ML12164A374

Kewaunee Power Station, Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications (TAC No. ME7110)

ML12164A374
Person / Time
Site:	Kewaunee
Issue date:	06/06/2012
From:	Price J A Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-349, TAC ME7110
Download: ML12164A374 (16)

Text

Dominion Energy Kewaunee, Inc. J5000 Dominion Boulevard, Glen Allen, VA 23060June 6, 2012U. S. Nuclear Regulatory Commission Serial No. 12-349Attention: Document Control Desk LIC/CDS/ROWashington, DC 20555 Docket No. 50-305License No. DPR-43DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATIONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:LICENSE AMENDMENT REQUEST 244, PROPOSED REVISION TORADIOLOGICAL ACCIDENT ANALYSIS AND CONTROL ROOM ENVELOPEHABITABILITY TECHNICAL SPECIFICATIONS (TAC NO. ME7110)By application dated August 30, 2011 (Reference 1), Dominion Energy Kewaunee, Inc.(DEK), requested an amendment to Facility Operating License Number DPR-43 forKewaunee Power Station (KPS). This proposed amendment (LAR 244) would revisethe KPS Operating License by modifying the Technical Specifications (TS) and thecurrent licensing basis (CLB) to incorporate changes to the current radiological accidentanalysis (RAA) of record. This amendment would also fulfill a commitment made to theNRC in response to Generic Letter 2003-01, "Control Room Habitability" (Reference 2)to submit proposed changes to the KPS TS based on the final approved version ofTSTF-448, "Control Room Habitability."Subsequently, on March 13, 2012 the Nuclear Regulatory Commission (NRC) stafftransmitted a request for additional information (RAI) regarding the proposedamendment (Reference 3). The following RAI questions and associated DEKresponses are provided in Attachment 1 to this letter.* ME71 10-RAII-AADB-Brown-005-2012-05-13" ME71 10-RAII-AADB-Brown-006-2012-05-13" ME71 10-RAII-AADB-Brown-007-2012-05-13* ME71 1 0-RAII-SCVB-Torres-001 -2012-05-12" ME71 10-RAII-SCVB-Torres-002-2012-05-12* ME71 10-RAII-SCVB-Torres-003-2012-05-12/I DIQ Serial No. 12-349LAR 244 RAI ResponsePage 2 of 3If you have any questions or require additional information, please contact Mr. Craig Slyat 804-273-2784.Si nclerely,A~LJ. PriceVice President -Nuclear Engineering-----IqIiVICKI L. HULLNotary PublicCommonweaith of Virginla140542My Commission Expires May 31. 2014wCOMMONWEALTH OF VIRGINIACOUNTY OF HENRICO)))IThe foregoing document was acknowledged before me, in and for the County and Stateaforesaid, today by J. Alan Price, who is Vice President -Nuclear Engineering, of DominionEnergy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and filethe foregoing document in behalf of that Company, and that the statements in the document aretrue to the best of his knowledge and belief.Acknowledged before me this _ day of 1My Commission Expires:,/AqL ,_ 3. 1. 2e2/4(.2012.J/Nofary PublicAttachment:1. NRC Request for Additional Information Questions and Dominion EnergyKewaunee ResponsesEnclosure:1. LAR 244, Attachment 3, Replacement Marked-up Technical Specification BasesPage B 3.7.10-9Commitments made in this letter: None Serial No. 12-349LAR 244 RAI ResponsePage 3 of 3References:1. Letter from J. A. Price (DEK) to Document Control Desk (NRC), "LicenseAmendment Request 244, Proposed Revision to Radiological Accident Analysisand Control Room Envelope Habitability Technical Specifications," dated August30, 2011. [ADAMS Accession No. ML11252A521]2. Letter from Craig W. Lambert (NMC) to Document Control Desk (NRC), "GenericLetter 2003-01; Control Room Habitability -Supplemental Response," dated April1, 2005. [ADAMS Accession No. ML050970303]3. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly and Jack Gadzala (DEK),"ME7110 Kewaunee -Request for Additional Information (RAI) AADB and SCVB2012-04-12," dated April 13, 2012. [ADAMS Accession No. ML12107A144]cc: Regional Administrator, Region IIIU. S. Nuclear Regulatory Commission2443 Warrenville RoadSuite 210Lisle, IL 60532-4352Mr. K. D. FeintuchProject ManagerU.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 08-H4A11555 Rockville PikeRockville, MD 20852-2738NRC Senior Resident InspectorKewaunee Power StationPublic Service Commission of WisconsinElectric DivisionP.O. Box 7854Madison, WI 53707 Serial No. 12-349ATTACHMENT 1RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:LICENSE AMENDMENT REQUEST 244, PROPOSED REVISION TORADIOLOGICAL ACCIDENT ANALYSIS AND CONTROL ROOM ENVELOPEHABITABILITY TECHNICAL SPECIFICATIONSNRC REQUEST FOR ADDITIONAL INFORMATION QUESTIONS AND DOMINIONENERGY KEWAUNEE RESPONSESKEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.

