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Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8)
	ML102371294
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: ML102371294 (0)
	v • d • e

{{#Wiki_filter:Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 1 of 90 ITS NRC Questions Id 2141 NRC Question MEH-009 Number Category Technical ITS Section 3.7 ITS Number 3.7.8 DOC Number JFD Number 6 JFD Bases 6 Number Page Number(s) NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N Requested NRC The May 12, 2010 supplement to the TS Conversion LAR proposed the Question addition of the word necessarily to the note in SR 3.7.8.1. The staff believes the proposed addition is contrary to TS usage convention because inserting the word would allow intentional entry into LCO 3.7.8 ACTIONS for operational convenience. The Bases for LCO 3.0.2 specifically state: Intentional entry into ACTIONS should not be made for operational convenience. The supplement stated that the reason for the proposed request is related to Area Fan Cooler Units and minimum Completion Times in Conditions of ITS 3.8.7 and 3.8.9. The staff believes that issues with such completion times should be addressed by proposing and justifying different Completion Times, not changing TS usage convention. If desired, please propose and justify different Completion Times for the affected Conditions of ITS 3.8.7 and 3.8.9. Attach File 1 Attach File 2 Issue Date 6/8/2010 Added By Matthew Hamm Date Modified Modified By Date Added 6/8/2010 7:47 AM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 1 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2141 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 2 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3611 NRC Question MEH-009 Number Select Licensee Response Application

Response

6/21/2010 4:10 PM Date/Time Closure Statement Response In the first paragraph of the NRC question, the NRC reviewer states that the Statement staff believes that inserting the word "necessarily" into the SR Note would allow intentional entry into LCO 3.7.8 ACTIONS for operational convenience. The NRC question further states that LCO 3.0.2 Bases specifically states that intentional entry into ACTIONS should not be made for operational convenience. While KPS concurs that the LCO 3.0.2, through the Bases, prohibits intentional entry into ACTIONS for operational convenience, KPS does not agree that performing routine preventive and corrective maintenance is operational convenience. The ITS 3.0.2 Bases also states that "The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems" (italics added for emphasis). Thus, LCO 3.0.2 does allow intentional entry into ACTIONS to perform preventive and corrective maintenance, which is the purpose of the proposed KPS Note change. Therefore, the proposed Note change is not contrary to the ITS usage convention. However, KPS has reviewed the NRC request to include the Completion Times in each affected Specification. Based on this review, the previous Note change to ITS 3.7.8 is withdrawn (reference - Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "License Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications (TAC NO. ME02467) - Request to Change Proposed Service water and Main Steam Isolation Valve Specifications," dated May 12, 2010 [ADAMS Accession No. ML101380399]) and a new Note has been added to ITS 3.8.4, ITS 3.8.7, and ITS 3.8.9 to essentially allow a 24 hour time to restore a non-functional room cooler that affects the DC electrical power subsystems, inverters, or electrical power distribution subsystems. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment. Question Closure Date Attachment Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 2 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3611 06/25/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 3 of 90 1 MEH-009 Markup.pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 6/21/2010 4:26 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 3 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3611 06/25/2010

Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 4 of 90 ITS ITS 3.8.4 L02 Add proposed ACTIONS Note ACTION C b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours. M01 and MODE 5 in 36 hours

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

See ITS 3.8.1

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either:

A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel M02 generator. DC electrical power subsystem 2 ACTION B 3. One battery may be inoperable for a period not exceeding 24 hours provided the L01 other battery and two battery chargers remain OPERABLE with one charger carrying the d-c supply system. Add proposed ACTION A L01

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE.

See ITS 3.8.1

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for See ITS 3.8.9 24 hours provided the redundant bus and its loads remain OPERABLE.

7. Two diesel generators may be inoperable for 2 hours.

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the See ITS requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: 3.8.1

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 M03 Amendment No. 194 TS 3.7-2 02/07/2008 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 4 of 90 Page 2 of 2

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 5 of 90 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING associated charger is inoperable) are being applied in the ITS than were applied in the CTS. INSERT DOC L02 Kewaunee Power Station Page 5 of 5 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 5 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 6 of 90 L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when a DC source is inoperable. ITS 3.8.4 also provides ACTIONS, but includes a Note that allows a DC electrical power subsystem to be inoperable for up to 24 hours solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the other DC electrical power subsystem is OPERABLE. This changes the CTS by allowing a 24 hour deferral in entering associated ACTIONS when a DC electrical power subsystem is inoperable solely due to a room cooler being non-functional. The purpose of the CTS 3.7.b and ITS 3.8.4 ACTIONS is to adequately control how long a DC electrical power subsystem can be inoperable. The change allows an additional 24 hours if the inoperability of the DC electrical power subsystem is due to a room cooler being non-functional, and provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the DC electrical power subsystems. This change is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS. Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 6 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 7 of 90 CTS All changes are 1 DC Sources - Operating 3.8.4 unless otherwise noted 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating 3.7.a.6 LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE. 3.7.a APPLICABILITY: MODES 1, 2, 3, and 4.

