ML12219A222

Kewaunee, Response to Request for Additional Information: License Amendment Request 244, Proposed Revision to Radiological Accident Analysis and Control Room Envelope Habitability Technical Specifications

ML12219A222
Person / Time
Site:	Kewaunee
Issue date:	08/03/2012
From:	Price J A Dominion Energy Kewaunee, Dominion
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-419, TAC ME7110
Download: ML12219A222 (50)

Text

Dominion Energy Kewaunee, Inc.Dominion5000 Dominion Boulevard, Glen Allen, VA 23060 --nAugust 3, 2012U. S. Nuclear Regulatory Commission Serial No. 12-419Attention: 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 May 15, 2012, the Nuclear Regulatory Commission (NRC) stafftransmitted a request for additional information (RAI) regarding the proposedamendment (Reference 3 and 4). The following RAI questions and associated DEKresponses are provided in Attachment 1 to this letter." ME71 1 0-RAII-EICB-Alva-008-2012-06-15* ME71 10-RAII-EICB-Alva-009-2012-06-15* M E7 11 0-RAI I-SCVB-Torres-004-2012-06-15" ME71 10-RAII-SCVB-Torres-005-2012-06-15* ME71 10-RAII-SCVB-Torres-006-2012-06-15* ME7 11 0-RAI I-SCVB-Torres-007-2012-06-15" ME7 11 0-RAI I-SCVB-Torres-008-2012-06-15* M E7110-RAII-SCVB-Torres-009-2012-06-15* ME71 1 0-RAII-SCVB-Torres-01 0-2012-06-15" ME71 1 0-RAII-SCVB-Torres-01 1-2012-06-15* ME71 1 0-RAII-SCVB-Torres-012-2012-06-150 tO-Z D!Serial No. 12-419LAR 244 RAI ResponsePage 2 of 3If you have any questions or require additional information, please contact Mr. Craig Slyat 804-273-2784.Sincerely,J. rice-Vice President- Nuclear Engineering VICKt L. HULLCommonwealth of Virginia M ,140542-ICOMMONWEALTH OF VIRGINIA my Commission Expires May 31, 2014COUNTY OF HENRICOThe 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 S_ :_day oft A ,2012.My Commission Expires: /AlA ./ a/Notary PublicAttachment:1. NRC Request for Additional Information Questions and Dominion EnergyKewaunee ResponsesEnclosure:1. LAR 244, Attachment 3, Replacement Marked-up Technical Specification Pagesand Technical Specification Bases PagesCommitments made in this letter:1. A revised Locked Rotor Analysis will be pursued by DEK to address an emergentissue identified at Kewaunee Power Station. This revised analysis will be providedas a supplement to LAR-244.

Serial No. 12-419LAR 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),"ME71 10 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET -EICBinput," dated May 15, 2012. [ADAMS Accession No. ML1 2137A003]4. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly and Jack Gadzala (DEK),"ME71 10 SCVB Draft RAI set Re: adoption of TSTF-51 & TSTF- 448, as part ofChi-over-Q action," dated May 15, 2012. [ADAMS Accession No. ML12138A007]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. 12-419ATTACHMENT IRESPONSE 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. 12-419Attachment 1Page 1 of 17NRC REQUEST FOR ADDITIONAL INFORMATION QUESTIONS AND DOMINIONENERGY KEWAUNEE RESPONSESOn May 15, 2012 the Nuclear Regulatory Commission (NRC) staff transmitted tworequests for additional information (RAI) (Reference 3 and 4) regarding DominionEnergy Kewaunee, Inc. (DEK) proposed amendment LAR 244 (Reference 1). Thefollowing RAI questions and associated DEK responses are provided in Attachment 1 tothis letter." ME71 1 0-RAI I-EICB-Alva-008-2012-06-15* ME71 10-RAII-EICB-Alva-009-2012-06-15* ME71 10-RAII-SCVB-Torres-004-2012-06-15* ME71 10-RAII-SCVB-Torres-005-2012-06-15" M E7 11 0-RAI I-SCVB-Torres-006-2012-06-15" ME71 10-RAII-SCVB-Torres-007-2012-06-15" ME71 10-RAII-SCVB-Torres-008-2012-06-15" ME71 10-RAII-SCVB-Torres-009-2012-06-15" ME71 10-RAII-SCVB-Torres-010-2012-06-15* ME71 10-RAII-SCVB-Torres-01 1-2012-06-15* ME71 10-RAII-SCVB-Torres-012-2012-06-15ME71 I 0-RAII-EICB-Alva-008-2012-06-15Background:NUREG-0737, "Clarification of TMI Action Plan Requirements," Item II1.D.3.4, "ControlRoom Habitability Requirements," required licensees to assure that control roomoperators will be adequately protected against the effects of accidental release of toxicand radioactive gas and that the plant can be safely operated or shutdown under designbasis accident conditions.Currently, Dominion Energy Kewaunee (DEK)'s Kewaunee Power Station uses either asafety injection (SI) signal or high radiation detection (R-23) to automatically isolate thecontrol room and start 100 percent recirculation (CRPAR). R-23 continuously monitorsthe Control Room environment for an indication of airborne activity (radiation) enteringthrough the Control Room ventilation system. If R-23 senses a high radiation condition,the monitor initiates closure of the outside air intake, provides a signal that isolates thecontrol room ventilation system and starts the control room post-accident recirculationsystem. R-23 in conjunction with other radiation monitors demonstrates compliancewith NUREG-0737.

Serial No. 12-419Attachment 1Page 2 of 17R-23 is credited in the current Radiation Accident Analysis (RAA) for mitigating theconsequences of an accident. Based on 10 CFR 50.36 criteria, Technical Specification(TS) actions and surveillance requirements for R-23 should be included in Kewaunee'sTS.The LAR-244 proposes removing radiation monitor channel R-23 from TS to theKewaunee's Technical Requirements Manual (TRM). DEK is proposing to creditmanual actuation of SI to isolate the control room and start CRPAR. Justifications forrelocating R-23 to the TRM are:* Radiation monitor R-23 is not safety grade" R-23 is a single radiation monitor" R-23 is a partial signal that will not close all control room inlet and outletventilationEICB Question (ME7110-RAII-EICB-Alva-002-2011-12-29) -If R-23 is removed fromTS, how will DEK comply with NUREG-0737, Item III.D.3.4?NUREG-0737 requires safety grade radioactivity monitors required for automaticisolation purpose. SRP 6.4 habitability systems, Section 2.0, item B states that: "Singlefailure of an active component should not result in loss of the system's functionalperformance. All the components of the control room emergency filter train should beconsidered active components." Even though DEK recognized inconsistency with theserequirements, DEK justified use of a single radioactivity monitor installed in the controlroom HVAC system air supply. This was justified because the automatic isolationfunction is accomplished by actuation of safety injection or high radiation in the controlroom air supply. These signals are diverse and provide adequate protection.Further, in 1983 Kewaunee performed an analysis to show how the control room wouldbe isolated during design basis accidents (DBA) if R-23 fails. In this analysis, DEKexplained that failure of R-23 would cause an alarm in the control room alerting thecontrol operators of loss of its function, and other radiation monitors (R-1 and R-5) willdetect and confirm the presence of unusual levels of radiation at the radiationmonitoring panel located in the control room, or a control room ventilation systemisolation signal would occur, such that the single monitor in the air intake would neverbe the sole means of isolating that system. However, R1 and R-5 only warns operatorsto the presence of an abnormal condition. Thus, the operator would have to manuallyisolate the control room.The NRC's safety evaluation (SE) for NUREG-0737 found that the control roomhabitability systems were acceptable and would provide a safe, habitable environmentunder DBA radiation and toxic gas conditions. In this SE, the staff stated that forradiation monitor, a radiation monitor in addition to R-23 should alarm in the controlroom or a control room ventilation system isolation signal would occur, such that the Serial No. 12-419Attachment 1Page 3 of 17single monitor in the air intake would never be the sole means of isolating that system.High radiation signal detected by R-23 and SI signal would initiate the CRPAR system.LAR-244 is proposing relocating R-23 from TS to TRM. R-23 would remain part of thecontrol room isolation logic and control room post-accident recirculation system(CRPAR), providing defense-in-depth for the control room isolation function.LAR-244 and RAI response received on January 25, 2012 justified relocating R-23based on a revised RAA without crediting the isolation function provided by R-23. DEKis proposing to credit operator actions to isolate the control room or a SI signal toperform isolation of the control room. DEK states that this is sufficient to meet therequirements in NUREG-0737.Further, if R-23 is not credited in the revised RAA, R-23 won't meet the criteria in 10CFR 50.36 to remain in TS.Based on this information, the NRC staff has the following follow up question:a) If an SI signal is not actuated and there is a radiation release, how will DEK meetthe NUREG-0737 requirement for automatic isolation capability?b) The basis to TS 3.12 indicates that the recirculation filter system is designed toautomatically start on a safety injection signal or a high radiation signal. How willthe design of the recirculation filter system be modified if R-23 is relocated toTRM?c) The current design considers the safety injection signal providing a diversemeans of post-accident actuation for R-23. If R-23 is relocated to the TRM, whatcomponent will provide diverse means for the SI signal?Response:(Note: Based on discussions with the NRC staff concerning DEK's proposal in LAR-244to relocate R-23 from the KPS Technical Specifications to the Technical RequirementsManual, DEK has decided to leave the existing TS in place and modify the wording ofthe TS bases to reflect the proposed new licensing basis for R-23. A revised copy of TS3.3.7, "CRPAR System Actuation Instrumentation," and the associated TS 3.3.7 Basesis provided in Enclosure 1.)a) The capability of R-23 to automatically isolate the control room is not being removedor modified. In LAR 244, DEK proposed only that R-23 be relocated from the KPSTechnical Specifications to the KPS Technical Requirements Manual. The testingrequirements for R-23 would not be changed.There are two accident scenarios for which an SI signal will not or may not occur,the fuel handling accident (FHA) and the locked rotor accident (LRA). For the FHA,DEK proposed a new TS limiting condition for operation that would require the Serial No. 12-419Attachment 1Page 4 of 17control room envelope to be isolated during movement of recently irradiated fuel.Therefore, the CRE does not need to "automatically" isolate in order to ensurecontrol room habitability after a FHA because the CRE will be required to be pre-isolated. In the case of the LRA, DEK has proposed a simple manual operatoraction to isolate the control room within one hour after initiation of a LRA. Thismanual action was proposed to compensate for the proposed TS changes thatwould discontinue credit for automatic isolation of the control room using a highradiation signal from R-23. The rationale and regulatory basis for crediting themanual action is described in LAR 244, Attachment 5. While the proposed manualaction is not an "automatic" action, DEK believes that the proposed manual action issimple and can be readily accomplished.b) The design of the recirculation filter system, which includes automatically starting ona safety injection signal or a high radiation signal from R-23, is not changed by theproposed revision.c) The CRPAR system actuation logic is actuated by a safety injection signal. Thelogic consists of two trains of automatic actuation logic and actuation relays. Bothtrains of automatic actuation logic are required to be maintained operable per KPSTS 3.3.7. Therefore, for design basis accidents that rely on an SI signal to actuatethe CRPAR system, redundant safety-related actuation logic is in place and willcontinue to remain in place.As stated in response a) above, R-23 will continue to function as presently designedand continue to provide a diverse means of isolating the control room. Therelocation of the TS related to R-23 to the TRM was proposed only because DEKconsidered the relocation consistent with the criteria of 10 CFR 50.36.

