ML110260316

Part 035 ME2139 ITS Conversion Regulatory Commitments List

ML110260316
Person / Time
Site:	Kewaunee
Issue date:	02/02/2011
From:	Feintuch K Plant Licensing Branch III
To:	Heacock D Dominion Energy Kewaunee
Feintuch K D, NRR/DORL/LPL3-1, 415-3079
Shared Package
ML103350500	List: ML102020662 ML102020664 ML103360504 ML103370691 ML103480931 ML110260316
References
TAC ME2139
Download: ML110260316 (4)

Text

LIST OF REGULATORY COMMITMENTS 1 The following list identifies those actions committed as regulatory commitments by Dominion Energy Kewaunee (DEK) for the Kewaunee Power Station (Kewaunee). Any other actions discussed in DEK's license amendment request are not regulatory commitments.

This following list is derived from "Commitment List," accessible in ADAMS by its Accession number as ML1023711

97. No. Commitment Due Date/Event 1 DEK will have written procedures available describing the compensatory measures when LCO 3.7.10, Control Room Post-Accident Recirculation (CRPAR) System, ACTION B, "Two CRPAR trains inoperable due to inoperable control room boundary in MODE 1, 2, 3, or 4," is entered.

Upon implementation 2 DEK will establish the Technical Specification Bases for LCO 3.0.8, as adopted, with the applicable license amendment.

Upon implementation 3 DEK will ensure that when LCO 3.0.8a is used, appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) must be available.

Upon implementation 4 DEK will ensure that when LCO 3.0.8b is used, appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), or some alternative means of core cooling (e.g., F&B, firewater system or aggressive secondary cooldown using the steam generators) must be available.

Upon implementation

LIST OF REGULATORY COMMITMENTS 2 No. Commitment Due Date/Event 5 DEK will ensure that when LCO 3.0.8 is used appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

Each time the provisions of LCO 3.0.8 are used DEK will confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non

-

seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e., seismic vs.

non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis.

Upon implementation 6 DEK will revise the USAR or TS Bases to describe the restrictions in commitments 3 and 4.

In accordance with 10 CFR 50.71(e) 7 DEK will have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into LCO 3.7.12, Auxiliary Building Special Ventilation (ASV) System, Condition B, "Two ASV trains inoperable due to inoperable ASV boundary."

Upon implementation 8 Withdrawn, refer to Enclosure Volume 8.

N/A LIST OF REGULATORY COMMITMENTS 3 No. Commitment Due Date/Event 9 DEK will implement administrative controls to include the following restrictions.

Activities that could degrade the availability of the auxiliary feedwater system, reactor coolant system pressure relief (pressurizer PORVs and safety valves), AMSAC (ATWS (Anticipated Transient Without Scram) Mitigating System Actuation Circuitry), or turbine trip should not be scheduled when a RTB is out of service.

Activities that could degrade other components of the RPS, including master relays or slave relays and activities that cause analog channels to be unavailable should not be scheduled when a logic cabinet is unavailable.

Activities on electrical systems that support the systems or functions listed in the first two bullets should not be scheduled when a RTB is unavailable.

Upon implementation 10 DEK commits to include in the USAR a requirement to maintain a 5% design margin for the batteries describing how this design margin is required to allow the use of a 2 amp float current value that is an indication that the battery is 95 percent charged. (Duplicated in Commitment 12 but included here for completeness.)

In accordance with 10 CFR 50.71(e) 11 DEK commits to incorporating the expected/qualified life of the safety related batteries in the battery monitoring program in the USAR.

In accordance with 10 CFR 50.71(e)

LIST OF REGULATORY COMMITMENTS 4 No. Commitment Due Date/Event 12 DEK commits to change or verify that the Kewaunee USAR describes:

1. The requirement to maintain a 5% design margin for the batteries describing how this design margin is required to allow the use of a 2 amp float current value as an indication that the battery is at least 95 percent charged.

2. The minimum established design limit for battery terminal float voltage.

3. The minimum established design limit for electrolyte level.

4. The minimum established design limit for electrolyte temperature.

5. The minimum requirements for the alternate means (i.e., spare battery charger) that is used to obtain an extended battery charger completion time (CT).

In accordance with 10 CFR 50.71(e) 13 DEK commits to change (or verify) procedure(s) to include the measuring and test equipment manufacturer's recommended practice for instrument stabilization whe n measuring float current to confirm battery state of charge.

Upon implementation 14 DEK commits to including vital switchgear and battery room temperature limits in the USAR.

In accordance with 10 CFR 50.71(e) 15 DEK has committed in the GL 20 08-01 letter to monitor the status of the industry/NRC Technical Specification Task Force (TSTF) Traveler to be developed as a follow

-up to GL 2008

-01. Following NRC approval of this TSTF, DEK will adopt applicable portions of the Traveler.

Following NRC approval of the TSTF, on a schedule consistent with the commitment made in the response to GL 2008

-01.