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| | number = ML12137A003 | | | number = ML12137A003 |
| | issue date = 05/15/2012 | | | issue date = 05/15/2012 |
| | title = 2012/05/15 NRR E-mail Capture - ME7110 Agenda for Draft RAI Clarification Call Re Wednesday 3-4 PM ET - Eicb Input | | | title = NRR E-mail Capture - ME7110 Agenda for Draft RAI Clarification Call Re Wednesday 3-4 PM ET - Eicb Input |
| | author name = Feintuch K | | | author name = Feintuch K |
| | author affiliation = NRC/NRR/DORL | | | author affiliation = NRC/NRR/DORL |
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| | page count = 5 | | | page count = 5 |
| | project = TAC:ME7110 | | | project = TAC:ME7110 |
| | stage = RAI | | | stage = Draft RAI |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:1NRR-PMDAPEm ResourceFrom:Feintuch, KarlSent:Tuesday, May 15, 2012 4:30 PMTo:'Craig D Sly'Cc:Alvarado, Rossnyev | | {{#Wiki_filter:NRR-PMDAPEm Resource From: Feintuch, Karl Sent: Tuesday, May 15, 2012 4:30 PM To: 'Craig D Sly' Cc: Alvarado, Rossnyev |
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| ==Subject:== | | ==Subject:== |
| ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET - EICB inputAttachments:ME7110-RAII 2nd round-EICB-Alva - 2012-05-15 Compliance with NUREG-0737 LAR.docxAttached is draft RAI set from Reviewer Alvarado. The request by date is 6/15/2012. If practical we would like to discuss at the meeting the information known at this time about the issues. | | ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET - EICB input Attachments: ME7110-RAII 2nd round-EICB-Alva - 2012-05-15 Compliance with NUREG-0737 LAR.docx Attached is draft RAI set from Reviewer Alvarado. The request by date is 6/15/2012. If practical we would like to discuss at the meeting the information known at this time about the issues. |
| I am currently preparing a draft set from the Containment and Ventilation Group (Reviewer Torres) | | I am currently preparing a draft set from the Containment and Ventilation Group (Reviewer Torres) |
| Karl Feintuch Hearing Identifier: NRR_PMDA Email Number: 375 Mail Envelope Properties (26E42474DB238C408C94990815A02F097B32B81C61) | | Karl Feintuch 1 |
| | |
| | Hearing Identifier: NRR_PMDA Email Number: 375 Mail Envelope Properties (26E42474DB238C408C94990815A02F097B32B81C61) |
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| ==Subject:== | | ==Subject:== |
| ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET - EICB input Sent Date: 5/15/2012 4:29:57 PM Received Date: 5/15/2012 4:29:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients: "Alvarado, Rossnyev" <Rossnyev.Alvarado@nrc.gov> Tracking Status: None | | ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET - EICB input Sent Date: 5/15/2012 4:29:57 PM Received Date: 5/15/2012 4:29:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients: |
| "'Craig D Sly'" <craig.d.sly@dom.com> Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 321 5/15/2012 4:29:00 PM ME7110-RAII 2nd round-EICB-Alva - 2012-05-15 Compliance with NUREG-0737 LAR.docx 31844 | | "Alvarado, Rossnyev" <Rossnyev.Alvarado@nrc.gov> |
| | Tracking Status: None |
| | "'Craig D Sly'" <craig.d.sly@dom.com> |
| | Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 321 5/15/2012 4:29:00 PM ME7110-RAII 2nd round-EICB-Alva - 2012-05-15 Compliance with NUREG-0737 LAR.docx 31844 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: |
| | Recipients Received: |
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| Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:
| | Items to Discuss During Conference Call Re: EICB Second Round set of draft RAI Questions: |
| 1 Items to Discuss During Conference Call Re: EICB Second Round set of draft RAI Questions:
| |
| * ME7110-RAII-EICB-Alva-008-2012-06-15 | | * ME7110-RAII-EICB-Alva-008-2012-06-15 |
| * ME7110-RAII-EICB-Alva-008-2012-06-15 | | * ME7110-RAII-EICB-Alva-008-2012-06-15 |
| : 1. Follow up to ME7110-RAII-EICB-Alva-002-2011-12-29 is assigned tracking number ME7110-RAII-EICB-Alva-008-2012-06-15 | | : 1. Follow up to ME7110-RAII-EICB-Alva-002-2011-12-29 is assigned tracking number ME7110-RAII-EICB-Alva-008-2012-06-15 |
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| ==Background:== | | ==Background:== |
