ML101890239

Enclosure - Q&A to Attachment 1 Volume 11 - Kewaunee ITS Conversion Database, ITS NRC Questions

ML101890239
Person / Time
Site:	Kewaunee
Issue date:	06/17/2010
From:	Dominion Energy Kewaunee
To:	Office of Nuclear Reactor Regulation
References
Download: ML101890239 (28)

Text

Kewaunee ITS Conversion Database Page 1 of 2 ITS NRC Questions Id 1851 NRC Question MEH-006 Number Category Technical ITS Section 3.6 ITS Number 3.6.6 DOC Number JFD Number 8 JFD Bases Number Page 157 of Att 1, Vol 7 Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC The proposed frequency for ITS SR 3.6.6.3 is 92 days while the frequency for the Question SR in STS is 31 days. The STS bases states that the frequency was developed with the following three items taken into consideration: 1) the known reliability of the cooling water system, 2) the two train redundancy available, and 3) the low probability of a significant degradation of flow occurring between surveillances.

JFD 8 on page 157 of attachment 1, Volume 11 states that the proposed 92 day frequency is consistent with the current IST program frequency. The JFD does not discuss the statements regarding reliability, train redundancy, and probability of significant flow degradation. Have the statements that justify the 31 day frequency in STS SR 3.6.6A.3 been evaluated for the proposed 92 day frequency?

Are they still valid? Please provide a detailed justification for the discrepancy between the STS frequency of 31 days and the 92 day frequency requested by the licensee.

Attach File 1

Attach File 2

Issue Date 3/8/2010 Added By Matthew Hamm Date Modified Modified By Date Added 3/8/2010 2:57 PM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1851 06/17/2010

Kewaunee ITS Conversion Database Page 2 of 2 Matthew Hamm http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1851 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 2 Licensee Response/NRC Response/NRC Question Closure Id 2651 NRC Question MEH-006 Number Select Licensee Response Application

Response

3/22/2010 4:20 PM Date/Time Closure Statement

Response

Statement The verification of Containment Fan Coil Unit flows using plant procedure SP-02-138, Service Water Pump and Valve Test-IST, began in August 1985 and subsequently was split into train dependent tests (SP-02-138A and B) in 2002. The Containment Fan Coil Unit flows have always been verified on a quarterly basis. During this period, Containment Fan Coil Unit flows have always been greater than 1100 gallons per minute for each fan coil unit.

Since the minimum required flow rate is normally 800 gpm (and 850 with a tube plugged), no fan coil has ever failed a flow criteria test. Based upon this data, the existing testing frequency is adequate to ensure system reliability and identification of significant flow degradation, i.e., the cooling water system is reliable and there is a low probability of a significant degradation of flow occurring between Surveillances, as described in the ITS SR 3.6.6.3 Bases. In addition, the design of the cooling water system is consistent with that described in the ISTS Bases, in that there are two trains, and each train is capable of performing the safety function. Thus redundancy is available.

Because cooling water is normally aligned to each of the Containment Fan Coils to support cooling of the Reactor Coolant Pump vaults (supplying approximately 1100 gpm to each fan coil while cooling water is also being supplied to the shroud cooling system), there are no issues with flow degradation within the fan coils due to sediment.

Any flow degradation due to a Containment Fan Coil tube leakage will be identified by Containment Sump A in-leakage within days or hours, depending on the size of the tube leak. Any tube leakage is collected in the Containment Sump A and the sump HI level alarms in the Control Room when the volume in the sump increases 339 gallons from the time the sump was last pumped out. Containment Sump A is monitored as part of the Reactor Coolant Leakage surveillance to identify "unidentified" leakage.

The Reactor Coolant Leakage surveillance is performed daily.

