Text

Enclosure (4 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8)
	ML102371294
Person / Time
Site:	Kewaunee
Issue date:	08/18/2010
From:	; Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
References
	10-457, TAC ME2139
	Download: ML102371294 (0)
	v • d • e

{{#Wiki_filter:ITS NRC Questions Id2141NRC Question Number MEH-009 Category Technical ITS Section 3.7 ITS Number 3.7.8 DOC Number JFD Number 6 JFD Bases Number 6 Page Number(s) NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question The May 12, 2010 supplem ent to the TS Conver sion LAR proposed the addition of the word "necessarily" to the note in SR 3. 7.8.1. The staff believes the proposed addition is contrary to TS usage convention because inserting the word would allow intentional entry into LCO 3.7.8 ACTIONS for operational convenie nce. The Bases for LCO 3.0.2 specifically state: "Inten tional entry into ACTIONS should not be made for operational convenience." The supplement stated that the reason for the proposed request is related to Area Fan Cooler Units and minimum Completion Times in Conditions of ITS 3.8.7 and 3.8.9. The staff believes that issues with such completion times should be addressed by proposing and justifying different Completion Times, not changing TS usage convention. If desired, please propose and justify different Completion Times for the affected Conditions of ITS 3.8.7 and 3.8.9. Attach File 1 Attach File 2 Issue Date 6/8/2010 Added By Matthew Hamm Date Modified Modified By Date Added 6/8/2010 7:47 AM Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=2141 Licensee Response/NRC Response/NRC Question Closure Id3611NRC Question Number MEH-009 Select Application Licensee Response Response Date/Time 6/21/2010 4:10 PM Closure Statement Response Statement In the first paragraph of the NRC question, the NRC reviewer states that the staff believes that inserting the word "necessarily" into th e SR Note would allow intentional entry into LC O 3.7.8 ACTIONS for operational convenience. The NRC question further states that LCO 3.0.2 Bases specifically states that intentional entry into ACTIONS s hould not be made for operational convenience. While KPS concurs that the LCO 3.0.2, through the Bases, prohibits intentional entry into ACTIONS for operational convenience, KPS does not agree that performing routine preventive and corrective maintenance is operational convenience. The ITS 3.0.2 Bases also states that "The Completion Times of the Required Actions are also applicable when a sys tem or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems" (italics added for emphasis). Thus, LCO 3.0.2 does allow intentional entry into ACTIONS to perform preventive and corrective maintenance, which is the purpose of the proposed KPS Note change. Therefore, the proposed Note change is not contrary to the ITS usage convention. However, KPS has reviewed the NRC request to include the Completion

Times in each affected Specification. Based on this review, the previous Note change to ITS 3.7.8 is withdrawn (reference - Letter fr om J. Alan Price (DEK) to Document Control Desk (NRC), "License Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications (TAC NO. ME02467) - Request to Change Proposed Service water and Main Steam Isolation Valve Specifications," dated May 12, 2010 [ADAMS Accession No. ML101380399]) and a new Note has been added to ITS 3.8.4, ITS 3.8.7, and ITS 3.8.9 to essentially allow a 24 hour time to restore a non-functional room cooler that affects the DC electrical power subsystems, inverters, or electrical pow er distribution subsystems. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment. Question Closure Date Attachment Pa ge 1of 2 Kewaunee ITS Conversion Database 06/25/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3611 1 MEH-009 Markup.pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 6/21/2010 4:26 PM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/25/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3611 A01ITS ITS 3.8.4 b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve

HOT STANDBY within the next 6 hours.

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either:

A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or

B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator.

3. One battery may be inoperable for a period not exceeding 24 hours provided the other battery and two battery chargers remain OPERABLE with one charger

carrying the d-c supply system.

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are

OPERABLE.

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for 24 hours provided the redundant bus and its loads remain OPERABLE.