Serial No. 12-419Attachment 1Page 5 of 17ME71 10-RAII-EICB-Alva-009-2012-06-15Background:KPS UFSAR Rev 23, page 9.6-12 states:The operator can add fresh air to the Control Room under post-accident conditions byfirst verifying that conditions at the intake plenum will not cause contamination of theControl Room atmosphere, then manually opening the selected outside air damper andthe damper at the suction of the post-accident recirculation fans. Excess air isexhausted to the Turbine Room through a backdraft damper. The operator can confirmthe incoming fresh/recirculation air mix is not contaminating the Control Roomatmosphere by observing a radiation monitor channel in the Control Room. Dampercontrol switches are spring return to the normal position so that when the dampercontrol switches are released the dampers automatically return to the recirculationconfigurationSince this is an isolation design, the control room needs to supplement the breathableair after a week to 10 days to keep the air habitable. Please explain if the radiationmonitor credited in the UFSAR for fresh air is R-23.Response:The USAR statement above contains requirements to; 1) verify that conditions at theintake plenum would allow the intake to be opened, and; 2) confirm that while intake isopen, the incoming air is not causing additional control room contamination.1. Procedure AOP-ACC-001, "Abnormal Control Room A/C System Operation,"provides guidance for system operation under design basis accident conditions.The normal and alternate air intakes are verified to be shut if a valid SI, HighRadiation or Steam Exclusion signal exists. This procedure presently allowsoperators to open either control room intake for a short duration to provide fresh airto the control room. (Note: Procedure AOP-ACC-001 will be revised as part of theimplementation process for this amendment to not allow opening of the alternateintake. See response to ME711O-RAII-AADB-Blum-009-2012-03-02 in Reference4 for details.) Fresh air would be introduced through the control room charcoal andHEPA filters. This procedure requires that operators in the control room requestradiation protection personnel verify that conditions at the intake plenum will notlikely cause contamination of the control room atmosphere after opening the inletdamper for fresh air. This verification is required to be performed prior to openingthe inlet damper.2. After the intake damper is opened, operators would use R-23 to monitor radiationlevels in the air being introduced to the control room. The radiation levels can bemonitored at a panel mounted readout or a panel mounted pen recorder, both ofwhich are located in the control room.

Serial No. 12-419Attachment 1Page 6 of 17ME71 10-RAII-SCVB-Torres-004-2012-06-15As presented in Table 3.6-1 of Attachment 4, "Basic Data and Assumptions for LockedRotor Accident (LRA)," unfiltered inleakage at 800 cfm is not assumed until the controlroom is isolated at 60 minutes following the onset of an accident. Provide justificationfor assuming zero inleakage during the first 60 minutes while the control room is notisolated, discuss the potential radiation dose from inleakage during this time period.Response:Prior to control room isolation, during operation of normal ventilation (unfiltered intakemode) the control room would be slightly pressurized which would tend to decreaseunfiltered inleakage or result in net outleakage. Furthermore, compared to theconcentration of radioactivity that would exist at the intake on the roof of the auxiliarybuilding, which is only about 12 meters from the assumed worst case release point froma LRA (Steam Generator B PORV), the concentrations in areas where inleakage couldoccur would be significantly less. Therefore, inleakage was not included for the firsthour of the LRA, prior to control room isolation. DEK verified that dose consequencesfrom inleakage during the first hour are insignificant. Assuming an additional 800 cfm ofunfiltered inleakage flow 'during the first 60 minutes 'of the LRA results in a doseincrease of approximately 100 mRem TEDE to the control room occupants. The totaldose remains less than the reported dose of 4.7 Rem TEDE provided in Table 3.6-2 ofLAR-244.A revised LRA analysis is being conducted to address an emergent issue identified atKPS. A recent discovery at one of Dominion's other nuclear plants identified that not allof the Control Rod Drive Mechanism (CRDM) fans are on vital power busses andtherefore the cooldown rate of the Reactor Coolant System (RCS) following a LockedRotor Accident (LRA) with a Loss of Offsite Power (LOOP) would be longer thanassumed in the radiological analyses. An extent of condition review determined thatthis issue is also applicable to KPS. This revised analysis will be provided as asupplement to LAR-244. DEK will include an assumption of 800 cfm unfilteredinleakage during the first 60 minutes following a LRA in this revised analysis.

Serial No. 12-419Attachment 1Page 7 of 17ME71 I 0-RAII-SCVB-Torres-005-2012-06-15Attachment 4 Table 3.2-5 "Basic Data and Assumptions for LOCA," identifiescontainment spray coverage as being 100%. Please define what you mean by"containment spray coverage" and identify the surfaces and surface area taken intoconsideration. Please justify the assumption of 100% spray coverage.Response:Containment spray coverage is defined as the containment air volume that is included inthe sprayed volume of containment. The sprayed volume benefits from spray removalof airborne gaseous and particulate radioactivity. The modeling of containment spraycoverage was previously addressed in 2002 as part of a response to a request foradditional information (Reference 6). The use of a sprayed volume equal to thecontainment vessel net volume (i.e., affected surfaces and surface area modeledinstead as the total containment volume, less the volume of structures and components)is consistent with the licensing basis value used to determine Containment Spraycapability in previous submittals to the NRC. The containment spray coverageassumption has only limited impact on the overall analysis results. Specifically,containment spray is only credited for a brief period (0.91 hrs) at the beginning of theLOCA analysis. This short duration of spray provides only a limited reduction incontainment airborne gaseous and particulate radioactivity, and results in only a minorreduction in LOCA offsite dose consequences. If a reduced spray coverage wereassumed, Control Room doses would continue to be demonstrated to remain withindose limits.

Serial No. 12-419Attachment 1Page 8 of 17ME71 I 0-RAII-SCVB-Torres-006-2012-06-15There appears to be a dichotomy between some statements made in the LAR and thechange requiring isolation of the alternate intake which is used to justify not creditingradiation monitor R-23 and removing it from technical specifications. The alternatecontrol room intake could now be opened using the note in TS 3.7.10. The presence ofthe note challenges the provided justification for the removal of R-23 which partiallyrelies on the permanent closure of the alternate control room intake. Please clarify thetreatment of the alternate control room intake considering the following statementscontained in the LAR.Page 29 of Attachment 4 states: As a result of the analyses documented in this LicenseAmendment Request (LAR), the alternate control room intake will be restricted fromuse. This restriction is required because of the X/Q that would result due to the closeproximity of the alternate intake to various release points; one of which is < 10 m fromthe alternate intake. Administrative controls will be in place to assure the alternatecontrol room intake is closed and prohibit its use during normal operation, following anaccident, or while moving recently irradiated fuel.Attachment 4, page 73 states: A single Kewaunee Power Station (KPS) Fuel HandlingAccident (FHA) scenario models the bounding FHA which does not credit mitigatingsystems (e.g., radiation monitor isolation, bypass and closure signals, or ventilationfiltration) and maximizes source term, dispersion and dose. This bounding scenarioprovides the basis to allow all penetrations to be open under administrative control whilemoving recently irradiated fuel. The results of this analysis show that control roomisolation is required prior to moving recently irradiated fuel assemblies in order tomaintain operator dose within 5 rem TEDE.Technical Specification (TS) 3.7.10, "Control Room Post Accident Recirculation(CRPAR) System" contains a note that applies to openings in the CRE boundary thatcould be rapidly restored to the design condition, such as doors, dampers, hatches,floor plugs, and access panels. This Note only applies to openings in the "CREboundary that can be rapidly restored to the design condition, such as doors, dampers,hatches, floor plugs, and access panels.Response:(Note: Based on discussions with the NRC staff concerning DEK's proposal in LAR-244to relocate R-23 from the KPS Technical Specifications to the Technical RequirementsManual, DEK has decided to leave the existing TS in place and modify the wording ofthe TS bases to reflect the proposed new licensing basis for R-23. A revised copy of TS3.3.7, "CRPAR System Actuation Instrumentation," and the associated TS 3.3.7 Basesis provided in Enclosure 1.)

Serial No. 12-419Attachment 1Page 9 of 17The alternate control room intake will not be allowed to be opened under administrativecontrols. In order to make this clear in the KPS TS, DEK proposes to add wording tothe TS 3.7.10 Note stating, "This Note does not apply to the alternate control roomintake, which must remain isolated at all times."A copy of the revised marked-up TS 3.7.10 is provided in Enclosure 1.

