ML12068A142

Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications

ML12068A142
Person / Time
Site:	Kewaunee
Issue date:	02/27/2012
From:	Jordan A Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-038, TAC ME7110
Download: ML12068A142 (18)

Text

Dmn ion Dominion Energy Kewaunee, Inc.

N490 Hwy 42, Kewaunee, WI 54216 Web Address: www.dom.com FEB 2 7 2012 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Serial No.12-038 LIC/CDS/R2 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 244, PROPOSED REVISION TO RADIOLOGICAL ACCIDENT ANALYSIS AND CONTROL ROOM ENVELOPE HABITABILITY TECHNICAL SPECIFICATIONS (TAC NO. ME7110)

By application dated August 30, 2011 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). This proposed amendment (LAR 244) would revise the KPS Operating License by modifying the Technical Specifications (TS) and the current licensing basis (CLB) to incorporate changes to the current radiological accident analysis (RAA) of record. This amendment would also fulfill a commitment made to the NRC in response to Generic Letter 2003-01, "Control Room Habitability" (References 1 and 2) to submit proposed changes to the KPS TS based on the final approved version of TSTF-448, "Control Room Habitability."

Subsequently, on January 9, 2012 the Nuclear Regulatory Commission (NRC) staff transmitted a request for additional information (RAI) regarding the proposed amendment (References 3 and 4). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.

I 4L~

Serial No.12-038 LAR 244 RAI Response Page 2 of 3 If you have any questions or require additional information, please contact Mr. Craig Sly at 804-273-2784.

Sincerely, A. J.

Poeotaio Site Vice r Psident - Kewaunee Power Station STATE OF WISCONSIN

))

COUNTY OF KEWAUNEE

)

The foregoing document was acknowledged before me, in and for the County and State aforesaid, today by A. J. Jordan, who is Site Vice President - Kewaunee Power Station, of Dominion Energy Kewaunee, Inc.

He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 2iZ day of

,2012.

My Commission Expires:

/Z2_.

7!2, is?

Notary.Public I NOREEN WENBORNE Notary Public State of Wisconsin

Attachment:

1. NRC Request for Additional Information Questions and Dominion Energy Kewaunee Responses Commitments made in this letter: None

Serial No.12-038 LAR 244 RAI Response Page 3 of 3

References:

1. Letter from J. A. Price (DEK) to Document Control Desk (NRC), "License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications," dated August 30, 2011. [ADAMS Accession No. ML11252A521]

2. Letter from Craig W. Lambert (NMC) to Document Control Desk (NRC), "Generic Letter 2003-01; Control Room Habitability - Supplemental Response," dated April 1, 2005. [ADAMS Accession No. ML050970303]

3. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly (DEK), "ME7110 Kewaunee Amendment Request Re: Chi-over-Q - AHPB Request for Additional Information (RAI)," dated January 9, 2012. [ADAMS Accession No. ML12023A047]

4. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly, Jack Gadzala (DEK), "ME71 10 Kewaunee Amendment request Re: Chi-over-Q - AHPB Request for Additional Information (RAI) - firm RAI items," dated January 13, 2011. [ADAMS Accession No. ML12023A057]

cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No.12-038 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

LICENSE AMENDMENT REQUEST 244, PROPOSED REVISION TO RADIOLOGICAL ACCIDENT ANALYSIS AND CONTROL ROOM ENVELOPE HABITABILITY TECHNICAL SPECIFICATIONS NRC REQUEST FOR ADDITIONAL INFORMATION QUESTIONS AND DOMINION ENERGY KEWAUNEE RESPONSES KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.12-038 Page 1 of 14 NRC REQUEST FOR ADDITIONAL INFORMATION QUESTIONS AND DOMINION ENERGY KEWAUNEE RESPONSES On January 9, 2012 the Nuclear Regulatory Commission (NRC) staff transmitted a request for additional information (RAI) (References 3 and 4) regarding Dominion Energy Kewaunee, Inc. (DEK) proposed amendment LAR 244 (Reference 1). The RAI questions and associated DEK responses are provided below.

1. NRC Question 1 (ME7110- RAII-AHPB-Lapin-001-2012-02-12)

"Explain why it was found to be preferable to add manual actions rather than upgrade the quality classification and redundancy of Radiation Monitor R-23."

DEK Response:

A description of the control room ventilation system response to a radiation monitor R-23 actuation signal is provided in the response to Question 4 below.

