Text

Enclosure, Q&A to Attachment 1, Vol 12 (Section 3.7)
	ML102370389
Person / Time
Site:	Kewaunee
Issue date:	07/16/2010
From:	; Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
References
	10-428
	Download: ML102370389 (55)
	v • d • e

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 1 of 55 ITS NRC Questions Id 2061 NRC Question KAB-074 Number Category Technical ITS Section 3.7 ITS 3.7.8 Number DOC Number JFD Number JFD Bases Number Page 181 and 182 Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Barry Marcus Branch POC Conf Call N

Requested NRC Technical Report EE-0116, Revision 6, includes a calculation for Forebay Level in Question ITS 3.7.8, Service Water System, (Attachment 1, Volume 12, page 181 of 415) and Current Technical Specification Table 3.5-1 Function 7 (Attachment 1, Volume 12, page 182 of 415). Calculation 4.7.3 in Technical Report EE-0116, Revision 6 (page 192 of 205), provides the Nominal Trip Setpoint, As Found Value, and As Left Value, for Forebay Level. However, neither the Nominal Trip Setpoint, As Found Value, nor, As Left Value is included in ITS 3.7.8. LA01 for ITS 3.7.8 (Attachment 1, Volume 12, page 187 of 415) states, ITS LCO 3.7.8 requires two SW trains to be OPERABLE. The ITS does not define the components, the associated flow path, or the forebay level trip system that comprise an OPERABLE SW train. If ITS 3.7.8 does not need to define the forebay level trip system, why is Calculation 4.7.3 included in Technical Report EE-0116, Revision 6? Please include the appropriate Forebay Level value in ITS 3.7.8, include Forebay Level in the setpoint control program, or provide justification for not including the Forbay Level appropriate value in ITS 3.7.8.

Attach File 1

Attach File 2

Issue Date 5/25/2010 Added By Kristy Bucholtz Date Modified Modified By Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 1 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2061 06/24/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 2 of 55 Date Added 5/25/2010 4:13 PM Notification NRC/LICENSEE Supervision Ravinder Grover Matthew Hamm Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 2 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2061 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 3 of 55 Licensee Response/NRC Response/NRC Question Closure Id 3311 NRC Question KAB-074 Number Select Licensee Response Application

Response

5/27/2010 2:10 PM Date/Time Closure Statement Response As can be seen on CTS Table TS 3.5-1, Functional Unit 7, the Forebay Level Statement does not have a specified Trip Setting. Thus, currently, KPS controls the Trip Setting in EE-0116. ITS LCO 3.7.8 does not specify all the details as to what constitutes OPERABILITY of the Service Water System. The ISTS allows these details to be in the Bases, which is where they are for the KPS ITS. The KPS ITS Bases, LCO Section (page 196), states that "In addition, the Forebay Water Level Trip System must be OPERABLE for the SW System to be considered OPERABLE." It should be noted that this same Bases section also defines other requirements for OPERABILITY, such as the pumps and flowpath. Furthermore, ITS SR 3.7.8.4 is a CHANNEL CALIBRATION for the Forebay Level instruments and ITS SR 3.7.8.5 is a verification that the pump breaker trips on an actual or simulated Forebay Water Level - Low Low signal. Both of these SRs have to be met, as required by ITS SR 3.0.1 (see Volume 3, Page 30 of 63), for the LCO to be met. Thus, if a CHANNEL CALIBRATION of the Forebay Water Level instruments failed, LCO 3.7.8 would not be met and the appropriate ACTIONS of ITS 3.7.8 would have to be entered. KPS believes that with the CHANNEL CALIBRATION Surveillance specified, ITS 3.7.8 is defining the Forebay Water Level Trip System as part of OPERABILITY. Furthermore, since the KPS CTS does not specify the Forebay Water Level setpoint, it is not required to be included in either the ITS nor the Setpoint Control Program.

KPS also notes that Section 4.7.3 of Technical Report EE-0116 determines values for Forebay Level because the parameter is part of the CTS Instrumentation Section. EE-0116 is written in a manner to be applicable to both CTS presently and ITS when implemented. When ITS is implemented, the trip setting will not be part of the KPS SCP.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 3 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3311 06/24/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 4 of 55 Victor Cusumano Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 5/27/2010 2:10 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 4 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3311 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 5 of 55 Licensee Response/NRC Response/NRC Question Closure Id 3411 NRC Question KAB-074 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 6/7/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 6/7/2010 7:18 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 5 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3411 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 6 of 55 ITS NRC Questions Id 1151 NRC Question MEH-001 Number Category Technical ITS Section 3.7 ITS 3.7.5 Number DOC L-5 Number JFD 7

Number JFD Bases Number Page Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Stanley Gardocki Branch POC Conf Call N

Requested NRC This question is related to Licensee-identified BSI#2. The question was posed by the Balance of Plant Question Branch:

The licensee is requesting a deviation from Standard Technical Specifications (STS) to allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore one of the two inoperable AFW trains when performing SR 3.7.5.1. STS for Westinghouse Plants, NUREG-1431, revision 3, does not permit any allowed outage time (AOT) for two auxiliary feedwater pumps being out of service.

STS - 3.7.5 (c) states when two AFW pumps are inoperable, the licensee is directed to directly enter a six (6) hour clock to be in mode 3. The licensee current technical specifications (CTS) 3.4.b.3 state that if two of the three AFW trains are inoperable, to reduce power to < 1673 MWt within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS 3.4.b.4.B continues with actions for two inoperable AFW trains requires restoration of one of the trains within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The licensee current design basis accident for loss of feedwater credits two motor-driven AFW pumps (assumes the loss of the steam-driven AFW pump). The Kewaunee safety analysis report states "Eight hundred seconds after the initiation of the lo-lo steam generator water level reactor trip, flow from the two motor-driven AFW pumps is credited, thus reducing the rate of water level decrease in the steam generators. The capacity of two motor-driven AFW pumps is sufficient to dissipate core residual heat.

10 CFR 50.36 (b) requires that technical specifications be derived from the analyses and evaluation included in the safety analysis report. The staff requests the licensee provide the analysis/evaluation justifying the plant can withstand its design basis accidents with two AFW trains inoperable.

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 6 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1151 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 7 of 55 Attach File 1

Attach File 2

Issue Date 11/20/2009 Added By Matthew Hamm Date Modified Modified By Date Added 11/20/2009 9:56 AM Notification NRC/LICENSEE Supervision Matthew Hamm Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 7 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1151 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 8 of 55 Licensee Response/NRC Response/NRC Question Closure Id 1191 NRC Question MEH-001 Number Select Licensee Response Application

Response

12/4/2009 11:35 AM Date/Time Closure Statement

Response

Statement The KPS Beyond Scope Change 2 is not requesting 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore one of two inoperable AFW trains when performing SR 3.7.5.1. KPS is requesting to not consider the turbine driven AFW train inoperable when performing SR 3.7.5.1 on a motor driven AFW train, provided only one of the AFW header cross-tie valves is closed.

The requested change is described in ITS 3.7.5, DOC L05. CTS 3.4.b.1.B requires the turbine driven AFW train to be capable of delivering flow to both steam generators. When the quarterly pump test of CTS 4.8.a is performed on the motor driven AFW pumps, one of the AFW header cross-tie valves is closed so that the motor driven AFW pump being tested will only pump to one of the SGs. When either of these valves is closed to perform this testing, KPS declares the turbine driven AFW train inoperable since the turbine driven AFW train cannot automatically provide flow to both SGs. In addition, during this test the motor driven AFW pump is also inoperable. Thus, two AFW trains are inoperable when either of the motor driven AFW pumps is being tested as required by CTS 4.8.a. This requires entry into CTS 3.4.b.4.B, which allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore one of the two inoperable trains to OPERABLE status. The ITS does not provide any restoration time when two AFW trains are inoperable. ITS 3.7.5 ACTION C requires a shutdown to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . Thus, under normal conditions, KPS will enter ITS 3.7.5 ACTION C when two AFW trains are inoperable. However, ITS SR 3.7.5.1, which requires verification that each manual, power operated, and automatic valve in each water flow path that is not locked sealed, or otherwise secured in position, is in the correct position, has been modified by Note 2. This Note states that one AFW header cross-tie valve is allowed to be closed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during testing of the motor driven AFW pump and the turbine driven AFW train may be considered OPERABLE, provided the cross-tie valve is capable of being remotely realigned. In the SR 3.7.5.1 configuration allowed by Note 2: 1) The AFW System is capable of performing its design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant pressure boundary (e.g. loss of normal feedwater transient) and accidents that require a faulted SG to be isolated (e.g. steam generator tube rupture and main steam line break); 2)

The turbine driven AFW pump is OPERABLE with redundant steam supplies from each of two main steam lines upstream of the MSIVs, and is capable of supplying AFW to both steam generators. The capability to supply AFW to Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 8 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1191 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 9 of 55 both SGs relies on the capability to remotely re-align a cross tie valve as stated in Note 2 to ITS SR 3.7.5.1; and 3) The piping, valves, instrumentation, and controls in the required flow paths are OPERABLE.

This changes the CTS by allowing the turbine driven AFW train to be considered OPERABLE during motor driven AFW pump testing when an AFW header cross-tie valve is closed (i.e., not in its normal open position). The justification for considering the turbine driven AFW train OPERABLE under this testing condition is also provided in DOC L05. The KPS safety analyses have the AFW header cross-tie valves in two different positions following an accident, depending upon the accident. For the loss of normal feedwater flow event, the AFW header cross-tie valves are open so the turbine driven AFW train can provide flow to both SGs. The analysis is run with flow to both SGs, however the analysis would be acceptable with two pumps and one SG for cooling. The analysis requires flow from two AFW Pumps in 60 seconds after AFW actuation signal. When using the Note allowance in SR 3.7.5.1 to perform the ASME testing of a motor driven AFW pump, the remaining motor driven AFW pump and the turbine driven AFW pump will still be able to provide flow automatically to one of the SGs.

Furthermore, once the closed cross-tie valve is manually opened, flow from all three AFW pumps would be available and flow to both SGs would be maintained. For the SG tube rupture event, the ruptured SG is required to be isolated, which requires one of the cross-tie valves to be closed.

Closing the valve is assumed to be performed manually by the operator -

no automatic closure function is provided for the valves. In addition, following a MSLB, AFW flow is assumed to be isolated by the operators, by tripping the pumps or isolating the flow path (potentially using these valves). Thus, one of the analyses has the valves open while the other analyses require at least one of the valves closed. Therefore based on the above discussion, because the two AFW header cross-tie valves (either AFW-10A or AFW-10B) are capable of being remotely re-aligned, the turbine driven AFW train is capable of supplying AFW to both steam generators and is considered OPERABLE. Because two AFW trains are OPERABLE during the performance of SR 3.7.5.1, it is not necessary to perform analyses justifying the plant can withstand its design basis accidents with two AFW trains inoperable. The safety analyses of the KPS design basis accidents are performed consistent with the ITS requirement that we have three OPERABLE AFW trains at rated power, 1772 MWth.

In addition, License Amendment 120 added the turbine driven AFW train requirements to the KPS Technical Specifications. In the KPS submittal, the following statements were made:

"The cross-connect valves (AFW-10A and AFW-10B) are normally maintained in the open position. This provides an added degree of redundancy above what is required for all accidents except for a MSLB.

During a MSLB, one of the cross-connect valves will have to be repositioned regardless if the valves are normally open or closed.

Therefore, the position of the cross-connect valves does not affect the operability of the turbine-driven AFW train. However, operability of the train is dependent on the ability of the valves to reposition."

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 9 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1191 06/07/2010

Kewaunee ITS Conversion Database Page 3 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 10 of 55 KPS believes that adopting the ISTS requirement that no time should be allowed when two AFW trains are inoperable is acceptable. ITS SR 3.7.5.1 Note 2 considers the turbine driven AFW train in an abnormal alignment during motor driven AFW Pump ASME testing (i.e., during performance of ITS SR 3.7.5.2), but KPS does not consider the TD AFW train inoperable during this ASME testing. The KPS analysis for the loss of normal feedwater flow event is acceptable with two AFW pumps supplying one SG.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months testing allowance in ITS SR 3.7.5.1 Note 2 is essentially the same as that already allowed by the NRC in the KPS CTS (i.e. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in CTS 3.4.b.4.B).

A simplified flow diagram of the AFW System is provided as an attachment to this response.

As an aside, the license basis analysis quoted in the NRC reviewer's question has been superseded in the latest revision of the USAR.

