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{{#Wiki_filter:ITS NRC Questions | {{#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 | ||
NRC Reviewer | Number Page Number(s) | ||
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 | NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N | ||
The supplement stated that the reason for the proposed request is related to Area Fan Cooler Units and minimum Completion Times in Conditions | 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. | ||
Attach File 1 Attach File 2 Issue Date 6/8/2010 Added By Matthew Hamm Date Modified | 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 | |||
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. | |||
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. | Therefore, the proposed Note change is not contrary to the ITS usage convention. | ||
However, KPS has reviewed the NRC request to include the Completion | 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. | |||
Times in each affected Specification. Based on this review, the previous Note change to ITS 3.7.8 is withdrawn (reference - Letter | 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 | ||
Question Closure Date | |||
Ray Schiele Added By Robert Hanley Date Added 6/21/2010 4:26 PM Modified By Date Modified | 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 | |||
HOT STANDBY within the next 6 hours. | 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. | : 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: | : 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 | 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. | |||
B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator. | 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 | |||
carrying the d-c supply system. | : 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. | ||
: 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 | : 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 | |||
: 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. | : 1. Its corresponding normal or emergency power source is OPERABLE; and | ||
: 6. One 4160-V or 480-V engineered safety features bus may be out of service for 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 | |||
requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | |||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | |||
: 2. Its redundant system, train, or component is OPERABLE. | : 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 | |||
ACTIONS | 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 | |||
A. One [or two] battery charger[s on one train] | 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 | |||
inoperable. | 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 | |||
DC Sources - Operating B 3.8.4 | |||
LCO The DC electrical power subsystems, each subsystem consisting of [two] | |||
batteries, battery charger [for each battery] and the corresponding control | |||
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 | |||
An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es). | 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: | 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 | : 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. | |||
and | The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." | ||
: b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | 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. | |||
The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." | 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 | ||
environmental requirements | |||
provided in | 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 | |||
the other DC | 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 | |||
A | |||
Page | |||
being non-functional, | |||
the design environmental requirements | |||
OPERABLE | |||
are within design environmental requirements. | |||
With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant voltage source transformer or inverter using internal AC source]. | |||
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." | |||
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 and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety | |||
systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC 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. | |||
B.1 and B.2 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. | |||
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. | 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 | 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. | |||
: 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | See ITS 3.8.1 | ||
: 3. The 4160-V buses 1-5 and 1-6 are both energized. | : 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | ||
: 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | Train A and B AC electrical power distribution | ||
: 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | : 3. The 4160-V buses 1-5 and 1-6 are both energized. subsystem shall be OPERABLE. LA01 | ||
: 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | : 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: | : 7. Both diesel generators are OPERABLE and each diesel generator shall have: | ||
A. Day tanks containing a minimum volume of 1000 gallons; B. An underground storage tank and corresponding day tanks containing a minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump. | 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: | : 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 | ||
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 | |||
HOT STANDBY within the next 6 hours. | 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. | ||
: 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. | and MODE 5 in 36 hours M01 | ||
: 2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either: | : 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. | ||
A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or | : 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. | |||
B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator. | : 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 | ||
: 3. One battery may be inoperable for a period not exceeding 24 hours provided the other battery and two battery chargers remain OPERABLE with one charger | : 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 | |||
carrying the d-c supply system. | : 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 | ||
: 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 | : 1. Its corresponding normal or emergency power source is OPERABLE; and | ||
OPERABLE. | |||
: 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. | |||
: 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: | |||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | |||
: 2. Its redundant system, train, or component is OPERABLE. | : 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 | |||
Add proposed SR 3.8.9.1 for 4160 and 480 VAC and 125 VDC M04 | |||
Applicability. | 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 | 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. | |||
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 | This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS. | ||
°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. | 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 | ||
This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS. | , 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. | |||
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 distribution power subsystems to be OPERABLE in MODES 1, 2, 3, and 4. | |||
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. | 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 - | 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. | ||
Operating," for DC Sources made inoperable by inoperable power distribution Kewaunee Power Station Page 2 of 5 | 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 | |||
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 | 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. | |||
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. | 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 | 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 | ||
A | |||
maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 | 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 | |||
In addition, tie breakers between redundant safety related AC, DC, and AC vital bus power distribution subsystems, if they exist, must be open. 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. | 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. | ||
: a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients | 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 | |||
A | |||
HOT STANDBY within the next 6 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. | |||
: 2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either: | : 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 | 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. | |||
B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator. | 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 | |||
carrying the d-c supply system. | : 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. | ||
: 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 | : 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 | |||
: 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. | : 1. Its corresponding normal or emergency power source is OPERABLE; and | ||
: 6. One 4160-V or 480-V engineered safety features bus may be out of service for 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 | |||
requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | |||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | |||
: 2. Its redundant system, train, or component is OPERABLE. | : 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 | |||
and maintained within the design environmental requirements and the other DC electrical power | 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 | |||
subsystem is OPERABLE. | 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 | ||
CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. | : 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. | ||
CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although | : 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 | |||
DC Sources - Operating B 3.8.4 | |||
LCO The DC electrical power subsystems, each subsystem consisting of [two] | |||
batteries, battery charger [for each battery] and the corresponding control | |||
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 | |||
An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es). | 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: | 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 | : 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. | |||
and | The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." | ||
: b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | 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. | |||
The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." | 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 | ||
acceptable because the room containing | |||
the DC electrical power subsystems is | |||
monitored on an hourly basis to ensure | |||
conditions are within design environmental | |||
requirements during this time. | |||
A | |||
Page | |||
------------------------------------------------------------------------------------------------------------------ | 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 | |||
and maintained within the design environmental requirements and the inverters in the other train are | 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 | |||
With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant voltage source transformer or inverter using internal AC source]. | |||
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." | |||
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 and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety | |||
systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC 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. | |||
B.1 and B.2 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. | |||
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. | 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 | 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. | |||
: 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | See ITS 3.8.1 | ||
: 3. The 4160-V buses 1-5 and 1-6 are both energized. | : 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | ||
: 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | Train A and B AC electrical power distribution | ||
: 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | : 3. The 4160-V buses 1-5 and 1-6 are both energized. subsystem shall be OPERABLE. LA01 | ||
: 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | : 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: | : 7. Both diesel generators are OPERABLE and each diesel generator shall have: | ||
