1

8. At least one pair of physically independent transmission lines serving the substation See ITS is OPERABLE. The three pairs of physically independent transmission lines are: 3.8.1 Add proposed ACTIONS Note M02 A. R-304 and Q-303 Add proposed ACTIONS A and E L01 B. F-84 and Y-51 Add proposed lube oil requirements (LCO 3.8.3, ACTIONS B and E, and M02 C. R-304 and Y-51 SR 3.8.3.2)

Add proposed fuel oil properties requirements (LCO 3.8.3, ACTIONS C, M02 D and E, and SR 3.8.3.3)

Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 3 Attachment 1, Volume 13, Rev. 1, Page 104 of 286

Attachment 1, Volume 13, Rev. 1, Page 105 of 286 CTS A01 ITS 3.8.3 4.1 OPERATIONAL SAFETY REVIEW APPLICABILITY Applies to items directly related to safety limits and LIMITING CONDITIONS FOR OPERATION.

OBJECTIVE To assure that instrumentation shall be checked, tested, and calibrated, and that equipment and sampling tests shall be conducted at sufficiently frequent intervals to ensure safe operation.

SPECIFICATION

a. Calibration, testing, and checking of protective instrumentation channels and testing of See other logic channels shall be performed as specified in Table TS 4.1-1. ITS SR 3.8.3.1 b. Equipment and sampling tests shall be conducted as specified in Table TS 4.1-2 and See other ITS TS 4.1-3.

c. Deleted

d. Deleted

e. Deleted M03 Add proposed SR 3.8.3.4 Amendment No. 119 TS 4.1-1 04/18/95 Page 2 of 3 Attachment 1, Volume 13, Rev. 1, Page 105 of 286

Attachment 1, Volume 13, Rev. 1, Page 106 of 286 ITS TABLE TS 4.1-3 A01 ITS 3.8.3 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS A03 EQUIPMENT TESTS(1) TEST FREQUENCY

1. Control Rods Rod drop times of all full Each REFUELING outage length rods Quarterly when at or above HOT See ITS Partial movement of all STANDBY 3.1.4 rods not fully inserted in the core 1a. Reactor Trip Breakers Independent test(2) shunt Monthly and undervoltage trip attachments See ITS 1b. Reactor Coolant Pump Breakers- OPERABILITY Each REFUELING outage 3.3.1 Open-Reactor Trip 1c. Manual Reactor Trip Open trip reactor(3) trip and Each REFUELING outage bypass breaker

2. Deleted

3. Deleted See ITS

4. Containment Isolation Trip OPERABILITY Each REFUELING outage 3.6.3

5. Refueling System Interlocks OPERABILITY Prior to fuel movement each See CTS REFUELING outage 3.8.a.11

6. Deleted See ITS

7. Deleted 3.4.15

8. RCS Leak Detection OPERABILITY Weekly(4)

SR 3.8.3.1 9. Diesel Fuel Supply Fuel Inventory(5) Weekly 31 days L02

10. Deleted See ITS 4.0

11. Fuel Assemblies Visual Inspection Each REFUELING outage See ITS

12. Guard Pipes Visual Inspection Each REFUELING outage 3.6.1

13. Pressurizer PORVs OPERABILITY Each REFUELING cycle See ITS (6) 3.4.11

14. Pressurizer PORV Block Valves OPERABILITY Quarterly See ITS

15. Pressurizer Heaters OPERABILITY(7) Each REFUELING cycle 3.4.9

16. Containment Purge and Vent OPERABILITY(8) Each REFUELING cycle See ITS Isolation Valves 3.6.3 (1)

Following maintenance on equipment that could affect the operation of the equipment, tests A03 should be performed to verify OPERABILITY.

(2)

Verify OPERABILITY of the bypass breaker undervoltage trip attachment prior to placing breaker into service.

(3) See ITS Using the Control Room push-buttons, independently test the reactor trip breakers shunt trip 3.3.1 and undervoltage trip attachments. The test shall also verify the undervoltage trip attachment on the reactor trip bypass breakers. See ITS (4)

When reactor is at power or in HOT SHUTDOWN condition. 3.4.15 (5)

Inventory of fuel required in all plant modes. A04 (6)

Not required when valve is administratively closed. See ITS 3.4.11 (7)

Test will verify OPERABILITY of heaters and availability of an emergency power supply.

(8) See ITS This test shall demonstrate that the valve(s) close in 5 seconds. 3.4.9 See ITS Amendment No. 125 Page 1 of 1 3.6.3 08/07/96 Page 3 of 3 Attachment 1, Volume 13, Rev. 1, Page 106 of 286

Attachment 1, Volume 13, Rev. 1, Page 107 of 286 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.7.a.7 states the requirements for the diesel generators (DGs), and includes a stored diesel fuel oil limit. CTS Table TS 4.1-3 Equipment Test 9 provides a Surveillance Requirement for the stored diesel fuel oil. Thus the stored diesel fuel oil limit is covered by CTS 3.7.a.7. ITS LCO 3.8.3 states, in part, that the stored diesel fuel oil shall be within limits for each required DG.

The requirements for the DGs are included in ITS 3.8.1 and 3.8.2. This changes the CTS by dividing the requirements for the DGs and the diesel fuel oil into separate Specifications.

The purpose of ITS 3.8.3 is to cover certain DG parameters. This change is acceptable because the current requirements are translated into ITS form with no technical changes. Diesel fuel oil is needed to support operation of the DGs.

The CTS and ITS maintain this relationship between the DGs and the diesel fuel oil system without any changes in the technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS Table TS 4.1-3 Equipment Test 9 requires a Fuel Inventory check on the DG fuel supply. The test is modified by Note 1, which states that following maintenance on equipment that could affect the operation of the equipment, tests should be performed to verify OPERABILITY. ITS SR 3.8.3.1 requires a similar verification, but does not include the Note concerning following maintenance that affects operation of the equipment. This changes the CTS by deleting the Note requirement.

The purpose of this type of Note is to ensure the Surveillance is performed after maintenance prior to calling the affected equipment OPERABLE. However, CTS 4.0.a and ITS SR 3.0.1 state that failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillances, shall be failure to meet the OPERABILITY requirements for the LCO. Thus, if the diesel fuel oil inventory is not within limits due to maintenance, the appropriate ACTIONS would have to be entered and remain entered until the Surveillance is performed and met. Thus, there is no reason to state this requirement individually; it applies to all Surveillances in the Technical Specifications. This change is designated as administrative since it does not result in any technical changes.

A04 CTS Table TS 4.1-3, Note 5, requires verification of diesel fuel oil inventory in all plant modes. CTS 3.7.a.7 requires a specific fuel oil inventory to support DG OPERABILITY. ITS 3.8.3 requires stored fuel oil to be within limits when the Kewaunee Power Station Page 1 of 5 Attachment 1, Volume 13, Rev. 1, Page 107 of 286

Attachment 1, Volume 13, Rev. 1, Page 108 of 286 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL associated DG is required to be OPERABLE. This changes the CTS by removing a potential conflict between two CTS statements.

This change is acceptable because the potential conflict within the CTS would be resolved by applying the requirements of CTS 4.0.a. CTS 4.0.a requires surveillance requirements to be met during the operational MODES specified in the LCO. The diesel fuel oil system is a support system for each DG. The CTS and ITS maintain this relationship between the DGs and the diesel fuel oil system without any changes in the technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.a requires the diesel generators (specified in CTS 3.7.a.7), and hence, the combined underground storage tank and corresponding day tanks level to be within the limits and be tested in accordance with Table TS 4.1-3 Equipment Test 9 when the reactor is critical. ITS LCO 3.8.3 requires the stored diesel fuel oil to be within limits "when associated DG is required to be OPERABLE."

ITS 3.8.1 requires both DGs to be OPERABLE in MODES 1, 2, 3, and 4 and ITS 3.8.2 requires one of the DGs to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies. This changes the CTS by adding requirements specifying the stored diesel fuel oil limit to be met for both DGs in MODES 3 and 4 and in MODE 2 when the reactor is not critical and for one DG in MODES 5 and 6 and during movement of irradiated fuel assemblies.

The purpose of CTS 3.7.a, in part, is to ensure the DGs are OPERABLE to mitigate the consequences of a transient or design basis accident. In ITS, the DGs are required to be OPERABLE in MODES 1, 2, 3, and 4 when an accident may occur. In MODE 1 and MODE 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODE 3 and MODE 4 the reactor is not critical, however the reactor coolant temperature is always above 200°F and there is considerable energy in the reactor coolant system and the DGs must be available to support equipment necessary to mitigate the consequences of a pipe break. One DG is required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies to be consistent with the requirements of LCO 3.8.2. Therefore, it is necessary and acceptable to require the stored diesel fuel to be within limits to ensure the DGs are OPERABLE. This change is designated as more restrictive because the LCO will be applicable under more plant conditions than in the CTS.

M02 The CTS does not provide any requirements for DG lube oil, stored diesel fuel oil total particulate level or new diesel fuel oil properties. ITS LCO 3.8.3, in part, requires the stored diesel fuel oil and lube oil to be within limits for each required DG. The Applicability for these requirements is when the associated DG is required to be OPERABLE. ITS SR 3.8.3.2 requires verification that the lube oil inventory is 504 gallons for each DG. ITS SR 3.8.3.3 requires verification that new and stored fuel oil properties are tested and maintained within limits, as specified in the Diesel Fuel Oil Testing Program. This includes stored fuel oil total particulate level and new fuel oil properties. ITS 3.8.3 ACTION B provides an ACTION if the limit of ITS SR 3.8.3.2 is not met. ITS 3.8.3 ACTION C Kewaunee Power Station Page 2 of 5 Attachment 1, Volume 13, Rev. 1, Page 108 of 286

Attachment 1, Volume 13, Rev. 1, Page 109 of 286 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL specifies the compensatory actions for one or more DGs with stored fuel oil total particulates not within limits. ITS 3.8.3 ACTION D specifies the compensatory actions for one or more DGs with new fuel oil properties not within limits. This changes the CTS by adding property limits for new and stored diesel fuel oil and a lube oil inventory limit, Surveillance Requirements to verify the limits are being maintained, and explicit ACTIONS for when the limits are not met.

The purpose of ITS SR 3.8.3.3 is to provide the appropriate limits for stored and new fuel oil properties. ITS 3.8.3 ACTIONS C and D provide explicit Required Actions and Completion Times for restoring both total particulates and stored fuel oil properties (affected by the addition of new fuel oil whose properties are not within limits) to within limits. ITS 3.8.3 ACTION C is entered as a result of a failure to meet the acceptance criterion of total particulate concentration specified in ITS 5.5.11. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures, contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not necessarily result in a failure of the fuel oil to burn properly in the diesel engine, particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, re-sampling and re-analysis of the DG fuel oil.

ITS 3.8.3 ACTION D is entered as a result of failure to meet the requirements specified in ITS 5.5.11.b. With the new fuel oil properties defined in the Bases for ITS SR 3.8.3.3 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil did not cause the stored fuel oil to be outside of the required limits, or to restore the stored fuel oil properties to within limits. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the stored fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

The purpose of the lube oil inventory requirement in ITS LCO 3.8.3 and SR 3.8.3.2 is to ensure a 7 day lube oil inventory for each DG is maintained. The proposed ITS SR 3.8.3.2 value, 504 gallons, will ensure the 7 day inventory requirement is met, based upon vendor recommendations. In addition, ITS 3.8.3 ACTION B will allow the 7 day limit to not be met for each DG for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months provided sufficient lube oil inventory is available for 6 days. If the lube oil inventory is not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if the 6 day limit is not met, then the associated DG is required to be declared inoperable immediately. Furthermore, as stated in the ITS 3.8.3 ACTIONS Note, ITS 3.8.3 ACTION B is allowed to be separately entered for each DG. Therefore, this change is acceptable.

These changes are designated as more restrictive because explicit requirements are included in the Technical Specifications for stored diesel fuel oil total particulates, new diesel fuel oil properties and lube oil inventory limits.

Kewaunee Power Station Page 3 of 5 Attachment 1, Volume 13, Rev. 1, Page 109 of 286

Attachment 1, Volume 13, Rev. 1, Page 110 of 286 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL M03 The CTS does not provide any specific testing requirements to check for or remove accumulated water from the fuel oil storage tanks. ITS SR 3.8.3.4 requires this verification every 92 days. This changes the CTS by requiring a new Surveillance Requirement to check for and remove accumulated water from the fuel oil storage tanks.

The purpose of ITS SR 3.8.3.4 is to ensure that an environment conducive to microbiological fouling does not exist. This change is acceptable because it provides additional assurance that accumulated water is removed on a regular basis to ensure an environment conducive to microbiological fouling does not exist in the fuel oil storage tanks.

This change is designated as more restrictive because an explicit Surveillance Requirement has been added to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.a.7 does not provide explicit compensatory actions if the volume of fuel oil in a storage tank and corresponding day tanks is less than the specified limit. Thus, if the minimum required volume is not met, the associated DG must be declared inoperable and CTS 3.7.b.7 must be entered. ITS 3.8.3 ACTION A allows the unit to not declare the associated DG inoperable as long as the usable volume of stored fuel oil is greater than a six day limit (i.e., > 27,961 gallons). In this situation, ITS 3.8.3 Required Action A.1 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the fuel oil volume to within limits.

As stated in the ACTIONS Note, a separate entry into this new ACTION is allowed for each DG. If this Required Action and associated Completion Time are not met or if the fuel oil storage tank usable volume is < 27,961 gallons, the associated DG must be declared inoperable immediately (ITS 3.8.3 ACTION E).

This changes the CTS by allowing the DGs to not be declared inoperable with the fuel oil storage tank and corresponding day tanks volume not within the specified Surveillance limit as long as the associated DG has enough fuel oil for 6 days of operation at rated load.

The purpose of ITS 3.8.3 ACTION A is to allow time to restore the stored diesel fuel oil volume to within the specified limit for a given DG. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to a degraded condition in order to minimize risk associated with continued operation while providing time to restore inventory. The Required Actions are consistent with safe operation under the Kewaunee Power Station Page 4 of 5 Attachment 1, Volume 13, Rev. 1, Page 110 of 286

Attachment 1, Volume 13, Rev. 1, Page 111 of 286 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The addition of ITS 3.8.3 ACTION A will allow each DG to not be declared inoperable with the associated stored diesel fuel oil volume not within the specified Surveillance limit as long as the DG has enough fuel oil for 6 days of operation at rated load. In this Condition, the 7 day fuel oil supply for the DG is not available. However, the Condition is restricted to fuel oil volume reductions that maintain at least a 6 day supply. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required fuel oil level, or feed and bleed operations, which may be necessary due to increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume prior to declaring the associated DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. This change is designated as less restrictive since less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 7 - Relaxation of Surveillance Frequency) CTS Table TS 4.1-3 Equipment Test 9 requires the diesel fuel oil inventory to be verified within limits weekly (every 7 days). ITS SR 3.8.3.1 requires the verification to be performed every 31 days. This changes the CTS by extending the Surveillance interval from 7 days to 31 days.

The purpose of the Surveillance is to verify that there is sufficient diesel fuel oil to operate the associated DG for 7 days. The change is acceptable since the DG is normally only required to be run every 31 days. Therefore, the 31 day check of the diesel fuel oil level is sufficient. Furthermore, a low level alarm is provided and the operators would be aware of any large use of diesel fuel oil during this period. This change is designated as less restrictive because a Surveillance will be performed less frequently under the ITS than under the CTS.

Kewaunee Power Station Page 5 of 5 Attachment 1, Volume 13, Rev. 1, Page 111 of 286

Attachment 1, Volume 13, Rev. 1, Page 112 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 112 of 286

Attachment 1, Volume 13, Rev. 1, Page 113 of 286 and CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS and 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air and 3.7.a.7, LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be 5 DOCs A02 within limits for each required diesel generator (DG).

and M02 3.7.a APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE-----------------------------------------------------------

DOC M02, Separate Condition entry is allowed for each DG.

DOC L01 CONDITION REQUIRED ACTION COMPLETION TIME 32,888 DOC L01 A. One or more DGs with A.1 Restore fuel oil level to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 1 fuel level < [33,000] gal within limits. 2 and > [28,285] gal in usable combined storage and day tanks storage tank. 27,961 DOC M02 B. One or more DGs with B.1 Restore lube oil inventory to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months lube oil inventory within limits. 2 504

< [500] gal and

> [425] gal.

432 DOC M02 C. One or more DGs with C.1 Restore fuel oil total 7 days stored fuel oil total particulates to within limits.

particulates not within limit.

DOC M02 D. One or more DGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limits.

not within limits.

E. One or more DGs with E.1 Restore starting air receiver 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months starting air receiver pressure to [225] psig. 5 pressure < [225] psig and [125] psig.

WOG STS 3.8.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 113 of 286

Attachment 1, Volume 13, Rev. 1, Page 114 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E E DOCs M02 F. Required Action and F.1 Declare associated DG Immediately 5 and L01 associated Completion inoperable.

Time not met.

of Condition A, 3 B, C, or D OR or One or more DGs with 5 diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than or Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY and associated day tanks 1

3.7.a.7, SR 3.8.3.1 Verify each fuel oil storage tank contains 31 days Table [33,000] gal of fuel. 2 4.1-3, #9 32,888 usable 504 for each DG DOC M02 SR 3.8.3.2 Verify lubricating oil inventory is [500] gal. 31 days 2 DOC M02 SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program SR 3.8.3.4 Verify each DG air start receiver pressure is 31 days

[225] psig. 5 92 DOC M03 SR 3.8.3.5 Check for and remove accumulated water from each [31] days 4 4

fuel oil storage tank. 5 WOG STS 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 114 of 286

Attachment 1, Volume 13, Rev. 1, Page 115 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL

1. Changes are made (additions, deletions, and/or changes) to the ISTS 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. These corrections have been made consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

4. ISTS SR 3.8.3.5 requires a check for and removal of accumulated water from each fuel oil storage tank every 31 days, and the 31 day Frequency is bracketed.

This check would normally be performed when the fuel oil storage tank particulate check required by ISTS 5.5.13.c is performed. As described in the JFDs for ITS Section 5.5, this 31 day particulate check has been changed to 92 days in the KPS ITS (ITS 5.5.11.c). Furthermore, Regulatory Guide 1.137 states that a quarterly Frequency is acceptable if the ground water table is below the bottom of the tank. The bottoms of the KPS fuel oil storage tanks are above the ground water level. Therefore, the 31 day water check required by ISTS SR 3.8.3.5 has also been extended to 92 days.

5. ISTS LCO 3.8.3 includes requirements for the starting air subsystem to be within limits for each DG. This requirement is not being added into the KPS ITS. The KPS CTS does not provide any requirements for the starting air receiver pressure. This limit is maintained outside of the CTS and under KPS control.