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

When a DC electrical power subsystem is inoperable solely due to the room cooler being non-functional, entry into associated ACTIONS may be delayed 6 for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the other DC electrical power subsystem is OPERABLE. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required 2 DOC L01 A. One [or two] battery A.1 Restore battery terminal 2 hours charger[s on one train] voltage to greater than or inoperable. equal to the minimum established float voltage. AND A.2 Verify battery float current Once per [12] hours

                                                                          [2] amps.

AND A.3 Restore battery charger[s] 7 days 72 hours 4 to OPERABLE status. [B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ] 3 on one train] inoperable. OPERABLE status. B B 3 3.7.b.3 C. One DC electrical power C.1 Restore DC electrical [2] hours subsystem inoperable power subsystem to for reasons other than OPERABLE status. Condition A [or B]. C 3.7.b D. Required Action and D.1 Be in MODE 3. 6 hours Associated Completion 3 Time not met. AND C D.2 Be in MODE 5. 36 hours WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 7 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 8 of 90 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

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. The term "required" has been added since the DC System has a spare battery charger that is common to both DC subsystems, and the spare charger can be used to meet the requirements of the LCO if the normal charger is inoperable.

3. The bracketed ISTS 3.8.4 ACTION B has been deleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been modified and renumbered, as necessary.

4. The Completion Time for ISTS 3.8.4 Required Action A.3 has been changed from 7 days to 72 hours. This change is consistent with proposed TSTF-500.

6. A new Note is being added to allow a DC electrical power subsystem to be inoperable for up to 24 hours due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours.

CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the DC electrical power subsystems. Kewaunee Power Station Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 8 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 9 of 90 All changes are 1 DC Sources - Operating B 3.8.4 unless otherwise noted BASES one LCO y The DC electrical power subsystems, each subsystem consisting of [two] 2 batteries, battery charger [for each battery] and the corresponding control subsystem equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any train DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 4). one y An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es). APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." ACTIONS A.1, A.2, and A.3 7 required 7 2 Condition A represents one train with one [or two] battery chargers The ACTIONS are modified by a Note that inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The allows a 24 hour delay in entering the ACTIONS when a DC electrical power ACTIONS provide a tiered response that focuses on returning the battery subsystem is inoperable solely due to the to the fully charged state and restoring a fully qualified charger to room cooler being non-functional, provided OPERABLE status in a reasonable time period. Required Action A.1 the associated room temperature is monitored and maintained within the design requires that the battery terminal voltage be restored to greater than or environmental requirements and the other equal to the minimum established float voltage within 2 hours. This time DC electrical power subsystem is provides for returning the inoperable charger to OPERABLE status or OPERABLE. The 24 hour allowance is provided in order to perform room cooler providing an alternate means of restoring battery terminal voltage to maintenance. If during the 24 hour period greater than or equal to the minimum established float voltage. Restoring the other DC electrical power subsystem the battery terminal voltage to greater than or equal to the minimum becomes inoperable, the associated established float voltage provides good assurance that, within [12] hours, 2 ACTIONS for an inoperable DC electrical power subsystem must immediately be the battery will be restored to its fully charged condition (Required Action entered. This 24 hour time period is A.2) from any discharge that might have occurred due to the charger acceptable because the room containing inoperability. the DC electrical power subsystems is monitored on an hourly basis to ensure conditions are within design environmental requirements during this time. WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 9 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 10 of 90 CTS Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 1 DOC M01 LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

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

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC 2 bus for 24 hours to perform an equalizing charge on [its/their] associated [common] battery, provided: instrument

a. The associated AC vital bus(es) [is/are] energized from [its/their] 5 2

[Class 1E constant voltage source transformers] [inverter using internal AC source], and 6

                             /rectifier instrument                     ;

b. All other AC vital buses are energized from their associated 5 OPERABLE inverters. ]