A. Day tanks containing a minimum volume of 1000 gallons; B. An underground storage tank and corresponding day tanks containing a minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump. | 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: | : 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 | ||
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 | |||
requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | 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. | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | 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. | : 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 34 of 90 Page 2 of 2 | |||
Add proposed SR 3.8.9.1 for 4160 and 480 VAC and 125 VDC M04 | |||
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 | Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 35 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. | ||
°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. | 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. | ||
This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS. | 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 distribution power subsystems to be OPERABLE in MODES 1, 2, 3, and 4. | 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. | |||
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. | 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. | 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 - | 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. | ||
Operating," for DC Sources made inoperable by inoperable power distribution Kewaunee Power Station Page 2 of 5 | 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 35 of 90 | |||
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 | Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 36 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. | |||
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. | 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 | 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 36 of 90 | ||
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 37 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 37 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 38 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 38 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 39 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 39 of 90 | |||
APPLICABILITY | Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 40 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 40 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 41 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3801 NRC Question MEH-009 Number Select Licensee Response Application | |||
A. | ===Response=== | ||
7/15/2010 10:40 AM Date/Time Closure Statement Response In the previous (second) response to this question (dated 6/28/2010), KPS Statement provided a draft markup of 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. This change included a requirement to monitor the room temperature on an hourly basis to ensure the temperature was maintained within the design environmental requirements. In a subsequent phone call with the NRC reviewer, he requested that KPS look at the Note restrictions, and include the value of the design temperature limit in the ITS Bases. KPS has reviewed the monitoring requirements and has decided to include the actual design temperature value in the ITS Bases (120 degrees F). 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 2.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 7/15/2010 10:41 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 41 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3801 07/19/2010 | |||
Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 42 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 | |||
HOT STANDBY within the next 6 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. | |||
: 2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either: | : 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 | 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. | |||
B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator. | 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 | |||
carrying the d-c supply system. | : 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. | ||
: 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 | : 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 | |||
: 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. | : 1. Its corresponding normal or emergency power source is OPERABLE; and | ||
: 6. One 4160-V or 480-V engineered safety features bus may be out of service for 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 | |||
requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | |||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | |||
: 2. Its redundant system, train, or component is OPERABLE. | : 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 42 of 90 Page 2 of 2 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 43 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 43 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 44 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 the associated room temperature is monitored and maintained within the design environmental requirements and 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 hours 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 44 of 90 | |||
ACTIONS | Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 45 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 the associated room temperature is monitored and maintained within the design environmental requirements and 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 45 of 90 | |||
A. | Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 46 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 hours 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 46 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 47 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 | |||
DC Sources - Operating B 3.8.4 | |||
LCO The DC electrical power subsystems, each subsystem consisting of [two] | |||
batteries, battery charger [for each battery] and the corresponding control | |||
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 | |||
An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es). | 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: | 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 | : 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. | |||
and | The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." | ||
: b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | 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 of 120°F during this time. | |||
The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." | 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 47 of 90 | ||
acceptable because the room containing | |||
the DC electrical power subsystems is | |||
monitored on an hourly basis to ensure | |||
conditions are within design environmental | |||
requirements of 120°F during this time. | |||
A | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 48 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 7 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 48 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 49 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 the associated room temperature is monitored and maintained within the design environmental requirements and 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 49 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 50 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 50 of 90 | |||
containing the inverters is monitored on an hourly basis to ensure conditions are within | 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 51 of 90 when 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 of 120°F during this time. | ||
4 | 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 51 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 52 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. | 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 | 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. | |||
: 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | See ITS 3.8.1 | ||
: 3. The 4160-V buses 1-5 and 1-6 are both energized. | : 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | ||
: 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | Train A and B AC electrical power distribution | ||
: 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | : 3. The 4160-V buses 1-5 and 1-6 are both energized. subsystem shall be OPERABLE. LA01 | ||
: 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | : 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: | : 7. Both diesel generators are OPERABLE and each diesel generator shall have: | ||
A. Day tanks containing a minimum volume of 1000 gallons; B. An underground storage tank and corresponding day tanks containing a minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump. | 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: | : 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 52 of 90 Page 1 of 2 | ||
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 | |||
HOT STANDBY within the next 6 hours. | Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 53 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. | ||
: 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. | and MODE 5 in 36 hours M01 | ||
: 2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either: | : 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. | ||
A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or | : 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 53 of 90 Page 2 of 2 | |||
B. | Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 54 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 54 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 55 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 55 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 56 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 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. This changes the CTS by allowing a 24 hour deferral in entering associated ACTIONS when an 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 hours 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 56 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 57 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 the associated room temperature is monitored and maintained 5 within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE . | |||
ACTIONS -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |||
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 57 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 58 of 90 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING | |||
The | : 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 58 of 90 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 59 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. | |||
This | 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 of 120°F during this time. | |||
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 59 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 60 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3871 NRC Question MEH-009 Number Select Licensee Response Application | |||
===Response=== | |||
7/16/2010 11:45 AM Date/Time Closure Statement Response During a discussion with the NRC staff concerning the environmental temperature Statement limits for the rooms specified in the MEH-009 markup posted on 7/15/2010 the staff requested DEK ensure the temperature limits are included in Kewaunees USAR. DEK commits to including the vital switchgear and the battery rooms temperature limits in the USAR. This change will be reflected in the supplement to this section of the ITS conversion amendment. | |||
Question Closure Date Attachment 1 | |||
Attachment 2 | |||
Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Gerald Waig Added By Robert Hanley Date Added 7/16/2010 11:45 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 60 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3871 07/19/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 61 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3921 NRC Question MEH-009 Number Select NRC Question Closure Application | |||
===Response=== | |||
Date/Time Closure Based on the 7/16/2010 resonse to the MEH-009, this question is closed and no further Statement information is required at this time to draft the Safety Evaluation. | |||
===Response=== | |||
Statement Question Closure 7/20/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Waig Date Added 7/20/2010 2:54 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 61 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3921 07/20/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 62 of 90 ITS NRC Questions Id 1691 NRC Question RW001 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases 5 | |||