KPS procedurally ensures that starting air pressure is adequate to maintain the DG OPERABLE (i.e., provide adequate starting air pressure to meet the accident analysis assumptions related to DG starting requirements). In addition, the specific ACTION (ISTS ACTION E) and SR (ISTS SR 3.8.3.4) have also been deleted. Subsequent ACTIONS and SRs have been renumbered due to these deletions.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 115 of 286

Attachment 1, Volume 13, Rev. 1, Page 116 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 116 of 286

Attachment 1, Volume 13, Rev. 1, Page 117 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS and B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air and two corresponding BASES day tanks combined BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel rated load as oil capacity sufficient to operate that diesel for a period of 7 days while the 1

DG is supplying maximum post loss of coolant accident load demand U

8.2.3.2 discussed in the FSAR, Section [9.5.4.2] (Ref. 1). The maximum load 2 demand is calculated using the assumption that a minimum of any two DGs is available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

s a Fuel oil is transferred from storage tank to day tank by either of two transfer pumps associated with each storage tank. Redundancy of 1 pumps and piping precludes the failure of one pump, or the rupture of any 1 pipe, valve or tank to result in the loss of more than one DG. All outside 1

any single active tanks, pumps, and piping are located underground. /below ground level failure from affecting For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity),

and impurity level.

The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each engine oil sump contains an inventory capable of 1 supporting a minimum of [7] days of operation. [The onsite storage in 2

addition to the engine oil sump is sufficient to ensure 7 days of continuous operation.] This supply is sufficient to allow the operator to replenish lube oil from outside sources.

Each DG has an air start system with adequate capacity for five 4

successive start attempts on the DG without recharging the air start receiver(s).

WOG STS B 3.8.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 117 of 286

Attachment 1, Volume 13, Rev. 1, Page 118 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U 1 SAFETY 14 analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems 2 4

are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

and Since diesel fuel oil, lube oil, and the air start subsystem support the 3 operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). rated LCO for each DG Stored diesel fuel oil is required to have sufficient supply for 7 days of full 1 load operation. It is also required to meet specific standards for quality.

Additionally, sufficient lubricating oil supply must be available to ensure each DG at rated the capability to operate at full load for 7 days. This requirement, in 1 conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. DG day tank fuel s s

requirements, as well as transfer capability from the storage tank to the 1 day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, "AC Sources - Shutdown."

The starting air system is required to have a minimum capacity for five 4 successive DG start attempts without recharging the air start receivers.

APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it and in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support 4 and LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated DG is required to be OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required WOG STS B 3.8.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 118 of 286

Attachment 1, Volume 13, Rev. 1, Page 119 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued)

Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.

A.1 In this Condition, the 7 day fuel oil supply for a DG is not available.

However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply. These circumstances may be caused by events, such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required level prior to declaring 1

the DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

B.1 504 gal for each DG With lube oil inventory < 500 gal, sufficient lubricating oil to support 4 7 days of continuous DG operation at full load conditions may not be available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. This restriction allows sufficient time to obtain the requisite replacement volume. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the low rate of usage, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 3

This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.5. Normally, trending of particulate levels allows 5 sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

WOG STS B 3.8.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 119 of 286

Attachment 1, Volume 13, Rev. 1, Page 120 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, resampling and re-analysis of the DG fuel oil.

D.1 3 With the new fuel oil properties defined in the Bases for SR 3.8.3.4 not 5 within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

E.1 With starting air receiver pressure < [225] psig, sufficient capacity for five successive DG start attempts does not exist. However, as long as the receiver pressure is > [125] psig, there is adequate capacity for at least 4 one start attempt, and the DG can be considered OPERABLE while the air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable. This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period.

WOG STS B 3.8.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 120 of 286

Attachment 1, Volume 13, Rev. 1, Page 121 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) 4 E F.1 either or With a Required Action and associated Completion Time not met, or one 4

or more DG's fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through D, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS associated This SR provides verification that there is an adequate inventory of fuel oil 4

in the storage tanks to support each DG's operation for 7 days at full load.

and corresponding day The 7 day period is sufficient time to place the unit in a safe shutdown 1 tanks (combined) condition and to bring in replenishment fuel from an offsite location.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 504 This Surveillance ensures that sufficient lube oil inventory is available to support at least 7 days of full load operation for each DG. The [500] gal 2 requirement is based on the DG manufacturer consumption values for the run time of the DG. Implicit in this SR is the requirement to verify the capability to transfer the lube oil from its storage location to the DG, when the DG lube oil sump does not hold adequate inventory for 7 days of full load operation without the level reaching the manufacturer recommended minimum level.

A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run time are closely monitored by the unit staff.

SR 3.8.3.3 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for WOG STS B 3.8.3-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 121 of 286

Attachment 1, Volume 13, Rev. 1, Page 122 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows: 88

a. Sample the new fuel oil in accordance with ASTM D4057-[ ] 2 (Ref. 6), 5 15°C +/- 2°C 06 2

b. Verify in accordance with the tests specified in ASTM D975-[ ]

0.825 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of 1 0.83 and 0.89 or an API gravity at 60°F of 27° and 39° when 41 99 tested in accordance with ASTM D1298-[ ] (Ref. 6), a kinematic 27.5 2 viscosity at 40°C of 1.9 centistokes and 4.1 centistokes, and a 5 flash point of 125°F, and

c. Verify that the new fuel oil has a clear and bright appearance with 86 proper color when tested in accordance with ASTM D4176-[ ] or a water and sediment content within limits when tested in accordance 2 with [ASTM D2709-[ )) (Ref. 6). 5 96 Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil sample, the fuel oil is 6

analyzed to establish that the other properties specified in Table 1 of ASTM D975-[ ] (Ref. 7) are met for new fuel oil when tested in 5 06 accordance with ASTM D975-[ ] (Ref. 6), except that the analysis for 2 sulfur may be performed in accordance with ASTM D1552-[ ], 88 5 82 ASTM D2622-[ ], or ASTM D4294-[ ] (Ref. 6). The 31 day period is 98 acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil for the DGs.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

WOG STS B 3.8.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 122 of 286

Attachment 1, Volume 13, Rev. 1, Page 123 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) 6217-98 Particulate concentrations should be determined in accordance with ASTM D5452-[ ] (Ref. 6). This method involves a gravimetric 5 1 determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. [For those designs in which the total stored fuel oil volume is contained in two or more interconnected 2 tanks, each tank must be considered and tested separately.]

fuel oil storage The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

SR 3.8.3.4 This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity for each DG is available. The system design requirements provide for a minimum of [five] engine start cycles without recharging. [A start cycle is defined by the DG vendor, but usually is measured in terms of time (seconds of cranking) or engine cranking 4

speed.] The pressure specified in this SR is intended to reflect the lowest value at which the [five] starts can be accomplished.

The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to below normal air start pressure.

4 SR 3.8.3.5 4 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must 92 have a water environment in order to survive. Removal of water from the fuel storage tanks once every [31] days eliminates the necessary 4 environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may WOG STS B 3.8.3-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 123 of 286

Attachment 1, Volume 13, Rev. 1, Page 124 of 286 and Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued) come from any of several sources, including condensation, ground water, rain water, and contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance.

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance.

REFERENCES 1. FSAR, Section [9.5.4.2]. 8.2.3.2 1 2 U

6

2. Regulatory Guide 1.137. , Rev. 1

3. ANSI N195-1976, Appendix B.

4. FSAR, Chapter [6]. 1 U 14 4 5. FSAR, Chapter [15]. 88 06 99 86 5

6. ASTM Standards: D4057-[ ]; D975-[ ]; D1298-[ ]; D4176-[ ]; 1 2

[D2709-[ ];] D1552-[ ]; D2622-[ ]; D4294-[ ]; D5452-[ ].

6 96 88 82 98 6217-98 1 2

7. ASTM Standards, D975-[ ], Table 1.

06 WOG STS B 3.8.3-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 124 of 286

Attachment 1, Volume 13, Rev. 1, Page 125 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL AND LUBE OIL

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. Changes made to be consistent with the name of the Specification.

4. Changes made to be consistent with changes made to the Specification.

5. Typographical error corrected.

6. Changes are made to be consistent with similar statements in other places in the Bases.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 125 of 286

Attachment 1, Volume 13, Rev. 1, Page 126 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 126 of 286

Attachment 1, Volume 13, Rev. 1, Page 127 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.3, DIESEL FUEL OIL AND LUBE OIL There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 127 of 286

, Volume 13, Rev. 1, Page 128 of 286 ATTACHMENT 4 ITS 3.8.4, DC SOURCES - OPERATING , Volume 13, Rev. 1, Page 128 of 286

, Volume 13, Rev. 1, Page 129 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 129 of 286

Attachment 1, Volume 13, Rev. 1, Page 130 of 286 ITS ITS 3.8.4 A01 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries.

OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features.

SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are satisfied:

1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

See ITS 3.8.1

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

3. The 4160-V buses 1-5 and 1-6 are both energized.

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their See ITS respective station service transformers. 3.8.9

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

LCO 3.8.4 6. Both station batteries and both DC systems are OPERABLE, except during testing M04 and surveillance as described in TS 4.6.b.

7. Both diesel generators are OPERABLE and each diesel generator shall have:

See ITS A. Day tanks containing a minimum volume of 1000 gallons; 3.8.1 and 3.8.3 B. An underground storage tank and corresponding day tanks containing a minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:

See ITS 3.8.1 A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 Attachment 1, Volume 13, Rev. 1, Page 130 of 286

Attachment 1, Volume 13, Rev. 1, Page 131 of 286 A01 ITS ITS 3.8.4 Add proposed ACTIONS Note L02 ACTION C b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, 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 MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . M01 and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

See ITS 3.8.1

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either:

A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel M02 generator.

DC electrical power subsystem 2 ACTION B 3. One battery may be inoperable for a period not exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the L01 other battery and two battery chargers remain OPERABLE with one charger carrying the d-c supply system.

Add proposed ACTION A L01

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE.

See ITS 3.8.1

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for See ITS 3.8.9 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the redundant bus and its loads remain OPERABLE.

7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the See ITS requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: 3.8.1

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 M03 Amendment No. 194 TS 3.7-2 02/07/2008 Page 2 of 2 Attachment 1, Volume 13, Rev. 1, Page 131 of 286

Attachment 1, Volume 13, Rev. 1, Page 132 of 286 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.a requires the station batteries and chargers (specified in CTS 3.7.a.6) to be OPERABLE when the reactor is critical. In addition, CTS 3.7.b provides actions when the station batteries are inoperable during power operation or recovery from an inadvertent trip. If the inoperable battery is not restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as required by CTS 3.7.b.3, then CTS 3.7.b requires the unit to be in HOT STANDBY (ITS equivalent MODE 2) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Furthermore, for inoperabilities of the DC battery chargers or of batteries in both trains, since no actions are provided, CTS 3.0.c would also require a the unit to be subcritical within a total of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in HOT SHUTDOWN (which requires the reactor to be subcritical)). ITS LCO 3.8.4 requires the Train A and Train B DC electrical power subsystems to be OPERABLE in MODES 1, 2, 3, and 4. When a unit shutdown is required due to an inoperability of the DC electrical power subsystem, ITS 3.8.4 ACTION C requires the unit to be in MODE 3 (CTS equivalent HOT SHUTDOWN) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by requiring the batteries to be OPERABLE in MODE 3 and 4 and in MODE 2 when the reactor is not critical and provides commensurate ACTIONS to cover the new Applicability.

The purpose of CTS 3.7.a, in part, is to ensure the station batteries and chargers are OPERABLE to mitigate the consequences of a transient or design basis accident. In ITS, the station batteries and chargers are required to be OPERABLE in MODES 1, 2, 3, and 4 when a design basis accident (e.g., loss of coolant accident) may occur. In MODE 1 and MODE 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODE 3 and MODE 4 the reactor is not critical, however the reactor coolant temperature is always above 200°F and there is considerable energy in the reactor core and the station batteries and chargers must be available to support equipment necessary to mitigate the consequences of a pipe break. Therefore, it is necessary and acceptable to require the batteries and chargers to be OPERABLE. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M02 CTS 3.7.b.3 allows one battery to be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.4 ACTION B requires the restoration of an inoperable battery within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This Kewaunee Power Station Page 1 of 5 Attachment 1, Volume 13, Rev. 1, Page 132 of 286

Attachment 1, Volume 13, Rev. 1, Page 133 of 286 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING changes the CTS by reducing the time the unit can operate with one battery inoperable.

The purpose of CTS 3.7.b.3 is to minimize the time the unit continues to operate with one battery inoperable. With one battery inoperable, the remaining OPERABLE battery has the capacity to support a safe shutdown and to mitigate an accident condition. A 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is consistent with RG 1.93, and minimizes the time where a subsequent worse-case single failure could result in a loss of the remaining battery necessary to mitigate a worse case accident, yet also reflects a reasonable time to assess unit status as a function of the inoperable battery and, if the battery is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown. This change is acceptable because it requires an inoperable battery to be restored to an OPERABLE status sooner than is currently required (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months versus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). This change reduces the time the unit would be allowed to continue to operate once the condition is identified. This change is designated as more restrictive because less time is allowed to restore an inoperable battery in the ITS than is allowed in the CTS.

M03 The CTS does not provide any specific testing requirements to verify battery terminal voltage. ITS SR 3.8.4.1 requires the verification that battery terminal voltage is greater than or equal to the minimum established float voltage every 7 days. ITS SR 3.8.4.2 requires verification, every 18 months, each required battery charger can supply 150 amps at greater than or equal to the minimum established float voltage for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or to verify each required battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis discharge state.

ITS SR 3.8.4.3 requires the verification that battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test every 18 months.

ITS SR 3.8.4.3 includes an allowance (Note 1) to perform a modified performance discharge test (ITS SR 3.8.6.6) in lieu of the battery service test. In addition, Note 2 includes a restriction that the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4, but allows credit to be taken for unplanned events that satisfy the SR. This changes the CTS by adding a new Surveillance Requirements for verifying the OPERABILITY of the batteries and the required battery chargers.

The purpose of ITS SR 3.8.4.1 is to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. The purpose of ITS SR 3.8.4.2 is to ensure that the required battery chargers are OPERABLE. The purpose of ITS SR 3.8.4.3 is to ensure the batteries can satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements to satisfy the design basis duty cycle. These changes are acceptable because they provide additional assurance that the batteries and the required battery chargers are OPERABLE. These changes are designated as more restrictive because new Surveillance Requirements are added to the CTS.

Kewaunee Power Station Page 2 of 5 Attachment 1, Volume 13, Rev. 1, Page 133 of 286

Attachment 1, Volume 13, Rev. 1, Page 134 of 286 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING M04 CTS 3.7.a.6 requires both station batteries and DC systems to be OPERABLE, "except during testing and Surveillance as described in TS 4.6.b." The tests and Surveillances in TS 4.6.b all affect the batteries. ITS 3.8.4 does not include this allowance - the DC electrical power system is required to be OPERABLE even when performing Surveillance Requirements, both for this Specification and for ITS 3.8.6, "Battery Parameters," on the batteries. This changes the CTS by requiring the DC batteries to be OPERABLE while performing Surveillance Requirements in MODES 1, 2, 3, and 4.

The tests and Surveillances of CTS 4.6.b all relate to the batteries. The only Surveillance that would normally result in inoperability of a battery is CTS 4.6.b.4, which requires a load test of the battery. The other tests require various parameters to be measured, which do not result in the inoperability of the associated battery. Thus, deletion of the allowance essentially requires the load test to be performed when the unit is not in MODES 1, 2, 3, and 4 (i.e., in a condition when the battery is not required to be OPERABLE). This ensures that testing and Surveillances that render a battery inoperable are not performed in a MODE where the battery is required to mitigate an accident. This change is designated as more restrictive since a CTS allowance to perform testing and Surveillances that renders a required battery inoperable will not be allowed in the ITS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.b.3 allows one battery to be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the other battery and two battery chargers are OPERABLE with one charger carrying the DC supply system. However, the CTS does not include explicit Actions when a DC electrical power subsystem is inoperable for reasons other than an inoperable battery (e.g., inoperable charger or inoperable battery and charger). Thus, when only one battery charger is inoperable, KPS considers the associated battery still OPERABLE until the battery voltage decreases below a minimum voltage limit. At that time, both the battery charger and associated battery are inoperable and the shutdown requirements of CTS 3.0.c would apply. ITS 3.8.4 ACTION A covers the condition of one required battery charger inoperable and requires the restoration of battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the verification that battery float current is 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and the restoration of the inoperable battery charger to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If one DC electrical power subsystem is inoperable for reasons other than those specified in ITS 3.8.4 ACTION A Kewaunee Power Station Page 3 of 5 Attachment 1, Volume 13, Rev. 1, Page 134 of 286

Attachment 1, Volume 13, Rev. 1, Page 135 of 286 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING (e.g., inoperable battery and charger), ITS 3.8.4 ACTION B requires the restoration of the inoperable DC electrical power subsystem within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by providing a restoration time for an inoperable battery charger and for an inoperable battery and charger prior to requiring a plant shutdown. See DOC M02 for discussion of reducing the restoration time for an inoperable battery.

The purpose of CTS 3.7.b.3 is to provide some time to restore an inoperable battery provided only one train is affected and the buses powered from the battery remain energized. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. Proposed ITS 3.8.4 ACTION A provides a 7 day restoration time for one required battery charger inoperable. However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained, as well as availability of an alternate means to charge the battery that is capable of being supplied power from a power source that is independent of the offsite power supply. The first priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (ITS 3.8.4 Required Action A.1). Presuming that the battery discharge (if occurring) can be terminated and that the DC bus remains energized (as required by a separate LCO, ITS 3.8.4), there is reasonable basis for providing a restoration time for an inoperable charger in lieu of an immediate shutdown per LCO 3.0.c. The second tiered action proposes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours).

Given the choice of a unit shutdown in this condition (as currently required) versus a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 7 day restoration period, this is an acceptable relaxation. Since the focus of this allowance is that battery capacity be preserved and assured, the means of accomplishing this may be to utilize the spare battery charger that could be employed within the initial 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , while in other cases it may be the degraded inservice charger that can continue to float the battery. Proposed ITS 3.8.4 ACTION B provides a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration time for a DC electrical power subsystem inoperable for reasons other than Condition A. This ACTION covers the inoperabilities associated with one battery and associated charger. If one DC electrical power subsystem is inoperable, the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is consistent with Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess plant status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit Kewaunee Power Station Page 4 of 5 Attachment 1, Volume 13, Rev. 1, Page 135 of 286

Attachment 1, Volume 13, Rev. 1, Page 136 of 286 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING shutdown. These changes are designated as less restrictive because less stringent Required Actions (depending on what the specific inoperability is and how long it takes for the battery to reach its minimum voltage limit when the associated charger is inoperable) are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when a DC source is inoperable. ITS 3.8.4 also provides ACTIONS, but includes a Note that allows a DC electrical power subsystem to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. This changes the CTS by allowing a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months deferral in entering associated ACTIONS when a DC electrical power subsystem is inoperable solely due to a room cooler being non-functional.

