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p h p?re q uestT ype=areaItemPrint&itemId=3611 A01ITS ITS 3.8.4 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 | p h p?re q uestT ype=areaItemPrint&itemId=3611 A01ITS ITS 3.8.4 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 | ||
HOT STANDBY within the next 6 hours. | 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. | : 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 generator. | 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 other battery and two battery chargers remain OPERABLE with one charger | : 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 | ||
carrying the d-c supply system. | 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 | : 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. | 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. | : 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 24 hours provided the redundant bus and its loads remain OPERABLE. | : 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. | : 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 | : 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: | requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | : 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. | ||
Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. | Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. | ||
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Once per [12] hours | Once per [12] hours | ||
7 days | 7 days | ||
[B. One [or two] batter[y][ies on one train] inoperable. | [B. One [or two] batter[y][ies on one train] inoperable. | ||
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other DC electrical power subsystem is OPERABLE. | other DC electrical power subsystem is OPERABLE. | ||
------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------- | ||
6 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING | 6 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. | : 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. | : 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 d eleted since it is not necessary. | : 3. The bracketed ISTS 3.8.4 ACTION B has been d eleted 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. | 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. | : 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. | ||
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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 functi on from being performed (Ref. 4). | 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 functi on from being performed (Ref. 4). | ||
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 | and | ||
: b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | : b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | ||
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7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS | 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS | ||
3.8.7 Inverters - Operating | |||
- Operating | |||
LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. | LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. | ||
-------------------------------- | -------------------------------- | ||
-------------NOTE-------------------------------------------- | -------------NOTE-------------------------------------------- | ||
[ [One/two] inverter[s] may be disconnected from [its/their] associated DC form an equalizing charge on [its/their] associated [common] battery, provided: | |||
: a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using | : a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using | ||
internal AC source], and | internal AC source], and | ||
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------ | : b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------ | ||
-------------------------------------------------- | -------------------------------------------------- | ||
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AND | AND | ||
6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A | 6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. | ||
Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. | |||
B.1 Restore one inverter to OPERABLE status. | B.1 Restore one inverter to OPERABLE status. | ||
2 hours DOC M01 3 CTS INSERT 1A | 2 hours DOC M01 3 CTS INSERT 1A | ||
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------------------------------------------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------ | ||
7 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING | 7 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 | : 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. | 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. Kewaunee Power Station Page 1 of 1 | 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. Kewaunee Power Station Page 1 of 1 | ||
: 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 | : 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 | ||
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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 a. The reactor shall not be made critical unless all of the following requirements are satisfied: | SPECIFICATION M01 a. The reactor shall not be made critical unless all of the following requirements are satisfied: | ||
A pplicabilit y 1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses. | A pplicabilit y 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. | : 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | ||
: 3. The 4160-V buses 1-5 and 1-6 are both energized. | : 3. The 4160-V buses 1-5 and 1-6 are both energized. | ||
: 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | : 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | ||
: 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | : 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | ||
: 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | : 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | ||
: 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; 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. | ||
: 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: | ||
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. | A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. | ||
LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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 | LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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 | ||
HOT STANDBY within the next 6 hours. | 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. | : 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 generator. | 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 other battery and two battery chargers remain OPERABLE with one charger | : 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 | ||
carrying the d-c supply system. | 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 | : 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. | 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. | : 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 24 hours provided the redundant bus and its loads remain OPERABLE. | : 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. | : 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 | : 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: | requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | : 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. | ||
See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) | See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) | ||
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Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS | Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS | ||
3.8.9 Distribution Systems - Operating | |||
Systems - Operating | |||
LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. | LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. | ||
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maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other trai n are OPERABLE . | maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other trai n are OPERABLE . | ||
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ||
5 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING | 5 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. | : 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. | : 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. | : 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. Kewaunee Power Station Page 1 of 1 | : 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. Kewaunee Power Station Page 1 of 1 | ||
: 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 | : 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 | ||
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Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued) | Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued) | ||
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. electrical instrument APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that: | 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. electrical instrument 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 | : a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients | ||
and 3; | and 3; | ||
: 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 - | : 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 - | ||
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p h p?re q uestT ype=areaItemPrint&itemId=3621 A01ITS ITS 3.8.4 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 | p h p?re q uestT ype=areaItemPrint&itemId=3621 A01ITS ITS 3.8.4 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 | ||
HOT STANDBY within the next 6 hours. | 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. | : 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 generator. | 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 other battery and two battery chargers remain OPERABLE with one charger | : 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 | ||
carrying the d-c supply system. | 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 | : 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. | 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. | : 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 24 hours provided the redundant bus and its loads remain OPERABLE. | : 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. | : 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 | : 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: | requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | : 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. | ||
Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. | Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. | ||
Line 525: | Line 520: | ||
Once per [12] hours | Once per [12] hours | ||
7 days | 7 days | ||
[B. One [or two] batter[y][ies on one train] inoperable. | [B. One [or two] batter[y][ies on one train] inoperable. | ||
Line 549: | Line 544: | ||
other DC electrical power subsystem is OPERABLE. | other DC electrical power subsystem is OPERABLE. | ||
------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------- | ||