DOC M01 APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS INSERT 1A CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. One [required] inverter A.1 --------------NOTE-------------- 1 inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de- 5 energized. instrument Restore inverter to 24 hours OPERABLE status. INSERT 1 3 DOC M01 B. Required Action and B.1 Be in MODE 3. 6 hours 3 associated Completion C Time not met. AND C WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 10 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 11 of 90 CTS 3.8.7 3 INSERT 1 DOC M01 B. Two inverters in one B.1 Restore one inverter to 2 hours train inoperable. OPERABLE status. 7 INSERT 1A

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

When one or both inverters in one train are inoperable solely due to the room cooler being non-functional, entry into associated ACTIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) both inverters in the other train are OPERABLE. Insert Page 3.8.7-1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 11 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 12 of 90 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. The word "required" has been deleted from the LCO and Condition A since all Train A and Train B inverters are required.

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. ITS 3.8.7 Condition B has been added to allow two inverters on the same train to be inoperable for up to 2 hours. The Kewaunee design incorporates two 120 VAC inverters on each train. As written, ISTS 3.8.7 requires entry into LCO 3.0.3 when two inverters in the same train are inoperable since no ACTION exists for when more than one inverter is inoperable. The inoperability of two inverters in the same train does not place the unit outside of its design basis because the other train remains OPERABLE to support engineered safety features operation.

Therefore, entry into LCO 3.0.3 is not necessary in this condition. An allowed outage time of 2 hours has been selected to be consistent with the allowed outage time in ITS 3.8.9 for two inoperable 120 VAC buses in the same train. In addition, the subsequent ACTION has been renumbered.

4. The SR has been modified to reflect that each inverter must have proper voltage, frequency, and alignment to its associated instrument bus.

5. The proper plant terminology has been used.

6. These 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.

7. A new Note is being added to allow one or more inverters in one train to be inoperable for up to 24 hours due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the inverters in the other train are OPERABLE. CTS does not contain a specification comparable to ITS 3.8.7, Inverters-Operating. The inverters are located within the battery rooms. Therefore, the room cooler for the associated battery room controls the environment conditions for the inverters. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the inverters are operating and connected to the associated DC bus(es) and AC instrument bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the inverters if room cooling is non-functional for an extended period of time.

Current procedural guidance requires monitoring the room containing the inverters to ensure conditions are within design environmental requirements. However, per ITS 3.8.7, two inverters in one train inoperable is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hours without exceeding the design environmental limits for the inverters. Kewaunee Power Station Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 12 of 90

The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 13 of 90 when a one or both inverters in one train are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and both inverters in the other train are OPERABLE. The 24 hour allowance is provided in order to perform room cooler All changes are 1 Inverters - Operating maintenance. If during the 24 hour period one or both of the inverters in the other train become inoperable, the associated ACTIONS for the inoperable inverter(s) must B 3.8.7 immediately be entered. This 24 hour time period is acceptable because the room unless otherwise noted containing the inverters is monitored on an hourly basis to ensure conditions are within 4 design environmental requirements. BASES Train A or Train B ACTIONS A.1 instrument 4 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant 2 voltage source transformer or inverter using internal AC source]. 5

                                                    /rectifier For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours.                                      instrument Required Action A.1 allows 24 hours to fix the inoperable inverter and return it to service. The 24 hour limit is based upon engineering judgment, taking into consideration the time required to repair an inverter Power to an instrument bus is               and the additional risk to which the unit is exposed because of the provided in the following order: 1) filtered AC through the inverter             inverter inoperability. This has to be balanced against the risk of an (referred to as "normal"); 2) DC              immediate shutdown, along with the potential challenges to safety instrument changed to AC via the inverter (referred to as "standby"), and; 3)            systems such a shutdown might entail. When the AC vital bus is powered non-filtered AC through the               from its constant voltage source, it is relying upon interruptible AC inverter via a static switch (referred to as "alternate").            electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

C C 4 INSERT 1 B.1 and B.2 Train A or Train B inverters 6 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 13 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 14 of 90 ITS ITS 3.8.9 A01 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries. OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features. SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are satisfied:

1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

See ITS 3.8.1

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

Train A and B AC electrical power distribution

3. The 4160-V buses 1-5 and 1-6 are both energized. subsystem shall be OPERABLE. LA01

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their LCO 3.8.9 respective station service transformers.