Question Closure Date Attachment MEH-001 Information.pdf (480KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Melissa Krcma Ray Schiele Added By Robert Hanley Date Added 12/4/2009 11:33 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 10 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1191 06/07/2010

Enclosure, Q&A to Attachemnt 1, Volume 12 (Section 3.7) Page 11 of 55 Enclosure, Q&A to Attachemnt 1, Volume 12 (Section 3.7) Page 11 of 55

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 12 of 55 Licensee Response/NRC Response/NRC Question Closure Id 1941 NRC Question MEH-001 Number Select NRC Response Application

Response

1/27/2010 6:00 PM Date/Time Closure Statement Response After reviewing the drawing, some minor questions came up.

Statement In the ITS submittal Attachment 1, Volume 12, Rev ), Page 112 or 415, the licensee states that during testing the TDAFW pump will only be able to deliver flow to one SG, it is isolated from the SG to which the MDAFW pump is being tested.

The licensee design basis for loss of normal feed accident states an assumption that "AFW flow is available 1 minute after reactor trip and is distributed equally to two steam generators." Depending on which crosstie valve is closed during pump test will determine which SG is fed by the TDAFW pump.

1) Provide justification for closing the cross tie valve to the SG that is being tested verses closing the opposite cross tie valve, allowing a line up where each of the two remaining operable pumps can deliver flow to the two different SGs automatically without operator action; thus meeting the assumption in the LONF accident. A more conservative approach would be to be in alignment were the two operable pumps are lined up to individual SGs.

Additionally:

2) Does the cross tie valves (AFW-10A and B) get an automatic signal to open on start of the TDAFW pump?

3) Can the cross tie valves (AFW-10A and B) be manually opened?

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Added By Matthew Hamm Date Added 1/27/2010 1:50 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 12 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1941 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 13 of 55 Licensee Response/NRC Response/NRC Question Closure Id 2081 NRC Question MEH-001 Number Select Licensee Response Application

Response

2/9/2010 7:10 AM Date/Time Closure Statement

Response

Statement KPS has reviewed the follow-up NRC reviewer questions and the following responses are provided:

NRC Follow-up Question 1 Provide justification for closing the cross tie valve to the SG that is being tested verses closing the opposite cross tie valve, allowing a line up where each of the two remaining operable pumps can deliver flow to the two different SGs automatically without operator action; thus meeting the assumption in the LONF accident. A more conservative approach would be to be in alignment were the two operable pumps are lined up to individual SGs.

KPS Response Each AFW pump Surveillance test procedure incorporates both SR 3.7.5.2 (Verify the developed head of each AFW Pump) and ITS 5.5.6 (Inservice Testing Program) sections. Present procedural guidance during motor-driven (MD) AFW pump testing closes and opens both AFW-10A and AFW-10B during each (A and B) MDAFW pump test. Both valves are cycled during each test to prevent possible issues with valve preconditioning associated with the Inservice Testing Program.

When the A MDAFW pump test is performed, AFW-10B is closed for the flow test. AFW-10B is closed to establish backpressure on AFW-1C, the turbine-driven (TD) AFW pump discharge check valve, to verify AFW-1C is seating properly to meet Inservice Valve Testing Program requirements.

When the B MDAFW Pump flow test is performed, AFW-10B is closed for the flow test. AFW-10B is closed be minimize the challenge to AFW-1C, as the check valve seating test is performed during the A MDAFW Pump test, as previously described.

In all test configurations, two AFW pumps (TDAFW pump and the non-test MDAFW pump) are available to automatically deliver AFW flow to either one SG OR two SGs, at any given time. Two AFW pumps delivering flow to one SG meets the LONF analysis requirements since the AFW flow from two Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 13 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2081 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 14 of 55 pumps is significantly greater than the AFW flow assumed in the LONF analysis. The AFW flow from two AFW pumps is more than adequate to remove core decay heat and mitigate the LONF event. The LONF analysis was performed assuming one AFW pump delivering flow to two SGs. The configuration of AFW delivery to two SGs is consistent with the normal AFW System configuration at power. Fluid System Analysis (Calculation C11783) Auxiliary Feedwater System supports two AFW pumps are capable of supplying enough flow to one SG to provide decay heat removal to meet the LONF accident analysis.

NRC Follow-up Question 2 Do the cross tie valves (AFW-10A and B) get an automatic signal to open on start of the TDAFW pump?

KPS Response AFW-10A and AFW-10B do not receive any automatic open (or close) signal. The final position of the valve following an accident is dependent upon the accident. For example, following a steam generator tube rupture or fault, plant procedures require the cross tie valve associated with the affected SG to be manually closed.

NRC Follow-up Question 3 Can the cross tie valves (AFW-10A and B) be manually opened?

KPS Response Yes. AFW-10A and AFW-10B can be manually opened using valve control switches in the Control Room and locally at the valve motor operator using the handwheel. Also, AFW-10A can be opened from the Dedicated Shutdown Panel (using a control switch). AFW-10A and AFW-10B are DC powered, motor-operated valves.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 2/9/2010 7:14 AM Modified By Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 14 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2081 06/07/2010

Kewaunee ITS Conversion Database Page 3 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 15 of 55 Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 15 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2081 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 16 of 55 Licensee Response/NRC Response/NRC Question Closure Id 2661 NRC Question MEH-001 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 3/25/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Matthew Hamm Added By Matthew Hamm Date Added 3/25/2010 2:45 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 16 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2661 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 17 of 55 ITS NRC Questions Id 1741 NRC Question MEH-003 Number Category Technical ITS Section 3.7 ITS Number 3.7.12 DOC Number JFD Number 4 JFD Bases Number Page ITS 3.7.12-2 (276 of Vol 12)

Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC The proposed adoption of ITS SR 3.7.12.4 reads "Verify one ASV train can Question maintain a measurable vacuum with coincident isolation of the normal vent ducts." JFD 4 on page 277 of Attachment 1, Volume 12 states " ITS SR 3.7.12.4 has been changed to reflect the current licensing bases for verification that the ASV train can maintain a measurable vacuum with coincident isolation of the normal vent duct. This change is acceptable because the SR is revised to reflect the current plant licensing bases."

The term measurable is undefined and not quantified. It appears the word measurable should be quantified. What constitutes a "measurable" vacuum? What constitutes a failed SR 3.7.12.4?

