Text

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8)
	ML102371294
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: ML102371294 (0)
	v • d • e

ITS NRC Questions Id 2141 NRC Question Number MEH-009 Category Technical ITS Section 3.7 ITS Number 3.7.8 DOC Number JFD Number 6 JFD Bases Number 6 Page Number(s)

NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question The May 12, 2010 supplement to the TS Conversion LAR proposed the addition of the word necessarily to the note in SR 3.7.8.1. The staff believes the proposed addition is contrary to TS usage convention because inserting the word would allow intentional entry into LCO 3.7.8 ACTIONS for operational convenience. The Bases for LCO 3.0.2 specifically state: Intentional entry into ACTIONS should not be made for operational convenience.

The supplement stated that the reason for the proposed request is related to Area Fan Cooler Units and minimum Completion Times in Conditions of ITS 3.8.7 and 3.8.9. The staff believes that issues with such completion times should be addressed by proposing and justifying different Completion Times, not changing TS usage convention. If desired, please propose and justify different Completion Times for the affected Conditions of ITS 3.8.7 and 3.8.9.

Attach File 1 Attach File 2 Issue Date 6/8/2010 Added By Matthew Hamm Date Modified Modified By Date Added 6/8/2010 7:47 AM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Page 1 of 1 Kewaunee ITS Conversion Database 06/24/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2141 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 1 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 1 of 90

Licensee Response/NRC Response/NRC Question Closure Id 3611 NRC Question Number MEH-009 Select Application Licensee Response

Response

Date/Time 6/21/2010 4:10 PM Closure Statement

Response

Statement In the first paragraph of the NRC question, the NRC reviewer states that the staff believes that inserting the word "necessarily" into the SR Note would allow intentional entry into LCO 3.7.8 ACTIONS for operational convenience. The NRC question further states that LCO 3.0.2 Bases specifically states that intentional entry into ACTIONS should not be made for operational convenience. While KPS concurs that the LCO 3.0.2, through the Bases, prohibits intentional entry into ACTIONS for operational convenience, KPS does not agree that performing routine preventive and corrective maintenance is operational convenience. The ITS 3.0.2 Bases also states that "The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems" (italics added for emphasis). Thus, LCO 3.0.2 does allow intentional entry into ACTIONS to perform preventive and corrective maintenance, which is the purpose of the proposed KPS Note change.

Therefore, the proposed Note change is not contrary to the ITS usage convention.

However, KPS has reviewed the NRC request to include the Completion Times in each affected Specification. Based on this review, the previous Note change to ITS 3.7.8 is withdrawn (reference - Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "License Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications (TAC NO. ME02467) - Request to Change Proposed Service water and Main Steam Isolation Valve Specifications," dated May 12, 2010

[ADAMS Accession No. ML101380399]) and a new Note has been added to ITS 3.8.4, ITS 3.8.7, and ITS 3.8.9 to essentially allow a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time to restore a non-functional room cooler that affects the DC electrical power subsystems, inverters, or electrical power distribution subsystems. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment Page 1 of 2 Kewaunee ITS Conversion Database 06/25/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3611 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 2 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 2 of 90

1 MEH-009 Markup.pdf (2MB)

Attachment 2

Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 6/21/2010 4:26 PM Modified By Date Modified Page 2 of 2 Kewaunee ITS Conversion Database 06/25/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3611 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 3 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 3 of 90

A01 ITS ITS 3.8.4

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.

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 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.

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 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 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.

Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months MODE 3 M01 M02 2

DC electrical power subsystem L01 M03 Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 Add proposed ACTIONS Note L02 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 4 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 4 of 90

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS.

INSERT DOC L02 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 5 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 5 of 90

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: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) 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 hour2.777778e-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.

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 6 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 6 of 90

DC Sources - Operating 3.8.4 WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1

3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [or two] battery charger[s on one train]

inoperable.

A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage.

AND A.2 Verify battery float current

[2] amps.

AND A.3 Restore battery charger[s]

to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Once per [12] hours 7 days

[B. One [or two] batter[y][ies on one train] inoperable.

B.1 Restore batter[y][ies] to OPERABLE status.

[2] hours ]

C. One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

C.1 Restore DC electrical power subsystem to OPERABLE status.

[2] hours D. Required Action and Associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours required CTS 3.7.a.6 B

C C

DOC L01 3.7.b.3 3.7.b 3

3 3

2 B

3.7.a 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4

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

When a DC electrical power subsystem is 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: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the other DC electrical power subsystem is OPERABLE.

6 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 7 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 7 of 90

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.

Kewaunee Power Station Page 1 of 1

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 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 hour2.777778e-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.

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 8 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 8 of 90

DC Sources - Operating B 3.8.4 WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 BASES LCO The DC electrical power subsystems, each subsystem consisting of [two]

batteries, battery charger [for each battery] and the corresponding control 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).

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."

ACTIONS A.1, A.2, and A.3 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.

All changes are unless otherwise noted 1

2 7

2 y

subsystem y

one one 2

required 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 a DC electrical power subsystem is 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 other DC electrical power subsystem is 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 other DC electrical power subsystem becomes inoperable, the associated ACTIONS for an inoperable DC electrical 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 acceptable because the room containing the DC electrical power subsystems is monitored on an hourly basis to ensure conditions are within design environmental requirements during this time.

7 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 9 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 9 of 90

Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 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 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:

a.

The associated AC vital bus(es) [is/are] energized from [its/their]

[Class 1E constant voltage source transformers] [inverter using internal AC source], and

b.

All other AC vital buses are energized from their associated OPERABLE inverters. ]

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [required] inverter inoperable.

A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized.

Restore inverter to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instrument instrument 5

INSERT 1 C

C instrument

/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1

2 2

6 5

1 5

3 3

INSERT 1A Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 10 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 10 of 90

3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable.

B.1 Restore one inverter to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months DOC M01 3

CTS INSERT 1A

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: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) both inverters in the other train are OPERABLE.

7 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 11 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 11 of 90

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.

Kewaunee Power Station Page 1 of 1

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 is 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.

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 12 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 12 of 90

Inverters - Operating B 3.8.7 WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1

BASES Train A or Train B ACTIONS A.1 instrument 4

With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant voltage source transformer or inverter using internal AC source].

For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

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 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 judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 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.

4 6

2 5

Train A or Train B inverters C

C instrument

/rectifier instrument 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").

INSERT 1 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 a one or both inverters in one train 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 both inverters 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 one or both of the inverters in the other train become inoperable, the associated ACTIONS for the inoperable inverter(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 inverters is monitored on an hourly basis to ensure conditions are within design environmental requirements.

4 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 13 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 13 of 90

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

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

Applicability

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 respective station service transformers.

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

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; 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:

A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02 Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01 Train A and B AC electrical power distribution subsystem shall be OPERABLE.

LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 ACTIONS Note Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 14 of 90 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 14 of 90

A01 ITS ITS 3.8.9