| NUREG-0737, "Clarification of TMI Action Plan Requirements," Item III.D.3.4, "Control Room Habitability Requirements," required licensees to assure that control room operators will be adequately protected against the effects of accidental release of toxic and radioactive gas and that the plant can be safely operated or shutdown under design basis accident conditions. Currently, Dominion Energy Kewaunee (DEK)'s Kewaunee Power Station uses either a safety injection (SI) signal or high radiation detection (R-23) to automatically isolate the control room and start 100 percent recirculation (CRPAR). R-23 continuously monitors the Control Room environment for an indication of airborne activity (radiation) entering through the Control Room ventilation system. If R-23 senses a high radiation condition, the monitor initiates closure of the outside air intake, provides a signal that isolates the control room ventilation system and starts the control room post-accident recirculation system. R-23 in conjunction with other radiation monitor demonstrates compliance with NUREG-0737. | | |
| R-23 is credited in the current Radiation Accident Analysis (RAA) for mitigating the consequences of an accident. Based on 10 CFR 50.36 criteria, Technical Specification (TS) actions and surveillance requirements for R-23 should be included in Kewaunee's TS. The LAR-244 proposes removing radiation monitor channel R-23 from TS to the Kewaunee's Technical Requirements Manual (TRM). DEK is proposing to credit manual actuation of SI to isolate the control room and start CRPAR. Justifications for relocating R-23 to the TRM are: | | NUREG-0737, Clarification of TMI Action Plan Requirements, Item III.D.3.4, Control Room Habitability Requirements, required licensees to assure that control room operators will be adequately protected against the effects of accidental release of toxic and radioactive gas and that the plant can be safely operated or shutdown under design basis accident conditions. |
| | Currently, Dominion Energy Kewaunee (DEK)s Kewaunee Power Station uses either a safety injection (SI) signal or high radiation detection (R-23) to automatically isolate the control room and start 100 percent recirculation (CRPAR). R-23 continuously monitors the Control Room environment for an indication of airborne activity (radiation) entering through the Control Room ventilation system. If R-23 senses a high radiation condition, the monitor initiates closure of the outside air intake, provides a signal that isolates the control room ventilation system and starts the control room post-accident recirculation system. R-23 in conjunction with other radiation monitor demonstrates compliance with NUREG-0737. |
| | R-23 is credited in the current Radiation Accident Analysis (RAA) for mitigating the consequences of an accident. Based on 10 CFR 50.36 criteria, Technical Specification (TS) actions and surveillance requirements for R-23 should be included in Kewaunees TS. |
| | The LAR-244 proposes removing radiation monitor channel R-23 from TS to the Kewaunees Technical Requirements Manual (TRM). DEK is proposing to credit manual actuation of SI to isolate the control room and start CRPAR. Justifications for relocating R-23 to the TRM are: |
| * Radiation monitor R-23 is not safety grade | | * Radiation monitor R-23 is not safety grade |
| * R-23 is a single radiation monitor | | * R-23 is a single radiation monitor |
| * R-23 is a partial signal that will not close all control room inlet and outlet ventilation EICB Question (ME7110-RAII-EICB-Alva-002-2011-12-29) - If R-23 is removed from TS, how will DEK comply with NUREG-0737, Item III.D.3.4? NUREG-0737 requires safety grade radioactivity monitors required for automatic isolation purpose. SRP 6.4 habitability systems, Section 2.0, item B states that: "Single failure of an active component should not result in loss of the system's functional performance. All the components of the control room emergency filter train should be considered active components." Even though DEK recognized inconsistency with these requirements, DEK justified use of a single radioactivity monitor installed in the control room HVAC system air supply. This was justified because the automatic isolation function is accomplished by actuation 2 of safety injection or high radiation in the control room air supply. These signals are diverse and provide adequate protection. Further, in 1983 Kewaunee performed an analysis to show how the control room would be isolated during design basis accidents (DBA) if R-23 fails. In this analysis, KDE explained that failure of R-23 would cause an alarm in the control room alerting the control operators of loss of its function, and other radiation monitors (R-1 and R-5) will detect and confirm the presence of unusual levels of radiation at the radiation monitoring panel located in the control room, or a control room ventilation system isolation signal would occur, such that the single monitor in the air intake would never be the sole means of isolating that system. However, R1 and R-5 only warns operators to the presence of an abnormal condition. Thus, the operator would have to manually