The purpose of the CTS 3.7.b and ITS 3.8.4 ACTIONS is to adequately control how long a DC electrical power subsystem can be inoperable. The change allows an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the inoperability of the DC electrical power subsystem is due to a room cooler being non-functional, and provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without exceeding the design environmental limits for the DC electrical power subsystems. This change is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS.

Kewaunee Power Station Page 5 of 5 Attachment 1, Volume 13, Rev. 1, Page 136 of 286

Attachment 1, Volume 13, Rev. 1, Page 137 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 137 of 286

Attachment 1, Volume 13, Rev. 1, Page 138 of 286 CTS All changes are 1 DC Sources - Operating 3.8.4 unless otherwise noted 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating 3.7.a.6 LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

NOTE------------------------------------------------------

3.7.a When a DC electrical power subsystem is inoperable solely due to the room cooler being APPLICABILITY: MODES 1, 2, 3, and 4. non-functional, entry into associated ACTIONS may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 6 provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required 2 DOC L01 A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months charger[s on one train] voltage to greater than or inoperable. equal to the minimum established float voltage.

AND A.2 Verify battery float current Once per [12] hours

[2] amps.

AND A.3 Restore battery charger[s] 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4 to OPERABLE status.

[B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ] 3 on one train] inoperable. OPERABLE status.

B B 3 3.7.b.3 C. One DC electrical power C.1 Restore DC electrical [2] hours subsystem inoperable power subsystem to for reasons other than OPERABLE status.

Condition A [or B].

C 3.7.b D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion 3

Time not met. AND C D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 138 of 286

Attachment 1, Volume 13, Rev. 1, Page 139 of 286 All changes are 1 DC Sources - Operating CTS 3.8.4 unless otherwise noted SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M03 SR 3.8.4.1 Verify battery terminal voltage is greater than or 7 days equal to the minimum established float voltage.

required 2 DOC M03 SR 3.8.4.2 Verify each battery charger supplies [400] amps at [18] months greater than or equal to the minimum established float voltage for [8] hours. 150 OR required 2

Verify each battery charger can recharge the battery to the fully charged state within [24] hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

DOC M03 SR 3.8.4.3 ------------------------------NOTES-----------------------------

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed 5 to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and [18] months maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

WOG STS 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 139 of 286

Attachment 1, Volume 13, Rev. 1, Page 140 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

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. The term "required" has been added since the DC System has a spare battery charger that is common to both DC subsystems, and the spare charger can be used to meet the requirements of the LCO if the normal charger is inoperable.

3. The bracketed ISTS 3.8.4 ACTION B has been deleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been modified and renumbered, as necessary.

4. The Completion Time for ISTS 3.8.4 Required Action A.3 has been changed from 7 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change is consistent with proposed TSTF-500.

5. This allowance in the Note to SR 3.8.4.3 has been deleted, as discussed in the response to RAI GMW-013.

6. A new Note is being added to allow a DC electrical power subsystem to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time.

Current procedural guidance requires monitoring the room containing the DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without exceeding the design environmental limits for the DC electrical power subsystems.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 140 of 286

Attachment 1, Volume 13, Rev. 1, Page 141 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 141 of 286

Attachment 1, Volume 13, Rev. 1, Page 142 of 286 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating instrument BASES BACKGROUND The station DC electrical power system provides the AC emergency power system with control power. It also provides both motive and Consistent with control power to selected safety related equipment and preferred AC vital the intent of bus power (via inverters). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3). Safety 6 The [125/250] VDC electrical power system consists of two independent 2 and redundant safety related Class 1E DC electrical power subsystems

([Train A and Train B]). Each subsystem consists of [two] 125 VDC one 2 batteries [(each battery [50]% capacity)], the associated battery y

charger(s) for each battery, and all the associated control equipment and interconnecting cabling.

a 2

[ The 250 VDC source is obtained by use of the two 125 VDC batteries connected in series. Additionally there is [one] spare battery charger per are subsystem, which provides backup service in the event that the preferred battery charger is out of service. If the spare battery charger is one of 3 s the two substituted for one of the preferred battery chargers, then the requirements of independence and redundancy between subsystems are maintained. ]

During normal operation, the [125/250] VDC load is powered from the 2

battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries.

The [Train A and Train B] DC electrical power subsystems provide the control power for its associated Class 1E AC power load group, [4.16] kV 2

switchgear, and [480] V load centers. The DC electrical power subsystems also provide DC electrical power to the inverters, which in turn power the AC vital buses.

instrument The DC power distribution system is described in more detail in Bases for LCO 3.8.9, "Distribution System - Operating," and LCO 3.8.10, "Distribution Systems - Shutdown."

WOG STS B 3.8.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 142 of 286

Attachment 1, Volume 13, Rev. 1, Page 143 of 286 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES BACKGROUND (continued)

Each 125/250 VDC battery is separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystem to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between redundant Class 1E subsystems, such as batteries, battery chargers, or distribution panels.

U Each battery has adequate storage capacity to meet the duty cycle(s) 3 discussed in the FSAR, Chapter [8] (Ref 4). The battery is designed with 2 additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.

The batteries for Train A and Train B DC electrical power subsystems are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%

design demand. The minimum design voltage limit is 105/210 V.

The battery cells are of flooded lead acid construction with a nominal specific gravity of [1.215]. This specific gravity corresponds to an open 2 circuit battery voltage of approximately 120 V for a [58] cell battery (i.e.,

cell voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the 4 voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will maintain its capacity for [30] days without further charging per 2.19 to 2.29 manufacturer's instructions. Optimal long term performance however, is )

Volts per cell ( obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides 2.24 adequate over-potential, which limits the formation of lead sulfate and self 132 discharge. The nominal float voltage of [2.22] Vpc corresponds to a total float voltage output of [128.8] V for a [58] cell battery as discussed in the 2 U FSAR, Chapter [8] (Ref. 4). 59 3

Each Train A and Train B DC electrical power subsystem battery charger has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger also has sufficient excess capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the FSAR, Chapter [8] (Ref. 4). 2 Each of the three safeguard battery chargers has been sized to recharge either of the partially discharged safeguard batteries within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , while carrying its normal load. Partially discharged is defined as any condition between the battery charge condition after 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of discharge (not less than 105V) and nominal (125V).

WOG STS B 3.8.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 143 of 286

Attachment 1, Volume 13, Rev. 1, Page 144 of 286 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES BACKGROUND (continued)

The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and amp-hours returned to the battery.

APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient 14 2 SAFETY analyses in the FSAR, Chapter [6] (Ref. 5) and Chapter [15] (Ref. 6), 4 ANALYSES assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the DC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power and 5 active

b. A worst-case single failure.

ies The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 6

-Operating WOG STS B 3.8.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 144 of 286

Attachment 1, Volume 13, Rev. 1, Page 145 of 286 All changes are 1 DC Sources - Operating B 3.8.4 unless otherwise noted BASES one LCO y The DC electrical power subsystems, each subsystem consisting of [two] 2 batteries, battery charger [for each battery] and the corresponding control subsystem equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any train DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 4).

one y

An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es).

APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown."

7 ACTIONS A.1, A.2, and A.3 required 7 2 The ACTIONS are modified by a Note that Condition A represents one train with one [or two] battery chargers allows a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay in entering the inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS when a DC electrical power subsystem is inoperable solely due to the ACTIONS provide a tiered response that focuses on returning the battery room cooler being non-functional, provided the associated room temperature to the fully charged state and restoring a fully qualified charger to is monitored and maintained within the OPERABLE status in a reasonable time period. Required Action A.1 design environmental requirements and the other DC electrical power subsystem requires that the battery terminal voltage be restored to greater than or is OPERABLE. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance is equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provided in order to perform room cooler maintenance. If during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period provides for returning the inoperable charger to OPERABLE status or the other DC electrical power subsystem providing an alternate means of restoring battery terminal voltage to becomes inoperable, the associated ACTIONS for an inoperable DC electrical greater than or equal to the minimum established float voltage. Restoring power subsystem must immediately be entered. This 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is the battery terminal voltage to greater than or equal to the minimum acceptable because the room containing established float voltage provides good assurance that, within [12] hours, 2 the DC electrical power subsystems is monitored on an hourly basis to ensure the battery will be restored to its fully charged condition (Required Action conditions are within design environmental A.2) from any discharge that might have occurred due to the charger requirements of 120°F during this time.

inoperability.

WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 145 of 286

Attachment 1, Volume 13, Rev. 1, Page 146 of 286 1

All changes are DC Sources - Operating unless otherwise noted B 3.8.4 BASES ACTIONS (continued)

REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months plus the time experienced to accomplish the exponential charging 8 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown 2 with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2). 2 Required Action A.2 requires that the battery float current be verified as capable of supplying the maximum less than or equal to [2] amps. This indicates that, if the battery had been is expected load requirement. The 2 amp value is based on returning the discharged as the result of the inoperable battery charger, it has now 9 2 battery to 95% charge and assumes a been fully recharged. If at the expiration of the initial [12] hour period the 5% design margin for the battery battery float current is not less than or equal to [2] amps this indicates there may be additional battery problems and the battery must be declared inoperable.

WOG STS B 3.8.4-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 146 of 286

Attachment 1, Volume 13, Rev. 1, Page 147 of 286 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Required Action A.3 limits the restoration time for the inoperable battery charger to 7 days. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum 11 established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 7 day Completion Time reflects a reasonable time to effect restoration of the qualified battery charger to OPERABLE status. 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.1

REVIEWERS NOTE-----------------------------------

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Times of Required Actions B.1 and C.1 are in brackets. Any licensee wishing to request a longer Completion Time will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications."

Condition B represents one train with one [or two] batter[y][ies]

inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that train. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of 7

the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the batter[y][ies] will not be able to be brought online. The [2] hour limit allows sufficient time to effect restoration of an inoperable battery given that the majority of the conditions that lead to battery inoperability (e.g., loss of battery charger, battery cell voltage less than [2.07] V, etc.) are identified in Specifications 3.8.4, 3.8.5, and 3.8.6 together with additional specific Completion Times.

WOG STS B 3.8.4-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 147 of 286

Attachment 1, Volume 13, Rev. 1, Page 148 of 286 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES ACTIONS (continued)

B C.1 7 B subsystem Condition C represents one train with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's subsystem attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected train. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC distribution system train. sub If one of the required DC electrical power subsystems is inoperable for 7

reasons other than Condition A or B (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate the an accident condition. Since a subsequent worst- case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation 5

should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on consistent with Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

C D.1 and D.2 7 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems. The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

5 WOG STS B 3.8.4-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 148 of 286

Attachment 1, Volume 13, Rev. 1, Page 149 of 286 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 for the batteries REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive times the adequate current to optimally charge the battery. The voltage number of requirements are based on the nominal design voltage of the battery and connected cells are consistent with the minimum float voltage established by the battery 10 2.22 manufacturer ([2.20] Vpc or [127.6] V at the battery terminals). This for a 59 2 130.98 voltage maintains the battery plates in a condition that supports cell battery maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 8). conservative when compared Each of the battery chargers has been sized to recharge its associated partially discharged battery within 24 SR 3.8.4.2 hours, while carrying its normal load.

required 7

This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref. 9), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied. s 150 This SR provides two options. One option requires that each battery charger be capable of supplying [400] amps at the minimum established 2 float voltage for [8] hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours. 2 The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the combined largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the WOG STS B 3.8.4-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 149 of 286

Attachment 1, Volume 13, Rev. 1, Page 150 of 286 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is [2] amps.

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month] 2 intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency of [18 months] is consistent with the 6 2 7 recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months]. 2 This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing 7 following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial WOG STS B 3.8.4-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 150 of 286

Attachment 1, Volume 13, Rev. 1, Page 151 of 286 1

All changes are DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator 7

procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

6 Safety

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE-308-[1978].

U 3 4. FSAR, Chapter [8].

2

5. FSAR, Chapter [6].

14 4

6. FSAR, Chapter [15]. 2 U

5 7. Regulatory Guide 1.93, December 1974.

8. IEEE-450-[1995]. 2 6

9. Regulatory Guide 1.32, February 1977.

7

10. Regulatory Guide 1.129, December 1974.

WOG STS B 3.8.4-10 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 151 of 286

Attachment 1, Volume 13, Rev. 1, Page 152 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING

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 description of the spare battery charger has been added to the Bases.

4. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification. Furthermore, the batteries are not maintained on open circuit. Thus, these statements are deleted.

5. These punctuation corrections have been made consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

6. Changes are made to be consistent with the name of the Specification.

7. Changes are made to reflect changes made to the Specifications.

8. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

9. Addition of text represents one method of selecting the return to service limit for a battery that has been approved by the NRC.

10. Changes made to provide clarification.

11. The Completion Time for ISTS 3.8.4 Required Action A.3 has been changed from 7 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change is consistent with proposed TSTF-500.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 152 of 286

Attachment 1, Volume 13, Rev. 1, Page 153 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 153 of 286

Attachment 1, Volume 13, Rev. 1, Page 154 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.4, DC SOURCES - OPERATING There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 154 of 286

, Volume 13, Rev. 1, Page 155 of 286 ATTACHMENT 5 ITS 3.8.5, DC SOURCES - SHUTDOWN , Volume 13, Rev. 1, Page 155 of 286

, Volume 13, Rev. 1, Page 156 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 156 of 286

, Volume 13, Rev. 1, Page 157 of 286 ITS 3.8.5 Add proposed ITS 3.8.5 M01 Page 1 of 1 , Volume 13, Rev. 1, Page 157 of 286

Attachment 1, Volume 13, Rev. 1, Page 158 of 286 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirements for the DC Sources in MODES 5 and 6 and during movement of irradiated fuel assemblies. ITS LCO 3.8.5 requires one DC electrical power subsystem to be OPERABLE. An appropriate ACTION and a Surveillance Requirement are also provided. This changes the CTS by incorporating the requirements of ITS 3.8.5.

The DC electrical power system provides emergency DC electrical power to mitigate events postulated during shutdown, such as a fuel handling accident involving movement of irradiated fuel. This change is acceptable since the DC Sources - Shutdown satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). This change is designated as more restrictive because it adds new requirements, including an LCO, ACTION, and Surveillance Requirement, to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 158 of 286

Attachment 1, Volume 13, Rev. 1, Page 159 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 159 of 286

Attachment 1, Volume 13, Rev. 1, Page 160 of 286 DC Sources - Shutdown CTS 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 [DC electrical power subsystem shall be OPERABLE to support the DC 1 electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."]

INSERT 1 2 DOC M01 [One DC electrical power subsystem shall be OPERABLE.]

REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.

Action A the bracketed optional wording in Condition B are also 1 eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.

DOC M01 APPLICABILITY: MODES 5 and 6, 3

During movement of [recently] irradiated fuel assemblies.

ACTIONS

NOTE-----------------------------------------------------------

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

[A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months charger[s on one train] voltage to greater than or inoperable. equal to the minimum established float voltage.

AND AND 1 The redundant train battery and charger[s] A.2 Verify battery float current Once per [12] hours OPERABLE. [2] amps.

AND WOG STS 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 160 of 286

Attachment 1, Volume 13, Rev. 1, Page 161 of 286 3.8.5 o2 INSERT 1 to support one subsystem of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution System - Shutdown."

Insert Page 3.8.5-1 Attachment 1, Volume 13, Rev. 1, Page 161 of 286

Attachment 1, Volume 13, Rev. 1, Page 162 of 286 CTS DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore battery charger[s] 7 days ] 1 to OPERABLE status.

A B. One [or more] required B.1 Declare affected required Immediately DOC M01 DC electrical power . feature(s) inoperable. 4 subsystem[s] inoperable

[for reasons other than OR Condition A.

B.2.1 Suspend CORE Immediately OR ALTERATIONS. TSTF-471-A Required Actions and AND associated Completion 4

Time of Condition A not B.2.2 Suspend movement of Immediately TSTF-471-A met]. [recently] irradiated fuel 3 A.1 assemblies.

AND B.2.3 Suspend operations Immediately 4 TSTF-471-A involving positive reactivity A.2 additions that could result in loss of required SDM or boron concentration.

AND B.2.4 Initiate action to restore Immediately 4 TSTF-471-A required DC electrical A.3 power subsystems to OPERABLE status.

WOG STS 3.8.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 162 of 286

Attachment 1, Volume 13, Rev. 1, Page 163 of 286 CTS DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY is DOC M01 SR 3.8.5.1 -------------------------------NOTE------------------------------

The following SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3.

the For DC sources required to be OPERABLE, the In accordance 2 following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 WOG STS 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 163 of 286

Attachment 1, Volume 13, Rev. 1, Page 164 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.5 and "Reviewers Note" have been deleted since the current licensing basis does not include any requirements for the DC electrical power subsystems to be OPERABLE in MODES 5 and 6 or during movement of irradiated fuel assemblies. Therefore, the option to require one complete DC electrical power subsystem will be added, consistent with the AC Sources requirements of ITS 3.8.2. ISTS 3.8.5 ACTION A and the bracketed optional wording in Condition B have also been deleted. The subsequent Condition and Required Actions have been renumbered, as applicable.

2. The second option of ISTS LCO 3.8.5 is not specific as to what the DC electrical power subsystem must be powering. The LCO has been modified to require one DC electrical power subsystem to be powering a DC train required OPERABLE by LCO 3.8.10. Also, ISTS SR 3.8.5.1 has been modified to be consistent with the LCO (only one DC electrical power subsystem is required to be OPERABLE).

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. ISTS 3.8.5 Required Action B.1 provides an option to declare affected required feature(s) inoperable with one or more required DC electrical power subsystems inoperable. The ISTS Bases states that this is acceptable because the remaining train with DC power available may be capable of supporting sufficient features to allow continued fuel movement. Thus, this Required Action assumes two DC power sources are required by the LCO. This option has been deleted since only one DC electrical power subsystem is required to be OPERABLE by the LCO. Subsequent Required Actions have been renumbered and modified, as applicable.