Serial No. 12-419Attachment 1Page 10 of 17ME7110-RAII-SCVB-Torres-007-2012-06-15Given that Attachment 4 states that control room isolation is required in order tomaintain operator dose within 5 rem TEDE (including the alternate control room intake),please confirm that the note will not be used to open the control room. If the controlroom is allowed to be opened, please provide the methodology that will be used toverify that the time to close the opening does not impact the design basis analyses andthe methods which are being used to determine the time of closure and insure that theboundary integrity is restored to its design state (i.e. leakage is not greater than thedesign value). In addition, please state whether the methods used to perform thisassessment includes all current design basis assumptions. If not, please state whichassumptions are to be changed and justify not using the design bases to perform thisassessment.Response:The KPS control room is assumed to be isolated prior to moving recently irradiated fuelassemblies because the previously credited automatic isolation device, R-23, is nolonger credited. The analysis assumes all containment penetrations are open. Themost conservative pathway to the control room was modeled as an unfiltered releasepathway from the reactor building ventilation exhaust stack, which has the largestcalculated control room X/Q. The analysis assumes essentially all activity is releasedwithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the release rate is conservatively biased to release 80% of all activitywithin the first half hour of the event. No credit is taken for dilution or mixing of theactivity released to the auxiliary building or containment air volumes. The time for therelease to reach the control room and the time for R-23 to cause the control room toisolate was not modeled because operation of R-23 is not credited in the analysis. TheFHA does assume that operators in the control room manually start CRPARS andinitiate filtered recirculation within 20 minutes after the accident. The analysis assumes800 cfm of unfiltered inleakage and 800 cfm of unfiltered outleakage.The control room intake will not be allowed to be opened during movement of recentlyirradiated fuel assemblies. In order to make this clear in the KPS TS, DEK proposes toadd wording to the TS 3.7.10 Note that states, "This Note does not apply to the normalcontrol room intake during movement of recently irradiated fuel assemblies."A copy of the revised marked-up TS 3.7.10 is provided in Enclosure 1.

Serial No. 12-419Attachment 1Page 11 of 17ME71 1 0-RAII-SCVB-Torres-008-2012-06-15The KPS UFSAR states: The operator can add fresh air to the Control Room underpost-accident conditions by first verifying that conditions at the intake plenum will notcause contamination of the Control Room atmosphere, then manually opening theselected outside air damper and the damper at the suction of the post-accidentrecirculation fans. Excess air is exhausted to the Turbine Room through a backdraftdamper. The operator can confirm the incoming fresh/recirculation air mix is notcontaminating the Control Room atmosphere by observing a radiation monitor channelin the Control Room. Damper control switches are spring return to the normal positionso that when the damper control switches are released the dampers automaticallyreturn to the recirculation configuration. (KPS UFSAR Rev 23, page 9.6-12)Since this is an isolation design, the control room needs to supplement the breathableair after a week to 10 days to keep the air habitable. Is the radiation monitor that isbeing credited in the UFSAR for fresh air the same monitor that is being proposed to beremoved from credit in the radiological analyses (R-23)? Since the radiologicalanalyses assume that the control room will remain isolated throughout the accident andthat no extra radiation (other than unfiltered inleakage) will enter the control room, howdo you intend to monitor for fresh air?Please note that in accordance to Safety Review Plan 6.4, Section 111.3.IV which refersto duel inlets for the emergency zone, the NRC staff would not allow full credit foroperator action to take in only un-contaminated air.Response:See response to ME711 0-RAII-EICB-Alva-009-2012-06-15 above.

Serial No. 12-419Attachment 1Page 12 of 17ME71 10-RAII-SCVB-Torres-009-2012-06-15TS 3.3.6- APPLICABILITY- In the Bases of TSTF-51 it is stated that "The ManualInitiation, Automatic Logic and Actuation Relays, Containment Isolation -Phase A, andContainment Radiation Functions are required OPERABLE in MODES 1, 2, 3, and 4,and during movement of [recently] irradiated fuel assemblies [(i.e., fuel that hasoccupied part of a critical reactor core within the previous [x] days)] within containment.Under these conditions, the potential exists for an accident that could release significantfission product radioactivity into containment." However, in your mark-up, dated July25, 2011 (ML1 1222A123) the words "an accident that could release significant" is notincluded. In order to be in compliance with TSTF-51 please update your mark-up toinclude these words, or provide acceptable justification explaining why it is notnecessary.Response:DEK would prefer to maintain the wording of TS 3.3.6 -Applicability, as proposed in theamendment request based on the discussion below.On August 24, 2009, DEK submitted an application to convert the KPS TS from the oldcustom TS format to the Improved Technical Specification (ITS) format [AgencywideDocuments Access and Management System (ADAMS) Accession No. ML092440398].For this conversion, DEK used NUREG-1431, Revision 3.0, "Standard TechnicalSpecifications -Westinghouse Plants" (ISTS) [ADAMS Accession No. ML062510017].The words "an accident that could release significant" were included in the proposedKPS TS 3.3.6 -Applicability Bases in the initially submitted license amendment for theITS conversion [ADAMS Accession No. ML092440398 (see Attachment 1, Volume 8,page 431 of 517)].On December 2, 2010, DEK submitted a supplement to the ITS amendment [ADAMSAccession Nos. ML1103400334, ML103400327, and ML103400335]. In that submittal,DEK provided NRC with proposed changes to some of the originally proposed TSBases. DEK felt these particular TS Bases changes were necessary because theoriginally submitted wording could be construed as changing the current licensing basisof the plant to include design basis accidents or events not presently postulated in theKPS USAR. The change to TS 3.3.6 -Applicability Bases was one of the changesincluded in that letter. Specifically, the wording of TS Bases 3.3.6 -Applicability wasdeliberately modified as compared to the standard wording contained in the original ITSsubmittal per DEK letter to NRC dated December 2, 2010 (see Attachment 1, Volume 8,Rev. 2, page 442 of 529). The wording of TS Bases 3.3.6 -Applicability was modifiedexplicitly to ensure there would be no confusion regarding the current licensing basis ofthe plant.

Serial No. 12-419Attachment 1Page 13 of 17On February 2, 2011, the NRC staff approved the conversion of the KPS TechnicalSpecifications from the original custom TS to the ITS format. The December 2, 2010supplement was referenced in the NRC Safety Evaluation.

Serial No. 12-419Attachment 1Page 14 of 17ME711 0-RAII-SCVB-Torres-01 0-2012-06-15The NRC staff understands that credit for the control room ventilation intake radiationmonitor R-23, which provides control room isolation, is being removed. And that, onlythe current fuel handling accident (FHA) and locked rotor accident (LRA) events useand credit the R-23 system for control room isolation. The proposed new FHA requiresthat the control room be isolated prior to moving recently irradiated fuel therefore R-23is no longer required for that accident. A proposed operator action will be required onehour following a LRA to isolate the control room. You stated that one hour is sufficienttime for the operator to identify the accident, take necessary emergency steps inresponse to the accident, and direct action to isolate the control room and start thecontrol room post accident recirculation system (CRPARS). Please provide adiscussion demonstrating continued compliance with 10 CFR 20.1701.Response:(Note: Subsequent to discussions with the NRC staff concerning DEK's proposal inLAR-244 to relocate R-23 from the KPS Technical Specifications to the TechnicalRequirements Manual, DEK has decided to leave the existing TS in place and modifythe wording of the TS bases to reflect the proposed new licensing basis for R-23. Arevised copy of TS 3.3.7, "CRPAR System Actuation Instrumentation," and theassociated TS 3.3.7 Bases is provided in Enclosure 1.)10 CFR 20.1701 states: "The licensee shall use, to the extent practicable, process orother engineering controls (e.g. containment, decontamination, or ventilation) to controlthe concentration of radioactive materials in air."R-23 will continue to provide the same function to control the concentration ofradioactive materials in the control room environment in the future as it has in the past.All control room isolation actions are conducted from the control room. Operators donot need to perform remote actions in the plant to isolate the control room or start theCRPAR system.

Serial No. 12-419Attachment 1Page 15 of 17ME7110-RAII-SCVB-Torres-011-2012-06-15In order for a licensee to correctly implement TSTF-51-A, Rev 2, it needs to includeInsert 0 "Reviewer's Note" into the Applicability Section of TS Bases 3.9-4"Containment Penetrations". The proposed Bases for Kewaunee TS 3.9-4, omit theinclusion of such a note. The note requires that the licensee make a commitmentconsistent with draft NUMARC 93-01, Revision 3, Section 11.3.6.5, "Safety Assessmentfor Removal of Equipment from Service During Shutdown Condition," subheading"Containment-Primary (PWR)/Secondary (BWR)." The staff notes that in Page 26 ofAttachment 2 to Kewaunee's LAR dated August 30, 2011 (ADAMS No. ML1 1252A651),the licensee has made an equivalent commitment to NUMARC 91-06 in regard to theassessment of fuel handling/core alterations, ventilation system and radiation monitoravailability, with respect to the filtration and monitoring of releases from the fuel. If thenote is not to be included, please justify the omission of Insert 0 in TS Bases 3.9-4.(Note: The NRC staff considers it acceptable to provide a Reviewer's Note in theapplicable TS bases committing to NUMARC 91-06)Response:(Note: In the KPS ITS, Section 3.9.6, "Containment Penetrations," is the equivalentsection to TS 3.9.4, "Containment Penetrations," as presented in TSTF-51-A, Revision2. Therefore the discussion below refers to KPS ITS Section 3.9.6.)The Improved Standard Technical Specifications (ISTS) (NUREG-1431 forWestinghouse plants) contains Reviewer's Notes. These Reviewer's Notes areintended to be used by NRC when reviewing plant-specific amendment requests whichpropose to adopt the standard language in the ISTS for a specific plant. TheReviewer's Notes themselves are not intended to be part of the plant-specific technicalspecifications or the plant-specific Technical Specification Bases. Therefore, DEK doesnot believe that adoption of this Reviewer's Note in the KPS plant-specific TS bases, inits entirety and exactly as written, is appropriate. In this case, DEK believes that it isappropriate to adopt language in the KPS plant-specific TS Bases that is consistent withthe Reviewer's Note mentioned above.DEK proposes the following be added to the Bases of TS 3.9.6 -Applicability:"The plant has committed to implement the guidance contained in NUMARC 93-01,Section 11.3.6.5, "Safety Assessment for Removal of Equipment from Service DuringShutdown Conditions," subheading, "Containment -Primary (PWR)/Secondary(BWR)," related to the assessment of systems removed from service duringmovement of recently irradiated fuel."A copy of the revised marked-up TS Bases page is provided in Enclosure 1.