isolate the control room. The NRC's safety evaluation (SE) for NUREG-0737 found that the control room habitability system were acceptable and would provide a safe, habitable environment under DBA radiation and toxic gas conditions. In this SE, the staff stated that for radiation monitor, a radiation monitor in addition to R-23 should alarm in the control room or a control room ventilation system isolation signal would occur, such that the single monitor in the air intake would never be the sole means of isolating that system. High radiation signal detected by R-23 and SI signal would initiate the CRPAR system LAR-244 is proposing relocating R-23 from TS to TRM. R-23 would remain part of the control room isolation logic and control room post-accident recirculation system (CRPAR), providing defense-in-depth for the control room isolation function. LAR-244 and RAI response received on January 25, 2012 justified relocating R-23 based on a revised RAA without crediting the isolation function provided by R-23. DEK is proposing to credit operator actions to isolate the control room or a SI signal to perform isolation of the control room. DEK states that this is sufficient to meet the requirements in NUREG-0737. Further, if R-23 is not credited in the revised RAA, R-23 won't meet the criteria in 10 CFR 50.36 to remain in TS Based on this information, the NRC staff has the following follow up question: ME7110-RAII-EICB-Alva-008-2012-06-15 a) If an SI signal is not actuated and there is a radiation release, how will DEK meet the NUREG-0737 requirement for automatic isolation capability? b) The basis to TS 3.12 indicates that the recirculation filter system is designed to automatically start on a safety injection signal or a high radiation signal. How will the design of the recirculation filter system be modified if R-23 is relocated to TRM? c) The current design considers the safety injection signal providing a diverse means of post-accident actuation for R-23. If R-23 is relocated to the TRM, what component will provide diverse means for the SI signal? | | * R-23 is a partial signal that will not close all control room inlet and outlet ventilation EICB Question (ME7110-RAII-EICB-Alva-002-2011-12-29) - If R-23 is removed from TS, how will DEK comply with NUREG-0737, Item III.D.3.4? |
| 3 2. Radiation monitor use for incoming fresh air (New Question): ME7110-RAII-EICB-Alva-009-2012-06-15
| | NUREG-0737 requires safety grade radioactivity monitors required for automatic isolation purpose. SRP 6.4 habitability systems, Section 2.0, item B states that: Single failure of an active component should not result in loss of the system's functional performance. All the components of the control room emergency filter train should be considered active components. Even though DEK recognized inconsistency with these requirements, DEK justified use of a single radioactivity monitor installed in the control room HVAC system air supply. This was justified because the automatic isolation function is accomplished by actuation 1 |
| | |
| | of safety injection or high radiation in the control room air supply. These signals are diverse and provide adequate protection. |
| | Further, in 1983 Kewaunee performed an analysis to show how the control room would be isolated during design basis accidents (DBA) if R-23 fails. In this analysis, KDE explained that failure of R-23 would cause an alarm in the control room alerting the control operators of loss of its function, and other radiation monitors (R-1 and R-5) will detect and confirm the presence of unusual levels of radiation at the radiation monitoring panel located in the control room, or a control room ventilation system isolation signal would occur, such that the single monitor in the air intake would never be the sole means of isolating that system. However, R1 and R-5 only warns operators to the presence of an abnormal condition. Thus, the operator would have to manually isolate the control room. |
| | The NRCs safety evaluation (SE) for NUREG-0737 found that the control room habitability system were acceptable and would provide a safe, habitable environment under DBA radiation and toxic gas conditions. In this SE, the staff stated that for radiation monitor, a radiation monitor in addition to R-23 should alarm in the control room or a control room ventilation system isolation signal would occur, such that the single monitor in the air intake would never be the sole means of isolating that system. High radiation signal detected by R-23 and SI signal would initiate the CRPAR system LAR-244 is proposing relocating R-23 from TS to TRM. R-23 would remain part of the control room isolation logic and control room post-accident recirculation system (CRPAR), providing defense-in-depth for the control room isolation function. |