6 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING | 6 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. | : 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. | : 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 d eleted since it is not necessary. | : 3. The bracketed ISTS 3.8.4 ACTION B has been d eleted 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. | 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. | : 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. | ||
Line 587: | Line 582: | ||
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 functi on from being performed (Ref. 4). | 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 functi on from being performed (Ref. 4). | ||
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 | and | ||
: b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | : b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | ||
Line 628: | Line 623: | ||
7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS | 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS | ||
3.8.7 Inverters - Operating | |||
- Operating | |||
LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. | LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. | ||
-------------------------------- | -------------------------------- | ||
-------------NOTE-------------------------------------------- | -------------NOTE-------------------------------------------- | ||
[ [One/two] inverter[s] may be disconnected from [its/their] associated DC form an equalizing charge on [its/their] associated [common] battery, provided: | |||
: a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using | : a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using | ||
internal AC source], and | internal AC source], and | ||
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------ | : b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------ | ||
-------------------------------------------------- | -------------------------------------------------- | ||
Line 661: | Line 655: | ||
AND | AND | ||
6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A | 6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. | ||
Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. | |||
B.1 Restore one inverter to OPERABLE status. | B.1 Restore one inverter to OPERABLE status. | ||
2 hours DOC M01 3 CTS INSERT 1A | 2 hours DOC M01 3 CTS INSERT 1A | ||
Line 679: | Line 670: | ||
------------------------------------------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------ | ||
7 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING | 7 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 | : 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. | 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. Kewaunee Power Station Page 1 of 1 | 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. Kewaunee Power Station Page 1 of 1 | ||
: 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 | : 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 | ||
Line 749: | Line 740: | ||
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 a. The reactor shall not be made critical unless all of the following requirements are satisfied: | SPECIFICATION M01 a. The reactor shall not be made critical unless all of the following requirements are satisfied: | ||
A pplicabilit y 1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses. | A pplicabilit y 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. | : 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | ||
: 3. The 4160-V buses 1-5 and 1-6 are both energized. | : 3. The 4160-V buses 1-5 and 1-6 are both energized. | ||
: 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | : 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | ||
: 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | : 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | ||
: 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | : 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | ||
: 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; 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. | ||
: 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: | ||
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. | A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. | ||
LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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 | LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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 | ||
HOT STANDBY within the next 6 hours. | 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. | : 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 generator. | 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 other battery and two battery chargers remain OPERABLE with one charger | : 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 | ||
carrying the d-c supply system. | 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 | : 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. | 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. | : 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 24 hours provided the redundant bus and its loads remain OPERABLE. | : 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. | : 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 | : 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: | requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | : 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. | ||
See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) | See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) | ||
Line 820: | Line 811: | ||
Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS | Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS | ||
3.8.9 Distribution Systems - Operating | |||
Systems - Operating | |||
LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. | LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. | ||
Line 867: | Line 857: | ||
maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other trai n are OPERABLE . | maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other trai n are OPERABLE . | ||
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ||
5 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING | 5 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. | : 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. | : 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. | : 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. Kewaunee Power Station Page 1 of 1 | : 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. Kewaunee Power Station Page 1 of 1 | ||
: 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 | : 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 | ||
Line 904: | Line 894: | ||
Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued) | Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued) | ||
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. electrical instrument APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that: | 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. electrical instrument 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 | : a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients | ||
and 3; | and 3; | ||
: 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 - | : 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 - | ||
Line 922: | Line 912: | ||
p h p?re q uestT ype=areaItemPrint&itemId=3801 A01ITS ITS 3.8.4 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 | p h p?re q uestT ype=areaItemPrint&itemId=3801 A01ITS ITS 3.8.4 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 | ||
HOT STANDBY within the next 6 hours. | 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. | : 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 generator. | 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 other battery and two battery chargers remain OPERABLE with one charger | : 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 | ||
carrying the d-c supply system. | 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 | : 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. | 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. | : 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 24 hours provided the redundant bus and its loads remain OPERABLE. | : 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. | : 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 | : 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: | requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | : 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. | ||
Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. | Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. | ||
Line 970: | Line 960: | ||
Once per [12] hours | Once per [12] hours | ||
7 days | 7 days | ||
[B. One [or two] batter[y][ies on one train] inoperable. | [B. One [or two] batter[y][ies on one train] inoperable. | ||
Line 994: | Line 984: | ||
DC electrical power subsystem is OPERABLE. | DC electrical power subsystem is OPERABLE. | ||
------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------- | ||
6 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING | 6 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. | : 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. | : 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 d eleted since it is not necessary. | : 3. The bracketed ISTS 3.8.4 ACTION B has been d eleted 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. | 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. | : 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. | ||
Line 1,032: | Line 1,022: | ||
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 functi on from being performed (Ref. 4). | 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 functi on from being performed (Ref. 4). | ||
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 | and | ||
: b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | : b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA. | ||
Line 1,073: | Line 1,063: | ||
7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS | 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS | ||
3.8.7 Inverters - Operating | |||
- Operating | |||
LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. | LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. | ||
-------------------------------- | -------------------------------- | ||
-------------NOTE-------------------------------------------- | -------------NOTE-------------------------------------------- | ||
[ [One/two] inverter[s] may be disconnected from [its/their] associated DC form an equalizing charge on [its/their] associated [common] battery, provided: | |||
: a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using | : a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using | ||
internal AC source], and | internal AC source], and | ||
: b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------ | : b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------ | ||
-------------------------------------------------- | -------------------------------------------------- | ||
Line 1,106: | Line 1,095: | ||
AND | AND | ||
