ML102580710

Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, ITS NRC Questions

ML102580710
Person / Time
Site:	Kewaunee
Issue date:	09/08/2010
From:	Dominion, Dominion Energy Kewaunee
To:	Office of Nuclear Reactor Regulation
References
10-521, LAR 249, TAC ME2139
Download: ML102580710 (7)

Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 1 of 7 ITS NRC Questions Id 2211 NRC Question KAB-084 Number Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number JFD Bases Number Page Number 102 (s)

NRC Reviewer Carl Schulten Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 102 of Attachment 1, Volume 16, insert 8 adds 5.5.16 the Kewaunee Setpoint Control Program (SCP) to the Administrative Controls section. Please provide a SCP that does not allow processing changes to be made to Kewaunees instrumentation settings without an approved setpoint methodology.

Attach File 1 Attach File 2 Issue Date 8/19/2010 Added By Kristy Bucholtz Date Modified Modified By Date Added 8/19/2010 11:55 AM Notification NRC/LICENSEE Supervision Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 1 of 7 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2211 08/20/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 2 of 7 Licensee Response/NRC Response/NRC Question Closure Id 4071 NRC Question KAB-084 Number Select Licensee Response Application

Response

8/19/2010 1:55 PM Date/Time Closure Statement Response Based on conversations with the NRC staff, KPS has developed an ITS Statement 5.5.16, Setpoint Control Program, that does not allow processing changes to the KPS instrument setting without an approved setpoint methodology.

A draft markup of the current revision (Rev. 1) regarding this change is attached. This change will be reflected in a supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment KAB-084 Markup.pdf (970KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Carl Schulten Added By Robert Hanley Date Added 8/19/2010 1:58 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 2 of 7 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4071 08/20/2010

Attachment 1, Volume 16, Rev. 1, Page 105 of 171 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 3 of 7 5.5 CTS 1

INSERT 8 DOC M11 5.5.18 Setpoint Control Program 25 16 This program shall establish the requirements for ensuring that setpoints for automatic protective devices are initially within and remain within the assumptions of the applicable safety analysis provides a means for processing 27 changes to instrumentation setpoints and identifies setpoint methodologies to ensure instrumentation will function as required. The program shall ensure that testing of automatic protective devices related to variables having significant safety functions as delineated by 10 CFR 50.36(c)(1)(ii)(A) verify that instrumentation will function as required.

a. The program shall list the Functions in the following specifications to which it applies: Protection P

1. LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation";

2. LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation Functions";

Offsite O

3. LCO 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation";

Vent 26

4. LCO 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation";

Post Accident Recirculation (CRPAR) and

5. LCO 3.3.7, "Control Room Emergency Filtration System (CREFS)

Actuation Instrumentation;" ."

6. LCO 3.3.8, "Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation;"

7. LCO 3.3.9, "Boron Dilution Protection System (BDPS)."

list the value of

b. The program shall require the Nominal Trip Setpoint (NTSP), Allowable Value for each (AV), As-Found Tolerance (AFT), and As-Left Tolerance (ALT) (as applicable) of the Functions described in Paragraph a. are calculated using 27 the NRC approved setpoint methodology, as listed below. In addition, the program shall list the value of the NTSP, AV, AFT, or ALT (as applicable) for each Function described in paragraph a. and shall identify the setpoint methodology used to calculate these values.

The NRC staff has not approved processing changes to Kewaunee Power Station instrumentation setpoints under 10 CFR 50.59 using an approved setpoint methodology as described in Option B of TSTF-493. NRC approval using 10 CFR 50.90 is required to change the listed value of the NTSP, AV, AFT, and ALT (as applicable) for each Function described in Paragraph a.

Insert Page 5.5-18b Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 3 of 7 Attachment 1, Volume 16, Rev. 1, Page 105 of 171

Attachment 1, Volume 16, Rev. 1, Page 106 of 171 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 4 of 7 5.5 CTS 1 INSERT 8 (continued)

DOC M11 --------------------------------- Reviewer's Note ---------------------------------------

List the NRC safety evaluation report by letter, date, and ADAMS accession 15 number (if available) that approved the setpoint methodologies.