Serial No. 12-419Attachment 1Page 16 of 17ME71 I 0-RAII-SCVB-Torres-01 2-2012-06-15Included in Kewaunee's LAR dated August 30, 2011 (ADAMS No. ML11252A521) is anew TS Section 5.5 "Programs and Manual." Subheading 5.5.9 "Ventilation Filtertesting Program (VFTP)," to the associated TS states "Demonstrate for each of thesafety related systems listed below that an inplace test of the HEPA filters shows apenetration and system bypass < 1.0% when tested in accordance with RegulatoryPosition C.5.c of the Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 at thesystem flowrate specified below + 10%." The proposed penetration bypass isinconsistent with the bypass stated in Regulatory Position C.5.c in Reg Guide 1.52 Rev2, which states "The in-place DOP test for HEPA filters should conform to Section 10 ofANSI N510-1975 (Ref. 2). HEPA filter sections should be tested in place (1) initially,(2) at least once per 18 months thereafter, and (3) following painting, fire, or chemicalrelease in any ventilation zone communicating with the system to confirm a penetrationof less than 0.05% at rated flow."In addition, subheading 5.5.9.b states "Demonstrate for each of the safety relatedsystems listed below that an inplace test of the charcoal adsorber shows a penetrationand system bypass < 1.0% when tested in accordance with Regulatory Position C.5.d ofthe Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 at the system flowratespecified below + 10%." Regulatory Position C.5.d of the Reg. Guide 1.52, Rev 2 states"The activated carbon adsorber section should be leak tested with a gaseoushalogenated hydrocarbon refrigerant in accordance with Section 12 of ANSI N510-1975(Ref. 2) to ensure that bypass leakage through the adsorber section is less than 0.05%."Please justify the proposed penetration and leakage bypass of < 1..0% taking intoconsideration that it differs from Regulatory Position C.5.c and C.5.d which states apenetration and leakage bypass of < 0.05%.Response:The amendment request dated August 30, 2011 does not propose adding a new TSSection 5.5.9, "Ventilation Filter Testing Program," to the KPS Technical Specifications.The KPS TS currently include a Section 5.5.9, "Ventilation Filter Testing Program(VFTP)," and no changes to current KPS TS 5.5.9 are being proposed as part of thisamendment request. The only change to Technical Specification Section 5.5,"Programs and Manuals," that was proposed in the amendment request dated August30, 2011 is the addition of new Section 5.5.17, "Control Room Envelope HabitabilityProgram."For a discussion regarding how the bypass of < 1.0% is accounted for in the designbasis radiological calculations, please refer to DEK response to NRC Question 13(ME71 1 0-RAII-AADB-Blum-01 3-2012-03-02) in Reference 4.

Serial No. 12-419Attachment 1Page 17 of 17References1. 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. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly and Jack Gadzala (DEK),"ME7110 Agenda for draft RAI clarification call Re Wednesday 3-4 PM ET -EICBinput," dated May 15, 2012. [ADAMS Accession No. ML12137A003]3. E-mail from Karl D. Feintuch (NRC) to Craig D. Sly and Jack Gadzala (DEK),"ME7110 SCVB Draft RAI set Re: adoption of TSTF-51 & TSTF- 448, as part ofChi-over-Q action," dated May 15, 2012. [ADAMS Accession No. ML12138A007]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. Letter from L. N. Hartz (DEK) to Document Control Desk, "License AmendmentRequest 211, 'Radiological Accident Analysis and Associated TechnicalSpecification Change,"' dated January 30, 2006. [ADAMS Accession No.ML060540217]6. Letter from T. Coutu (NMC) to NRC, "Response to Request for AdditionalInformation Related to Proposed Revision to Kewaunee Nuclear Power PlantDesign-Basis Radiological Analysis Source Term," dated September 13, 2002.[ADAMS Accession No. ML022680167]

Serial No. 12-419Enclosure 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 Technical Specification Pagesand Technical Specification Bases PagesTS 3.3.7, "CRPAR Actuation Instrumentation"TS B3.3.7, "CRPAR Actuation Instrumentation"TS 3.7.10, "CRPAR System"TS B3.7.10, "CRPAR System"TS B3.9.6, "Refueling Operations"KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE INC.