Also, performing the Cooling Water Flow verification monthly (as in the ISTS) versus quarterly (as proposed by KPS in the ITS submittal) would add, on an annual basis, eight additional Service Water Pump starts and eight additional cycles of the shroud bypass cooling valves.

http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2651 06/17/2010

Kewaunee ITS Conversion Database Page 2 of 2 Therefore, the words in the KPS ITS Bases for SR 3.6.6.3 are accurate, in that the 92 day Frequency does take into consideration the known reliability of the cooling water system, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 3/22/2010 4:21 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2651 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 3301 NRC Question MEH-006 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 5/27/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Added By Matthew Hamm Date Added 5/27/2010 1:55 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3301 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 1 ITS NRC Questions Id 1861 NRC Question MEH-007 Number Category Technical ITS Section 3.6 ITS Number 3.6.6 DOC Number JFD Number JFD Bases Number Page Number (s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC The proposed ITS SR 3.6.6.3 does not contain a value for cooling water flow rate, Question rather it contains a phrase "sufficient to remove the assumed accident heat load." The flow rates are then listed in the proposed TS Bases. In the STS, the flow rates are bracketed and provided in the Surveillance Requirement itself.

Why are the flow rates for each cooling train not listed in the TS SR consistent with the STS?

Attach File 1 Attach File 2 Issue Date 3/8/2010 Added By Matthew Hamm Date Modified Modified By Date Added 3/8/2010 2:59 PM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Matthew Hamm http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1861 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 2 Licensee Response/NRC Response/NRC Question Closure Id 2571 NRC Question MEH-007 Number Select Licensee Response Application

Response

3/15/2010 3:30 AM Date/Time Closure Statement Response The justification for not including the flow rate value for ITS SR 3.6.6.3 is Statement provided in JFD 8 (Page 157). With regard to the flow rate value, JFD 8 states:

"The SR acceptance criteria is specified as "is sufficient to remove the assumed accident heat load." The CTS does not include the flow rate value. This value is currently controlled outside of the Technical Specifications. Each containment cooling train consists of two fan-coil units. Thus, the flow rate is on a fan-coil unit basis, not a train basis.

Furthermore, the flow rate for a fan-coil unit depends upon whether or not there are any plugged tubes. Currently, one of the four fan-coil units is operating with tubing plugged, thus the necessary flow to remove the assumed accident heat load is higher for this fan-coil unit than it is for the other three fan-coil units. Therefore, since this value is currently controlled by KPS outside of the Technical Specifications, the KPS ITS will maintain this allowance, but clearly specify the criteria the fan-coil units must meet.

The values for the fan-coil unit flow will be specified in the ITS Bases."

KPS continues to desire to maintain this value in the ITS Bases. The ITS SR will continue to state that the flow is "sufficient to remove the assumed accident heat load." The ITS Bases contains the actual flow rate for each fan-coil unit, and the values in the Bases can only be changed using the ITS Bases Control Program in ITS 5.5. The Program will ensure that any changes to the values in the Bases are adequately controlled.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Ray Schiele http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2571 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 2 Added By Robert Hanley Date Added 3/15/2010 3:31 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2571 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 3111 NRC Question MEH-007 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 5/20/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Added By Matthew Hamm Date Added 5/20/2010 1:38 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3111 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 2 ITS NRC Questions Id 1871 NRC Question MEH-008 Number Category Technical ITS Section 3.6 ITS Number 3.6.3 DOC Number JFD Number JFD Bases 3

Number Page 101 of Att 1, Vol 11 Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC The proposed TS Bases page B 3.6.3-4 adopts changes proposed in TSTF-502.

Question TSTF-502 has not been approved by NRC. JFD 3 on page 101 of Attachment 1, Volume 11 states that "The phrase "closed systems are intact" is incorrect and has been deleted. The status of the closed system does not affect the ability of the containment isolation valve to perform its specified function. The condition of the closed system has no effect on the ability of the containment isolation valve to open, close, seal, or meet the Surveillance Requirements." The staff does not agree that the phrase "closed systems are intact" should be removed from the TS Bases. The phrase is included because the closed system pressure boundary either inside or outside containment acts as one of two barriers for the penetration. Most often the barriers are two valves, but flanges or closed system boundaries are allowed in lieu of a valve for one or both the penetration barrier(s).