7. Two diesel generators may be inoperable for 2 hours.

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the

requirements of its applicable LIMITING CONDITION FOR OPERATION, provided:

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

Page 2 of 2 See ITS 3.8.1 See ITS 3.8.9 See ITS 3.8.1 See ITS 3.8.1 ACTION C ACTION B and MODE 5 in 36 hours MODE 3 M01 M02 2 DC electrical power subsystem L01 M03Add proposed SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 Add proposed ACTION A L01 Amendment No. 194 TS 3.7-2 02/07/2008 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING Kewaunee Power Station Page 5 of 5 associated charger is inoperable) are being applied in the ITS than were applied in the CTS. INSERT DOC L02 L02(Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when a DC source is inoperable. ITS 3.8.4 also provides ACTIONS, but includes a Note that allows a DC electrical power subsystem to be inoperable for up to 24 hours solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the other DC electrical power subsystem is OPERABLE. This changes the CTS by allowing a 24 hour deferral in entering associated ACTIONS when a DC electrical power subsystem is inoperable solely due to a room cooler being non-functional. The purpose of the CTS 3.7.b and ITS 3.8.4 ACTIONS is to adequately control how long a DC electrical power subsystem can be inoperable. The change allows an additional 24 hours if the inoperability of the DC electrical power subsystem is due to a room cooler being non-functional, and provided the associated room temperature is monitored and maintained within the design environmental requirements and the other DC electrical power subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural

guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC electrical power subsystem inoperability is limited to 2 hours. Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the DC electrical power subsystems. This change is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS. DC Sources - Operating 3.8.4 WOG STS 3.8.4-1 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 3.8 ELECTRICAL POWER SYSTEMS

3.8.4 DC Sources - Operating

LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One [or two] battery charger[s on one train]

inoperable.

A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage. AND A.2 Verify battery float current AND A.3 Restore battery charger[s] to OPERABLE status.

2 hours

Once per [12] hours

7 days [B. One [or two] batter[y][ies on one train] inoperable.

B.1 Restore batter[y][ies] to OPERABLE status.

[2] hours ]

C. One DC electrical power subsystem inoperable for reasons other than

Condition A [or B].

C.1 Restore DC electrical power subsystem to OPERABLE status.

[2] hours D. Required Action and Associated Completion Time not met. D.1 Be in MODE 3. AND D.2 Be in MODE 5.

6 hours

36 hours required CTS 3.7.a.6 B C C DOC L01 3.7.b.3 3.7.b 3 3 3 2 B 3.7.a 72 hours 4 ---------------------------------------------------------------------------NOTE---------------------------------------------------------------- When a DC electrical power subsystem is inoperable solely due to the room cooler being non-functional, entry into associated AC TIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and maintained within the design environmental req uirements; and b) the

other DC electrical power subsystem is OPERABLE.

6 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

1. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

2. The term "required" has been added since the DC System has a spare battery charger that is common to both DC subsystems, and the spare charger can be used to meet the requirements of the LCO if the normal charger is inoperable.

3. The bracketed ISTS 3.8.4 ACTION B has been d eleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been modified and renumbered, as necessary.

4. The Completion Time for ISTS 3.8.4 Required Action A.3 has been changed from 7 days to 72 hours. This change is consistent with proposed TSTF-500.

Kewaunee Power Station Page 1 of 1

6. A new Note is being added to allow a DC electrical power subsystem to be inoperable for up to 24 hours due to a room cooler being non-functional, provided the associated room temperature is monitored

and maintained within the design environmental requirements and the other DC electrical power

subsystem is OPERABLE. CTS 3.7.b.3 allows one battery to be inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room cooler is non-functional. Although the DC electrical power

subsystems are operating and connected to the associated DC bus(es), with room cooling being non-functional, the

design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional

for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical

power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.4, DC

electrical power subsystem inoperability is limited to 2 hours. Therefore, the current procedural guidance for using

the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler

maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour

without exceeding the design environmental limits for the DC electrical power subsystems. DC Sources - Operating B 3.8.4 WOG STS B 3.8.4-4 Rev. 3.0, 03/31/04 BASES

LCO The DC electrical power subsystems, each subsystem consisting of [two] batteries, battery charger [for each battery] and the corresponding control

equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any train DC electrical power subsystem does not prevent the minimum safety functi on from being performed (Ref. 4). An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es). APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients

and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown." ACTIONS A.1, A.2, and A.3 Condition A represents one train with one [or two] battery chargers inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restor ing a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability. All changes are unless otherwise noted 1 2 7 2 y subsystem y one one 2 required The ACTIONS are modified by a Note that allows a 24 hour delay in entering the A CTIONS when a DC electrical power subsystem is inoperable solely due to the

room cooler being non-functional, provided

the associated room temperature is

monitored and maintained within the design

environmental requirements and the other

DC electrical power subsystem is

OPERABLE. The 24 hour allowance is

provided in order to perform room cooler

maintenance. If during the 24 hour period

the other DC electrical power subsystem

becomes inoperable, the associated A CTIONS for an inoperable DC electrical power subsystem must immediately be

entered. This 24 hour time period is

acceptable because the room containing

the DC electrical power subsystems is

monitored on an hourly basis to ensure

conditions are within design environmental

requirements during this time. 7 Inverters - Operating 3.8.7 WOG STS 3.8.7-1 Rev. 3.0, 03/31/04 3.8 ELECTRICAL POWER SYSTEMS