Attach File 1 Attach File 2 Issue Date 2/23/2010 Added By Matthew Hamm Date Modified Modified By Date Added 2/23/2010 1:24 PM Notification NRC/LICENSEE Supervision Matthew Hamm Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 17 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1741 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 18 of 55 Licensee Response/NRC Response/NRC Question Closure Id 2461 NRC Question MEH-003 Number Select Licensee Response Application

Response

3/8/2010 10:25 AM Date/Time Closure Statement

Response

Statement This Surveillance Requirement was the as-issued requirement when KPS received their Technical Specifications with the Operating License. During the NRC and KPS discussions concerning this requirement prior to issuance of the Operating License, the Surveillance originally required a 1/4 inch of water vacuum limit. This limit was submitted by KPS in Amendment 8, dated 2/25/71 (this was an amendment to the draft Technical Specifications). During further discussions, KPS stated to the NRC in Amendment 14, dated 1/4/72 that : "The leakage specification for the Zone SV stipulates there be no exfiltration of air from the Zone SV boundary with only one of the redundant trains of the Auxiliary Building Special Ventilation System in operation. Initial acceptance tests will demonstrate the integrity of the Zone SV Perimeter, as well as the capacity of the Ventilation System. Because of the steep head-versus-capacity curve for the system fans, the flow is relatively unaffected by the vacuum attained, therefore vacuum has little significance in demonstrating the functional performance of Zone SV and the associated Auxiliary Building Special Ventilation System." Based on this information, the surveillance requirement was then changed in Amendment 26, dated 2/5/73, to require only a measurable vacuum. This final version was issued with the KPS Technical Specifications when the Operating License was issued.

CTS 4.4.d.3 is currently ensured by the performance of procedures SP 117A and B. Step 4.7 of the procedure states that measurable vacuum is demonstrated by verifying that the 606' elevation inside the Auxiliary Building readings are less than the outside readings. Step 8.2 of the procedure, which provides acceptance criteria, states that a measurable vacuum shall be demonstrated throughout the Auxiliary Building relative to normal ventilation conditions as indicated on Data Sheet 1 (Run #1 greater than Run #2 for corresponding Points A through G) The instrumentation used to take the readings is in inches of water and reads to the nearest hundredths. Therefore, a measurable vacuum requires the reading to be at least 0.01 inches water vacuum between the before and after readings at the various locations in the Auxiliary Building. The instrumentation used to take the readings is in inches of water and reads to the nearest hundredths.

Step 8.3 acceptance criteria states that a measurable vacuum exists at the 606' elevation of the Auxiliary Building relative to the outside environment Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 18 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2461 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 19 of 55 as indicated on Data Sheet 1 (Point 1 greater than Point A, Point 2 greater than Point G). Therefore, a measurable vacuum requires the reading to be at least 0.01 inches water vacuum between the two locations (inside versus outside).

KPS believes that using the term "measurable" in the Surveillance Requirement is consistent with the current acceptance criteria for the Technical Specifications and the design basis of the plant, and is adequately controlled in the plant procedures implementing this Surveillance.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Robert Hanley Jerry Jones Bryan Kays Added By David Mielke Date Added 3/8/2010 10:13 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 19 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2461 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 20 of 55 Licensee Response/NRC Response/NRC Question Closure Id 2731 NRC Question MEH-003 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 4/9/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Matthew Hamm Date Added 4/9/2010 1:44 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 20 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2731 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 21 of 55 ITS NRC Questions Id 1771 NRC Question MEH-004 Number Category Technical ITS Section 3.7 ITS Number 3.7.14 DOC Number JFD Number 4 JFD Bases Number Page 311-313 of att 1, v 12 Number(s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Proposed ITS LCO 3.7.14 would read "The spent fuel pool boron Question concentration shall be greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration"". The STS equivalent LCO, LCO 3.7.16 contains brackets around a plant specific number for boron concentration. The proposed ITS LCO would replace the number with a reference. This is a beyond scope issue since the proposed change is not in the existing TS, or the STS.

JFD 4 on page 313 of Attachment 1, Volume 12 states that ITS LCO 3.9.1 is referenced in the ITS LCO 3.7.14 statement, but does not provide specific detail as to how the proposed ITS LCO 3.7.14 will ensure that postulated criticality related accidents will be prevented or mitigated. Provide a more detailed justification for the proposed change, which does not adopt STS.

Attach File 1 Attach File 2 Issue Date 2/24/2010 Added By Matthew Hamm Date Modified Modified By Date Added 2/24/2010 3:18 PM Notification NRC/LICENSEE Supervision Matthew Hamm Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 21 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1771 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 22 of 55 Licensee Response/NRC Response/NRC Question Closure Id 2381 NRC Question MEH-004 Number Select Licensee Response Application

Response

3/2/2010 11:05 AM Date/Time Closure Statement Response As stated in the JFD, CTS 5.4.a.3, which is the requirement in the CTS that Statement is equivalent to ITS LCO 3.7.14, requires the spent fuel pool boron concentration to match that used in the reactor refueling cavity and refueling canal. While this is not in Section 3 of the CTS, it is still a Technical Specification requirement. Thus, this spent fuel pool boron concentration requirement is in the CTS and it is not a beyond scope change.

CTS 5.4.a.3 states that the spent fuel pool boron concentration must be the same as in the reactor refueling cavity and refueling canal. CTS 3.8.a.5 (Volume 14, Page 5 of 175) specifies the boron limit of the RCS during refueling, which includes the reactor refueling cavity and refueling canal.

CTS 3.8.a.5 further specifies that the boron limit is as specified in the COLR. This allowance is maintained in ITS 3.9.1 (i.e., the actual ppm limit is specified in the COLR, not in LCO 3.9.1). Furthermore, having the actual boron value in the COLR is identical to the ISTS 3.9.1 requirements. Thus, specifying the location of the boron limit for ITS 3.7.14 is consistent with not only CTS 5.4.a.3 (which references CTS 3.8.a.3), but also with the manner in which the limit is specified in ISTS LCO 3.9.1. Postulated criticality related accidents while in the Applicability of ITS 3.7.14 are prevented in the same manner in which they are prevented when in the Applicability of ISTS 3.9.1. The COLR will specify the actual boron concentration necessary. The Applicable Safety Analyses section of ITS Bases 3.7.14 clearly describes the accident analysis for the spent fuel storage pool, and this analysis is also referenced in the USAR. The actual boron concentration value is currently controlled in the COLR, and it is the KPS position that this is an acceptable method of controlling boron concentration. This method (i.e., controlling the value in the COLR) has already been found to be acceptable by the NRC for ITS 3.9.1, which is the LCO that ensures the proper keff is maintained during refueling to preclude inadvertent criticality.