Please revise your request to retain the "closed systems are intact" language or provide additional justification for removal of the words.

Attach File 1

Attach File 2

Issue Date 3/9/2010 Added By Matthew Hamm Date Modified Modified By Date Added 3/9/2010 9:54 AM http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1871 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 2 Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Matthew Hamm http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1871 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 2581 NRC Question MEH-008 Number Select Licensee Response Application

Response

3/15/2010 3:35 AM Date/Time Closure Statement Response TSTF-502 is a "T" traveler, which is a traveler not submitted to the NRC for Statement approval. It is a traveler that fixes minor errors in the Bases. Thus, while the traveler has not been approved by the NRC, it also has not been disapproved by the NRC. KPS provided a justification for the change to the Bases (JFD 3) and did not mention TSTF-502T. The LCO requirements are not on "closed systems"; they are on Containment Isolation Valves. Thus, while the piping is a barrier, it is not covered by this LCO. Thus, to state in the LCO section of the Bases, which describes how the LCO is being met, that systems must be intact is not correct. Furthermore, there are no Surveillance Requirements in ISTS 3.6.3 to verify systems are intact; there are only Surveillances on the actual devices (valves and blind flanges). In conclusion, KPS does not believe that deleting these words from the Bases results in changing the intent or requirements of the LCO 3.6.3.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 3/15/2010 3:33 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2581 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 2931 NRC Question MEH-008 Number Select Licensee Response Application

Response

5/12/2010 1:45 PM Date/Time Closure Statement Response Kewaunee Power Station (KPS) has decided to not include this change in Statement the ITS submittal at this time. 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 1 MEH-008 Markup.pdf (1MB)

Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 5/12/2010 1:47 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2931 06/07/2010

Attachment 1, Volume 11, Rev. 0, Page 86 of 366 Containment Isolation Valves (Atmosperic, Subatmospheric, Ice Condenser, and Dual) 1 B 3.6.3 BASES LCO (continued)

The normally closed isolation valves are considered OPERABLE when stet manual valves are closed, automatic valves are de-activated and secured and in their closed position, blind flanges are in place, and closed systems are 3 intact. These passive isolation valves/devices are those listed in Penetrations which extend (i.e., combined bypass into the auxiliary building Reference 2.

leakage rate limits) special ventilation zone and penetrations which are Purge valves with resilient seals [and secondary containment bypass 6 exterior to both the shield valves] must meet additional leakage rate requirements. The other building and the auxiliary containment isolation valve leakage rates are addressed by LCO 3.6.1, building special ventilation zone "Containment," as Type C testing.

This LCO provides assurance that the containment isolation valves and purge valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment S

isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are and 6 7

addressed in LCO 3.9.4, "Containment Penetrations."

ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths, 36 2 except for [42] inch purge valve penetration flow paths, to be unisolated and vent intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for containment isolation and vent is indicated. Due to the size of the containment purge line penetration 2 and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls. A single 7

purge valve in a penetration flow path may be opened to effect repairs to an inoperable valve, as allowed by SR 3.6.3.1.

WOG STS B 3.6.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 86 of 366

Attachment 1, Volume 11, Rev. 0, Page 101 of 366 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES

1. The headings for ISTS 3.6.3 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual). This identifying information is not included in the Kewaunee Power Station (KPS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. The ISTS LCO section of the Bases states "The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed Not used. systems are intact." The phrase "closed systems are intact" is incorrect and has been deleted. The status of the closed system does not affect the ability of the containment isolation valve to perform its specified function. The condition of the closed system has no effect on the ability of the containment isolation valve to open, close, seal, or meet the Surveillance Requirements.

4. 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.

5. Changes made to be consistent with changes made to the ISTS. The SR related to blocking the purge valves has not been included in the KPS ITS.

6. Changes made to be consistent with changes made to the ISTS. The KPS plant-specific bypass leakage description has been provided, consistent with CTS 6.20, and the purge valve leakage requirements are not included since the KPS purge and vent valves do not have resilient seals/seats.

