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Enclosure, Q&A to Attachment 1, Volume 14 (Section 3.9)
	ML102371297
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: ML102371297 (208)
	v • d • e

ITS NRC Questions Id1461NRC Question Number RPG-001 Category Technical ITS Section 3.9 ITS Number 3.9.1 DOC Number JFD Number JFD Bases Number Page Number(s)

NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Marked-up changes to CT S pages for several LCOs in ITS section 3.9, "Refueling Operations," refer to same CTS LCO Cond ition instead of specifying the affected ITS LCO Condition. For e xample, a side note for CTS LCO Conditions 3.8.a.1a and b, (pl. refer to Attachment 1, Volume 14, Rev 0, Page 5 of 1 75), states, "see CTS 3.8.a.1 and 3.8.a.

8." The side note should have specified the affected ITS LCO Condition to which the CTS LCO Conditions 3.8.a.1a&b are relocated/converted.

This concern also applies to side notes on the same page (page 5) for CTS LCO Conditions 3.8.a.2, 3.8.a.3, and note 1 (bottom of CTS page 3.8-1). Please note that marked changes on page 5 are also repeated on pa ges 25, 26, 27, 48, 49, 94, 95, 111, 112 , 119, 126, 132, 139, and 147.

The staff believes that correct marked-up changes are necessary to perform a technical review of the subject ITS section.

Attach File 1 Attach File 2 Issue Date 1/8/2010 Added By Ravinder Grover Date Modified Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1461 Modified By Date Added 1/8/2010 2:24 PM Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1461 Licensee Response/NRC Response/NRC Question Closure Id1841NRC Question Number RPG-001 Select Application Licensee Response Response Date/Time 1/21/2010 12:45 PM Closure Statement Response Statement During the ITS conversion, informati on which is included in the current Technical Specifications (CTS) will no t be captured in the site specific Improved Technical Specifications (ITS). When this happens, a specific section in the submittal is provided for the information not being relocated. When the entire Specific ation is not being relocated, this information is included in the Volume of the submittal that closely relates to the Specification. It will be contained in an area called "Relocated/Deleted Curren t Technical Speci fication." This Specification in this section is identified by the CTS Specification number. Each Relocated/Deleted Specification includes a CTS Markup, Discussion of Change, and a Specific No Significa nt Hazard Consideration. The information that you are looking for is contained in Attachment 1, Volume 14, starting on page 108 of 175.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 1/21/2010 12:46 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1841 Licensee Response/NRC Response/NRC Question Closure Id2391NRC Question Number RPG-001 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 Date 3/2/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Added By Ravinder Grover Date Added 3/2/2010 12:12 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2391 ITS NRC Questions Id1781NRC Question Number RPG-002 Category Technical ITS Section 3.9 ITS Number 3.9.1 DOC Number JFD Number JFD Bases Number Page Number(s) 15 of 175 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question Attachment 1, Volume 14, Rev. 0, Page 15 of 175 proposed ITS Bases Section B 3.9.1 A statement in ITS Bases Section B 3.9.1 (3rd paragraph) states, "The Chemical and Volume Control System (CVCS) is the system capable of maintaining the reactor subcritical in cold conditions by maintaining the boron concentration."

KPS proposes to replace the statement with insert 1 on Page 16. However, the proposed insert does not specify a plant specific system for maintaining the boron concentration. KPS USAR section 1.3.5, "Reactivity Control (GDC 27 - GDC 32)," states, "In addition to the reactivity control achieved by the RCC assemblies (RCCA) as detailed in Chapter 7, reactivity control is provided by the Chemical and Volume Control System which regulates the concentration of boric acid solution neutron absorber in the Reactor Coolant System."

Please explain the reason for deletion of the CVCS function from the Bases section. Attach File 1 Attach File 2 Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1781 Issue Date 2/24/2010 Added By Ravinder Grover Date Modified Modified By Date Added 2/24/2010 3:49 PM Notification NRC/LICENSEE Supervision Ravinder Grover Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1781 Licensee Response/NRC Response/NRC Question Closure Id2371NRC Question Number RPG-002 Select Application Licensee Response Response Date/Time 3/2/2010 10:50 AM Closure Statement Response Statement While the quoted informati on from USAR section 1.3.5 is correct, it is not the current and licensed requirement; it is the original FSAR requirement. Specifically, on the first page of Section 1.3, a No te at the front of the Section states:

"NOTE: Section 1.

3 provides original lice nsing and design basis information for the Kewaunee Plant as described in the facility license application Amendment No. 7 (the FSAR), dated January 27, 1971, and subsequent Amendments 8 through 20; and approved in the AEC Safety Evaluation issued July 24, 1972, and its supplements. This information was developed in support of pl ant licensing; therefore, this section is considered historical and should not be revised. Updated information can be found in the applicable section of the USAR." For KPS GDC 27, this is found in USAR Section 3.1.2.3, as shown in the Reference Section of the ITS 3.9.1 Bases (Page 19).

USAR Section 3.1.2.3 states as the Criterion: "Two i ndependent reactivit y control systems, preferably of different principles, shal l be provided (GDC 27)." These are the words KPS inserted in lieu of the ISTS wording for 10 CFR 50, Appendix A, GDC 26.

KPS further noted that the ISTS wo rding stated that there were two independent reactivity co ntrol systems, bu t only one potential system, the Chemical and Volume C ontrol System (CVCS), is identified in the paragraph. The main reactivity control system that is specified in the Technical Specifications, i.

e., control rods, is not in the paragraph. KPS also reviewed the wording of 10 CFR 50, Appendix A, GDC 56 and noted that the ISTS wording does not matc h the GDC being referenced. The words in 10 CFR 50, Appendix A are:

" Criterion 26--Reactivity control system re dundancy and capability. Two independent reactivity co ntrol systems of differen t design principles shall be provided. One of the systems sh all use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of

normal operation, in cluding anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2371 acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel desi gn limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions." None of the words in 10 CFR 50, Appendix A use the CVCS by name. Furthermore, the CVCS was deleted fr om the Technical Specifications and allowed to be placed in a document unde r utility control when the ISTS was originally issued. Thus, adding the name of a non-Technica l Specification System into the Applicable Safety Analyses Bases coul d imply that the System needs to be in the Technical Specification.

Therefore, KPS does not believe that the CVCS should be mentioned in the Bases paragraph, and that the propos ed words in the KPS submittal are correct and should be maintained as is.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Robert Hanley Jerry Jones Bryan Kays Added By David Mielke Date Added 3/2/2010 10:57 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2371 Licensee Response/NRC Response/NRC Question Closure Id2631NRC Question Number RPG-002 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 Date 3/18/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Added By Ravinder Grover Date Added 3/18/2010 9:05 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2631 ITS NRC Questions Id1791NRC Question Number RPG-003 Category Technical ITS Section 3.9 ITS Number 3.9.5 DOC Number JFD Number 3 JFD Bases Number Page Number(s) 58, 59 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question Attachment 1, Volume 14, Rev. 0, Page 58 of 175 proposed ITS LCO 3.9.3, "Residual Heat Removal (RHR) and Coolant Circulation

- High Water Level

" Proposed change deletes logical connector OR between Required Actions A.6.1 and A.6.2. Justification For Deviations (JFD) note 3 on page 59 states, "ISTS 3.9.5 Required Actions A.6.1 and A.6.2 are connected by an "OR" logical connector, such that either one can be performed to meet the requirements of the ACTION. However, the two Required Actions are applicable to all the penetrations; either Required Action A.6.1 or Required Action A.6.2 must be performed for all the penetrations. Thus, this will not allow one penetration to be isolated by use of a manual valve and another penetration to be capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. This is not the intent of the requirement. The requirement is based on ISTS LCO 3.9.4, which requires each penetration to be either: a) closed by a manual or automatic isolation valve, blind flange, or equivalent; or b) capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. For consistency with the actual LCO requirement, ISTS 3.9.5 Required Actions A.6.1 and A.6.2 have been combined into a single Required Action in ITS 3.9.3 Required Action A.6."

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1791 TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings. Required Actions A.6.1 and A.6.2 as specified in the TS, must be taken when the plant is in Condition A. These Actions as well as Completion Times for the Actions are not bracketed, and therefore plant specific changes are not acceptable. Revise the proposed ITS to incorporate the Required Actions and completion times of A.6.1 and A.6.2 per NUREG-1431, Revision 3. .

Please note, the above evaluation also applies to proposed changes in ITS LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level," Attachment 1, Volume 14, Rev. 0, Page 79 of 175.

Attach File 1 Attach File 2 Issue Date 2/25/2010 Added By Ravinder Grover Date Modified Modified By Date Added 2/25/2010 9:16 AM Notification NRC/LICENSEE Supervision Ravinder Grover Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1791 Licensee Response/NRC Response/NRC Question Closure Id2481NRC Question Number RPG-003 Select Application Licensee Response Response Date/Time 3/8/2010 10:20 AM Closure Statement Response Statement The purpose of ISTS 3.9.5 Required Actions A.4, A.5, A.6.1 and A.6.2, as stated in the ISTS Bases, is to ensure that all c ontainment penetrations are either closed or can be closed so that the dose limits are not exceeded when the RHR loop requirements are not met. These actions come directly from the requirements of ISTS 3.9.3. With respect to the penetrations providing direct access fr om the containment atmo sphere to the outside atmosphere, ISTS LC O 3.9.3.c (shown on Page 16 4 of Volume 14) requires that for each penetration, either it mu st be capable of being closed by a manual or automatic isolatio n valve, blind flange, or equivalent, or it must be capable of being closed by an OPERABLE Contai nment Purge and Exhaust Isolation System. Thus, ISTS LCO 3.9.3 allows either option for each of the penetrations; a single option does not have to be used for all of the penetrations.

ISTS 3.9.5 Required Actions A.6.1 and A.6.2 are written su ch that only one of these can be used for every single penetration. Either you have to meet Required Action A.6.1 for al l the penetrations or y ou have to meet Required Action A.6.2 for all the penetrati ons. Obviously, a plant cannot meet Required Action A.6.2 fo r all the penetrations, since they all do not have automatic closure capability. The true intent of these two Required Actions is as stated in the ISTS Bases.

The ISTS Bases for these two Required Actions (Page 64) are in the same paragraph and describes that each penetration must be closed by a manual or automatic isol ation valve, blind flange, or equivalent, or verified to be capable of being closed by and OPERABLE Containment Purge and Ex haust Isolation Sy stem. Thus, for each penetration, you chose Required Action A.6.1 or A.6.2.

KPS has made a change to reflect wh at the requirements are in both ISTS LCO 3.9.3 and ISTS 3.9.5 Required Actions A.6.1 and A.6.2 Bases.

Adopting the ISTS 3.9.5 Required Actions A.6.1 an d A.6.2 as written, without combining the two in a single Required Action, wo uld force KPS to essentially use ISTS 3.9.5 Required Action A.6.1 at all times (since not all penetrations are capable of being closed by an automatic isolation system). This change has been previously reviewed and approved by the NRC during recent ITS c onversions, like DC Cook Units 1 and 2 and Davis-Besse. Therefore, KPS believes that this change is only an editorial change to correct an inconsistency with the base requirement in ISTS Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2481 3.9.3. Furthermore, as proposed in ITS 3.9.3 Re quired Action A.6 (i.e., combined into one Required Action), it is also consistent with the ISTS Bases for the Required Actions.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Robert Hanley Jerry Jones Bryan Kays Added By David Mielke Date Added 3/8/2010 10:21 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2481 Licensee Response/NRC Response/NRC Question Closure Id2671NRC Question Number RPG-003 Select Application NRC Response Response Date/Time 3/29/2010 6:00 PM Closure Statement Response Statement Attachment 1, Volume 14, Rev. 0, Page 58 of 175 proposed ITS LCO 3.9.3, "Residual Heat Removal (RHR) and Coolant Circulation

- High Water Level

" FOLLOW-UP on the Licensee

's response to the NRC

's question RPG

-003 NRC question RPG-003 concerned KPS's proposed ITS deletion of the logical connector OR between Required Actions A.6.1 and A.6.2. KPS's 3/8/2010, response to question RPG-003 does not provide adequate justification for the change. Please provide plant-specific information to explain why the the logical connector format, as stated in the STS and reiterated in the question, 'Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies' is NOT applicable to the KPS ITS. Also, please provide the plant-specific justification for the proposed ITS deletion of

'OPERABLE' requirement from STS REQUIRED ACTION A.6.2 for the Containment Purge and Exhaust System.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Added By Ravinder Grover Date Added 3/29/2010 1:10 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2671 Licensee Response/NRC Response/NRC Question Closure Id2861NRC Question Number RPG-003 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 Date 4/29/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Added By Ravinder Grover Date Added 4/29/2010 3:02 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2861 ITS NRC Questions Id1801NRC Question Number RPG-004 Category Technical ITS Section 3.9 ITS Number 3.9.3 DOC Number JFD Number JFD Bases Number Page Number(s) 58 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question Attachment 1, Volume 14, Rev. 0, Page 58 of 175 , proposed ITS LCO 3.9.3, "Residual Heat Removal (RHR) and Coolant Circulation

- High Water Level," Proposed change in SR 3.9.3.1 deletes the bracketed flow rate requirement for the RHR loop. This information is required to satisfy the surveillance criteria in 10CFR50.36(c)(3). The flow rate is specified in the

KPS USAR. Please note, the same concern also applies to proposed ITS LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level," Attachment 1, Volume 14, Rev. 0, Page 80 of 175.

Attach File 1 Attach File 2 Issue Date 2/25/2010 Added By Ravinder Grover Date Modified Modified By Date Added 2/25/2010 9:20 AM Notification NRC/LICENSEE Supervision Ravinder Grover Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1801 Licensee Response/NRC Response/NRC Question Closure Id2501NRC Question Number RPG-004 Select Application Licensee Response Response Date/Time 3/10/2010 7:05 AM Closure Statement Response Statement The Kewaunee Power Station (KPS)

CTS does not include any shutdown cooling minimum flow rate requirements while in MODE 6.

KPS added SR 3.9.3.1 (and SR 3.9.

4.1) as part of the ITS conversion. However, the minimum flow rate value w as not included, as is stated in JFD 5. The JFD states that "The ISTS Bases states that the flow rate is determined by the flow rate necessary to pr ovide sufficient decay heat removal capability.