Question Closure Date Attachment 1

Attachment Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 22 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2381 06/25/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 23 of 55 2

Notification NRC/LICENSEE Supervision Matthew Hamm Robert Hanley Jerry Jones Bryan Kays Added By David Mielke Date Added 3/2/2010 11:09 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 23 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2381 06/25/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 24 of 55 Licensee Response/NRC Response/NRC Question Closure Id 3151 NRC Question MEH-004 Number Select Licensee Response Application

Response

5/24/2010 3:15 PM Date/Time Closure Statement Response This response supplements the previous KPS response. During the Statement weekly informal discussion with the NRC reviewers, the NRC continued to express concern over the ITS 3.7.14 limit being referenced back to another LCO, in lieu of it being directly stated in the LCO itself. KPS has reviewed this concern and believes that the LCO would be more user friendly by stating that the limit is in the COLR, in lieu of the current method of referencing LCO 3.9.1, which then references the COLR. 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 MEH-004 Markup.pdf (797KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 5/24/2010 3:16 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 24 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3151 06/25/2010

Attachment 1, Volume 12, Rev. 0, Page 307 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 25 of 55 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL BORON CONCENTRATION ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev.

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

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

A02 CTS 5.4.a.3 states, in part, that the spent fuel pool is filled with water at a boron concentration to match that used in the reactor refueling cavity and refueling within canal. ITS LCO 3.7.14 states the spent fuel pool boron concentration shall be the COLR.

greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration."

This changes the CTS by specifying the actual LCO that contains the boron concentration value of the spent fuel pool water. location (i.e., COLR)

Therefore, the limit for the spent fuel pool is The purpose of CTS 5.4.a.3 is to ensure adequate dissolved boron is in the spent currently specified in the fuel pool water to maintain the required subcriticality margin. CTS 3.8.a.5, in COLR, and the ITS part, requires boron concentration of the RCS to be as specified in the COLR maintains the limit in the COLR. while loading or unloading fuel from the reactor. Thus, during these evolutions, the refueling cavity and canal must be at the same limit. ITS LCO 3.9.1 is the LCO that covers the CTS 3.8.1.5 requirements. This change is acceptable and is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 5.4.a.3 states the spent fuel pool is filled with water at a boron concentration to match that used in the reactor refueling cavity and refueling canal during REFUELING OPERATIONS or whenever there is fuel in the pool. CTS Section 1.0 defines REFUELING OPERATIONS as the movement of reactor vessel internals that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. ITS 3.7.14 is applicable when fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool. This changes the CTS by deleting the requirement that the boron concentration of the spent fuel pool water be within limit during REFUELING OPERATIONS.

This change is acceptable because the technical requirements have not changed. As defined in CTS Section 1.0, REFUELING OPERATIONS is movement of reactor vessel internal components that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. In order for REFUELING OPERATIONS to occur, the reactor head must be removed and the refueling cavity is flooded with water to the level of the water in the transfer canal in preparation for removal of fuel assemblies from the reactor core. The CTS Specification applies to those times when the water of the refueling cavity and refueling canal is mixed with the water in the spent fuel pool during the movement of fuel assemblies from the reactor core to the spent fuel pool. The ITS requirement is for the spent fuel pool boron concentration to be within the limit whenever there is spent fuel in the pool regardless of whether or Kewaunee Power Station Page 1 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 25 of 55 Attachment 1, Volume 12, Rev. 0, Page 307 of 415

Attachment 1, Volume 12, Rev. 0, Page 311 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 26 of 55 CTS [Fuel Storage Pool Boron Concentration]

All changes are 1 2 Spent 3.7.16 3 unless otherwise noted 14 3.7 PLANT SYSTEMS Spent 3.7.16 [ Fuel Storage Pool Boron Concentration ] 3 2 14 spent 5.4.a.3 LCO 3.7.16 The fuel storage pool boron concentration shall be [2300] ppm. 3 2 4 within greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration."

the COLR. spent spent 5.4.a.3 APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.

spent ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Spent DOC M01 A. Fuel storage pool boron --------------------NOTE-------------------

concentration not within LCO 3.0.3 is not applicable.

limit. ------------------------------------------------

A.1 Suspend movement of fuel Immediately assemblies in the fuel storage pool.

spent AND A.2.1 Initiate action to restore fuel Immediately storage pool boron concentration to within limit.

OR A.2.2 Initiate action to perform a Immediately fuel storage pool spent verification.

WOG STS 3.7.16-1 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 26 of 55 Attachment 1, Volume 12, Rev. 0, Page 311 of 415

Attachment 1, Volume 12, Rev. 0, Page 313 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 27 of 55 JUSTIFICATION FOR DEVIATIONS ITS 3.7.14, SPENT FUEL POOL BORON CONCENTRATION

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 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. ISTS 3.7.16 has been renumbered to ITS 3.7.14 since ISTS 3.7.13 and ISTS 3.7.14 have not been included in the Kewaunee Power Station (KPS) ITS.

4. CTS 5.4.a.3 requires the spent fuel pool boron concentration to match that used CTS 3.8.a.5 in the reactor refueling cavity and refueling canal. ITS LCO 3.9.1 provides the refueling cavity and refueling canal limit. CTS 3.8.a.5 and ITS LCO 3.9.1 do not and references the COLR as the state a specific value; they reference the COLR. Therefore, in lieu of providing a location of the specific boron concentration in ITS LCO 3.7.14, the LCO requires the limit to be limit; a specific as specified in LCO 3.9.1. This is consistent with the CTS requirements.

value (i.e., in ppm) is not provided. within the limit in the COLR.