6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 7 | 6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 7 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. | ||
Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. | |||
B.1 Restore one inverter to OPERABLE status. | B.1 Restore one inverter to OPERABLE status. | ||
2 hours DOC M01 3 CTS INSERT 1A | 2 hours DOC M01 3 CTS INSERT 1A | ||
Line 1,124: | Line 1,110: | ||
------------------------------------------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------ | ||
7 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING | 7 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 | : 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. | 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. Kewaunee Power Station Page 1 of 1 | 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. Kewaunee Power Station Page 1 of 1 | ||
: 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 | : 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 | ||
Line 1,194: | Line 1,180: | ||
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 a. The reactor shall not be made critical unless all of the following requirements are satisfied: | SPECIFICATION M01 a. The reactor shall not be made critical unless all of the following requirements are satisfied: | ||
A pplicabilit y 1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses. | A pplicabilit y 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. | : 2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6. | ||
: 3. The 4160-V buses 1-5 and 1-6 are both energized. | : 3. The 4160-V buses 1-5 and 1-6 are both energized. | ||
: 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | : 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers. | ||
: 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | : 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers. | ||
: 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | : 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b. | ||
: 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; 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. | ||
: 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: | ||
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. | A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. | ||
LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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 | LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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 | ||
HOT STANDBY within the next 6 hours. | 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. | : 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 generator. | 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 other battery and two battery chargers remain OPERABLE with one charger | : 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 | ||
carrying the d-c supply system. | 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 | : 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. | 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. | : 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 24 hours provided the redundant bus and its loads remain OPERABLE. | : 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. | : 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 | : 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: | requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: | ||
: 1. Its corresponding normal or emergency power source is OPERABLE; and | : 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. | ||
See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) | See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) | ||
Line 1,263: | Line 1,249: | ||
Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS | Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS | ||
3.8.9 Distribution Systems - Operating | |||
Systems - Operating | |||
LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. | LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. | ||
Line 1,311: | Line 1,296: | ||
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ||
5 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING | 5 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. | : 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. | : 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. | : 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. Kewaunee Power Station Page 1 of 1 | : 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. Kewaunee Power Station Page 1 of 1 | ||
: 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 | : 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 | ||
Line 1,348: | Line 1,333: | ||
Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued) | Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued) | ||
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. electrical instrument APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that: | 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. electrical instrument 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 | : a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients | ||
and 3; | and 3; | ||
: 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 - | : 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 - | ||
Line 1,365: | Line 1,350: | ||
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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/19/2010 htt p://www.excelservices.com/rai/index. | 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/19/2010 htt p://www.excelservices.com/rai/index. | ||
p h p?re q uestT ype=areaItemPrint&itemId=3871 Licensee Response/NRC Response/NRC Question Closure Id3921NRC Question Number MEH-009 Select Application NRC Question Closure Response Date/Time Closure Statement Based on the 7/16/2010 resonse to the MEH-009, this question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 7/20/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Waig Date Added 7/20/2010 2:54 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 07/20/2010 htt p://www.excelservices.com/rai/index. | p h p?re q uestT ype=areaItemPrint&itemId=3871 Licensee Response/NRC Response/NRC Question Closure Id3921NRC Question Number MEH-009 Select Application NRC Question Closure Response Date/Time Closure Statement Based on the 7/16/2010 resonse to the MEH-009, this question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 7/20/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Waig Date Added 7/20/2010 2:54 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 07/20/2010 htt p://www.excelservices.com/rai/index. | ||
p h p?re q uestT ype=areaItemPrint&itemId=3921 ITS NRC Questions Id1691NRC Question Number RW001 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number 5 Page Number(s) Volume 13, Page 117 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question Condition F of LCO | p h p?re q uestT ype=areaItemPrint&itemId=3921 ITS NRC Questions Id1691NRC Question Number RW001 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number 5 Page Number(s) Volume 13, Page 117 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question Condition F of LCO 3.8.3 states in part "One or more DGs with required air receiver bank pressure | ||
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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. | $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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. | ||
p h p?re q uestT ype=areaItemPrint&itemId=1691 Licensee Response/NRC Response/NRC Question Closure Id2301NRC Question Number RW001 Select Application Licensee Response Response Date/Time 2/25/2010 10:45 AM Closure Statement Response Statement The Kewaunee design includes both primary and reser ve air receiver banks for each diesel gene rator. As stated in the Background section of the ITS Bases (last paragr aph 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 on e air receiver bank is normally in service. The refore, 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. | p h p?re q uestT ype=areaItemPrint&itemId=1691 Licensee Response/NRC Response/NRC Question Closure Id2301NRC Question Number RW001 Select Application Licensee Response Response Date/Time 2/25/2010 10:45 AM Closure Statement Response Statement The Kewaunee design includes both primary and reser ve air receiver banks for each diesel gene rator. As stated in the Background section of the ITS Bases (last paragr aph 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 on e air receiver bank is normally in service. The refore, 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. | ||
Line 1,404: | Line 1,386: | ||
Logic drawing E-1633 (attached to this response) shows the operation of the EDG cooling water isolation valve. | Logic drawing E-1633 (attached to this response) shows the operation of the EDG cooling water isolation valve. | ||
Question Closure Date Attachment 1 RW-002 information.pdf (259KB) 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 Modified 2/25/2010 11:11 AM Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. | Question Closure Date Attachment 1 RW-002 information.pdf (259KB) 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 Modified 2/25/2010 11:11 AM Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. | ||
p h p?re q uestT ype=areaItemPrint&itemId=2311 | p h p?re q uestT ype=areaItemPrint&itemId=2311 | ||
[-1633 ,'H1191 or-PASS | [-1633 ,'H1191 or-PASS | ||
(.ONT/lINMLi'Ol F"i'OU"'."Nr1"5 | (.ONT/lINMLi'Ol F"i'OU"'."Nr1"5 | ||
Line 1,444: | Line 1,426: | ||
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. | 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 tw o terms on their use in ISTS LCO 3.6.3. This Specification requires c ontainment isolatio n valves to be OPERABLE. Note 1 to the ACTIONS al lows certain penetration flow paths to be unisolated "intermittently" unde r "administrative controls" (Volume 11, Page 71). Unisolati ng the valves in these pene tration flow paths makes the associated containment isolation valves inoperable. The Bases for the Note (Page 86, first paragraph of th e ACTIONS) describes "administrative controls" in a similar manner (i.e., a dedicated operator at the valve controls, who is in continuous comm unication with th e control room) as Kewaunee proposes for the ITS 3. | Kewaunee based the use of these tw o terms on their use in ISTS LCO 3.6.3. This Specification requires c ontainment isolatio n valves to be OPERABLE. Note 1 to the ACTIONS al lows certain penetration flow paths to be unisolated "intermittently" unde r "administrative controls" (Volume 11, Page 71). Unisolati ng the valves in these pene tration flow paths makes the associated containment isolation valves inoperable. The Bases for the Note (Page 86, first paragraph of th e ACTIONS) describes "administrative controls" in a similar manner (i.e., a dedicated operator at the valve controls, who is in continuous comm unication with th e 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 - | |||
Action E.2 Note. Furthermore, the term "intermittently" is not clarified in the ISTS Bases - | |||
the meaning and application is left for licensee interpretation. | 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. | 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. | ||