CRPAR System Actuation Instrumentation3.3.73.3 INSTRUMENTATION3.3.7Control Room Post Accident Recirculation (CRPAR) System ActuationInstrumentationLCO 3.3.7APPLICABILITY:The CRPAR System actuation instrumentation for each Function inTable 3.3.7-1 shall be OPERABLE.According to Table 3.3.7-1.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One Automatic Actuation A.1 Place associated CRPAR 7 daysLogic and Actuation train in emergency mode.Relay train inoperable.B. Two Automatic Actuation B.1.1 Place one CRPAR train in ImmediatelyLogic and Actuation emergency mode.Relay trains inoperable.ANDORB.1.2 Enter applicable Conditions ImmediatelyControl Room Vent and Required Actions forRadiation Monitor one CRPAR train madeinoperable, inoperable by inoperableCRPAR System actuationinstrumentation.ORB.2 Place both CRPAR trains in Immediatelyemergency mode.Kewaunee Power Station3.3.7-1Amendment No. 20702/02/2011 CRPAR System Actuation Instrumentation3.3.7ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEC. Required Action and C.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime for Condition A ANDor B not met in MODE 1,2, 3, or 4. C.2 Be in MODE 5. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sD. Required Action and D.1 Suspend movement of Immediatelyassociated Completion irradiated fuel assemblies.Time for Condition Aor B not met duringmovement of radiatedfuel assembli recentlyE. Required Action and E. 1 Initiate action to restore one Imme, ,--"-associated Completion CRPAR train toTiefor Condition A s ts.or B not met inSURVEILLANCE REQUIREMENTS-- --------------------------NOTE-Refer to Table 3.3.7-1 to determine which SRs apply for each CRPAR System ActuationFunction.SURVEILLANCE FREQUENCYSR 3.3.7.1 Perform CHANNEL CHECK. 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />sSR 3.3.7.2 Perform COT in accordance with the Setpoint 92 daysControl Program.Kewaunee Power Station3.3.7-2Amendment No. 20702/02/2011 CRPAR System Actuation Instrumentation3.3.7SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.3.7.3 ----------------------NOTE ----------------This Surveillance is only applicable to the actuationlogic of the ESFAS Instrumentation.Perform ACTUATION LOGIC TEST. 18 monthsSR 3.3.7.4 Perform CHANNEL CALIBRATION in accordance 18 monthswith the Setpoint Control Program.Kewaunee Power Station3.3.7-3Amendment No. 20702/02/2011 CRPAR System Actuation Instrumentation3.3.7Table 3.3.7-1 (page 1 of 1)CRPAR System Actuation InstrumentationAPPLICABLEMODES OROTHERSPECIFIED REQUIRED SURVEILLANCEFUNCTION CONDITIONS CHANNELS REQUIREMENTS1. Automatic Actuation Logic and 1, 2, 3, 4a 2 trains SR 3.3.7.3Actuation Relays (a)2 Control Room Vent Radiation 1.2,3, )"' 1 SR 3.3.7.1Monitor (a) SR 3.3.7.2SR 3.3.7.43. Safety Injection Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 1, forall initiation functions and requirements.(a) During movement of irradiated fuel assemblies.tSrecentyKewaunee Power Station3.3.7-4Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.7B 3.3 INSTRUMENTATIONB 3.3.7 Control Room Post Accident Recirculation (CRPAR) System Actuation InstrumentationBASESBACKGROUNDThe CRPAR System provides an enclosed control room environmentfrom which the unit can be operated following an uncontrolled release ofradioactivity. The CRPAR System is part of the Control Room AirConditioning System. During normal unit operation, the Control Room AirConditioning System provides cooling and heating of recirculated andfresh air to ventilate the control room. Upon receipt of an actuationsignal, both CRPAR fans are started, the flow path through theEmergency Filtration System is opened, and a portion of the return airvolume is filtered to remove airborne contaminants and airborneradioactivity, then mixed with the recirculated return air. This system isdescribed in the Bases for LCO 3.7.10, "Control Room Post AccidentRecirculation (CRPAR) System."The actuation instrumentation consists of a single radiation monitor(R-23) located on the common discharge of the outlet of the airconditioning fan units. A high radiation signal from the detector willinitiate both trains of the CRPAR System. The control room operator canalso start the CRPAR fan(s) by manual switches in the control room. TheCRPAR System is also actuated by a safety injection (SI) signal. The SIFunction is discussed in LCO 3.3.2, "Engineered Safety FeatureActuation System (ESFAS) Instrumentation."APPLICABLESAFETYANALYSESThe control room must be kept habitable for the operators stationed thereduring accident recovery and post accident operations.The CRPAR System acts to terminate the normal supply of unfilteredoutside air to the control room, both CRPAR fans are started, the flowpath through the Emergency Filtration System is opened, and a portion ofthe return air volume is filtered to remove airborne contaminants andairborne radioactivity, then mixed with the recirculated return air. Theseactions are necessary to ensure the control room is kept habitable for theoperators stationed there during accident recovery and post accidentoperations by minimizing the radiation exposure of control roompersonnel.Tho rd-iation ...M.......ManuaI actuation of the CRPAR System is a backupfor the SI signal actuation. This ensures initiation of the CRPAR Systemduring a loss of coolant accident or steam generator tube rupture whenan initiation of SI is anticipated. In addition, the rFadiatin nMe tomitmanualactuation of the CRPAR System is the primary means to ensure controlroom habitability in the event of a locked rotor accident.Kewaunee Power StationB 3.3.7-1Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.7BASESAPPLICABLE SAFETY ANALYSES (continued).Tho rd4ftion m,-,itorManual actuation of the CRPAR System inMODES 5 -Ad 6, and a requirement for the control room envelope to beisolated-during movement of reetyirradiated fuel assemblies (TSis the primary means to ensure control room habitability in theevent of a fuel handling, Yo'umo control tank, Or waste gas d.cay tankFUPtw~ accident.The Safety Injection signal oortion of CRPAR System actuationinstrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). -not specifically credited in the design basis accident radiologicalconsequences analysis, provides a diverse means for actuating theCRPAR system during accident recovery and post-accident operations.LCO The LCO requirements ensure that instrumentation necessary to initiatethe CRPAR System is OPERABLE.1. Automatic Actuation Lo-gic and Actuation RelaysThe LCO requires two trains of Actuation Logic and RelaysOPERABLE to ensure that no single random failure can preventautomatic actuation.Automatic Actuation Logic and Actuation Relays consist of the samefeatures and operate in the same manner as described for ESFASFunction 1.b., SI, in LCO 3.3.2 and include the slave relays that sendthe Sl signal to the CRPAR System. The applicable MODES andspecified conditions for the CRPAR System portion of these functionsare different than those specified for their SI roles. If one or more ofthe SI functions becomes inoperable in such a manner that only theCRPAR System function is affected, the Conditions applicable totheir Sl function need not be entered. The less restrictive Actionsspecified for inoperability of the CRPAR System Functions specifysufficient compensatory measures for this case.2. Control Room Vent Radiation MonitorThe LCO specifies one Control Room Vent Radiation Monitor toensure that the radiation monitoring instrumentation necessary toinitiate the CRPAR System remains OPERABLE.For sampling systems, channel OPERABILITY involves more thanOPERABILITY of channel electronics. OPERABILITY may alsorequire correct valve lineups, sample pump operation, and filter motoroperation, as well as detector OPERABILITY, if these supportingfeatures are necessary for trip to occur under the conditions assumedby the safety analyses.Kewaunee Power Station B 3.3.7-2 Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.73. Safety InjectionRefer to LCO 3.3.2, Function 1, for all initiating Functions andrequirements.Kewaunee Power StationB 3.3.7-3Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.7BASESAPPLICABILITY The CRPAR Functions must be OPERABLE in MODES 1, 2, 3, 4, andduring movement of reety irradiated fuel assemblies (i.e., fueoccupied Dart of the critical reactor core within the previous 375 hours0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br />).The Functiocn must a!co bo OPERPRBLE in MODES 5 Rnd 6 Whonraguirod for a waste gar, docay tank rupturo accidont, to oncuro ah-Abit-Rblo o-nvArnnmont for tho con-trol room eporaterc.The Applicability for the CRPAR actuation on the ESFAS Safety InjectionFunctions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2for discussion of the Safety Injection Function Applicability.ACTIONSThe most common cause of channel inoperability is outright failure or driftof the bistable or process module sufficient to exceed the toleranceallowed by the unit specific calibration procedures. Typically, the drift isfound to be small and results in a delay of actuation rather than a totalloss of function. This determination is generally made during theperformance of a COT, when the process instrumentation is set up foradjustment to bring it within specification. If the Trip Setpoint is lessconservative than the tolerance specified by the calibration procedure, thechannel must be declared inoperable immediately and the appropriateCondition entered.A._1Condition A applies to the Automatic Actuation Logic and ActuationRelays Function of the CRPAR System.If one train is inoperable, 7 days are permitted to restore it to OPERABLEstatus. The 7 day Completion Time is the same as is allowed if one trainof the mechanical portion of the system is inoperable. The basis for thisCompletion Time is the same as provided in LCO 3.7.10. If the traincannot be restored to OPERABLE status, the associated CRPAR trainmust be placed in the emergency mode of operation. This accomplishesthe actuation instrumentation Function and places the unit in aconservative mode of operation.B.1.1, B.1.2. and B.2Condition B applies to the failure of two Automatic Actuation Logic andActuation Relay trains or the Control Room Vent Radiation Monitor. Thefirst Required Action is to place one CRPAR train in the emergency modeof operation immediately. This accomplishes the actuationinstrumentation Function that may have been lost and places the unit in aconservative mode of operation. The applicable Conditions and RequiredKewaunee Power StationB 3.3.7-4Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.7BASESACTIONSB.1.1, B.1.2, and B.2 (continued)Actions of LCO 3.7.10 must also be entered for the CRPAR train madeinoperable by the inoperable actuation instrumentation and not placed inthe emergency mode of operation. This ensures appropriate limits areplaced upon train inoperability as discussed in the Bases for LCO 3.7.10.Alternatively, both CRPAR trains may be placed in the emergency mode.This ensures the CRPAR function is performed even in the presence of asingle failure.C.1 and C.2Condition C applies when the Required Action and associatedCompletion Time for Condition A or B have not been met and the unit is inMODE 1, 2, 3, or 4. The unit must be brought to a MODE in which theLCO requirements are not applicable. To achieve this status, the unitmust be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.The allowed Completion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unit systems.D.1Condition D applies when the Required Action and associatedCompletion Time for Condition A or B have not been met when rcnyirradiated fuel assemblies are being moved. Movement ofirradiated fuel assemblies must be suspended immediately to reduce therisk of accidents that would require CRPAR System actuation.E-4Con-d-ition Em applies whon tho Requircd Action and associ'ated ComplotionTmoe for Condition A. or B have; not boonme int MODEF 5 or 6. ActionRSMUC 0 ri C2 V tv r0a "rut V mvp----------------------------- ..1 .-001JW1111! 1UU1JWy to uRituiu adequate isltuiuRi Gapabuiity in the uVent 91 awaste gas decay tank u1pturo.Kewaunee Power StationB 3.3.7-5Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.7BASESSURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.7-1REQUIREMENTS determines which SRs apply to which CRPAR System ActuationFunctions.SR 3.3.7.1Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures thata gross failure of instrumentation has not occurred. A CHANNEL CHECKis normally a comparison of the parameter indicated on one channel to asimilar parameter on other channels. It is based on the assumption thatinstrument channels monitoring the same parameter should readapproximately the same value. Significant deviations between the twoinstrument channels could be an indication of excessive instrument drift inone of the channels or of something even more serious. A CHANNELCHECK will detect gross channel failure; thus, it is key to verifying theinstrumentation continues to operate properly between each CHANNELCALIBRATION.Agreement criteria are determined by the unit staff, based on acombination of the channel instrument uncertainties, including indicationand readability. If a channel is outside the criteria, it may be an indicationthat the sensor or the signal processing equipment has drifted outside itslimit.The Frequency is based on operating experience that demonstrateschannel failure is rare. The CHANNEL CHECK supplements less formal,but more frequent, checks of channels during normal operational use ofthe displays associated with the LCO required channels.SR 3.3.7.2A COT is performed once every 92 days on each required channel toensure the entire channel will perform the intended function. This testverifies the capability of the instrumentation to provide the CRPARSystem actuation. A successful test of the required contact(s) of achannel relay may be performed by the verification of the change of stateof a single contact of the relay. This clarifies what is an acceptable COTof a relay. This is acceptable because all of the other required contacts ofthe relay are verified by other Technical Specifications and non-TechnicalSpecifications tests at least once per refueling interval with applicableextensions. The Setpoint Control Program (SCP) has controls whichrequire verification that the instrument channel functions as required byverifying the as-left and as-found setting are consistent with thoseestablished by the setpoint methodology. The Frequency is based on theknown reliability of the monitoring equipment and has been shown to beacceptable through operating experience.Kewaunee Power Station B 3.3.7-6 Amendment No. 20702/02/2011 CRPAR System Actuation InstrumentationB 3.3.7BASESSURVEILLANCE REQUIREMENTS (continued)SR 3.3.7.3SR 3.3.7.3 is the performance of an ACTUATION LOGIC TEST. For theportion of the logic common to ESFAS, Function 1.b ACTUATION LOGICTEST, the train being tested is placed in the test condition, thuspreventing inadvertent actuation and all possible SI logic combinationsare tested for each protection function. For the portion of the logic nottested as part of the ESFAS Function 1.b ACTUATION LOGIC TEST (i.e.,the slave relay), actuation of the end devices may occur. The Frequencyof 18 months is based on the refueling outage cycle, since the slave relaycannot be tested at power without resulting in actuation of affectedcomponents.The SR is modified by a Note stating that the Surveillance is onlyapplicable to the actuation logic of the ESFAS Instrumentation.SR 3.3.7.4A CHANNEL CALIBRATION is performed every 18 months, orapproximately at every refueling. CHANNEL CALIBRATION is acomplete check of the instrument loop, including the sensor. The testverifies that the channel responds to a measured parameter within thenecessary range and accuracy.The SCP has controls which require verification that the instrumentchannel functions as required by verifying the as-left and as-found settingare consistent with those established by the setpoint methodology.The Frequency is based on operating experience and is consistent withthe typical industry refueling cycle.REFERENCES1. WCAP-15376, Rev. 0, "Risk-Informed Assessment of the RTS andESFAS Surveillance Test Intervals and Reactor Trip Breaker Testand Completion Times," October 2000.Kewaunee Power StationB 3.3.7-7 LC00040702/12/2011 ANDThe CRE shall be isolated during movement3.7 PLANT SYSTEM °of recently irradiated fuel assemblies.3.7.10 Control Ro m Post Accident Recirculation (CRPAR) SystemI envelope (CRE) ILCO 3.7.10 o CRPAR trais shall be OPERABLE.CRPAR System3.7.10---. ---ý. r .. ------------------- -J I r------ ------------------------------............-The control room bounday may be opened intermittently underadministrative control. FThis Note does not apply to the alternate control room intake, which must remain closed at all times.This Note does not apply to the normal control room intake during movement of recently irradiatedfuel assemblies.APPLICABILITY:MODES 1, 2, 9. 4,During movee nt of irradiated fuel assemblies.IandREQUIRED ACTIONCOMPLETION TIMERestore CRPAR train toOPERABLE status.7 daysB. Two CRPAR trains B.1 Restore control roomt inoperable due to boundary tinoperable control roomboundary in MC. Required Action and C.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime of Condition A or B ANDnot met in MODE 1, 2, 3,or 4. C.2 Be in MODE 5. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sKewaunee Power Station3.7.10-1Amendment No. 20702/02/2011 CRPAR System3.7.10ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMED. Required Action and D.1 Place OPERABLE CRPAR Immediatelyassociated Completion train in emergency mode.Time of Condition A notme r OR recentlyduring movement oirradiated fuel D.2 Suspend movement Immediatelyassemblies, irradiated fuel assemblies.I recentlyE. Two CRPAR trains E.1 Suspend movement of Immediatelyinoerablel irradiated fuel assemb s.movement Iofadiated fuelassem i recentlyI recently IF. Two CRPAR trains\noperable in MODE 1,, 3, or 4 for reasonsrther than Condition B.F.1 Enter LCO 3.0.3.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.7.10.1 Operate each CRPAR train for ? 15 minutes. 31 daysSR 3.7.10.2 Perform required CRPAR filter testing in accordance In accordancewith the Ventilation Filter Testing Program (VFTP). with VFTPSR 3.7.10.3 Verify each CRPAR train actuates on an actual or 18 monthssimulated actuation signal.SR 3.7.10.4 Perform required CRE unfiltered air inleakage In accordance withtesting in accordance with CRE Habitability CRE HabitabilityProgram ProgramKewaunee Power Station3.7.10-2Amendment No. 20702/02/2011 Insert 2:B.1 Initiate action to implementB. One or more CRPARtrains inoperable due to aninoperable CRE boundaryin Modes 1, 2, 3, or 4.B.1 Initiate action to implementmitigating actions.ANDB.2 Verify mitigating actions ensureCRE occupant exposures toradiological, chemical, and smokehazards will not exceed limits.ANDB.3 Restore CRE boundary toOPERABLE status.Immediately24 hours90 daysInsert 3:ORRequired Actions andassociated CompletionTimes of Condition B notmet during movement ofrecently irradiated fuelassemblies.ORCRE not isolated duringmovement of recentlyirradiated fuel assemblies.