| | LAR-244 and RAI response received on January 25, 2012 justified relocating R-23 based on a revised RAA without crediting the isolation function provided by R-23. DEK is proposing to credit operator actions to isolate the control room or a SI signal to perform isolation of the control room. DEK states that this is sufficient to meet the requirements in NUREG-0737. |
| | Further, if R-23 is not credited in the revised RAA, R-23 wont meet the criteria in 10 CFR 50.36 to remain in TS Based on this information, the NRC staff has the following follow up question: |
| | ME7110-RAII-EICB-Alva-008-2012-06-15 a) If an SI signal is not actuated and there is a radiation release, how will DEK meet the NUREG-0737 requirement for automatic isolation capability? |
| | b) The basis to TS 3.12 indicates that the recirculation filter system is designed to automatically start on a safety injection signal or a high radiation signal. How will the design of the recirculation filter system be modified if R-23 is relocated to TRM? |
| | c) The current design considers the safety injection signal providing a diverse means of post-accident actuation for R-23. If R-23 is relocated to the TRM, what component will provide diverse means for the SI signal? |
| | 2 |
| | : 2. Radiation monitor use for incoming fresh air (New Question): |
| | ME7110-RAII-EICB-Alva-009-2012-06-15 |
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| ==Background:== | | ==Background:== |
| KPS UFSAR Rev 23, page 9.6-12 states: The operator can add fresh air to the Control Room under post-accident conditions by first verifying that conditions at the intake plenum will not cause contamination of the Control Room atmosphere, then manually opening the selected outside air damper and the damper at the suction of the post-accident recirculation fans. Excess air is exhausted to the Turbine Room through a backdraft damper. The operator can confirm the incoming fresh/recirculation air mix is not contaminating the Control Room atmosphere by observing a radiation monitor channel in the Control Room. Damper control switches are spring return to the normal position so that when the damper control switches are released the dampers automatically return to the recirculation configuration. ME7110-RAII-EICB-Alva-009-2012-06-15 Since this is an isolation design, the control room needs to supplement the breathable air after a week to 10 days to keep the air habitable. Please explain if the radiation monitor credited in the UFSAR for fresh air is R-23. | | |
| }} | | KPS UFSAR Rev 23, page 9.6-12 states: |
| | The operator can add fresh air to the Control Room under post-accident conditions by first verifying that conditions at the intake plenum will not cause contamination of the Control Room atmosphere, then manually opening the selected outside air damper and the damper at the suction of the post-accident recirculation fans. Excess air is exhausted to the Turbine Room through a backdraft damper. The operator can confirm the incoming fresh/recirculation air mix is not contaminating the Control Room atmosphere by observing a radiation monitor channel in the Control Room. Damper control switches are spring return to the normal position so that when the damper control switches are released the dampers automatically return to the recirculation configuration. |
| | ME7110-RAII-EICB-Alva-009-2012-06-15 Since this is an isolation design, the control room needs to supplement the breathable air after a week to 10 days to keep the air habitable. Please explain if the radiation monitor credited in the UFSAR for fresh air is R-23. |
| | 3}} |
Letter Sequence Draft RAI |
|---|
TAC:ME7110, Control Room Habitability, Administratively Control Containment Penetrations, Deletion of E BAR Definition and Revision to RCS Specific Activity Tech Spec, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Open) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance
|
MONTHYEARML11222A1232011-07-25025 July 2011
License Amendment Request 244: Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Request
ML11252A5212011-08-30030 August 2011
License Amendment Request 244: Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Request
ML11252A6532011-08-30030 August 2011
License Amendment Request 244, Marked-Up Operating License and Technical Specifications Pages, Attachment 2
Project stage: Request
ML11252A6542011-08-30030 August 2011
License Amendment Request 244, Marked-Up Operating Technical Specifications Bases Pages, Attachment 3
Project stage: Request
ML11252A6562011-08-30030 August 2011