27 1

NRC Safety Evaluation dated [ ] 1. [Insert reference to NRC safety evaluation that approved the setpoint methodology.]

c. The program shall establish methods to ensure that Functions described in Paragraph a. will function as required by verifying the as-left and as-found 27 settings are consistent with those established by the setpoint methodology. If the as-found value of the instrument channel trip setting is less conservative than the specified AV, then the SR is not met and the instrument channel the list of values established by Paragraph shall be immediately declared inoperable.

b.

d. ----------------------------------- REVIEWERS NOTE --------------------------------------

A license amendment request to implement a Setpoint Control Program must list the instrument functions to which the program requirements of paragraph

d. will be applied. Paragraph d shall apply to all Functions in the Reactor Trip System and Engineered Safety Feature Actuation System specifications unless one or more of the following exclusions apply:

1. Manual actuation circuits, automatic actuation logic circuits or to instrument functions that derive input from contacts which have no associated sensor or adjustable device, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded. In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded.

2. Settings associated with safety relief valves are excluded. The 15 performance of these components is already controlled (i.e., trended with as-left and as-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program.

3. Functions and Surveillance Requirements which test only digital components are excluded. There is no expected change in result between SR performances for these components. Where separate as-left and as-found tolerance is established for digital component SRs, the requirements would apply.

Insert Page 5.5-18c Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 4 of 7 Attachment 1, Volume 16, Rev. 1, Page 106 of 171

Attachment 1, Volume 16, Rev. 1, Page 107 of 171 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 5 of 7 No changes. For Info only 5.5 CTS 1

INSERT 8 (continued)

DOC M11 The program shall identify the Functions described in Paragraph a. that are automatic protective devices related to variables having significant safety functions as delineated by 10 CFR 50.36(c)(1)(ii)(A). The NTSP of these Functions are Limiting Safety System Settings. These Functions shall be demonstrated to be functioning as required by applying the following requirements during CHANNEL CALIBRATIONS, CHANNEL OPERATIONAL TESTS, and TRIP ACTUATING DEVICE OPERATIONAL TESTS that verify the NTSP.

1. The as-found value of the instrument channel trip setting shall be compared with the previous as-left value or the specified NTSP.

2. If the as-found value of the instrument channel trip setting differs from the previous as-left value or the specified NTSP by more than the pre-defined test acceptance criteria band (i.e., the specified AFT), then the instrument channel shall be evaluated before declaring the SR met and returning the instrument channel to service. This condition shall be entered in the plant corrective action program.

3. If the as-found value of the instrument channel trip setting is less conservative than the specified AV, then the SR is not met and the instrument channel shall be immediately declared inoperable.

4. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the NTSP at the completion of the surveillance test; otherwise, the channel is inoperable (setpoints may be more conservative than the NTSP provided that the as-found and as-left tolerances apply to the actual setpoint used to confirm channel performance).

e. The program shall be specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

the Technical Requirements Manual Insert Page 5.5-18d Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 5 of 7 Attachment 1, Volume 16, Rev. 1, Page 107 of 171

Attachment 1, Volume 16, Rev. 1, Page 112 of 171 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 6 of 7 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage." This is inconsistent with the OPERABILITY requirements used in the KPS ITS, which state that verifying battery float current to be 2 amps while on float charge determines the battery is fully charged (See SR 3.8.6.1).

Exception 5: Regulatory Guide 1.129, Regulatory Position 7, recommends recording the specific gravity and float voltage of each cell in the string following the test. The Battery Monitoring and Maintenance Program requires obtaining specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations. The provision to follow the manufacturer's recommendations is a reasonable allowance given that the battery manufacturer is qualified to determine the benefit of the readings.

25. ISTS 5.5.18, "Setpoint Control Program (SCP)," has been added consistent with proposed TSTF-493, Revision 4. Any changes to the proposed program are discussed in other Justification for Deviations. In addition, the bracketed ISTS 5.5.3, "Post Accident Sampling," and the ISTS 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program," are not included in the Kewaunee Power Station (KPS) ITS. Therefore, this Specification has been renumbered in the KPS ITS as 5.5.16.

26. Changes are made to be consistent with the LCO title in Section 3.3. In addition, ISTS 3.3.8 and 3.3.9 have not been adopted in the KPS ITS.

27. The NRC has not approved processing changes using the KPS setpoint methodology such that the Setpoint Control Program can be implemented as described in TSTF-493, Rev. 4 and shown in Insert 8. Therefore, based on discussions with the NRC staff, changes have been made to the Setpoint Control Program that essentially requires any changes to the NTSP, AV, AFT and ALT be reviewed and approved by the NRC.

Kewaunee Power Station Page 5 of 5 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 6 of 7 Attachment 1, Volume 16, Rev. 1, Page 112 of 171

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 7 of 7 Licensee Response/NRC Response/NRC Question Closure Id 4081 NRC Question KAB-084 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 8/19/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 8/19/2010 2:12 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 16 (Chapter 5.0) Rev 2, Page 7 of 7 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4081 08/20/2010