DEK has performed a revised radiological accident analysis (RAA) that assumes no credit for radiation monitor R-23 automatic functions in mitigating the radiological consequences of postulated design basis accidents. Consequently, DEK is proposing to eliminate all credit for R-23 in isolating the control room and starting the CRPAR system.

The rationale for eliminating credit for R-23 is explained in LAR-244,, Section 2.7, "Removal of R-23 Credit for Control Room Isolation," which states:

"The R-23 system is not safety grade and consists of a single radiation monitor. In addition, the isolation signal generated by R-23 is only a partial signal that will not assure closure of all control room inlet and outlet ventilation dampers to provide complete control room isolation."

The revised RAAs are provided in LAR-244, Attachment 4 and require the following:

= In order to maintain Fuel Handling Accident (FHA) control room dose within limits without crediting the automatic functions provided by R-23, the proposed FHA analysis in LAR-244 requires; 1) the control room is isolated prior to moving

Serial No.12-038 Page 2 of 14 recently irradiated fuel, and; 2) the Control Room Post Accident Recirculation (CRPAR) system is manually initiated within 20 minutes of the release.

In order to maintain Locked Rotor Accident (LRA) control room dose within limits without crediting the automatic functions provided by R-23, the proposed LRA analysis in LAR-244 requires manual operator action within one hour following the LRA to isolate the control room and start CRPAR.

DEK is proposing to credit manual initiation of Safety Injection (SI) as an approved method to accomplish this requirement.

Initiation of SI isolates the control room and starts the CRPAR system.

DEK has elected to rely on the proposed manual actions rather than on upgrading the quality classification and redundancy of R-23 for the following reasons.

Eliminating credit for radiation monitor R-23 to isolate the control room and start the CRPAR system removes reliance on instrumentation that is not redundant, not safety grade, and does not provides complete isolation of the control room.

• The proposed manual actions for the FHA and LRA RAAs are simple, can be accomplished from the control room, and will be procedurally controlled.

The times for accomplishing these manual actions are reasonable.

" The proposed manual actions ensure a complete isolation of the control room will occur and that post-accident dose consequences are acceptable.

Upgrading the quality and redundancy of R-23 would be very costly and resource intensive without a commensurate decrease in plant risk. Upgrading the quality and redundancy of R-23 would not reduce the current core damage frequency or large early release frequency for the plant.

" The proposed manual actions for the FHA and LRA event provide a reasonable level of assurance that the control room operators will be adequately protected against the accidental release of radioactive gases and that the plant can be safely operated or shut down under design bacis accident conditions.

Although DEK is proposing to no longer credit R-23 in the revised RAAs, the current function of R-23 will not be changed.

DEK intends to maintain R-23 in service and functional for defense-in-depth.

A description of, and justification for, both of the proposed two new manual actions mentioned above is provided in LAR-244, Attachment 5.

o t

Serial No.12-038 Page 3 of 14

2. NRC Question 2 (ME7110- RAII-AHPB-Lapin-002-2012-02-12)

"Among the proposed changes is a change to LCO 3.9.6.a to allow the containment equipment hatch to be open during handling of recently irradiated fuel when measures are in place which ensure the capability to close equipment hatch in the event of a fuel handling accident (FHA). As described, closing the equipment hatch requires special tools and equipment, such as, a trolley, a 'Yactuator", chainfalls, etc.

a. How will personnel ensure that all required tools and equipment needed to close the equipment hatch are pre-staged/available and operable?

b. How will personnel know whether and what kind of radiation protection equipment and clothing is needed?

c. Is a written procedure required and available?

d. Is training provided to all personnel who may be called upon to close the equipment hatch ?"

DEK Response:

a. The equipment hatch trolley, jactuator, and chain operator are all permanently installed equipment. As such, this equipment is continuously available for closing the equipment hatch during refueling operations. The only tools needed to close the equipment hatch are a step ladder and a torque wrench. Required items (including resources to provide communication between the control room and personnel responsible for hatch closure) are verified available by the procedurally required equipment hatch closure plan contained in procedure MA-KW-MCM-BLD-002, "Opening and Closing Containment Building Inner Equipment Hatch," Attachment B. Procedure MA-KW-MCM-BLD-002 requires an inspection and lubrication of the trolley and rigging prior to the first time the hatch is opened for an outage. Because the same equipment is used to open and close the hatch, the equipment would remain in its same functional state and available to close the hatch, if needed.

b. The equipment hatch is operated from inside containment, where normal radiation protection requirements are always in effect. As such, personnel required to close the hatch would already be wearing the appropriate protective clothing as specified by the applicable radiation work permits for that area and activity. No special radiation protection requirements are necessary for closing the hatch beyond those normally required for this area of containment.