License Amendment Request 244, Radiological Accident Analysis and Discussion of Associated Technical Specification Changes, Attachment 4
Project stage: Request
ML11252A6572011-08-30030 August 2011
License Amendment Request 244, Evaluation of New Proposed Manual Actions, Attachment 5
Project stage: Request
ML11252A6582011-08-30030 August 2011
License Amendment Request 244, Data Files, Kewaunee Power Station Meterological Data 2002-2006 X/Q Calculation Support, Enclosure 1
Project stage: Request
ML11252A6512011-08-30030 August 2011
License Amendment Request 244, Discussion of Change, Safety Evaluation, Significant Hazards Determination and Environmental Considerations, Attachment 1
Project stage: Request
ML11290A1482011-10-17017 October 2011
NRR E-mail Capture - ME7110 - Chi-over-Q Amendment Application - Non-acceptance with Opportunity to Supplement
Project stage: Other
ML11298A2652011-10-25025 October 2011
NRR E-mail Capture - FW: ME7110 - Kewaunee Chi-over-Q - Acceptance Review RAL Items - Conference Calls of October 20, 25, 2011
Project stage: Acceptance Review
ML11304A1462011-10-27027 October 2011
NRR E-mail Capture - FW: ME7110 - Kewaunee Chi-over-Q - Acceptance Review RAL Items - Conference Calls of October 20, 25, 26, 2011
Project stage: Acceptance Review
ML11318A2052011-11-0808 November 2011
Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML11325A0782011-11-18018 November 2011
NRR E-mail Capture - ME7110 - Kewaunee - LIC-109 Acceptance Review Results for Chi-over-Q License Amendment Request
Project stage: Acceptance Review
ML11339A0012011-12-0101 December 2011
NRR E-mail Capture - ME7110 Kewaunee Amendment Request Re_ Chi-over-Q - Eicb Request for Additional Information (RAI)
Project stage: RAI
ML12023A0472012-01-0909 January 2012
NRR E-mail Capture - ME7110 Kewaunee Amendment Request Re_ Chi-over-Q - Ahpb Request for Additional Information (RAI)
Project stage: RAI
ML12023A0572012-01-13013 January 2012
NRR E-mail Capture - ME7110 Kewaunee Amendment Request Re_ Chi-over-Q - Ahpb Request for Additional Information (RAI) - Firm RAI Items
Project stage: RAI
ML12031A1382012-01-25025 January 2012
Response to Request for Additional Information on License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12033A0102012-01-30030 January 2012
NRR E-mail Capture - ME7110 Kewaunee Amendment Request Chi-over-Q - Rsxb Request for Additional Information (RAI)
Project stage: RAI
ML12068A1422012-02-27027 February 2012
Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12066A0082012-03-0202 March 2012
NRR E-mail Capture - ME7110 Kewaunee Amendment Request- Chi-over-Q - Aadb Request for Additional
Project stage: Other
ML12068A4202012-03-0606 March 2012
E-mail Capture - ME7110 Record of Clarification Conference Call for ME7110 Kewaunee Amendment Request Re_ Chi-over-Q - Aadb Request for Additional Information (RAI)
Project stage: RAI
ML12080A2232012-03-12012 March 2012
Response to Request for Additional Information: License Amendment Request 244. Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12107A1442012-04-13013 April 2012
NRR E-mail Capture - ME7110 Kewaunee - Request for Additional Information (RAI) Aadb and Scvb 2012-04-12
Project stage: RAI
ML12124A2832012-04-30030 April 2012
Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12138A0072012-05-15015 May 2012
NRR E-mail Capture - ME7110 Scvb Draft RAI Set Adoption of TSTF-51 & TSTF- 448, as Part of Chi-over-Q Action
Project stage: Draft RAI
ML12137A0032012-05-15015 May 2012
NRR E-mail Capture - ME7110 Agenda for Draft RAI Clarification Call Re Wednesday 3-4 PM ET - Eicb Input
Project stage: Draft RAI
ML12164A3742012-06-0606 June 2012
Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12166A0062012-06-13013 June 2012
NRR E-mail Capture - ME7110 - Kewaunee - Chi-Over-Q - Record of Conference Call - Wednesday, June 13, 2012 3:00 PM
Project stage: Other
ML12193A6832012-06-19019 June 2012
NRR E-mail Capture - ME7110- Kewaunee LAR 244: Executive Summary of LRA Emergent Issue - Further Information - Generic Implications for Otherv Plants
Project stage: Other
ML12193A6842012-07-11011 July 2012
NRR E-mail Capture - Record of ME7110 - Kewaunee - Chi-Over-Q - Progress Review (Dated Wed 7/11/2012 3:00 PM - 4:00 PM from Outlook Invitation)
Project stage: Other
ML12219A2222012-08-0303 August 2012
Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12226A5062012-08-0909 August 2012
Response to Request for Additional Information: License Amendment Request 244. Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Response to RAI
ML12236A2062012-08-22022 August 2012
NRR E-mail Capture - FW: ME7110- Kewaunee LAR 244: Executive Summary of LRA Emergent Issue - Further Information - Generic Implications for Other Plants
Project stage: Other
ML12248A1492012-08-29029 August 2012