Number Page Number Volume 13, Page 117 of 289 (s) | |||
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N | |||
Requested NRC Question Condition F of LCO 3.8.3 states in part One or more DGs with required air receiver bank pressure $200 psig. Please confirm that required air receiver bank means both the primary and reserve air receiver bank for each DG. | |||
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:20 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 62 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1691 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 63 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2301 NRC Question RW001 Number Select Licensee Response Application | |||
Therefore, the | ===Response=== | ||
2/25/2010 10:45 AM Date/Time Closure Statement Response The Kewaunee design includes both primary and reserve air receiver Statement banks for each diesel generator. As stated in the Background section of the ITS Bases (last paragraph on Page 120), each primary and reserve air receiver bank has the capacity to start the DG and provide air to operate the DG room ventilation dampers. However, only one air receiver bank is normally in service. Therefore, as stated in the LCO section of the ITS Bases last paragraph of LCO section on Page 121), only one of the two air receiver banks is required for OPERABILITY of the associated DG. | |||
Condition F is entered when the required (in service) air receiver bank for a DG is inoperable. | |||
If the primary air receiver bank is in service, the primary bank is the "required air receiver bank." If the reserve air receiver bank is in service, the reserve bank is the "required air receiver bank." For the air receiver bank to be considered the "required air receiver bank" it must be in service (aligned to supply starting air to the DG). | |||
Therefore, "required air receiver bank" does NOT mean both the primary and reserve air receiver bank. | |||
The use of the term "required" in the ISTS implies that there are more installed components than are required by the LCO. In this case, there are two air receiver banks for each DG, and only one is required to be OPERABLE. The use of the term "required" is described in TSTF-GG 01, Writer's Guide for Plant-Specific Improved Technical Specifications, Section 4.1.3.b. The ISTS (i.e., NUREG-1431) uses this term in many places in the ISTS. For example, ISTS LCO 3.8.7, including Condition A, uses the term "required." | |||
However, KPS noted that the LCO Bases does not specifically state that the required air receiver bank must be in service; it only implies it with the word OPERABLE. For clarity, the ITS LCO Bases will be modified to clarify that OPERABLE means in service and within the pressure limit. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment. | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 63 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2301 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 64 of 90 Question Closure Date Attachment RW-001 Markup.pdf (718KB) 1 Attachment 2 | |||
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:51 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 64 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2301 06/07/2010 | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 65 of 90 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U 1 SAFETY 14 analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems 2 4 | |||
are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems. | |||
ing Air Since diesel fuel oil, lube oil, and the air start subsystem support the 3 operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). rated LCO for each DG Stored diesel fuel oil is required to have sufficient supply for 7 days of full 1 load operation. It is also required to meet specific standards for quality. | |||
Additionally, sufficient lubricating oil supply must be available to ensure each DG at rated the capability to operate at full load for 7 days. This requirement, in 1 conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of DGs required to shut down the reactor and to The Starting Air System for each DG maintain it in a safe condition for an anticipated operational occurrence is required to have a capacity to start (AOO) or a postulated DBA with loss of offsite power. DG day tank fuel s and operate the DG. Thus, the air compressor is required to be s requirements, as well as transfer capability from the storage tank to the 1 OPERABLE, as well as one of the day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and two air receiver banks is required to be OPERABLE and within the LCO 3.8.2, "AC Sources - Shutdown." | |||
pressure limit. | |||
The starting air system is required to have a minimum capacity for five 1 4 | |||
) | |||
(i.e., in service successive DG start attempts without recharging the air start receivers. | |||
APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated DG is required to be OPERABLE. | |||
ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required WOG STS B 3.8.3-2 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 65 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 66 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3061 NRC Question RW001 Number Select Licensee Response Application | |||
===Response=== | |||
5/18/2010 9:05 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure requirements are being deleted from the ITS submittal. | |||
Therefore, all references to the air receivers are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004. | |||
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:08 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 66 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3061 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 67 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3221 NRC Question RW001 Number Select Licensee Response Application | |||
A. | ===Response=== | ||
5/25/2010 12:10 PM Date/Time Closure Statement Response Note that the draft markup provided as an attachment to the KPS first Statement response to this RAI has been superseded by the draft markup described in the KPS second response to this RAI and attached to the third response to RAI GMW-004. | |||
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/25/2010 12:09 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 67 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3221 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 68 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3161 NRC Question RW001 Number Select Application NRC Question Closure | |||
===Response=== | |||
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. | |||
===Response=== | |||
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:54 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 68 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3161 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 69 of 90 ITS NRC Questions Id 1701 NRC Question RW002 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number L-3 JFD Number JFD Bases Number Page Number Attachment 1, Volume 13, Rev. 0, Page 112 of 289 (s) | |||
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N | |||
Requested NRC Question L03 states in part The purpose of the air receiver bank pressure requirement is to ensure adequate starting air is available for OPERABILITY of the DGs. For KPS, the DGs are also dependent upon air for operation of the DG room ventilation system. | |||
The KPS USAR states in Section 8.2.3.1 Primary and reserve tanks of the air receivers supply compressed air to the associated EDG Air Start System, the EDG cooling water isolation valve actuators, and the EDG Vent intake, recirculation, and exhaust damper actuators. | |||
Please explain why the supply of compressed air from the air receivers to the EDG cooling water isolation valve actuators is not mentioned in L03 and not mentioned as one of the air consumers in the referenced analysis in L03. | |||
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:25 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 69 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1701 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 70 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2311 NRC Question RW002 Number Select Licensee Response Application | |||
===Response=== | |||
2/25/2010 10:50 AM Date/Time Closure Statement | |||
===Response=== | |||
Statement The EDG cooling water isolation valve actuator does not use air when the DG is running. When the DG reaches 200 RPM during startup, a signal is sent to a 3-way solenoid valve, which isolates air to the EDG cooling water isolation valve actuator and vents the air from the actuator. When the air is vented from the 3-way valve, the EDG cooling water isolation valve relies on the force of a spring to open the valve. Air is only needed to maintain the valve in the closed position when the DG is not running. The EDG cooling water isolation valve actuator does not consume air while the DG is running and therefore is not included as an air consumer during safety related analysis. Furthermore, the EDG cooling water isolation valve fails open on a loss of air, which is the required position when the EDG is in operation. | |||
Logic drawing E-1633 (attached to this response) shows the operation of the EDG cooling water isolation valve. | |||
Question Closure Date Attachment RW-002 information.pdf (259KB) 1 Attachment 2 | |||
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:54 AM Modified By Ray Schiele Date 2/25/2010 11:11 AM Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 70 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2311 06/07/2010 | |||
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Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 71 of 90 | |||
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~- AE Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 71 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 72 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3071 NRC Question RW002 Number Select Licensee Response Application | |||
===Response=== | |||
5/18/2010 9:10 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure and air compressor requirements are being deleted from the ITS submittal. Therefore, all references to the air receivers and the compressors are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004. | |||
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:10 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 72 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3071 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 73 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3171 NRC Question RW002 Number Select Application NRC Question Closure | |||
===Response=== | |||
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. | |||
===Response=== | |||
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:54 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 73 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3171 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 74 of 90 ITS NRC Questions Id 1711 NRC Question RW003 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Attachment 1, Volume 13, Rev. 0, Page 118 of 289 Number(s) | |||
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N | |||
Requested NRC Question Justification 5 states in part The KPS CTS does not include any requirements for the Starting Air Systems. Thus, as long as enough air is in each required air start receiver bank to start the DG one time, the pressure is acceptable. | |||
The KPS USAR indicates that the Starting Air System has multiple start capability. Section 8.2.3.1 states: | |||
Each diesel generator is automatically started by either one of two pairs of air motors mounted on each side of the diesel (four air motors per engine). Each unit has its own independent starting system including a bank of four air storage tanks, two primary and reserve tanks, and one compressor powered from the 480V emergency bus. An air cooler/dryer is installed on the discharge of each air start system compressor. The dry air improves the starting performance of the diesel engine. The primary or reserve tanks have sufficient storage to crank the engine for twenty seconds. The diesel generator is capable of being started and ready to accept load in ten seconds. | |||
Starting air is admitted from the air start receivers to the starting system through a pressure-reducing valve to supply air to the air starter motors. | |||
The following describes a typical diesel engine start sequence. The sequence stated assumes the air start motor priority selector switch is in Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 74 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1711 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 75 of 90 the #1 position. The air start motor priority selector switch is typically rotated from set #1 to set #2 on a monthly basis. This ensures even run time on the air start motors. | |||