3.8.7 Inverters - Operating

LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

 --------------------------------

NOTE--------------------------------------------

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC form an equalizing charge on [its/their] associated [common] battery, provided:

a. The associated AC vital bus(es) [is/are] energized from [its/their] [Class 1E constant voltage source transformers] [inverter using

internal AC source], and

b. All other AC vital buses are energized from their associated OPERABLE inverters. ] ------------------------------------------------

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One [required] inverter inoperable.

A.1 --------------NOTE-------------- Enter applicable Conditions and Required Actions of

LCO 3.8.9, "Distribution Systems - Operating" with any AC vital bus de-energized. -------------------------------------

Restore inverter to OPERABLE status.

24 hours B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND

6 hours instrument instrument 5INSERT 1 C C ;instrument/rectifier DOC M01 DOC M01 DOC M01 DOC M01 CTS 1 2 2 6 5 1 5 3 3 INSERT 1A 3.8.7 Insert Page 3.8.7-1 INSERT 1 B. Two inverters in one train inoperable. B.1 Restore one inverter to OPERABLE status. 2 hours DOC M01 3 CTS INSERT 1A

NOTE-----------------------------------------------------------

When one or both inverters in one train are inoperable solely due to the room cooler

being non-functional, entry into associated ACTIONS may be delayed for up to 24

hours provided: a) the associated room temperature is monitored and maintained within

the design environmental requirements; and b) both inverters in the other train are

OPERABLE.

7 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. The word "required" has been deleted from the LCO and Condition A since all Train A and Train B inverters are required. 2. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design. 3. ITS 3.8.7 Condition B has been added to allow two inverters on the same train to be inoperable for up to 2 hours. The Kewaunee design incorporates two 120 VAC inverters on each train. As written, ISTS 3.8.7 requires entry into LCO 3.0.3

when two inverters in the same train are inoperable since no ACTION exists for when more than one inverter is inoperable. The inoperability of two inverters in the same train does not place the unit outside of its design basis because the other train remains OPERABLE to support engineered safety features operation. Therefore, entry into LCO 3.0.3 is not necessary in this condition. An allowed outage time of 2 hours has been selected to be consistent with the allowed outage time in ITS 3.8.9 for two inoperable 120 VAC buses in the same train. In addition, the subsequent ACTION has been renumbered. 4. The SR has been modified to reflect that each inverter must have proper voltage, frequency, and alignment to its associated instrument bus. 5. The proper plant terminology has been used. 6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3. Kewaunee Power Station Page 1 of 1

7. A new Note is being added to allow one or more inverters in one train to be inoperable for up to 24 hours due to a room cooler being non-functional, provided the associated room temperature is monitored

and maintained within the design environmental requirements and the inverters in the other train are

OPERABLE. CTS does not contain a specification comparable to ITS 3.8.7, Inverters-Operating. The

inverters are located within the battery rooms. Therefore, the room cooler for the associated battery

room controls the environment conditions for the inverters. CTS 3.7.b.3 allows one battery to be

inoperable for a period not to exceed 24 hours. CTS 3.7.b.3 is also entered when the associated room

cooler is non-functional. Although the inverters are operating and connected to the associated DC

bus(es) and AC instrument bus(es), with room cooling being non-functional, the design environment

limits could be exceeded for the inverters if room cooling is non-functional for an extended period of time.

Current procedural guidance requires monitoring the room containing the inverters to ensure conditions

are within design environmental requirements. However, per ITS 3.8.7, two inverters in one train

inoperable is limited to 2 hours. Therefore, the current procedural guidance for using the same

completion time from the specification for a non-functional room cooler is not practicable, as room cooler

maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed

within 24 hours without exceeding the design environmental limits for the inverters. Inverters - Operating B 3.8.7 WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1 BASES Train A or Train B ACTIONS A.1 instrument 4 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant voltage source transformer or inverter using internal AC source].