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

Train A and B DC electrical power distribution subsystems A02

6. Both station batteries and both DC systems are OPERABLE, except during testing See ITS and surveillance as described in TS 4.6.b. 3.8.4 and 3.8.6

7. Both diesel generators are OPERABLE and each diesel generator shall have:

A. Day tanks containing a minimum volume of 1000 gallons; See ITS 3.8.1 and B. An underground storage tank and corresponding day tanks containing a 3.8.3 minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are: See ITS 3.8.1 A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution M02 subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 ACTIONS Note Amendment No. 203 TS 3.7-1 02/06/2009 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 14 of 90 Page 1 of 2

Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 15 of 90 ITS ITS 3.8.9 Add proposed ACTIONS Note L02 ACTION D b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours. and MODE 5 in 36 hours M01

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either: See ITS 3.8.1 A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator.

3. One battery may be inoperable for a period not exceeding 24 hours provided the See ITS 3.8.4 and other battery and two battery chargers remain OPERABLE with one charger 3.8.6 carrying the d-c supply system.

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE. See ITS 3.8.1

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

Add proposed ACTION A Note M03 ACTION A 6. One 4160-V or 480-V engineered safety features bus may be out of service for 8 24 hours provided the redundant bus and its loads remain OPERABLE. M03 M03 ACTION E 7. Two diesel generators may be inoperable for 2 hours. A03

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: See ITS 3.8.1

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Add proposed ACTIONS C and E (for 125 VDC) L01 Add proposed SR 3.8.9.1 for 4160 and 480 VAC and 125 VDC M04 Amendment No. 194 TS 3.7-2 02/07/2008 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 15 of 90 Page 2 of 2

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 16 of 90 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Furthermore, for inoperabilities of the DC buses or of AC buses in both trains, since no actions are provided, CTS 3.0.c would also require the unit to be subcritical within a total of 13 hours (1 hour to initiate action, 6 hours to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours to be in HOT SHUTDOWN (which requires the reactor to be subcritical)). ITS LCO 3.8.9 requires the Train A and B AC and DC electrical power distribution subsystems to be OPERABLE in MODES 1, 2, 3, and 4. When a unit shutdown is required due to inoperabilities of the AC or DC buses, ITS 3.8.9 ACTION D requires the unit to be in MODE 3 (CTS equivalent HOT SHUTDOWN) within 6 hours and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours. This changes the CTS by requiring the Train A and B AC and DC electrical power distribution subsystems to be OPERABLE in MODES 3 and 4 and in MODE 2 when the reactor is not critical and provides commensurate ACTIONS to cover the new Applicability. The purpose of CTS 3.7.a, in part, is to ensure the Train A and B AC and DC electrical power distribution subsystems are OPERABLE to mitigate the consequences of a transient or design basis accident. The Train A and B AC and DC electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 when an accident may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODES 3 and 4 the reactor is not critical, however the reactor coolant temperature is always above 200°F and there is considerable energy in the reactor core and the electrical power distribution systems must be available to support equipment necessary to mitigate the consequences of a pipe break. Therefore, it is acceptable to require the AC and DC electrical power distribution subsystems to be OPERABLE in MODES 3 and 4 as well as MODES 1 and 2. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS. M02 The CTS does not specify requirements for AC instrument electrical power distribution subsystems to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.8.9, in part, requires the Train A and Train B AC instrument bus electrical power , including an ACTIONS distribution power subsystems to be OPERABLE in MODES 1, 2, 3, and 4. Note Appropriate ACTIONS (B and E) and a Surveillance Requirement (SR 3.8.9.1) are also provided. This changes the CTS by incorporating these ITS 3.8.9 requirements. The purpose of ITS 3.8.9 is, in part, to ensure the necessary AC instrument electrical power distribution subsystems are available to provide electrical power to mitigate postulated events. This change is acceptable since the distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). This change is designated as more restrictive because it adds new requirements to the CTS. M03 CTS 3.7.b.6 requires inoperable AC buses to be restored to OPERABLE status within 24 hours provided the redundant bus and its loads remain OPERABLE. ITS 3.8.9 Required Action A.1 allows 8 hours to restore the Train A and Train B AC electrical power distribution subsystem(s) to OPERABLE status. In addition, a Note has been added (ITS 3.8.9, Note to ACTION A) that requires entry into applicable Conditions and Required Action of LCO 3.8.4, "DC Sources - Operating," for DC Sources made inoperable by inoperable power distribution Kewaunee Power Station Page 2 of 5 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 16 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 17 of 90 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING provided by ITS 3.8.9 ACTION C would not be allowed. This changes the CTS by providing some time to restore an inoperable DC electrical power distribution subsystem prior to requiring a plant shutdown provided a loss of function has not occurred. The purpose of CTS 3.7.a.6 is to ensure the availability of necessary DC electrical power to ESF systems. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows a short time period to restore an inoperable DC electrical power distribution subsystem to OPERABLE status. This is acceptable because there are sufficient electrical power distribution subsystems available to ensure all plant safety functions can be supported by the Train A and Train B electrical power distribution subsystems. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. INSERT DOC L02 Kewaunee Power Station Page 5 of 5 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 17 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 18 of 90 L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when an AC or DC electrical power distribution subsystem is inoperable. ITS 3.8.9 also provides ACTIONS, but includes a Note that allows one or more electrical power distribution subsystems to be inoperable for up to 24 hours solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other train are OPERABLE. This changes the CTS by allowing a 24 hour deferral in entering associated ACTIONS when a electrical power distribution subsystem is inoperable solely due to a room cooler being non-functional. The purpose of the CTS 3.7.b and ITS 3.8.9 ACTIONS is to adequately control how long an electrical power distribution subsystem can be inoperable. The change allows an additional 24 hours if the inoperability of the electrical power distribution subsystem is due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. CTS 3.7.b.6 allows one 480-V engineered safety features bus may be out of service for 24 hours. CTS 3.7.b.6 is also entered when the associated room cooler is non-functional. The CTS does not contain a specification specifically for DC distribution subsystem or AC instrument bus electrical power distribution subsystem. Although the AC, DC, and AC instrument bus electrical power subsystems are operating and connected to the associated AC, DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.9, an electrical power distribution subsystem inoperability can be limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the AC, DC, and AC instrument bus electrical power distribution subsystems. This change is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS. Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 18 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 19 of 90 CTS Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating instrument 3.7.a.3, 1 3.7.a.4, LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution 3.7.a.5, subsystems shall be OPERABLE. 3.7.a.6 3.7.a APPLICABILITY: MODES 1, 2, 3, and 4.