Submittal of Revision to Locked Rotor Radiological Accident Analysis: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications
Project stage: Request
ML12285A1572012-10-10010 October 2012
NRR E-mail Capture - ME7110 - Kewaunee - Chi-over-Q - Request for Additional Information (RAI)
Project stage: RAI
2012-02-27
[Table View] |
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Category:E-Mail
MONTHYEARML24030A0672024-01-26026 January 2024
Email EA Fonsi Notice to Kewaunee Solutions for Exemptions on Site Restoration Activities
ML23268A4362023-09-21021 September 2023
Extension Date Approval for Request for Additional Information for Exemptions on Site Restoration Activities
ML23134A0012023-05-0909 May 2023
NRC Email Acceptance - Kewaunee Solutions Exemption Request Regarding Decommissioning Trust Funds for Site Restoration Activities (Docket No. 50-305)
ML23129A0672023-05-0505 May 2023
NRC Email Acceptance - Kewaunee Solutions Exemption Request for Low-Level Radioactive Waste Transport Change from 20 to 45 Days Acknowledgement
ML23100A0032023-04-0404 April 2023
Solutions - Acknowledgement Email Regarding Exemption Regarding Decommissioning Trust Funds for Site Restoration Activities (Docket No 50-305)
ML23094A1442023-03-31031 March 2023
Solutions - Acknowledgement Email Regarding Exemption for Low-Level Radioactive Waste Transport within 20 Days (Docket No. 50-305)
ML22108A1762022-04-14014 April 2022
E-mail: Proposed Order Conditions for In-Direct Transfer of Licenses Held by Energysolutions, LLC (Zion, TMI Unit-2, La Crosse Boiling Water Reactor, Kewaunee, Energysolutions Radioactive Materials License, and Energysolutions Export Licens
ML22053A2992022-02-18018 February 2022
Email - Additional Time for Request for Additional Information Response Regarding Kewaunee Solutions Decommissioning Quality Assurance Program; NRC Response Included; (EPID L-2021-LLO-0002 and L-2021-DP3-0000)
ML22027A3642022-01-26026 January 2022
KPS: CY2022 Inspection Plan, Docket No. 05000305, License No. DPR-43
ML22007A3182022-01-0707 January 2022
E-mail from C. Adams, State of Wisconsin, to K. Sturzebecher, NRC, Notification and Request Kewaunee Power Station License Transfer (L-2021-LLO-002)
ML21348A0522021-12-0303 December 2021
E-mail to P. Schmidt, State of Wisconsin, from K. Sturzebecher, NRC - Notification and Request Kewaunee Power Station License Transfer
ML21096A1332021-04-0606 April 2021
E-mail for Approval of Proprietary Withholding for Dominion Energy Exemptions for the Magnastor Storage Cask
ML20015A3002020-01-14014 January 2020
KPS: CY2020 Master Inspection Plan
ML19130A2082019-05-0808 May 2019
Email - NRC Email to FEMA Dated May 8, 2019: NRC Response to Comment on FEMA Review of Proposed Changes to DBNPS Emergency Plan for Permanently Defueled Condition
ML19072A0652019-03-0606 March 2019
Conversation Record with T. Szymanski/Dominion Energy Response to 10 CFR 72.30(c)(3) in Triennial Update for Kewaunee
ML19070A2642019-03-0505 March 2019
Email Conversation with T. Szymanski/Dominion Energy Decommissioning Funding Plan (Dfp): Kewaunee
ML18351A2742018-12-17017 December 2018
KPS: CY2019 Master Inspection Plan
ML17354A9382017-12-20020 December 2017
CY2018 Master Inspection Plan
ML17156A0032017-06-0202 June 2017
NRR E-mail Capture - Acceptance for Review of Revision 24 to the Dominion Nuclear Facility Quality Assurance Program Description (QAPD) Topical Report (CAC Nos. MF9732-MF9739)
ML17040A0222016-10-18018 October 2016
Wisconsin State Notification (LAR259-L53082)
ML16287A7142016-10-13013 October 2016
E-mail - Request for Additional Information: Dominion Energy Kewaunee, Dominion Nuclear Connecticut and Virginia Electric Power Company Nuclear Facility Quality Assurance Program Description Topical Report
ML16041A2732016-02-10010 February 2016
Final RAIs Regarding LAR 259
ML16054A2382015-10-14014 October 2015
E-44108 Attachment 8 E-mail from Stewart J. Yuen (Kewaunee Power Station) to Don Shaw (Areva) for Kewaunee Power Station
ML15090A4872015-03-26026 March 2015
OEDO-15-00251 - Michael Mulligan, Citizen Ltr 2.206 - Emergency Ultrasonic Inspection Test or Best Available Flaw Detection Technology for USA Reactor Plants Similar to the Thousands of Cracks Discovered in Belgium Nuclear Power Plants
ML15071A2752015-03-12012 March 2015
NRR E-mail Capture - Request for Additional Information on Kewaunee 50.54(p) Changes to Physical Security Plan - TAC MF5779
ML15057A2192015-02-25025 February 2015
NRR E-mail Capture - Acceptance Review: Dominion Fleet-Request for Approval of Cyber Security Plan (CSP) Revised Implementation Schedule
ML14258A7432014-09-0505 September 2014
NRR E-mail Capture - FW: Comparison of Crystal River'S Exemption Secy Paper with Kewaunee'S