For this reason a Note has been included in Condition A requiring the

entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours.

Required Action A.1 allows 24 hours to fix the inoperable inverter and

return it to service. The 24 hour limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety

systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this

status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant

systems. 4 6 2 5Train A or Train B inverters C C instrument /rectifier instrument Power to an instrument bus is provided in the following order: 1) filtered AC through the inverter (referred to as "normal"); 2) DC changed to AC via the inverter (referred to as "standby"), and; 3) non-filtered AC through the inverter via a static switch (referred to as "alternate"). INSERT 1 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS when a one or both inverters in one train are inoperable solely due to the room cooler being

non-functional, provided the associated room temperature is monitored and maintained

within the design environmental requirements and both inverters in the other train are

OPERABLE. The 24 hour allowance is provided in order to perform room cooler

maintenance. If during the 24 hour period one or both of the inverters in the other train

become inoperable, the associated ACTIONS for the inoperable inverter(s) must

immediately be entered. This 24 hour time period is acceptable because the room

containing the inverters is monitored on an hourly basis to ensure conditions are within designenvironmentalrequirements. 4 ITS ITS 3.8.9 A013.7 AUXILIARY ELECTRICAL SYSTEMS APPLICABILITY Applies to the availability of electrical power for the operation of plant auxiliaries.

OBJECTIVE To define those conditions of electrical power availability necessary to provide 1) safe reactor operation and 2) continuing availability of engineered safety features. SPECIFICATION M01 a. The reactor shall not be made critical unless all of the following requirements are satisfied: A pplicabilit y 1. The reserve auxiliary transformer is fully operational and energized to supply power to the 4160-V buses.

2. A second external source of power is fully operational and energized to supply power to emergency buses 1-5 and 1-6.

3. The 4160-V buses 1-5 and 1-6 are both energized.

4. The 480-V buses 1-52 and 1-62 and their MCC's are both energized from their respective station service transformers.

5. The 480-V buses 1-51 and 1-61 are both energized from their respective station service transformers.

6. Both station batteries and both DC systems are OPERABLE, except during testing and surveillance as described in TS 4.6.b.

7. Both diesel generators are OPERABLE and each diesel generator shall have:

A. Day tanks containing a minimum volume of 1000 gallons; B. An underground storage tank and corresponding day tanks containing a minimum volume of 32,888 gallons of useable fuel; C. An OPERABLE diesel fuel oil transfer pump.

8. At least one pair of physically independent transmission lines serving the substation is OPERABLE. The three pairs of physically independent transmission lines are:

A. R-304 and Q-303 B. F-84 and Y-51 C. R-304 and Y-51 See ITS 3.8.1 and 3.8.3 See ITS 3.8.1 See ITS 3.8.1 Add proposed LCO 3.8.9 Train A and B AC instrument bus electrical power distribution subsystem requirements, including LCO 3.8.9, ACTIONS B and E, and SR 3.8.9.1 M02Train A and B DC electrical power distribution subsystems See ITS 3.8.4 and 3.8.6 A02 LA01Train A and B AC electrical power distribution subsystem shall be OPERABLE. LCO 3.8.9 Amendment No. 203 TS 3.7-1 02/06/2009 Page 1 of 2 A CTIONS Note A01ITS ITS 3.8.9 b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve

HOT STANDBY within the next 6 hours.

1. Either auxiliary transformer may be out of service for a period not exceeding 7 days provided the other auxiliary transformer and both diesel generators are OPERABLE.

2. One diesel generator may be inoperable for a period not exceeding 7 days provided within 24 hours, either:

A. Determine the OPERABLE diesel generator is not inoperable due to common cause failure, or

B. Perform surveillance requirement TS 4.6.a.1.A on the OPERABLE diesel generator.

3. One battery may be inoperable for a period not exceeding 24 hours provided the other battery and two battery chargers remain OPERABLE with one charger

carrying the d-c supply system.

4. If the conditions in TS 3.7.a.8 cannot be met, power operation may continue for up to 7 days provided at least two transmission lines serving the substation are

OPERABLE.

5. Three off-site power supply transmission lines may be out of service for a period of 7 days provided reactor power is reduced to 50% of rated power and the two diesel generators shall be tested daily for OPERABILITY.