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

When one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, entry into associated ACTIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and 5 maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other train are ACTIONS OPERABLE . CONDITION REQUIRED ACTION COMPLETION TIME 3.7.b.6 A. One or more AC --------------------NOTE------------------- electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains 1 sources made inoperable by inoperable power distribution subsystems. A.1 Restore AC electrical power 8 hours distribution subsystem(s) to OPERABLE status. instrument 1 DOC M02 B. One or more AC vital B.1 Restore AC vital bus 2 hours buses inoperable. subsystem(s) to (es) instrument OPERABLE status. DOC L01 2 C. One or more DC C.1 Restore DC electrical 2 hours electrical power power distribution distribution subsystems subsystem(s) to inoperable. OPERABLE status. WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 19 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 20 of 90 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

1. 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.

2. The allowance in ISTS 3.8.9 ACTION C to have one or more DC electrical power distribution subsystems inoperable for 2 hours has been changed to address only the inoperability of one Train A or Train B DC electrical power distribution subsystem, since if both the Train A and Train B buses were inoperable, then a loss of safety function would exist and entry into ACTION E would be necessary.

3. Changes made to be consistent with the Specification.

4. 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.

5. A new Note is being added to allow one or more electrical power distribution subsystems to be inoperable for up to 24 hours due to a room cooler being non-functional, provided associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. CTS 3.7.b.6 allows one 480-V engineered safety features bus may be out of service for 24 hours. CTS 3.7.b.6 is also entered when the associated room cooler is non-functional. CTS does not contain a specification specifically for DC distribution subsystem or AC instrument bus electrical power distribution subsystem. Although the AC, DC, and AC instrument bus electrical power subsystems are operating and connected to the associated AC and DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the AC, DC, or AC Instrument bus electrical power distribution subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing AC, DC, or AC instrument bus electrical power distribution subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.9, an electrical power distribution subsystem inoperability can be limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hours without exceeding the design environmental limits for the AC, DC, and AC instrument bus electrical power distribution subsystems.