When the diesel start signal is initiated, a start attempt is made through air start motor set #1. If the air start motor set #1 fails to engage within 2 seconds, a second start attempt is made with the same set of motors. If the air start motors still do not engage, and then after 5 seconds a third start attempt is made, this time using the second pair of air start motors (set #2). Air start motors set #2 will continue to attempt to start the diesel generator on a two second cycle, until the engine starts or 15 seconds after the start signal, whichever occurs first. The start signal also initiates starting of the fuel priming pump and the governor booster pump. If, after fifteen seconds, the diesel has not reached 200 rpm, a start failure signal opens the fault relay. Starting air is cut off, the fuel priming and governor booster pump are stopped. Operator action is then required for further start attempts. | |||
The ITS is not consistent with the USAR regarding the number of DG starts from the Starting Air System. Please explain. | |||
Attach File 1 | |||
Attach File 2 | |||
Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:28 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 75 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1711 06/07/2010 | |||
2 | Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 76 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2321 NRC Question RW003 Number Select Licensee Response Application | ||
within the | ===Response=== | ||
2/25/2010 10:55 AM Date/Time Closure Statement Response The following two paragraphs are from USAR Section 8.2.3.1 and Statement referenced in RW-003: | |||
"The following describes a typical diesel engine start sequence. The sequence stated assumes the air start motor priority selector switch is in the #1 position. The air start motor priority selector switch is typically rotated from set #1 to set #2 on a monthly basis. This ensures even run time on the air start motors. | |||
When the diesel start signal is initiated, a start attempt is made through air start motor set #1. If the air start motor set #1 fails to engage within 2 seconds, a second start attempt is made with the same set of motors. If the air start motors still do not engage, and then after 5 seconds a third start attempt is made, this time using the second pair of air start motors (set #2). | |||
Air start motors set #2 will continue to attempt to start the diesel generator on a two second cycle, until the engine starts or 15 seconds after the start signal, whichever occurs first. The start signal also initiates starting of the fuel priming pump and the governor booster pump. If, after fifteen seconds, the diesel has not reached 200 rpm, a start failure signal opens the fault relay. Starting air is cut off, the fuel priming and governor booster pump are stopped. Operator action is then required for further start attempts." | |||
The above USAR description does NOT describe multiple starts of the DG engine, but the process of the air start motors attempting to engage the DG engine flywheel ring gear to begin starting the DG engine (cranking the engine). | |||
The DG engine start (cracking the engine) does not begin until a set of air start motors are engaged with the DG engine flywheel ring gear and the engine begins rotating (cranking). The air start motor sequence discussed above describes how the air start motors alternate in their attempt to engage the DG engine flywheel ring gear. Once a set of air start motors has engaged the DG engine flywheel ring gear the DG engine will be "cranked" until the DG engine starts or 15 seconds has elapsed since the start signal was initiated. | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 76 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2321 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 77 of 90 Question Closure Date Attachment 1 | |||
Attachment 2 | |||
: | Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:56 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 77 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2321 06/07/2010 | ||
: | |||
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 78 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2781 NRC Question RW003 Number Select Licensee Response Application | |||
===Response=== | |||
4/13/2010 3:15 PM Date/Time Closure Statement | |||
is | ===Response=== | ||
Statement This response supplements the first response to this RAI. | |||
The design basis for the EDG air start system (as described in the previous response) is that the primary or reserve tanks must have sufficient storage to crank the diesel engine for 20 seconds. At the time of the EDG start, the minimum pressure in the tanks supplying the starting air is 200 psig. | |||
KPS Procedures KW-PROC-TEC-OSP-DGE-003A and B, Diesel Generator A and B Semi-Annual Fast Start Test, demonstrate capability of EDG A and B, respectively, to automatically start and reach rated speed and voltage within 10 seconds per CTS 4.6 Basis, Regulatory Guide 1.9, and IEEE 387-1977, paragraph 6.4.1. In reviewing completed tests, the voltage and frequency acceptance criteria are being met in 6 to 7 seconds. The tests are being performed with the primary air start banks aligned (normal alignment) to supply the air start motors and the reserve air start banks isolated. | |||
Data was collected per Calculation C10021, Method for Determining Diesel Generator Damper Operation Times After Loss of Air-Start Compressors (dated 9/9/2009), from the 2005 and 2006 EDG A and B Semi-Annual Fast Start Tests. Data was also collected during the 2004 Station Blackout Tests. Recorders were used to determine the time for the EDGs to reach 200 RPM during a startup. At 200 RPM, a speed switch isolates starting air to the EDG air start motors, as the EDG has obtained the necessary speed to be started. The data indicated that the EDGs reached 200 RPM in 1.6 to 1.8 seconds, when the EDG was cold started. A hot start was documented for A EDG, and the time to reach 200 RPM was recorded as 2.1 seconds. | |||
From ESI-EMD Owners Group Position, 5-Start Criteria (dated 1/23/2004), it states that a 3 second cranking cycle matches the typical cranking time for a normal successful start of the large diesel engines common in nuclear service. This is consistent with the data collected for Calculation C10021. | |||
The design basis for the air start system is 20 seconds of cranking time from either the primary or reserve tanks. From data collected for Calculation C10021, the worst case start time to reach 200 RPM was 2.1 seconds during a hot start. Although a five start test has not been Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 78 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2781 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 79 of 90 conducted at KPS, there is reasonable assurance, based upon empirical and design data that the EDGs can be successfully started five times using one air start bank (primary or reserve) with the air start bank pressure initially at 200 psig. | |||
Question Closure Date Attachment 1 | |||
Attachment 2 | |||
Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 4/13/2010 3:16 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 79 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2781 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 80 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3081 NRC Question RW003 Number Select Licensee Response Application | |||
===Response=== | |||
5/18/2010 9:05 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure requirements are being deleted from the ITS submittal. | |||
Therefore, all references to the air receivers are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004. | |||
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:12 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 80 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3081 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 81 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3181 NRC Question RW003 Number Select Application NRC Question Closure | |||
===Response=== | |||
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. | |||
===Response=== | |||
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:56 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 81 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3181 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 82 of 90 ITS NRC Questions Id 1721 NRC Question RW004 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number L-3 JFD Number JFD Bases Number Page Number Attachment 1, Volume 13, Rev. 0, Page 116 of 289 (s) | |||
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N | |||
Requested NRC Question Required Action E.2 states The cross-tie between the DG Starting Air Systems may be intermittently opened under administrative control to achieve and maintain the inoperable Starting Air System air receiver banks pressure $200 psig. | |||
The terms intermittently and administrative control are vague. | |||
Please provide a detailed description as to what these terms mean in this case. | |||
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:32 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 82 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1721 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 83 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2331 NRC Question RW004 Number Select Licensee Response Application | |||
===Response=== | |||
2/25/2010 10:55 AM Date/Time Closure Statement Response The two terms are described in the ITS Bases for the Required Action E.2 Statement Note. The Bases states (Page 124, INSERT 1, second paragraph) that: | |||
"These administrative controls consist of stationing a dedicated operator at the DG starting Air System cross-connect valve for the OPERABLE DG, who is in continuous communication with the control room. In this way, the OPERABLE Starting Air System can be isolated from the inoperable Starting Air System if a need for isolation is indicated." | |||
Furthermore, the Bases states: "The time the cross-connect valves are opened should be minimized." This statement controls the "intermittent" requirement specified in the Note. Since the requirement the ITS 3.8.3 Note is modifying states to maintain pressure in both air receiver banks is > 200 psig, the cross-tie valves would be opened only to maintain this pressure. | |||
That is, the cross-tie valves would be opened intermittently to recharge the air receiver banks associated with the inoperable air compressor back to nominal pressure, and then re-closed. | |||
Kewaunee based the use of these two terms on their use in ISTS LCO 3.6.3. This Specification requires containment isolation valves to be OPERABLE. Note 1 to the ACTIONS allows certain penetration flow paths to be unisolated "intermittently" under "administrative controls" (Volume 11, Page 71). Unisolating the valves in these penetration flow paths makes the associated containment isolation valves inoperable. The Bases for the Note (Page 86, first paragraph of the ACTIONS) describes "administrative controls" in a similar manner (i.e., a dedicated operator at the valve controls, who is in continuous communication with the control room) as Kewaunee proposes for the ITS 3.8.3 Required Action E.2 Note. | |||
Furthermore, the term "intermittently" is not clarified in the ISTS Bases - | |||
the meaning and application is left for licensee interpretation. | |||
Therefore, Kewaunee believes that use of the two terms is consistent with the use already approved by the NRC in other locations in NUREG-1431. | |||
The NRC's position in the NUREGs is that administrative controls and intermittent can be defined either in the Bases or in another location outside of Technical Specification. | |||
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 83 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2331 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 84 of 90 Question Closure Date Attachment 1 | |||
Attachment 2 | |||
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:59 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 84 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2331 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 85 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3091 NRC Question RW004 Number Select Licensee Response Application | |||
===Response=== | |||
5/18/2010 9:15 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure and air compressor requirements are being deleted from the ITS submittal. Therefore, all references to the air receivers and compressors are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004. | |||