5. The allowance not to perform SR 3.8.4.2 has been deleted. The KPS design includes a spare battery charger. Therefore, the battery charger SR can be performed without making the train inoperable for the entire duration of the test.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 164 of 286

Attachment 1, Volume 13, Rev. 1, Page 165 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 165 of 286

Attachment 1, Volume 13, Rev. 1, Page 166 of 286 DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient 14 SAFETY analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 1 1 2 ANALYSES assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of [recently] irradiated fuel 2 assemblies ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods, 3

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

3

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel handling 2 accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in MODES 2

[5 and 6] because the energy contained within the reactor pressure WOG STS B 3.8.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 166 of 286

Attachment 1, Volume 13, Rev. 1, Page 167 of 286 DC Sources - Shutdown B 3.8.5 BASES BACKGROUND (continued) boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

-Shutdown ies The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 4 LCO One The DC electrical power subsystems, [each required ] [the required]

[subsystem consisting of two batteries, one battery charger per battery, one and the corresponding control equipment and interconnecting cabling y subsystem within the train, [are] [is] required to be OPERABLE to support [required]

[one] train[s] of the distribution systems [required OPERABLE by 2 LCO 3.8.10, "Distribution Systems - Shutdown."] This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling recently irradiated fuel]). i.e.

and inadvertent dilution events WOG STS B 3.8.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 167 of 286

Attachment 1, Volume 13, Rev. 1, Page 168 of 286 DC Sources - Shutdown B 3.8.5 BASES 5

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies, 2 provide assurance that: 5 s

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core, 3

b. Required features needed to mitigate a fuel handling accident

[involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] are 2 available,

3

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and 3

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2, and A.3

REVIEWERS NOTE-----------------------------------

ACTION A is included only when plant-specific implementation of 5

LCO 3.8.5 includes the potential to require both trains of the DC System to be OPERABLE. If plant-specific implementation results in LCO 3.8.5 requiring only one trains of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.

WOG STS B 3.8.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 168 of 286

Attachment 1, Volume 13, Rev. 1, Page 169 of 286 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

Condition A represents one train with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 5

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months plus the time experienced to accomplish the exponential charging current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

WOG STS B 3.8.5-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 169 of 286

Attachment 1, Volume 13, Rev. 1, Page 170 of 286 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as 5

less than or equal to [2] amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial [12] hour period the battery float current is not less than or equal to [2] amps this indicates there may be additional battery problems and the battery must be declared inoperable.

Required Action A.3 limits the restoration time for the inoperable battery charger to 7 days. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 7 day Completion Time reflects a reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

A.1, A.2, and A.3 TSTF-5 B.1, B.2.1, B.2.2, B.2.3, and B.2.4 471-A

[If two trains are required by LCO 3.8.10, the remaining train with DC power available may be capable of supporting sufficient systems to allow TSTF-With the required DC continuation of CORE ALTERATIONS and [recently] irradiated fuel 471-A electrical power movement]. By allowing the option to declare required features subsystem inoperable, the minimum required inoperable with the associated DC power source(s) inoperable, 5 DC electrical power appropriate restrictions will be implemented in accordance with the subsystem is not available. Therefore, affected required features LCO ACTIONS. In many instances this option suspension of the may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE TSTF-471-A ALTERATIONS, movement of [recently] irradiated fuel assemblies, and operations involving positive reactivity additions) that could result in loss 2 of required SDM (MODE 5) or boron concentration (MODE 6). is required Suspending positive reactivity additions that could result in failure to meet WOG STS B 3.8.5-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 170 of 286

Attachment 1, Volume 13, Rev. 1, Page 171 of 286 DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from 6

Reactor Coolant System ( sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration.

) 6 This may result in an overall reduction in RCS boron concentration, but Moderator Temperature provides acceptable margin to maintaining subcritical operation.

Coefficient ( Introduction of temperature changes including temperature increases 6

when operating with a positive MTC must also be evaluated to ensure

) they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystem[s] and to continue this action until restoration is accomplished 2 in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible 5 in order to minimize the time during which the unit safety systems may be without sufficient power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

1 REFERENCES 1. FSAR, Chapter [6].

1 U 14 2

2. FSAR, Chapter [15].

WOG STS B 3.8.5-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 171 of 286

Attachment 1, Volume 13, Rev. 1, Page 172 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5 BASES, DC SOURCES - SHUTDOWN

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. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

4. Changes are made to be consistent with the name of the Specification.

5. Changes are made to the Bases which reflect changes made to the Specifications.

6. Typographical/grammatical error corrected.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 172 of 286

Attachment 1, Volume 13, Rev. 1, Page 173 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 173 of 286

Attachment 1, Volume 13, Rev. 1, Page 174 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 174 of 286

, Volume 13, Rev. 1, Page 175 of 286 ATTACHMENT 6 ITS 3.8.6, BATTERY PARAMETERS , Volume 13, Rev. 1, Page 175 of 286

, Volume 13, Rev. 1, Page 176 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 176 of 286

Attachment 1, Volume 13, Rev. 1, Page 177 of 286 ITS ITS 3.8.6 A01 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries.

OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features.

SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are satisfied:

1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

See ITS 3.8.1

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

3. The 4160-V buses 1-5 and 1-6 are both energized.

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their See ITS respective station service transformers. 3.8.9

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

Add proposed LCO 3.8.6 A02

6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b.

7. Both diesel generators are OPERABLE and each diesel generator shall have:

A. Day tanks containing a minimum volume of 1000 gallons; See ITS 3.8.1 and B. An underground storage tank and corresponding day tanks containing a 3.8.3 minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:

See ITS 3.8.1 A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 3 Attachment 1, Volume 13, Rev. 1, Page 177 of 286

Attachment 1, Volume 13, Rev. 1, Page 178 of 286 A01 ITS ITS 3.8.6

b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, 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 .

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

See ITS Add proposed 3.8.1 ACTIONS Note

2. One diesel generator may be inoperable for a period not exceeding 7 days provided and ACTIONS within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either:

A, B, C, D, E and F.

A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel L01 generator.

3. One battery may be inoperable for a period not exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the other battery and two battery chargers remain OPERABLE with one charger carrying the d-c supply system.

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE.

See ITS 3.8.1

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for See ITS 3.8.9 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the redundant bus and its loads remain OPERABLE.

7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the See ITS requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: 3.8.1

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Amendment No. 194 TS 3.7-2 02/07/2008 Page 2 of 3 Attachment 1, Volume 13, Rev. 1, Page 178 of 286

Attachment 1, Volume 13, Rev. 1, Page 179 of 286 ITS A01 ITS 3.8.6

5. Each diesel generator shall be operated for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months every operating cycle:

Note 1 Momentary transients outside the load and power factor ranges do not invalidate this test.

Note 2 This Surveillance shall not normally be performed in the OPERATING or HOT STANDBY MODE. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this surveillance requirement.

Note 3 If performed with the diesel generator synchronized with offsite power, it See ITS shall be performed at a power factor 0.89. However, if grid conditions 3.8.1 do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

A. For 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded to 2860 KW (nominal) and, B. For the remaining hours of the test loaded to 2700 KW (nominal).

6. Safeguard bus undervoltage and safeguard bus second level undervoltage relays See ITS shall be calibrated at least once per operating cycle. 3.3.5 Add proposed voltage limit

b. Station Batteries M03 Add proposed SR 3.8.6.1 M02 LA01 SR 3.8.6.2, 1. The voltage of each cell shall be measured to the nearest hundredth volt each SR 3.8.6.5 month. An equalizing charge shall be applied if the lowest cell in the battery falls L07 SR 3.8.6.4 < 2.13 volts. The temperature and specific gravity of a pilot cell in each battery L03 shall be measured. Add proposed L02 M03 31 days M04 92 days for non-pilot cells temperature limit SR 3.8.6.3 2. The following additional measurements shall be made quarterly: the specific gravity L03 and height of electrolyte in every cell and the temperature of every fifth cell. L04 Add proposed level limit M03

3. All measurements shall be recorded and compared with previous data to detect L07 signs of deterioration.

L05 SR 3.8.6.6 4. The batteries shall be subjected to a load test during the first REFUELING and A03 once every 5 years thereafter. Battery voltage shall be monitored as a function of time to establish that the battery performs as expected during heavy discharge and L06 that all electrical connections are tight.

Add proposed battery capacity limit M05 Add proposed SR 3.8.6.6 2nd and 3rd Frequencies M06 Add proposed Note to SR 3.8.6.6 M07 Amendment No. 191 TS 4.6-2 05/01/2007 Page 3 of 3 Attachment 1, Volume 13, Rev. 1, Page 179 of 286

Attachment 1, Volume 13, Rev. 1, Page 180 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.7.a.6, in part, requires the batteries to be OPERABLE. CTS 4.6.b provides Surveillance Requirements for various battery parameters. Thus, the battery parameter requirements are covered by CTS 3.7.a.6. ITS 3.8.6 requires the battery parameters to be within limits. The requirements for the batteries are included in ITS 3.8.4 and ITS 3.8.5. This changes the CTS by dividing the requirements for the batteries and the requirements for battery parameters into separate Specifications.

The purpose of ITS 3.8.6 is to cover the battery parameter requirements for the batteries. There are no technical changes as a result of treating battery parameters as a separate Technical Specification since it simply converts the CTS into the format of the ITS. Any technical changes to the battery parameters are discussed below. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 4.6.b.4 requires performance of a "load test" (i.e., a "performance discharge test" in the ITS) during the "first REFUELING." ITS SR 3.8.6.6 requires the battery capacity to be verified, however it does not explicitly include a Frequency of "during the first Refueling." This changes the CTS by deleting a specific time for performing the Surveillance.

KPS has completed its first Refueling. Therefore, specifying an initial performance requirement for the SR is unnecessary. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.a requires the station batteries (specified in CTS 3.7.a.6), and hence, the battery parameters tested as specified in CTS 4.6.b, to be within limits when the reactor is critical. ITS LCO 3.8.6 requires the Train A and Train B battery parameters to be within limits "when associated DC electrical power subsystems are required to be OPERABLE." ITS 3.8.4 requires both Train A and Train B batteries to be OPERABLE in MODES 1, 2, 3, and 4 and ITS 3.8.5 requires one of the Train A or B battery to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies. This changes the CTS by requiring the batteries parameters to be within limits for both batteries in MODE 3 and 4 and in MODE 2 when the reactor is not critical and for one battery in MODES 5 and 6 and during movement of irradiated fuel assemblies.

Kewaunee Power Station Page 1 of 8 Attachment 1, Volume 13, Rev. 1, Page 180 of 286

Attachment 1, Volume 13, Rev. 1, Page 181 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The purpose of CTS 3.7.a, in part, is to ensure the station batteries are OPERABLE to mitigate the consequences of a transient or design basis accident. The station batteries are required to be OPERABLE in MODES 1, 2, 3, and 4 when a design basis accident (e.g., loss of coolant accident) may occur. In MODE 1 and MODE 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODE 3 and MODE 4 the reactor is not critical, however the reactor coolant temperature is always above 200°F and there is considerable energy in the reactor core and the station batteries must be available to support equipment necessary to mitigate the consequences of a pipe break. The station batteries are required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies so that the unit can be maintained in the shutdown or refueling condition for extended periods, to ensure sufficient instrumentation and control capability is available for monitoring and maintaining unit status, and to mitigate events postulated during shutdown, such as a fuel handling accident. Therefore, it is necessary and acceptable to require the batteries parameters to be within limits to ensure the batteries are OPERABLE. This change is designated as more restrictive because the LCO will be applicable under more conditions than in the CTS.

M02 CTS 4.6.b, which specifies the Surveillances for the batteries, does not provide any Surveillances on battery float current. ITS SR 3.8.6.1 requires verification every 7 days that each battery float current is 2 amps. However, as Noted, this requirement is not required to be met when battery terminal voltage is less than the limit of SR 3.8.4.1. This changes the CTS by adding an explicit Surveillance for battery float current.

The purpose of SR 3.8.6.1 is to assist in the determination of the state of charge of the battery while the purpose of ITS SR 3.8.6.2 is to ensure the battery cell voltages are greater than or equal to the short-term absolute minimum voltage.

The specified float current is based on the float current that is indicative of a charged battery and the required pilot cell float voltage ensures optimal long-term battery performance. These Surveillances are consistent with IEEE 450. This change is acceptable since the Surveillances are necessary to help ensure the batteries remain OPERABLE. This change is designated as more restrictive because explicit Surveillance Requirements have been added.

M03 CTS 4.6.b.1 requires each cell voltage and each pilot cell temperature to be measured. However, no voltage or temperature limit is provided in the CTS.

CTS 4.6.b.2 requires the electrolyte level in each cell to be measured. However, no level limit is provided in the CTS. ITS SR 3.8.6.2 and SR 3.8.6.5 require verification that each pilot cell voltage and battery connected cell voltage, respectively, is 2.07 V. ITS SR 3.8.6.4 requires verification that each pilot cell temperature is greater than or equal to minimum established design limits. ITS SR 3.8.6.3 requires verification that each battery connected cell electrolyte level is greater than or equal to minimum established design limits. This changes the CTS by specifying an acceptance criteria for battery cell voltage, temperature, and electrolyte level limits.

The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 and SR 3.8.6.5 is to ensure the cell voltages are greater than or equal to the short term absolute minimum voltage. The purpose of the proposed Surveillance limit in ITS Kewaunee Power Station Page 2 of 8 Attachment 1, Volume 13, Rev. 1, Page 181 of 286

Attachment 1, Volume 13, Rev. 1, Page 182 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS SR 3.8.6.4 is to help ensure the battery can provide required current and voltage to meet the design requirements. The purpose of the proposed Surveillance limit in ITS SR 3.8.6.3 is to ensure that the battery plates suffer no physical damage and maintains adequate electron transfer capability. This change is acceptable because limits are specified for cell voltage, temperature, and electrolyte level where they were not previously specified. This change is designated as more restrictive because more stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

M04 CTS 4.6.b.2, in part, requires measurement of the electrolyte level of each battery cell every 92 days. ITS SR 3.8.6.3 requires verification that each battery connected cell electrolyte level is greater than or equal to the established limit every 31 days. This changes the CTS by increasing the Frequency of performance of the Surveillance from 92 days to 31 days.

The purpose of CTS 4.6.b.2 is to ensure the electrolyte level is within the specified limit to ensure the battery plates suffer no physical damage and maintains adequate electron transfer capability. IEEE 450 recommends a Surveillance Frequency of 31 days. The change is acceptable since it will help ensure the battery plates will not suffer physical damage and maintain adequate electron transfer capability. This change is designated as more restrictive because the Surveillance Requirement Frequency has been increased.

M05 CTS 4.6.b.4 requires the "load test" (i.e., a "performance discharge test" in the ITS) to be performed, but it does not provide an acceptance limit. ITS SR 3.8.6.6 requires the same test, but provides a capacity limit of 80% of the manufacturer's rating. This changes the CTS by specifying the battery capacity limit.

The purpose of CTS 4.6.b.4 is to verify the capacities of the batteries are acceptable. ITS SR 3.8.6.6 includes the acceptance criteria for verifying the battery capacity consistent with the current Kewaunee practice. Although this change is consistent with current plant practice, adding the acceptance criteria is an additional restriction on unit operation since the control of this requirement will now be governed by Technical Specifications. This change is designated as more restrictive because it adds a specific limit to the CTS where non previously existed.

M06 CTS 4.6.b.4 requires the "load test" (i.e., a "performance discharge test" in the ITS) to be performed every 5 years. ITS SR 3.8.6.6 is performed every 60 months, every 12 months when the battery shows degradation or has reached 85% if the expected life with capacity < 100% of manufacturer's rating, and every 24 months when the battery has reached 85% of the expected life with capacity 100% of manufacturer's rating. This changes the CTS by adding accelerated Frequencies of 24 months if the battery has reached 85% of expected life, provided the battery capacity is 100% of the manufacturer's rating, and 12 months if the battery has reached 85% of expected life and the capacity is

< 100% of manufacturer's rating.

The purpose of CTS 4.6.b.4 is to ensure the battery capacity is 90% of the manufacturer's rating. ITS SR 3.8.6.6 adds accelerated Frequencies for when Kewaunee Power Station Page 3 of 8 Attachment 1, Volume 13, Rev. 1, Page 182 of 286

Attachment 1, Volume 13, Rev. 1, Page 183 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS the battery shows signs of degradation or when the battery has reached 85% of the expected life. The accelerated Frequencies are every 12 months when the battery show degradation, or has reached 85% of the expected life with capacity

< 100% of manufacturer's rating, and 24 months when the battery has reached 85% of the expected life with capacity 100% of manufacturer's rating. This change is acceptable since the battery capacity test will be determined more often when the battery show signs of degradation, or when it has reached 85% of its expected life, to ensure its capacity does not decrease below 90% of the manufacturers rating. This change is designated as more restrictive because Surveillances will be performed more frequently under the ITS than under the CTS.

M07 CTS 4.6.b.4 requires performance of a "load test" (i.e., a "performance discharge test" in the ITS), but it does not provide any restrictions for when the test may be performed. In addition, CTS 3.7.a.6, which requires the batteries to be OPERABLE, states that they are not required when the tests and Surveillances of CTS 4.6.b are being performed. Thus, the CTS allows CTS 4.6.b.4 to be performed while critical. ITS SR 3.8.6.6 requires the same test, however a Note to SR 3.8.6.6 specifies that this Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. This changes the CTS by adding a specific restriction as to when the Surveillance can be performed.

Currently, this Surveillance could be performed while critical as allowed by CTS 3.7.a.6. However, performing the Surveillance would render one of the two station batteries inoperable and during this time, a single failure in the remaining battery concurrent with an accident would place the unit in a condition such that the accident analysis cannot be met. Therefore, the addition of this Note is acceptable since it will ensure that routine testing will not be performed that renders one of the two batteries inoperable in MODES 1, 2, 3, and 4. This change is designated as more restrictive since a new requirement is being added to ensure SR 3.8.6.6 is not routinely performed when the associated battery is required to be OPERABLE.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.b.1 requires each battery cell voltage to be measured "to the nearest hundredth volt." ITS SR 3.8.6.2 and 3.8.6.5 requires verification that each pilot cell voltage and battery connected cell voltage, respectively is 2.07 V. This changes the CTS by relocating the details that the cell voltage measurement be "to the nearest hundredth volt" to the Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate Kewaunee Power Station Page 4 of 8 Attachment 1, Volume 13, Rev. 1, Page 183 of 286

Attachment 1, Volume 13, Rev. 1, Page 184 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS protection of public health and safety. The ITS still retains the requirement that the cell voltage be measured and be within a specified limit. The details of how the cell voltages are measured does not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the CTS.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.b.3 allows one battery to be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a reactor shutdown is required. This Action is applicable when the battery is inoperable due to battery parameters not within limits. In lieu of this current Action under these conditions, the ITS 3.8.6 ACTIONS provide compensatory actions when battery parameters are not within limits, to be taken prior to declaring the associated battery inoperable. This changes the CTS by replacing the current Action with new compensatory actions for battery parameters not within limits.

The purpose of the ITS 3.8.6 ACTIONS is to allow a certain amount of time to restore battery parameters to within limits before declaring the associated battery inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, time for repairs or replacement, and the low probability of a DBA occurring during the repair period. ACTIONS have been added to allow a short time period to restore parameters to within limits.