Serial No. 12-349Attachment 1Page 1 of 10NRC REQUEST FOR ADDITIONAL INFORMATION QUESTIONS AND DOMINIONENERGY KEWAUNEE RESPONSESOn March 2, 2012 the Nuclear Regulatory Commission (NRC) staff transmitted arequest for additional information (RAI) (Reference 3) regarding Dominion EnergyKewaunee, Inc. (DEK) proposed amendment LAR 244 (Reference 1). The followingRAI questions and associated DEK responses are provided in Attachment 1 to thisletter.* ME71 1 0-RAI I-AADB-Brown-005-2012-05-13* ME71 1 0-RAI I-AADB-Brown-006-2012-05-13" ME71 10-RAII-AADB-Brown-007-2012-05-13* ME7 110-RAII-SCVB-Torres-001-2012-05-12" M E7110-RAII-SCVB-Torres-002-2012-05-12" M E7 11 0-RAI I-SCVB-Torres-003-2012-05-12ME711 0-RAII-AADB-Brown-005-2012-05-13The LAR states that Figure 3.1-1, "Kewaunee Source and Receptor Points," ofAttachment 4 provides a relative scaled drawing of the Kewaunee Power Stationbuilding orientation and control room location showing all identified release points andreceptors. The figure is very informative, but does not appear to be drawn entirely toscale and/or to have all sources and receptors positioned on the figure based upon thescale. For example, Table 3.1-1, "Line-of Sight Horizontal Distance from Source toReceptor," of Attachment 4, lists the distances from the "SG [steam generator] B PORV[power operated relief valve]" and "SG B Dumps" to the Control Room Intake as 12.06meters (m) and 24.81 m, respectively. However, in Figure 3.1-1, the SG B Dumpsappear to be slightly closer to the Control Room Intake than the SG B PORV. Pleaserevise Figure 3.1-1 to provide the scaled position of each source and receptor, asappropriate, to confirm the information provided in Table 3.1-1 and Table 3.1-2,"Direction from Receptor to Source," of Attachment 4.Response:Figure 3.1-1 was revised and scaled to more accurately identify the physical orientationof release points and receptors. The revised Figure 3.1-1 is provided below.