7. Changes made to be consistent with changes made to the ISTS.

8. The words in the ISTS 3.6.3 ACTIONS B.1 Bases, concerning how Required Action A.2 works, have been deleted. This description is already in the ACTION A.1 and A.2 Bases, and does not need to be repeated. This is consistent with many other Bases descriptions of ACTIONS, which do not include a description of other Conditions' Required Actions that may also be required when in another ACTION.

This is also consistent with the BWR ISTS Bases, NUREG-1433 and NUREG-1434.

9. These ITS 3.6.3 Bases words have been added/modified to be consistent with the CTS Bases. The words were added to the CTS Bases as part of Amendment No.

155, which added the CTS Actions for containment isolation valves (CTS 3.6.b).

Furthermore, when the allowance consistent with ITS 3.6.3 ACTION C was added in Amendment 155, the definition of a closed system was not required to be added to the CTS Bases, since KPS was designed and built prior to the existence of the design requirements of Reference 3 (Standard Review Plan 6.2.4). Thus, the words in ACTION C.1 concerning the closed system requirements have been deleted.

Kewaunee Power Station Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 101 of 366

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 3021 NRC Question MEH-008 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 5/17/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Added By Matthew Hamm Date Added 5/17/2010 12:32 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3021 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 2 ITS NRC Questions Id 2151 NRC Question RPG-010 Number Category Technical ITS Section 3.9 ITS Number 3.9.4 DOC Number JFD Number JFD Bases Number Page 89,127,164,166 Number(s)

NRC Reviewer Carl Schulten Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question Attachment 1, Volume 14, Rev. 0, Pages 89,164,166 of 175 proposed ISTS Section 3.9.4, Containment Penetrations KPS Proposed changes:

(a) ISTS LCO 3.9.4, addresses specific requirements for the containment penetrations status during movement of

[recently] irradiated fuel assemblies within containment. On page 166, KPS states that no credit is taken for the containment penetrations in the fuel handling accident analysis at KPS and since the Applicability of ISTS 3.9.4 is during movement of recently irradiated fuel assemblies within containment, the subject LCO is not included in KPS ITS.

(b) On page 127, KPS states, CTS 3.8.a.3 requires the reactor to be subcritical for 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> prior to movement of its irradiated fuel assemblies. The ITS does not include this requirement. This changes the CTS by moving the explicit decay time requirement from the Technical Specifications to http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2151 06/22/2010

Kewaunee ITS Conversion Database Page 2 of 2 the Technical Requirements Manual (TRM). This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications. Whereas, marked-up changes on page 102 of KPS ITS Bases B 3.9.7 (KPS B 3.9.5) show that KPS intends to keep the minimum decay time which is marked-up as 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, in the Bases.

Discussion:

As stated in the ITS Bases, fuel handling accidents, analyzed in Reference 3, include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.7, "Refueling Cavity Water Level," in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to [irradiated fuel movement with containment closure capability or a minimum decay time of [x]

days without containment closure capability], ensures that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100.

Based on the above, please retain ITS LCO 3.9.4 for KPS ITS and specify of minimum decay time requirement in KPS ITS Bases to ensure the staff can conclude KPS TS ensure adequate protection of the public health and safety.

Attach File 1

Attach File 2

Issue Date 6/14/2010 Added By Ravinder Grover Date Modified Modified By Date Added 6/14/2010 12:51 PM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2151 06/22/2010

Kewaunee ITS Conversion Database Page 1 of 1 ITS NRC Questions Id 1921 NRC Question VGC-012 Number Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number JFD Bases Number Page Number Vol 16, page 99 of 167 (s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question In Vol 16, page 99 of 167 in TS 5.5.14, the containment design pressure plant-specific value is removed from 5.5.14 b. Please explain the difficulty leaving this information in your TS causes, and a justification for its removal.