Line 1,457: | Line 1,437: | ||
p h p?re q uestT ype=areaItemPrint&itemId=3191 ITS NRC Questions Id1831NRC Question Number RW005 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Number(s) Attachment 1, Volume 13, Rev. 0, Page 118 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. | p h p?re q uestT ype=areaItemPrint&itemId=3191 ITS NRC Questions Id1831NRC Question Number RW005 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Number(s) Attachment 1, Volume 13, Rev. 0, Page 118 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. | ||
p h p?re q uestT ype=areaItemPrint&itemId=1831 Licensee Response/NRC Response/NRC Question Closure Id2511NRC Question Number RW005 Select Application Licensee Response Response Date/Time 3/10/2010 7:10 AM Closure Statement Response Statement Kewaunee Power Station (KPS) does not have any test data or analysis that supports starting of the EDG more than one time for each receiver bank. KPS licensing basis indicates that the ED G 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 rece ivers and this was demonstr ated 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 provid ed in ITS SR 3. | p h p?re q uestT ype=areaItemPrint&itemId=1831 Licensee Response/NRC Response/NRC Question Closure Id2511NRC Question Number RW005 Select Application Licensee Response Response Date/Time 3/10/2010 7:10 AM Closure Statement Response Statement Kewaunee Power Station (KPS) does not have any test data or analysis that supports starting of the EDG more than one time for each receiver bank. KPS licensing basis indicates that the ED G 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 rece ivers and this was demonstr ated 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 provid ed in ITS SR 3. | ||
8.3.4 ensures the design basis of the starting air system (as de scribed 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. | |||
the design basis of the starting air system (as de scribed 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. | 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. | ||
p h p?re q uestT ype=areaItemPrint&itemId=2511 Licensee Response/NRC Response/NRC Question Closure Id3101NRC Question Number RW005 Select Application Licensee Response Response Date/Time 5/18/2010 9:15 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third response), the air receiver pressure requirements are being deleted from the ITS submittal. | p h p?re q uestT ype=areaItemPrint&itemId=2511 Licensee Response/NRC Response/NRC Question Closure Id3101NRC Question Number RW005 Select Application Licensee Response Response Date/Time 5/18/2010 9:15 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third response), the air receiver pressure requirements are being deleted from the ITS submittal. |
Revision as of 23:34, 30 April 2019
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
{{#Wiki_filter:ITS NRC Questions Id2141NRC Question Number MEH-009 Category Technical ITS Section 3.7 ITS Number 3.7.8 DOC Number JFD Number 6 JFD Bases Number 6 Page Number(s) NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question The May 12, 2010 supplem ent to the TS Conver sion LAR proposed the 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 convenie nce. The Bases for LCO 3.0.2 specifically state: "Inten tional 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2141 Licensee Response/NRC Response/NRC Question Closure Id3611NRC Question Number MEH-009 Select Application Licensee Response Response Date/Time 6/21/2010 4:10 PM Closure Statement Response Statement In the first paragraph of the NRC question, the NRC reviewer states that the staff believes that inserting the word "necessarily" into th e SR Note would allow intentional entry into LC O 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 s hould 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 sys tem 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 fr om 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. ML101 380399]) 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 pow er 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 Pa ge 1of 2 Kewaunee ITS Conversion Database 06/25/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3611 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 Pa ge 2of 2 Kewaunee ITS Conversion Database 06/25/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3611 A01ITS ITS 3.8.4 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
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:
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 other battery and two battery chargers remain OPERABLE with one charger
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.
- 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 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.
Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. INSERT DOC L02 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. DC Sources - Operating 3.8.4 WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 3.8 ELECTRICAL POWER SYSTEMS
3.8.4 DC Sources - Operating
LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One [or two] battery charger[s on one train]
inoperable.
A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage. AND A.2 Verify battery float current AND A.3 Restore battery charger[s] to OPERABLE status.
2 hours
Once per [12] hours
7 days [B. One [or two] batter[y][ies on one train] inoperable.
B.1 Restore batter[y][ies] to OPERABLE status.
[2] hours ]
C. One DC electrical power subsystem inoperable for reasons other than
Condition A [or B].
C.1 Restore DC electrical power subsystem to OPERABLE status.
[2] hours D. Required Action and Associated Completion Time not met. D.1 Be in MODE 3. AND D.2 Be in MODE 5.
6 hours
36 hours required CTS 3.7.a.6 B C C DOC L01 3.7.b.3 3.7.b 3 3 3 2 B 3.7.a 72 hours 4 ---------------------------------------------------------------------------NOTE---------------------------------------------------------------- When a DC electrical power subsystem is inoperable solely due to the room cooler being non-functional, entry into associated AC TIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental req uirements; and b) the
other DC electrical power subsystem is OPERABLE.
6 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 d eleted 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.
Kewaunee Power Station Page 1 of 1
- 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. DC Sources - Operating B 3.8.4 WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 BASES
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 functi on from being performed (Ref. 4). 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 Condition A represents one train with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restor ing a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability. All changes are unless otherwise noted 1 2 7 2 y subsystem y one one 2 required The ACTIONS are modified by a Note that allows a 24 hour delay in entering the A CTIONS when a DC electrical power subsystem is 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 other
DC electrical power subsystem is
OPERABLE. The 24 hour allowance is
provided in order to perform room cooler
maintenance. If during the 24 hour period
the other DC electrical power subsystem
becomes inoperable, the associated A CTIONS for an inoperable DC electrical power subsystem must immediately be
entered. This 24 hour time period is
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. 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS
3.8.7 Inverters - Operating
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 form an equalizing charge on [its/their] associated [common] battery, provided:
- a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using
internal AC source], and
- b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One [required] inverter inoperable.
A.1 --------------NOTE-------------- Enter applicable Conditions and Required Actions of
LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized. -------------------------------------
Restore inverter to OPERABLE status.
24 hours B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND
6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. B.1 Restore one inverter to OPERABLE status. 2 hours DOC M01 3 CTS 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.
7 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. Kewaunee Power Station Page 1 of 1
- 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. Inverters - Operating B 3.8.7 WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 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 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." This ensures that the vital bus is re-energized within 2 hours.
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. 4 6 2 5Train A or Train B inverters C C instrument /rectifier instrument Power to an instrument bus is provided in the following order: 1) filtered AC through the inverter (referred to as "normal"); 2) DC changed to AC via the inverter (referred to as "standby"), and; 3) non-filtered AC through the inverter via a static switch (referred to as "alternate"). INSERT 1 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS 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
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
immediately be entered. This 24 hour time period is acceptable because the room
containing the inverters is monitored on an hourly basis to ensure conditions are within designenvironmentalrequirements. 4 ITS ITS 3.8.9 A013.7 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 a. The reactor shall not be made critical unless all of the following requirements are satisfied: A pplicabilit y 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.
- 3. The 4160-V buses 1-5 and 1-6 are both energized.
- 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers.
- 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.
- 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b.
- 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.
- 8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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
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:
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 other battery and two battery chargers remain OPERABLE with one charger
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.
- 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 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.
See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) 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 Page 2 of 2 A dd proposed ACTIONS Note L02 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 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. 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
, including an ACTIONS Note DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Kewaunee Power Station Page 5 of 5 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 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. Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS
3.8.9 Distribution Systems - Operating
LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more AC electrical power
distribution subsystems inoperable.