CRPAR SystemB 3.7.10B 3.7 PLANT SYSTEMSB 3.7.10 Control Room Post Accident Recirculation (CRPAR) SystemBASESBACKGROUND The CRPAR System provides a protected environment from whichOcan control the unit following an uncontrolled releaseof radioactivity, hazardous-chemicals, or tWAG Gasmok.The CRPAR System consists of two independent, redundant trains thatrecirculate and filter the air On the control room envelope ( and aCRE boundary that limits the inleakage of unfiltered aireuts'de-aiF. EachCRPAR train consists of a prefilter, a high efficiency particulate air(HEPA) filter, an activated charcoal adsorber section for removal ofgaseous activity (principally iodines), and a fan. Common ductwork,valves or dampers, doors, barriers, and instrumentation also form part ofthe system.The CRE is the area within the confines of the CRE boundary thatcontains the spaces that control room occupants inhabit to control the unitdurina normal and accident conditions. This area encompasses thecontrol room. and other non-critical areas to which freauent personnelaccess or continuous occupancy is not necessary in the event of anaccident. The CRE is orotected during normal operation, natural events.and accident conditions. The CRE boundary is the combination of walls.floor, roof. ducting. doors, penetrations and eauipment that physicallyform the CRE. The OPERABILITY of the CRE boundary must bemaintained to ensure that the inleakaoe of unfiltered air into the CRE willnot exceed the inleakage assumed in the licensing basis analysis ofdesign basis accident (DBA) consequences to CRE occupants. The CREand its boundary are defined in the Control Room Envelope HabitabilityThe CRPAR System is an emergency system, which is normally in thestandby mode of operation. The CRPAR System is part of the ControlRoom Air Conditioning (CRAC) System. During normal unit operation,the CRAC System provides cooling of recirculated and fresh air toventilate the control room. Upon receipt of the actuating signal(s), normaloutside air intake supply to the co.ntrol roomCRE is isolated, both CRPARfans are started, the flow path through the Emergency Filtration System isopened, and a portion of the return air volume is filtered to removeairborne contaminants and airborne radioactivity, then mixed with therecirculated return air. The prefilters remove any large particles in the airto prevent excessive loading of the HEPA filters and charcoal adsorbers.The neutral pressure envelope design of the Qcntrol roomCRE minimizesinfiltration of unfiltered air from the surrounding areas of the building. TheCRPAR System fans are started upon receipt of a safety injection signal,Kewaunee Power Station B 3.7.10-1 Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10ermanual Sl initiation throuah switches in the control room. or a~highradiation signal as detected by the radiation monitor R-23 mounted in themain control room emergency zone (CREZ) supply duct.The CRPAR System operation in maintaining a habitable environment inthe CRE w,,trI room discussed in the USAR, Section 9.6.4(Ref. 1 ).Redundant supply and recirculation trains provide the required filtrationshould an excessive pressure drop develop across the other filter train.Normally open isolation dampers of the CRAC Alternate Cooling Systemprovide double/redundant isolation capability so that the failure of onedamper to shut will not result in a breach of control room ventilationisolation. The CRPAR System is designed in accordance with SeismicCategory I requirements.Isolation of the CRE durina movement of recently irradiated fuelassemblies (i.e.. fuel that has occupied part of a critical reactor corewithin the orevious 375 hours0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br />) and manual actuation of the CRPAR within20 minutes after a fuel handling accident is the primary means to ensureCRE habitability in the event of a fuel handling accident while handlin'recently irradiated fuel Actuation of the CRPAR System and CREisolation are Derformed by a Sl actuation signal, either automatically ormanually initiated. Calculated doses to CRE occuoants from a volumecontrol tank rupture or waste oas decay tank ruoture are sufficiently smallthat manual actuation of the CRPAR System is not required for theseKewaunee Power StationB 3.7.10-2Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10BASESBACKGROUND (continued)The CRPAR System is designed to maintain a habitable environment inthe CREtrol room ni,-,vronmf-t for 30 days of continuous occupancyafter a Design Basis Accident (DBA) without exceeding a 5 rem totaleffective dose equivalent (TEDE).APPLICABLESAFETYANALYSESThe CRPAR System components are arranged in redundant, safetyrelated ventilation trains. The location of components and ducting withinthe c.ontrol roorm onvolopoCRE ensures an adequate supply of filtered airto all areas requiring access. The CRPAR System provides airborneradiological protection for the co.ntrol room asdemonstrated by the "wentrcl rom accident o dose analysesfor the most limiting design basis less of -eka accident7 fission productrelease presented in the USAR, Chapter 14 (Ref. 2).The CRPAR System also provides protection from smoke and hazardouschemicals to the CRE occupants. The analysis of hazardous chemicalreleases demonstrates that the toxicity limits are not exceeded in theCRE following a hazardous chemical release (Ref. 6). The evaluation ofa smoke challenge also demonstrates that it will not result in the inabilityof the CRE occuoants to control the reactor either from the control roomor IKUIT LIIe remIIae sf~uulwow panel kri eL I.J-1,LWF i,.;.;u GGUG P0 08Ft0in t-ho- ro;mo~to prossibility of a firo i the cnetrol room, as decr,,Fbod iRef er~enne4-.The worst case single active failure of a component of the CRPARSystem, assuming a loss of offsite power, does not impair the ability ofthe system to perform its design function.The CRPAR System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).LCOTwo independent and redundant CRPAR trains are required to beOPERABLE to ensure that at least one is available aesu.. ,-iLa singleactive failure disables the other train. Total system failure .suh as frmaloss of both ventilation trains or from an inoperable CRE boundary, couldresult in exceeding a dose of 5 rem TEDE to the control room operator inthe event of a large radioactive release.T-he-EachtCRPAR System-trinis considered OPERABLE when theindividual components necessary to limit epeiterREc nexposure are OPERABLE an beth trains. A CRPAR train is OPERABLEwhen the associated:a. Fan is OPERABLE;b. HEPA filters and charcoal adsorbers are not excessively restrictingflow, and are capable of performing their filtration functions; andKewaunee Power StationB 3.7.10-3Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10c. Ductwork, valves, and dampers are OPERABLE, and air circulationcan be maintained.In addition, the CRAC fan in the same train must be OPERABLE whenthe CRPAR train is required. Fu"thormoro, the control room boundarymi e* a .~nG.,na ;s-cI A;n +k, ;+a , af +ka safir fin-c. H;iinMW .NO C1 MCI U ri U F xx = TTCX m, %7wm, W= " 0,QUiW9FoK, ana accocs GoorI.In order for the CRPAR trains to be considered OPERABLE. the CREboundary must be maintained such that the CRE occupant dose from alarae radinactive release does not exrceed the calculated dose in thelicensing basis consequence analyses for DBAs. and that CRE occupantsare protected from hazardous chemicals and smoke.The CRE is also reouired to be isolated during movement of recentlyirradiated fuel assemblies. The fuel handlina accident analysis assumesthe control room is isolated at the initiation of the accident. Pre-isolationof the control room minimizes infiltration of radioactive materials into theCRE Prior to initiation of the CRPAR in the emeraencv mode and ensuresdose to CRE occupants remains within applicable limits.Kewaunee Power StationB 3.7.10-4Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10BASESLCO (continued)The LCO is modified by aNote allowing the cnntrc r-eein'RE boundaryto be opened intermittently under administrative controls. This Note onlyapplies to ooeninas in the CRE boundary that can be rapidly restored tothe desian condition, such as doors. dampers, hatches, floor oluas, andacces oanels. For entry and exit through doors, the administrativecontrol of the opening is performed by the person(s) entering or exitingthe area. For other openings, these controls should be proceduralizedand-consist of stationing a dedicated individual at the opening who is incontinuous communication with the operators in the CREGeitrml FOrM.This individual will have a method to rapidly close the opening and restorthe CRE boundary to a condition equivalent to the design condition whena need for control roomCRE isolation is indicated. The Note does notapplv to the alternate control room intake, which must remain closed at alltimes. The Note also does not apply to the normal control room intakeduring movement of recently irradiated fuel assemblies.APPLICABILITY In MODES 1, 2, 3, and4, ., and during movement of rirradiated fuel assemblies, the CRPAR System must be OPERABLE toensure that the CRE will remain habitable control .p.ratOr oxpoSUr-during and following a DBA.In A.O-DE -5 or 6, tho CRPAR System ic roquirod to cope with the roloasofrom the rupturo of an ~niowcogas tank.During movement of rey irradiated fuel assemblies, the CRPARSystem must be OPERABLE to cope with the release from a fuelhandling accident involving handling of recentlyirradiated fuel.LTheCRPAR is only reouired to be OPERABLE during fuel handling involvinghandling of recently irradiated fuel (i.e.. fuel that has occuoied part of acritical reactor core within the previous 375 hours0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br />), due to radioactiveACTIONS A.1When one CRPAR train is inoperable, for reasons other than aninoperable CRE boundarv. action must be taken to restore OPERABLEstatus within 7 days. In this condition, the remaining OPERABLE CRPARtrain is adequate to perform the n-entrol rom,.CRE occupajA protectionfunction. However, the overall reliability is reduced because a sin&aotive-failure in the OPERABLE CRPAR train could result in loss ofCRPAR function. The 7 day Completion Time is based on the lowprobability of a DBA occurring during this time period, and ability of theremaining train to provide the required capability.Kewaunee Power Station B 3.7.10-5 Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10B.1, B.2, and B.3If the