Attach File 1 Attach File 2 Issue Date 3/18/2010 Added By Victor Cusumano Date Modified Modified By Date Added 3/18/2010 9:45 AM Notification NRC/LICENSEE Supervision http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1921 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 2701 NRC Question VGC-012 Number Select Licensee Response Application

Response

4/5/2010 9:05 AM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) agrees to include the Statement containment design pressure value in the ITS. However, due to this change, KPS is also modifying ITS 5.5.14.b and c. Specifically, the CTS 6.20 requirements do not include the maximum calculated internal design pressure. CTS 6.20 includes the test pressure, which is higher than the maximum calculated internal design pressure for the LOCA. Therefore, ITS 5.5.14.b has been modified to include the maximum calculated internal design pressure for the LOCA and ITS 5.5.14.c has been modified to clarify the 46 psig pressure limit is the peak test pressure. Furthermore, due to these changes, two minor Bases changes have been made to ITS 3.6.1 and ITS 3.6.4. 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 VGC-012 Markup.pdf (2MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 4/5/2010 9:06 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2701 06/07/2010

Attachment 1, Volume 16, Rev. 0, Page 70 of 167 ITS A01 ITS 5.5 6.20 CONTAINMENT LEAKAGE RATE TESTING PROGRAM 5.5.14.a A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. The program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995. The provisions of TS 4.0.b do not apply to the test frequencies specified A08 in the Containment Leakage Rate Testing Program. The provisions of TS 4.0.c are Add proposed 5.5.14.e applicable to the Containment Leakage Rate Testing Program. calculated containment 5.5.14.b The peak calculated containment internal pressure for the design basis loss-of-coolant internal pressure and accident is less than the containment internal test pressure, Pa. The maximum allowable containment 5.5.14.c leakage rate (La) is 0.2 weight percent of the contained air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the peak test design pressure 5.5.14.b pressure (Pa) of 46 psig.

c M12 For penetrations which extend into the auxiliary building special ventilation zone, the combined leak rate from these penetrations shall not exceed 0.10La. For penetrations See ITS which are exterior to both the shield building and the auxiliary building special ventilation 3.6.3 zone, the combined leak rate from these penetrations shall not exceed 0.01La. If leak rates are exceeded, repairs and retest shall be performed to demonstrate reduction of the combined leak rate to these values.

5.5.14.d Leakage rate acceptance criteria:

5.5.14.d.1 a. The containment leakage rate acceptance criterion is 1.0La.

5.5.14.d.1 b. Prior to unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.6La for Type B and C tests and < 0.75La for the Type A test. L01

5.5.14.d.1 c. The personnel and emergency air lock leakage rates, when combined with the A09 cumulative Type B and C leakage, shall be < 0.6La. For each air lock door seal, the 5.5.14.d.2 leakage rate shall be < 0.005La when tested to 10 psig.

Add Proposed ITS 5.5.4 M03 Add Proposed ITS 5.5.5 M04 Add Proposed ITS 5.5.10 M07 Add Proposed ITS 5.5.11 M08 Add proposed ITS 5.5.13 M09 Add proposed ITS 5.5.15 M10 Add proposed ITS 5.5.16 M11 Amendment No. 190 TS 6.20-1 03/08/2007 Page 17 of 17 Attachment 1, Volume 16, Rev. 0, Page 70 of 167

Attachment 1, Volume 16, Rev. 0, Page 77 of 167 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS found in ITS 5.5.13. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.

M10 The CTS does not include a requirement for Battery Monitoring and Maintenance Program. The ITS includes a requirement for this program. This changes the CTS by adding the ITS 5.5.15, "Battery Monitoring and Maintenance Program."

The Battery Monitoring and Maintenance Program is included to provide for battery restoration and maintenance. The specific wording associated with this program may be found in ITS 5.5.15. This change is acceptable because it supports implementation of the requirements of the ITS. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.