Serial No.12-038 Page 4 of 14

c. Procedure MA-KW-MCM-BLD-002, "Opening and Closing Containment Building Inner Equipment Hatch," provides instruction for opening and closing of the containment building inner equipment hatch. This procedure is a "Continuous Use" procedure. MA-KW-MCM-BLD-002, Attachment B, "Inner Equipment Hatch Closure Plan Documentation," contains a written equipment hatch closure plan for situations where personnel are required to be available and capable of closing the equipment hatch, if needed. Attachment B requires the following conditions be established and verified:

Equipment passing through hatch or that could obstruct closure can be rapidly removed.

Equipment necessary to expedite hatch closure is stationed at the hatch.

• Resources are available to provide communication between the Control Room and personnel responsible for hatch closure.

• The Shift Manager has a list of contacts to expedite hatch closure.

• Personnel are available in the area of the hatch with responsibility to remove obstructions and close the hatch.

• Personnel operating the hatch are qualified and briefed to close the hatch upon notification.

• The door is moved through the closure process to confirm closure capability.

Attachment B also requires personnel be assigned each shift to periodically monitor for compliance with these conditions.

d. MA-KW-MCM-BLD-002, Attachment B, "Inner Equipment Hatch Closure Plan Documentation," requires personnel who would be called upon to close the hatch to be briefed on performance of the procedure steps needed to close the hatch.

As stated in Procedure MA-KW-MCM-BLD-002, closing the equipment hatch is performed locally by the operator pulling on the operating chain. By design, the chain force is low enough such that one operator is capable of closing the hatch without assistance. The closing process consists of a few simple steps that are contained in the procedure.

Serial No.12-038 Page 5 of 14

3. NRC Question 3 (ME7110- RAII-AHPB-Lapin-003-2012-02-12)

A proposed new Note, applicable to LCO 3.9.6.c, would allow penetration flow paths providing direct access from the containment to outside atmosphere to be opened under administrative controls. How will each of the administrative controls be implemented:

a. How will containment penetration status be communicated? (to the CR and in-plant personnel)

b. How will designated personnel know their assigned penetration(s)?

c. How will designated personnel be cautioned about obstructions?

d. How will Operations know that designated personnel are at their posts?

DEK Response:

LCO 3.9.6, "Containment Penetrations,"

is a Refueling Operations Technical Specification and is currently applicable "During movement of recently irradiated fuel assemblies within containment." DEK is proposing to change the applicability of LCO 3.9.6 to "During movement of recently irradiated fuel assemblies."

Administrative controls that govern open containment penetration flow paths are contained in plant procedures (e.g., OP-AA-100, "Conduct of Operations;" OP-KW-NCL-FH-004, "Refueling Daily Checklist;" N-CCI-56A, "Open Containment Boundary Tracking;" N-CCI-56A-CL, "Reduced Inventory Containment Operability Checklist").

a. OP-KW-NCL-FH-004, "Refueling Daily Checklist," requires a daily check of remotely operated and automatic containment isolation valve status. These valves can be checked from panels and consoles in the control room.

Isolation boundaries for non-operable containment isolation valves and dampers are required to be administratively controlled by a Tagout.

N-CCI-56A currently requires that all open containment boundaries be recorded in an Open Boundary Tracking Log (required by N-CCI-56A as discussed below) and that the responsible work group and responsible person be recorded.

b. N-CCI-56A, "Open Containment Boundary Tracking," currently requires that a person shall be appointed for each open containment boundary to ensure the boundary is closed if containment closure is required. Additionally, this procedure requires that when the RCS is in a reduced inventory condition, then coverage for each open containment boundary shall be provided on a 24-hour basis by an

Serial No.12-038 Page 6 of 14 appointed responsible person. N-CCI-56A requires that the name of the person responsible for closure of each open penetration be listed in the Open Boundary Tracking Log maintained in the control room.

c. OP-AA-100, "Conduct of Operations," provides direction regarding the conduct of pre-job briefings and pre-job walk-downs. Such briefings and walk-downs would be expected to identify pertinent obstructions that could adversely impact the operators' ability to isolate an open penetration and include cautioning the operator about such obstructions. With respect to the containment hatch, procedure MA-KW-MCM-BLD-002, "Opening and Closing Containment Building Inner Equipment Hatch," contains a specific requirement that equipment passing through the hatch or that could obstruct hatch closure can be rapidly removed.

d. Procedure use is directed by plant administrative requirements.