ITS 3.8.6 ACTION A covers the condition of one battery with one or more battery cells float voltage less than the specified limit, and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the performance of SR 3.8.6.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and restoration of the affected cell voltage to within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.6 ACTION B covers the condition of one battery with float current not within the specified limit, and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and restoration of the battery float current to within limits within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.8.6 ACTION C covers the condition of one battery with one or more cells electrolyte level less than minimum established design limits, and requires the restoration of electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , verification that there is no evidence of leakage within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and restoration of electrolyte level to greater than or equal to the minimum established design limits within 31 days. ITS 3.8.6 ACTION D covers the condition of one battery with pilot cell electrolyte temperature less than the minimum established design limits, and requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.8.6 ACTION E covers the condition of two batteries with battery parameters not within limits, and requires Kewaunee Power Station Page 5 of 8 Attachment 1, Volume 13, Rev. 1, Page 184 of 286

Attachment 1, Volume 13, Rev. 1, Page 185 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS restoration of the battery parameters for one battery to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Thus, the allowed restoration times provided in ACTIONS A, B, C, and D are allowed only if one of the two batteries is affected. This ensures that, while in the Conditions for ACTIONS A, B, C, and D, one battery is still OPERABLE.

ITS 3.8.6 ACTION F covers the conditions when a Required Action and associated Completion Time of any of the above ACTIONS cannot be met, if one battery with one or more battery cells float voltage and float current are not within limits, or if SR 3.8.6.6 is not met, and requires the immediate declaration that the associated battery is inoperable. ITS 3.8.6 ACTIONS Note is also included and allows separate Condition entry for each battery. The allowances are considered acceptable since only a short time is allowed to exist with battery parameters not within limits. In addition, when redundant batteries have battery parameters not within limit, only 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is allowed to restore at least one redundant division before declaring the battery inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 7 - Relaxation Of Surveillance Frequency) CTS 4.6.b.1 requires, in part, the verification that the cell voltage is within limits every month. ITS SR 3.8.6.5 requires verification of each battery connected cell voltage every 92 days.

This changes the CTS by extending the Surveillance interval for verification of cell voltage from 31 days to 92 days.

The purpose of ITS 3.8.6.5 is to ensure the cell voltages are equal to or greater than the short-term absolute minimum voltage. This change extends the Surveillance Frequency from 31 days to 92 days for verification of cell float voltage. This change is acceptable since ITS 5.5.15, "Battery Monitoring and Maintenance Program," has been added which requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the ITS SR 3.8.6.5 limit of 2.07 V. Furthermore, ITS SR 3.8.6.2, which measures the pilot cell voltages, is still being maintained at a 31 day Frequency. In addition, the Frequency is consistent with IEEE-450-1987. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L03 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.b.1 requires measurement of each pilot cell specific gravity every month and CTS 4.6.b.3 requires measurement of specific gravity for each cell every quarter. ITS 3.8.6 does not include these specific gravity Surveillances. This changes the CTS by deleting these specific gravity Surveillances.

The purpose of the specific gravity measurements of CTS 4.6.b.1 and CTS 4.6.b.3, is to ensure the state of charge of each cell. This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the equipment used to meet the LCO can perform its required function.

Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. While the specified Surveillances have been deleted, other Surveillances are included which help to ensure the batteries will function as designed. ITS SR 3.8.6.1 (discussed in DOC M01) requires the verification that each battery float current is 2 amps every 7 days. IEEE 450-1987, Section Kewaunee Power Station Page 6 of 8 Attachment 1, Volume 13, Rev. 1, Page 185 of 286

Attachment 1, Volume 13, Rev. 1, Page 186 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 4.5 states that the most accurate indicator of return to full charge is a stabilized charging or float current. Specific gravity readings may not be accurate when the battery is on charge following a discharge. These Surveillances give a better indication of the overall battery conditions. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.b.2 requires verification of the temperature of every fifth cell every quarter. ITS 3.8.6 does not include this Surveillance. This changes the CTS by deleting this Surveillance.

The purpose of the temperature verification portion of CTS 4.6.b.2 is to ensure the battery will be able to provide the required current and voltage to meet the design requirements. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions; other Surveillances ensure the equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function.

While the specified Surveillances have been deleted, other Surveillances are included which help to ensure the batteries will function as designed. ITS SR 3.8.6.4 requires verification of each battery pilot cell temperature is within limit.

This Surveillance is sufficient to ensure the electrolyte temperature throughout the battery is acceptable to provide the required current and voltage to meet the design requirements, since all battery cells for a battery are in the same room.

This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L05 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.b.4 requires the performance of a "load test" of the batteries. ITS SR 3.8.6.6 requires the performance of a "performance discharge" test or a "modified performance discharge" test. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test (equivalent to the load test).

The purpose of CTS 4.6.b.4 is to verify the capacities of the batteries are acceptable. This change is acceptable because it has been determined, as described below, that the relaxed Surveillance Requirement test method for verification that the equipment used to meet the LCO can perform its required functions is acceptable. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test. The modified performance discharge test is performed by simulating the duty cycle consisting of two rates: 1 min rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test. Since the ampere-hours removed by a rated 1 min discharge represent a very small portion of the batterys capacity, the test rate can be changed to that for the performance test without compromising the results of the performance test. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Kewaunee Power Station Page 7 of 8 Attachment 1, Volume 13, Rev. 1, Page 186 of 286

Attachment 1, Volume 13, Rev. 1, Page 187 of 286 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS L06 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.b.4 requires the performance of a load test. During this test, the CTS also requires that the battery voltage be monitored as a function of time to establish that the battery performs as expected during heavy discharge and that all electrical connections are tight. ITS SR 3.8.6.6 requires a similar battery test; however, the battery voltage monitoring as a function of time and monitoring that the connections are tight during the test is not included. This changes the CTS by deleting the measurement requirements that are required to be taken during performance of the test.

The purpose of CTS 4.6.b.4 is to measure the battery capacity and ensure the battery is still capable of performing its function. The ITS still retains the requirement to perform the test, and includes an actual limit that was not previously specified (as discussed in DOC M05). The requirement to periodically measure the voltage as a function of time is not necessary since it is information that is normally specified in the procedures used to perform the test.

Furthermore, the "connections are tight" requirement is also not needed since this is a maintenance type activity and is more appropriately located in plant test procedures. Theses deletions are acceptable because the necessary requirements and limits are being maintained in the ITS. This change is designated as less restrictive because the manner in which the test is performed is not being retained in the ITS.

L07 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.b.1, in part, requires an equalizing charge to be performed if the lowest cell in the battery falls

< 2.13 volts. CTS 4.6.b.3 requires that all measurements be recorded and compared with previous data to detect signs of deterioration. The ITS does not include these specific requirements. This changes the CTS by deleting the equalizing charge requirement and the comparison of parameters from past tests requirement.

The purpose of the equalizing charge requirement in CTS 4.6.b.1 is to help restore the battery to a fully charged state. The purpose of CTS 4.6.b.3 is to trend the battery parameters to detect degradation. Trending of parameters to detect degradation is a method to detect long term problems, not immediate OPERABILITY concerns. Both of these requirements are maintenance type functions. ITS 3.8.6 includes Surveillances (SRs 3.8.6.1, 3.8.6.2, 3.8.6.3, and 3.8.6.4) that verify critical battery parameters are within the necessary limits to maintain the battery OPERABLE. These Surveillances provide adequate assurance that the battery is OPERABLE. Furthermore, the ITS includes a Battery Monitoring and Maintenance Program (ITS 5.5.15). The Program provides for battery restoration and maintenance. Therefore, these Surveillances and the Battery Monitoring and Maintenance Program provide assurance of battery OPERABILITY and that necessary monitoring and maintenance will be performed. This change is designated as less restrictive because Surveillance Requirements are not being retained in the ITS.

Kewaunee Power Station Page 8 of 8 Attachment 1, Volume 13, Rev. 1, Page 187 of 286

Attachment 1, Volume 13, Rev. 1, Page 188 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 188 of 286

Attachment 1, Volume 13, Rev. 1, Page 189 of 286 Battery Parameters CTS 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters

REVIEWER'S NOTE-------------------------------------------------

Licensees must implement a program, as specified in Specification 5.5.17, to monitor battery parameters that is based on the recommendations of IEEE Standard 450-1995, "IEEE 1 Recommended Practice For Maintenance, Testing, And Replacement Of Vented Lead-Acid Batteries For Stationary Applications."

DOC A02, LCO 3.8.6 Battery parameters for Train A and Train B batteries shall be within limits.

3.7.a.6 electrical power subsystem 6 3.7.a APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS

NOTE-----------------------------------------------------------

DOC L01 Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. One [or two] batter[y][ies A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months on one train] with one or 2 more battery cells float AND voltage < [2.07] V.

A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND A.3 Restore affected cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 2

voltage [2.07] V.

DOC L01 B. One [or two] batter[y][ies B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2

on one train] with float current > [2] amps. AND B.2 Restore battery float current [12] hours 2 to [2] amps.

WOG STS 3.8.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 189 of 286

Attachment 1, Volume 13, Rev. 1, Page 190 of 286 CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE-------------- -------------------NOTE--------------------

Required Action C.2 shall be Required Actions C.1 and C.2 are completed if electrolyte level only applicable if electrolyte level was below the top of plates. was below the top of plates.

DOC L01 C. One [or two] batter[y][ies C.1 Restore electrolyte level to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2 on one train] with one or above top of plates.

more cells electrolyte level less than minimum AND established design limits. C.2 Verify no evidence of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leakage.

AND C.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits.

DOC L01 D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2 on one train] with pilot temperature to greater than cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

Two DOC L01 E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 3 redundant trains with for batteries in one train to one battery parameters not within limits.

y within limits.

WOG STS 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 190 of 286

Attachment 1, Volume 13, Rev. 1, Page 191 of 286 Battery Parameters CTS 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR One [or two] batter[y][ies 2 on one train] with one or more battery cells float OR voltage < [2.07] V and 2 4

float current > [2] amps. SR 3.8.6.6 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M02 SR 3.8.6.1 -------------------------------NOTE------------------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

2 Verify each battery float current is [2] amps. 7 days float 6 4.6.b.1 SR 3.8.6.2 Verify each battery pilot cell voltage is [2.07] V. 31 days 2 4.6.b.2 SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than or equal to minimum established design limits.

4.6.b.1 SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits.

WOG STS 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 191 of 286

Attachment 1, Volume 13, Rev. 1, Page 192 of 286 Battery Parameters CTS 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY float 6 4.6.b.1 SR 3.8.6.5 Verify each battery connected cell voltage is 92 days 2

[2.07] V.

4.6.b.4 SR 3.8.6.6 -------------------------------NOTE------------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines 5 the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is [80%] of the 60 months 2 manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation, or has reached 2

[85]% of the expected life with capacity < 100%

of manufacturer's rating AND 24 months when battery has reached [85]% of 2 the expected life with capacity 100% of manufacturer's rating WOG STS 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 192 of 286

Attachment 1, Volume 13, Rev. 1, Page 193 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6, BATTERY PARAMETERS

1. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

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. ISTS 3.8.6 ACTION E has been modified to reflect the Kewaunee design consisting of one battery per train. Therefore, when both redundant train batteries are affected, the Condition refers to two batteries and requires the restoration of battery parameters to within limits for one battery within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

4. ISTS SR 3.8.6.6 requires a battery performance discharge or modified performance discharge test to be performed and provides acceptance criteria.

However, no ACTION is provided in the ISTS 3.8.6 ACTIONS for when this SR is not met. Thus in the ISTS, LCO 3.0.3 would have to be entered. To preclude an LCO 3.0.3 entry, ISTS 3.8.6 Condition F has been modified to cover the case when SR 3.8.6.6 is not met. ACTION F will require the associated battery to be declared inoperable. This is also consistent with the current Technical Specification requirements.

5. The allowance has been deleted consistent with TSTF-360, Rev. 1. This TSTF was previously approved and was incorporated into NUREG 1431, Rev. 2.

However, this portion of the TSTF was inadvertently not incorporated.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 193 of 286

Attachment 1, Volume 13, Rev. 1, Page 194 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 194 of 286

Attachment 1, Volume 13, Rev. 1, Page 195 of 286 Battery Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Parameters BASES BACKGROUND This LCO delineates the limits on battery float current as well as electrolyte temperature, level, and float voltage for the DC power subsystem batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown." In 1

Battery Monitoring and Maintenance addition to the limitations of this Specification, the [licensee controlled Program program] also implements a program specified in Specification 5.5.17 for 15 2

monitoring various battery parameters that is based on the recommendations of IEEE Standard 450-1995, "IEEE Recommended 2 Practice For Maintenance, Testing, And Replacement Of Vented Lead-Acid Batteries For Stationary Applications" (Ref. 1).

The battery cells are of flooded lead acid construction with a nominal 1 specific gravity of [1.215]. This specific gravity corresponds to an open circuit battery voltage of approximately 120 V for [58] cell battery (i.e., cell 3 voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will maintain its capacity for [30] days without further charging per manufacturer's instructions. Optimal long term performance however, is

> 2.22 obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self 1

> 2.22 discharge. The nominal float voltage of [2.22] Vpc corresponds to a total float voltage output of [128.8] V for a [58] cell battery as discussed in the U FSAR, Chapter [8] (Ref. 2). 130.98 59 4 1 APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient 14 4

SAFETY analyses in the FSAR, Chapter [6] (Ref. 3) and Chapter [15] (Ref. 4),

1 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining at least one train of DC sources OPERABLE during accident conditions, in the event of: 5 The specific Applicable Safety Analyses for the DC Electrical Power System are provided in the Bases for LCO 3.8.4 and LCO 3.8.5.

WOG STS B 3.8.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 195 of 286

Attachment 1, Volume 13, Rev. 1, Page 196 of 286 Battery Parameters B 3.8.6 BASES APPLICABLE SAFETY ANALYSES (continued)

a. An assumed loss of all offsite AC power or all onsite AC power and 5

b. A worst-case single failure.

6 Battery parameters satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter limits are conservatively power 7 Battery Monitoring established, allowing continued DC electrical system function even with and Maintenance limits not met. Additional preventative maintenance, testing, and Program monitoring performed in accordance with the [licensee controlled 1 15 program] is conducted as specified in Specification 5.5.17. 2 APPLICABILITY The battery parameters are required solely for the support of the 7

associated DC electrical power subsystems. Therefore, battery electrical parameter limits are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

y ACTIONS A.1, A.2, and A.3 8

With one or more cells in one or more batteries in one train < [2.07] V, the battery cell is degraded. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries < [2.07] V, and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Since the Required Actions only specify "perform," a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s),

depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed then there is not assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

WOG STS B 3.8.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 196 of 286

Attachment 1, Volume 13, Rev. 1, Page 197 of 286 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

B.1 and B.2 y One or more batteries in one train with float current > [2] amps indicates 8 1 that a partial discharge of the battery capacity has occurred. This may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage is found to be less than the minimum established float voltage there are two possibilities, the battery charger is inoperable or is operating in the current limit mode. Condition A addresses charger 2 inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within

[12] hours (Required Action B.2). The battery must therefore be declared 1 inoperable.

If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage less than [2.07] V, the associated "OR" 2 statement in Condition F is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells less than [2.07] V there is good assurance that, within [12] hours, the 1 battery will be restored to its fully charged condition (Required Action B.2) from any discharge that might have occurred due to a temporary loss of the battery charger.

REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 9 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months plus the time experienced to accomplish the exponential charging current portion of the battery charge profile following the service test (SR 3.8.4.3).

WOG STS B 3.8.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 197 of 286

Attachment 1, Volume 13, Rev. 1, Page 198 of 286 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery 1

within [12] hours, avoiding a premature shutdown with its own attendant risk.

If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this 1 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.

Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

y C.1, C.2, and C.3 With one or more batteries in one train with one or more cells electrolyte 8 level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met.

Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this " 7 potential (as well as provisions in Specification 5.5.17, Battery Monitoring 2 15 and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates.

Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months level is required to be restored to above the top of the requirement plates. The Required Action C.2 requirement to verify that there is no 2 7 leakage by visual inspection and the Specification 5.5.17.b item to initiate action to equalize and test in accordance with manufacturer's 15 recommendation are taken from Annex D of IEEE Standard 450-1995. 11 They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing the batter[y][ies] may have to be declared 8 inoperable and the affected cell[s] replaced.

(s)

WOG STS B 3.8.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 198 of 286

Attachment 1, Volume 13, Rev. 1, Page 199 of 286 Battery Parameters B 3.8.6 BASES ACTIONS (continued) y D.1 With one or more batteries in one train with pilot cell temperature less 8 than the minimum established design limits, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

E.1 two With one or more batteries in redundant trains with battery parameters 8 not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer 8 Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one train within 11 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . subsystem F.1 y or SR 3.8.6.6 With one or more batteries with any battery parameter outside the not met, allowances of the Required Actions for Condition A, B, C, D, or E, 8 sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding battery must be declared inoperable. y Additionally, discovering one or more batteries in one train with one or more battery cells float voltage less than [2.07] V and float current greater 1 than [2] amps indicates that the battery capacity may not be sufficient to 1 perform the intended functions. The battery must therefore be declared inoperable immediately.

WOG STS B 3.8.6-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 199 of 286

Attachment 1, Volume 13, Rev. 1, Page 200 of 286 Battery Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). The 7 day Frequency is consistent with IEEE-450 (Ref. 1).

This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of [2] amps is 1 established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5 Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits 132 2.24 provided by the battery manufacturer, which corresponds to [130.5] V at 1 the battery terminals, or [2.25] Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable. Float voltages in 15 this range or less, but greater than [2.07] Vpc, are addressed in 2 4 Specification 5.5.17. SRs 3.8.6.2 and 3.8.6.5 require verification that the cell float voltages are equal to or greater than the short term absolute (to the nearest minimum voltage of [2.07] V. The Frequency for cell voltage verification hundredth volt) every 31 days for pilot cell and 92 days for each connected cell is consistent with IEEE-450 (Ref. 1).

SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability.

The Frequency is consistent with IEEE-450 (Ref. 1).

WOG STS B 3.8.6-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 200 of 286

Attachment 1, Volume 13, Rev. 1, Page 201 of 286 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater than or 67 1 equal to the minimum established design limit (i.e., [40]°F). Pilot cell electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. The Frequency is consistent with IEEE-450 (Ref. 1).

SR 3.8.6.6 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.6.6; however, only the modified performance discharge test may be used to satisfy the battery service test requirements of SR 3.8.4.3.