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:14 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 85 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3091 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 86 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3191 NRC Question RW004 Number Select Application NRC Question Closure | |||
===Response=== | |||
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. | |||
24 | ===Response=== | ||
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:57 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 86 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3191 06/07/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 87 of 90 ITS NRC Questions Id 1831 NRC Question RW005 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Number Attachment 1, Volume 13, Rev. 0, Page 118 of 289 (s) | |||
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N | |||
Requested NRC Question Assuming the DG starts on the first attempt every time (i.e. the air start motors engage every time on the first attempt), how many DG starts can be made from one air receiver bank starting at the minimum allowable TS pressure set point? | |||
Attach File 1 Attach File 2 Issue Date 3/1/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 3/1/2010 6:55 AM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 87 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1831 07/08/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 88 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2511 NRC Question RW005 Number Select Licensee Response Application | |||
=== | ===Response=== | ||
3/10/2010 7:10 AM Date/Time Closure Statement Response Kewaunee Power Station (KPS) does not have any test data or analysis that Statement supports starting of the EDG more than one time for each receiver bank. | |||
KPS licensing basis indicates that the EDG start up air receivers were sized such that the EDG could be cranked for at least 20 seconds with the volume of air in the receivers and this was demonstrated in pre-op testing. | |||
KPS does not currently have any requirement to start the EDG multiple times; the accident analysis assumes one DG starts on the first attempt and the other DG fails to start. No credit is then taken in the analysis for further attempting to start the failed DG. Therefore, KPS has not analyzed the scenario nor tested the scenario posed by the NRC reviewer's question The 200 psig minimum pressure provided in ITS SR 3.8.3.4 ensures the design basis of the starting air system (as described above) is met. It also ensures sufficient air is available to start the DG one time and operate it for at least 48 hours without recharging, as described in Discussion of Change L03 (pages 112 and 113). Furthermore, the normal air pressure of the in-service air receiver bank is 220-240 psig, which is well above the minimum required by the SR. | |||
Question Closure Date Attachment 1 | |||
Attachment 2 | |||
Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Ray Schiele Robert Wolfgang Added By Robert Hanley Date Added 3/10/2010 7:09 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 88 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2511 07/08/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 89 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3101 NRC Question RW005 Number Select Licensee Response Application | |||
===Response=== | |||
5/18/2010 9:15 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure requirements are being deleted from the ITS submittal. | |||
Therefore, all references to the air receivers are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004. | |||
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:16 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 89 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3101 07/08/2010 | |||
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 90 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3391 NRC Question RW005 Number Select Application NRC Question Closure | |||
===Response=== | |||
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. | |||
=== | ===Response=== | ||
Statement Question Closure 6/3/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Gerald Waig Robert Wolfgang Added By Robert Wolfgang Date Added 6/3/2010 12:10 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 90 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3391 07/08/2010}} | |||
Latest revision as of 15:04, 21 March 2020
| 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) | |
Text
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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. M01 and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />
- 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE.
- 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
- 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion 3
Time not met. AND C D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time DC electrical power subsystem is provides for returning the inoperable charger to OPERABLE status or OPERABLE. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler providing an alternate means of restoring battery terminal voltage to maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 ;
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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status. INSERT 1 3 DOC M01 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler All changes are 1 Inverters - Operating maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. instrument Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE. M03 M03 ACTION E 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate action, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE.
ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.
instrument 1
DOC M02 B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to (es) instrument OPERABLE status.
DOC L01 2 C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The ACTIONS are modified by a Note that allows a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. M01 and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />
- 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE.
- 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
- 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion 3
Time not met. AND C D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time DC electrical power subsystem is provides for returning the inoperable charger to OPERABLE status or OPERABLE. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler providing an alternate means of restoring battery terminal voltage to maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 ;
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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status. INSERT 1 3 DOC M01 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler All changes are 1 Inverters - Operating maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. instrument Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE. M03 M03 ACTION E 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 34 of 90 Page 2 of 2
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 35 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 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate action, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE.
ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 35 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 36 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 36 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 37 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 37 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 38 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.
instrument 1
DOC M02 B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to (es) instrument OPERABLE status.
DOC L01 2 C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 38 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 39 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 39 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 40 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The ACTIONS are modified by a Note that allows a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 40 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 41 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3801 NRC Question MEH-009 Number Select Licensee Response Application
Response
7/15/2010 10:40 AM Date/Time Closure Statement Response In the previous (second) response to this question (dated 6/28/2010), KPS Statement provided a draft markup of 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with the associated components covered by the LCO inoperable due to a non-functional room cooler. This change included a requirement to monitor the room temperature on an hourly basis to ensure the temperature was maintained within the design environmental requirements. In a subsequent phone call with the NRC reviewer, he requested that KPS look at the Note restrictions, and include the value of the design temperature limit in the ITS Bases. KPS has reviewed the monitoring requirements and has decided to include the actual design temperature value in the ITS Bases (120 degrees F). 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 2.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 7/15/2010 10:41 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 41 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3801 07/19/2010
Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 42 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. M01 and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />
- 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE.
- 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
- 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 42 of 90 Page 2 of 2
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 43 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 43 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 44 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. This changes the CTS by allowing a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 44 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 45 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the associated room temperature is monitored and maintained within the design environmental requirements and 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion 3
Time not met. AND C D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 45 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 46 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 46 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 47 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time DC electrical power subsystem is provides for returning the inoperable charger to OPERABLE status or OPERABLE. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler providing an alternate means of restoring battery terminal voltage to maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 of 120°F 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 47 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 48 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 ;
DOC M01 APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS INSERT 1A 7 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status. INSERT 1 3 DOC M01 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 48 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 49 of 90 CTS 3.8.7 3 INSERT 1 DOC M01 B. Two inverters in one B.1 Restore one inverter to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the associated room temperature is monitored and maintained within the design environmental requirements and 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 49 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 50 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 50 of 90
The ACTIONS are modified by a Note that allows a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay in entering the ACTIONS Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 51 of 90 when 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler All changes are 1 Inverters - Operating maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 of 120°F during this time.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. instrument Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 51 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 52 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 52 of 90 Page 1 of 2
Enclosure (4 of 4), Q&A to Attachment 1,A01Volume 13 (Section 3.8) Page 53 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to achieve MODE 3 HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE. M03 M03 ACTION E 7. Two diesel generators may be inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 53 of 90 Page 2 of 2
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 54 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 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate action, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant bus and its loads remain OPERABLE.
ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 54 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 55 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 55 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 56 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> solely due to a room cooler being non-functional and not require the ACTIONS to be entered, 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. This changes the CTS by allowing a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> deferral in entering associated ACTIONS when an 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 56 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 57 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the associated room temperature is monitored and maintained 5 within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE .
ACTIONS --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to OPERABLE status.
instrument 1
DOC M02 B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to (es) instrument OPERABLE status.
DOC L01 2 C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 57 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 58 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Historically, room cooler maintenance has been completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 58 of 90
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 59 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The ACTIONS are modified by a Note that allows a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance is provided in order to perform room cooler maintenance. If during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 of 120°F during this time.
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 59 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 60 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3871 NRC Question MEH-009 Number Select Licensee Response Application
Response
7/16/2010 11:45 AM Date/Time Closure Statement Response During a discussion with the NRC staff concerning the environmental temperature Statement limits for the rooms specified in the MEH-009 markup posted on 7/15/2010 the staff requested DEK ensure the temperature limits are included in Kewaunees USAR. DEK commits to including the vital switchgear and the battery rooms temperature limits in the USAR. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Gerald Waig Added By Robert Hanley Date Added 7/16/2010 11:45 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 60 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3871 07/19/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 61 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3921 NRC Question MEH-009 Number Select NRC Question Closure Application
Response
Date/Time Closure Based on the 7/16/2010 resonse to the MEH-009, this question is closed and no further Statement information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 7/20/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Waig Date Added 7/20/2010 2:54 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 61 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3921 07/20/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 62 of 90 ITS NRC Questions Id 1691 NRC Question RW001 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases 5
Number Page Number Volume 13, Page 117 of 289 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question Condition F of LCO 3.8.3 states in part One or more DGs with required air receiver bank pressure $200 psig. Please confirm that required air receiver bank means both the primary and reserve air receiver bank for each DG.
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:20 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 62 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1691 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 63 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2301 NRC Question RW001 Number Select Licensee Response Application
Response
2/25/2010 10:45 AM Date/Time Closure Statement Response The Kewaunee design includes both primary and reserve air receiver Statement banks for each diesel generator. As stated in the Background section of the ITS Bases (last paragraph on Page 120), each primary and reserve air receiver bank has the capacity to start the DG and provide air to operate the DG room ventilation dampers. However, only one air receiver bank is normally in service. Therefore, as stated in the LCO section of the ITS Bases last paragraph of LCO section on Page 121), only one of the two air receiver banks is required for OPERABILITY of the associated DG.
Condition F is entered when the required (in service) air receiver bank for a DG is inoperable.
If the primary air receiver bank is in service, the primary bank is the "required air receiver bank." If the reserve air receiver bank is in service, the reserve bank is the "required air receiver bank." For the air receiver bank to be considered the "required air receiver bank" it must be in service (aligned to supply starting air to the DG).
Therefore, "required air receiver bank" does NOT mean both the primary and reserve air receiver bank.
The use of the term "required" in the ISTS implies that there are more installed components than are required by the LCO. In this case, there are two air receiver banks for each DG, and only one is required to be OPERABLE. The use of the term "required" is described in TSTF-GG 01, Writer's Guide for Plant-Specific Improved Technical Specifications, Section 4.1.3.b. The ISTS (i.e., NUREG-1431) uses this term in many places in the ISTS. For example, ISTS LCO 3.8.7, including Condition A, uses the term "required."
However, KPS noted that the LCO Bases does not specifically state that the required air receiver bank must be in service; it only implies it with the word OPERABLE. For clarity, the ITS LCO Bases will be modified to clarify that OPERABLE means in service and within the pressure limit. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 63 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2301 06/07/2010
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 64 of 90 Question Closure Date Attachment RW-001 Markup.pdf (718KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:51 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 64 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2301 06/07/2010
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 65 of 90 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U 1 SAFETY 14 analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems 2 4
are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.
ing Air Since diesel fuel oil, lube oil, and the air start subsystem support the 3 operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). rated LCO for each DG Stored diesel fuel oil is required to have sufficient supply for 7 days of full 1 load operation. It is also required to meet specific standards for quality.
Additionally, sufficient lubricating oil supply must be available to ensure each DG at rated the capability to operate at full load for 7 days. This requirement, in 1 conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of DGs required to shut down the reactor and to The Starting Air System for each DG maintain it in a safe condition for an anticipated operational occurrence is required to have a capacity to start (AOO) or a postulated DBA with loss of offsite power. DG day tank fuel s and operate the DG. Thus, the air compressor is required to be s requirements, as well as transfer capability from the storage tank to the 1 OPERABLE, as well as one of the day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and two air receiver banks is required to be OPERABLE and within the LCO 3.8.2, "AC Sources - Shutdown."
pressure limit.
The starting air system is required to have a minimum capacity for five 1 4
)
(i.e., in service successive DG start attempts without recharging the air start receivers.
APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air are required to be within limits when the associated DG is required to be OPERABLE.
ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required WOG STS B 3.8.3-2 Rev. 3.0, 03/31/04 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 65 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 66 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3061 NRC Question RW001 Number Select Licensee Response Application
Response
5/18/2010 9:05 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure requirements are being deleted from the ITS submittal.
Therefore, all references to the air receivers are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:08 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 66 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3061 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 67 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3221 NRC Question RW001 Number Select Licensee Response Application
Response
5/25/2010 12:10 PM Date/Time Closure Statement Response Note that the draft markup provided as an attachment to the KPS first Statement response to this RAI has been superseded by the draft markup described in the KPS second response to this RAI and attached to the third response to RAI GMW-004.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/25/2010 12:09 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 67 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3221 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 68 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3161 NRC Question RW001 Number Select Application NRC Question Closure
Response
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:54 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 68 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3161 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 69 of 90 ITS NRC Questions Id 1701 NRC Question RW002 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number L-3 JFD Number JFD Bases Number Page Number Attachment 1, Volume 13, Rev. 0, Page 112 of 289 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question L03 states in part The purpose of the air receiver bank pressure requirement is to ensure adequate starting air is available for OPERABILITY of the DGs. For KPS, the DGs are also dependent upon air for operation of the DG room ventilation system.
The KPS USAR states in Section 8.2.3.1 Primary and reserve tanks of the air receivers supply compressed air to the associated EDG Air Start System, the EDG cooling water isolation valve actuators, and the EDG Vent intake, recirculation, and exhaust damper actuators.
Please explain why the supply of compressed air from the air receivers to the EDG cooling water isolation valve actuators is not mentioned in L03 and not mentioned as one of the air consumers in the referenced analysis in L03.