Kewaunee Power Station Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 27 of 55 Attachment 1, Volume 12, Rev. 0, Page 313 of 415

Attachment 1, Volume 12, Rev. 0, Page 317 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 28 of 55 For Information Only; No changes to this page 1

[Fuel Storage Pool Boron Concentration] 2 All changes are B 3.7.16 6 unless otherwise noted Spent 14 BASES APPLICABLE Most accident conditions do not result in an increase in the activity of SAFETY either of the two regions. Examples of these accident conditions are the ANALYSES loss of cooling (reactivity increase with decreasing water density) and the areas (the north and dropping of a fuel assembly on the top of the rack. However, accidents south pool racks and the can be postulated that could increase the reactivity. This increase in canal pool racks) reactivity is unacceptable with unborated water in the storage pool. Thus, areas for these accident occurrences, the presence of soluble boron in the storage pool prevents criticality in both regions. The postulated accidents are basically of two types. A fuel assembly could be incorrectly loaded in the canal pool racks transferred from [Region 1 to Region 2] (e.g., an unirradiated fuel assembly or an insufficiently depleted fuel assembly). The second type of postulated accidents is associated with a fuel assembly which is dropped adjacent to the fully loaded [Region 2] storage rack. This could have a small positive reactivity effect on [Region 2]. However, the negative reactivity effect of the soluble boron compensates for the increased reactivity caused by either one of the two postulated accident scenarios. 3 Holtec Report 2 3 No. HI-992208 The accident analyses is provided in the FSAR, Section [15.7.4] (Ref. 4).

are 5 INSERT 2 The concentration of dissolved boron in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). spent INSERT 3 2 LCO spent The fuel storage pool boron concentration is required to be [2300] ppm.

The specified concentration of dissolved boron in the fuel storage pool preserves the assumptions used in the analyses of the potential critical 3 3

accident scenarios as described in Reference 4. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the fuel storage pool.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel storage pool, until a complete spent fuel storage pool verification has been performed following the last movement of fuel assemblies in the spent fuel storage pool. This LCO does not apply following the verification, since the verification would confirm that there are no misloaded fuel assemblies. With no further fuel assembly movements in progress, there is no potential for a misloaded fuel assembly or a dropped fuel assembly.

ACTIONS A.1, A.2.1, and A.2.2 The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply.

WOG STS B 3.7.16-2 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 28 of 55 Attachment 1, Volume 12, Rev. 0, Page 317 of 415

Attachment 1, Volume 12, Rev. 0, Page 318 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 29 of 55 B 3.7.14 1

INSERT 2 This report assumes a minimum of 240 ppm of boron is sufficient to ensure criticality does not occur during the worst case fuel loading accident in the spent fuel pool racks.

However, since the fuel pool is connected to the refueling cavity during refueling operations, the spent fuel pool boron concentration is maintained at the same concentration as the refueling cavity to preclude dilution of the refueling cavity. This boron concentration value is greater than the concentration required by Ref. 3.

2 INSERT 3 within the COLR greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration."

Insert Page B 3.7.16-2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 29 of 55 Attachment 1, Volume 12, Rev. 0, Page 318 of 415

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 30 of 55 Licensee Response/NRC Response/NRC Question Closure Id 3291 NRC Question MEH-004 Number Select NRC Response Application

Response

5/26/2010 6:00 PM Date/Time Closure Statement Response According to GL 88-16 in order for a value to be transferred to the COLR it Statement must be a cycle-specific value that is determined with an NRC approved methodology. The SFP soluble boron limit is neither. The soluble boron limit does not change based on the particulars of a given cycle. There is no NRC approved methodology for calculation the soluble boron limit; therefore, the staff believes it is inappropriate to transfer the SFP soluble boron limit value to the COLR. Please revise the proposed TS 3.7.14 LCO statement to include a minimum number.

Question Closure Date Attachment 1

Attachment 2

Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Matthew Hamm Robert Hanley Added By Matthew Hamm Date Added 5/26/2010 4:54 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 30 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3291 06/25/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 31 of 55 Licensee Response/NRC Response/NRC Question Closure Id 3441 NRC Question MEH-004 Number Select Licensee Response Application

Response

6/7/2010 1:20 AM Date/Time Closure Statement

Response

Statement In the NRC reviewer's comment to KPS third response, the NRC reviewer has stated that the spent fuel pool boron value cannot be placed in the COLR, since it is not covered by the Generic Letter 88-16 allowances (i.e., it is not cycle specific). However, the limit is already in the COLR; KPS is not requesting permission to move it to the COLR. CTS 5.4.a.3, which is the requirement in the CTS that covers requirements similar to ITS LCO 3.7.14, requires the spent fuel pool boron concentration to match that used in the reactor refueling cavity and refueling canal. No value is provided in CTS 5.4.a.3 other than to match that in the reactor cavity and refueling canal.

CTS 3.8.a.5 (Volume 14, Page 5 of 175) specifies the boron limit of the RCS during refueling, which includes the reactor refueling cavity and refueling canal. CTS 3.8.a.5 further specifies that the boron limit is as specified in the COLR. Thus, CTS 5.4.a.3 limit is already in the COLR, and CTS 5.4.a.3 is only stating to match the limit for CTS 3.8.a.5. In the original submittal, KPS maintained our current licensing basis by only referencing LCO 3.9.1 as the location of the limit, consistent with CTS 5.4.a.3. The previous KPS response attempted to alleviate the chained reference by referencing the COLR directly in LCO 3.7.14. This change was provided as an attachment to our previous response.

KPS has had further phone conversations with the NRC concerning this issue. It was agreed upon that CTS 5.4.a.3 is actually covering two separate conditions. The first condition is when the spent fuel pool is connected to the RCS during refueling operations and the second condition is when the spent fuel pool is not connected to the RCS. ISTS LCO 3.7.14 is written to cover the second condition. As stated in the ISTS Bases, the spent fuel pool boron concentration limits ensures subcriticality is maintained in the pool during two events; a dropped fuel assembly and a misplaced fuel assembly. For KPS, the limiting boron concentration limit for these two events is 240 ppm, as described in the KPS spent fuel pool criticality analyses. 240 ppm is the boron concentration limit during a misplaced bundle event and zero ppm is the boron concentration limit during a dropped fuel assembly event. These values were reviewed and concurred with by the NRC as documented in the NRC Safety Evaluation for License Amendment 150, dated 1/23/01 (ADAMS Accession No. ML010240051). This safety evaluation concerned the re-racking of the KPS spent fuel storage pool. Therefore, ITS LCO 3.7.14 will be modified to Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 31 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3441 06/25/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 32 of 55 require the spent fuel pool boron concentration limit to be > 240 ppm.