NOTE-------------------
Enter applicable Conditions and
Required Actions of LCO 3.8.4, "DC
Sources - Operating," for DC trains
made inoperable by inoperable power distribution subsystems.
A.1 Restore AC electrical power distribution subsystem(s) to OPERABLE status.
8 hours
B. One or more AC vital buses inoperable.
B.1 Restore AC vital bus subsystem(s) to OPERABLE status.
2 hours
C. One or more DC electrical power
distribution subsystems inoperable.
C.1 Restore DC electrical power distribution
subsystem(s) to OPERABLE status.
2 hours 2 instrument (es)instrument instrument DOC L01 DOC M02 3.7.b.6 sources 1 1 1 3.7.a.3, 3.7.a.4, 3.7.a.5, 3.7.a.6 3.7.a CTS -------------------------------------------------------------------------------NOTE---------------------------------------------------------------------------------------- When one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, en try 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) the electrical power distribution subsystems in the other trai n are OPERABLE .
5 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. Kewaunee Power Station Page 1 of 1
- 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. Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued)
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. electrical instrument 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
and 3;
- 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." ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor control centers, or distribution panels (except AC vital buses), in one train 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 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 buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours. instrument 4electrical power distribution subsystem electrical 4electrical power distribution subsystem 6 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS when one or more electrical power distri bution subsystems are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monit ored 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 subsequentl y 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. Licensee Response/NRC Response/NRC Question Closure Id3621NRC Question Number MEH-009 Select Application Licensee Response Response Date/Time 6/28/2010 4:10 PM Closure Statement Response Statement In the previous response to this quest ion, KPS 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 associa ted components covered by the LCO inoperable due to a non-functional ro om 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-r eviewed the monitoring requirements and has decided to include in the Note a requirement that the room temperature must be monitored and maintain ed within the design environmental requirements. Furthermore, the ITS Bases states that the room temperature monito ring 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 wi ll be reflected in the supplement to this section of the ITS conversion amendment. Question Closure Date Attachment 1 MEH-009 Markup Rev 1.pdf (2MB) 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/01/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3621 A01ITS ITS 3.8.4 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
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:
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 other battery and two battery chargers remain OPERABLE with one charger
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.
- 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 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.
Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. INSERT DOC L02 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. DC Sources - Operating 3.8.4 WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 3.8 ELECTRICAL POWER SYSTEMS
3.8.4 DC Sources - Operating
LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One [or two] battery charger[s on one train]
inoperable.
A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage. AND A.2 Verify battery float current AND A.3 Restore battery charger[s] to OPERABLE status.
2 hours
Once per [12] hours
7 days [B. One [or two] batter[y][ies on one train] inoperable.
B.1 Restore batter[y][ies] to OPERABLE status.
[2] hours ]
C. One DC electrical power subsystem inoperable for reasons other than
Condition A [or B].
C.1 Restore DC electrical power subsystem to OPERABLE status.
[2] hours D. Required Action and Associated Completion Time not met. D.1 Be in MODE 3. AND D.2 Be in MODE 5.
6 hours
36 hours required CTS 3.7.a.6 B C C DOC L01 3.7.b.3 3.7.b 3 3 3 2 B 3.7.a 72 hours 4 ---------------------------------------------------------------------------NOTE---------------------------------------------------------------- When a DC electrical power subsystem is inoperable solely due to the room cooler being non-functional, entry into associated AC TIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental req uirements; and b) the
other DC electrical power subsystem is OPERABLE.
6 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 d eleted 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.
Kewaunee Power Station Page 1 of 1
- 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. DC Sources - Operating B 3.8.4 WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 BASES
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 functi on from being performed (Ref. 4). 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 Condition A represents one train with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restor ing a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability. All changes are unless otherwise noted 1 2 7 2 y subsystem y one one 2 required The ACTIONS are modified by a Note that allows a 24 hour delay in entering the A CTIONS when a DC electrical power subsystem is 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 other
DC electrical power subsystem is
OPERABLE. The 24 hour allowance is
provided in order to perform room cooler
maintenance. If during the 24 hour period
the other DC electrical power subsystem
becomes inoperable, the associated A CTIONS for an inoperable DC electrical power subsystem must immediately be
entered. This 24 hour time period is
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. 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS
3.8.7 Inverters - Operating
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 form an equalizing charge on [its/their] associated [common] battery, provided:
- a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using
internal AC source], and
- b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One [required] inverter inoperable.
A.1 --------------NOTE-------------- Enter applicable Conditions and Required Actions of
LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized. -------------------------------------
Restore inverter to OPERABLE status.
24 hours B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND
6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. B.1 Restore one inverter to OPERABLE status. 2 hours DOC M01 3 CTS 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.
7 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. Kewaunee Power Station Page 1 of 1
- 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. Inverters - Operating B 3.8.7 WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 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 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." This ensures that the vital bus is re-energized within 2 hours.
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. 4 6 2 5Train A or Train B inverters C C instrument /rectifier instrument Power to an instrument bus is provided in the following order: 1) filtered AC through the inverter (referred to as "normal"); 2) DC changed to AC via the inverter (referred to as "standby"), and; 3) non-filtered AC through the inverter via a static switch (referred to as "alternate"). INSERT 1 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS 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
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
immediately be entered. This 24 hour time period is acceptable because the room
containing the inverters is monitored on an hourly basis to ensure conditions are within designenvironmentalrequirements. 4 ITS ITS 3.8.9 A013.7 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 a. The reactor shall not be made critical unless all of the following requirements are satisfied: A pplicabilit y 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.
- 3. The 4160-V buses 1-5 and 1-6 are both energized.
- 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers.
- 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.
- 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b.
- 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.
- 8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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
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:
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 other battery and two battery chargers remain OPERABLE with one charger
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.
- 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 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.
See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) 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 Page 2 of 2 A dd proposed ACTIONS Note L02 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 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. 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
, including an ACTIONS Note DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Kewaunee Power Station Page 5 of 5 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 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. Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS
3.8.9 Distribution Systems - Operating
LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more AC electrical power
distribution subsystems inoperable.
NOTE-------------------
Enter applicable Conditions and
Required Actions of LCO 3.8.4, "DC
Sources - Operating," for DC trains
made inoperable by inoperable power distribution subsystems.
A.1 Restore AC electrical power distribution subsystem(s) to OPERABLE status.