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:25 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 69 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1701 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 70 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2311 NRC Question RW002 Number Select Licensee Response Application
Response
2/25/2010 10:50 AM Date/Time Closure Statement
Response
Statement The EDG cooling water isolation valve actuator does not use air when the DG is running. When the DG reaches 200 RPM during startup, a signal is sent to a 3-way solenoid valve, which isolates air to the EDG cooling water isolation valve actuator and vents the air from the actuator. When the air is vented from the 3-way valve, the EDG cooling water isolation valve relies on the force of a spring to open the valve. Air is only needed to maintain the valve in the closed position when the DG is not running. The EDG cooling water isolation valve actuator does not consume air while the DG is running and therefore is not included as an air consumer during safety related analysis. Furthermore, the EDG cooling water isolation valve fails open on a loss of air, which is the required position when the EDG is in operation.
Logic drawing E-1633 (attached to this response) shows the operation of the EDG cooling water isolation valve.
Question Closure Date Attachment RW-002 information.pdf (259KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:54 AM Modified By Ray Schiele Date 2/25/2010 11:11 AM Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 70 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2311 06/07/2010
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Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 72 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3071 NRC Question RW002 Number Select Licensee Response Application
Response
5/18/2010 9:10 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure and air compressor requirements are being deleted from the ITS submittal. Therefore, all references to the air receivers and the compressors are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:10 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 72 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3071 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 73 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3171 NRC Question RW002 Number Select Application NRC Question Closure
Response
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:54 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 73 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3171 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 74 of 90 ITS NRC Questions Id 1711 NRC Question RW003 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Attachment 1, Volume 13, Rev. 0, Page 118 of 289 Number(s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question Justification 5 states in part The KPS CTS does not include any requirements for the Starting Air Systems. Thus, as long as enough air is in each required air start receiver bank to start the DG one time, the pressure is acceptable.
The KPS USAR indicates that the Starting Air System has multiple start capability. Section 8.2.3.1 states:
Each diesel generator is automatically started by either one of two pairs of air motors mounted on each side of the diesel (four air motors per engine). Each unit has its own independent starting system including a bank of four air storage tanks, two primary and reserve tanks, and one compressor powered from the 480V emergency bus. An air cooler/dryer is installed on the discharge of each air start system compressor. The dry air improves the starting performance of the diesel engine. The primary or reserve tanks have sufficient storage to crank the engine for twenty seconds. The diesel generator is capable of being started and ready to accept load in ten seconds.
Starting air is admitted from the air start receivers to the starting system through a pressure-reducing valve to supply air to the air starter motors.
The following describes a typical diesel engine start sequence. The sequence stated assumes the air start motor priority selector switch is in Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 74 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1711 06/07/2010
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 75 of 90 the #1 position. The air start motor priority selector switch is typically rotated from set #1 to set #2 on a monthly basis. This ensures even run time on the air start motors.
When the diesel start signal is initiated, a start attempt is made through air start motor set #1. If the air start motor set #1 fails to engage within 2 seconds, a second start attempt is made with the same set of motors. If the air start motors still do not engage, and then after 5 seconds a third start attempt is made, this time using the second pair of air start motors (set #2). Air start motors set #2 will continue to attempt to start the diesel generator on a two second cycle, until the engine starts or 15 seconds after the start signal, whichever occurs first. The start signal also initiates starting of the fuel priming pump and the governor booster pump. If, after fifteen seconds, the diesel has not reached 200 rpm, a start failure signal opens the fault relay. Starting air is cut off, the fuel priming and governor booster pump are stopped. Operator action is then required for further start attempts.
The ITS is not consistent with the USAR regarding the number of DG starts from the Starting Air System. Please explain.
Attach File 1
Attach File 2
Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:28 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 75 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1711 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 76 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2321 NRC Question RW003 Number Select Licensee Response Application
Response
2/25/2010 10:55 AM Date/Time Closure Statement Response The following two paragraphs are from USAR Section 8.2.3.1 and Statement referenced in RW-003:
"The following describes a typical diesel engine start sequence. The sequence stated assumes the air start motor priority selector switch is in the #1 position. The air start motor priority selector switch is typically rotated from set #1 to set #2 on a monthly basis. This ensures even run time on the air start motors.
When the diesel start signal is initiated, a start attempt is made through air start motor set #1. If the air start motor set #1 fails to engage within 2 seconds, a second start attempt is made with the same set of motors. If the air start motors still do not engage, and then after 5 seconds a third start attempt is made, this time using the second pair of air start motors (set #2).
Air start motors set #2 will continue to attempt to start the diesel generator on a two second cycle, until the engine starts or 15 seconds after the start signal, whichever occurs first. The start signal also initiates starting of the fuel priming pump and the governor booster pump. If, after fifteen seconds, the diesel has not reached 200 rpm, a start failure signal opens the fault relay. Starting air is cut off, the fuel priming and governor booster pump are stopped. Operator action is then required for further start attempts."
The above USAR description does NOT describe multiple starts of the DG engine, but the process of the air start motors attempting to engage the DG engine flywheel ring gear to begin starting the DG engine (cranking the engine).
The DG engine start (cracking the engine) does not begin until a set of air start motors are engaged with the DG engine flywheel ring gear and the engine begins rotating (cranking). The air start motor sequence discussed above describes how the air start motors alternate in their attempt to engage the DG engine flywheel ring gear. Once a set of air start motors has engaged the DG engine flywheel ring gear the DG engine will be "cranked" until the DG engine starts or 15 seconds has elapsed since the start signal was initiated.
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 76 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2321 06/07/2010
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 77 of 90 Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:56 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 77 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2321 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 78 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2781 NRC Question RW003 Number Select Licensee Response Application
Response
4/13/2010 3:15 PM Date/Time Closure Statement
Response
Statement This response supplements the first response to this RAI.
The design basis for the EDG air start system (as described in the previous response) is that the primary or reserve tanks must have sufficient storage to crank the diesel engine for 20 seconds. At the time of the EDG start, the minimum pressure in the tanks supplying the starting air is 200 psig.
KPS Procedures KW-PROC-TEC-OSP-DGE-003A and B, Diesel Generator A and B Semi-Annual Fast Start Test, demonstrate capability of EDG A and B, respectively, to automatically start and reach rated speed and voltage within 10 seconds per CTS 4.6 Basis, Regulatory Guide 1.9, and IEEE 387-1977, paragraph 6.4.1. In reviewing completed tests, the voltage and frequency acceptance criteria are being met in 6 to 7 seconds. The tests are being performed with the primary air start banks aligned (normal alignment) to supply the air start motors and the reserve air start banks isolated.
Data was collected per Calculation C10021, Method for Determining Diesel Generator Damper Operation Times After Loss of Air-Start Compressors (dated 9/9/2009), from the 2005 and 2006 EDG A and B Semi-Annual Fast Start Tests. Data was also collected during the 2004 Station Blackout Tests. Recorders were used to determine the time for the EDGs to reach 200 RPM during a startup. At 200 RPM, a speed switch isolates starting air to the EDG air start motors, as the EDG has obtained the necessary speed to be started. The data indicated that the EDGs reached 200 RPM in 1.6 to 1.8 seconds, when the EDG was cold started. A hot start was documented for A EDG, and the time to reach 200 RPM was recorded as 2.1 seconds.