unfiltered inleakage of potentially contaminated air past the CREboundary and into the CRE can result in CRE occuoant radiological doseareater than the calculated dose of the licensing basis analyses of DBAconseauences (allowed to be uo to 5 rem TEDE .or inadequateprotection of CRE occupants from hazardous chemicals or smoke. theCRE boundary is inoperable. Actions must be taken to restore anOPERABLE CRE boundary within 90 days.During the period that the CRE boundary is considered inoperable, actionmust be initiated to implement mitigating actions to lessen the effect onCRE occupants from the potential hazards of a radiological or chemicalevent or a challenae from smoke. Actions must be taken within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sto vedfv, that in the event of a DBA. the mitigating actions will ensure thatCRE occuoant radiological exoosures will not exceed the calculated doseof the licensing basis analyses of DBA conseauences, and that CREoccupants are protected from hazardous chemicals and smoke. Thesemitiaating actions (i.e.. actions that are taken to offset the conseauencesof the inoperable CRE boundarvy should be preplanned forimplementation upon entry into the condition, reaardless of whether entryis intentional or unintentional. The 24-hour Completion Time isreasonable based on the low probability of a DBA occurring during thistime period, and the use of mitigating actions. The 90-day CgompletionTime is reasonable based on the determination that the mitigating actionswill ensure protection of CRE occupants within analyzed limits whilelimitino the nomhahilitv that CRE occunants will have to imolementprotective measures that may adversely affect their ability to control thereactor and maintain it in a safe shutdown condition in the event of aDBA. In addition, the 90 day Completion Time is a reasonable time todiagnose, plan and possibly repair, and test most oroblems with the CREIf the control room boundary is iMODE 1, 2, 3, or 4, theC ^RPAR trainS cannot perform t+hoi;r hfuncteins. Action mu..t beti;kont mto m ;ntrin QPFPARI F= rontrgl room hQijnd-ir" 'ithiF; 24 hoiic-. .--~-.~ .-.- -.. ..-.. -.-.. .During the poriod that the control roomF boundary icinooabcappropriato componcator; moeacuroc (conGsitont With the inton oGDC 19) should- -he utfiliod to protect control room oporators from9otontial hazard-s suc.h ;As ra4diactv cqja Ontamination. WAGd chomic~als.W ......PsmK, WAm porauro and ,r, , hao, .umia-ty, aRd p..ysical s..ufIly,.Proplannod Mo-asuros should be availablo to ;d-d-ress tho-So conco9Rn forKewaunee Power StationB 3.7.10-6Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10BASESACTIONS (continued)intontion-al and- unintentional ontry inothe condition. Tho 24 hourFCoMPlotion TiMo is roasonablo balsod on the low probability of a DBAoccurring during this timo8 poiod, and tho u9o f com~poneatory monacuro-.Tho .24 hou -Compntion Timo Rn trpicGaly rFaon-ablo time; to diagnoco,plan and poscbl -oaRnd- tos-t- mostM probloms- Wit-h t-ho conQ-trol roomC.1 and C.2In MODE 1, 2, 3, or 4, if the inoperable CRPAR train or eeetrl reelm theCRE boundary cannot be restored to OPERABLE status within therequired Completion Time, the unit must be placed in a MODE thatminimizes accident risk. To achieve this status, the unit must be placedin at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Theallowed Completion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unit systems.D.1 and D.2In, MODE 5 or 6, or d~unng movement of een irradiated fuelassemblies, if the inoperable CRPAR train cannot be restored toOPERABLE status within the required Completion Time, action must betaken to immediately place the OPERABLE CRPAR train in theemergency mode. This action ensures that the remaining train isOPERABLE and that any active failure would be readily detected.An alternative to Required Action D.1 is to immediately suspend activitiesthat could result in a release of radioactivity that might require isolation ofthe centre! roomCRE. This places the unit in a condition that minimizesthe accident risk. This does not preclude the movement of fuel to a safeposition.E._1In MODEr= 5 o 6r, or d-uring movement of rctyirradiated fuelassemblies, with two CRPAR trains inoperable, or with one or moreCRPAR trains inooerable due to an inoperable CRE boundary, actionmust be taken immediately to suspend activities that could result in arelease of radioactivity that might enteF reguire isolation of the CREGe.itelr-eem. This places the unit in a condition that minimizes theaccident risk.This does not preclude the movement of fuel to a safe position.Kewaunee Power Station B 3.7.10-7 Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10BASESACTIONS (continued)F. 1If both CRPAR trains are inoperable in MODE 1, 2, 3, or 4 for reasonsother than an inoperable control roomCRE boundary (i.e., Condition B),the CRPAR System may not be capable of performing the intendedfunction and the unit is in a condition outside the accident analyses.Therefore, LCO 3.0.3 must be entered immediately.SURVEILLANCEREQUIREMENTSSR 3.7.10.1Standby systems should be checked periodically to ensure that theyfunction properly. As the environment and normal operating conditionson this system are not too severe, testing each train once every monthprovides an adequate check of this system. Operating each CRPAR trainfor > 15 minutes demonstrates the function of the system. The 31 dayFrequency is based on the reliability of the equipment and the two trainredundancy-a SR 3.7.10.2This SR verifies that the required CRPAR testing is performed inaccordance with the Ventilation Filter Testing Program (VFTP). TheVFTP includes testing the performance of the HEPA filter, charcoaladsorber efficiency, minimum flow rate, and the physical properties of theactivated charcoal. Specific test Frequencies and additional informationare discussed in detail in the VFTP.SR 3.7.10.3This SR verifies that each CRPAR train starts and operates on an actualor simulated actuation (high radiation and safety injection) signal. Thefreauencv of 18 months is based on industry operatina exae'ence and isrznniktafnt with tho tvnir-l rAfi ilinn rmfnf haG7r-*-- Isnownin t.At these compenentc usuall';pc n uviac wnon~oriormou at ma ia monmn i-ruauoncv. i norworo. ma r-roaui~ncv wa~concudodto bo acceotablo fromn a roliability standvoint.l J'SIR 3.710.4This SR verifies the OPERABILITY of the CRE boundary by testing forunfiltered air inleakaae past the CRE boundary and into the CRE. Thedetails of the testina are soecified in the Control Room EnvelopeKewaunee Power StationB 3.7.10-8Amendment No. 20702/02/2011 CRPAR SystemB 3.7.10The CRE is considered habitable when the radiological dose to CREoccuoants calculated in the licensina basis analyses of DBAconsequences is no more than 5 rem TEDE and the CRE occupants areorotected from hazardous chemicals and smoke.This SR verifies thatthe unfiltered air inleakage into the CRE is no areater than the flow rateassumed in the licensinn basis analyses of DBA conseauences.Whenunfiltered air inleakaae is areater than the assumed flow rate. Condition Bmu + hk -r--rl0 ; A A ^+; rill 11 +; + 0+^ 0% roLIJUR R RU RL-U -SAMSd L.U MU , Ed MJLX32 Uju M Lyd LU 3dboundary 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 Reaulatorv 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 asreauired by Reeuired Action B.2. Temporary analytical methods may alsobe used as comDensatorv measures to restore OPERABILITY (Ref. 3).Ootions for restorina the CRE boundary to OPERABLE status includechanging the licensing basis DBA conseouence 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.REFERENCES1. USAR, Section 9.6.4.2. USAR, Chapter 14.3. Letter from Eric J. Leeds (NRC) to James W, Davis (NEIl. "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. ML0403006941.4. Regulatory Guide 1.196. Rev. 1.5. NEI 99-03, "Control Room Habitability Assessment Guidance." June2001.6. Letter from C. R. Steinhardt to NRC. "Submittal of Kewaunee'sUpdated Control Room Habitability Evaluation Renort to AddressConcems Over Control Room Ventilation." dated February. 28 1989.7. USAR Section 9.6.4.Kewaunee Power StationB 3.7.10-9Amendment No. 20702/02/2011 Refueling OperationsB 3.9.6B 3.9 REFUELING OPERATIONSB 3.9.6 Containment PenetrationsBASESBACKGROUND During movement of icnyirradiated fuel assemblies (.i.e. fuelthat hasoccupied Dart of a critical reactor core within the orevious 375 hour0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br />s1within containment, a release of fission product radioactivity withincontainment will be restricted from escaping to the environment when theLCO requirements are met. In MODES 1, 2, 3, and 4, this isaccomplished by maintaining containment OPERABLE as described inLCO 3.6.1, "Containment." In MODE 6, the potential for containmentpressurization as a result of an accident is not likely; therefore,requirements to isolate the containment from the outside atmosphere canbe less stringent. The LCO requirements are referred to as "containmentclosure" rather than "containment OPERABILITY." Containment closuremeans that all potential escape paths are closed or capable of beingclosed. Since there is no potential for containment pressurization, theAppendix J leakage criteria and tests are not required.The containment serves to contain fission product radioactivity that maybe released from the reactor core following an accident, such that offsiteradiation exposures are maintained well within the guidance of RegulatoryGuide 1.183 (Ref. 1). Additionally, the containment provides radiationshielding from the fission products that may be present in the containmentatmosphere following accident conditions.The containment equipment hatch, which is part of the containmentpressure boundary, provides a means for moving large equipment andcomponents into and out of containment. During movement of rirradiated fuel assemblies within containment, the equipment hatch-mayremain open, but must be caoable of being closed must be held in placoby at least four bolts. Good 9Rginooring practir-c dicatatoAs that the bolts-roquirod by this L-CO -ho approximately equally spaceAd.The containment air locks, which are also part of the containmentpressure boundary, provide a means for personnel access duringMODES 1, 2, 3, and 4 unit operation in accordance with LCO 3.6.2,"Containment Air Locks." Each air lock has a door at both ends. Thedoors are normally interlocked to prevent simultaneous opening whencontainment OPERABILITY is required. During