6. One 4160-V or 480-V engineered safety features bus may be out of service for 24 hours provided the redundant bus and its loads remain OPERABLE.

7. Two diesel generators may be inoperable for 2 hours.

c. When its normal or emergency power source is inoperable, a system, train or component may be considered OPERABLE for the purpose of satisfying the

requirements of its applicable LIMITING CONDITION FOR OPERATION, provided:

1. Its corresponding normal or emergency power source is OPERABLE; and

2. Its redundant system, train, or component is OPERABLE.

See ITS 3.8.4 and 3.8.6 See ITS 3.8.1 M03 MODE 3 and MODE 5 in 36 hours See ITS 3.8.1 ACTION D ACTION A M01 M03 A03 ACTION E 8 M03 Add proposed ACTION A Note See ITS 3.8.1 L01 Add proposed ACTIONS C and E (for 125 VDC) Add proposed SR 3.8.9.1 for 4160 and 480 VAC and 125 VDC M04 Amendment No. 194 TS 3.7-2 02/07/2008 Page 2 of 2 A dd proposed ACTIONS Note L02 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Furthermore, for inoperabilities of the DC buses or of AC buses in both trains, since no actions are provided, CTS 3.0.c would also require the unit to be subcritical within a total of 13 hours (1 hour to initiate action, 6 hours to be in HOT STANDBY (which allows the reactor to still be critical), and 6 hours to be in HOT SHUTDOWN (which requires the reactor to be subcritical)). ITS LCO 3.8.9 requires the Train A and B AC and DC electrical power distribution subsystems to be OPERABLE in MODES 1, 2, 3, and 4. When a unit shutdown is required due to inoperabilities of the AC or DC buses, ITS 3.8.9 ACTION D requires the unit to be in MODE 3 (CTS equivalent HOT SHUTDOWN) within 6 hours and in MODE 5 (CTS equivalent COLD SHUTDOWN) in 36 hours. This changes the CTS by requiring the Train A and B AC and DC electrical power distribution subsystems to be OPERABLE in MODES 3 and 4 and in MODE 2 when the reactor is not critical and provides commensurate ACTIONS to cover the new

Applicability. The purpose of CTS 3.7.a, in part, is to ensure the Train A and B AC and DC electrical power distribution subsystems are OPERABLE to mitigate the

consequences of a transient or design basis accident. The Train A and B AC and DC electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 when an accident may occur. In MODE 1 and 2 the reactor is either critical or there is a potential for the reactor to become critical. In MODES 3 and 4 the reactor is not critical, however the reactor coolant temperature is always above 200 °F and there is considerable energy in the reactor core and the electrical power distribution systems must be available to support equipment necessary to mitigate the consequences of a pipe break. Therefore, it is acceptable to require the AC and DC electrical power distribution subsystems to be OPERABLE in MODES 3 and 4 as well as MODES 1 and 2. This change is designated as more restrictive because the LCO will be applicable under more reactor operating conditions than in the CTS.

M02 The CTS does not specify requirements for AC instrument electrical power distribution subsystems to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.8.9, in part, requires the Train A and Train B AC instrument bus electrical power distribution power subsystems to be OPERABLE in MODES 1, 2, 3, and 4.

Appropriate ACTIONS (B and E) and a Surveillance Requirement (SR 3.8.9.1) are also provided. This changes the CTS by incorporating these ITS 3.8.9 requirements. The purpose of ITS 3.8.9 is, in part, to ensure the necessary AC instrument electrical power distribution subsystems are available to provide electrical power to mitigate postulated events. This change is acceptable since the distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). This change is designated as more restrictive because it adds new requirements to the CTS. M03 CTS 3.7.b.6 requires inoperable AC buses to be restored to OPERABLE status within 24 hours provided the redundant bus and its loads remain OPERABLE. ITS 3.8.9 Required Action A.1 allows 8 hours to restore the Train A and Train B AC electrical power distribution subsystem(s) to OPERABLE status. In addition, a Note has been added (ITS 3.8.9, Note to ACTION A) that requires entry into applicable Conditions and Required Action of LCO 3.8.4, "DC Sources - Operating," for DC Sources made inoperable by inoperable power distribution Kewaunee Power Station Page 2 of 5

, including an ACTIONS Note DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Kewaunee Power Station Page 5 of 5 provided by ITS 3.8.9 ACTION C would not be allowed. This changes the CTS by providing some time to restore an inoperable DC electrical power distribution subsystem prior to requiring a plant shutdown provided a loss of function has not occurred.