A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

It may consist of just two rates; for instance the one minute rate for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a one discharge minute discharge represents a very small portion of the battery capacity, modified the test rate can be changed to that for the performance test without 4 compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

WOG STS B 3.8.6-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 201 of 286

Attachment 1, Volume 13, Rev. 1, Page 202 of 286 Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued) 4 The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the 1 battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this [80]% limit. 1 The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturer's ratings. Degradation is indicated, according to IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is [10%] below the manufacturer's rating. 1 These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, 10 corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

WOG STS B 3.8.6-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 202 of 286

Attachment 1, Volume 13, Rev. 1, Page 203 of 286 Battery Parameters B 3.8.6 BASES 1

REFERENCES 1. IEEE-450-[1995]. 11 U 4

2. FSAR, Chapter 8.

3. FSAR, Chapter [6].

U 14 1 3

4. FSAR, Chapter [15].

4 4

5. IEEE-485-[1983], June 1983.

WOG STS B 3.8.6-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 203 of 286

Attachment 1, Volume 13, Rev. 1, Page 204 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6 BASES, BATTERY PARAMETERS

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. Changes are made to reflect Specification 5.5.15.

3. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification.

4. 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.

5. ISTS 3.8.6 is applicable when associated DC electrical power subsystems are required to be OPERABLE. The DC electrical power subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 (ITS 3.8.4) and in MODES 5 and 6 and during movement of irradiated fuel assemblies (ITS 3.8.5). The Applicable Safety Analyses Bases only discusses accident analyses related to MODES 1, 2, 3, and 4; it does not discuss events in MODES 5 and 6 and during movement of irradiated fuel assemblies. Therefore, for completeness, the Applicable Safety Analyses for MODES 5 and 6 and during movement of irradiated fuel assemblies needs to be discussed. However, in lieu of adding this large description from the ITS 3.8.5 Bases, the MODES 1, 2, 3, and 4 description has been deleted and in its place a statement has been added referencing the Applicable Safety Analyses Bases for ITS 3.8.4 and ITS 3.8.5. This is consistent with the manner in which similar information in one ISTS Bases is referenced in another ISTS Bases (e.g.,

the ISTS 3.8.5 Background Bases references ISTS 3.8.4 Background Bases).

6. Changes are made to reflect the title of the Specification.

7. Grammatical/editorial/spelling error corrected.

8. Changes are made to reflect changes made to the Specifications.

9. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

10. This allowance has been deleted consistent with TSTF-360, Rev. 1. This TSTF was previously approved and was incorporated into NUREG-1431, Rev. 2.

However, this portion of the TSTF was inadvertently not incorporated.

11. Changes made to be consistent with TSTF-500, Rev. 2 and the KPS response to NRC question GMW-007.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 204 of 286

Attachment 1, Volume 13, Rev. 1, Page 205 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 205 of 286

Attachment 1, Volume 13, Rev. 1, Page 206 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.6, BATTERY PARAMETERS There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 206 of 286

, Volume 13, Rev. 1, Page 207 of 286 ATTACHMENT 7 ITS 3.8.7, INVERTERS - OPERATING , Volume 13, Rev. 1, Page 207 of 286

, Volume 13, Rev. 1, Page 208 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 208 of 286

, Volume 13, Rev. 1, Page 209 of 286 ITS 3.8.7 Add proposed ITS 3.8.7 M01 Page 1 of 1 , Volume 13, Rev. 1, Page 209 of 286

Attachment 1, Volume 13, Rev. 1, Page 210 of 286 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirement for inverters to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.8.7 requires the Train A and Train B inverters to be OPERABLE in MODES 1, 2, 3, and 4. This changes the CTS by incorporating the requirements of ITS 3.8.7.

The safety related function of the Train A and Train B inverters is to provide an uninterruptible power supply for the 120 VAC instrument buses. This change is acceptable because the safety analyses assume that the loads supported by the 120 VAC instrument buses have an uninterruptible supply of AC electrical power even if the 4.16 kV essential buses are de-energized. This change is designated as more restrictive because it adds new requirements, including an LCO, ACTIONS, and Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 210 of 286

Attachment 1, Volume 13, Rev. 1, Page 211 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 211 of 286

Attachment 1, Volume 13, Rev. 1, Page 212 of 286 CTS Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 1

DOC M01 LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

NOTE--------------------------------------------

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC 2 bus for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on [its/their]

associated [common] battery, provided:

instrument

a. The associated AC vital bus(es) [is/are] energized from [its/their] 5 2

[Class 1E constant voltage source transformers] [inverter using

/rectifier internal AC source], and 6 instrument ;

b. All other AC vital buses are energized from their associated 5 OPERABLE inverters. ]

DOC M01 APPLICABILITY: MODES 1, 2, 3, and 4.

7 INSERT 1A ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. One [required] inverter A.1 --------------NOTE-------------- 1 inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de- 5 energized. instrument Restore inverter to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status. INSERT 1 3 DOC M01 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3 associated Completion C Time not met. AND C WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 212 of 286

Attachment 1, Volume 13, Rev. 1, Page 213 of 286 CTS 3.8.7 3 INSERT 1 DOC M01 B. Two inverters in one B.1 Restore one inverter to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months train inoperable. OPERABLE status.

INSERT 1A 7

NOTE-----------------------------------------------------

When one or both inverters in one train are inoperable solely due to the room cooler being non-functional, entry into associated ACTIONS may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the associated room temperature is monitored and maintained within the design environmental requirements and both inverters in the other train are OPERABLE.

Insert Page 3.8.7-1 Attachment 1, Volume 13, Rev. 1, Page 213 of 286

Attachment 1, Volume 13, Rev. 1, Page 214 of 286 Inverters - Operating CTS 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 3 C

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M01 SR 3.8.7.1 Verify correct inverter voltage, [frequency], and 7 days alignment to required AC vital buses.

4 its associated instrument 5 WOG STS 3.8.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 214 of 286

Attachment 1, Volume 13, Rev. 1, Page 215 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. The word "required" has been deleted from the LCO and Condition A since all Train A and Train B inverters are required.

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. ITS 3.8.7 Condition B has been added to allow two inverters on the same train to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Kewaunee design incorporates two 120 VAC inverters on each train. As written, ISTS 3.8.7 requires entry into LCO 3.0.3 when two inverters in the same train are inoperable since no ACTION exists for when more than one inverter is inoperable. The inoperability of two inverters in the same train does not place the unit outside of its design basis because the other train remains OPERABLE to support engineered safety features operation.

Therefore, entry into LCO 3.0.3 is not necessary in this condition. An allowed outage time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months has been selected to be consistent with the allowed outage time in ITS 3.8.9 for two inoperable 120 VAC buses in the same train. In addition, the subsequent ACTION has been renumbered.

4. The SR has been modified to reflect that each inverter must have proper voltage, frequency, and alignment to its associated instrument bus.

5. The proper plant terminology has been used.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

7. A new Note is being added to allow one or more inverters in one train to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the inverters in the other train are OPERABLE.

CTS does not contain a specification comparable to ITS 3.8.7, Inverters-Operating. The inverters are located within the battery rooms. Therefore, the room cooler for the associated battery room controls the environment conditions for the inverters. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.b.3 is also entered when the associated room cooler in non-functional. Although the inverters are operating and connected to the associated DC bus(es) and AC instrument bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the inverters if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing the inverters to ensure conditions are within design environmental requirements. However, per ITS 3.8.7, two inverters in one train inoperable is limited to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without exceeding the design environmental limits for the inverters.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 215 of 286

Attachment 1, Volume 13, Rev. 1, Page 216 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 216 of 286

Attachment 1, Volume 13, Rev. 1, Page 217 of 286 All changes are 1 Inverters - Operating B 3.8.7 unless otherwise noted B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES instrument BACKGROUND The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses. The inverters inverter can be powered from an internal AC source/rectifier or from the station battery. The station battery provides an uninterruptible power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Feature Actuation System (ESFAS). Specific details on inverters and their operating characteristics are found in the 2

U FSAR, Chapter [8] (Ref. 1).

14 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY U analyses in the FSAR, Chapter [6] (Ref. 2) and Chapter [15] (Ref. 3), 2 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The 2 inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the RPS and ESFAS instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and is based on meeting the design basis of the unit. This includes maintaining required AC vital buses OPERABLE during accident conditions in the event of: instrument

a. An assumed loss of all offsite AC electrical power or all onsite AC electrical power and

3

b. A worst case single failure.

active Electrical Power Inverters are a part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverters ensure the availability of AC electrical power for the systems instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA.

WOG STS B 3.8.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 217 of 286

Attachment 1, Volume 13, Rev. 1, Page 218 of 286 All changes are 1 Inverters - Operating B 3.8.7 unless otherwise noted BASES LCO (continued)

Maintaining the required inverters OPERABLE ensures that the redundancy incorporated into the design of the RPS and ESFAS instrumentation and controls is maintained. The four inverters [(two per 2 train)] ensure an uninterruptible supply of AC electrical power to the AC instrument vital buses even if the 4.16 kV safety buses are de-energized.

instrument OPERABLE inverters require the associated vital bus to be powered by from DC changed to AC via the inverter (referred the inverter with output voltage and frequency within tolerances, and to as "standby"). power input to the inverter from a [125 VDC] station battery. 2 (filtered AC) through Alternatively, power supply may be from an internal AC source via the inverter (referred to rectifier as long as the station battery is available as the uninterruptible as "normal")

power supply. instrument This LCO is modified by a Note that allows [one/two] inverters to be an disconnected from a [common] battery for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if the vital bus(es) is powered from a [Class 1E constant voltage transformer or inverter

/rectifier 2 using internal AC source] during the period and all other inverters are operable. This allows an equalizing charge to be placed on one battery. 7 If the inverters were not disconnected, the resulting voltage condition might damage the inverter[s]. These provisions minimize the loss of equipment that would occur in the event of a loss of offsite power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period for the allowance minimizes the time during which a loss of offsite power could result in the loss of equipment energized from instrument the affected AC vital bus while taking into consideration the time required to perform an equalizing charge on the battery bank.

The intent of this Note is to limit the number of inverters that may be disconnected. Only those inverters associated with the single battery undergoing an equalizing charge may be disconnected. All other inverters must be aligned to their associated batteries, regardless of the number of inverters or unit design.

APPLICABILITY The inverters are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients 3 and ;

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Inverter requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.8, "Inverters - Shutdown."

WOG STS B 3.8.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 218 of 286

Attachment 1, Volume 13, Rev. 1, Page 219 of 286 All changes are 1 Inverters - Operating B 3.8.7 unless otherwise noted BASES 4

Train A or Train B ACTIONS A.1 instrument 4 The ACTIONS are modified by a Note that allows a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay in With a required inverter inoperable, its associated AC vital bus becomes entering the ACTIONS when one or both inverters in one train are inoperable until it is [manually] re-energized from its [Class 1E constant 2 inoperable solely due to the room voltage source transformer or inverter using internal AC source]. 5 cooler being non-functional, /rectifier provided the associated room temperature is monitored and For this reason a Note has been included in Condition A requiring the maintained within the design environmental requirements and entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution both inverters in the other train are Systems - Operating." This ensures that the vital bus is re-energized OPERABLE. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance is provided in order to within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . instrument perform room cooler maintenance.

If during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period one or both of the inverters in the other Required Action A.1 allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to fix the inoperable inverter and train become inoperable, the associated ACTIONS for the return it to service. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit is based upon engineering inoperable inverter(s) must judgment, taking into consideration the time required to repair an inverter immediately be entered. This 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is acceptable and the additional risk to which the unit is exposed because of the because the room containing the inverter inoperability. This has to be balanced against the risk of an inverters is monitored on an hourly basis to ensure conditions are immediate shutdown, along with the potential challenges to safety instrument within design environmental requirements of 120°F.

systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC Power to an instrument bus is electrical power sources (offsite and onsite). The uninterruptible inverter provided in the following order: 1) source to the AC vital buses is the preferred source for powering filtered AC through the inverter (referred to as "normal"); 2) DC instrumentation trip setpoint devices.

changed to AC via the inverter (referred to as "standby"), and; 3) non-filtered AC through the C C 4 INSERT 1 inverter via a static switch B.1 and B.2 (referred to as "alternate"). Train A or Train B inverters 6 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems.

WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 219 of 286

Attachment 1, Volume 13, Rev. 1, Page 220 of 286 B 3.8.7 4

INSERT 1 B.1 With two inverters in the same train inoperable, the remaining inverters are capable of supporting the minimum safety function necessary to shutdown the reactor and maintain it in a safe condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in one of the two remaining inverters could result in the minimum ESF functions not being supported. Therefore, one of the inverters must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is consistent with that allowed for an inoperable train of 120 VAC instrument buses.

Insert Page B 3.8.7-3 Attachment 1, Volume 13, Rev. 1, Page 220 of 286

Attachment 1, Volume 13, Rev. 1, Page 221 of 286 All changes are 1 Inverters - Operating B 3.8.7 unless otherwise noted BASES SURVEILLANCE SR 3.8.7.1 REQUIREMENTS instrument This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures 4 its associated that the required power is readily available for the instrumentation of the instrument RPS and ESFAS connected to the AC vital buses. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

2 REFERENCES 1. FSAR, Chapter [8].

U

2. FSAR, Chapter [6].

U 14 2

2 3. FSAR, Chapter [15].

WOG STS B 3.8.7-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 221 of 286

Attachment 1, Volume 13, Rev. 1, Page 222 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7 BASES, INVERTERS - OPERATING

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. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes are made to reflect those changes made to the ISTS.

5. Editorial correction made.

6. Changes are made to be consistent with the Specifications.

7. Typographical error corrected.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 222 of 286

Attachment 1, Volume 13, Rev. 1, Page 223 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 223 of 286

Attachment 1, Volume 13, Rev. 1, Page 224 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.7, INVERTERS - OPERATING There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 224 of 286

, Volume 13, Rev. 1, Page 225 of 286 ATTACHMENT 8 ITS 3.8.8, INVERTERS - SHUTDOWN , Volume 13, Rev. 1, Page 225 of 286

, Volume 13, Rev. 1, Page 226 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 226 of 286

, Volume 13, Rev. 1, Page 227 of 286 ITS 3.8.8 Add proposed ITS 3.8.8 M01 Page 1 of 1 , Volume 13, Rev. 1, Page 227 of 286

Attachment 1, Volume 13, Rev. 1, Page 228 of 286 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirement for inverters to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies. ITS 3.8.8 requires one inverter to be OPERABLE to support the 120 VAC instrument electrical distribution subsystem required by LCO 3.8.10, "Distribution Systems-Shutdown." This changes the CTS by incorporating the requirements of ITS 3.8.8.

The safety related function of the Train A and Train B inverters is to provide an uninterruptible power supply for the 120 VAC instrument buses. This change is acceptable because this ensures one 120 VAC instrument bus has an uninterruptible supply of AC electrical power even if the associated 4.16 kV essential bus is de-energized. This change is designated as more restrictive because it adds new requirements, including an LCO, ACTIONS, and Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 228 of 286

Attachment 1, Volume 13, Rev. 1, Page 229 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 229 of 286

Attachment 1, Volume 13, Rev. 1, Page 230 of 286 CTS Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 [Inverters shall be OPERABLE to support the onsite Class 1E AC vital 1 bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."]

DOC M01

[One] inverter[s] shall be OPERABLE.] 2 INSERT 1

REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"

3 optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.

DOC M01 APPLICABILITY: MODES 5 and 6, During movement of [recently] irradiated fuel assemblies. 4 ACTIONS

NOTE-----------------------------------------------------------

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. One [or more] [required] A.1 Declare affected required Immediately 1 inverter[s] inoperable. feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS. TSTF-471-A AND WOG STS 3.8.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 230 of 286

Attachment 1, Volume 13, Rev. 1, Page 231 of 286 3.8.8 o 2 INSERT 1 to support the 120 VAC electrical distribution subsystem required by LCO 3.8.10, Distribution Systems - Shutdown.

Insert Page 3.8.8-1 Attachment 1, Volume 13, Rev. 1, Page 231 of 286

Attachment 1, Volume 13, Rev. 1, Page 232 of 286 CTS Inverters - Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 1

DOC M01 A.2.2 Suspend movement of Immediately 1 TSTF-471-A

[recently] irradiated fuel 4

assemblies.

AND 2

1 TSTF-A.2.3 Suspend operations Immediately 471-A involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND 3

1 TSTF-A.2.4 Initiate action to restore Immediately 471-A required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M01 SR 3.8.8.1 Verify correct inverter voltage, [frequency,] and 7 days 4 alignments to required AC vital buses. 2 5 its associated instrument WOG STS 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 232 of 286

Attachment 1, Volume 13, Rev. 1, Page 233 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8, INVERTERS - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.8 and "Reviewer's Note" have been deleted because the current licensing basis does not include any requirements for inverters to be OPERABLE. ISTS 3.8.8 Required Action A.1 provides an option to declare affected required feature(s) inoperable with one or more required inverters inoperable. The ISTS Bases states that this is acceptable since the remaining inverters may be capable of supporting sufficient features to allow continuation of fuel movement. Therefore, this Required Action assumes more than one inverter is required by the LCO. This option has been deleted since only one inverter is required to be OPERABLE by ITS LCO 3.8.8. The subsequent Required Actions have been renumbered and modified, as applicable.

2. The second option of ISTS LCO 3.8.8 is not specific as to what the inverters must be powering. The LCO has been modified to require one inverter to be powering one of the 120 VAC instrument buses required by LCO 3.8.10. In addition, SR 3.8.8.1 has been modified to reflect that all inverters at the unit are not required to be OPERABLE and that the required inverter must be aligned to the associated 120 VAC instrument bus.

3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

4. 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.

5. The proper plant terminology has been used.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 233 of 286

Attachment 1, Volume 13, Rev. 1, Page 234 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 234 of 286

Attachment 1, Volume 13, Rev. 1, Page 235 of 286 Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

14 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 1 SAFETY U analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 1 2

ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

(RCS) 3 The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. required 120 V 4 one a The OPERABILITY of the minimum inverters to each AC vital bus during 5

and during movement of MODES 5 and 6 ensures that: instrument irradiated fuel assemblies

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

6

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

6

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, the AC and DC 2

inverters are only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in 2 MODES [5 and 6] because the energy contained within the reactor WOG STS B 3.8.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 235 of 286

Attachment 1, Volume 13, Rev. 1, Page 236 of 286 Inverters - Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued) pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

Electrical Power 1

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverter[s] ensure the availability of electrical power for the 2 instrumentation for systems required to shut down the reactor and required maintain it in a safe condition after an anticipated operational occurrence 1

or a postulated DBA. The battery powered inverter[s] provide[s] 2 uninterruptible supply of AC electrical power to the AC vital bus[es] even if the 4.16 kV safety buses are de-energized. OPERABILITY of the instrument 1

inverter[s] requires that the AC vital bus be powered by the inverter. This ensures the availability of sufficient inverter power sources to operate the INSERT 1 unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 2 recently irradiated fuel]). i.e.

and inadvertent dilution events WOG STS B 3.8.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 236 of 286

Attachment 1, Volume 13, Rev. 1, Page 237 of 286 B 3.8.8 1

INSERT 1 the associated 120 VAC instrument bus to be powered by the inverter with output voltage and frequency within tolerances, and power input to the inverter from a 125 VDC station battery. Power to an instrument bus is provided in the following order: 1) filtered AC through the inverter (referred to as "normal"); 2) DC changed to AC via the inverter (referred to as "standby"), and; 3) non-filtered AC through the inverter via a static switch (referred to as "alternate"). Alternatively, power supply may be from an internal AC source via rectifier as long as the station battery is available as the uninterruptible power supply.