Kewaunee Power Station Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 20 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 21 of 90 All changes are 1 Distribution Systems - Operating B 3.8.9 unless otherwise noted BASES LCO (continued) instrument In addition, tie breakers between redundant safety related AC, DC, and AC vital bus power distribution subsystems, if they exist, must be open. electrical This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s). If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV buses from being powered from the same offsite circuit. APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients 3

and ;

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems - Shutdown." 6 ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor 4 electrical power distribution control centers, or distribution panels (except AC vital buses), in one train instrument subsystem inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The electrical overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC electrical power buses, load centers, motor control centers, and distribution panels must 4 distribution subsystem be restored to OPERABLE status within 8 hours. The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS when one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. The 24 hour allowance is provided in order to perform room cooler maintenance. If during the 24 hour period the buses subsequently become inoperable such that a loss of function occurs, the associated ACTIONS for the inoperable DC electrical power subsystem(s) must immediately be entered. This 24 hour time period is acceptable because the room containing the AC, DC, and AC instrument bus electrical power distribution subsystems is monitored on an hourly basis to ensure conditions are within design environmental requirements. WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 21 of 90

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 22 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3621 NRC Question MEH-009 Number Select Licensee Response Application

Response

6/28/2010 4:10 PM Date/Time Closure Statement Response In the previous response to this question, KPS provided a draft markup of Statement changes to ITS 3.8.4, ITS 3.8.7, and ITS 3.8.9 that added a Note to the ACTIONS to allow up to 24 hours with the associated components covered by the LCO inoperable due to a non-functional room cooler. During a subsequent phone call with the NRC reviewer, he requested that KPS re-look at the Note restrictions, specifically related to monitoring the room temperature while using the Note. KPS has re-reviewed the monitoring requirements and has decided to include in the Note a requirement that the room temperature must be monitored and maintained within the design environmental requirements. Furthermore, the ITS Bases states that the room temperature monitoring requirement is met by monitoring the room temperature on an hourly basis while using the note. A draft markup regarding this change is attached and supersedes the markup attached to the previous response. This change will be reflected in the supplement to this section of the ITS conversion amendment. Question Closure Date Attachment MEH-009 Markup Rev 1.pdf (2MB) 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Gerald Waig Added By Robert Hanley Date Added 6/28/2010 4:14 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 22 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3621 07/01/2010

Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 23 of 90 ITS ITS 3.8.4 L02 Add proposed ACTIONS Note ACTION C b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours. M01 and MODE 5 in 36 hours

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

See ITS 3.8.1

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either:

A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel M02 generator. DC electrical power subsystem 2 ACTION B 3. One battery may be inoperable for a period not exceeding 24 hours provided the L01 other battery and two battery chargers remain OPERABLE with one charger carrying the d-c supply system. Add proposed ACTION A L01

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are OPERABLE.

See ITS 3.8.1

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for See ITS 3.8.9 24 hours provided the redundant bus and its loads remain OPERABLE.

7. Two diesel generators may be inoperable for 2 hours.

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the See ITS requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: 3.8.1

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 M03 Amendment No. 194 TS 3.7-2 02/07/2008 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 23 of 90 Page 2 of 2

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 24 of 90 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING associated charger is inoperable) are being applied in the ITS than were applied in the CTS. INSERT DOC L02 Kewaunee Power Station Page 5 of 5 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 24 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 25 of 90 L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when a DC source is inoperable. ITS 3.8.4 also provides ACTIONS, but includes a Note that allows a DC electrical power subsystem to be inoperable for up to 24 hours solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the other DC electrical power subsystem is OPERABLE. This changes the CTS by allowing a 24 hour deferral in entering associated ACTIONS when a DC electrical power subsystem is inoperable solely due to a room cooler being non-functional. The purpose of the CTS 3.7.b and ITS 3.8.4 ACTIONS is to adequately control how long a DC electrical power subsystem can be inoperable. The change allows an additional 24 hours if the inoperability of the DC electrical power subsystem is due to a room cooler being non-functional, and provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the DC electrical power subsystems. This change is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS. Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 25 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 26 of 90 CTS All changes are 1 DC Sources - Operating 3.8.4 unless otherwise noted 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating 3.7.a.6 LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE. 3.7.a APPLICABILITY: MODES 1, 2, 3, and 4.

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

When a DC electrical power subsystem is inoperable solely due to the room cooler being non-functional, entry into associated ACTIONS may be delayed 6 for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the other DC electrical power subsystem is OPERABLE. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required 2 DOC L01 A. One [or two] battery A.1 Restore battery terminal 2 hours charger[s on one train] voltage to greater than or inoperable. equal to the minimum established float voltage. AND A.2 Verify battery float current Once per [12] hours

                                                                         [2] amps.