The purpose of CTS 3.7.a.6 is to ensure the availability of necessary DC electrical power to ESF systems. This change is acceptable because the

Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The

Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows a short time period

to restore an inoperable DC electrical power distribution subsystem to OPERABLE status. This is acceptable because there are sufficient electrical power distribution subsystems available to ensure all plant safety functions can be supported by the Train A and Train B electrical power distribution subsystems. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. INSERT DOC L02 L02(Category 3 - Relaxation of Completion Time) CTS 3.7.b provides the requirement when an AC or DC electrical power distribution subsystem is inoperable. ITS 3.8.9 also provides ACTIONS, but includes a Note that allows one or more electrical power distribution subsystems to be inoperable for up to 24 hours solely due to a room cooler being non-functional and not require the ACTIONS to be entered, provided: a) the associated room temperature is monitored and maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the

other train are OPERABLE. This changes the CTS by allowing a 24 hour deferral in entering associated ACTIONS when a electrical power distribution subsystem is inoperable solely due to a room cooler being non-functional. The purpose of the CTS 3.7.b and ITS 3.8.9 ACTIONS is to adequately control how long an electrical power distribution subsystem can be inoperable. The change allows an

additional 24 hours if the inoperability of the electrical power distribution subsystem is due to a room cooler being non-functional, provided the associated room temperature is monitored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. CTS 3.7.b.6 allows one 480-V engineered safety features bus may be out of service for 24 hours. CTS 3.7.b.6 is also entered when the associated room cooler is non-functional. The CTS does not contain a specification specifically for DC distribution subsystem or AC instrument bus electrical power distribution subsystem. Although the AC, DC, and AC instrument bus electrical power subsystems are operating and connected to the associated AC, DC bus(es), with room cooling being non-functional, the design environment limits could be exceeded for the DC electrical power subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance requires monitoring the room containing DC electrical power subsystems to ensure conditions are within design environmental requirements. However, per ITS 3.8.9, an electrical power distribution subsystem inoperability can be limited to 2 hours.

Therefore, the current procedural guidance for using the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hour without exceeding the design environmental limits for the AC, DC, and AC instrument bus electrical power distribution subsystems. This change

is designated as less restrictive because the Required Action Completion Time in the ITS under certain conditions is longer than allowed in the CTS. Distribution Systems - Operating 3.8.9 WOG STS 3.8.9-1 Rev. 3.1, 12/01/05 3.8 ELECTRICAL POWER SYSTEMS

3.8.9 Distribution Systems - Operating

LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more AC electrical power

distribution subsystems inoperable.

NOTE-------------------

Enter applicable Conditions and

Required Actions of LCO 3.8.4, "DC

Sources - Operating," for DC trains

made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power distribution subsystem(s) to OPERABLE status.

8 hours

B. One or more AC vital buses inoperable.

B.1 Restore AC vital bus subsystem(s) to OPERABLE status.

2 hours

C. One or more DC electrical power

distribution subsystems inoperable.

C.1 Restore DC electrical power distribution

subsystem(s) to OPERABLE status.

2 hours 2 instrument (es)instrument instrument DOC L01 DOC M02 3.7.b.6 sources 1 1 1 3.7.a.3, 3.7.a.4, 3.7.a.5, 3.7.a.6 3.7.a CTS -------------------------------------------------------------------------------NOTE---------------------------------------------------------------------------------------- When one or more electrical power distribution subsystems are inoperable solely due to the room cooler being non-functional, en try into associated ACTIONS may be delayed for up to 24 hours provided: a) the associated room temperature is monitored and

maintained within the design environmental requirements; and b) the electrical power distribution subsystems in the other trai n are OPERABLE .

5 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

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

2. The allowance in ISTS 3.8.9 ACTION C to have one or more DC electrical power distribution subsystems inoperable for 2 hours has been changed to address only the inoperability of one Train A or Train B DC electrical power distribution subsystem, since if both the Train A and Train B buses were inoperable, then a loss of safety function would exist and entry into ACTION E would be necessary.