Furthermore, the spent fuel pool boron limit when the pool is connected to the RCS (i.e., during refueling operations) will be controlled by ITS 3.9.1.

ITS LCO 3.9.1 will continue to require the boron concentration to be within the limit specified in the COLR. A draft markup regarding this change is attached. This draft markup supersedes the previous draft markup provided in the last KPS response. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment MEH-004 Markup, Rev. 1.pdf (1MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Matthew Hamm Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 6/7/2010 1:21 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 32 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3441 06/25/2010

Attachment 1, Volume 12, Rev. 0, Page 305 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 33 of 55 ITS A01 ITS 3.7.14 5.4 FUEL STORAGE APPLICABILITY Applies to the capacity and storage arrays of new and spent fuel.

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

SPECIFICATION

a. Criticality

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

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

b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties See ITS 4.0

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

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

b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties See ITS 3.9.1

c. keff < 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties A02 L02 LCO 3.7.14

3. The spent fuel pool is filled with borated water at a concentration to match that used in the reactor REFUELING cavity and REFUELING canal during REFUELING A03 OPERATIONS or whenever there is fuel in the pool.

Applicability L01

b. Capacity See ITS The spent fuel storage pool is designed with a storage capacity of 1205 assemblies and 4.0 shall be limited to no more than 1205 fuel assemblies.

c. Canal Rack Storage Fuel assemblies stored in the canal racks shall meet the minimum required fuel See ITS 3.7.15 assembly burnup as a function of nominal initial enrichment as shown in Figure TS 5.4-1. These assemblies shall also have been discharged prior to or during the 1984 REFUELING outage.

Add proposed ACTION A M01 Amendment No. 162 TS 5.4-1 09/19/2002 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 33 of 55 Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 305 of 415

Attachment 1, Volume 12, Rev. 0, Page 307 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 34 of 55 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL BORON CONCENTRATION ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev.

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

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

A02 CTS 5.4.a.3 states, in part, that the spent fuel pool is filled with water at a boron concentration to match that used in the reactor refueling cavity and refueling canal. ITS LCO 3.7.14 states the spent fuel pool boron concentration shall be greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration."

This changes the CTS by specifying the actual LCO that contains the boron concentration value of the spent fuel pool water.

The purpose of CTS 5.4.a.3 is to ensure adequate dissolved boron is in the spent fuel pool water to maintain the required subcriticality margin. CTS 3.8.a.5, in part, requires boron concentration of the RCS to be as specified in the COLR while loading or unloading fuel from the reactor. Thus, during these evolutions, the refueling cavity and canal must be at the same limit. ITS LCO 3.9.1 is the LCO that covers the CTS 3.8.1.5 requirements. This change is acceptable and is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 5.4.a.3 states the spent fuel pool is filled with water at a boron concentration to match that used in the reactor refueling cavity and refueling canal during REFUELING OPERATIONS or whenever there is fuel in the pool. CTS Section 1.0 defines REFUELING OPERATIONS as the movement of reactor vessel internals that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. ITS 3.7.14 is applicable when fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool. This changes the CTS by deleting the requirement that the boron concentration of the spent fuel pool water be within limit during REFUELING OPERATIONS.

This change is acceptable because the technical requirements have not changed. As defined in CTS Section 1.0, REFUELING OPERATIONS is movement of reactor vessel internal components that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. In order for REFUELING OPERATIONS to occur, the reactor head must be removed and the refueling cavity is flooded with water to the level of the water in the transfer canal in preparation for removal of fuel assemblies from the reactor core. The CTS Specification applies to those times when the water of the refueling cavity and refueling canal is mixed with the water in the spent fuel pool during the movement of fuel assemblies from the reactor core to the spent fuel pool. The ITS requirement is for the spent fuel pool boron concentration to be within the limit whenever there is spent fuel in the pool regardless of whether or Kewaunee Power Station Page 1 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 34 of 55 Attachment 1, Volume 12, Rev. 0, Page 307 of 415

Attachment 1, Volume 12, Rev. 0, Page 308 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 35 of 55 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL BORON CONCENTRATION not REFUELING OPERATIONS are occurring. By requiring the spent fuel pool boron concentration to be within the limit when fuel assemblies are stored in the spent fuel pool, the spent fuel pool water boron concentration will be essentially the same as the water added to flood the reactor refueling cavity. Therefore, when the two volumes of water mix in preparation for removal of fuel assemblies from the reactor cavity, the boron concentration of each will be the same. The boron concentration limit ensures adequate dissolved boron is in the spent fuel pool water to maintain the required subcriticality margin in order to meet the assumptions of the fuel handling accident analyses. This change is acceptable and is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 5.4.a.3 does not provide any ACTIONS to take when the spent fuel pool boron concentration is not within limit. When the spent fuel pool boron concentration is not within limit, ITS 3.7.14 ACTION A requires the immediate suspension of movement of fuel assemblies in the spent fuel pool; immediate action to restore the spent fuel pool boron concentration to within limit; and, immediate action to perform a spent fuel pool verification. This changes the CTS by providing specific ACTIONS when the spent fuel pool boron concentration is not within limit.

The purpose of CTS 5.4.a.3 is to ensure adequate dissolved boron is in the spent fuel pool water to maintain the required subcriticality margin. ITS 3.7.14 ACTION A effectively places the unit outside of the Applicability by requiring the plant to immediately suspend any operations that would further decrease the spent fuel pool subcriticality margin and to initiate actions to restore the boron concentration to within limits. The proposed Required Actions reflect the importance of maintaining the spent fuel pool boron concentration. This change is designated more restrictive because a new proposed ACTION has been added.

M02 CTS Table TS 4.1-2 Sampling Test 6 requires verification of the boron concentration of the spent fuel pool once a month. ITS SR 3.7.14.1 requires verification that the spent fuel pool boron concentration is within limit every 7 days. This changes the CTS by requiring the verification of the spent fuel pool boron concentration every 7 days versus once per month.

The purpose of CTS Table TS 4.1-2 Sampling Test 6 is to ensure adequate dissolved boron is in the spent fuel pool water to maintain the required subcriticality margin. This change is acceptable because the 7 day sampling Frequency is more frequent than the current sampling requirement. This change is designated more restrictive because less time is allowed for performing a Surveillance Requirement than was allowed in the CTS.