8 hours
B. One or more AC vital buses inoperable.
B.1 Restore AC vital bus subsystem(s) to OPERABLE status.
2 hours
C. One or more DC electrical power
distribution subsystems inoperable.
C.1 Restore DC electrical power distribution
subsystem(s) to OPERABLE status.
2 hours 2 instrument (es)instrument instrument DOC L01 DOC M02 3.7.b.6 sources 1 1 1 3.7.a.3, 3.7.a.4, 3.7.a.5, 3.7.a.6 3.7.a CTS -------------------------------------------------------------------------------NOTE---------------------------------------------------------------------------------------- When one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, en try 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) the electrical power distribution subsystems in the other trai n are OPERABLE .
5 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. Kewaunee Power Station Page 1 of 1
- 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. Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued)
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. electrical instrument 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
and 3;
- 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." ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor control centers, or distribution panels (except AC vital buses), in one train 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 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 buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours. instrument 4electrical power distribution subsystem electrical 4electrical power distribution subsystem 6 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS when one or more electrical power distri bution subsystems are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monit ored 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 subsequentl y 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. Licensee Response/NRC Response/NRC Question Closure Id3801NRC Question Number MEH-009 Select Application Licensee Response Response Date/Time 7/15/2010 10:40 AM Closure Statement Response Statement In the previous (second) response to this question (dat ed 6/28/2010), KPS provided a draft markup of changes to IT S 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 th e LCO inoperable due to a non-functional room cooler. This change included a re quirement to monitor the room temperature on an hourly basis to ensure the temperature was maintained within the design environmental requir ements. In a subs equent 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 requireme nts and has decide d to include the actual design temperature value in the ITS Bases (120 degrees F). A draft markup regarding this ch ange is attached a nd supersedes the markup attached to the previous response. Thi s change will be reflected in the supplement to this section of the ITS conversion amendment. Question Closure Date Attachment 1 MEH-009 Markup Rev 2.pdf (2MB) 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/19/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3801 A01ITS ITS 3.8.4 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
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:
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 other battery and two battery chargers remain OPERABLE with one charger
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.
- 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 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.
Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. INSERT DOC L02 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. DC Sources - Operating 3.8.4 WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 3.8 ELECTRICAL POWER SYSTEMS
3.8.4 DC Sources - Operating
LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One [or two] battery charger[s on one train]
inoperable.
A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage. AND A.2 Verify battery float current AND A.3 Restore battery charger[s] to OPERABLE status.
2 hours
Once per [12] hours
7 days [B. One [or two] batter[y][ies on one train] inoperable.
B.1 Restore batter[y][ies] to OPERABLE status.
[2] hours ]
C. One DC electrical power subsystem inoperable for reasons other than
Condition A [or B].
C.1 Restore DC electrical power subsystem to OPERABLE status.
[2] hours D. Required Action and Associated Completion Time not met. D.1 Be in MODE 3. AND D.2 Be in MODE 5.
6 hours
36 hours required CTS 3.7.a.6 B C C DOC L01 3.7.b.3 3.7.b 3 3 3 2 B 3.7.a 72 hours 4 ---------------------------------------------------------------------------NOTE---------------------------------------------------------------- When a DC electrical power subsystem is inoperable solely due to the room cooler being non-functional, entry into associated AC TIONS may be delayed for up to 24 hours provided the associated room temperature is monitored and maintained within the design environmental require ments and the other
DC electrical power subsystem is OPERABLE.
6 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 d eleted 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.
Kewaunee Power Station Page 1 of 1
- 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. DC Sources - Operating B 3.8.4 WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 BASES
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 functi on from being performed (Ref. 4). 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 Condition A represents one train with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restor ing a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability. All changes are unless otherwise noted 1 2 7 2 y subsystem y one one 2 required The ACTIONS are modified by a Note that allows a 24 hour delay in entering the A CTIONS when a DC electrical power subsystem is 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 other
DC electrical power subsystem is
OPERABLE. The 24 hour allowance is
provided in order to perform room cooler
maintenance. If during the 24 hour period
the other DC electrical power subsystem
becomes inoperable, the associated A CTIONS for an inoperable DC electrical power subsystem must immediately be
entered. This 24 hour time period is
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. 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS
3.8.7 Inverters - Operating
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 form an equalizing charge on [its/their] associated [common] battery, provided:
- a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using
internal AC source], and
- b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One [required] inverter inoperable.
A.1 --------------NOTE-------------- Enter applicable Conditions and Required Actions of
LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized. -------------------------------------
Restore inverter to OPERABLE status.
24 hours B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND
6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 7 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. B.1 Restore one inverter to OPERABLE status. 2 hours DOC M01 3 CTS 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.
7 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. Kewaunee Power Station Page 1 of 1
- 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. Inverters - Operating B 3.8.7 WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 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 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." This ensures that the vital bus is re-energized within 2 hours.
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. 4 6 2 5Train A or Train B inverters C C instrument /rectifier instrument Power to an instrument bus is provided in the following order: 1) filtered AC through the inverter (referred to as "normal"); 2) DC changed to AC via the inverter (referred to as "standby"), and; 3) non-filtered AC through the inverter via a static switch (referred to as "alternate"). INSERT 1 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS 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
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
immediately be entered. This 24 hour time period is acceptable because the room
containing the inverters is monitored on an hourly basis to ensure conditions are within desi g n environmental re q uirements of 120°F durin g this time. 4 ITS ITS 3.8.9 A013.7 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 a. The reactor shall not be made critical unless all of the following requirements are satisfied: A pplicabilit y 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.
- 3. The 4160-V buses 1-5 and 1-6 are both energized.
- 4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers.
- 5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.
- 6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b.
- 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.
- 8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:
A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 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
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:
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 other battery and two battery chargers remain OPERABLE with one charger
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.
- 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 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.
See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) 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 Page 2 of 2 A dd proposed ACTIONS Note L02 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 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. 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
, including an ACTIONS Note DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Kewaunee Power Station Page 5 of 5 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 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. Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS
3.8.9 Distribution Systems - Operating
LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more AC electrical power
distribution subsystems inoperable.
NOTE-------------------
Enter applicable Conditions and
Required Actions of LCO 3.8.4, "DC
Sources - Operating," for DC trains
made inoperable by inoperable power distribution subsystems.
A.1 Restore AC electrical power distribution subsystem(s) to OPERABLE status.