3. Changes made to be consistent with the Specification.

4. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design. Kewaunee Power Station Page 1 of 1

5. A new Note is being added to allow one or more electrical power distribution subsystems to be inoperable for up to 24 hours due to a room cooler being non-functional, provided associated room

temperature is monitored and maintained within the design environmental requirements and the electrical

power distribution subsystems in the other train are OPERABLE. CTS 3.7.b.6 allows one 480-V engineered safety features bus may be out of service for 24 hours. CTS 3.7.b.6 is also entered when the associated room cooler

is non-functional. CTS does not contain a specification specifically for DC distribution subsystem or AC instrument

bus electrical power distribution subsystem. Although the AC, DC, and AC instrument bus electrical power

subsystems are operating and connected to the associated AC and DC bus(es), with room cooling being non-

functional, the design environment limits could be exceeded for the AC, DC, or AC Instrument bus electrical power

distribution subsystems if room cooling is non-functional for an extended period of time. Current procedural guidance

requires monitoring the room containing AC, DC, or AC instrument bus electrical power distribution subsystems to

ensure conditions are within design environmental requirements. However, per ITS 3.8.9, an electrical power

distribution subsystem inoperability can be limited to 2 hours. Therefore, the current procedural guidance for using

the same completion time from the specification for a non-functional room cooler is not practicable, as room cooler

maintenance requires more than 2 hours. Historically, room cooler maintenance has been completed within 24 hours

without exceeding the design environmental limits for the AC, DC, and AC instrument bus electrical power distribution

subsystems. Distribution Systems - Operating B 3.8.9 WOG STS B 3.8.9-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1 BASES LCO (continued)

In addition, tie breakers between redundant safety related AC, DC, and AC vital bus power distribution subsystems, if they exist, must be open. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s). If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV buses from being powered from the same offsite circuit. electrical instrument APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients

and 3;

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA. Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems -

Shutdown." ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor control centers, or distribution panels (except AC vital buses), in one train inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours. instrument 4electrical power distribution subsystem electrical 4electrical power distribution subsystem 6 The ACTIONS are modified by a Note that allows a 24 hour delay in entering the ACTIONS when one or more electrical power distri bution subsystems are inoperable solely due to the room cooler being non-functional, provided the associated room temperature is monit ored and maintained within the design environmental requirements and the electrical power distribution subsystems in the other train are OPERABLE. The

24 hour allowance is provided in order to perform room cooler maintenance. If during the 24 hour period the buses subsequentl y become inoperable such that a loss of function occurs, the associated ACTIONS for the inoperable DC electrical power subsystem(s) must immediately be

entered. This 24 hour time period is acceptable because the room containing the AC, DC, and AC instrument bus electrical power distribution

subsystems is monitored on an hourly basis to ensure conditions are within design environmental requirements. Licensee Response/NRC Response/NRC Question Closure Id3621NRC Question Number MEH-009 Select Application Licensee Response Response Date/Time 6/28/2010 4:10 PM Closure Statement Response Statement In the previous response to this quest ion, KPS provided a draft markup of changes to ITS 3.8.4, ITS 3.8.7, and ITS 3.8.9 that added a Note to the ACTIONS to allow up to 24 hours with the associa ted components covered by the LCO inoperable due to a non-functional ro om cooler. During a subsequent phone call with the NRC reviewer, he requested that KPS re-look at the Note restrictions, specifically related to monitoring the room temperature while using the Note. KPS has re-r eviewed the monitoring requirements and has decided to include in the Note a requirement that the room temperature must be monitored and maintain ed within the design environmental requirements. Furthermore, the ITS Bases states that the room temperature monito ring requirement is met by monitoring the room temperature on an hourly basis while using the note. A draft markup regarding this change is attached and supersedes the markup attached to the previous response. This change wi ll be reflected in the supplement to this section of the ITS conversion amendment. Question Closure Date Attachment 1 MEH-009 Markup Rev 1.pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Gerald Waig Added By Robert Hanley Date Added 6/28/2010 4:14 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 07/01/2010 htt p://www.excelservices.com/rai/index. p h p?re q uestT ype=areaItemPrint&itemId=3621 A01ITS ITS 3.8.4 b. During power operation or recovery from inadvertent trip, any of the following conditions of inoperability may exist during the time intervals specified. If OPERABILITY is not restored within the time specified, then within 1 hour action shall be initiated to achieve