However, the decay heat is not always the same; it is a function of time after shutdown and the power history of the fuel." Thus, there is no single value of shutdown cooling flow that will ensure decay heat is removed under all conditions. The JFD further states "Furth ermore, SRs in Section 3.4 (ITS SRs 3.4.6.1, 3.4.7.1, and 3.4.8.1) require a similar verification that the RHR loop is in op eration, but do not specify a flow rate requirement." In addition, KPS does not have RHR flow indication that could quantify the fl ow through the RHR heat exchanger (which is the flow removing the decay heat). The RH R flow meter is downstream of the connection where the heat exchanger discharge flow and heat exchanger bypass fl ow is merged. When in the shutdown cooling mode, some of the flow is going through th e heat exchange r and some of the flow is bypassing the heat exchanger. Flow through the bypass is throttled to obtain the flow necessary to maintain RCS temperature at the desired value. However, the actual flow through the heat exchanger is not known, only the total RHR flow is known. USAR Figure 9.3-1, on page 9.3-27, provides a drawing of the RHR System (FT 626 is the flow instrument)

KPS believes that includin g a Surveillance to ver ify one RHR loop is in operation and circulating reactor coolant is suff icient to ensure the surveillance criteria of 10 CFR 50.36(c)(3) are met. Sp ecifically, 10 CFR 50.36(c)(3) states that "S urveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the li miting conditions for operation will be met." SR 3.9.3.1 c ontinues to ensure that this requirement is met, since there is no specific flow value in any safety limit. LCO 3.9.3 is required to ensure temperature is maintained to prevent boiling (as stated in the ASA section of the ISTS Bases), and this is met by having one RHR loop in operation and circulating coolant.

Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2501 Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 3/10/2010 7:05 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2501 Licensee Response/NRC Response/NRC Question Closure Id2641NRC Question Number RPG-004 Select Application NRC Response Response Date/Time 3/19/2010 6:00 PM Closure Statement Response Statement KPS's March 10, 2010 res ponse to the NRC questi on RPG-004 concerning KPS's justification for not specifying the RHR loop flowrate as required in the ITS, and KPS's proposed changes to the ITS Bases section B3.9.3 (Page 64 of 175), do not provide adequate information on how KPS's circulating coolant system woul d ensure that thermal and boron stratification is minimize d without establishing the R HR loop flow rate. The ITS Bases state that RHR loop flowrate is necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the core. Please provide additional justification for minimizing/preventing thermal and boron stratification in the core.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Added By Ravinder Grover Date Added 3/19/2010 8:26 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2641 Licensee Response/NRC Response/NRC Question Closure Id2681NRC Question Number RPG-004 Select Application Licensee Response Response Date/Time 3/30/2010 6:45 AM Closure Statement Response Statement KPS does not include the RHR flowrate in the KPS ITS SRs similar to several similar vintage PWRs (Point Beach, Prairie Island, and R.E. Ginna) which all have ITS. KPS does not have a specific anal ysis for boron and thermal stratification.

The Kewaunee Power Station reviewed boron and thermal stratification industry standards that were consid ered in the development of NUREG-1431. As an industry, the fact that by license, RHR flow is maintained to the Reactor Coolant System while shut down precludes that possibility of stratification. The one hour exception in the ISTS LCO 3.9.5 Note (KPS ITS LCO 3.9.3 Note) allows for stable water conditi ons during movement of components such as reactor internals.

This is an accepted industry practice and an allowance already appr oved by the NRC.

The ISTS Bases description of the Note does not discuss thermal st ratification is sues. It only provides compensatory measures to preclude boron concentration reduction during th is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

Thermal and boron stratification do not occur with forced circulation as required by ITS. During MODE 6, temperatures are maintained well below boiling in the core with the water level above the core and temperature of the coolant at <140°F by procedure in the refueling cavity. Temperatures encountered in MODE 6 do not present a safety issue from thermal stratification since it is common industry practice to secure RHR for short periods of time. CTS re quires RHR pumps to be OPERABLE, but does not specify a flow requirement.

Boron stratification is not a concern due to the fact that boron is soluble well above refueling concentrations th at could possibly cause blockage of flow channels. WCAP 15 70 solubility curves in wa ter show that at 0 ºC boron is soluble to ~4800 ppm and at 20ºC boron is soluble to ~8000 ppm.

Also, when in MODE 6 wi th boron con centration within the limits of LCO 3.9.1, the possibility of a reactivity event is extremely remote.

Diffusion of boron follows the rules of di ffusion theory, thus ther e is low probability of varying concentrations of boron in the reactor coolant without flow.

Stratification is more of a post accident situation with a loss of coolant Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2681 accident at power.

Therefore KPs considers that industr y PWR design prec ludes thermal and boron stratification in MODE 6.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 3/30/2010 6:48 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2681 Licensee Response/NRC Response/NRC Question Closure Id2951NRC Question Number RPG-004 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 Date 5/13/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 5/13/2010 8:37 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2951 ITS NRC Questions Id2151NRC Question Number RPG-010 Category Technical ITS Section 3.9 ITS Number 3.9.4 DOC Number JFD Number JFD Bases Number Page Number(s) 89,127,164,166 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question Attachment 1, Volume 14, Rev.

0, Pages 89,16 4,166 of 175 proposed ISTS Section 3.9.4, "Containment Penetrations

" KPS Proposed changes:

(a) ISTS LCO 3.9.4, addresses specific requirements for the containment penetrations status du ring movement of

[recently] irradiated fuel assemblies within containment. On page 166, KPS states that no credit is taken for the containment penetrations in the fuel handling accident analysis at KPS and since the Applicability of ISTS 3.9.4 is during movement of recently irradiated fuel assemblies within containment, the subject LCO is not included in KPS ITS.

(b) On pa ge 127, KPS states, "CTS 3.8.a.3 requires the reactor to be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies.

The ITS does not include this requirement. This changes the CTS by moving the explicit decay time requirement from th e Technical Specifications to Pa ge 1of 2 Kewaunee ITS Conversion Database 06/22/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2151 the Technical Requirements Manua l (TRM). This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications." Whereas, marked-up changes on page 102 of KPS ITS Bases B 3.9.7 (KPS B 3.9.

5) show that KPS intends to keep the minimum decay time which is marked-up as 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , in the Bases.

Discussion:

As stated in the ITS Bases, "fuel handling accidents, analyzed in Reference 3, include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies.

The requirements of LCO 3.9.7, "Refueling Cavity Water Level," in conjunction with a minimum decay time of 100 hour0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months s prior to [irradiated fuel movement with containment closure capability or a minimum decay time of [x] days without containment closure capability], ensures that the release of fission pro duct radioactivity, s ubsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100."

Based on the above, please retain ITS LCO 3.9.4 for KPS ITS and specify of minimum decay time requirement in KPS ITS Bases to ensure the staff can conclude KPS TS ensure adequate protection of the public health and safety.

Attach File 1 Attach File 2 Issue Date 6/14/2010 Added By Ravinder Grover Date Modified Modified By Date Added 6/14/2010 12:51 PM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Pa ge 2of 2 Kewaunee ITS Conversion Database 06/22/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2151 Licensee Response/NRC Response/NRC Question Closure Id3601NRC Question Number RPG-010 Select Application Licensee Response Response Date/Time 6/21/2010 4:00 PM Closure Statement Response Statement KPS has re-reviewed the decision to request the relocation of the Containment Penetration Specificati on (CTS 3.8.a.1 a nd 8) and will withdraw the request. IS TS 3.9.4, as modified to meet the KPS design and analysis, will be included as ITS 3.

9.6. Due to this change, other Specifications are al so being modified. Specific ally, ITS 3.3.6, Containment Purge and Vent Isolation Instrumentat ion (new Applicability and ACTIONS for moving fuel), ITS 3.6.1, Containmen t (ITS cross-reference change only) , ITS 3.6.2, Containment Air Locks (ITS cross-reference change only), ITS 3.9.3, RHR and Coolant Circulation - High Water Level (change related to adding the Specification back in), and ITS 3.9.4, RHR and Coolant Circulation - Low Water Level (chang e related to addi ng the Specification back in). Furthermore, the relocation justification for CTS 3.8.a.1 and 8 in Section 3.9, as well as other CTS Mark up cross-references in Sections 3.7 and 3.9 have been included. A draf t markup regarding this change is attached. This change will be reflected in the suppl ement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 RPG-010 Markup.pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 6/21/2010 3:58 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/22/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=3601 NEW ITS 3.9.6 ATTACHMENT 6 ITS 3.9.6, CONTAINMENT PENETRATIONS Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during REFUELING OPERATIONS that would affect public health and safety.

SPECIFICATIONa. During REFUELING OPERATIONS: 1. Containment Closure a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation

valve or an operable automatic isolation valve. 2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously. 3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least two neutron monitors, each with continuous visual indication in the control room and

one with audible indication in the containment whenever core geometry is being

changed. When core geometry is not being changed at least one neutron flux

monitor shall be in service. 4. At least one residual heat removal pump shall be OPERABLE. 5. When there is fuel in the reactor, a minimum boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily. (1) Administrative controls ensure that:

Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITSA01 ITS 3.9.6 See ITS 3.9.2 See ITS 3.9.1 See ITS 3.3.6 and 3.3.8See ITS 3.9.3 LA01See CTS 3.8.a.3 L06 LCO 3.9.6.a and b LCO 3.9.6.c.1 and 2 Applicability Page 1 of 2 L03Add proposed LCO Note LA01 L01 L02, blind flange, or equivalent Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place.7. Deleted. 8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be operable immediately prior to and daily during REFUELING OPERATIONS. 9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool

sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed). b. Performance Requirements 1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal. 2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >

95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested. 10. The minimum water level above the vessel flange shall be maintained at 23 feet. 11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling. 12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS. b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.ACTION A A01 ITS 3.9.6 ITSSee CTS 3.8.a.6 See CTS 3.8.a.9 See ITS 3.9.5 See CTS 3.8.a.11See CTS 3.8.a.12 Page 2 of 2 SR 3.9.6.2 L05Add p ro posed SR 3.9.6.2 NoteM01Add proposed SR 3.9.6.1 L04 L05 LCO 3.9.6.c.2 on an actual or simulated actuation signal A02See ITS 5.5.9 DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 5 ADMINISTRATIVE CHANGESA01 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 When the containment penetrations are not in the required condition specified in CTS 3.8.a.1 or CTS 3.8.a.8, CTS 3.8.b requires refueling of the reactor to cease, initiation of action to restore the containment penetrations to the required conditions, and no operations be performed that could increase the reactivity of the core. Under similar conditions, ITS 3.9.6 ACTION A only requires movement of irradiated fuel assemblies within containment to be suspended. This changes the CTS by deleting the requirements to initiate action to restore the containment penetrations to the required conditions and that no operations be performed that

could increase the reactivity of the core. The purpose of CTS 3.8.a.8 is to ensure proper compensatory actions are taken to exit the Applicability of the LCO. CTS 3.8.a.1 and 3.8.a.8 are only applicable during REFUELING OPERATIONS, which is defined in CTS Section 1.0 as the movement of reactor vessel internals that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. Thus, after the first requirement of CTS 3.8.b is met (i.e., suspend refueling the reactor), the Applicability has been exited and thus, continuation of the requirements of CTS 3.8.b are not required. Therefore, this change is acceptable and is designated as administrative since the technical requirements have not been changed.

MORE RESTRICTIVE CHANGESM01 CTS 3.8.a does not provide a Surveillance Requirement to verify each required containment penetration is in the required status. The ITS adds a Surveillance Requirement (SR 3.9.6.1) to verify each required containment penetration is in the required status once every 7 days. This changes the CTS by adding a new Surveillance Requirement for the containment penetrations. This change is acceptable because the added Surveillance Requirement ensures that each required containment penetration is in the required status to support the containment penetration conditions assumed in the Fuel Handling Accident (FHA) analysis. In addition, this cha nge is acceptable because the Surveillance Requirement continues to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This

change is designated as more restrictive because a new Surveillance Requirement has been added.

DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 2 of 5 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01(Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.a.1.a requires at least one door in each personnel air lock to be capable of being closed "within 30 minutes."

CTS 3.8.a.1.a is modified by a footnote (1) that states "Administrative controls ensure that appropriate personnel are aware that both personnel air lock doors are open; a specified individual(s) is designated and available to close the air

lock following a required evacuation of containment; and, any obstruction(s) (e.g.,

cables and hoses) that could prevent closure of an open air lock can be quickly

removed." ITS 3.9.6 does not contain this footnote information or the 30 minute requirement. This changes the CTS by moving the information contained in the footnote and the 30 minute requirement to the Bases. The removal of these details, which are related to procedural details for meeting Technical Specification 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 protection of public health and safety. The ITS still retains the requirement for at least one door in each personnel air lock to be capable of being closed. 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. 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

procedural details for meeting Technical Specification requirements is being removed from the Technical Specifications. LESS RESTRICTIVE CHANGES L01(Category 1 - Relaxation of LCO Requirements) CTS 3.8.a.1.a, in part, requires at least one door in each personnel air lock to be closed when the reactor vessel head or upper internals are being lifted. ITS 3.9.6 does not include this requirement. This changes the CTS by not requiring one door in each personnel air lock to be closed when the reactor vessel head or upper internals are being lifted. The purpose of CTS 3.8.a.1 is to ensure that if a fuel handling accident occurs, the release of any subsequent fission products results in doses that are well within the guideline values specified in Regulatory Guide 1.183. A fuel handling accident, as analyzed in USAR Section 14.2.1, is postulated to occur during

handling of irradiated fuel assemblies; not handling the vessel head or upper internals. Thus, moving the vessel head or upper internals cannot result in a fuel handling accident. Any additional requirements, above those required to meet the assumptions of the fuel handling accident, are more appropriately controlled DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 3 of 5 by plant procedures. Therefore, this change is acceptable and is designated a less restrictive change since the requirement to maintain containment closure capability during movement of the vessel head or upper internals is being deleted from the CTS.

L02(Category 1 - Relaxation of LCO Requirements) CTS 3.8.a.1.b, in part, states that each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve. ITS LCO 3.9.6.c.1 states that each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by

a manual or automatic isolation valve, blind flange, or equivalent. This changes the CTS by specifying the use of a blind flange or an equivalent means of isolating a containment penetration. The purpose of CTS 3.8.a.1 is to ensure the containment penetrations are in the condition assumed in the Fuel Handling Accident (FHA) analysis. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The addition of the option to use a blind flange or some other equivalent means of isolating the containment penetration allows additional flexibility in the ITS that was not available in CTS. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L03(Category 1 - Relaxation of LCO Requirements) ITS LCO 3.9.6 Note states "Penetration flow path(s), except the equipment hatch, providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls." CTS 3.8.a does not include such an allowance. This changes the CTS by allowing containment penetration flow paths to be unisolated under administrative controls during movement of irradiated fuel

assemblies within containment. The purpose of CTS 3.8.a.1 is to ensure the containment penetrations are in the condition assumed in the Fuel Handling Accident (FHA) analysis. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The Reviewer's Note in the ISTS LCO Bases associated with the LCO Note states that the allowance to have the personnel air lock doors open and the penetration flow paths unisolated under administrative control requires confirmatory dose calculations approved by the NRC staff and commitments from the licensee to implement acceptable administrative procedures to ensure that in the event of a refueling accident that the open penetration(s) can and will be promptly closed. The confirmatory dose calculations were made by the NRC as part of Amendment 166, dated 3/17/2003 (ADAMS Accession No. ML030210062) as modified by Amendment 190, dated 3/8/2007 (ADAMS Accession No. ML070430020). These Amendments revised the radiological consequence analyses for the KPS FHA to implement the Alternate Source Term. Kewaunee Power Station commits to implementing

administrative procedures to ensure that in the event of a refueling accident, the open air locks and open penetration(s) can and will be promptly closed. This DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 4 of 5 change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

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

CTS 3.8.a.8 requires verification of the automatic actuation of the Containment Ventilation and Purge valves on a containment ventilation isolation signal. ITS SR 3.9.6.2 specifies that the signal may be from either an actual or simulated signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal to perform the Surveillance. The purpose of CTS 3.8.a.8 is to ensure that the containment purge and vent valves operate 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," "simulated," or "test" 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.