M11 The CTS does not have a program for Setpoint Control. ISTS 5.5.18 (ITS 5.5.16) requires a program to satisfy the regulatory requirement of 10 CFR 50.36(c)(1)(ii)(A) that Technical Specifications will include items in the category of limiting safety system settings (LSSS), which are settings for automatic protective devices related to those variables having significant safety functions. This changes the CTS by incorporating the requirements of ISTS 5.5.18 (ITS 5.5.16).

The purpose of the program is to establish, implement, and maintain instrument setpoint controls for automatic protective devices related to those variables having significant safety functions. This change is designated as more restrictive because it imposes new programmatic requirements in the Technical Specifications.

INSERT M12 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.18.b.1 requires changes to the ODCM to be documented and records of reviews performed to be retained as required by the quality assurance program. CTS 6.18.b.2 requires changes to the ODCM to be effective after review and acceptance by the PORC. ITS 5.5.1.c.1 requires changes to the ODCM to be documented and records of reviews performed to be retained. ITS 5.5.1.c.2 requires changes to the ODCM to become effective after the approval of the plant manager. This changes the CTS by moving the record retention requirements reference and the PORC review and approval requirements to the Nuclear Facility Quality Assurance Program Description (NFQAPD). DOC M01 describes the addition of the plant manager approval.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Kewaunee Power Station Page 7 of 8 Attachment 1, Volume 16, Rev. 0, Page 77 of 167

M12 CTS 6.20 states that the peak calculated containment internal pressure for the design basis loss of coolant accident is less than the containment internal test pressure. The containment internal test pressure is defined as Pa in the CTS. ITS 5.5.14.b contains a specific value for the calculated peak containment internal pressure for the design basis loss of coolant accident and the containment design pressure. The calculated peak containment internal pressure for the design basis loss of coolant accident is defined as Pa in the ITS. This changes the CTS by adding a specific value for the calculated peak containment internal pressure for the design basis loss of coolant accident and a value for the containment design pressure.

The peak calculated containment internal pressure for the design basis loss of coolant accident is derived from the maximum containment pressure which is given as 44.6 psig at 19.9 seconds in USAR Table 14.3.5-8. The same maximum containment pressure was also reviewed and approved by the NRC as documented in the NRC Safety Evaluation for License Amendment 172 (the KPS Stretch Power Uprate), section 3.8.2.1.2.2, dated February 27, 2004 (ML040430633). The containment design pressure of 46 psig is also documented in the USAR and was reviewed and approved in the original USAR approval. This change is designated as more restrictive because it imposes new values that were not included in the CTS.

Attachment 1, Volume 16, Rev. 0, Page 99 of 167 CTS Programs and Manuals 5.5 5.5 Programs and Manuals 6.20 5.5.16 Containment Leakage Rate Testing Program (continued) 6 14 19

[OPTION B]

6.20 a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September, 1995, as .

modified by the following exceptions:

1. The visual examination of containment concrete surfaces intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, 20 will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRC.

2. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.

[ 3. ...]

6.20 b. The calculated peak containment internal pressure for the design basis loss 46 of coolant accident, Pa, is [45 psig]. The containment design pressure is 1 21 44.6

[50 psig].

Stet with changes 0.2 46 6.20 c. The maximum allowable containment leakage rate, La, at Pa, shall be [ ]% of 14 1 containment air weight per day. 46 psig (Peak Test Pressure)

d. Leakage rate acceptance criteria are:

6.20.a, 1. Containment leakage rate acceptance criterion is 1.0 La. During the 6.20.b first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and 0.75 La for Type A tests.

door seal leakage 6.20.c 2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is [0.05 La] when tested at Pa. 22 seal is a b) For each door, leakage rate is [0.01 La] when pressurized to

[ 10 psig]. < 0.005 of WOG STS 5.5-16 Rev. 3.1, 12/01/05 Attachment 1, Volume 16, Rev. 0, Page 99 of 167

Attachment 1, Volume 16, Rev. 0, Page 107 of 167 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS final version of the plant specific submittal. Therefore, the Reviewer's Note has been deleted.