ML14251A0972014-08-22022 August 2014
NRR E-mail Capture - Draft RAI to Kewaunee Power Station on Control Room Staffing Issue
ML14164A0742014-06-0202 June 2014
NRR E-mail Capture - Draft Request for Additional Information Concerning Dek'S Request for Exemption from Conducting Annual Force-on-Force Exercises at Kewaunee Power Station
ML14132A2062014-04-27027 April 2014
NRR E-mail Capture - Kewaunee Amendment Request for Emergency Plan Changes MF3411 - Draft RAIs
ML14155A0402014-04-0707 April 2014
NRR E-mail Capture - Summarry of Kewaunee Mitigation Strategy Phone Call Last Week
ML14134A5872014-04-0707 April 2014
NRR E-mail Capture - Minor Editorial/Typographical Changes to License Condition TAC MF1771)
ML14097A5112014-04-0101 April 2014
NRR E-mail Capture - Draft RAI Related to Kewaunee Proposed Deletion of License Condition on Mitigation Strategy
ML14069A3832014-03-0606 March 2014
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ML13312A2422013-11-0707 November 2013
NRR E-mail Capture - MF1952-RAII-SRXB-Cunana-002-2011-11-08, Request for Additional Information
ML13297A0482013-10-23023 October 2013
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ML13295A5672013-10-22022 October 2013
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ML13275A0772013-10-0101 October 2013
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ML13275A0722013-10-0101 October 2013
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ML13275A0622013-09-27027 September 2013
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ML13246A0032013-08-30030 August 2013
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ML13218B3722013-08-0606 August 2013
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ML13151A2452013-05-29029 May 2013
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2024-01-26
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Text
NRR-PMDAPEm Resource From: Feintuch, Karl Sent: Tuesday, May 15, 2012 4:30 PM To: 'Craig D Sly' Cc: Alvarado, Rossnyev
Subject:
ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET - EICB input Attachments: ME7110-RAII 2nd round-EICB-Alva - 2012-05-15 Compliance with NUREG-0737 LAR.docx Attached is draft RAI set from Reviewer Alvarado. The request by date is 6/15/2012. If practical we would like to discuss at the meeting the information known at this time about the issues.
I am currently preparing a draft set from the Containment and Ventilation Group (Reviewer Torres)
Karl Feintuch 1
Hearing Identifier: NRR_PMDA Email Number: 375 Mail Envelope Properties (26E42474DB238C408C94990815A02F097B32B81C61)
Subject:
ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET - EICB input Sent Date: 5/15/2012 4:29:57 PM Received Date: 5/15/2012 4:29:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients:
"Alvarado, Rossnyev" <Rossnyev.Alvarado@nrc.gov>
Tracking Status: None
"'Craig D Sly'" <craig.d.sly@dom.com>
Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 321 5/15/2012 4:29:00 PM ME7110-RAII 2nd round-EICB-Alva - 2012-05-15 Compliance with NUREG-0737 LAR.docx 31844 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Items to Discuss During Conference Call Re: EICB Second Round set of draft RAI Questions:
- ME7110-RAII-EICB-Alva-008-2012-06-15
- ME7110-RAII-EICB-Alva-008-2012-06-15
- 1. Follow up to ME7110-RAII-EICB-Alva-002-2011-12-29 is assigned tracking number ME7110-RAII-EICB-Alva-008-2012-06-15
Background:
NUREG-0737, Clarification of TMI Action Plan Requirements, Item III.D.3.4, Control Room Habitability Requirements, required licensees to assure that control room operators will be adequately protected against the effects of accidental release of toxic and radioactive gas and that the plant can be safely operated or shutdown under design basis accident conditions.
Currently, Dominion Energy Kewaunee (DEK)s Kewaunee Power Station uses either a safety injection (SI) signal or high radiation detection (R-23) to automatically isolate the control room and start 100 percent recirculation (CRPAR). R-23 continuously monitors the Control Room environment for an indication of airborne activity (radiation) entering through the Control Room ventilation system. If R-23 senses a high radiation condition, the monitor initiates closure of the outside air intake, provides a signal that isolates the control room ventilation system and starts the control room post-accident recirculation system. R-23 in conjunction with other radiation monitor demonstrates compliance with NUREG-0737.
R-23 is credited in the current Radiation Accident Analysis (RAA) for mitigating the consequences of an accident. Based on 10 CFR 50.36 criteria, Technical Specification (TS) actions and surveillance requirements for R-23 should be included in Kewaunees TS.