AND A.3 Restore battery charger[s] 7 days 72 hours 4 to OPERABLE status. [B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ] 3 on one train] inoperable. OPERABLE status. B B 3 3.7.b.3 C. One DC electrical power C.1 Restore DC electrical [2] hours subsystem inoperable power subsystem to for reasons other than OPERABLE status. Condition A [or B]. C 3.7.b D. Required Action and D.1 Be in MODE 3. 6 hours Associated Completion 3 Time not met. AND C D.2 Be in MODE 5. 36 hours WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 26 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 27 of 90 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

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. The term "required" has been added since the DC System has a spare battery charger that is common to both DC subsystems, and the spare charger can be used to meet the requirements of the LCO if the normal charger is inoperable.

3. The bracketed ISTS 3.8.4 ACTION B has been deleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been modified and renumbered, as necessary.

4. The Completion Time for ISTS 3.8.4 Required Action A.3 has been changed from 7 days to 72 hours. This change is consistent with proposed TSTF-500.

6. A new Note is being added to allow a DC electrical power subsystem to be inoperable for up to 24 hours due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours.

CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the DC electrical power subsystems. Kewaunee Power Station Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 27 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 28 of 90 All changes are 1 DC Sources - Operating B 3.8.4 unless otherwise noted BASES one LCO y The DC electrical power subsystems, each subsystem consisting of [two] 2 batteries, battery charger [for each battery] and the corresponding control subsystem equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any train DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 4). one y An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es). APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." ACTIONS A.1, A.2, and A.3 7 required 7 2 Condition A represents one train with one [or two] battery chargers The ACTIONS are modified by a Note that inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The allows a 24 hour delay in entering the ACTIONS when a DC electrical power ACTIONS provide a tiered response that focuses on returning the battery subsystem is inoperable solely due to the to the fully charged state and restoring a fully qualified charger to room cooler being non-functional, provided OPERABLE status in a reasonable time period. Required Action A.1 the associated room temperature is monitored and maintained within the design requires that the battery terminal voltage be restored to greater than or environmental requirements and the other equal to the minimum established float voltage within 2 hours. This time DC electrical power subsystem is provides for returning the inoperable charger to OPERABLE status or OPERABLE. The 24 hour allowance is provided in order to perform room cooler providing an alternate means of restoring battery terminal voltage to maintenance. If during the 24 hour period greater than or equal to the minimum established float voltage. Restoring the other DC electrical power subsystem the battery terminal voltage to greater than or equal to the minimum becomes inoperable, the associated established float voltage provides good assurance that, within [12] hours, 2 ACTIONS for an inoperable DC electrical power subsystem must immediately be the battery will be restored to its fully charged condition (Required Action entered. This 24 hour time period is A.2) from any discharge that might have occurred due to the charger acceptable because the room containing inoperability. the DC electrical power subsystems is monitored on an hourly basis to ensure conditions are within design environmental requirements during this time. WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 28 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 29 of 90 CTS Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 1 DOC M01 LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

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

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC 2 bus for 24 hours to perform an equalizing charge on [its/their] associated [common] battery, provided: instrument

a. The associated AC vital bus(es) [is/are] energized from [its/their] 5 2

[Class 1E constant voltage source transformers] [inverter using internal AC source], and 6

                             /rectifier instrument                     ;

b. All other AC vital buses are energized from their associated 5 OPERABLE inverters. ]

DOC M01 APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS INSERT 1A CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. One [required] inverter A.1 --------------NOTE-------------- 1 inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de- 5 energized. instrument Restore inverter to 24 hours OPERABLE status. INSERT 1 3 DOC M01 B. Required Action and B.1 Be in MODE 3. 6 hours 3 associated Completion C Time not met. AND C WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 29 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 30 of 90 CTS 3.8.7 3 INSERT 1 DOC M01 B. Two inverters in one B.1 Restore one inverter to 2 hours train inoperable. OPERABLE status. 7 INSERT 1A

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

When one or both inverters in one train are inoperable solely due to the room cooler being non-functional, entry into associated ACTIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) both inverters in the other train are OPERABLE. Insert Page 3.8.7-1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 30 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 31 of 90 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. The word "required" has been deleted from the LCO and Condition A since all Train A and Train B inverters are required.