The change also allows a simulated signal to be used, if necessary. 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 7 - Relaxation Of Surveillance Frequency)

CTS 3.8.a.8 includes a Surveillance Frequency of "immediately prior to and daily during REFUELING OPERATIONS" for performing a Surveillance of the Containment Ventilation and Purge System. The ITS SR 3.9.6.2 Frequency for the same requirement is 18 months. ITS SR 3.9.6.2 is also modified by a Note that states that SR 3.9.6.2 is not required to be met for containment purge and vent valve(s) in penetrations

that are closed to comply with LCO 3.9.6.c.1. This changes the CTS by changing the Surveillance Frequency from immediately prior to and daily during REFUELING OPERATIONS to 18 months and adding the Note that the SR is not required to be met for containment purge and vent valve(s) in penetrations that are closed to comply with ITS LCO 3.9.6.c.1. The purpose of CTS 3.8.a.8 is to verify the equipment required to meet the LCO is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Containment purge and vent valve testing is still required, but at a Frequency consistent with the testing Frequency for containment isolation valves required in MODES 1, 2, 3, and 4. This Frequency provides an appropriate degree of assurance that the valves are OPERABLE. When

containment purge and vent valve(s) in penetrations are closed to comply with ITS LCO 3.9.6.c.1, the penetrations are in the expected condition (isolated) to mitigate the effects of a fuel handling accident inside containment. Therefore, there is no need for the actuation signal to reposition the valves to the closed position. This change is designated as less restrictive because Surveillances will

be performed less frequently under the ITS than under the CTS.

L06(Category 1 - Relaxation of LCO Requirements) CTS 3.8.a specifies that the CTS 3.8.a.1 containment closure requirements are applicable during DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 5 of 5 REFUELING OPERATIONS, which is defined in CTS Section 1.0 as the movement of reactor vessel internals that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. ITS 3.9.6 is applicable during movement of irradiated fuel assemblies within containment.

This changes the CTS by not requiring the containment closure requirements to be met when moving or handling control rods during MODE 6 operation. The purpose of CTS 3.8.a.1 is to ensure that if a fuel handling accident occurs, the release of any subsequent fission products results in doses that are well within the guideline values specified in Regulatory Guide 1.183. A fuel handling accident, as analyzed in USAR Section 14.2.1, can only occur during handling of irradiated fuel assemblies; not moving or handling control rods (which are the only other reactor vessel internals currently in use at KPS that could affect reactivity of the core). Thus, moving or handling the control rods cannot result in a fuel handling accident. Any additional requirements, above those required to meet the assumptions of the fuel handling accident, are more appropriately controlled by plant procedures. Therefore, this change is acceptable and is designated a less restrictive change since the requirement to maintain containment closure capability during movement or handling of control rods in

MODE 6 is being deleted from the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Containment Penetrations 3.9.4 WOG STS 3.9.4-1Rev. 3.0, 03/31/04 6 3.9 REFUELING OPERATIONS 3.9.4 Containment Penetrations LCO 3.9.4 The containment penetrations shall be in the following status:

a. The equipment is hatch closed and held in place by [four] bolts, b. One door in each air lock is [capable of being] closed, and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere is either:

1. Closed by a manual or automatic isolation valve, blind flange, or equivalent or

2. Capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. --------------------------------

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

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls. ------------------------------------------------

APPLICABILITY: During movement of [recently] irradiated fuel assemblies within containment.

ACTIONS CONDITIONREQUIRED ACTION COMPLETION TIME A. One or more containment penetrations not in required status. A.1 Suspend movement of

[recently] irradiated fuel assemblies within containment.

ImmediatelyCTS 3.8.a.1.a 3.8.a.1.b 3.8.a 3.8.b DOC L03 2 1 5 5;3 3;Vent 4 3.8.1.a.b, 3.8.a.8 1 6 6 6 6 6, except the equipment hatch, 7 Containment Penetrations 3.9.4 WOG STS 3.9.4-2Rev. 3.0, 03/31/04 6SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCYSR 3.9.4.1 Verify each required containment penetration is in the required status.

7 days SR 3.9.4.2 -------------------------------

NOTE------------------------------ Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.4.c.1. --------------------------------------------------------------------- Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

[18] months CTS DOC M01 1 3.8.a.8 vent 4vent 4 6 6 6 6 6 6 6 JUSTIFICATION FOR DEVIATIONS ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 1 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. A typographical error within the ISTS has been corrected. The word "is" has been placed after the word "hatch". 3. The punctuation corrections have been made consistent with Section 5.1.3 of the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01. 4. 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. 5. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. In ITS 3.9.6 Applicability and Required Action A.1, the brackets and the term "recently" have been deleted since the term "recently" does not apply to KPS when referring to irradiated fuel assemblies. 6. ISTS 3.9.4 has been renumbered to ITS 3.9.6 since it was added back into the ITS as the result of an NRC RAI and KPS chose not to renumber multiple Specifications due to this later addition. 7. The ISTS 3.9.4 LCO Note has been modified to not allow the Note to apply to the equipment hatch. As stated in the ISTS Bases, the LCO Note is allowed provided confirmatory dose calculations have been performed and approved by the NRC.

Confirmatory dose calculations of the type required by the Note have not been performed and approved by the NRC for the equipment hatch.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Containment Penetrations B 3.9.4 WOG STS B 3.9.4-1 Rev. 3.0, 03/31/04 6B 3.9 REFUELING OPERATIONS B 3.9.4 Containment Penetrations BASES BACKGROUND During movement of [recently] irradiated fuel assemblies within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY." Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required. The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100. Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions. The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. During movement of [recently]

irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced. The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 unit operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of unit shutdown when containment closure is not required, the door interlock mechanism

may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

During movement of [recently] irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain [capable of being] closed.

2All changes are unless otherwise noted 1 6 5 5Regulatory Guide 1.183 (Ref. 1) guidance Containment Penetrations B 3.9.4 WOG STS B 3.9.4-2 Rev. 3.0, 03/31/04 6 BASES BACKGROUND (continued) The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted to within regulatory limits.

The Containment Purge and Exhaust System includes two subsystems. The normal subsystem includes a 42 inch purge penetration and a 42 inch exhaust penetration. The second subsystem, a minipurge system, includes an 8 inch purge penetration and an 8 inch exhaust penetration. During MODES 1, 2, 3, and 4, the two valves in each of the normal purge and exhaust penetrations are secured in the closed position. The two valves in each of the two minipurge penetrations can be opened intermittently, but are closed automatically by the Engineered Safety Features Actuation System (ESFAS). Neither of the subsystems is subject to a Specification in MODE 5. In MODE 6, large air exchangers are necessary to conduct refueling operations. The normal 42 inch purge system is used for this purpose, and all four valves are closed by the ESFAS in accordance with LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation."[ The minipurge system remains operational in MODE 6, and all four valves are also closed by the ESFAS.

[or]

The minipurge system is not used in MODE 6. All four 8 inch valves are secured in the closed position. ]

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by an OPERABLE automatic

isolation valve, or by a manual isolation valve, blind flange, or equivalent. Equivalent isolation methods must be approved and may include use of a material that can provide a temporary, atmospheric pressure, ventilation barrier for the other containment penetrations during [recently] irradiated fuel movements (Ref. 1).

36 2 2 36 Ventvent 2 2 2vent The Post LOCA H y dro gen Controlvent fresh, tempered air is provided All changes are unless otherwise noted 1 5Two systems can be used to purge or ventilate the containment; the Containment Purge and Vent System and the Post LOCA Hydrogen Control System. or capable of being isolated 6 areINSERT 1 B 3.9.6 Insert Page B 3.9.4-2 INSERT 1The Post LOCA Hydrogen Control subsystem contains two trains. The valves in Train A are normally closed. The valves in Train B are also normally closed but are periodically opened to control containment pressure within the required limits.

The Train B valves receive a signal to close via the Engineered Safety Features Actuation System and the Containment Purge and Vent Isolation System.

2 Containment Penetrations B 3.9.4 WOG STS B 3.9.4-3 Rev. 3.0, 03/31/04 6 BASES APPLICABLE During CORE ALTERATIONS or movement of irradiated fuel assemblies SAFETY within containment, the most severe radiological consequences result ANALYSES from a fuel handling accident [involving handling recently irradiated fuel].

The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 2). Fuel handling accidents, analyzed in Reference 3, include dropping a single irradiated fuel assembly and handling tool or a

heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.7, "Refueling Cavity Water Level," in conjunction with a minimum decay time of 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to [irradiated fuel movement with containment closure capability or a minimum decay time of [x] days without containment closure capability], ensures that the release of fission product radioactivity, subsequent to a fuel handling accident, results in

doses that are well within the guideline values specified in 10 CFR 100.

Standard Review Plan, Section 15.7.4, Rev. 1 (Ref. 3), defines "well within" 10 CFR 100 to be 25% or less of the 10 CFR 100 values. The acceptance limits for offsite radiation exposure will be 25% of 10 CFR 100

values or the NRC staff approved licensing basis (e.g., a specified

fraction of 10 CFR 100 limits). Containment penetrations satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO -----------------------------------REVIEWER'S NOTE----------------------------------- The allowance to have containment personnel air lock doors open and penetration flow paths with direct access from the containment atmosphere to the outside atmosphere to be unisolated during fuel movement and CORE ALTERATIONS is based on (1) confirmatory dose calculations of a fuel handling accident as approved by the NRC staff which indicate acceptable radiological consequences and (2) commitments from the licensee to implement acceptable administrative procedures that ensure in the event of a refueling accident (even though the containment fission product control function is not required to meet acceptable dose consequences) that the open air lock can and will be promptly closed follo wing containment evacuation and that the open penetration(s) can and will be promptly closed. The time to close such penetrations or combination of penetrations shall be included in the confirmatory dose calculations.

This LCO limits the consequences of a fuel handling accident [involving

handling recently irradiated fuel] in containment by limiting the potential escape paths for fission product radioactivity released within containment. The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except

for the OPERABLE containment purge and exhaust penetrations [and the

containment personnel air locks]. For the OPERABLE TSTF-471-A TSTF-471-Avertically onto a rigid surface or Regulatory Guide 1.183 (Ref. 1) 2 3 2 2 2 2vent 2All changes are unless otherwise noted 1 7 5 5 Containment Penetrations B 3.9.4 WOG STS B 3.9.4-4 Rev. 3.0, 03/31/04 6 BASES LCO (continued) containment purge and exhaust penetrations, this LCO ensures that these penetrations are isolable by the Containment Purge and Exhaust Isolation System. The OPERABILITY requirements for this LCO ensure that the automatic purge and exhaust valve closure times specified in the

FSAR can be achieved and, therefore, meet the assumptions used in the safety analysis to ensure that releases through the valves are terminated, such that radiological doses are within the acceptance limit.

The LCO is modified by a Note allowing penetration flow paths with direct access from the containment atmosphere to the outside atmosphere to be unisolated under administrative controls. Administrative controls ensure that 1) appropriate personnel are aware of the open status of the penetration flow path during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, and 2) specified individuals are designated and readily available to isolate the flow path in the event

of a fuel handling accident. The containment personnel air lock doors many be open during movement of [recently] irradiated fuel in the containment provided that one door is capable of being closed in the event of a fuel handling accident. Should a fuel handling accident occur inside containment, one personnel air lock door will be closed following an evacuation of containment.APPLICABILITY The containment penetration requirements are applicable during movement of [recently] irradiated fuel assemblies within containment because this is when there is a potential for the limiting fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist.

[Additionally, due to radioactive decay, 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) will result in doses that are well within the guideline values specified in 10 CFR 100 even without

containment closure capability.] Therefore, under these conditions no requirements are placed on containment penetration status.

Vent 2vent may TSTF-471-AINSERT 3 4 2 1 1 1within 30 minutes 5, except the equipmenthatch, 8 INSERT 2 2 2 B 3.9.6 Insert Page B 3.9.4-4 INSERT 2 This Note does not apply to the equipment hatch because there are no confirmatory dose calculations that have been approved by the NRC staff for the fuel handling accident that shows acceptable radiological consequences if the equipment hatch is

open.INSERT 3When both personnel airlock doors are open during the movement of irradiated fuel in the containment, appropriate plant personnel shall be notified of this condition. A specified individual(s) is designated and available to close the airlock following a required evacuation of containment. Any obstruction(s) (e.g.,

cables and hoses) that can prevent closure of an open airlock shall be able to be removed in a timely manner (i.e., within the 30 minutes specified above).

2 2 Containment Penetrations B 3.9.4 WOG STS B 3.9.4-5 Rev. 3.0, 03/31/04 6 BASES APPLICABILITY (continued) -----------------------------------REVIEWER'S NOTE----------------------------------- The addition of the term "recently" associated with handling irradiated fuel in all of the containment function Technical Specification requirements is only applicable to those licensees who have demonstrated by analysis that after sufficient radioactive decay has occurred, off-site doses

resulting from a fuel handling accident remain below the Standard Review Plan limits (well within 10 CFR 100). Additionally, licensees adding the term "recently" must make the following commitment which is consistent with NUMARC 93-01, Revision 4, Section 11.3.6.5 "Safety Assessment for Removal of Equipment from Service During Shutdown Conditions," subheading "Containment - Primary (PWR)/Secondary (BWR)." "The following guidelines are included in the assessment of systems removed from service during movement irradiated fuel: - During fuel handling/core alterations, ventilation system and

radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the fuel decays away fairly rapidly. The basis of the Technical Specification OPERABILITY amendment is the reduction in doses due to such decay. The goal of maintaining ventilation system and radiation monitor availability is to

reduce doses even further below that provided by the natural decay. - A single normal or contingency method to promptly close primary or secondary containment penetrations should be developed. Such prompt methods need not completely block the penetration or be capable of resisting pressure. The purpose of the "prompt methods" mentioned above are to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored."