16. The program details of the Explosive Gas and Storage Tank Radioactivity Monitoring Program are described in ISTS 5.5.12 (ITS 5.5.10) part a, b, and c.

Therefore, the sentence in the introductory paragraph that specifies a method to determine the explosive gas and storage tank radioactivity is not necessary.

Additionally, this change is consistent with the requirements in ODCM Sections 3/4.3 and 3/4.4.

17. ISTS 5.5.13.c requires the total particulate concentration of the fuel oil to be tested every 31 days. The current test frequency at KPS is 92 days (per plant procedures). ITS 5.5.11.c has been changed to be consistent with current KPS practices. KPS has reviewed the maintenance history of this test and determined that the proposed 92 day Frequency is sufficient to ensure total particulates stays within the new ITS 5.5.11.c limit of 10 mg/l. In addition, the KPS diesel storage tanks are outdoor tanks, subject to the weather. Thus, minimizing the number of times the tanks must be opened to obtain fuel oil samples will also benefit keeping snow, rain water, and other contaminants out of the storage tanks.

18. Changes are made to the ISTS which reflect the plant specific nomenclature.

19. Kewaunee Power Station (KPS) complies with Option B of 10 CFR 50, Appendix J. Therefore, the ISTS 5.5.16 Option A and combined Option A and B provisions have been deleted.

20. ISTS 5.5.16.a (ITS 5.5.14.a) contains exceptions to Regulatory Guide (RG) 1.163. The KPS Containment Leak Rate Testing Program does not take any exceptions to the RG 1.163 requirements. Therefore, these exceptions are deleted.

21. ISTS 5.5.16.b contains a statement with a bracketed value for the containment design pressure. The containment design pressure limit specified in ISTS Not used.

5.5.16.b has not been included because it currently does not exist in the KPS CTS, and because this limit does not provide any useful input to the Containment Leakage Rate Testing Program. Pa is the test pressure and thus is included in the ITS.

22. KPS does not include a separate overall air lock leakage limit; it is only included as part of the combined Types B and C leakage limit (0.60 La). Therefore, ISTS 5.5.16.d.2.a) has not been included. Due to this, there is no reason to include the requirements of ISTS 5.5.16.d.2.b) separate from ISTS 5.5.16.d.2. Thus it has been combined into ISTS 5.5.16.d.2. Furthermore, ISTS 5.5.16.d.2.b) states, in part, the air lock acceptance criteria for each door. The CTS 6.20.c states, in part, the air lock acceptance criteria for each air lock door seal. ITS 5.5.14.d.2) is written to address each air lock door seal. This is acceptable since the ITS is edited to reflect the text in the CTS and for clarification. Lastly, ISTS 5.5.16.d.2.b) (ITS 5.5.14.d) contains a bracketed value for the air lock door seal containment leakage rate acceptance criteria and the pressure to which each door seal is tested. The brackets have been removed for the pressure to which each door seal is tested and an acceptance criteria value of < 0.005 La has been Kewaunee Power Station Page 3 of 4 Attachment 1, Volume 16, Rev. 0, Page 107 of 167

Attachment 1, Volume 11, Rev. 0, Page 19 of 366 Containment (Dual) 1 B 3.6.1B BASES BACKGROUND (continued)

a. All penetrations required to be closed during accident conditions are either:

1. Capable of being closed by an OPERABLE automatic containment isolation system or  ;

4

2. Closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.3, "Containment Isolation Valves,"  ;

4

b. Each air lock is OPERABLE, except as provided in LCO 3.6.2, "Containment Air Locks," 4

5

c. All equipment hatches are closed, and .

[d. The pressurized sealing mechanism associated with a penetration is 5 OPERABLE, except as provided in LCO 3.6.[ ]. ]

APPLICABLE The safety design basis for the containment is that the containment must SAFETY withstand the pressures and temperatures of the limiting Design Basis ANALYSES Accident (DBA) without exceeding the design leakage rate.