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. ITS 3.8.7 Condition B has been added to allow two inverters on the same train to be inoperable for up to 2 hours. The Kewaunee design incorporates two 120 VAC inverters on each train. As written, ISTS 3.8.7 requires entry into LCO 3.0.3 when two inverters in the same train are inoperable since no ACTION exists for when more than one inverter is inoperable. The inoperability of two inverters in the same train does not place the unit outside of its design basis because the other train remains OPERABLE to support engineered safety features operation.

Therefore, entry into LCO 3.0.3 is not necessary in this condition. An allowed outage time of 2 hours has been selected to be consistent with the allowed outage time in ITS 3.8.9 for two inoperable 120 VAC buses in the same train. In addition, the subsequent ACTION has been renumbered.

4. The SR has been modified to reflect that each inverter must have proper voltage, frequency, and alignment to its associated instrument bus.

5. The proper plant terminology has been used.

6. These 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.

7. A new Note is being added to allow one or more inverters in one train to be inoperable for up to 24 hours due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the inverters in the other train are OPERABLE. CTS does not contain a specification comparable to ITS 3.8.7, Inverters-Operating. The inverters are located within the battery rooms. Therefore, the room cooler for the associated battery room controls the environment conditions for the inverters. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the inverters are operating and connected to the associated DC bus(es) and AC instrument bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the inverters if room cooling is non-functional for an extended period of time.

Current procedural guidance requires monitoring the room containing the inverters to ensure conditions are within design environmental requirements. However, per ITS 3.8.7, two inverters in one train inoperable is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hours without exceeding the design environmental limits for the inverters. Kewaunee Power Station Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 31 of 90

The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 32 of 90 when a one or both inverters in one train are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and both inverters in the other train are OPERABLE. The 24 hour allowance is provided in order to perform room cooler All changes are 1 Inverters - Operating maintenance. If during the 24 hour period one or both of the inverters in the other train become inoperable, the associated ACTIONS for the inoperable inverter(s) must B 3.8.7 immediately be entered. This 24 hour time period is acceptable because the room unless otherwise noted containing the inverters is monitored on an hourly basis to ensure conditions are within 4 design environmental requirements. BASES Train A or Train B ACTIONS A.1 instrument 4 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant 2 voltage source transformer or inverter using internal AC source]. 5

                                                    /rectifier For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours.                                      instrument Required Action A.1 allows 24 hours to fix the inoperable inverter and return it to service. The 24 hour limit is based upon engineering judgment, taking into consideration the time required to repair an inverter Power to an instrument bus is               and the additional risk to which the unit is exposed because of the provided in the following order: 1) filtered AC through the inverter             inverter inoperability. This has to be balanced against the risk of an (referred to as "normal"); 2) DC              immediate shutdown, along with the potential challenges to safety instrument changed to AC via the inverter (referred to as "standby"), and; 3)            systems such a shutdown might entail. When the AC vital bus is powered non-filtered AC through the               from its constant voltage source, it is relying upon interruptible AC inverter via a static switch (referred to as "alternate").            electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

C C 4 INSERT 1 B.1 and B.2 Train A or Train B inverters 6 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 32 of 90

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 33 of 90 ITS ITS 3.8.9 A01 3.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries. OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features. SPECIFICATION M01 Applicability a. The reactor shall not be made critical unless all of the following requirements are satisfied:

1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

See ITS 3.8.1

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

Train A and B AC electrical power distribution

3. The 4160-V buses 1-5 and 1-6 are both energized. subsystem shall be OPERABLE. LA01

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their LCO 3.8.9 respective station service transformers.

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

Train A and B DC electrical power distribution subsystems A02

6. Both station batteries and both DC systems are OPERABLE, except during testing See ITS and surveillance as described in TS 4.6.b. 3.8.4 and 3.8.6

7. Both diesel generators are OPERABLE and each diesel generator shall have:

A. Day tanks containing a minimum volume of 1000 gallons; See ITS 3.8.1 and B. An underground storage tank and corresponding day tanks containing a 3.8.3 minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are: See ITS 3.8.1 A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution M02 subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 ACTIONS Note Amendment No. 203 TS 3.7-1 02/06/2009 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 33 of 90 Page 1 of 2

Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 34 of 90 ITS ITS 3.8.9 Add proposed ACTIONS Note L02 ACTION D b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours. and MODE 5 in 36 hours M01