Serial No. 12-349Attachment 1Page 2 of 10Figure 3.1-1 Kewaunee Source and Receptor PointsI 7 E 4 i la1I 4 t ! oh r4i4F f T Y T ~ ' I T '01 ~ ~ ~ 00 00 ~~44 4~p4-.-.Iii -Shield .. ..----H--- -- Building44-Reactor Building0 0 ý-R-14i-Ios ITRecepor Pi -4-44:: -Iittth -of2o ,ICO;.>-I --4,, "~** :Control,.... , : ' .J :,Room0102-, 0- 'i1~.... ThrOb 0;.0011-u 0010Turbine Building:1.,1m0SIGSGS 0SGSORER,21-+ -5L300 ft00 Boudin 101as Ri I 14.r~rr~~r: Ms 11.00 1+4~ r1ht.. .ii~+/-. .. ...22ai ... .......-lonI~eel --i- IL:J10 .1C .z .... H.... -H H -051 1 1- p~~-.000 1; L: ]L EE- --27, 21.S11 1.03.-.r I :-- --E-]E [~h E ]T....... ..... -I-.I.. ..W ai-f:c.L1 1 i. -i I. I .-4-4.-::[jj4 iI-t -I HT jr -:000251~k LCIOC.0000;~ 11f.. 4-1 41-J 1+/-ILT+00 ]~ ~ 4 ~ IU1~;u__ t2.34 I.Is-i-F Serial No. 12-349Attachment 1Page 3 of 10ME7110-RAII-AADB-Brown-006-2012-05-13Page 29 of Attachment 4 states: "As a result of the analyses documented in this LAR,the alternate control room intake will be restricted from use. This restriction is requiredbecause of the X/Q that would result due to the close proximity of the alternate intake tovarious release points; one of which is < [less than] 10 m from the alternate intake.Administrative controls will be in place to assure the alternate control room intake isclosed and prohibit its use during normal operation, following an accident, or whilemoving recently irradiated fuel."a. With regard to Figure 3.1-1, where is the alternative CR intake?b. Describe the conditions under which its use is permitted.c. Provide the inputs to the CR atmospheric dispersion factor (X/Q value) estimatesfor each design basis accident which could occur when the alternative CR intakeis in use.Response:a. Figure 3.1-1 was revised to include the identification where the alternative CRintake is located. See response to Question 5 above.b. There is no longer any condition for which the alternate control room intake willbe used and administrative controls will be in place to prohibit the use of thealternative CR intake and applicable procedures will be revised accordingly. Foradditional information regarding maintaining the alternate CR intake closed at alltimes see DEK response to Question 9 in Reference 4.c. The alternative CR intake will no longer be a potential intake to the control room.There is no likelihood of leakage into the control room through this pathway dueto the bubble-tight damper design and the fact that the alternate CR intakedampers will be maintained closed. Therefore, CR atmospheric dispersion factor(X/Q value) estimates were not generated for the alternate CR intake.

Serial No. 12-349Attachment 1Page 4 of 10ME71 I 0-RAII-AADB-Brown-007-2012-05-13Please confirm that the values in Tables 3.1-1 and 3.1-2 are correct. For example, isthe distance from the Auxiliary Building Stack and Equipment Hatch to the ControlRoom Intake 39.60 m for both source locations?Response:The values in Table 3.1-1 and 3.1-2 were verified as correct. The distance between theAuxiliary Building Stack and the Control Room Intake and the distance between theEquipment Hatch and the Control Room Intake are both 39.60 meters.

Serial No. 12-349Attachment 1Page 5 of 10ME7110-RAII-SCVB-Torres-001-2012-05-12TSTF-448 "Control Room Habitability", was developed for plants with pressurizedcontrol room envelopes. You stated that your plant has a non-pressurized control roomenvelope. Note that in the programs and manuals section of the standard technicalspecifications (STS) as modified by TSTF-448 revision 3, paragraph (d) of section[5.5.18], "Control Room Envelope Habitability Program,", specifies a differentialpressure (dp) test to be conducted between performances on inleakage testing for thepurpose of providing input to a periodic assessment of the control room envelope (CRE)boundary. The NRC staff recognizes that non-pressurized control room envelopes maynot be able to conduct a dp test, nevertheless, the staff believes that all plantsrequesting adoption of TSTF-448 should include in their request, a method to collectdata that will serve as input in a periodic assessment of the CRE boundary. Thisposition is supported by the technical analysis section of the TSTF-448 revision 3 onpage 8 where an explanation of the basis for paragraph (d) is provided. Consequently,the staff is requesting that you provide a method to collect data, and an explanation ofhow you intend to use it, that can be use as input to a periodic assessment of your CREboundary. The method should, to the extent practicable, provide information that canbe used in a manner similar to the manner in which the information is to be used that isrequested by paragraph (d) of section [5.5.18] of the programs and manuals section ofthe STS as modified by revision 3 of TSTF-448.Response:DEK recognized that TSTF-448, Revision 3, Section 5.5.18, paragraph d, specified thata differential pressure test was to be conducted between performances of inleakagetesting for the purpose of providing input to a periodic assessment of the CREboundary. As noted above, the KPS control room ventilation system is designed tomaintain the control room at a neutral pressure. As a neutral pressure control room, theresults of measuring differential pressure between the control room and adjacent areasare subject to much variation. This variation may be caused by ventilation systemconfigurations, location and sensitivity of instrumentation, and the effects of weatherconditions and building structures on intake air. Furthermore, in Generic Letter 2003-01(Reference 5) the NRC also called into question the usefulness of differential pressuremeasurements of CREs in general. Based upon this information, and a review of thedifferential pressure data taken during the December 2004 tracer gas testing performedon the KPS CREZ, it is concluded that a pressurization (differential pressure) test for theCRE boundary would not yield useful data regarding the status of the KPS neutralpressure control room. In lieu of a differential pressurization test, DEK conductspreventative maintenance (PM) and surveillance tests (STs) that provide assurance thatthe CRE boundary is maintained in a manner that will provide protection for theoperators. The data from these PMs and STs will be used as a means of monitoring the Serial No. 12-349Attachment 1Page 6 of 10health of the CRE between the quantitative in-leakage tracer gas tests. A discussion ofthese PMs and STs are provided below.1. Damper Maintenance (PM) -Once every two operating cycles, inspect andreplace (as necessary) the Control Room Ventilation dampers' mechanicalcomponents and internal blade seals with parts.2. Control Room Air Conditioning Mechanical Inspection and Maintenance (PM) -Once per year, inspect and replace (as necessary) control room ventilationboundary components including:a. Door inspections -Inspection and repair/replacement of weather stripseals of the control room envelope doors.b. Cable tray penetration inspections -Inspection and repair, as necessary,of the relay room electrical cable tray penetrations.3. Penetration Fire Barrier Inspection (PM) -Once per operating cycle inspect andrepair (as necessary) the fire and steam exclusion barrier penetrationsassociated with the CRE.4. Post Accident Recirculation Test (ST) -Monthly functional test of the emergencyventilation filter components.5. Control Room Post Accident Recirculation Train Operability Testing (ST) -Monthly functional test of the Control Room emergency ventilation system.6. Control Room Post Accident Train Recirculation Filter Testing (ST) -At leastonce per operating cycle, test the HEPA filters and charcoal adsorber banks.Fan flows are also obtained during this testing and verified to be within allowabledesign flow rate limits. The charcoal adsorber flow rates are also verified aswithin TS limits. Ensuring maintenance of proper flow rates reduces thepossibility of control room pressure changes which may affect unfiltered in-leakage.7. Auxiliary Building Special Ventilation Operability Test (ST) -Monthly verificationof closure of some CRE boundary dampers, which are also steam exclusiondampers.8. RMS Channel R-23, Control Room Ventilation Radiation Monitor Quarterly Test(ST) -Quarterly test for actuation of the control room ventilation system from ahigh radiation signal.In addition to the above PMs and STs the Barrier Control Procedure providesinstructions for managing and controlling the integrity of the CRE. This includes Serial No. 12-349Attachment 1Page 7 of 10permitting and managing opening and total opening size in the CRE, managingimpairments and logging TS requirements for the CRE.Any criteria that are not met while performing any of these activities are documentedand resolved in accordance with the KPS Corrective Action Program. Appropriateactions are identified and implemented to restore the degraded conditions and assessthe impact on the CRE boundary. These procedures and processes ensure that theKPS CRE boundary can perform its safety function in a similar manner to performing apressurization test and trending the test data. This information will be reviewed as partof the required periodic assessment of the CRE boundary.

Serial No. 12-349Attachment 1Page 8 of 10ME7110-RAII-SCVB-Torres-002-2012-05-12In Attachment 3 to your letter dated July 25, 2011 you provided a mark-up of theTechnical Specification (TS) Bases pages. On page B.3.7.10-9 you referred to NEI 99-03 Section 8.4 and Appendix F and to Reference 5 of the attachment. Reference 5 isNEI 99-03, "Control Room Habitability Assessment" dated March 2003. The TedhnicalSpecifications Task Force (TSTF) determined that this reference is in error (see theTSTF letter to the NRC dated December 29, 2006, Agencywide Document andManagement System (ADAMS) Accession No. ML063630467). The correct referenceis NEI 99-03, "Control Room Habitability Assessment", dated June 2001. In order to beconsistent with both the intent of TSTF-448 Revision 3 and NEI 99-03 dated June 2001,you are requested to update your submittal to refer to of NEI 99-03 dated June 2001.However, if you insist on using NEI 99-03 dated March 2003 you will need to providethis document on the NRC docket for NRC staff review and approval and be prepared toprovide acceptable answers to all questions that may result from that review.Response:This question was deleted by the NRC staff.

Serial No. 12-349Attachment 1Page 9 of 10ME71 I 0-RAII-SCVB-Torres-003-2012-05-12Please verify that Reference 4 "Regulatory Guide 1.196, Rev. 2," is the correct versionof the regulatory guide being used at Kewaunee.Response:The reference to Regulatory Guide 1.196, Revision 2 is not correct (see LAR 244,Attachment 3, marked-up TS Bases page B 3.7.10-9, Reference 4). Reference 4 on TSBases page 3.7.10-9 should be "Regulatory Guide 1.196, Revision 1."A corrected copy of marked-up TS Bases page B 3.7.10-9 is provided in Enclosure 1 ofthis letter.

Serial No. 12-349Attachment 1Page 10 of 10References1. Letter from J. A. Price (DEK) to Document Control Desk (NRC), "LicenseAmendment Request 244, Proposed Revision to Radiological Accident Analysisand Control Room Envelope Habitability Technical Specifications," dated August30, 2011. [ADAMS Accession No. ML11252A521]2. Letter from Craig W. Lambert (NMC) to Document Control Desk (NRC), "GenericLetter 2003-01; Control Room Habitability -Supplemental Response," dated April1, 2005. [ADAMS Accession No. ML050970303]3. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly and Jack Gadzala (DEK),"ME7110 Kewaunee -Request for Additional Information (RAI) AADB and SCVB2012-04-12," dated April 13, 2012. [ADAMS Accession No. ML12107A144]4. Letter from J. A. Price (DEK) to Document Control Desk, "Response to Request forAdditional Information: License Amendment Request 244, Proposed Revision toRadiological Accident Analysis and Control Room Envelope Habitability TechnicalSpecifications (TAC No ME7110)," dated April 30, 2012. [ADAMS Accession No.ML12124A283]5. Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003 [ADAMSAccession No. ML031620248]

Serial No. 12-349Enclosure 1ENCLOSURE 1RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:LICENSE AMENDMENT REQUEST 244, PROPOSED REVISION TORADIOLOGICAL ACCIDENT ANALYSIS AND CONTROL ROOM ENVELOPEHABITABILITY TECHNICAL SPECIFICATIONSNRC REQUEST FOR ADDITIONAL INFORMATION QUESTIONS AND DOMINIONENERGY KEWAUNEE RESPONSESLAR 244, Attachment 3, Replacement Marked-up TS Bases Page B 3.7.10-9KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE INC.

CRPAR SystemB 3.7.10The CRE is considered habitable when the radiological dose to CREoccupants calculated in the licensing basis analyses of DBAconsequences is no more than 5 rem TEDE and the CRE occupants areprotected from hazardous chemicals and smoke. This SR verifies thatthe unfiltered air inleakage into the CRE is no greater than the flow rateassumed in the licensing basis analyses of DBA consequences. Whenunfiltered air inleakage is greater than the assumed flow rate. Condition Bmust be entered. Required Action B.3 allows time to restore the CREboundary to OPERABLE status provided mitigating actions can ensurethat the CRE remains within the licensing basis habitability limits for theoccupants following an accident. Compensatory measures are discussedin Regulatory Guide 1.196. Section C.2.7.3. (Ref. 4) which endorses, withexceptions. NEI 99-03. Section 8.4 and Appendix F (Ref. 5). Thesecompensatory measures may also be used as mitigating actions asrequired by Required Action B.2. Temporary analytical methods may alsobe used as compensatory measures to restore OPERABILITY (Ref. 3).Options for restoring the CRE boundary to OPERABLE status includechanging the licensing basis DBA consequence analysis, repairing theCRE boundary. or a combination of these actions. Depending upon thenature of the problem and the corrective action. a full scope inleakagetest may not be necessary to establish that the CRE boundary has beenrestored to OPERABLE status.REFERENCES 1. USAR, Section 9.6.4.2. USAR, Chapter 14.3. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI). "NEI DraftWhite Paper. Use of Generic Letter 91-18 Process and AlternativeSource Terms in the Context of Control Room Habitability." datedJanuary 30. 2004. [ADAMS Accession No. ML040300694].4. Regulatory Guide 1.196. Rev. 1.5. NEI 99-03. "Control Room Habitability Assessment Guidance." June200-.6. Letter from C. R. Steinhardt to NRC. "Submittal of Kewaunee'sUpdated Control Room Habitability Evaluation Report to AddressConcerns Over Control Room Ventilation." dated February 28, 1989.7. USAR Section 9.6.4.Kewaunee Power Station B 3.7.10-9 Amendment No. 20702/02/2011