The DBAs that result in a challenge to containment OPERABILITY from main 2 high pressures and temperatures are a LOCA, a steam line break, and a RCCA ejection rod ejection accident (REA) (Ref. 2). In addition, release of significant fission product radioactivity within containment can occur from a LOCA or 2 REA. In the DBA analyses, it is assumed that the containment is OPERABLE such that, for the DBAs involving release of fission product radioactivity, release to the environment is controlled by the rate of has 2 containment leakage. The containment was designed with an allowable 0.2 leakage rate of [0.1]% of containment air weight per day (Ref. 3). This 3 leakage rate, used in the evaluation of offsite doses resulting from 3

accidents, is defined in 10 CFR 50, Appendix J, Option [A][B] (Ref. 1), as La: the maximum allowable containment leakage rate at the calculated peak containment internal pressure (Pa) resulting from the limiting design basis LOCA. The allowable leakage rate represented by La forms the basis for the acceptance criteria imposed on all containment leakage rate testing. La is assumed to be [0.1]% per day in the safety analysis at 3 46 Pa = [46.3] psig (Ref. 3). 2 (Peak Test Pressure)

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

WOG STS B 3.6.1B-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 19 of 366

Attachment 1, Volume 11, Rev. 0, Page 115 of 366 Containment Pressure (Atmospheric, Dual, and Ice Condenser) 1 B 3.6.4A B 3.6 CONTAINMENT SYSTEMS B 3.6.4A Containment Pressure (Atmospheric, Dual, and Ice Condenser) 1 and simultaneous start of all four containment fan-coil units and both trains BASES BACKGROUND The containment pressure is limited during normal operation to preserve main the initial conditions assumed in the accident analyses for a loss of M 2 coolant accident (LOCA) or steam line break (SLB). These limits also annulus prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere in the event of inadvertent actuation of the Containment Spray System.

Containment pressure is a process variable that is monitored and integrity controlled. The containment pressure limits are derived from the input analyses conditions used in the containment functional analyses and the 2 containment structure external pressure analysis. Should operation occur outside these limits coincident with a Design Basis Accident (DBA), post accident containment pressures could exceed calculated values.

APPLICABLE Containment internal pressure is an initial condition used in the DBA SAFETY analyses to establish the maximum peak containment internal pressure.

ANALYSES M The limiting DBAs considered, relative to containment pressure, are the LOCA and SLB, which are analyzed using computer pressure transients. are MSLB more effects of The worst case LOCA generates larger mass and energy release than severe 2 those of the worst case SLB. Thus, the LOCA event bounds the SLB event from LOCA the containment peak pressure standpoint (Ref. 1). LOCA MSLB 2.15 The initial pressure condition used in the containment analysis was 16.85 [17.7] psia ([3.0] psig). This resulted in a maximum peak pressure from a 44.4 LOCA of [53.9] psig. The containment analysis (Ref. 1) shows that the 44.6 maximum peak calculated containment pressure, Pa, results from the 3 MSLB limiting LOCA. The maximum containment pressure resulting from the worst case LOCA, [44.1] psig, does not exceed the containment design 2 pressure, [55] psig. 45.68 maximum internal 46 allowed 0.8 The containment was also designed for an external pressure load equivalent to [-2.5] psig. The inadvertent actuation of the Containment 3 Spray System was analyzed to determine the resulting reduction in 14.7 psia containment pressure. The initial pressure condition used in this analysis (0.0 psig) was [-0.3] psig. This resulted in a minimum pressure inside containment 3 3

of [-2.0] psig, which is less than the design load. and simultaneous start of 13.917 psia all four containment fan-coil 2

(-0.783 psig) units and both trains WOG STS B 3.6.4A-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 115 of 366

Kewaunee ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 2791 NRC Question VGC-012 Number Select NRC Question Closure Application

Response

Date/Time Closure The licensee response was reviewed by Harold Walker in the Containment and Ventilation Statement Branch and was found to be acceptable per his e-mail dated 4/14/2010.

This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 4/20/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 4/20/2010 7:37 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2791 06/07/2010