Procedures specifying the conduct of operations, along with communication equipment operating procedures ensure that operators are aware of, and communicating with, designated personnel at their posts.

Serial No.12-038 Page 7 of 14

4. NRC Question 4 (ME7110- RAII-AHPB-Lapin-004-2012-02-12)

a. "Does Radiation Monitor R-23 perform any functions other than the isolation function that is being removed?

b. If yes, what functions will remain?

c. If no, will all controls, displays, and logic interfaces associated with R-23 be physically removed?"

DEK Response:

a. Actuation of the control room ventilation radiation monitor (R-23) causes a partial isolation of the control room and starts both control room post-accident recirculation fans. R-23 also provides indication, alarm, and trending of radiation levels. The following automatic actions occur when R-23 is actuated:

Post-Accident Recirculation Fans A and B start.

A/C Fans A and B start if in ON or AUTO.

Motor operated Dampers ACC-1A/MD-32367 and ACC-1 B/MD-32368 close to isolate both fresh air intakes.

Solenoid Valve SV-33094 de-energizes and closes the Non-Accident Fresh Air Damper ACC-5/CD-34007.

Post-Accident Recirculation Dampers ACC-3A/MD-32397 and ACC-3B/MD-32371 open.

Normally closed Post-Accident Fresh Air Damper ACC-2/MD-32370 closes if open.

R-23 also provides control room indication, alarm, and trending of radiation levels.

b. The current function of R-23 will not be changed. DEK is proposing to no longer credit R-23 in the revised RAAs.

However, DEK intends to maintain R-23 in service and functional for defense-in-depth. DEK plans to relocate the current TS requirements for R-23 into the KPS Technical Requirements Manual and maintain the description of R-23 in the KPS USAR as discussed in LAR-244, Attachment 1, Section 2.2.3.

c. All controls, displays, and logic interfaces associated with R-23 will remain physically installed in the plant and functional.

Serial No.12-038 Page 8 of 14

5. NRC Question 5 (ME7110- RAII-AHPB-Lapin-005-2012-02-12)

"In Attachment 5 of the licensee's revised submittal, it is stated that: "Operations personnel were included in the walkdown of the control room."

a. Was at least one crew included in the walkdown?

b. If not, what plans are being made to validate the procedures, training, and physical interfaces with a representative sample of operators, i.e., at least one crew."

DEK Response:

a. The walkdown was not performed by an operating crew. Rather, the walkdown was performed by a select group of operations personnel involved in obtaining information to support the license amendment request.

b. As part of the normal implementation process for this license amendment, the new operator actions and required times will be incorporated into the KPS time-critical operator action validation procedure, ORT-MISC-014, "Validation of Time Critical Operator Actions." Procedures, training, and physical interfaces will be validated for the new operator actions by demonstrating, with a representative sample of operators, that the time-critical operator action requirements of ORT-MISC-014 are satisfied.

Serial No.12-038 Page 9 of 14

6. NRC Question 6 (ME7110- RAII-AHPB-Lapin-006-2012-02-12)

"The revised RAA credits manual initiation of the CRE isolation within 60 minutes of the occurrence of an LRA, and initiation of the Control Room Post Accident Recirculation (CRPAR) system within 20 minutes of occurrence of a FHA and within 60 minutes of an LRA.

a, How were these completion times estimated?

b, What are the actual times or the estimated required times for these actions?

c. How much margin is built into the estimates of completion times?"

DEK Response:

a. To assess completion time estimates, Operations and Engineering personnel reviewed the analysis requirements, the proposed changes to the procedures, and then walked-through the actions that would be required to complete the new operator actions.

The actual completion times were estimated based on an assessment of performance time changes resulting from the proposed procedure changes, coupled with a walk-through of the actions.

b. The required times are those times that are assumed in the analyses (as stated therein). The actual times have been estimated to be within the required times with margin. Verification of the actual times will occur during the implementation phase of this amendment during the time-critical operator action validation performed in accordance with ORT-MISC-014, "Validation of Time Critical Operator Actions" (as discussed above).

Based on assessments and initial walkdowns, the final verifications are expected to confirm that actual times will fully conform to the analyses assumptions.

c. A conservative estimate is that at least 20% margin between the actual completion time and the required completion time is built into the estimates of the actual completion time.