Insert Page B 3.8.8-2 Attachment 1, Volume 13, Rev. 1, Page 237 of 286

Attachment 1, Volume 13, Rev. 1, Page 238 of 286 Inverters - Shutdown B 3.8.8 BASES APPLICABILITY The inverter[s] required to be OPERABLE in MODES 5 and 6 and during 2

movement of [recently] irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available 6 for the irradiated fuel in the core, ;

b. Systems needed to mitigate a fuel handling accident [involving 2 handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] are available, 6

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and 6

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

TSTF-471 A.1, A.2, and A.3 A.1, A.2.1, A.2.2, A.2.3, and A.2.4 4

[If two trains are required by LCO 3.8.10, "Distribution Systems -

Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of CORE INSERT 2 ALTERATIONS, [recently] irradiated fuel movement, and operations with a potential for positive reactivity additions.] By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance 4 with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made TSTF-(i.e., to suspend CORE ALTERATIONS, movement of [recently] irradiated 471-A fuel assemblies, and operations involving positive reactivity WOG STS B 3.8.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 238 of 286

Attachment 1, Volume 13, Rev. 1, Page 239 of 286 B 3.8.8 4

INSERT 2 With the required inverter inoperable, suspension of movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) specified in LCO 3.1.1, SHUTDOWN MARGIN (SDM), or boron concentration (MODE 6) specified in LCO 3.9.1, Boron Concentration, Insert Page B 3.8.8-3 Attachment 1, Volume 13, Rev. 1, Page 239 of 286

Attachment 1, Volume 13, Rev. 1, Page 240 of 286 Inverters - Shutdown B 3.8.8 BASES ACTIONS (continued) additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that 4 could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or 7 refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including Moderator Temperature temperature increases when operating with a positive MTC must also be 3 Coefficient ( )

evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverter[s] and to 2 continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required 1 inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 is REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with 4 instrument all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures instrument that the required power is readily available for the instrumentation connected to the AC vital buses. The 7 day Frequency takes into account 4 the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES 1. FSAR, Chapter [6]. 1 2 14 1

2. FSAR, Chapter [15].

U WOG STS B 3.8.8-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 240 of 286

Attachment 1, Volume 13, Rev. 1, Page 241 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8 BASES, INVERTERS - SHUTDOWN

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. These corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 3.2.2.

4. Changes are made to reflect changes made to the Specification.

5. Changes are made to reflect the Specifications.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

7. Typographical/grammatical error corrected.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 241 of 286

Attachment 1, Volume 13, Rev. 1, Page 242 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 242 of 286

Attachment 1, Volume 13, Rev. 1, Page 243 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.8, INVERTERS - SHUTDOWN There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 243 of 286

Attachment 1, Volume 13, Rev. 1, Page 244 of 286 ATTACHMENT 9 ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Attachment 1, Volume 13, Rev. 1, Page 244 of 286

, Volume 13, Rev. 1, Page 245 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 245 of 286

Attachment 1, Volume 13, Rev. 1, Page 246 of 286 ITS ITS 3.8.9 A01 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries.

OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features.

SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are satisfied:

1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

See ITS 3.8.1

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

Train A and B AC electrical power distribution

3. The 4160-V buses 1-5 and 1-6 are both energized. subsystem shall be OPERABLE. LA01

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their LCO 3.8.9 respective station service transformers.

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

Train A and B DC electrical power distribution subsystems A02

6. Both station batteries and both DC systems are OPERABLE, except during testing See ITS and surveillance as described in TS 4.6.b. 3.8.4 and 3.8.6

7. Both diesel generators are OPERABLE and each diesel generator shall have:

A. Day tanks containing a minimum volume of 1000 gallons; See ITS 3.8.1 and B. An underground storage tank and corresponding day tanks containing a 3.8.3 minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are: See ITS 3.8.1 A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem M02 requirements, including LCO 3.8.9, ACTIONS Note, ACTIONS B and E, and SR 3.8.9.1 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 Attachment 1, Volume 13, Rev. 1, Page 246 of 286

Attachment 1, Volume 13, Rev. 1, Page 247 of 286 A01 ITS ITS 3.8.9 Add proposed ACTIONS Note L02 ACTION D b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, 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 MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months M01

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either: See ITS 3.8.1 A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator.

3. One battery may be inoperable for a period not exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the See ITS 3.8.4 and other battery and two battery chargers remain OPERABLE with one charger 3.8.6 carrying the d-c supply system.

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE. See ITS 3.8.1

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

Add proposed ACTION A Note M03 ACTION A 6. One 4160-V or 480-V engineered safety features bus may be out of service for 8 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the redundant bus and its loads remain OPERABLE. M03 M03 ACTION E 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . A03

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: See ITS 3.8.1

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Add proposed ACTIONS C and E (for 125 VDC) L01 Add proposed SR 3.8.9.1 for 4160 and 480 VAC and 125 VDC M04 Amendment No. 194 TS 3.7-2 02/07/2008 Page 2 of 2 Attachment 1, Volume 13, Rev. 1, Page 247 of 286

Attachment 1, Volume 13, Rev. 1, Page 248 of 286 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.7.a.6 requires both station batteries and both DC systems to be OPERABLE, however the CTS does not explicitly require the DC distribution buses to be OPERABLE. ITS LCO 3.8.9, in part, requires the Train A and B DC electrical power distribution subsystems to be OPERABLE. This changes the CTS by specifying the requirements for DC distribution buses.

The purpose of CTS 3.7.a.6, in part, is to ensure the DC distribution buses are OPERABLE. This is implicitly required since CTS 3.7.a.6 requires both DC systems to be OPERABLE. The proposed change explicitly requires the Train A and B DC electrical power distribution subsystems to be OPERABLE. The details of which buses are covered by this LCO are discussed in the Bases. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.7.b.6 allows a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration time when a 4160V or 480 V ESF bus is inoperable, provided the redundant bus "and its loads" remain OPERABLE.

Under similar conditions (inoperable AC buses), the ITS 3.8.9 ACTIONS do not specifically include a provision that the loads on the redundant buses must be OPERABLE. This changes the CTS by deleting a specific requirement that loads on redundant buses be OPERABLE when an AC bus is inoperable.

The purpose of the CTS 3.7.b.6 provision is to ensure that when an AC bus is inoperable, the loads powered from the redundant bus are OPERABLE. This ensures that a loss of safety function is not occurring during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time currently allowed for restoration of the inoperable AC bus. This provision is covered generically in the ITS through the use of LCO 3.0.6 and the Safety Function Determination Program in ITS Chapter 5. Therefore, the deletion of the specific requirement in CTS 3.7.b.6 is acceptable and is considered administrative since this deletion does not result in a technical change.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.a requires the Train A and B AC and DC electrical power distribution subsystems (specified in CTS 3.7.a.3, 4, 5, and 6) to be OPERABLE when the reactor is critical. In addition, CTS 3.7.b provides actions when the Train A and B AC electrical power distribution subsystems are inoperable during power operation or recovery from an inadvertent trip. If the inoperable AC bus is not restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as required by CTS 3.7.b.6, then CTS 3.7.b requires the unit to be in HOT STANDBY (ITS equivalent MODE 2) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Kewaunee Power Station Page 1 of 6 Attachment 1, Volume 13, Rev. 1, Page 248 of 286

Attachment 1, Volume 13, Rev. 1, Page 249 of 286 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Furthermore, for inoperabilities of the DC buses or of AC buses in both trains, since no actions are provided, CTS 3.0.c would also require the unit to be subcritical within a total of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in HOT SHUTDOWN (which requires the reactor to be subcritical)). ITS LCO 3.8.9 requires the Train A and B AC and DC electrical power distribution subsystems to be OPERABLE in MODES 1, 2, 3, and 4. When a unit shutdown is required due to inoperabilities of the AC or DC buses, ITS 3.8.9 ACTION D requires the unit to be in MODE 3 (CTS equivalent HOT SHUTDOWN) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by requiring the Train A and B AC and DC electrical power distribution subsystems to be OPERABLE in MODES 3 and 4 and in MODE 2 when the reactor is not critical and provides commensurate ACTIONS to cover the new Applicability.

The purpose of CTS 3.7.a, in part, is to ensure the Train A and B AC and DC electrical power distribution subsystems are OPERABLE to mitigate the consequences of a transient or design basis accident. The Train A and B AC and DC electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 when an accident may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODES 3 and 4 the reactor is not critical, however the reactor coolant temperature is always above 200°F and there is considerable energy in the reactor core and the electrical power distribution systems must be available to support equipment necessary to mitigate the consequences of a pipe break.

Therefore, it is acceptable to require the AC and DC electrical power distribution subsystems to be OPERABLE in MODES 3 and 4 as well as MODES 1 and 2.

This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M02 The CTS does not specify requirements for AC instrument electrical power distribution subsystems to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.8.9, in part, requires the Train A and Train B AC instrument bus electrical power distribution power subsystems to be OPERABLE in MODES 1, 2, 3, and 4.

Appropriate ACTIONS (B and E, including an ACTIONS Note) and a Surveillance Requirement (SR 3.8.9.1) are also provided. This changes the CTS by incorporating these ITS 3.8.9 requirements.

The purpose of ITS 3.8.9 is, in part, to ensure the necessary AC instrument electrical power distribution subsystems are available to provide electrical power to mitigate postulated events. This change is acceptable since the distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). This change is designated as more restrictive because it adds new requirements to the CTS.

M03 CTS 3.7.b.6 requires inoperable AC buses to be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the redundant bus and its loads remain OPERABLE.

ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore the Train A and Train B AC electrical power distribution subsystem(s) to OPERABLE status. In addition, a Note has been added (ITS 3.8.9, Note to ACTION A) that requires entry into applicable Conditions and Required Action of LCO 3.8.4, "DC Sources -

Operating," for DC Sources made inoperable by inoperable power distribution Kewaunee Power Station Page 2 of 6 Attachment 1, Volume 13, Rev. 1, Page 249 of 286

Attachment 1, Volume 13, Rev. 1, Page 250 of 286 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING subsystems. Furthermore, if redundant AC buses are inoperable, ITS 3.8.9 ACTION E will require entry into LCO 3.0.3, which will then require a unit shutdown, consistent with the current CTS 3.7.b.6 requirement. This changes the CTS by reducing the time the unit can operate with one or more AC buses inoperable and by requiring the compensatory actions for DC Sources to be taken immediately if a DC Source is made inoperable by inoperable AC power distribution subsystems. The deletion of the CTS 3.7.b.6 provision concerning the associated loads is discussed in DOC A03.

The purpose of CTS 3.7.b.6 is to minimize the time the unit continues to operate with an inoperable AC electrical power distribution subsystem. If one AC electrical power distribution subsystem is inoperable and a loss of safety function has not occurred, the remaining AC electrical power distribution subsystem is capable of supporting a safe shutdown and to mitigate an accident condition. An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time minimizes the time where a subsequent worse-case single failure could result in a loss of the remaining electrical power distribution subsystem necessary to mitigate a worse case accident, yet is a reasonable amount of time to assess the cause of the inoperable AC electrical power distribution subsystem(s) and either restore them to OPERABLE status or prepare and effect an orderly and safe unit shutdown. This change is acceptable because it requires inoperable AC electrical power distribution subsystem(s) to be restored to an OPERABLE status sooner than is currently required (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months versus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). This change reduces the time the unit would be allowed to continue to operate once the condition is identified. The addition of the Note only acts as a reminder to enter the appropriate actions if the emergency bus which supplies the Train A or Train B battery charger becomes de-energized. In the event an emergency bus is inoperable such that a Train A or Train B battery charger were inoperable, ITS LCO 3.0.6 would allow taking only the Distribution System - Operating ACTIONS; taking exception to complying with the DC Sources - Operating ACTIONS. Since the Distribution System - Operating ACTIONS may not be sufficiently conservative in this event (i.e., a battery charger may be without power), specific direction to take appropriate ACTIONS for the DC Sources - Operating is added (ITS 3.8.9, Note to ACTION A) when there is no power to support the associated required battery charger.

Furthermore, if a loss of function has occurred due to inoperabilities of AC buses in both trains, ITS 3.8.9 ACTION E requires an immediate entry into LCO 3.0.3, consistent with the current requirements. This change is designated as more restrictive because less time is allowed to restore inoperable AC buses in the ITS than is allowed in the CTS.

M04 CTS 3.7.a does not provide any specific testing requirements for the Train A and B AC and DC electrical power distribution subsystems. ITS SR 3.8.9.1, in part, requires verification of correct breaker alignments and voltage to required AC and DC electrical power distribution subsystems. This changes the CTS by requiring a new Surveillance Requirement for verifying the OPERABILITY of the required Train A and B AC and DC electrical power distribution subsystems.

The purpose of ITS SR 3.8.9.1 is to ensure that the buses associated with the Train A and B AC and DC electrical power distribution subsystems are OPERABLE. This change is acceptable because it provides additional assurance that the buses associated with the Train A and B AC and DC electrical Kewaunee Power Station Page 3 of 6 Attachment 1, Volume 13, Rev. 1, Page 250 of 286

Attachment 1, Volume 13, Rev. 1, Page 251 of 286 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING power distribution subsystems are OPERABLE. This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.a.3 requires the 4160V Buses 1-5 and 1-6 to be energized. CTS 3.7.a.4 requires the 480V Buses 1-52 and 1-62 and their MCCs to be energized from their respective station service transformers. CTS 3.7.a.5 requires the 480 V buses 1-51 and 1-61 to be energized from their respective station service transformers. ITS LCO 3.8.9, in part, requires the Train A and B AC electrical power distribution subsystems to be OPERABLE. This changes the CTS by moving the specific names of the buses, the associated nominal bus voltages (i.e., 4160 V and 480 V), that the buses must be energized, and that the 480 V buses and MCCs are energized from their respective station service transformers from the CTS to the Bases.

The removal of these details which are related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the Train A and B AC electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignments and voltage to required AC electrical power distribution subsystems. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information related to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.a.6 requires, in part, that both DC systems be OPERABLE, however, the CTS does not include Actions to take when a DC electrical power distribution subsystem is inoperable. Therefore, the shutdown requirements of CTS 3.0.c would apply. ITS 3.8.9 ACTION C covers the condition for one or more DC electrical power distribution subsystems inoperable and requires the restoration of the DC electrical power distribution subsystem within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Furthermore, if multiple DC electrical power distribution subsystems were inoperable such that a loss of safety function resulted, ITS 3.8.9 ACTION E requires immediate entry into LCO 3.0.3 (which requires a unit shutdown). Under these conditions, the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration time Kewaunee Power Station Page 4 of 6 Attachment 1, Volume 13, Rev. 1, Page 251 of 286

Attachment 1, Volume 13, Rev. 1, Page 252 of 286 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING provided by ITS 3.8.9 ACTION C would not be allowed. This changes the CTS by providing some time to restore an inoperable DC electrical power distribution subsystem prior to requiring a plant shutdown provided a loss of function has not occurred.

The purpose of CTS 3.7.a.6 is to ensure the availability of necessary DC electrical power to ESF systems. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows a short time period to restore an inoperable DC electrical power distribution subsystem to OPERABLE status. This is acceptable because there are sufficient electrical power distribution subsystems available to ensure all plant safety functions can be supported by the Train A and Train B electrical power distribution subsystems.

This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when an AC or DC electrical power distribution subsystem is inoperable. ITS 3.8.9 also provides ACTIONS, but includes a Note that allows one or more electrical power distribution subsystems to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other train are OPERABLE. This changes the CTS by allowing a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months deferral in entering associated ACTIONS when an electrical power distribution subsystem is inoperable solely due to a room cooler being non-functional.

The purpose of the CTS 3.7.b and ITS 3.8.9 ACTIONS is to adequately control how long an electrical power distribution subsystem can be inoperable. The change allows an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the inoperability of the electrical power distribution subsystem is due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. CTS 3.7.b.6 allows one 480-V engineered safety features bus may be out of service for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.b.6 is also entered when the associated room cooler is non-functional. The CTS does not contain a specification specifically for DC distribution subsystem or AC instrument bus electrical power distribution subsystem. Although the AC, DC, and AC instrument bus electrical power subsystems are operating and Kewaunee Power Station Page 5 of 6 Attachment 1, Volume 13, Rev. 1, Page 252 of 286

Attachment 1, Volume 13, Rev. 1, Page 253 of 286 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING connected to the associated AC, DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.9, an electrical power distribution subsystem inoperability can be limited to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without exceeding the design environmental limits for the AC, DC, and AC instrument bus electrical power distribution subsystems. This change is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS.

Kewaunee Power Station Page 6 of 6 Attachment 1, Volume 13, Rev. 1, Page 253 of 286

Attachment 1, Volume 13, Rev. 1, Page 254 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 254 of 286

Attachment 1, Volume 13, Rev. 1, Page 255 of 286 CTS Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating instrument 3.7.a.3, 1 3.7.a.4, LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution 3.7.a.5, subsystems shall be OPERABLE.

3.7.a.6 3.7.a

NOTE-------------------------------------------

When one or more electrical distribution subsystems are inoperable solely due to the room cooler being non-functional, entry into associated APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the associated 5 room temperature is monitored and maintained within the design environmental requirements the electrical power distribution subsystems in the other train are OPERABLE.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.7.b.6 A. One or more AC --------------------NOTE-------------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains 1 sources made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status.

instrument 1

DOC M02 B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses inoperable. subsystem(s) to (es) instrument OPERABLE status.

DOC L01 C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2 electrical power power distribution distribution subsystems subsystem(s) to inoperable. OPERABLE status.

WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 255 of 286

Attachment 1, Volume 13, Rev. 1, Page 256 of 286 Distribution Systems - Operating CTS 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.7.b D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND 3

of Condition A, B, or C D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months DOC M03 E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M04 SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days 4

[required] AC, DC, and AC vital bus electrical power distribution subsystems. instrument 1

WOG STS 3.8.9-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 256 of 286

Attachment 1, Volume 13, Rev. 1, Page 257 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

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

2. The allowance in ISTS 3.8.9 ACTION C to have one or more DC electrical power distribution subsystems inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months has been changed to address only the inoperability of one Train A or Train B DC electrical power distribution subsystem, since if both the Train A and Train B buses were inoperable, then a loss of safety function would exist and entry into ACTION E would be necessary.

3. Changes made to be consistent with the Specification.

4. 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.