3 5 Containment Penetrations B 3.9.4 WOG STS B 3.9.4-6 Rev. 3.0, 03/31/04 6 BASES ACTIONS A.1If the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, including the Containment Purge and Exhaust Isolation System not capable of

automatic actuation when the purge and exhaust valves are open, the unit must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending movement of [recently] irradiated fuel assemblies within containment. Performance of

these actions shall not preclude completion of movement of a component to a safe position. SURVEILLANCE SR 3.9.4.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are not blocked from closing. Also the Surveillance will demonstrate that each valve operator has motive power, which will ensure that each valve is capable of being closed by an OPERABLE automatic containment purge and exhaust isolation signal. The Surveillance is performed every 7 days during movement of [recently] irradiated fuel assemblies within containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. A surveillance before the start of refueling operations will provide two or three surveillance verifications during the applicable period for this LCO. As such, this Surveillance ensures that a postulated fuel handling accident [involving handling recently irradiated fuel] that releases fission product radioactivity within the containment will not result in a release of significant fission product radioactivity to the environment in excess of those recommended by

Standard Review Plan Section 15.7.4 (Reference 3).

SR 3.9.4.2This Surveillance demonstrates that each containment purge and exhaust valve actuates to its isolation position on manual initiation or on an actual

or simulated high radiation signal. The 18 month Frequency maintains consistency with other similar ESFAS instrumentation and valve testing requirements. In LCO 3.3.6, the Containment Purge and Exhaust Vent 2ventis in the requiredstatusvent 1Regulatory Guide 1.183 ventrequired 2 2 2 1 1 1INSERT 4 6 5 5 5 6 B 3.9.6 Insert Page B 3.9.4-6 INSERT 4LCO 3.3.6, "Containment Purge and Vent Isolation Instrumentation," provides additional Surveillance Requirements for the containment purge and vent valve actuation circuitry.

2 Containment Penetrations B 3.9.4 WOG STS B 3.9.4-7 Rev. 3.0, 03/31/04 6 BASES SURVEILLANCE REQUIREMENTS (continued) Isolation instrumentation requires a CHANNEL CHECK every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and a COT every 92 days to ensure the channel OPERABILITY during refueling operations. Every 18 months a CHANNEL CALIBRATION is performed. The system actuation response time is demonstrated every 18 months, during refueling, on a STAGGERED TEST BASIS.

SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements. These Surveillances performed during MODE 6 will ensure that the valves are capable of closing after a postulated fuel handling accident [involving handling recently irradiated fuel] to limit a release of fission product

radioactivity from the containment. The SR is modified by a Note stating that this Surveillance is not required to be met for valves in isolated penetrations. The LCO provides the option to close penetrations in lieu of requiring automatic actuation

capability. REFERENCES 1. GPU Nuclear Safety Evaluation SE-0002000-001, Rev. 0, May 20, 1988. 2. FSAR, Section [15.4.5]. 3. NUREG-0800, Section 15.7.4, Rev. 1, July 1981.

U 214.2.1 2 Re g ulator y Guide 1.183, Jul y 2000 1 2 1 2 5 JUSTIFICATION FOR DEVIATIONS ITS 3.9.6 BASES, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 1 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 (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 Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal. 4. Typographical error corrected. 5. ISTS 3.9.4 has been renumbered to ITS 3.9.6 since it was added back into the ITS as the result of an NRC RAI and KPS chose not to renumber multiple Specifications due to this later addition. 6. Changes made to be consistent with the actual Specification. 7. The correct ITS number has been provided. 8. Changes have been made to be consistent with changes to the Specification.

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 1 There are no specific NSHC discussions for this Specification.

Split Report changes

SUMMARY

DISPOSITION MATRIX FOR KEWAUNEE POWER STATION (a) The Applicable Safety Analyses section of the Bases for the individual Technical Specifications describes the reason specific Technical Specification selection criteria are met.

Page 9 of 25 CURRENT TS (CTS) NUMBER CURRENT TITLE NEW TS (ITS) NUMBER RETAINED/ CRITERION FOR INCLUSION NOTES(a) 3.7.b.5 Condition for Inoperability 3.8.1 YES-3 3.7.b.6 Condition for Inoperability 3.8.9 YES-3 3.7.b.7 Condition for Inoperability 3.8.1 YES-3 3.7.c Condition for Inoperability 3.8.1 YES-3

3.8 Refueling

Operations 3.8.a.1 Containment Closure Relocated NO See Appendix A, Page 6.

3.8.a.2 Radiation Levels Monitoring Relocated NO See Appendix A, Page 7.

3.8.a.3 Neutron Monitoring 3.9.2, Relocated YES-3 See technical change discussion in the Discussion of Changes for CTS 3.8.a.3.

3.8.a.4 Residual Heat Removal Pump Operability 3.9.4 YES-4 3.8.a.5 Boron Concentration 3.9.1 YES-2 3.8.a.6 Direct Communications Relocated NO See Appendix A, Page 8. 3.8.a.7 Deleted 3.8.a.8 Containment Ventilation and Purge System Relocated NO See Appendix A, Page 6.

3.8.a.9 Spent Fuel Pool Sweep System Relocated NO See Appendix A, Page 9. 3.8.a.10 Minimum Water Level Above the Flange 3.9.6 YES-2 3.8.a.11 Dead Load Test Relocated NO See Appendix A, Page 10.

YES-3 3.9.6, 3.3.6 3.9.6 YES-3 Appendix A - Justification For Specification Relocation 3.8.a.1: Containment Closure 3.8.a.8: Containment Closure

DISCUSSION:

CTS 3.8.a.1 and 3.8.a.8 provide requirements for Containment Closure during refueling operations.

The purpose of the Containment Closure during Refueling requirements is to restrict the release of fission product radioactivity within containment from escaping to the environment following a fuel handling accident within the containment.

COMPARISON TO SCREENING CRITERIA

1. Containment closure is not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

2. Containment closure is not a process variable, design feature, or operating restriction that is in an initial condition of a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

3. Containment closure is not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. Containment closure was found to be non-significant risk contributor to core damage frequency and offsite releases.

CONCLUSION:

Since the screening criteria have not been satisfied, the Containment Closure Specifications may be relocated to other plant controlled documents outside Technical Specifications.

Page 6 of 15 Pa g e Blank ITS 3.3.6 changes Amendment No. 105 TS 3.5-1 02/09/94 3.5 INSTRUMENTATION SYSTEM APPLICABILITY Applies to reactor protection and engineered safety features instrumentation systems.

OBJECTIVE To provide for automatic initiation of the engineered safety features in the event that principal process variable limits ar e exceeded, and to delineate the conditions of the reactor protection instrumentation and engineered safety features circuits necessary to

ensure reactor safety.

SPECIFICATIONS

a. Setting limits for instrumentation which initiate operation of the engineered safety features shall be as stated in Table TS 3.5-1.

b. For on-line testing or in the event of failure of a subsystem instrumentation channel, plant operation shall be permitted to continue at RATED POWER in accordance with

Tables TS 3.5-2 through TS 3.5-5.

c. If for Tables TS 3.5-2 through TS 3.5-5, the number of channels of a particular subsystem in service falls below the limits given in Column 3, or if the values in Column 4 cannot be achieved, operation shall be limited according to the requirement shown in Column 6, as soon as practicable.

d. In the event of subsystem instrumentation channel failure permitted by TS 3.5.b, Tables TS 3.5-2 through TS 3.5-5 need not be observed during the short period of time (approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) the operable subsystem channels are tested, where the failed

channel must be blocked to prevent unnecessary reactor trip.

e. The accident monitoring instrumentation in Table TS 3.5-6 shall be OPERABLE whenever the plant is above HOT SHUTDO WN. In the event the limits given in Columns 1 and 2 cannot be maintained, operator action will be in accordance with the respective notes. A change in operational MODES or conditions is acceptable with an inoperable accident monitoring instrumentation channel(s).

ITS A01 ITS 3.3.6 Page 1 of 6 See ITS 3.3.3 LCO 3.3.6, DOC A02 ACTION B, DOC A02 LA02 M04 M04 8 Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during REFUELING OPERATIONS that would affect public health and safety.

SPECIFICATIONa. During REFUELING OPERATIONS: 1. Containment Closure a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation

valve or an operable automatic isolation valve. 2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously. 3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least two neutron monitors, each with continuous visual indication in the control room and

one with audible indication in the containment whenever core geometry is being

changed. When core geometry is not being changed at least one neutron flux

monitor shall be in service. 4. At least one residual heat removal pump shall be OPERABLE. 5. When there is fuel in the reactor, a minimum boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily. (1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITSA01 ITS 3.3.6 A pplicabilit yof Table 3.3.6-1 footnote (a)

L02See ITS 3.9.6 See CTS 3.8.a.3 See ITS 3.9.2 See ITS 3.9.1 See ITS 3.9.6 See ITS 3.9.3 Page 2 of 8See CTS 3.8.a.2 New Page Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place.7. Deleted. 8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be operable immediately prior to and daily during REFUELING OPERATIONS. 9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool

sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed). b. Performance Requirements 1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal. 2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >

95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested. 10. The minimum water level above the vessel flange shall be maintained at 23 feet. 11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling. 12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS. b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.ITSA01 ITS 3.3.6 Page 3 of 8See ITS 5.5.9 See CTS 3.8.a.6 See ITS 3.9.6 See CTS 3.8.a.11See CTS 3.8.a.12ACTIONS A and C See ITS 3.9.5 See CTS 3.8.a.9 L02 L03Add proposed ACTION A (for one channel inoperable) and ACTION C (for two or more channels inoperable during movement of irradiated fuel

)New Page TABLE TS 3.5-1 ENGINEERED SAFETY FEATURES INITIA TION INSTRUMENT SETTING LIMITS Amendment No. 131 Page 2 of 2 01/06/97 NO. FUNCTIONAL UNIT CHANNEL SETTING LIMIT 8 Containment Purge and Vent System Radiation Particulate Detector Radioactive Gas Detector Containment ventilation isolation value of radiation levels in exhaust duct as defined in footnote (3)9 Safeguards Bus Undervoltage (4)Loss of power 85.0% +/- 2% nominal bus voltage

2.5 seconds

time delay 10 Safeguards Bus Second Level Undervoltage (5)Degraded grid voltage 93.6% +/- 0.9% of nominal bus voltage 7.4 seconds time delay

(3) The setting limits for max radiation levels are derived from ODCM Specification 3.4.1 and Table 2.2, and USAR Section 6.5.

(4) This undervoltage protection channel ensures ESF equipment will perform as assumed in the USAR.

(5) This undervoltage protection channel protects ESF equipment from long-term low voltage operation. ITS ITS 3.3.6 A01 Page 2 of 6 See ITS 3.3.5 Table 3.3.6-1, Functions 2.a, 2.b, and 2.c See ITS 3.3.5 LA02 LA02 4 of 8 KAB-072 change and 2.b NOTE: KAB-072 changes shown in green TABLE TS 3.5-4 INSTRUMENT OPERATING CONDITIONS FOR ISOLATION FUNCTIONS Amendment No. 202 Page 1 of 2 1/12/2009 1 2 3 4 5 6

NO.

FUNCTIONAL UNIT NO. OF CHANNELS NO. OF CHANNELS TO TRIP MINIMUM OPERABLE CHANNELS MINIMUM DEGREE OF REDUNDANCY PERMISSIBLE BYPASS CONDITIONS OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET 1 Containment Isolation a. Safety Injection Refer to Item No. 1 of Table TS 3.5-3 HOT SHUTDOWN (1 ) b. Manual 2 1 1 - HOT SHUTDOWN 2 Steam Line Isolation

a. Hi-Hi Steam Flow with Safety Injection 2/loop 1 1 (3) - HOT SHUTDOWN (1) b. Hi Steam Flow and 2 of 4 Lo-Lo Tavg with Safety Injection 2/loop 1 1 (3) - HOT SHUTDOWN (1) c. Hi-Hi Containment Pressure 3 2 2 (3) - HOT SHUTDOWN (1) d. Manual 1/loop 1/loop 1/loop (3) - HOT SHUTDOWN

(1) If minimum conditions are not met within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , steps shall be taken to place the plant in a COLD SHUTDOWN condition.

(3) Steam Line Isolation channels are not required to be operable when both main steam isolation valves are closed and deactivated.

ITS ITS 3.3.6 A01 See ITS 3.3.2 Table 3.3.6-1 Function 3 Add proposed Function 1, including ACTIONS B and C M02 LA03 See ITS 3.3.2 Pa g e 3 of 6 ACTION B LA03 A05 M01 2 L01 REQUIRED 5 of 8 M05 KAB-031 change NOTE: KAB-031 changes shown in green TABLE TS 3.5-4 INSTRUMENT OPERATING CONDITIONS FOR ISOLATION FUNCTIONS Amendment No. 102 Page 2 of 2 10/18/93 1 2 3 4 5 6

NO.

FUNCTIONAL UNIT NO. OF CHANNELS NO. OF CHANNELS TO TRIP MINIMUM OPERABLE CHANNELS MINIMUM DEGREE OF REDUNDANCY PERMISSIBLE BYPASS CONDITIONS OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET 3 Containment Ventilation

Isolation a. High Containment Radiation 2 1 1 - - These channels are not required to

activate containment

ventilation isolation

when the containment purge

and ventilation

system isolation

valves are maintained

closed.(2 ) b. Safety Injection Refer to Item 1 of Table TS 3.5-3

c. Containment Spray Refer to Item 3 of Table TS 3.5-3 4 Main Feedwater Isolation

a. Hi-Hi Steam Generator Level 3 2 2 1 HOT SHUTDOWN

(2) The detectors are required for Reactor Coolant System leak detection as referenced in TS 3.1.d.5.

A01 LA03 Table 3.3.6-1 Function 4 See ITS 3.3.2 LA03 Table 3.3.6-1 Function 2.a, 2.b, and 2.c Table 3.3.6-1 Function 5 ITS ITS 3.3.6 Pa g e 4 of 6 ACTION B A05 REQUIRED A06 6 of 8 NOTE: KAB-072 changes shown in green and 2.b Amendment No. 119 TS 4.1-1 04/18/95 4.1 OPERATIONAL SAFETY REVIEW APPLICABILITY Applies to items directly related to safety limits and LIMITIN G CONDITIONS FOR OPERATION.