Serial No.12-038 Page 10 of 14

7. NRC Question 7 (ME7110- RAII-AHPB-Lapin-007-2012-02-12)

[Deleted Question].

This question was deleted during a telephone discussion between NRC and DEK personnel on January 12, 2012 (see Reference 4)

Serial No.12-038 Page 11 of 14

8. NRC Question 8 (ME7110- RAII-AHPB-Lapin-008-2012-02-12)

"The licensee stated in Attachment 5 of the revised submittal, that "The appropriate modifications to plant procedures will be made as part of the implementation of this amendment request. Identify all procedure changes that will be made in support of this LAR.

Include the procedure numbers and titles of the affected emergency operating procedures."

DEK Response:

The following procedures are expected to be revised as a result of this LAR.

Fuel Handlinq Accident (FHA)

1. OP-KW-AOP-FH-002, "Dropped or Damaged Fuel Assembly."

The operator action to start the CRPAR system in the event of a FHA will likely become part of OP-KW-AOP-FH-002.

Currently, step 4 of this procedure describes operation of the CRPAR System and starting of the system per OP-KW-AOP-ACC-001, "Abnormal Control Room A/C System Operation."

2. NF-KW-RRF-014, "Fuel Movement during a Refueling Outage."

The specific procedure changes that will be made are not yet finalized. However, isolation of the CRE during movement of recently irradiated fuel assemblies is expected to become part of the NF-KW-RRF-014 pre-requisite requirements.

Locked Rotor Accident (LRA)

1. Emergency Operating Procedure ES-0.1, "Reactor Trip Response."

The specific changes to this procedure have not yet been finalized.

A LRA causes a reactor trip. In ES-0.1, if an automatic actuation of SI does not occur, the operators are directed to manually initiate both trains of SI if RCS subcooling, based on core exit thermocouple indication, is less than 150F. This action (manual initiation of SI) isolates the CRE and starts both CRPAR trains.

During certain potential LRA scenarios, there is the possibility that RCS subcooling could be lost and regained prior to operators completing their

Serial No.12-038 Page 12 of 14 initial post-trip actions (i.e. a short-duration LRA).

In such cases, the short-duration loss and recovery of RCS subcooling could initially go unnoticed by operators; whereupon they would not be prompted to initiate SI per ES-0.1.

However, based on the ongoing radiological event, operators would isolate the control room and start CRPARS in accordance with currently existing procedures (AOP-RM-001, "Abnormal Radiation Monitoring System").

Time Critical Operator Action Validation As described above, ORT-MISC-014, "Validation of Time Critical Operator Actions," will be revised to include the new operator manual actions for FHA and LRA response.

Serial No.12-038 Page 13 of 14

9. NRC Question 9 (ME7110- RAII-AHPB-Lapin-009-2012-02-12)

"Describe any changes to training that are necessary to support this LAR."

DEK Response:

Training needs are evaluated as part of the implementation process for license amendments. This includes the training needs for the new time-critical operator actions, starting the CRPAR system after a FHA, and initiating SI after a LRA.

Based on an initial assessment, operators would be trained on the new time-critical operator actions and their requirements. The two tasks, starting CRPAR and initiating Sl, are already contained in the Operations Training Programs. The training changes would reflect that these tasks are time-critical operator actions in response to specific accidents. These actions would also be included in the time-critical operator action validation procedure. Training changes would also be needed to address the procedure changes that are required to support LAR 244 (as required by existing processes).

Serial No.12-038 Page 14 of 14 References

1.

Letter from J. A. Price (DEK) to Document Control Desk (NRC), "License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications," dated August 30, 2011. [ADAMS Accession No. ML11252A521]

2.

Letter from Craig W. Lambert (NMC) to Document Control Desk (NRC), "Generic Letter 2003-01; Control Room Habitability - Supplemental Response," dated April 1, 2005. [ADAMS Accession No. ML050970303]

3.

E-mail from Karl D. Feintuch (NRC) to Craig D. Sly, Jack Gadzala (DEK), "ME71 10 Kewaunee Amendment request Re: Chi-over-Q - AHPB Request for Additional Information (RAI),"

dated January 9,

2011.

[ADAMS Accession No.

ML12023A047]

4.

E-mail from Karl D. Feintuch (NRC) to Craig D. Sly, Jack Gadzala (DEK), "ME71 10 Kewaunee Amendment request Re: Chi-over-Q - AHPB Request for Additional Information (RAI) - firm RAI items," dated January 13, 2011. [ADAMS Accession No. ML12023A057]