5. A new Note is being added to allow one or more electrical power distribution subsystems to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to a room cooler being non-functional, provided associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. CTS 3.7.b.6 allows one 480-V engineered safety features bus may be out of service for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.b.6 is also entered when the associated room cooler is non-functional. CTS does not contain a specification specifically for DC distribution subsystem or AC instrument bus electrical power distribution subsystem. Although the AC, DC, and AC instrument bus electrical power subsystems are operating and connected to the associated AC and DC bus(es),

with room cooling being non-functional, the design environment limits could be exceeded for the AC, DC, or AC instrument bus electrical power distribution subsystems if room cooling is non-functional for an extended period of time.

Current procedural guidance requires monitoring the room containing AC, DC, or AC instrument bus electrical power distribution subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.9, an electrical power distribution subsystem inoperability can be limited to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without exceeding the design environmental limits for the AC, DC, and AC instrument bus electrical power distribution subsystems.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 257 of 286

Attachment 1, Volume 13, Rev. 1, Page 258 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 258 of 286

Attachment 1, Volume 13, Rev. 1, Page 259 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating instrument BASES BACKGROUND The onsite Class 1E AC, DC, and AC vital bus electrical power 2

distribution systems are divided by train into [two] redundant and independent AC, DC, and AC vital bus electrical power distribution subsystems. instrument The AC electrical power subsystem for each train consists of a primary Engineered Safety Feature (ESF) 4.16 kV bus and secondary [480 and 120] V buses, distribution panels, motor control centers and load centers.

Each [4.16 kV ESF bus] has at least [one separate and independent 2 offsite source of power] as well as a dedicated onsite diesel generator (DG) source. Each [4.16 kV ESF bus] is normally connected to a preferred offsite source. After a loss of the preferred offsite power source to a 4.16 kV ESF bus, a transfer to the alternate offsite source is a qualified circuit becomes accomplished by utilizing a time delayed bus undervoltage relay. If all offsite sources are unavailable, the onsite emergency DG supplies power to the 4.16 kV ESF bus. Control power for the 4.16 kV breakers is supplied from the Class 1E batteries. Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources -

Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating."

and The secondary AC electrical power distribution subsystem for each train includes the safety related buses, load centers, motor control centers, and distribution panels shown in Table B 3.8.9-1.

instrument The 120 VAC vital buses are arranged in two load groups per train and instrument are normally powered from the inverters. The alternate power supply for the vital buses are Class 1E constant voltage source transformers is either filtered AC through the inverter (referred to as "normal"), powered from the same train as the associated inverter, and its use is DC changed to AC via the inverter (referred to as governed by LCO 3.8.7, "Inverters - Operating." Each constant voltage "standby"), or non-filtered AC source transformer is powered from a Class 1E AC bus. two through the inverter via a static switch (referred to as "alternate"). The DC electrical power distribution subsystem consists of [125] V 2 bus(es) and distribution panel(s). for each train The list of all required DC and vital AC distribution buses [and panels] is 2 presented in Table B 3.8.9-1.

instrument WOG STS B 3.8.9-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 259 of 286

Attachment 1, Volume 13, Rev. 1, Page 260 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES U

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 1), and in the FSAR, 14 ANALYSES Chapter [15] (Ref. 2), assume ESF systems are OPERABLE. The AC, 2 1 DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to instrument ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

instrument The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit.

This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC electrical power 3 and ;

active

b. A worst case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

instrument LCO The required power distribution subsystems listed in Table B 3.8.9-1 ensure the availability of AC, DC, and AC vital bus electrical power for the systems required to shut down the reactor and maintain it in a safe instrument condition after an anticipated operational occurrence (AOO) or a postulated DBA. The AC, DC, and AC vital bus electrical power distribution subsystems are required to be OPERABLE.

instrument Maintaining the Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

and OPERABLE AC electrical power distribution subsystems require the associated buses, load centers, motor control centers, and distribution panels to be energized to their proper voltages. OPERABLE DC electrical power distribution subsystems require the associated buses and distribution panels to be energized to their proper voltage from either the Power to an instrument bus is provided in associated battery or charger. OPERABLE vital bus electrical power instrument the following order: 1) filtered AC through the inverter (referred to as "normal"); 2) DC distribution subsystems require the associated buses to be energized to changed to AC via the inverter (referred to as "standby"); and 3) non-filtered AC their proper voltage from the associated [inverter via inverted DC voltage, 2 through the inverter via a static switch inverter using internal AC source, or Class 1E constant voltage (referred to as "alternate").

transformer].

WOG STS B 3.8.9-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 260 of 286

Attachment 1, Volume 13, Rev. 1, Page 261 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES LCO (continued) instrument In addition, tie breakers between redundant safety related AC, DC, and AC vital bus power distribution subsystems, if they exist, must be open.

electrical This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s). If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV buses from being powered from the same offsite circuit.

APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients 3

and ;

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems -

Shutdown."

6 ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor 4 electrical power distribution control centers, or distribution panels (except AC vital buses), in one train instrument subsystem inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The electrical overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC electrical power buses, load centers, motor control centers, and distribution panels must 4 distribution subsystem be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The ACTIONS are modified by a Note that allows a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay in entering the ACTIONS when one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance is provided in order to perform room cooler maintenance. If during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period the buses subsequently become inoperable such that a loss of function occurs, the associated ACTIONS for the inoperable DC electrical power subsystem(s) must immediately be entered. This 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is acceptable because the room containing the AC, DC, and AC instrument bus electrical power distribution subsystems is monitored on an hourly basis to ensure conditions are within design environmental requirements of 120°F.

WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 261 of 286

Attachment 1, Volume 13, Rev. 1, Page 262 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES ACTIONS (continued)

Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to 3

shutdown within this time limit and

b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

Required Action A.1 is modified by a Note that requires the applicable sources Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

5 to be entered for DC trains made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

B.1 instrument instrument With one or more AC vital buses inoperable, and a loss of function has not yet occurred, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum [required] ESF functions not being supported. Therefore, the 2 instrument required AC vital bus must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated [inverter via inverted DC, inverter using internal AC source, or Class 1E constant voltage 2 transformer].

either filtered AC through the inverter (referred to as "normal"), DC changed to AC via the inverter (referred to as "standby"), or non-filtered AC through the inverter via a static switch (referred to as "alternate")

WOG STS B 3.8.9-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 262 of 286

Attachment 1, Volume 13, Rev. 1, Page 263 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES ACTIONS (continued) instrument Condition B represents one or more AC vital buses without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital buses and restoring power to the affected vital bus.

instrument This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate vital AC power.

Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if declared inoperable, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable 3

operations to continue,

b. The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without instrument adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and 3

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety instrument of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

electrical power C.1 distribution subsystem 6 4 With one or more DC buses or distribution panels inoperable, and a loss of function has not yet occurred, the remaining DC electrical power is distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF 2 4 electrical power functions not being supported. Therefore, the [required] DC buses and distribution subsystem distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

WOG STS B 3.8.9-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 263 of 286

Attachment 1, Volume 13, Rev. 1, Page 264 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES electrical power ACTIONS (continued) distribution subsystem 6 4 Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable 7

operations to continue, not

3

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to 3

the affected train, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

2 If any required Action and associated Completion Time of D.1 and D.2 Condition A, B, or C is not met 6

If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems.

WOG STS B 3.8.9-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 264 of 286

Attachment 1, Volume 13, Rev. 1, Page 265 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES ACTIONS (continued)

E.1 Condition E corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 instrument REQUIREMENTS 2

This Surveillance verifies that the [required] AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the AC, DC, and instrument AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. FSAR, Chapter [6].

1 14 2

2. FSAR, Chapter [15].

U 2 3. Regulatory Guide 1.93, December 1974.

WOG STS B 3.8.9-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 265 of 286

Attachment 1, Volume 13, Rev. 1, Page 266 of 286 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted Table B 3.8.9-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems TYPE VOLTAGE TRAIN A* TRAIN B*

1-5 1-6 2

AC safety buses [4160 V] [ESF Bus] [NB01] [ESF Bus] [NB02]

[480 V] Load Centers Load Centers 2

[NG01, NG03] [NG02, NG04]

1-51, 1-52 1-61, 1-62

[480 V] Motor Control Motor Control Centers Centers 1-52A, 1-52B, [NG01A, NG01I, [NG02A, NG02I, 1-62A, 1-62B, 1-52C, 1-52D, NG01B, NG03C, NG02B, NG04C, 1-62C, 1-62D, 1-62E, 1-62G, 1-52E, 1-52F NG03I, NG03D] NG04I, NG04D] 1-62H, 1-62J 1 2

[120 V] Distribution Panels Distribution Panels

[NP01, NP03] [NP02, NP04]

DC buses [125 V] Bus [NK01] Bus [NK02] 2 BRA-102 BRB-102 Bus [NK03] Bus [NK04] 2 BRA-104 BRB-104 Distribution Panels Distribution Panels 1 2

[NK41, NK43, NK51] [NK42, NK44, NK52]

AC vital buses [120 V] Bus [NN01] Bus [NN02] 2 BRA-113 and extension BRB-113 and extension instrument Bus [NN03] Bus [NN04] 2 BRA-114 BRB-114

Each train of the AC and DC electrical power distribution systems is a subsystem.

WOG STS B 3.8.9-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 13, Rev. 1, Page 266 of 286

Attachment 1, Volume 13, Rev. 1, Page 267 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9 BASES, DISTRIBUTION SYSTEMS - OPERATING

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. These punctuation corrections have been made consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes have been made to match the Specification.

5. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

6. Changes have been made to reflect changes made to the Specification.

7. Typographical/grammatical error corrected.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 267 of 286

Attachment 1, Volume 13, Rev. 1, Page 268 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 268 of 286

Attachment 1, Volume 13, Rev. 1, Page 269 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 269 of 286

Attachment 1, Volume 13, Rev. 1, Page 270 of 286 ATTACHMENT 10 ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN Attachment 1, Volume 13, Rev. 1, Page 270 of 286

, Volume 13, Rev. 1, Page 271 of 286 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 1, Page 271 of 286

, Volume 13, Rev. 1, Page 272 of 286 ITS 3.8.10 Add proposed ITS LCO 3.8.10 and ITS 3.8.10 ACTION A A01 Add proposed SR 3.8.10.1 M01 Page 1 of 1 , Volume 13, Rev. 1, Page 272 of 286

Attachment 1, Volume 13, Rev. 1, Page 273 of 286 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A01 The CTS does not contain any specific OPERABILITY requirements for the Distribution Systems during shutdown conditions. However, the CTS 1.0.e definition of OPERABLE requires that, for all equipment required to be OPERABLE, "all necessary attendant ... normal and emergency electrical power sources ... that are required for the system or component to perform its required function is also capable of performing their related support function." ITS LCO 3.8.10 requires the necessary portions of the AC, DC, and AC instrument bus electrical power distribution subsystem to be OPERABLE to support equipment required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies. If one or more required electrical power distribution subsystems are inoperable, ITS 3.8.10 ACTION A must be entered and the associated supported required features(s) must be declared inoperable or certain activities must be suspended (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration), action must be initiated to restore the inoperable distribution subsystem, and the required residual heat removal subsystem(s) must be declared inoperable and not in operation. This changes the CTS by adding the explicit requirements of ITS LCO 3.8.10 and ITS 3.8.10 ACTION A.

The purpose of ITS 3.8.10 is to ensure the necessary AC, DC, and AC instrument bus electrical power distribution subsystems are available to provide emergency electrical power to mitigate events postulated during shutdown, such as a fuel handling accident. The change is acceptable since it is consistent with the requirements in CTS 1.0.e that all attendant equipment must be performing its related support function to support a required feature. In addition, the Required Action that allows the supported features to be declared inoperable is also acceptable because this declaration will require entry into all other Technical Specifications associated with inoperable features. This change is also consistent with the CTS since electrical power distribution system inoperabilities are currently covered by the supported system type LCOs. ITS 3.8.10 ACTION A includes an option to the requirement to declare supported features inoperable.

The option is to suspend certain activities (movement of irradiated fuel assemblies and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration operations involving positive reactivity additions that could result in loss of required SDM or boron concentration), to immediately initiate action to restore the inoperable distribution subsystem(s) to OPERABLE status, and to declare the required residual heat removal subsystem(s) inoperable and not in operation. The requirement to declare the affected residual heat removal subsystem inoperable has been added because Residual Heat Removal System LCOs have been added to the ITS and this change ensures the proper Actions are entered if the second action is taken. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power. Although not explicitly stated this action is always applied due to the importance of the equipment. This change is designated as administrative because it does not result in technical changes to the CTS.

Kewaunee Power Station Page 1 of 2 Attachment 1, Volume 13, Rev. 1, Page 273 of 286

Attachment 1, Volume 13, Rev. 1, Page 274 of 286 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN MORE RESTRICTIVE CHANGES M01 The CTS does not have any specific Surveillance Requirements for the Distribution Systems when they are required to be OPERABLE to support equipment required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies. ITS SR 3.8.10.1 requires verification of correct breaker alignment and voltage to the required AC, DC, and AC instrument bus electrical power distribution subsystems every 7 days. This changes the CTS by adding the explicit Surveillance for the portions of the electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies.

The purpose of ITS SR 3.8.10.1 is to ensure the AC, DC, and AC instrument bus electrical power distribution subsystems are OPERABLE to provide emergency electrical power to mitigate events postulated during shutdown, such as a fuel handling accident. This change is acceptable because the proposed Surveillance helps to ensure the required portions of the electrical power distribution subsystems are OPERABLE. This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 2 of 2 Attachment 1, Volume 13, Rev. 1, Page 274 of 286

Attachment 1, Volume 13, Rev. 1, Page 275 of 286 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 275 of 286

Attachment 1, Volume 13, Rev. 1, Page 276 of 286 Distribution Systems - Shutdown CTS 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown instrument 1

DOC A01 LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of [recently] irradiated fuel assemblies. 2 ACTIONS

NOTE-----------------------------------------------------------

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME DOC A01 A. One or more required A.1 Declare associated Immediately 1 AC, DC, or AC vital bus supported required electrical power feature(s) inoperable.

distribution subsystems inoperable. OR instrument TSTF-A.2.1 Suspend CORE Immediately 471-A ALTERATIONS.

AND A.2.2 Suspend movement of Immediately TSTF-471-A

[recently] irradiated fuel 2 1 assemblies.

AND TSTF-A.2.3 Suspend operations Immediately 471-A involving positive reactivity 2 additions that could result in loss of required SDM or boron concentration.

AND WOG STS 3.8.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 276 of 286

Attachment 1, Volume 13, Rev. 1, Page 277 of 286 CTS Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC A01 A.2.4 Initiate actions to restore Immediately TSTF-471-A required AC, DC, and AC 3

vital bus electrical power 1 distribution subsystems to instrument OPERABLE status.

AND A.2.5 Declare associated Immediately TSTF-471-A required residual heat 4

removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M01 SR 3.8.10.1 Verify correct breaker alignments and voltage to 7 days required AC, DC, and AC vital bus electrical power 1 distribution subsystems.

instrument WOG STS 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 277 of 286

Attachment 1, Volume 13, Rev. 1, Page 278 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Changes are made to reflect plant specific nomenclature.

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.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 278 of 286

Attachment 1, Volume 13, Rev. 1, Page 279 of 286 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 1, Page 279 of 286

Attachment 1, Volume 13, Rev. 1, Page 280 of 286 Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown instrument BASES 1

BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating."

14 2 APPLICABLE U The initial conditions of Design Basis Accident and transient analyses in SAFETY the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), assume 1 3

ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to instrument provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. instrument The OPERABILITY of the AC, DC, and AC vital bus electrical power 1 distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. instrument The OPERABILITY of the minimum AC, DC, and AC vital bus electrical 1 power distribution subsystems during MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies ensures that: 3

a. The unit can be maintained in the shutdown or refueling condition for 4 extended periods,

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and 4

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, AC and DC 3 electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

The AC and DC electrical power distribution systems satisfy Criterion 3 of 5 10 CFR 50.36(c)(2)(ii).

WOG STS B 3.8.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 280 of 286

Attachment 1, Volume 13, Rev. 1, Page 281 of 286 Distribution Systems - Shutdown B 3.8.10 BASES LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires power energization of the portions of the electrical distribution system necessary 5 to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

3 fuel handling accidents [involving handling recently irradiated fuel]).

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of [recently] 3 irradiated fuel assemblies, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,

4

b. Systems needed to mitigate a fuel handling accident [involving 3

handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] are available,

4

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and

4

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

instrument The AC, DC, and AC vital bus electrical power distribution subsystems 1 requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

WOG STS B 3.8.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 281 of 286

Attachment 1, Volume 13, Rev. 1, Page 282 of 286 Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued) 1 2 3 4 TSTF-A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 471-A Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting TSTF-sufficient required features to allow continuation of CORE ALTERATIONS 471-A and [recently] irradiated fuel movement. By allowing the option to declare 3 required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made TSTF-(i.e., to suspend CORE ALTERATIONS, movement of [recently] irradiated 471-A 3

fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that 7 what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required TSTF-Actions, a required residual heat removal (RHR) subsystem may be 3 471-A inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be 4 entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions.

WOG STS B 3.8.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 282 of 286

Attachment 1, Volume 13, Rev. 1, Page 283 of 286 Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

SURVEILLANCE SR 3.8.10.1 instrument 1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution subsystems are functioning properly, with all the buses energized. The verification of proper voltage availability on the buses required 6 ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. FSAR, Chapter [6].

14 2 3 1 2. FSAR, Chapter [15].

U WOG STS B 3.8.10-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 13, Rev. 1, Page 283 of 286

Attachment 1, Volume 13, Rev. 1, Page 284 of 286 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10 BASES, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Changes are made to the Bases that reflect changes made to the Specifications.

2. 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.

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. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

5. Changes are made to be consistent with the name of the Specification.

6. Changes are made to be consistent with the Specification.

7. Typographical/grammatical error corrected.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 284 of 286

Attachment 1, Volume 13, Rev. 1, Page 285 of 286 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 1, Page 285 of 286

Attachment 1, Volume 13, Rev. 1, Page 286 of 286 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 13, Rev. 1, Page 286 of 286

v t e Letter Sequence Other
TAC:ME2139, Deletion of E BAR Definition and Revision to RCS Specific Activity Tech Spec (Approved, Closed)
Initiation Request, Request, Request, Request, Request Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance Questions 13 January 2010 11 March 2010 Answers Results Approval, Approval, Approval Other: ML093130368, ML102210288, ML102371088, ML102371098, ML102371109, ML102371140, ML102371178, ML102371203, ML102371205, ML102371210, ML102371257, ML102371260, ML102371266, ML102371269, ML102371282, ML102371283, ML102371290, ML102371292, ML102371294, ML102371297, ML102580704, ML102580706, ML102580709, ML102580710, ML102670754, ML102730398, ML102730399, ML103370691, ML110260316
MONTHYEAR2010-07-01 [Table View]

ML102371140

Text

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