OBJECTIVE

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

SPECIFICATION

a. Calibration, testing, and checking of protec tive instrumentation channels and testing of logic channels shall be performed as specified in Table TS 4.1-1.

b. Equipment and sampling tests shall be conducted as specified in Table TS 4.1-2 and TS 4.1-3.

c. Deleted

d. Deleted

e. Deleted A01 ITS 3.3.6 ITS Page 5 of 6 SR 3.3.6.1, SR 3.3.6.3, SR 3.3.6.4 See other ITS 7 of 8 TABLE TS 4.1-1 MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS Amendment No. 182 Page 4 of 7 4/06/2005 CHANNEL DESCRIPTION CHECK CALIBRATE TEST REMARKS 18. a. Containment Pressure (SIS signal) Each shift Each refueling cycle Monthly(a) (a) Isolation Valve Signal

b. Containment Pressure (Steamline

Isolation) Each shift(a) Each refueling cycle(a) Monthly(a) (a) Narrow range containment pressure

(-3.0, +3.0 psig excluded)

c. Containment Pressure (Containment

Spray Act) Each shift Each refueling cycle Monthly

d. Annulus Pressure (Vacuum Breaker) Not applicable Each refueling cycle Each refueling cycle 19. Radiation Monitoring System Daily (a,b) Each refueling cycle (a) Quarterly (a) (a) Includes only channels R11 thru R15, R19, R21, and R23 (b) Channel check required in all plant modes

20. Deleted

21. Containment Sump Level Not applicable Not applicable Each refueling cycle 22. Accumulator Level and Pressure Each shift Deleted Not applicable 23. Steam Generator Pressure Each shift Each refueling cycle Monthly ITS ITS 3.3.6 A01 Page 6 of 6 Table 3.3.6-1, Functions 2.a, 2.b, and 2.c See ITS 3.3.2 See ITS 3.6.9 See ITS 3.3.2 LA01 A03 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months M03 See ITS 3.5.1 A03 See ITS 3.4.15 SR 3.3.6.4 SR 3.3.6.1 SR 3.3.6.3 M02 Add proposed SR 3.3.6.2 A04 COT Discussion of Change LA01 is for channel R11, R12, and 21. For other channels, see ITS 3.3.2, 3.3.7, 3.4.15, and CTS 3.8.a.9.

8 of 8 NOTE: KAB-072 changes shown in green and 2.b DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION Kewaunee Power Station Page 6 of 6 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 to provide adequate protection of public health and safety. The ITS still retains the requirement for the Containment Purge and Vent Isolation Instrumentation be OPERABLE and specifies the number of required channels. 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 Contr ol Program in ITS 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 relating system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action)

When both Containment Isolation Manual channels are inoperable, CTS Table TS 3.5-4 Column 6 requires the unit to be placed in HOT SHUTDOWN (ITS MODE 3). Under similar conditions, ITS 3.3.6 Required Action B.1 requires immediately entering the applicable

Conditions and Required Actions for the containment purge and vent isolation valves made inoperable by isolation instrumentation. This changes the CTS by allowing the actions for inoperable containment purge and vent valves to be taken when both Manual initiation channels are inoperable in lieu of shutting down the unit.

The purpose of the CTS Table TS 3.5-4 Column 6 action is to provide compensatory actions when both Manual Initiation channels are inoperable.

However, the CTS action is overly conserv ative in that it requires more restrictive actions than are allowed if the valves themselves were inoperable. The purpose

of the instrumentation is to isolate the associated valves. Thus, this change is acceptable since the proposed ITS Required Ac tion would accomplish this action (since ITS 3.6.3 would require isolat ion of the associated penetration flow path). This change is designated as less restri ctive since the proposed Required Action will allow operation to continue with the associated flow path isolated in lieu of

shutting down the unit.

INSERT L02 and L03 Not used.NOTE: KAB-031 changes shown in green L02 (Category 2 - Relaxation of Applicability) CTS 3.8.a.1.b requires an OPERABLE automatic isolation valve under certain conditions. This is referring to the Containment Purge and Vent System valves, and thus includes the instruments that provide the isolation signal. The Specification is applicable during REFUELING OPERATIONS. This requirement can be met by an OPERABLE automatic isolation valve or a closed isolation valve. When this requirement is not being met, CTS 3.8.b provides actions to be taken if any of the specified limiting conditions in CTS 3.8 a are not met during REFUELING OPERATIONS. ITS 3.3.6 is applicable, in part, during movement of irradiated fuel assemblies within containment, as stated in footnote (a) to Table 3.3.6-1. This changes the CTS by requiring the containment purge and vent isolation instrumentation be OPERABLE during times of movement of irradiated fuel assemblies within containment, in lieu of during REFUELING OPERATIONS. The purpose of CTS 3.8.a.1.b is to ensure each line that penetrates containment and provides a direct air path from containment atmosphere to the outside atmosphere have a closed isolation valve or an OPERABLE automatic isolation valve. Continuous monitoring of the radiation levels of the containment atmosphere (general or exhaust vent) is required to provide automatic action during an unsafe condition as a result of a fuel handling accident. CTS 3.8.a.1.b requires an OPERABLE automatic isolation valve during REFUELING OPERATIONS, and includes the isolation instrumentation. As defined in CTS Section 1.0, REFUELING OPERATIONS is movement of reactor vessel internal components that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. This would include both moving irradiated fuel assemblies and control rods. Since movement of irradiated fuel assemblies within containment can only occur when the vessel head is unbolted or removed, ITS 3.3.6 is applicable, with respect to moving fuel assemblies, under the same conditions as CTS 3.8.a.1.b. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The fuel handling accident is based on damaging a single irradiated fuel assembly. Movement of control rods is not assumed to result in a fuel handling accident. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS. L03 (Category 4 - Relaxation of Required Action) CTS 3.8.a.1.b requires an OPERABLE automatic isolation valve under certain conditions. This is referring to the Containment

Purge and Vent System valves, and thus includes the instruments that provide the isolation signal. The Specification is applicable during REFUELING OPERATIONS. When this requirement is not being met, the isolation valve must be closed or CTS 3.8.b requires refueling of the reactor to cease, initiation of action to restore the monitoring capability, and no operations be performed that could increase the reactivity of the core.

Under similar conditions, ITS 3.3.6 does not require the refueling of the reactor to cease or require all operations that could increase the reactivity of the core to cease. With one radiation monitoring channel inoperable, ITS 3.3.6 ACTION A requires restoration of the affected channel to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.3.6 ACTION C, which is only applicable during the movement of irradiated fuel assemblies within containment, requires immediately placing and maintaining containment purge and vent valves in the closed position (Required Action C.1) or immediately entering the applicable Conditions and Required Actions of LCO 3.9.6 for containment purge and vent valves made inoperable by isolation instrumentation (Required Action C.2). Note that under this condition ITS LCO 3.9.6 would require suspension of movement of irradiated fuel assemblies in containment. This changes the CTS by deleting the requirements to cease refueling of the reactor and that no operations be performed that could increase the reactivity of the core and provides new ACTIONS to restore the radiation monitors to service and maintain the containment boundary. The purpose of CTS 3.8.a.1.b is to ensure the Containment Purge and Vent System is OPERABLE to provide automatic actuation of the valves if an unsafe condition as a result of a fuel handling accident occurs or the valves are closed. CTS 3.8.b requires

compensatory actions be taken to exit the Applicability of the LCO if continuous monitoring is not available and the isolation valves cannot be closed; however, the CTS Actions are overly restrictive. The proposed compensatory actions of ITS 3.3.6 ACTIONS A and C ensure that acceptable actions are taken when radiation channels are inoperable. The proposed ACTION A is acceptable since channels are still available to ensure the containment purge and vent valve receive an isolation signal. The proposed ACTION C is acceptable since when multiple channels are inoperable, the proposed action places the containment purge and vent valves in the isolated position, which performs the function of the radiation channels. This change is designated as less restrictive since less restrictive actions have been added for when the radiation channels are inoperable.

Containment Purge and Exhaust Isolation Instrumentation 3.3.6 WOG STS 3.3.6-1 Rev. 3.0, 03/31/04 Vent 3.3 INSTRUMENTATION

3.3.6 Containment

Purge and Exhaust Isolation Instrumentation

LCO 3.3.6 The Containment Purge and Exhaust Isolation instrumentation for each Function in Table 3.3.6-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.6-1.

ACTIONS

NOTE----------------------------------------------------------- Separate Condition entry is allowed for each Function. -------------------------------------------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME

A. One radiation monitoring channel inoperable.

A.1 Restore the affected channel to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. ------------NOTE------------

Only applicable in MODE 1, 2, 3, or 4. ---------------------------------

One or more Functions with one or more manual

or automatic actuation trains inoperable.

OR Two or more radiation monitoring channels inoperable.

OR Required Action and associated Completion

Time of Condition A not

met.

B.1 Enter applicable Conditions and Required Actions of LCO 3.6.3, "Containment Isolation Valves," for

containment purge and

exhaust isolation valves

made inoperable by isolation instrumentation.

Immediately Vent Vent vent CTS 1 1 1 1 3.5.b 3.8.a , 3.8.a.2 DOC A02 3.8.b 3.5.c, Table TS 3.5-4 Functional Units 1.b and 3.a Column 6, DOC M02 6 3 Stet Containment Purge and Exhaust Isolation Instrumentation 3.3.6 WOG STS 3.3.6-2 Rev. 3.0, 03/31/04 Vent ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ------------NOTE------------

Only applicable during movement of [recently]

irradiated fuel assemblies within

containment. ---------------------------------

One or more Functions with one or more manual

or automatic actuation trains inoperable.

OR Two or more radiation monitoring channels

inoperable.

OR Required Action and associated Completion Time for Condition A not

met.

C.1 Place and maintain containment purge and

exhaust valves in closed position.

OR C.2 Enter applicable Conditions and Required Actions of LCO 3.9.4, "Containment Penetrations," for containment purge and

exhaust isolation valves

made inoperable by isolation instrumentation.

Immediately

SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE----------------------------------------------------------- Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Purge and Exhaust Isolation Function.

SURVEILLANCE FREQUENCY

SR 3.3.6.1 Perform CHANNEL CHECK.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Vent 3 1 1 CTS 4.1.a, Table TS 4.1-1 Channel Description 19 Stet with changes 3.8.b, DOC

M02, Table

TS 3.5-4 Functional

Unit 3.a Column 6 2 1 6 1 6 vent vent Containment Purge and Exhaust Isolation Instrumentation 3.3.6 WOG STS 3.3.6-5 Rev. 3.0, 03/31/04 Vent Table 3.3.6-1 (page 1 of 1) Containment Purge and Exhaust Isolation Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS

TRIP SETPOINT

1. Manual Initiation 1,2,3,4, (a) 2 SR 3.3.6.6 NA

2. Automatic Actuation Logic and Actuation Relays 1,2,3,4, (a) 2 trains SR 3.3.6.2 SR 3.3.6.3 SR 3.3.6.5 NA 3. [ Containment Radiation

a. Gaseous 1,2,3,4, (a)

[1] SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 ground] b. Particulate 1,2,3,4, (a)

[1] SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 ground] c. Iodine 1,2,3,4, (a)

[1] SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 ground]

d. Area Radiation 1,2,3,4, (a)

[1] SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 ground] ]

4. Containment Isolation -

Phase A Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a., for all initiation functions and requirements.

(a) During movement of [recently] irradiated fuel assemblies within containment.

Vent 5 1 1 2 2 2 1 3 Manual Initiation 1 2 3 CTS DOC M02 6 1 INSERT 1 4 4 4 Table TS 3.5-1 Functional Unit 8, Table TS 3.5-4 Functional Unit 3a, Table TS 4.1-1 Channel Description 19 Table TS 3.5-4 Functional Unit 1.b 6 6 2 6 3 3 3 3 3 3 3 2 KAB-072 changes shown in green 1 Stet Stet Stet with changes 2 3.8.a JUSTIFICATION FOR DEVIATIONS ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION Kewaunee Power Station Page 1 of 4 1. Changes are made (additions, deletions, and/or changes) to the ISTS that 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. ISTS 3.3.6 Table 3.3.6-1 Functions 2 and 3 are applicable in MODES 1, 2, 3, and 4 and during movement of recently irradiated fuel assemblies in containment. ISTS 3.3.6 ACTION B provides the actions when two or more radiation monitoring channels are inoperable or when the Required Action and associated Completion Time of Condition A (i.e., one radiation monitor is inoperable) is not met in MODES 1, 2, 3, and 4. ISTS 3.3.6 ACTION C provides the actions when two or more

radiation monitoring channels are inoperable or when the Required Action and associated Completion Time of Condition A is not met during movement of recently irradiated fuel assemblies within containment. ISTS 3.3.6 ACTION C requires immediately placing and maintaining containment purge and exhaust valves in the closed position or to immediately enter the applicable Conditions and Required Actions of LCO 3.9.4, "Containment Penetrations," for containment purge and exhaust isolation valves made inoperable by isolation instrumentation. Kewaunee Power Station (KPS) does not credit containment isolation in a fuel handling accident analysis in the USAR. Therefore, ITS 3.3.6 does not maintain the applicability of during movement of recently irradiated fuel assemblies within

containment as part of the Applicability. Therefore, all requirements related to movement of irradiated fuel assemblies in the containment (Table 3.3.6-1 Footnote (a) and ACTION C) have been deleted. In addition, due to this deletion, the Note to Condition B has been deleted since it is not necessary (there are no Actions other than those for MODES 1, 2, 3, and 4).

4. The ISTS contains a Surveillance R equirement (SR) for an ACTUATION LOGIC TEST (ISTSSR 3.3.6.2) for the Containment Purge and Vent Isolation Instrumentation that is performed every 31 days on a STAGGERED TEST BASIS. The ISTS also contains an ACTUATION LOGIC TEST (ISTS SR 3.3.6.4) for the Containment Purge and Vent Isolation Instrumentation that is performed every 92 days on a STAGGERED TEST BASIS. ISTS SR 3.3.6.4 was added to the ISTS as part of the incorporation of TSTF-411, which, in part, increases the surveillance test interval (STI) for the actuation logic and actuation relays. The basis for the increase in the STI is WCAP-15376-P, Revision 0, which is consistent with the Nuclear Regulatory Commission's (NRC) approach for using probabilistic risk assessment in risk-informed decisions on plant-specific changes to the current licensing basis as presented in Regulatory Guides 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Current Licensing Basis," and 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." KPS has

elected to adopt the specific ISTS ch anges authorized by the results of WCAP-15376-P Revision 0. Therefore, the bracketed ISTS SR 3.3.6.4 (ITS SR 3.3.6.2) has been adopted for testing of the actuation logic and actuation relays. Subsequent Surveillance Requirements have been renumbered as a result of not including ISTS SR 3.3.6.2 in the ITS.

ISTS 3.9.4 has been renumbered to

ITS 3.9.6.

Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 WOG STS B 3.3.6-2 Rev. 3.0, 03/31/04 Vent BASES

APPLICABLE SAFETY ANALYSES (continued)

rapid isolation is assumed. The containment purge and exhaust isolation radiation monitors act as backup to the SI signal to ensure closing of the purge and exhaust valves. They are also the primary means for automatically isolating containment in the event of a fuel handling accident during shutdown. Containment isolation in turn ensures meeting

the containment leakage rate assumptions of the safety analyses, and ensures that the calculated accidental offsite radiological doses are below 10 CFR 100 (Ref. 1) limits. [Due to radioactive decay, containment is only required to isolate during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has o ccupied part of a critical reactor core within the previous [X] days).]

The containment purge and exhaust isolati on instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requirements ensure that the instrumentation necessary to initiate Containment Purge and Exhaust Isolation, listed in Table 3.3.6-1, is OPERABLE.

1. Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate Containment Purge Isolation at any time by using either of two switches in the control room. Ei ther switch actuates both trains. This action will cause actuation of all components in the same manner as any of the automatic actuation signals.

The LCO for Manual Initiation ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation capability.