8 hours
B. One or more AC vital buses inoperable.
B.1 Restore AC vital bus subsystem(s) to OPERABLE status.
2 hours
C. One or more DC electrical power
distribution subsystems inoperable.
C.1 Restore DC electrical power distribution
subsystem(s) to OPERABLE status.
2 hours 2 instrument (es)instrument instrument DOC L01 DOC M02 3.7.b.6 sources 1 1 1 3.7.a.3, 3.7.a.4, 3.7.a.5, 3.7.a.6 3.7.a CTS -------------------------------------------------------------------------------NOTE---------------------------------------------------------------------------------------- When one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, en try 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 the electrical power distribution subsystems in the other train are OPERABLE .
5 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. Kewaunee Power Station Page 1 of 1
- 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. Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued)
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. electrical instrument 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
and 3;
- 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." ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor control centers, or distribution panels (except AC vital buses), in one train 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 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 buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours. instrument 4electrical power distribution subsystem electrical 4electrical power distribution subsystem 6 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS when one or more electrical power distri bution subsystems are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monit ored 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 subsequentl y 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 th is time. Licensee Response/NRC Response/NRC Question Closure Id3871NRC Question Number MEH-009 Select Application Licensee Response Response Date/Time 7/16/2010 11:45 AM Closure Statement Response Statement During a discussion with the NRC staff concerning th e environmental temperature limits for the rooms sp ecified in the MEH-009 markup posted on 7/15/2010 the staff requested DEK ensure the temperature limits are included in Kewaunee's USAR. DEK commits to including the vital switchgear and the battery room's temperature limits in the USAR. This change will be reflected in the supplemen t 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/19/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3871 Licensee Response/NRC Response/NRC Question Closure Id3921NRC Question Number MEH-009 Select Application NRC Question Closure Response Date/Time Closure Statement Based on the 7/16/2010 resonse to the MEH-009, this question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 7/20/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Waig Date Added 7/20/2010 2:54 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 07/20/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3921 ITS NRC Questions Id1691NRC Question Number RW001 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number 5 Page Number(s) Volume 13, Page 117 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=1691 Licensee Response/NRC Response/NRC Question Closure Id2301NRC Question Number RW001 Select Application Licensee Response Response Date/Time 2/25/2010 10:45 AM Closure Statement Response Statement The Kewaunee design includes both primary and reser ve air receiver banks for each diesel gene rator. As stated in the Background section of the ITS Bases (last paragr aph 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 on e air receiver bank is normally in service. The refore, 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 "r equired air receiver bank." For the air receiver bank to be considered th e "required air receiver bank" it must be in service (aligned to supply star ting air to the DG). Therefore, "required air receiver ba nk" 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 th is case, there are two air receiver banks for each DG, and only on e is required to be OPERABLE. The use of th e term "required" is described in TSTF-GG-05-01, 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 Conditio n A, uses the term "required." However, KPS noted that the LCO Bases does not spec ifically 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. Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2301 Question Closure Date Attachment 1 RW-001 Markup.pdf (718KB) 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 Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2301 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 WOG STS B 3.8.3-2 Rev. 3.0, 03/31/04 BASES
APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems 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. Since diesel fuel oil, lube oil, and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO Stored diesel fuel oil is required to have sufficient supply for 7 days of full load operation. It is also required to meet specific standards for quality.
Additionally, sufficient lubricating oil supply must be available to ensure the capability to operate at full load for 7 days. This requirement, in conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (AOO) or a postulated DBA with loss of offsite power. DG day tank fuel requirements, as well as transfer capability from the storage tank to the day tank, are addressed in LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, "AC Sources - Shutdown." The starting air system is required to have a minimum capacity for five 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 modifi ed 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 1 U 14 4 2 ing Air 3 rated for each DG each DG at rated s s 1 1 1 1 4 The Starting Air System for each DG is required to have a capacity to start and operate the DG. Thus, the air compressor is required to be OPERABLE, as well as one of the two air receiver banks is required to be OPERABLE and within the pressure limit. (i.e., in service ) Licensee Response/NRC Response/NRC Question Closure Id3061NRC Question Number RW001 Select Application Licensee Response Response Date/Time 5/18/2010 9:05 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third response), the air 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3061 Licensee Response/NRC Response/NRC Question Closure Id3221NRC Question Number RW001 Select Application Licensee Response Response Date/Time 5/25/2010 12:10 PM Closure Statement Response Statement Note that the draft markup provided as an attachment to the KPS first response to this RAI has been superseded by the draft markup described in the KPS second res ponse 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3221 Licensee Response/NRC Response/NRC Question Closure Id3161NRC Question Number RW001 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 5/24/2010 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3161 ITS NRC Questions Id1701NRC Question Number RW002 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number L-3 JFD Number JFD Bases Number Page Number(s) Attachment 1, Volume 13, Rev. 0, Page 112 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N 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 an d reserve tanks of the air receivers supply compressed air to the asso ciated EDG Air Start System, the EDG cooling water isol ation valve actuators, and the EDG Vent intake, recirculation, a nd exhaust damper actuators." Please explain why the supply of compre ssed air from the air receivers to the EDG cooling water is olation valve actuators is not mentio ned in L03 and not mentioned as one of the air consumers in th e 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=1701 Licensee Response/NRC Response/NRC Question Closure Id2311NRC Question Number RW002 Select Application Licensee Response Response Date/Time 2/25/2010 10:50 AM 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 1 RW-002 information.pdf (259KB) 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 Modified 2/25/2010 11:11 AM Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2311 [-1633 ,'H1191 or-PASS (.ONT/lINMLi'Ol F"i'OU"'."Nr1"5
Z Z>if-:If-gf"_:51'"" ,.,,, Sd..08 d8 4>$$I I I I , , I I , I I I I I I , i I , I I I I I II I I I I , I I I I , I I , I I , I I I I Ira FJC6JA F:i:J(,?A[[91-]WISCONSIN PUBLIC SERVICE CORP..-."'""" PIolleerSnmC(l&EIlQlI1eerlIlQGoAE Licensee Response/NRC Response/NRC Question Closure Id3071NRC Question Number RW002 Select Application Licensee Response Response Date/Time 5/18/2010 9:10 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third response), the air receiver pressure a nd air compressor requirements are being deleted from the ITS submittal. Therefo re, 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3071 Licensee Response/NRC Response/NRC Question Closure Id3171NRC Question Number RW002 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 5/24/2010 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3171 ITS NRC Questions Id1711NRC Question Number RW003 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Number(s) Attachment 1, Volume 13, Rev. 0, Page 118 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question Justification 5 states in part "The KPS CT S does not include any requirements for the Starti ng 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. Sect ion 8.2.3.1 states:
"Each diesel generator is automatically st arted by either on e 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 ai r 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 starte d and ready to accept load in ten seconds. Starting air is admitted from the air start receivers to the starting system through a pressure-reduci ng valve to supply air to the air starter motors.