The LAR-244 proposes removing radiation monitor channel R-23 from TS to the Kewaunees Technical Requirements Manual (TRM). DEK is proposing to credit manual actuation of SI to isolate the control room and start CRPAR. Justifications for relocating R-23 to the TRM are:
- Radiation monitor R-23 is not safety grade
- R-23 is a single radiation monitor
- R-23 is a partial signal that will not close all control room inlet and outlet ventilation EICB Question (ME7110-RAII-EICB-Alva-002-2011-12-29) - If R-23 is removed from TS, how will DEK comply with NUREG-0737, Item III.D.3.4?
NUREG-0737 requires safety grade radioactivity monitors required for automatic isolation purpose. SRP 6.4 habitability systems, Section 2.0, item B states that: Single failure of an active component should not result in loss of the system's functional performance. All the components of the control room emergency filter train should be considered active components. Even though DEK recognized inconsistency with these requirements, DEK justified use of a single radioactivity monitor installed in the control room HVAC system air supply. This was justified because the automatic isolation function is accomplished by actuation 1
of safety injection or high radiation in the control room air supply. These signals are diverse and provide adequate protection.
Further, in 1983 Kewaunee performed an analysis to show how the control room would be isolated during design basis accidents (DBA) if R-23 fails. In this analysis, KDE explained that failure of R-23 would cause an alarm in the control room alerting the control operators of loss of its function, and other radiation monitors (R-1 and R-5) will detect and confirm the presence of unusual levels of radiation at the radiation monitoring panel located in the control room, or a control room ventilation system isolation signal would occur, such that the single monitor in the air intake would never be the sole means of isolating that system. However, R1 and R-5 only warns operators to the presence of an abnormal condition. Thus, the operator would have to manually isolate the control room.
The NRCs safety evaluation (SE) for NUREG-0737 found that the control room habitability system were acceptable and would provide a safe, habitable environment under DBA radiation and toxic gas conditions. In this SE, the staff stated that for radiation monitor, a radiation monitor in addition to R-23 should alarm in the control room or a control room ventilation system isolation signal would occur, such that the single monitor in the air intake would never be the sole means of isolating that system. High radiation signal detected by R-23 and SI signal would initiate the CRPAR system LAR-244 is proposing relocating R-23 from TS to TRM. R-23 would remain part of the control room isolation logic and control room post-accident recirculation system (CRPAR), providing defense-in-depth for the control room isolation function.
LAR-244 and RAI response received on January 25, 2012 justified relocating R-23 based on a revised RAA without crediting the isolation function provided by R-23. DEK is proposing to credit operator actions to isolate the control room or a SI signal to perform isolation of the control room. DEK states that this is sufficient to meet the requirements in NUREG-0737.
Further, if R-23 is not credited in the revised RAA, R-23 wont meet the criteria in 10 CFR 50.36 to remain in TS Based on this information, the NRC staff has the following follow up question:
ME7110-RAII-EICB-Alva-008-2012-06-15 a) If an SI signal is not actuated and there is a radiation release, how will DEK meet the NUREG-0737 requirement for automatic isolation capability?
b) The basis to TS 3.12 indicates that the recirculation filter system is designed to automatically start on a safety injection signal or a high radiation signal. How will the design of the recirculation filter system be modified if R-23 is relocated to TRM?
c) The current design considers the safety injection signal providing a diverse means of post-accident actuation for R-23. If R-23 is relocated to the TRM, what component will provide diverse means for the SI signal?
2
- 2. Radiation monitor use for incoming fresh air (New Question):
ME7110-RAII-EICB-Alva-009-2012-06-15
Background:
KPS UFSAR Rev 23, page 9.6-12 states:
The operator can add fresh air to the Control Room under post-accident conditions by first verifying that conditions at the intake plenum will not cause contamination of the Control Room atmosphere, then manually opening the selected outside air damper and the damper at the suction of the post-accident recirculation fans. Excess air is exhausted to the Turbine Room through a backdraft damper. The operator can confirm the incoming fresh/recirculation air mix is not contaminating the Control Room atmosphere by observing a radiation monitor channel in the Control Room. Damper control switches are spring return to the normal position so that when the damper control switches are released the dampers automatically return to the recirculation configuration.
ME7110-RAII-EICB-Alva-009-2012-06-15 Since this is an isolation design, the control room needs to supplement the breathable air after a week to 10 days to keep the air habitable. Please explain if the radiation monitor credited in the UFSAR for fresh air is R-23.
3