Each channel consists of one push button and the interconnecting

wiring to the actuation logic cabinet.

2. Automatic Actuation Logic and Actuation Relays The LCO requires two trains of Automatic Actuation Logic and

Actuation Relays OPERABLE to ensure that no single random failure

can prevent automatic actuation. vent vent Vent vent 3 All changes are unless otherwise noted 1 1 50.67 4 4 control room and ensuring contributes to both Stet Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 WOG STS B 3.3.6-3 Rev. 3.0, 03/31/04 Vent BASES

LCO (continued)

Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b, SI, and ESFAS Function 3.a, Containment Phase A Isolation. The applicable MODES and specified conditions for the containment purge isolation portion of these Functions are different and less restrictive than those for the ir Phase A isolation and SI roles. If one or more of the SI or Phase A isolation Functions becomes inoperable in such a manner that only the Containment Purge Isolation Function is affected, the Conditions applicable to their

SI and Phase A isolation Functions need not be entered. The less restrictive Actions specified for inoperability of the Containment Purge Isolation Functions specify sufficient compensatory measures for this case.

3. Containment Radiation

The LCO specifies four required channels of radiation monitors to ensure that the radiation monitoring instrumentation necessary to initiate Containment Purge Isolation remains OPERABLE.

For sampling systems, channel OPERABILITY involves more than OPERABILITY of the channel electronics. OPERABILITY may also require correct valve lineups, sample pump operation, and filter motor operation, as well as detector OPERABILITY, if these supporting features are necessary for trip to occur under the conditions assumed

by the safety analyses.

4. Containment Isolation - Phase A Refer to LCO 3.3.2, Function 3.a., for all initiating Functions and requirements.

APPLICABILITY The Manual Initiation, Automatic Actuation Logic and Actuation Relays, Containment Isolation - Phase A, and Containment Radiation Functions are required OPERABLE in MODES 1, 2, 3, and 4, and during movement of [recently] irradiated fuel assemblies [(i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] within containment.

Under these conditions, the potential exists for an accident that could

release significant fission produc t radioactivity into containment. Therefore, the containment purge and exhaust isolation instrumentation

must be OPERABLE in these MODES. and vent Containment and Vent Containment and Vent three and Vent vent INSERT 4 4 4 All changes are unless otherwise noted 1 2 4 INSERT 3 will since Stet words boxed in red Stet words

boxed in red 3

Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 WOG STS B 3.3.6-5 Rev. 3.0, 03/31/04 Vent BASES

ACTIONS (continued)

B.1 Condition B applies to all Containment Purge and Exhaust Isolation Functions and addresses the train orientation of the Solid State Protection System (SSPS) and the master and slave relays for these Functions. It also addresses the failure of multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1.

If a train is inoperable, multiple channels are inoperable, or the Required

Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action for the applicable Conditions of LCO 3.6.3 is met for each valve made inoperable by failure

of isolation instrumentation.

A Note is added stating that Condition B is only applicable in MODE 1, 2, 3, or 4. C.1 and C.2

Condition C applies to all Containment Purge and Exhaust Isolation Functions and addresses the train orientation of the SSPS and the master and slave relays for these Functions. It also addresses the failure of multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1. If a train is inoperable, multiple channels are inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action to place and maintain containment purge and exhaust isolation valves in their

closed position is met or the applicable Conditions of LCO 3.9.4, "Containment Penetrations," are met for each valve made inoperable by failure of isolation instrumentation. The Completion Time for these Required Actions is Immediately.

A Note states that Condition C is applicable during movement of [recently] irradiated fuel assemblies within containment.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.6-1 REQUIREMENTS determines which SRs apply to which Containment Purge and Exhaust Isolation Functions.

Vent 4 1 4 1 4 one or more Automatic Actuation Lo gic and Actuation Rela ys trains 1 Stet Stet with changes one or more Automatic Actuation Logic and Actuation relays trains vent 6 4 1 1 4 3 Section 3.6 cross reference changes Containment (Dual)

B 3.6.1B WOG STS B 3.6.1B-3 Rev. 3.1, 12/01/05 BASES

LCO Containment OPERABILITY is mai a , except prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test. At this time the applicable leakage limits must be met.

Compliance with this LCO will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.

Individual leakage rates specified for the containment air lock (LCO 3.6.2)

[, purge valves with resilient seals, and secondary bypass leakage (LCO 3.6.3)] are not specifically part of the acceptance criteria of

10 CFR 50, Appendix J. Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 L

a.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.9.4, "Containment Penetrations." ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem commensurate with the importance

of maintaining containment OPERABLE during MODES 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment

is inoperable is minimal.

B.1 and B.2

If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant 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 plant conditions from full power conditions in an orderly manner and without challenging plant systems. 1 Note that while the Background section describes the Shield Building, the Shield Building requirements are not covered by this LCO; they are provided in LCO 3.6.8, "Shield Building." 6 9 combined 3 11 6 Containment Air Locks (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

B 3.6.2 WOG STS B 3.6.2-2 Rev. 3.0, 03/31/04 BASES

APPLICABLE SAFETY ANALYSES (continued)

10 CFR 50, Appendix J, Option A (Ref. 1), as L a = [0.1]% of containment air weight per day, the maximum allowable containment leakage rate at the calculated peak containment internal pressure P a = [14.4] psig following a design basis LOCA. This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air locks.

The containment air locks satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Each containment air lock forms part of the containment pressure boundary. As part of the containment pressure boundary, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE. For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross br each of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into or exit from containment.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive

material from containment. The re quirements for the containment air locks during MODE 6 are addressed in LCO 3.9.3, "Containment Penetrations." ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perform repairs on the affected air lock component. If the outer door is inoperable, then it may be easily accessed for most repairs. It is

preferred that the air lock be accessed from inside primary containment by entering through the other OPERABLE air lock. However, if this is not practicable, or if repairs on either door must be performed from the barrel

side of the door then it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the

containment boundary is not intact (during access through the 1 B 2 8 8 If the inner door is inoperable, then 5 , 6 10 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2 BASES, CONTAINMENT AIR LOCKS Kewaunee Power Station Page 1 of 1 1. The type of Containment (Dual) and the S pecification designator "B" are deleted since they are unnecessary (only one C ontainment Specification is used in the Kewaunee Power Station (KPS) ITS). This information is provided in NUREG-1431, Rev. 3.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific

implementation.

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 Kewaunee Power Station design does not include a control room indicator for the status of the interlock mechanisms. 4. The brackets have been removed and the pr oper plant specific information/value has been provided. 5. Editorial change made for clarity. 6. Changes made to be consistent with the actual Specification. ISTS 3.6.2 ACTION C has three Required Actions; C.1, C.2, and C.3. 7. Changes made to be consistent with the actual Specification. ISTS 3.6.2 ACTION B does not require the interlock mechanism to be restored to OPERABLE status. Therefore, the words have been changed to be consistent with the actual words in

ISTS 3.6.2 Condition D. 8. 10 CFR 50, Appendix J does not define the values for La and Pa. It only defines what La and Pa are. Therefore, the actual values have been deleted. The words as modified are consistent with similar words in the Applicable Safety Analyses Bases

for ISTS 3.6.1. 9. Changes made to be consistent with changes made to SR 3.6.2.2.

10. Change made to be consistent with the actual Specification number.

ITS 3.9.3 and 3.9.4 changes Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least

two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITS A01 ITS 3.9.3 Page 3 of 4 LCO 3.9.3 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.2 See CTS 3.8.a.3 See ITS 3.9.2 See ITS 3.9.1 See CTS 3.8.a.1 and 3.8.a.8 Applicability A05 ITS 3.9.6 ITS 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge sys tem, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed. ITS A01 ITS 3.9.3 Page 4 of 4 See CTS 3.8.a.1 and 3.8.a.8 See ITS 3.9.5 See CTS 3.8.a.6 See CTS 3.8.a.11 See CTS 3.8.a.12 ACTION A Add proposed Required Actions A.1, A.4, A.5, and A.6 Add proposed Required Action A.3 M02 M02 A04 See CTS 3.8.a.9 ITS 3.9.6 DISCUSSION OF CHANGES ITS 3.9.3, RHR AND COOLANT CIRCULATION - HIGH WATER LEVEL Kewaunee Power Station Page 4 of 6 verification that each penetration providing direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by a Containment Ventilation and Purge Isolation System in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action A.6). This changes the CTS by adding new Required Actions when the required RHR loop is inoperable.

These added Required Actions are acceptable since they assist in minimizing the consequences of the required RHR loop being inoperable. Note that while CTS 3.8.b requires operations not be performed that could increase the reactivity of the core, this action is actually not required to be taken since once movement of fuel has been suspended, REFUELING OPERATIONS has ceased (thus, the LCO requirements of CTS 3.8.a are not required to be met). Thus, the addition of a similar Required Action (Required Action A.1), as well as the other above described Required Actions, is designated as more restrictive.

M03 CTS 3.1.a.1.A does not contain any ACTIONS to take should there be less than the required number of RHR pumps in operation. As a result, CTS 3.0.c would normally be entered. However, LCO 3.0.c states that it is not applicable in COLD SHUTDOWN or REFUELING. Since the RHR pump only has to be in operation when a reduction in boron concentration is being made, and for this

Specification, the unit is already in MODE 6, the CTS does not provide any compensatory measures. Therefore, 10 CFR 50.36 (c)(2)(i) would apply, which states to shutdown the unit. However, no times are provided to complete the shutdown and no further actions (i.e., suspend boron concentration reductions)

are required. Note that while no ACTIONS are required, KPS in all likelihood would suspend dilution if this occurre

d. ITS 3.9.3 ACTION A specifies the Required Actions for a required RHR loop not in operation, and requires immediate suspension of operations that w ould cause introduction of coolant into the RCS with a boron concentration less than required to meet the boron concentration of LCO 3.9.1 (Required Action A.1), immediate suspension of loading irradiated fuel assemblies into the core (Required Action A.2), immediate initiation of action to restore one RHR loop to operation (Required Action A.3), closing the equipment hatch and securing it with four bolts in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action A.4), closing one door in each air lock in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action A.5), and a verification that each penetration pr oviding direct access from the containment atmosphere to the outside atmosphere is either closed with a

manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by a Containment Ventilation Isolation System in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action A.6). This changes the CTS by adding a new ACTION.

The purpose of the Actions should be to place the unit outside of the Applicability of the Specification. ITS 3.9.3 ACTION A effectively places the unit in an equivalent condition by requiring the plant to immediately suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the boron concentration of LCO 3.9.1 and to initiate action to restore one RHR loop to operation. The proposed Required Actions reflect the importance of maintaining operation for decay heat removal and boron mixing. This change is designated as more restrictive because a new proposed ACTION has been added.

an OPERABLE an OPERABLE Purge and Vent and Vent RHR and Coolant Circulation - High Water Level 3.9.5 WOG STS 3.9.5-2 Rev. 3.0, 03/31/04 CTS 4 3ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.4 Close equipment hatch and secure with [four] bolts.

AND A.5 Close one door in each air lock.

AND A.6.1 Close each penetration providing direct access

from the containment

atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

OR A.6.2 Verify each penetration is capable of being closed by

an OPERABLE Containment Purge and

Exhaust Isolation System.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 3.1.a.2.B.2, 3.8.b, DOC M03 2; or is either closed Ventilation Verify 3

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.9.5.1 Verify one RHR loop is in operation and circulating

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4 3 DOC M04 5 Stet Purge and Vent JUSTIFICATION FOR DEVIATIONS ITS 3.9.3, RHR AND COOLANT CIRCULATION - HIGH WATER LEVEL

1. The title of the LCO has been provided since this is the first reference to the LCO.

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 requirements.

3. ISTS 3.9.5 Required Actions A.6.1 and A.6.2 are connected by an "OR" logical connector, such that either one can be performed to meet the requirements of the ACTION. However, the two Required Actions are applicable to all the penetrations; either Required Action A.6.1 or Required Action A.6.2 must be performed for all the penetrations. Thus, this will not allow one penetration to be isolated by use of a manual valve and another penetration to be capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. This is not the intent of the requirement. The requirement is based on ISTS LCO 3.9.4, which requires each penetration to be either: a) closed by a manual or automatic isolation valve, blind flange, or equivalent; or b) capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. For consistency with the actual LCO requirement, ISTS 3.9.5 Required Actions A.6.1 and A.6.2 have been combined into a single Required Action in ITS 3.9.3 Required Action A.6. In addition, since ISTS 3.9.4 has not been adopted, the term OPERABLE has been deleted.

Furthermore, the title of the system has been changed to be consistent with the Kewaunee Power Station System name (i.e., Containment Ventilation Isolation System). 4. ISTS 3.9.5 has been renumbered to ITS 3.9.3 since ISTS 3.9.2 and ISTS 3.9.4 have not been included in the KPS ITS. 5. The minimum required RHR flow rate requirement has not been included in KPS ITS SR 3.9.3.1. The Bases states that the flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. However, the decay heat is not always the same; it is a function of time after shutdown and the power history of the fuel. Furthermore, SRs in Section 3.4 (ITS SRs 3.4.6.1, 3.4.7.1, and 3.4.8.1) require a similar verification that the RHR loop is in operation, but do not

specify a flow rate requirement. This change is also consistent with the KPS current Technical Specifications, which does not specify a flow rate for the RHR loop. Kewaunee Power Station Page 1 of 1 and ISTS 3.9.4 is being numbered as ITS 3.9.6.

has Purge and Vent RHR and Coolant Circulation - High Water Level B 3.9.5 WOG STS B 3.9.5-4 Rev. 3.0, 03/31/04 3 BASES

ACTIONS (continued)

b. One door in each air lock must be closed, and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere must be either closed by a manual or automatic isolation valve, blind flange, or equivalent, or verified to be capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

With RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere.

Performing the actions described above ensures that all containment penetrations are either closed or can be closed so that the dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allows fixing of most RHR problems and is reasonable, based on the low probability of the coolant boiling in that

time. SURVEILLANCE SR 3.9.5.1 REQUIREMENTS This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the core. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering the flow, temperature, pump control, and alarm indications available to th e operator in the control room for monitoring the RHR System.

REFERENCES 1. FSAR, Section [5.5.7].

U 14.1.4.2 2 5 ; Ventilation 2 2. USAR, Section 9.3.1.2.

2 10 11 3 11 9 9 Circulating coolant ensures thermal and boron stratification are minimized Stet Purge and Ven t

JUSTIFICATION FOR DEVIATIONS ITS 3.9.3 BASES, RHR AND COOLANT CIRCULATION - HIGH WATER LEVEL Kewaunee Power Station Page 1 of 1 1. Kewaunee Power Station (KPS) was designed and under construction prior to the promulgation of 10 CFR 50 Appendix A. KPS was designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967. The KPS USAR Section 1.8 provides a descripti on of each of the proposed General Design Criteria and how KPS meets the intent of each one. However, the proposed General Design Criteria did not have a criteria equivalent to 10 CFR 50 Appendix A, GDC 34. Therefore, reference to this GDC has been deleted.

