ML100700300

Draft RAI Re. Use of TSTF-490-A in Kewaunee'S ITS Conversion

ML100700300
Person / Time
Site:	Kewaunee
Issue date:	03/11/2010
From:	Tam P Plant Licensing Branch III
To:	Breene T, Gadzala J, Sommers D Dominion Energy Kewaunee
Tam P
References
TAC ME2139
Download: ML100700300 (3)

Text

Accession NO. ML100700300 From: Tam, Peter Sent: Thursday, March 11, 2010 9:35 AM To: Jack Gadzala (jack.gadzala@dom.com); Thomas Breene (thomas.l.breene@dom.com); Davis Sommers (david.sommers@dom.com)

Cc: Benton, Laray; Tate, Travis; Cusumano, Victor; Grover, Ravinder

Subject:

Kewaunee - Draft RAI re. TSTF-490-A in ITS conversion amendment (TAC ME2139)

Jack, Dave:

Please forward this e-mail to Dominion personnel who are involved with the proposed ITS conversion amendment.

The NRC staff is reviewing Dominion Energy Kewaunee's application to convert the current Kewaunee custom Tech Spec into the Improved Standard Tech Spec (ITS) format. As part of its review, the NRC staff has determined that additional information, set forth below, is needed to complete its review of the issue regarding the proposed adoption of TSTF-490-A.

1. In the subject license amendment application, the licensee proposed to adopt industry standard technical specifications which include proposed Limiting Condition for Operation (LCO) 3.4.16, "RCS Specific Activity," APPLICABILITY requirements to specify that the LCO is applicable in MODES 1, 2, 3, and 4. In accordance with this proposal, the licensee also proposed to add the NOTE that states, "Only required to be performed in MODE 1" to the surveillance requirements of the TS, thus removing the applicability of the surveillance requirements to other MODES.

The NRC staff has a concern about the proposed addition of the aforementioned NOTE. The proposed change revises the conditions for sampling, and may exclude sampling during the plant conditions where LCO 3.4.16 may be exceeded. After transient conditions (i.e. reactor trip, plant depressurization, shutdown or startup) that end in MODES 2, 3, or 4, the SR is not required to be performed. Isotopic spiking and fuel failures are more likely during transient conditions than during steady-state plant operations.

Because LCO 3.4.16 could potentially be exceeded after plant transient or power changes, please justify why sampling is no longer needed in the plant MODES that are proposed to be eliminated and justify how the LCO 3.4.16 remains consistent with the design bases analysis from which the LCO limits are derived (i.e. main steamline break, steam generator tube rupture, etc.). Furthermore, please justify why there is an apparent disparity between the modes of applicability (MODES 1, 2, 3, and 4) and the limited mode (MODE 1) under which the surveillance is required. In addition, please provide marked up TS pages identifying your proposed changes.

2. The licensee stated:

The Dose Conversion Factors used in the determination of DOSE EQUIVALENT I-131 AND Xe-133 are consistent with the Dose Conversion factors used in the applicable dose consequence analysis.

Consistent with the safety evaluation for TSTF-490, please confirm that the site-specific limits for both DEI and DEX, and the dose conversion factors (DCFs) used for the determination of DEI and DEX surveillances, are consistent with the current design-basis radiological dose consequence analyses (i.e. steam generator tube rupture and main steamline break). Also, for both DEI and DEX, please provide the information necessary (dose conversion factors and reactor coolant system radioisotopic concentrations) for the NRC staff to verify the proposed value in the LCO.

In addition, please provide marked up TS pages identifying your proposed changes.

Please set up a conference call with me to discuss disposition of the above draft questions. Note that this draft RAI is part of the ITS conversion review; as such, Dominion's response should be provided within the schedular framework to support the NRC staff's completion of the ITS review.

This e-mail does not at this time formally request for information, and does not formally convey an NRC staff position. Its sole purpose is to prepare you and others for the proposed conference call.

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Tel. 301-415-1451 E-mail Properties Mail Envelope Properties (0A64B42AAA8FD4418CE1EB5240A6FED10E15E300DA)

Subject:

Kewaunee - Draft RAI re. TSTF-490-A in ITS conversion amendment (TAC ME2139)

Sent Date: 3/11/2010 9:35:01 AM Received Date: 3/11/2010 9:35:00 AM From: Tam, Peter Created By: Peter.Tam@nrc.gov Recipients:

jack.gadzala@dom.com (Jack Gadzala (jack.gadzala@dom.com))

Tracking Status: None thomas.l.breene@dom.com (Thomas Breene (thomas.l.breene@dom.com))

Tracking Status: None david.sommers@dom.com (Davis Sommers (david.sommers@dom.com))

Tracking Status: None Laray.Benton@nrc.gov (Benton, Laray)

Tracking Status: None

Travis.Tate@nrc.gov (Tate, Travis)

Tracking Status: None Victor.Cusumano@nrc.gov (Cusumano, Victor)

Tracking Status: None Ravinder.Grover@nrc.gov (Grover, Ravinder)

Tracking Status: None Post Office:

HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 16252 3/11/2010 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: