ML101890242

Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) - Kewaunee ITS Conversion Database

ML101890242
Person / Time
Site:	Kewaunee
Issue date:	06/02/2010
From:	Dominion Energy Kewaunee
To:	Office of Nuclear Reactor Regulation
References
Download: ML101890242 (29)

Text

ITS NRC Questions Id 1161 NRC Question Number ALK-005 Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number JFD Number JFD Bases Number Page Number(s) Section 4.2.1 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Section 5.3.a of the CTS contains the statement, Limited substitutions of zirconium alloy, ZIRLOTM, or stainless steel filler rods for fuel rods, in accordance with NRC-approved [emphasis added] applications of fuel rod configurations, may be used. Section 4.2.1 of the proposed ITS contains the statement, Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved [emphasis added] applications of fuel rod configurations, may be used. Eliminating NRC-in front of approved could be interpreted to mean that KPS can now use fuel rod configurations that have not been approved by the NRC but may have been approved by other organizations or entities. Please provide justification for why eliminating NRC-in front of approved does not constitute a less restrictive change.

Attach File 1

Attach File 2

Issue Date 11/23/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/23/2009 8:44 AM Notification NRC/LICENSEE Supervision Audrey Klett Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1161 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 1 of 29

Licensee Response/NRC Response/NRC Question Closure Id 901 NRC Question Number ALK-005 Select Application Licensee Response

Response

Date/Time 11/24/2009 12:40 PM Closure Statement

Response

Statement The words "NRC-approved" in CTS 5.3.a (Page 7) and "approved" in ITS 4.2.1 Page 15) have the identical meaning. The words in the KPS proposed ITS 4.2.1 are identical to the approved ISTS 4.2.1. KPS does not believe that the NRC's intent in ISTS 4.2.1 is to allow other organizations or entities to approve fuel configurations. Since the Technical Specifications are approved and issued by the NRC, it is KPS position that the word "approved" means approved by the NRC.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 11/24/2009 12:42 PM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=901 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 2 of 29

Licensee Response/NRC Response/NRC Question Closure Id 1161 NRC Question Number ALK-005 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 12/3/2009 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/3/2009 12:55 PM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1161 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 3 of 29

Licensee Response/NRC Response/NRC Question Closure Id 1211 NRC Question Number ALK-005 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 12/14/2009 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/14/2009 8:26 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1211 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 4 of 29

ITS NRC Questions Id 1171 NRC Question Number ALK-006 Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number JFD Number JFD Bases Number Page Number(s) Section 4.2.1 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Section 5.3.a of the CTS states in part, Each assembly shall consist of a matrix of zircaloy or ZIRLOTM clad fuel rods []. Limited substitutions of zirconium alloy, ZIRLOTM, or stainless steel [] may be used. Section 4.2.1 of the proposed ITS states, in part, Each assembly shall consist of a matrix of Zircalloy or ZIRLO fuel rods []. Limited substitutions of zirconium alloy or stainless steel [] may be used. (1) Please clarify whether there are any differences between ZIRLO and ZIRLOTM, such as differences in chemical composition and/or manufacturer. (2)

Eliminating ZIRLOTM from the statement, Limited substitutions of zirconium alloy, ZIRLOTM, or stainless steel [] may be used, in the TS could be interpreted to mean that KPS may use substitution filler rods for fuel rods of zirconium alloy having a different chemical composition than ZIRLOTM (or ZIRLO). Please provide justification for why eliminating ZIRLOTM from the referenced statement does not constitute a less restrictive change.

Attach File 1

Attach File 2

Issue Date 11/23/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/23/2009 8:46 AM Page 1 of 2 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1171 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 5 of 29

Notification NRC/LICENSEE Supervision Audrey Klett Page 2 of 2 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1171 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 6 of 29

Licensee Response/NRC Response/NRC Question Closure Id 911 NRC Question Number ALK-006 Select Application Licensee Response

Response

Date/Time 11/24/2009 12:45 PM Closure Statement

Response

Statement The term ZIRLO is a trademarked name. Thus in the KPS CTS, the term "TM" follows the word ZIRLO. However, the ISTS wording does not include the "TM" term, since using the words ZIRLO (all in capital letters) implies that this is the title of a special type of fuel. That is, the NRC decided not to include the term "TM" to annotate the word ZIRLO is a trademarked name.

The statement in the CTS discussing limited substitutions includes a ZIRLO allowance. The ISTS does not include this term because it is already covered by the term "zirconium alloy." ZIRLO is a zirconium alloy type fuel. Therefore, since the term in the ISTS (and ITS) zirconium alloy encompasses the ZIRLO brand of fuel, it is redundant and is not necessary to be included in the allowance.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 11/24/2009 12:44 PM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=911 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 7 of 29

Licensee Response/NRC Response/NRC Question Closure Id 1221 NRC Question Number ALK-006 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 12/14/2009 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/14/2009 8:27 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1221 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 8 of 29

ITS NRC Questions Id 1441 NRC Question Number ALK-007 Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number M-1 JFD Number 4 JFD Bases Number Page Number(s) Vol 15; page 17 of 20 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question KPS proposed to replace WOG STS 4.3.1.1.e and f with, Spent fuel assemblies stored in the north and south pools and the canal pool in accordance with LCO 3.7.15, Spent Fuel Pool Storage., in the KEW ITS. The STS address storage of both new and spent fuel assemblies, but the proposed statement appears to only address storage of spent fuel assemblies. Please clarify if the spent fuel storage pools would contain any new fuel assemblies or if all new fuel assemblies are stored in the new fuel storage pit. Please also clarify if and/or how Figure 3.7.15-1 of the KEW ITS applies to storage of new fuel assemblies.

Attach File 1 Attach File 2 Issue Date 1/6/2010 Added By Audrey Klett Date Modified Modified By Date Added 1/6/2010 3:58 PM Notification NRC/LICENSEE Supervision Audrey Klett Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1441 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 9 of 29

Licensee Response/NRC Response/NRC Question Closure Id 1811 NRC Question Number ALK-007 Select Application Licensee Response

Response

Date/Time 1/20/2010 10:40 AM Closure Statement

Response

Statement Currently, there are no specific requirements in the KPS CTS for the storage of new fuel assemblies. However, after further review, Kewaunee Power Station will add this new requirement into the ITS. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment, as well as the supplement to Section 3.7 of the ITS conversion amendment.

Question Closure Date Attachment 1 ALK-007 Markup.pdf (2MB)

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 1/20/2010 10:43 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1811 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 10 of 29

DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES Kewaunee Power Station Page 1 of 3 ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev.

3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 5.4.a.1.a and 5.4.a.2.a states that the spent fuel storage racks and the new fuel storage racks, respectively, are designed and shall be maintained with the fuel assemblies having a maximum enrichment of 56.067 grams Uranium-235 per axial centimeter. ITS 4.3.1.1.a and 4.3.1.2.a states that the spent fuel storage racks and the new fuel storage racks, respectively, are designed and shall be maintained with the fuel assemblies having a maximum U-235 enrichment of 4.9776 weight percent. This changes the CTS by specifying the weight percent of the U-235 enrichment instead of the actual weight per axial centimeter.

The purpose of CTS 5.4.a.1.a and 5.4.a.2.a is to specify the maximum amount of uranium for a fuel assembly per axial centimeter. Based on Westinghouse letter BD-03-193, Rev. 0, dated December 11, 2003, 56.067 grams of U-235 per axial centimeter corresponds to 4.9776 weight percent of U-235. Therefore, the ITS percent weight is the same as the CTS actual weight. This change is acceptable and is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 ITS 4.3.1.1.c requires that spent fuel storage racks in the Fuel Transfer Canal Pool are designed and maintained to have a nominal 8.3 inch rack cell lattice spacing between fuel assemblies in order to prevent criticality of the spent fuel assemblies. ITS 4.3.1.1.d requires that spent fuel storage racks in the North and South Pools Combined are designed and maintained to have a minimum 10 inch center to center distance between fuel assemblies in order to prevent criticality of the spent fuel assemblies. ITS 4.3.1.1.e provides the requirements for loading spent fuel assemblies in accordance with ITS LCO 3.7.15. The CTS does not contain this information. This changes the CTS by adding specific requirements for the design and maintenance of the spent fuel storage racks.

The purpose of ITS 4.3.1.1.c and 4.3.1.1.d is to prevent criticality in the Fuel Transfer Canal spent fuel pool and the North and South Pools Combined spent fuel pool. USAR Section 9.5.1.1 describes KPS General Design Criterion (GDC) 66, Prevention of Fuel Storage Criticality, which states, in part, that criticality in the new and spent fuel storage pools shall be prevented by physical systems or processes. Such means, as geometrically safe configurations shall be emphasized over procedural controls. The establishment of minimum spacing design requirements for the spent fuel storage racks assists in meeting the, Volume 15, Rev. 0, Page 11 of 20, Volume 15, Rev. 0, Page 11 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 11 of 29 new and

DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES Kewaunee Power Station Page 2 of 3 requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. This change is acceptable because it provides appropriate limits for the spent fuel storage racks.

The purpose of ISTS 4.3.1.1.e is to provide requirements for loading spent fuel assemblies in accordance with ISTS Figure 3.7.15-1 into the appropriate spent fuel pool. License Amendment 150 allows KPS to store only those spent fuel assemblies prior to or from the 1984 refueling outage in the Canal Pool storage racks. The design of the Canal Pool is fixed and the storage of spent fuel assemblies is restricted by the licensing requirements of License Amendment 150. Therefore, ITS 4.3.1.1.e has been revised to state that the spent fuel assemblies in both the North and South Pools and the Canal Pool shall be in accordance with LCO 3.7.15. LCO 3.7.15 is more applicable for placement of the requirements of the spent fuel assemblies in the spent fuel pools at KPS than ITS 4.0. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

M02 ITS 4.3.1.2.d requires that new fuel storage racks are designed and maintained to have a nominal 21 inch center to center distance between fuel assemblies in order to prevent criticality of the spent fuel assemblies. The CTS does not contain this information. This changes the CTS by adding specific requirements for the design and maintenance of the new fuel storage racks.

The purpose of ITS 4.3.1.2.d is to prevent criticality in the new fuel storage pool.

USAR Section 9.5.1.1 describes KPS GDC 66, Prevention of Fuel Storage Criticality, which states, in part, that criticality in the new fuel storage pit and the spent fuel storage pools shall be prevented by physical systems or processes.

Such means, as geometrically safe configurations shall be emphasized over procedural controls. The establishment of minimum spacing design requirements for the new fuel storage racks assists in meeting the requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. Furthermore, USAR Table 9.5-1 states that the center to center spacing of assemblies is 21 inches for the new fuel storage pit. This change is acceptable because it provides appropriate limits for the new fuel storage racks. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 5.2 describes the various design features of the containment. The ITS does not contain this information. This changes the CTS by moving the description of the containment to the USAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not, Volume 15, Rev. 0, Page 12 of 20, Volume 15, Rev. 0, Page 12 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 12 of 29 new and new and

Design Features 4.0 WOG STS 4.0-2 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1

4.0 DESIGN FEATURES 4.3 Fuel Storage (continued)

[ e. New or partially spent fuel assemblies with a discharge burnup in the "acceptable range" of Figure [3.7.17-1] may be allowed unrestricted storage in [either] fuel storage rack(s), and ]

[ f.

New or partially spent fuel assemblies with a discharge burnup in the "unacceptable range" of Figure [3.7.17-1] will be stored in compliance with the NRC approved [specific document containing the analytical methods, title, date, or specific configuration or figure]. ]

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a.

Fuel assemblies having a maximum U-235 enrichment of

[4.5] weight percent,

b.

keff 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in [Section 9.1 of the FSAR],

c.

keff 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties as described in [Section 9.1 of the FSAR], and

d.

A nominal [10.95] inch center to center distance between fuel assemblies placed in the storage racks.

4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft].

4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than [1737] fuel assemblies.

1205 2

5.4.b CTS 21 U

U 5

DOC M01 5.4.a.2.a 5.4.a.2.b 5.4.a.2.c DOC M02 3

2 3

2 3

5 5

6 4

4 Spent fuel assemblies stored in the north and south pools and the canal pool in accordance with LCO 3.7.15, "Spent Fuel Pool Storage."

4.9776 2

2, Volume 15, Rev. 0, Page 17 of 20, Volume 15, Rev. 0, Page 17 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 13 of 29 New and

3.7.15 Insert Page 3.7.17-1 INSERT 1 the spent fuel pool shall be in accordance with the following:

a.

Irradiated fuel assemblies discharged prior to or during the 1984 refueling outage with a combination of burnup and initial nominal enrichment in the "Acceptable Domain" of Figure 3.7.15-1 shall be stored in the transfer canal spent fuel pool or the north and south combined spent fuel pools; and

b.

Irradiated fuel assemblies discharged after the 1984 refueling outage and irradiated fuel assemblies with a combination of burnup and initial nominal enrichment in the "Unacceptable Domain" of Figure 3.7.15-1 shall be stored in the north and south combined spent fuel pools.

2, Volume 12, Rev. 0, Page 331 of 415, Volume 12, Rev. 0, Page 331 of 415 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 14 of 29 New fuel assemblies, discharged prior to or during the 1984 refueling outage

[Spent Fuel Pool Storage]

B 3.7.17 WOG STS B 3.7.17-1 Rev. 3.0, 03/31/04 15 5

B 3.7 PLANT SYSTEMS B 3.7.17 [ Spent Fuel Pool Storage ]

BASES BACKGROUND In the Maximum Density Rack (MDR) [(Refs. 1 and 2)] design, the spent fuel storage pool is divided into two separate and distinct regions which, for the purpose of criticality considerations, are considered as separate pools. [Region 1], with [336] storage positions, is designed to accommodate new fuel with a maximum enrichment of [4.65] wt% U-235, or spent fuel regardless of the discharge fuel burnup. [Region 2], with

[2670] storage positions, is designed to accommodate fuel of various initial enrichments which have accumulated minimum burnups within the acceptable domain according to Figure 3.7.17-1, in the accompanying LCO. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance with paragraph 4.3.1.1 in Section 4.3, Fuel Storage.

The water in the spent fuel storage pool normally contains soluble boron, which results in large subcriticality margins under actual operating conditions. However, the NRC guidelines, based upon the accident condition in which all soluble poison is assumed to have been lost, specify that the limiting keff of 0.95 be evaluated in the absence of soluble boron. Hence, the design of both regions is based on the use of unborated water, which maintains each region in a subcritical condition during normal operation with the regions fully loaded. The double contingency principle discussed in ANSI N-16.1-1975 and the April 1978 NRC letter (Ref. 3) allows credit for soluble boron under other abnormal or accident conditions, since only a single accident need be considered at one time. For example, the most severe accident scenario is associated with the movement of fuel from [Region 1 to Region 2], and accidental misloading of a fuel assembly in [Region 2]. This could potentially increase the criticality of [Region 2]. To mitigate these postulated criticality related accidents, boron is dissolved in the pool water. Safe operation of the MDR with no movement of assemblies may therefore be achieved by controlling the location of each assembly in accordance with the accompanying LCO. Prior to movement of an assembly, it is necessary to perform SR 3.7.16.1.

2 2

990 The canal pool INSERT 1 The north and south pools (combined) 215 2

are 2

2 the spent fuel pool three separate pools separate pool and the transfer canal 2

3 the north and south combined pools this 2

All changes are unless otherwise noted 1

4 all three separate pools within the Unacceptable Domain region the north and south pools (combined) 5 15 15 15 14 5

5 4.9776 reactivity the inadvertent placement of a fresh (unirradiated) fuel assembly into a location restricted to a burned assembly, Volume 12, Rev. 0, Page 336 of 415, Volume 12, Rev. 0, Page 336 of 415 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 15 of 29 stet which have been discharged prior to or during the 1984 refueling outage and New fuel assemblies, spent fuel assemblies which have been discharged after the 1984 outage, or spent

[Spent Fuel Pool Storage]

B 3.7.17 WOG STS B 3.7.17-2 Rev. 3.0, 03/31/04 15 5

BASES APPLICABLE The hypothetical accidents can only take place during or as a result of SAFETY the movement of an assembly (Ref. 4). For these accident occurrences, ANALYSES the presence of soluble boron in the spent fuel storage pool (controlled by LCO 3.7.16, "Fuel Storage Pool Boron Concentration") prevents criticality in both regions. By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time. During the remaining time period with no potential for accidents, the operation may be under the auspices of the accompanying LCO.

The configuration of fuel assemblies in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The restrictions on the placement of fuel assemblies within the spent fuel pool, in accordance with Figure 3.7.17-1, in the accompanying LCO, ensures the keff of the spent fuel storage pool will always remain < 0.95, assuming the pool to be flooded with unborated water. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance with Specification 4.3.1.1 in Section 4.3.

APPLICABILITY This LCO applies whenever any fuel assembly is stored in [Region 2] of the fuel storage pool.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

When the configuration of fuel assemblies stored in [Region 2] the spent fuel storage pool is not in accordance with Figure 3.7.17-1, or paragraph 4.3.1.1, the immediate action is to initiate action to make the necessary fuel assembly movement(s) to bring the configuration into compliance with Figure 3.7.17-1 or Specification 4.3.1.1.

If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

3 3

4 2

All changes are unless otherwise noted 1

spent spent 2

4 4

2 the north or south pools (combined) 5 15 5

5 5

15 in the Acceptable Domain 15 15 LCO 3.7.15 and 4

LCO 3.7.15 and, Volume 12, Rev. 0, Page 338 of 415, Volume 12, Rev. 0, Page 338 of 415 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 16 of 29 Irradiated fuel assemblies discharged prior to or during the 1984 refueling outage with a combination of burnup and initial nominal enrichment in the Acceptable Domain of Figure 3.7.15-1 are allowed to be stored in the transfer canal spent fuel pool or the north and south combined spent fuel pools New fuel assemblies, irradiated fuel assemblies discharged after the 1984 refueling outage, or spent 5

Licensee Response/NRC Response/NRC Question Closure Id 2001 NRC Question Number ALK-007 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 2/2/2010 Notification NRC/LICENSEE Supervision Audrey Klett Added By Audrey Klett Date Added 2/2/2010 8:48 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2001 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 17 of 29

ITS NRC Questions Id 1451 NRC Question Number ALK-008 Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number JFD Number 5 JFD Bases Number Page Number(s) Vol. 15; page 17 of 20 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested Y NRC Question KPS proposed to not adopt STS 4.3.2 regarding drainage of the spent fuel storage pool (SFP), which states, The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft]. Although the SFP may be designed to prevent inadvertent draining, the STS also require that the pool be maintained to prevent inadvertent draining of the SFP below [23 ft]. STS 4.3.2 also appears to be applicable when fuel is present in the SFP, regardless of whether or not there is movement of irradiated fuel assemblies in the SFP. Without this design feature requirement, there is no TS requirement to maintain SFP level for when KPS ITS LCO 3.7.13 is not applicable.

Although KPS stated that the current TS have no requirements for SFP level, the current KPS TS 5.4.3 requires, in part, that the SFP is filled with borated water whenever there is fuel in the pool.

Given the available operating experience associated with the draining of SFPs, ITSB staff is concerned about: (1) the effect on the SFP level if the check valves in the SFP cooling return lines failed and how the failure would be identified; (2) how defects or cracks in the SFP liner would be identified; (3) how the licensee verifies the SFP level in accordance with the analysis in Revision 21.5 of the KPS USAR, Section 9.5.3.1.2, which credits 20 feet (or 25 feet, which needs clarification) of water covering the spent fuel as protection for the fuel from tornado missiles; and (4) what level is required to be maintained in the SFP at all times for radiation protection purposes. The NRC staff is requesting a teleconference with Kewaunee staff regarding adopting STS 4.3.2 in the KPS ITS.

Attach File 1

Attach File 2

Issue Date 1/6/2010 Added By Audrey Klett Page 1 of 2 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1451 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 18 of 29

Date Modified Modified By Date Added 1/6/2010 4:04 PM Notification NRC/LICENSEE Supervision Audrey Klett Page 2 of 2 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1451 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 19 of 29

Licensee Response/NRC Response/NRC Question Closure Id 1821 NRC Question Number ALK-008 Select Application Licensee Response

Response

Date/Time 1/20/2010 10:45 AM Closure Statement

Response

Statement After further review, Kewaunee Power Station will add this new requirement into the ITS. 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 ALK-008 Markup.pdf (803KB)

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 1/20/2010 10:47 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1821 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 20 of 29

Amendment No. 162 TS 5.4-1 09/19/2002 5.4 FUEL STORAGE APPLICABILITY Applies to the capacity and storage arrays of new and spent fuel.

OBJECTIVE To define those aspects of fuel storage relating to prevention of criticality in fuel storage areas.

SPECIFICATION

a. Criticality

1. The spent fuel storage racks are designed and shall be maintained with the following:

a. Fuel assemblies having a maximum enrichment of 56.067 grams Uranium-235 per axial centimeter

b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties

2. The new fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum enrichment of 56.067 grams Uranium-235 per axial centimeter

b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties

c. keff < 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties

3. The spent fuel pool is filled with borated water at a concentration to match that used in the reactor REFUELING cavity and REFUELING canal during REFUELING OPERATIONS or whenever there is fuel in the pool.

b. Capacity The spent fuel storage pool is designed with a storage capacity of 1205 assemblies and shall be limited to no more than 1205 fuel assemblies.

c. Canal Rack Storage Fuel assemblies stored in the canal racks shall meet the minimum required fuel assembly burnup as a function of nominal initial enrichment as shown in Figure TS 5.4-1. These assemblies shall also have been discharged prior to or during the 1984 REFUELING outage.

Page 5 of 7 A01 ITS 4.0 ITS 4.3.1.1.a 4.3.1.1.b 4.3.1.2.a 4.3.1.2.b 4.3.1.2.c 4.3.2 See ITS 3.7.14 M01 Add proposed 4.3.1.1.c, 4.3.1.1.d, and 4.3.1.1.e Add proposed 4.3.1.2.d M02 See ITS 3.7.15 A02 4.9776 weight percent A02 4.9776 weight percent, Volume 15, Rev. 0, Page 8 of 20, Volume 15, Rev. 0, Page 8 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 21 of 29 3

Add proposed 4.3.2 M03

DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES Kewaunee Power Station Page 2 of 3 requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. This change is acceptable because it provides appropriate limits for the spent fuel storage racks.

The purpose of ISTS 4.3.1.1.e is to provide requirements for loading spent fuel assemblies in accordance with ISTS Figure 3.7.15-1 into the appropriate spent fuel pool. License Amendment 150 allows KPS to store only those spent fuel assemblies prior to or from the 1984 refueling outage in the Canal Pool storage racks. The design of the Canal Pool is fixed and the storage of spent fuel assemblies is restricted by the licensing requirements of License Amendment 150. Therefore, ITS 4.3.1.1.e has been revised to state that the spent fuel assemblies in both the North and South Pools and the Canal Pool shall be in accordance with LCO 3.7.15. LCO 3.7.15 is more applicable for placement of the requirements of the spent fuel assemblies in the spent fuel pools at KPS than ITS 4.0. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

M02 ITS 4.3.1.2.d requires that new fuel storage racks are designed and maintained to have a nominal 21 inch center to center distance between fuel assemblies in order to prevent criticality of the spent fuel assemblies. The CTS does not contain this information. This changes the CTS by adding specific requirements for the design and maintenance of the new fuel storage racks.

The purpose of ITS 4.3.1.2.d is to prevent criticality in the new fuel storage pool.

USAR Section 9.5.1.1 describes KPS GDC 66, Prevention of Fuel Storage Criticality, which states, in part, that criticality in the new fuel storage pit and the spent fuel storage pools shall be prevented by physical systems or processes.

Such means, as geometrically safe configurations shall be emphasized over procedural controls. The establishment of minimum spacing design requirements for the new fuel storage racks assists in meeting the requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. Furthermore, USAR Table 9.5-1 states that the center to center spacing of assemblies is 21 inches for the new fuel storage pit. This change is acceptable because it provides appropriate limits for the new fuel storage racks. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 5.2 describes the various design features of the containment. The ITS does not contain this information. This changes the CTS by moving the description of the containment to the USAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not, Volume 15, Rev. 0, Page 12 of 20, Volume 15, Rev. 0, Page 12 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 22 of 29 Insert DOC M03

M03 ITS 4.3.2 requires that spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 645 ft 2 inches (mean sea level).

The CTS does not contain this information. This changes the CTS by adding a new requirement for the design and maintenance of the spent fuel storage pool.

The purpose of ITS 4.3.2 is to prevent the spent fuel pool from being inadvertently drained such that an unanalyzed criticality event could occur in the spent fuel storage pool. USAR Table 9.5-2, Item 6 describes the KPS design conformance to Safety Guide

13. The proposed water level ensures this design conformance requirement is maintained. This change is acceptable because it provides an appropriate design requirement to prevent inadvertent draining of the spent fuel storage pool. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 23 of 29

Design Features 4.0 WOG STS 4.0-2 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1

4.0 DESIGN FEATURES 4.3 Fuel Storage (continued)

[ e. New or partially spent fuel assemblies with a discharge burnup in the "acceptable range" of Figure [3.7.17-1] may be allowed unrestricted storage in [either] fuel storage rack(s), and ]

[ f.

New or partially spent fuel assemblies with a discharge burnup in the "unacceptable range" of Figure [3.7.17-1] will be stored in compliance with the NRC approved [specific document containing the analytical methods, title, date, or specific configuration or figure]. ]

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a.

Fuel assemblies having a maximum U-235 enrichment of

[4.5] weight percent,

b.

keff 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in [Section 9.1 of the FSAR],

c.

keff 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties as described in [Section 9.1 of the FSAR], and

d.

A nominal [10.95] inch center to center distance between fuel assemblies placed in the storage racks.

4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft].

4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than [1737] fuel assemblies.

1205 2

5.4.b CTS 21 U

U 5

DOC M01 5.4.a.2.a 5.4.a.2.b 5.4.a.2.c DOC M02 3

2 3

2 3

5 5

6 4

4 Spent fuel assemblies stored in the north and south pools and the canal pool in accordance with LCO 3.7.15, "Spent Fuel Pool Storage."

4.9776 2

2, Volume 15, Rev. 0, Page 17 of 20, Volume 15, Rev. 0, Page 17 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 24 of 29 Stet Stet w/changes 645 ft 2 inches (mean sea level)

JUSTIFICATION FOR DEVIATIONS ITS 4.0, DESIGN FEATURES Kewaunee Power Station Page 1 of 1

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.

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.

3.

The 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.

4.

The spent fuel pool configuration at Kewaunee Power Station (KPS) consists of North and South Pools and a Canal Pool. Spent fuel assemblies of varying enrichment may be stored in the North and South Pools. However, with the creation of the Canal Pool, limitations on the enrichment of the spent fuel that could be stored in the Canal Pool were imposed via License Amendment 150 dated January 23, 2001 (ADAMS accession No. ML010240051). License Amendment 150 states that only assemblies which have been discharged prior to or during the 1984 refueling outage are permitted to be stored in the Canal Pool.

License Amendment 150 also utilized the concept of burnup reactivity equivalencing for the storage of the spent fuel in the Canal Pool. This concept is based on the reactivity decrease associated with fuel depletion and has been previously found acceptable by the NRC for use in PWR fuel storage analysis. A series of reactivity calculations is performed to generate a set of enrichment versus burnup ordered pairs which yield an equivalent k-eff of less than 0.95 (approximately 0.945) for fuel stored in the storage racks. The requirements of ISTS 4.3.1.1.e and 4.3.1.1.f, which address the applicable discharge burnup limitations, are addressed in LCO 3.7.15, "Spent Fuel Pool Storage," for the KPS ITS.

5.

ISTS 4.3.2 states the spent fuel pool is designed and shall be maintained to prevent inadvertent draining of the pool. The information in Item 6 of Kewaunee Power Station (KPS) Updated Safety Analysis Report (USAR) Table 9.5-2, "Design Conformance with Safety Guide 13," reflects that no drains have been provided for the spent fuel storage pool. In addition, the USAR states that since the pump suction connections extend no more than two feet below normal water level, there is also no possibility of inadvertently draining pool water below that level. As an additional measure to ensure against inadvertent draining of the spent fuel pool by a siphon effect, each spent fuel pool cooling return line contains a check valve to prevent reverse flow. Therefore, the information in ISTS 4.3.2 has been deleted as it is considered not applicable to the design of KPS.

6.

ISTS 4.3.2 has been deleted as discussed in Justification For Deviations (JFD) 5.

As a result, Section 4.3.3 has been appropriately renumbered., Volume 15, Rev. 0, Page 18 of 20, Volume 15, Rev. 0, Page 18 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 25 of 29

Licensee Response/NRC Response/NRC Question Closure Id 1991 NRC Question Number ALK-008 Select Application NRC Response

Response

Date/Time 2/2/2010 6:00 PM Closure Statement

Response

Statement The level in WOG STS 4.3.2 corresponds to [23 feet] over the top of irradiated fuel assemblies. KPS proposed a value corresponding to 645'2" (mean sea level). Please clarify why this level was chosen and how many feet over the top of irradiated fuel assemblies this level corresponds to.

Question Closure Date Notification NRC/LICENSEE Supervision Victor Cusumano Audrey Klett Added By Audrey Klett Date Added 2/2/2010 8:41 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1991 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 26 of 29

Licensee Response/NRC Response/NRC Question Closure Id 2171 NRC Question Number ALK-008 Select Application Licensee Response

Response

Date/Time 2/15/2010 3:45 PM Closure Statement

Response

Statement ISTS 4.3.2, "Drainage" states "The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft.]" The 23 ft limit is in brackets and it does not specifically state the 23 ft limit is 23 ft above the top of the irradiated fuel assemblies.

It uses the term "elevation," which implies a level based on an external value, such as mean sea level. The bracketed requirement means that KPS is to put in the plant specific design requirement for the KPS spent fuel storage pool.

Kewaunees design is discussed in the following USAR references.

UFSAR Section 9.3.4.2.3, Leakage Provisions, Spent Fuel Pool Cooling states: Since the pump suction connections extend no more than 2 feet below normal water level, there is no possibility of inadvertently draining pool water below that level. UFSAR 9.3.4.3.3, Incident Control, Spent Fuel Pool Cooling states: The possibility of a line failure causing complete drainage is precluded by the fact that the suction lines do not extend more than 2 feet below normal operating level. This leaves a margin of 22 feet above the top of the fuel assemblies.

From UFSAR Figure 9.5-2, Spent Fuel Pool and New Fuel Storage Plan (drawing M-234), Detail X, Skimmer Intake, the elevation at which pump suction is lost (bottom of the skimmer intake) is 645 feet 2 inches.

Therefore, the elevation of 645 feet 2 inches is the elevation KPS specifies in ITS 4.3.2, Drainage, associated with system design.

Regarding relative elevations:

649 6 Refueling Floor 647 4 SFP High Level Alarm

< 647 4 > 646 2 Normal SFP level 646 2 SFP Low Level Alarm 645 6 23 feet above fuel 645 2 Bottom of Skimmer Intake 644 6 22 feet above fuel 622 6 Top of the fuel 608 Spent Fuel Pool floor As shown above, an elevation of 645 2 is 22 8 above the top of the fuel.

Page 1 of 2 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2171 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 27 of 29

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 2/15/2010 3:47 PM Modified By Date Modified Page 2 of 2 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2171 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 28 of 29

Licensee Response/NRC Response/NRC Question Closure Id 2531 NRC Question Number ALK-008 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 3/12/2010 Notification NRC/LICENSEE Supervision Victor Cusumano Audrey Klett Added By Audrey Klett Date Added 3/12/2010 7:54 AM Modified By Date Modified Page 1 of 1 Kewaunee ITS Conversion Database 06/02/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2531 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 29 of 29