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

3. Changes have been made to be consistent with the actual wording in the Specification. ISTS 3.9.5 (ITS 3.9.3) requires an RHR "loop" to be "OPERABLE and in operation." 4. The correct title for the LCO has been provided, since this LCO is what meets Criterion 4, not the entire RHR System.

5. The 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. Changes have been made to be consistent with the actual wording in the Specification. ISTS 3.9.5 (ITS 3.9.3) does not require reactor coolant temperature indication to be OPERABLE; it requires an RHR loop to be OPERABLE and in operation.

7. The title of the LCO has been provided since this is the first reference to the LCO.

8. The wording has been modified since Section 3.5 does not provide requirements for the RHR decay heat removal function.

9. Changes made to be consistent with changes made to the Specification.

10. The ISTS Bases 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.

11. ISTS 3.9.5 has been renumbered to ITS 3.9.3 since ISTS 3.9.2 and ISTS 3.9.4 have not been included in the KPS ITS.

12. Typographical error corrected.

has and ISTS 3.9.4 is being numbered as ITS 3.9.6 DISCUSSION OF CHANGES ITS 3.9.4, RHR AND COOLANT CIRCULATION - LOW WATER LEVEL Kewaunee Power Station Page 3 of 5 OPERABLE status or to above the top of the reactor vessel flange. This changes the CTS by adding a new ACTION when both required RHR loops are inoperable.

The change is acceptable because the Completion Times are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features, a r easonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Times. The immediate initiation of action to restore the required loops to OPERABLE status or to estt of water above the top of the reactor vessel flange reflects the impo rtance of maintaining operation for decay heat removal. This change is designated as more restrictive because a new

ACTION is being added to the ITS that was not required by the CTS.

M03 CTS 3.1.a.1.A does not contain any ACTIONS to take should there be less than the required number of RHR pumps in operation. As a result, CTS 3.0.c would normally be entered. However, LCO 3.0.c states that it is not applicable in COLD SHUTDOWN or REFUELING. Since the RHR pump only has to be in operation when a reduction in boron concentration is being made, and for this specification, the unit is already in MODE 6, the CTS does not provide any compensatory

measures. Therefore, 10 CFR 50.36 (c)(2)(i) would apply, which states to shut

down the unit. However, no times are provided to complete the shutdown and no further actions (i.e., suspend boron concentr ation reductions) are required. Note that while no ACTIONS are required, KPS in all likelihood would suspend dilution if this occurred. ITS 3.9.4 ACTION B s pecifies the Required Actions for a required RHR loop not in operation, and requires immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the boron concentration of LCO 3.9.1 (Required Action B.1), immediate initiation of action to restore one RHR loop to operation (Required Action B.2), closing the equipment hatch and securing it with four bolts in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action B.3), closing one door in each air lock in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action B.4), and a verification that each penetration providing

direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by a Containment Ventilation Isolation System in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Required Action B.5). This changes the CTS by adding a new ACTION.

The purpose of the Actions should be to place the unit outside of the Applicability of the Specification. ITS 3.9.4 ACTION B effectively places the unit in an equivalent condition by requiring the plant to immediately suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the boron concentration of LCO 3.9.1 and to initiate action to restore one RHR loop to operation. The proposed Required Actions reflect the importance of maintaining operation for decay heat removal and boron mixing. This change is designated as more restrictive because a new proposed

ACTION has been added.

M04 CTS 3.1.a.1.A requires one RHR pump to be in operation under certain conditions, but does not provide a Surveillance Requirement to periodically verify the required pump is in operation. ITS SR 3.9.4.1 requires verification that each an OPERABLE Purge and Vent RHR and Coolant Circulation - Low Water Level 3.9.6 WOG STS 3.9.6-3 Rev. 3.0, 03/31/04 4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.9.6.2 Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation.

7 days DOC M04 DOC M04 DOC M03 Ventilation Move to Required Action 6 9 -----------------------------NOTE------------------------- Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. --------------------------------------------------------------

7 CTS 6 8 8 8 4 4 Stet Purge and Vent JUSTIFICATION FOR DEVIATIONS ITS 3.9.4, RHR AND COOLANT CIRCULATION - LOW WATER LEVEL Kewaunee Power Station Page 1 of 2 1. The term "train" in ISTS 3.9.6 LCO Note 1 has been changed to "loop" to be consistent with the actual LCO statement, which requires loops to be OPERABLE and in operation, not trains. In addition, the term "degrees" has been replaced with the unit designator "º" consistent with its use throughout the ISTS (see ISTS LCO 3.4.6, 3.4.7, and 3.4.8 Note 1).

2. The 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.

3. The title of the LCO has been provided since this is the first reference to the LCO.

4. Typographical error corrected.

5. 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 requirements.

6. ISTS 3.9.6 Required Actions B.5.1 and B.5.2 are connected by an "OR" logical connector, such that either one can be performed to meet the requirements of the

ACTION. However, the two Required Actions are applicable to all the penetrations;

either Required Action B.5.1 or Required Action B.5.2 must be performed for all the penetrations. Thus, this will not allow one penetration to be isolated by use of a

manual valve and another penetration to be capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. This is not the intent of the requirement. The requirement is based on ISTS LCO 3.9.4, which requires each penetration to be either: a) closed by a manual or automatic isolation valve, blind flange, or equivalent; or b) capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. For consistency with the actual LCO requirement, ISTS 3.9.6 Required Actions B.5.1 and B.5.2 have been combined into a single Required Action in ITS 3.9.4 Required Action B.5. In addition, since ISTS 3.9.4 has not been adopted, the term OPERABLE has been deleted.

Furthermore, the title of the system has been changed to be consistent with the Kewaunee Power Station System name (i.e., Containment Ventilation Isolation System). 7. TSTF-265 was previously approved and incorporated in NUREG-1431, Rev. 2, in similar SRs (e.g., ISTS SRs 3.4.5.3, 3.4.6.3, 3.4.7.3, and 3.4.8.2). Consistent with

TSTF-265, a Note is added to ITS SR 3.9.4.2 that permits the performance of the SR to verify correct breaker alignment and power availability to be delayed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RHR pump is not in operation. This provision is required because when RHR pumps are swapped under the current requirements, the Surveillance is immediately not met on the RHR pump taken out of operation. This change avoids entering an Action for a routine operational occurrence. The change is acceptable because adequate assurance exists that the RHR pump is aligned to the correct breaker with power available because, prior to being removed from operation, the applicable pump had been in operation. Allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the breaker alignment verification is acceptable because the RHR pump was in operation, which demonstrated OPERABILITY, and because 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed in the ISTS by Purge and Vent JUSTIFICATION FOR DEVIATIONS ITS 3.9.4, RHR AND COOLANT CIRCULATION - LOW WATER LEVEL Kewaunee Power Station Page 2 of 2 invoking SR 3.0.3. This is also a new Surveillance Requirement not required in CTS 3.1.a.2.B. 8. ISTS 3.9.6 has been renumbered to ITS 3.9.4 since ISTS 3.9.2 and ISTS 3.9.4 have not been included in the KPS ITS. 9. The minimum required RHR flow rate requirement has not been included in KPS ITS SR 3.9.4.1. The Bases states that the flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. However, the decay heat is not always the same; it is a function of time after shutdown and the power history of the fuel. Furthermore, SRs in Section 3.4 (ITS SRs 3.4.6.1, 3.4.7.1, and 3.4.8.1) require a similar verification that the RHR loop is in operation, but do not specify a flow rate requirement. This change is also consistent with the KPS current Technical Specifications, which does not specify a flow rate for the RHR loop.

has and ISTS 3.9.4 is being numbered as ITS 3.9.6 RHR and Coolant Circulation - Low Water Level B 3.9.6 WOG STS B 3.9.6-4 Rev. 3.0, 03/31/04 14 4 BASES ACTIONS (continued)

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere must be either closed by a manual or automatic isolation valve, blind flange, or equivalent, or verified to be capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

With RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere.

Performing the actions stated above ensures that all containment penetrations are either closed or can be closed so that the dose limits are

not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allows fixing of most RHR problems and is reasonable, based on the low probability of the coolant boiling in that

time.

SURVEILLANCE SR 3.9.6.1 REQUIREMENTS This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the core. In addition, during operation of the RHR loop with the water level in the vicinity of the reactor vessel nozzles, the RHR pump suction requirements must be met. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering the flow, temperature, pump control, and alarm indications available to the operator for monitoring the RHR System in the control room.

Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

REFERENCES 1. FSAR, Section [5.5.7].

SR 3.9.4.2 914.1.4.2 2 U 14Ventilation 2 14 4 13This SR is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. 2. USAR, Section 9.3.1.2.

7 2 12Circulating coolant ensures thermal and boron stratification are minimized.

12 14 stet Purge and Vent JUSTIFICATION FOR DEVIATIONS ITS 3.9.4 BASES, RHR AND COOLANT CIRCULATION - LOW WATER LEVEL Kewaunee Power Station Page 2 of 2 14. ISTS 3.9.6 has been renumbered to ITS 3.9.4 since ISTS 3.9.2 and ISTS 3.9.4 have not been included in the KPS ITS.

has and ISTS 3.9.4 is being numbered as ITS 3.9.6 CTS 3.8.a.1 and 3.8.a.8 relocation deletion CTS 3.8.a.1 and 3.8.a.8, CONTAINMENT PENETRATIONS

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and whic h provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least

two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed.

CTS 3.8.a.1 and 3.8.a.8 See ITS 3.9.2 See ITS 3.9.1 See CTS 3.8.a.2 See ITS 3.9.3 R01 See CTS 3.8.a.3 Page 1 of 2 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 R01 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system , including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.6 See CTS 3.8.a.9 See ITS 3.9.5 See CTS 3.8.a.11 See CTS 3.8.a.12 Page 2 of 2 R01 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 DISCUSSION OF CHANGES CTS 3.8.a.1 and 3.8.a.8, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 2 ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None

RELOCATED SPECIFICATIONS

R01 CTS 3.8.a.1 and 3.8.a.8 provide requirements for Containment Closure during refueling operations. The purpose of the Containment Closure during Refueling requirements is to restrict the release of fission product radioactivity within

containment from escaping to the environment following a fuel handling accident within the containment. The containment closure is not taken credit for in any accident analyses in the USAR. This is also documented in the NRC Safety Evaluation for License Amendment 190, dated March 8, 2007 (ADAMS

Accession No. ML070430020). Therefor e, the ITS does not include these Specifications. This changes the CTS by relocating the Containment Closure Specifications to the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3.8.a.1 and 3.8.a.8 do not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. Containment closure is not instal led instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The Containment Closure

Specifications do not satisfy criterion 1.

2. Containment closure is not a process variable, design feature, or operating restriction that is in an initial condition of a DBA or Transient

Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Containment Closure

Specifications do not satisfy criterion 2.

3. Containment closure is not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Containment Closure Specifications do not satisfy criterion 3.

4. Containment closure was found to be non-significant risk contributor to core damage frequency and offsite releases. Dominion Energy Kewaunee (DEK) has performed a plant specific evaluation to ensure that the Containment Closure requirements do not contain constraints of prime importance in limiting the lik elihood or severity of the accident DISCUSSION OF CHANGES CTS 3.8.a.1 and 3.8.a.8, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 2 of 2 sequences that are commonly found to be important to public health and safety.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Containment Closure Specifications (CTS 3.8.a.1 and 3.8.a.8) may be relocated out of the Technical Specifications. The containment closure specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is desi gnated as relocation because the specifications did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None

Specific No Significant Hazar ds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3.8.a.1 and 3.8.a.8, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 1 There are no specific NSHC discussions for this Specification.

Section 3.7 CTS Markup cross reference change Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.CTS 3.8.a.9 Page 1 of 4 See CTS 3.8.a.6 See ITS 3.9.5 See CTS 3.8.a.11 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 See CTS 3.8.a.12 R01 See CTS 3.8.a.1 and 3.8.a.8 ITS 3.9.6 , and 3.9.6 Section 3.9 CTS Markup cross reference change Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and whic h provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least

two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITS A01 ITS 3.9.1 Page 1 of 3 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.2 See CTS 3.8.a.3 See ITS 3.9.2 See CTS 3.8.a.1 and 3.8.a.8 Applicability See ITS 3.9.3 M01 LCO 3.9.1 SR 3.9.1.1 L01 M02 Add proposed Applicability Note M01 M01 M02 Applicability Applicability LA01 every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ITS 3.9.6 ITS 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge sys tem, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

ITS A01 ITS 3.9.1 Page 2 of 3 See CTS 3.8.a.6 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.9 See CTS 3.8.a.11 See CTS 3.8.a.12 ACTION A See ITS 3.9.5 ITS 3.9.6 Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and whic h provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least

two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITS A01 ITS 3.9.2 Page 1 of 3 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.3 See CTS 3.8.a.1 and 3.8.a.8 Applicability See ITS 3.9.3 M01 See ITS 3.9.1 LCO 3.9.2 M01 LCO 3.9.2 Applicability A02 OPERABLE See CTS 3.8.a.2 LA01 A02 OPERABLE ITS 3.9.6 ITS 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

ITS A01 ITS 3.9.2 Page 2 of 3 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.9 See CTS 3.8.a.6 See CTS 3.8.a.11 See CTS 3.8.a.12 ACTION A See ITS 3.9.5 M02 A03 Add proposed Required Action A.2 Add proposed ACTIONS B and C ITS 3.9.6 Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and whic h provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least

two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITS A01 ITS 3.9.5 Page 1 of 2 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.2 See CTS 3.8.a.3 See ITS 3.9.2 See ITS 3.9.1 See CTS 3.8.a.1 and 3.8.a.8 Applicability See ITS 3.9.3 L01 ITS 3.9.6 ITS 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

ITS A01 ITS 3.9.5 Page 2 of 2 See CTS 3.8.a.6 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.9 See CTS 3.8.a.11 See CTS 3.8.a.12 ACTION A LCO 3.9.5 M01 Add proposed SR 3.9.5.1 L02 ITS 3.9.6 Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling ar eas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed.

CTS 3.8.a.2 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.3 See ITS 3.9.2 See ITS 3.9.1 See CTS 3.8.a.1 and 3.8.a.8 See ITS 3.9.3 Page 1 of 1 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 See ITS 3.9.1, 3.9.2, 3.9.3, 3.9.5, and CTS 3.8.a.3 R01 3.9.6, ITS 3.9.6 ITS 3.9.6 , and 3.9.6 Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during RE FUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel head or upper internals are lifted. b. Each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least

two neutron monitors, each with continuous visual indication in the control room and one with audible indication in the contai nment whenever core geometry is being changed. When core geometry is not bei ng changed at least one neutron flux monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimu m boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed.