From ESI-EMD Owners Group Position, 5-Start Criteria (dated 1/23/2004), it states that a 3 second cranking cycle matches the typical cranking time for a normal successful start of the large diesel engines common in nuclear service. This is consistent with the data collected for Calculation C10021.
The design basis for the air start system is 20 seconds of cranking time from either the primary or reserve tanks. From data collected for Calculation C10021, the worst case start time to reach 200 RPM was 2.1 seconds during a hot start. Although a five start test has not been Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 78 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2781 06/07/2010
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 79 of 90 conducted at KPS, there is reasonable assurance, based upon empirical and design data that the EDGs can be successfully started five times using one air start bank (primary or reserve) with the air start bank pressure initially at 200 psig.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 4/13/2010 3:16 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 79 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2781 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 80 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3081 NRC Question RW003 Number Select Licensee Response Application
Response
5/18/2010 9:05 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure requirements are being deleted from the ITS submittal.
Therefore, all references to the air receivers are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:12 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 80 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3081 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 81 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3181 NRC Question RW003 Number Select Application NRC Question Closure
Response
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:56 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 81 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3181 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 82 of 90 ITS NRC Questions Id 1721 NRC Question RW004 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number L-3 JFD Number JFD Bases Number Page Number Attachment 1, Volume 13, Rev. 0, Page 116 of 289 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question Required Action E.2 states The cross-tie between the DG Starting Air Systems may be intermittently opened under administrative control to achieve and maintain the inoperable Starting Air System air receiver banks pressure $200 psig.
The terms intermittently and administrative control are vague.
Please provide a detailed description as to what these terms mean in this case.
Attach File 1 Attach File 2 Issue Date 2/18/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 2/18/2010 1:32 PM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 82 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1721 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 83 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2331 NRC Question RW004 Number Select Licensee Response Application
Response
2/25/2010 10:55 AM Date/Time Closure Statement Response The two terms are described in the ITS Bases for the Required Action E.2 Statement Note. The Bases states (Page 124, INSERT 1, second paragraph) that:
"These administrative controls consist of stationing a dedicated operator at the DG starting Air System cross-connect valve for the OPERABLE DG, who is in continuous communication with the control room. In this way, the OPERABLE Starting Air System can be isolated from the inoperable Starting Air System if a need for isolation is indicated."
Furthermore, the Bases states: "The time the cross-connect valves are opened should be minimized." This statement controls the "intermittent" requirement specified in the Note. Since the requirement the ITS 3.8.3 Note is modifying states to maintain pressure in both air receiver banks is > 200 psig, the cross-tie valves would be opened only to maintain this pressure.
That is, the cross-tie valves would be opened intermittently to recharge the air receiver banks associated with the inoperable air compressor back to nominal pressure, and then re-closed.
Kewaunee based the use of these two terms on their use in ISTS LCO 3.6.3. This Specification requires containment isolation valves to be OPERABLE. Note 1 to the ACTIONS allows certain penetration flow paths to be unisolated "intermittently" under "administrative controls" (Volume 11, Page 71). Unisolating the valves in these penetration flow paths makes the associated containment isolation valves inoperable. The Bases for the Note (Page 86, first paragraph of the ACTIONS) describes "administrative controls" in a similar manner (i.e., a dedicated operator at the valve controls, who is in continuous communication with the control room) as Kewaunee proposes for the ITS 3.8.3 Required Action E.2 Note.
Furthermore, the term "intermittently" is not clarified in the ISTS Bases -
the meaning and application is left for licensee interpretation.
Therefore, Kewaunee believes that use of the two terms is consistent with the use already approved by the NRC in other locations in NUREG-1431.
The NRC's position in the NUREGs is that administrative controls and intermittent can be defined either in the Bases or in another location outside of Technical Specification.
Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 83 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2331 06/07/2010
Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 84 of 90 Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Robert Wolfgang Added By David Mielke Date Added 2/25/2010 10:59 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 84 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2331 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 85 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3091 NRC Question RW004 Number Select Licensee Response Application
Response
5/18/2010 9:15 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure and air compressor requirements are being deleted from the ITS submittal. Therefore, all references to the air receivers and compressors are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:14 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 85 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3091 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 86 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3191 NRC Question RW004 Number Select Application NRC Question Closure
Response
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 5/24/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members Victor Cusumano Gerald Waig Added By Robert Wolfgang Date Added 5/24/2010 4:57 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 86 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3191 06/07/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 87 of 90 ITS NRC Questions Id 1831 NRC Question RW005 Number Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Number Attachment 1, Volume 13, Rev. 0, Page 118 of 289 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question Assuming the DG starts on the first attempt every time (i.e. the air start motors engage every time on the first attempt), how many DG starts can be made from one air receiver bank starting at the minimum allowable TS pressure set point?
Attach File 1 Attach File 2 Issue Date 3/1/2010 Added By Robert Wolfgang Date Modified Modified By Date Added 3/1/2010 6:55 AM Notification NRC/LICENSEE Supervision Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 87 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1831 07/08/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 88 of 90 Licensee Response/NRC Response/NRC Question Closure Id 2511 NRC Question RW005 Number Select Licensee Response Application
Response
3/10/2010 7:10 AM Date/Time Closure Statement Response Kewaunee Power Station (KPS) does not have any test data or analysis that Statement supports starting of the EDG more than one time for each receiver bank.
KPS licensing basis indicates that the EDG start up air receivers were sized such that the EDG could be cranked for at least 20 seconds with the volume of air in the receivers and this was demonstrated in pre-op testing.
KPS does not currently have any requirement to start the EDG multiple times; the accident analysis assumes one DG starts on the first attempt and the other DG fails to start. No credit is then taken in the analysis for further attempting to start the failed DG. Therefore, KPS has not analyzed the scenario nor tested the scenario posed by the NRC reviewer's question The 200 psig minimum pressure provided in ITS SR 3.8.3.4 ensures the design basis of the starting air system (as described above) is met. It also ensures sufficient air is available to start the DG one time and operate it for at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> without recharging, as described in Discussion of Change L03 (pages 112 and 113). Furthermore, the normal air pressure of the in-service air receiver bank is 220-240 psig, which is well above the minimum required by the SR.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Ray Schiele Robert Wolfgang Added By Robert Hanley Date Added 3/10/2010 7:09 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 88 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2511 07/08/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 89 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3101 NRC Question RW005 Number Select Licensee Response Application
Response
5/18/2010 9:15 AM Date/Time Closure Statement Response Based on the latest KPS response to GMW-004 (third response), the air Statement receiver pressure requirements are being deleted from the ITS submittal.
Therefore, all references to the air receivers are being removed from the ITS submittal. Refer to the markup attached to the third response for GMW-004.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Gerald Waig Robert Wolfgang Added By Robert Hanley Date Added 5/18/2010 9:16 AM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 89 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3101 07/08/2010
Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 90 of 90 Licensee Response/NRC Response/NRC Question Closure Id 3391 NRC Question RW005 Number Select Application NRC Question Closure
Response
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
Response
Statement Question Closure 6/3/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Gerald Waig Robert Wolfgang Added By Robert Wolfgang Date Added 6/3/2010 12:10 PM Modified By Date Modified Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 90 of 90 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3391 07/08/2010