The following describes a typical die sel engine start sequence. The sequence stated assumes the air start motor priority selector switch is in Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=1711 the #1 position. The air start motor priority selec tor 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 atte mpt is made through air start motor set #1. If th e air start motor set #1 fa ils to engage within 2 seconds, a second start attempt is made with the same set of motors. If the air start motors sti ll do not engage, and then after 5 seconds a third start attempt is ma de, this time using the sec ond 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 re quired 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 Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=1711 Licensee Response/NRC Response/NRC Question Closure Id2321NRC Question Number RW003 Select Application Licensee Response Response Date/Time 2/25/2010 10:55 AM Closure Statement Response Statement The following two paragraphs are from USAR Section 8.2.3.1 and 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 mo nthly basis. This ensures even run time on the air start motors.
When the diesel start signal is initiated, a start atte mpt is made through air start motor set #1. If th e 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 ai r start motors (set #2). Air start motors set #2 wi ll 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 go vernor booster pump are stopped. Operator action is then required for further start attempts." The above USAR description does NOT d escribe 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 st arting the DG engine (cranking the engine). The DG engine start (cra cking the engine) doe s not begin until a set of air start motors are engaged with the DG engine flywheel ri ng gear and the engine begins rotating (c ranking). The air start motor sequence discussed above describes how the air start moto rs 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 th e DG engine will be "cranked" until the DG engine starts or 15 seconds has elapsed since the start signal was initiated. Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2321 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 Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2321 Licensee Response/NRC Response/NRC Question Closure Id2781NRC Question Number RW003 Select Application Licensee Response Response Date/Time 4/13/2010 3:15 PM 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, dem onstrate 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 suppl y the air start moto rs and the reserv e air start banks isolated. Data was collected per Calculation C10021, Method for Determining Diesel Generator Damper Operat ion 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 collect ed 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 th e EDGs reached 20 0 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 cr anking cycle matc hes the typical cranking time for a normal successful start of the large diesel e ngines common in nuclear service. This is consistent with the data collected for Calculation C10021. The design basis for the air start sy stem 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". Althou gh a "five start te st" has not been Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2781 conducted at KPS, there is reasonable assuranc e, 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 Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2781 Licensee Response/NRC Response/NRC Question Closure Id3081NRC Question Number RW003 Select Application Licensee Response Response Date/Time 5/18/2010 9:05 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third response), the air 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3081 Licensee Response/NRC Response/NRC Question Closure Id3181NRC Question Number RW003 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 5/24/2010 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3181 ITS NRC Questions Id1721NRC Question Number RW004 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number L-3 JFD Number JFD Bases Number Page Number(s) Attachment 1, Volume 13, Rev. 0, Page 116 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question Required Action E.2 states "The cr oss-tie between th e 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=1721 Licensee Response/NRC Response/NRC Question Closure Id2331NRC Question Number RW004 Select Application Licensee Response Response Date/Time 2/25/2010 10:55 AM Closure Statement Response Statement The two terms are described in the ITS Bases for the Required Action E.2 Note. The Bases states (Page 124, INSERT 1, s econd paragraph) that:
"These administrative controls consist of stationing a dedicated operator at the DG starting Air System cross-c onnect valve for th e OPERABLE DG, who is in continuous comm unication with the control room. In this way, the OPERABLE Starting Ai r System can be isolat ed from the inoperable Starting Air System if a need for isolation is indicated." Furthermore, the B ases states: "The time th e cross-connect valves are opened should be minimized." This statement contro ls 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 tw o terms on their use in ISTS LCO 3.6.3. This Specification requires c ontainment isolatio n valves to be OPERABLE. Note 1 to the ACTIONS al lows certain penetration flow paths to be unisolated "intermittently" unde r "administrative controls" (Volume 11, Page 71). Unisolati ng the valves in these pene tration flow paths makes the associated containment isolation valves inoperable. The Bases for the Note (Page 86, first paragraph of th e ACTIONS) describes "administrative controls" in a similar manner (i.e., a dedicated operator at the valve controls, who is in continuous comm unication with th e 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 th e NUREGs is that administrative controls and intermittent can be defined either in the Bases or in another location outside of Technical Specification. Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2331 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 Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2331 Licensee Response/NRC Response/NRC Question Closure Id3091NRC Question Number RW004 Select Application Licensee Response Response Date/Time 5/18/2010 9:15 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third re sponse), the air receiver pressure and air compressor requirements are being deleted from the ITS submittal. There fore, 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3091 Licensee Response/NRC Response/NRC Question Closure Id3191NRC Question Number RW004 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 5/24/2010 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3191 ITS NRC Questions Id1831NRC Question Number RW005 Category Technical ITS Section 3.8 ITS Number 3.8.3 DOC Number JFD Number 5 JFD Bases Number Page Number(s) Attachment 1, Volume 13, Rev. 0, Page 118 of 289 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=1831 Licensee Response/NRC Response/NRC Question Closure Id2511NRC Question Number RW005 Select Application Licensee Response Response Date/Time 3/10/2010 7:10 AM Closure Statement Response Statement Kewaunee Power Station (KPS) does not have any test data or analysis that supports starting of the EDG more than one time for each receiver bank. KPS licensing basis indicates that the ED G 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 rece ivers and this was demonstr ated 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 provid ed in ITS SR 3. 8.3.4 ensures the design basis of the starting air system (as de scribed 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2511 Licensee Response/NRC Response/NRC Question Closure Id3101NRC Question Number RW005 Select Application Licensee Response Response Date/Time 5/18/2010 9:15 AM Closure Statement Response Statement Based on the latest KPS response to GMW-004 (third response), the air 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3101 Licensee Response/NRC Response/NRC Question Closure Id3391NRC Question Number RW005 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 6/3/2010 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 Pa ge 1of 1 Kewaunee ITS Conversion Database 07/08/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3391}}