periods of unit shutdownwhen containment closure is not required, the door interlock mechanismmay be disabled, allowing both doors of an air lock to remain open forextended periods when frequent containment entry is necessary.During movement of recently irradiated fuel assemblies withincontainment, containment closure is required; therefore, the door interlockmechanism may remain disabled, but one air lock door must alwaysremain capable of being closed.Kewaunee Power Station B 3.9.6-1 Amendment No. 20702/02/2011 J6Refueling OperationsB 3.9.6BASESBACKGROUND (continued)The requirements for containment penetration closure ensure that arelease of fission product radioactivity within containment will be restrictedto within regulatory limits.Two systems can be used to purge or ventilate the containment; theContainment Purge and Vent System and the Post LOCA HydrogenControl System. The Containment Purge and Vent System includes a36 inch purge penetration and a 36 inch vent penetration. The PostLOCA Hydrogen Control System includes a 2 inch purge penetration anda 2 inch vent penetration. During MODES 1, 2, 3, and 4, the two valvesin each of the normal purge and vent penetrations are secured in theclosed position. The post LOCA hydrogen control subsystem containstwo trains. The valves in Train A are normally closed. The valves inTrain B are also normally closed but are periodically opened to controlcontainment pressure within the required limits. The Train B valvesreceive a signal to close via the Engineered Safety Features ActuationSystem and the Containment Purge and Vent Isolation System. Neitherof the systems are subject to a Specification in MODE 5.In MODE 6, fresh, tempered air is provided to conduct refuelingoperations. The normal 36 inch purge system is used for this purpose,and all four valves are closed by the ESFAS in accordance withLCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)Instrumentation."The other containment penetrations that provide direct access fromcontainment atmosphere to outside atmosphere must be isolated orcapable of being isolated on at least one side. Isolation may be achievedby an OPERABLE automatic isolation valve, or by a manual isolationvalve, blind flange, or equivalent. Equivalent isolation methods must beapproved and may include use of a material that can provide a temporary,atmospheric pressure, ventilation barrier for the other containmentpenetrations during recently irradiated fuel movements.APPLICABLESAFETYANALYSESDuring movement of irradiated fuel assemblies within containment,the most severe radiological consequences result from a fuel handlingaccident involving handling of recently irradiated fuel. The fuel handlingaccident is a postulated event that involves damage to irradiated fuel.Fuel handling accidents, analyzed in Reference 2, include dropping asingle irradiated fuel assembly vertically onto a rigid surface or onto otherirradiated fuel assemblies. The requirements of LCO 3.9.5, "RefuelingCavity Water Level," in conjunction with a minimum decay time of100 hours prior to irradiated fuel movement, ensures that the release offission product radioactivity, subsequent to a fuel handling accident,results in doses that are well within the guideline values specified inRegulatory Guide 1.183 (Ref. 1).Kewaunee Power StationB 3.9.6-2Amendment No. 20702/02/2011 Refueling OperationsB 3.9.6BASESLCO This LCO limits the consequences of a fuel handling accident involvinghandling rcny irradiated fuel in containment by limiting the potentialescape paths for fission product radioactivity released within containment.The LCO requires any penetration providing direct access from thecontainment atmosphere to the outside atmosphere to be closed exceptwhen appropriate administrative controls are in olace which ensure thecaoabilitv to close the penetration for tho c.,ontin nt .pugoan.d ....t pon.otrationeR.. and tho .=c..tAn .t por..nn.. ;'ir l""kc. For theOPERABLE containment purge and vent penetrations, this LCO ensuresthat these penetrations are isolable by the Containment Purge and VentIsolation System.The LCO is modified by a Note allowina penetration flow oaths with directaccess from the containment atmosohere to the outside atmosohere to beunisolated under administrative controls. Administrative controls ensurethat 1 ) aooroodate nersonnel are aware of the ooen status of thepenetration flow oath during CORE ALTERATIONS or movement ofirradiated fuel assemblies within containment, and 2) specified individualsare designated and readily available to isolate the flow oath in the eventof a fuel handlina accident.The containment personnel air lock doors may be open during movement0ofre ty irradiated fuel in the containment provided that one door iscapable of being closed within 30 minutes in the event of a fuel handlingaccident within containment. When both personnel airlock doors areopen during the movement of irradiated fuel in the containment,appropriate plant personnel shall be notified of this condition. A specifiedindividual(s) is designated and available to close the airlock following arequired evacuation of containment. Any obstruction(s) (e.g., cables andhoses) that can prevent closure of an open airlock shall be able to beremoved in a timely manner (i.e., within the 30 minutes specified above).Should a fuel handling accident occur inside containment, one personnelair lock door will be closed following an evacuation of containment.The containment eauioment hatch may be ooen durinao movement ofrecently irradiated fuel in the containment orovided that it is caoable ofbeing closed within 45 minutes in the event of a fuel handling accidentwithin containment. When the eguioment hatch is ooen during themovement of irradiated fuel in the containment, aoorooriate plantpersonnel shall be notified of this condition. A specified individual(s) isdesianated and available to close the eguigment hatch following areguired evacuation of containment. Any obstruction(s) (e.a., cables andhoses) that can prevent closure of the equipment hatch within 45 minutesshall be able to be removed in a timely manner. Should a fuel handlingaccident occur inside containment, the eguioment hatch will be closedfollowing an evacuation of containment.Kewaunee Power StationB 3.9.6-3 Refueling OperationsB 3.9.6APPLICABILITYThe containment penetration requirements are applicable duringmovement of reenlirradiated fuel assemblies within containmentbecause this is when there is a potential for the limiting fuel handlingaccident within containment. In MODES 1, 2, 3, and 4, containmentpenetration requirements are addressed by LCO 3.6.1. In MODES 5and 6, when movement of irradiated fuel assemblies within containment isnot being conducted, the potential for a fuel handling accident does notexist. Additionally, due to radioactive decay, a fuel handling accidentinvolvina handling recently irradiated fuel (i.e., fuel that has occuoied Dartof a critical reactor core within the previous 375 hours0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br />) will result in dosesthat are within the guideline values specified in 10 CFR 50.67. evenwithout containment closure caoabilitv. Therefore, under these conditionsno requirements are placed on containment penetration status.The olant has committed to implement the guidance contained inNUMARC 93-01. Section 11.3.6.5. "Safety Assessment for Removal ofEguioment from Service During Shutdown Conditions." subheadina."Containment- Primary (PWR-Secondarv (BWR)." related to theassessment of systems removed from service during movement ofrradiated fueLI ACTIONSA..1If the containment equipment hatch, air locks, or any containmentpenetration that provides direct access from the containment atmosphereto the outside atmosphere is not in the required status, including theContainment Purge and Vent Isolation System not capable of automaticactuation when the purge and vent valves are open, the unit must beplaced in a condition where the isolation function is not needed. This isaccomplished by immediately suspending movement of rirradiated fuel assemblies within containment. Performance of theseactions shall not preclude completion of movement of a component to asafe position.Kewaunee Power StationB 3.9.6-4 Refueling OperationsB 3.9.6BASESSURVEILLANCE SR 3.9.6.1REQUIREMENTSThis Surveillance demonstrates that each required containmentpenetration is in the required status. The Surveillance on the open purgeand vent valves will demonstrate that the valves are not blocked fromclosing. Also the Surveillance will demonstrate that each valve operatorhas motive power, which will ensure that each valve is capable of beingclosed by an OPERABLE automatic containment purge and vent isolationsignal.The Surveillance is performed every 7 days during movement ofrenyirradiated fuel assemblies within containment. The Surveillance interval isselected to be commensurate with the normal duration of time tocomplete fuel handling operations. A surveillance before the start ofrefueling operations will provide two or three surveillance verificationsduring the applicable period for this LCO. As such, this Surveillanceensures that a postulated fuel handling accident involving handlingrcny irradiated fuel that releases fission product radioactivity within thecontainment will not result in a release of significant fission productradioactivity to the environment in excess of those recommended byRegulatory Guide 1.183 (Reference 1).SR 3.9.6.2This Surveillance demonstrates that each required containment purgeand vent valve actuates to its isolation position on an actual or simulatedhigh radiation signal. The 18 month Frequency maintains consistencywith other similar ESFAS instrumentation and valve testing requirements.LCO 3.3.6, "Containment Purge and Vent Isolation Instrumentation,"provides additional Surveillance Requirements for the containment purgeand vent valve actuation circuitry. These Surveillances performed duringMODE 6 will ensure that the valves are capable of closing after apostulated fuel handling accident involving handling geILirradiatedfuel to limit a release of fission product radioactivity from the containment.The SR is modified by a Note stating that this Surveillance is not requiredto be met for valves in isolated penetrations. The LCO provides theoption to close penetrations in lieu of requiring automatic actuationcapability.REFERENCES 1. Regulatory Guide 1.183, July 2000.2. USAR, Section 14.2.1.Kewaunee Power Station B 3.9.6-5 Amendment No. 20702/02/2011