CTS 3.8.a.3 Page 1 of 1 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.2 See ITS 3.9.2 See ITS 3.9.1 See CTS 3.8.a.1 and 3.8.a.8 See ITS 3.9.3 LA01 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 LA01 ITS 3.9.6 ITS 3.9.6 , and 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge sys tem, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

CTS 3.8.a.6 Page 1 of 1 R01 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.9 See ITS 3.9.5 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 See CTS 3.8.a.11 See CTS 3.8.a.12 ITS 3.9.6 , and 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

Page 1 of 2 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.9 See ITS 3.9.5 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 See CTS 3.8.a.12 CTS 3.8.a.11 See CTS 3.8.a.6 R01 ITS 3.9.6 , and 3.9.6 Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, incl uding the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.

Page 1 of 1 See CTS 3.8.a.1 and 3.8.a.8 See CTS 3.8.a.9 See ITS 3.9.5 See ITS 3.9.1, 3.9.2, 3.9.3, and 3.9.5 CTS 3.8.a.12 See CTS 3.8.a.6 See CTS 3.8.a.11 A01 , and 3.9.6 ITS 3.9.6 Licensee Response/NRC Response/NRC Question Closure Id3811NRC Question Number RPG-010 Select Application Licensee Response Response Date/Time 7/16/2010 8:30 AM Closure Statement Response Statement Based upon a recent discussion with the NRC reviewers, DEK is submitting the attached markup that supersedes the markup posted on 6/10/2010. This revised markup removes the note in 3.9.6 regarding the allowance for unisolating penetrations under administrative controls. In addition, DOC L03 was deleted with subsequent DOCs renumbered, the CTS insert was removed, the LCO Bases for the note deleted, and the ISTS JFD was modified. This cha nge will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 RPG-010 Markup Rev. 1.pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 7/16/2010 8:36 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 07/19/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=3811 NEW ITS 3.9.6 ATTACHMENT 6 ITS 3.9.6, CONTAINMENT PENETRATIONS Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Amendment No. 165 TS 3.8-1 03/11/2003 3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs during REFUELING OPERATIONS that would affect public health and safety.

SPECIFICATION

a. During REFUELING OPERATIONS:

1. Containment Closure

a. The equipment hatch shall be closed and at least one door in each personnel air lock shall be capable of being closed (1) in 30 minutes or less. In addition, at least one door in each personnel air lock shall be closed when the reactor vessel

head or upper internals are lifted.

b. Each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation

valve or an operable automatic isolation valve.

2. Radiation levels in fuel handling areas, the containment and the spent fuel storage pool shall be monitored continuously.

3. The reactor will be subcritical for 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months prior to movement of its irradiated fuel assemblies. Core subcritical neutron flux shall be continuously monitored by at least two neutron monitors, each with continuous visual indication in the control room and

one with audible indication in the containment whenever core geometry is being

changed. When core geometry is not being changed at least one neutron flux

monitor shall be in service.

4. At least one residual heat removal pump shall be OPERABLE.

5. When there is fuel in the reactor, a minimum boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System during reactor vessel

head removal or while loading and unloading fuel from the reactor. The required

boron concentration shall be verified by chemical analysis daily. (1) Administrative controls ensure that: Appropriate personnel are aware that both personnel air lock doors are open, A specified individual(s) is designated and available to close the air lock following a required evacuation of containment, and Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed. ITS A01 ITS 3.9.6 See ITS 3.9.2 See ITS 3.9.1 See ITS 3.3.6 and 3.3.8See ITS 3.9.3 LA01See CTS 3.8.a.3 L05 LCO 3.9.6.a and b LCO 3.9.6.c.1 and 2 Applicability Page 1 of 2LA01 L01 L02, blind flange, or equivalent Amendment No. 200 TS 3.8-2 11/20/2008 6. Direct communication between the control room and the operating floor of the containment shall be available whenever changes in core geometry are taking place. 7. Deleted.

8. The containment ventilation and purge system, including the capability to initiate automatic containment ventilation isolation, shall be tested and verified to be

operable immediately prior to and daily during REFUELING OPERATIONS.

9. a. The spent fuel pool sweep system, including the charcoal adsorbers, shall be operating during fuel handling and when any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days. If the spent fuel pool

sweep system, including the charcoal adsorber, is not operating when required, fuel movement shall not be started (any fuel assembly movement in progress

may be completed).

b. Performance Requirements

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show

>99% DOP removal and >

99% halogenated hydrocarbon removal.

2. The results of laboratory carbon sample analysis from spent fuel pool sweep system carbon shall show >

95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C and 95% RH. 3. Fans shall operate within +

10% of design flow when tested.

10. The minimum water level above the vessel flange shall be maintained at 23 feet.

11. A dead-load test shall be successfully performed on both the fuel handling and manipulator cranes before fuel movement begins. The load assumed by the cranes for this test must be equal to or greater than the maximum load to be assumed by the cranes during the REFUELING OPERATIONS. A thorough visual inspection of

the cranes shall be made after the dead-load test and prior to fuel handling.

12. A licensed senior reactor operator will be on-site and designated in charge of the REFUELING OPERATIONS.

b. If any of the specified limiting conditions for REFUELING OPERATIONS are not met, refueling of the reactor shall cease. Work shall be initiated to correct the violated conditions so that the specified limits are met, and no operations which may increase the reactivity of the core shall be performed.ACTION A A01 ITS 3.9.6 ITS See CTS 3.8.a.6 See CTS 3.8.a.9 See ITS 3.9.5 See CTS 3.8.a.11See CTS 3.8.a.12 Page 2 of 2 SR 3.9.6.2 L04Add p ro posed SR 3.9.6.2 NoteM01Add proposed SR 3.9.6.1 L03 L04 LCO 3.9.6.c.2 on an actual or simulated actuation signal A02See ITS 5.5.9 DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 4 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 When the containment penetrations are not in the required condition specified in CTS 3.8.a.1 or CTS 3.8.a.8, CTS 3.8.b requires refueling of the reactor to cease, initiation of action to restore the containment penetrations to the required conditions, and no operations be performed that could increase the reactivity of the core. Under similar conditions, ITS 3.9.6 ACTION A only requires movement of irradiated fuel assemblies within containment to be suspended. This changes the CTS by deleting the requirements to initiate action to restore the containment penetrations to the required conditions and that no operations be performed that

could increase the reactivity of the core.

The purpose of CTS 3.8.a.8 is to ensure proper compensatory actions are taken to exit the Applicability of the LCO. CTS 3.8.a.1 and 3.8.a.8 are only applicable during REFUELING OPERATIONS, which is defined in CTS Section 1.0 as the movement of reactor vessel internals that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. Thus, after the first requirement of CTS 3.8.b is met (i.e., suspend refueling the reactor), the Applicability has been exited and thus, continuation of the requirements of CTS 3.8.b are not required. Therefore, this change is acceptable and is designated as administrative since the technical requirements have not been changed.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.a does not provide a Surveillance Requirement to verify each required containment penetration is in the required status. The ITS adds a Surveillance Requirement (SR 3.9.6.1) to verify each required containment penetration is in the required status once every 7 days. This changes the CTS by adding a new Surveillance Requirement for the containment penetrations.

This change is acceptable because the added Surveillance Requirement ensures that each required containment penetration is in the required status to support the containment penetration conditions assumed in the Fuel Handling Accident (FHA) analysis. In addition, this cha nge is acceptable because the Surveillance Requirement continues to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This

change is designated as more restrictive because a new Surveillance Requirement has been added.

DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 2 of 4 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.a.1.a requires at least one door in each personnel air lock to be capable of being closed "within 30 minutes."

CTS 3.8.a.1.a is modified by a footnote (1) that states "Administrative controls ensure that appropriate personnel are aware that both personnel air lock doors are open; a specified individual(s) is designated and available to close the air

lock following a required evacuation of containment; and, any obstruction(s) (e.g.,

cables and hoses) that could prevent closure of an open air lock can be quickly

removed." ITS 3.9.6 does not contain this footnote information or the 30 minute requirement. This changes the CTS by moving the information contained in the footnote and the 30 minute requirement to the Bases.

The removal of these details, which are related to procedural details for meeting Technical Specification 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 protection of public health and safety. The ITS still retains the requirement for at least one door in each personnel air lock to be capable of being closed. 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. 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

procedural details for meeting Technical Specification requirements is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.a.1.a, in part, requires at least one door in each personnel air lock to be closed when the reactor vessel head or upper internals are being lifted. ITS 3.9.6 does not include this requirement. This changes the CTS by not requiring one door in each personnel air lock to be closed when the reactor vessel head or upper internals are being lifted.

The purpose of CTS 3.8.a.1 is to ensure that if a fuel handling accident occurs, the release of any subsequent fission products results in doses that are well within the guideline values specified in Regulatory Guide 1.183. A fuel handling accident, as analyzed in USAR Section 14.2.1, is postulated to occur during

handling of irradiated fuel assemblies; not handling the vessel head or upper internals. Thus, moving the vessel head or upper internals cannot result in a fuel handling accident. Any additional requirements, above those required to meet the assumptions of the fuel handling accident, are more appropriately controlled DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 3 of 4 by plant procedures. Therefore, this change is acceptable and is designated a less restrictive change since the requirement to maintain containment closure capability during movement of the vessel head or upper internals is being deleted from the CTS.

L02 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.a.1.b, in part, states that each line that penetrates containment and which provides a direct air path from containment atmosphere to the outside atmosphere shall have a closed isolation valve. ITS LCO 3.9.6.c.1 states that each penetration providing direct access from the containment atmosphere to the outside atmosphere is closed by

a manual or automatic isolation valve, blind flange, or equivalent. This changes the CTS by specifying the use of a blind flange or an equivalent means of isolating a containment penetration.

The purpose of CTS 3.8.a.1 is to ensure the containment penetrations are in the condition assumed in the Fuel Handling Accident (FHA) analysis. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The addition of the option to use a blind flange or some other equivalent means of isolating the containment penetration allows additional flexibility in the ITS that was not available in CTS. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L03 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 3.8.a.8 requires verification of the automatic actuation of the Containment Ventilation and Purge valves on a containment ventilation isolation signal. ITS SR 3.9.6.2 specifies that the signal may be from either an actual or simulated signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal to perform the Surveillance.

The purpose of CTS 3.8.a.8 is to ensure that the containment purge and vent valves operate 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," "simulated," or "test" 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.

The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L04 (Category 7 - Relaxation Of Surveillance Frequency)

CTS 3.8.a.8 includes a Surveillance Frequency of "immediately prior to and daily during REFUELING OPERATIONS" for performing a Surveillance of the Containment Ventilation and Purge System. The ITS SR 3.9.6.2 Frequency for the same requirement is 18 months. ITS SR 3.9.6.2 is also modified by a Note that states that SR 3.9.6.2 is not required to be met for containment purge and vent valve(s) in penetrations that are closed to comply with LCO 3.9.6.c.1. This changes the CTS by DISCUSSION OF CHANGES ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 4 of 4 changing the Surveillance Frequency from immediately prior to and daily during REFUELING OPERATIONS to 18 months and adding the Note that the SR is not required to be met for containment purge and vent valve(s) in penetrations that are closed to comply with ITS LCO 3.9.6.c.1.

The purpose of CTS 3.8.a.8 is to verify the equipment required to meet the LCO is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Containment purge and vent valve testing is still required, but at a Frequency consistent with the testing Frequency for containment isolation valves required in MODES 1, 2, 3, and 4. This Frequency provides an appropriate degree of assurance that the valves are OPERABLE. When containment purge and vent valve(s) in penetrations are closed to comply with ITS LCO 3.9.6.c.1, the penetrations are in the expected condition (isolated) to mitigate the effects of a fuel handling accident inside containment. Therefore, there is no need for the actuation signal to reposition the valves to the closed position. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L05 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.a specifies that the CTS 3.8.a.1 containment closure requirements are applicable during REFUELING OPERATIONS, which is defined in CTS Section 1.0 as the movement of reactor vessel internals that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. ITS 3.9.6 is applicable during movement of irradiated fuel assemblies within containment.

This changes the CTS by not requiring the containment closure requirements to be met when moving or handling control rods during MODE 6 operation.

The purpose of CTS 3.8.a.1 is to ensure that if a fuel handling accident occurs, the release of any subsequent fission products results in doses that are well within the guideline values specified in Regulatory Guide 1.183. A fuel handling accident, as analyzed in USAR Section 14.2.1, can only occur during handling of irradiated fuel assemblies; not moving or handling control rods (which are the only other reactor vessel internals currently in use at KPS that could affect reactivity of the core). Thus, moving or handling the control rods cannot result in a fuel handling accident. Any additional requirements, above those required to meet the assumptions of the fuel handling accident, are more appropriately controlled by plant procedures. Therefore, this change is acceptable and is designated a less restrictive change since the requirement to maintain containment closure capability during movement or handling of control rods in

MODE 6 is being deleted from the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Containment Penetrations 3.9.4 WOG STS 3.9.4-1 Rev. 3.0, 03/31/04 6 3.9 REFUELING OPERATIONS

3.9.4 Containment

Penetrations

LCO 3.9.4 The containment penetrations shall be in the following status:

a. The equipment is hatch closed and held in place by [four] bolts,

b. One door in each air lock is [capable of being] closed, and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere is either:

1. Closed by a manual or automatic isolation valve, blind flange, or equivalent or

2. Capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

NOTE-------------------------------------------- Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under

administrative controls. ------------------------------------------------

APPLICABILITY: During movement of [recently] irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more containment penetrations not in required status.

A.1 Suspend movement of

[recently] irradiated fuel assemblies within containment.

Immediately

CTS 3.8.a.1.a 3.8.a.1.b 3.8.a 3.8.b 2 1 5 5;3 3;Vent 4 3.8.1.a.b, 3.8.a.8 1 6 6 6 6 6 7 Containment Penetrations 3.9.4 WOG STS 3.9.4-2 Rev. 3.0, 03/31/04 6SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify each required containment penetration is in the required status.

7 days SR 3.9.4.2 -------------------------------

NOTE------------------------------ Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.4.c.1. ---------------------------------------------------------------------

Verify each required containment purge and exhaust valve actuates to the isolation position on an actual

or simulated actuation signal.

[18] months CTS DOC M01 1 3.8.a.8 vent 4vent 4 6 6 6 6 6 6 6 JUSTIFICATION FOR DEVIATIONS ITS 3.9.6, CONTAINMENT PENETRATIONS Kewaunee Power Station Page 1 of 1 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. A typographical error within the ISTS has been corrected. The word "is" has been placed after the word "hatch".

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

4. 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.

5. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. In ITS 3.9.6 Applicability and Required Action A.1, the brackets and the term "recently" have been deleted since the term "recently" does not apply to KPS when referring to irradiated fuel assemblies.

6. ISTS 3.9.4 has been renumbered to ITS 3.9.6 since it was added back into the ITS as the result of an NRC RAI and KPS chose not to renumber multiple Specifications due to this later addition.

7. The ISTS 3.9.4 LCO Note allowance has not been adopted.