RELOCATED SPECIFICATIONS None Kewaunee Power Station Page 2 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 35 of 55 Attachment 1, Volume 12, Rev. 0, Page 308 of 415

Attachment 1, Volume 12, Rev. 0, Page 309 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 36 of 55 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL BORON CONCENTRATION REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 5.4.a.3 is applicable, in part, when there is fuel in the pool. ITS 3.7.14 is applicable when fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool.

This changes the CTS by reducing the Applicability of the Spent Fuel Pool Boron Concentration Specification to only the time when fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool.

The purpose of CTS 5.4.a.3 is to ensure adequate dissolved boron is in the fuel storage pool water to maintain the required subcriticality margin. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When the fuel storage pool is unloaded or following performance of a spent fuel pool verification, there is no potential for criticality. Performing a spent fuel pool verification provides assurance that no fuel assemblies have been inadvertently misplaced in the spent fuel pool. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

Insert DOC L02 Kewaunee Power Station Page 3 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 36 of 55 Attachment 1, Volume 12, Rev. 0, Page 309 of 415

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 37 of 55 L02 (Category 1 - Relaxation of LCO Requirements) CTS 5.4.a.3 requires the spent fuel pool boron concentration to match that in the refueling cavity and refueling canal during refueling operations or whenever there is fuel in the pool. Currently, the refueling cavity and refueling canal boron limit is provided in the COLR. The current COLR limit is >

2500 ppm. ITS 3.7.14 requires the boron concentration of the spent fuel pool to be >

240 ppm when fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool. This changes the CTS by reducing the LCO limit from the value specified in the COLR for the RCS during refueling operations (currently > 2500 ppm) to

> 240 ppm. The change in the spent fuel pool boron concentration Applicability related to the pool itself (adding the spent fuel pool verification allowance) is discussed in DOC L01 and the Applicability related to "during REFUELING OPERATIONS" is covered in ITS 3.9.1.

The purpose of CTS 5.4.a.3 is to ensure adequate dissolved boron is in the fuel storage pool water to maintain the required subcriticality margin in the spent fuel pool during a dropped fuel assembly event and a misloaded fuel assembly event and to be consistent with the RCS boron concentration limit during refueling operations. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When the fuel storage pool is not connected to the RCS, the licensing basis analyses concluded no boron is needed to prevent a dropped fuel assembly criticality event and 240 ppm of boron is needed to prevent a misloaded fuel assembly criticality event. These values were reviewed and concurred with by the NRC in the Safety Evaluation dated January 23, 2001 (ADAMS Accession No. ML010240051). This safety evaluation concerned the re-racking of the KPS spent fuel storage pool. Note that the boron concentration limit for the spent fuel pool when the pool is connected to the RCS during refueling will be controlled by ITS 3.9.1, and will remain the same as currently required. This change is designated as less restrictive because the LCO limit in the ITS for when the spent fuel pool is not connected to the RCS is less than that required in the CTS.

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 37 of 55

Attachment 1, Volume 12, Rev. 0, Page 311 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 38 of 55 CTS [Fuel Storage Pool Boron Concentration]

All changes are 1 2 Spent 3.7.16 3 unless otherwise noted 14 3.7 PLANT SYSTEMS Spent 3.7.16 [ Fuel Storage Pool Boron Concentration ] stet 3 2 14 spent 5.4.a.3 LCO 3.7.16 The fuel storage pool boron concentration shall be [2300] ppm. 3 2 4 greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration."

240 spent spent 5.4.a.3 APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.

spent ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Spent DOC M01 A. Fuel storage pool boron --------------------NOTE-------------------

concentration not within LCO 3.0.3 is not applicable.

limit. ------------------------------------------------

A.1 Suspend movement of fuel Immediately assemblies in the fuel storage pool.

spent AND A.2.1 Initiate action to restore fuel Immediately storage pool boron concentration to within limit.

OR A.2.2 Initiate action to perform a Immediately fuel storage pool spent verification.

WOG STS 3.7.16-1 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 38 of 55 Attachment 1, Volume 12, Rev. 0, Page 311 of 415

Attachment 1, Volume 12, Rev. 0, Page 313 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 39 of 55 JUSTIFICATION FOR DEVIATIONS ITS 3.7.14, SPENT FUEL POOL BORON CONCENTRATION

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 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. ISTS 3.7.16 has been renumbered to ITS 3.7.14 since ISTS 3.7.13 and ISTS 3.7.14 have not been included in the Kewaunee Power Station (KPS) ITS.

4. CTS 5.4.a.3 requires the spent fuel pool boron concentration to match that used in the reactor refueling cavity and refueling canal. ITS LCO 3.9.1 provides the refueling cavity and refueling canal limit. CTS 3.8.a.5 and ITS LCO 3.9.1 do not state a specific value; they reference the COLR. Therefore, in lieu of providing a specific boron concentration in ITS LCO 3.7.14, the LCO requires the limit to be as specified in LCO 3.9.1. This is consistent with the CTS requirements.

When the fuel storage pool is not connected to the RCS during refueling, the licensing basis analyses concluded no boron is needed to prevent a dropped bundle criticality event and 240 ppm of boron is needed to prevent a misloaded bundle criticality event. These values were reviewed and concurred with by the NRC in the Safety Evaluation dated January 23, 2001 (ADAMS Accession No. ML010240051). This safety evaluation concerned the re-racking of the KPS spent fuel storage pool. Therefore, the more limiting of the values (240 ppm) has been included in the ITS LCO.

Kewaunee Power Station Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 39 of 55 Attachment 1, Volume 12, Rev. 0, Page 313 of 415

Attachment 1, Volume 12, Rev. 0, Page 317 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 40 of 55 1

[Fuel Storage Pool Boron Concentration] 2 All changes are B 3.7.16 6 unless otherwise noted Spent 14 BASES APPLICABLE Most accident conditions do not result in an increase in the activity of SAFETY either of the two regions. Examples of these accident conditions are the ANALYSES loss of cooling (reactivity increase with decreasing water density) and the areas (the north and dropping of a fuel assembly on the top of the rack. However, accidents south pool racks and the can be postulated that could increase the reactivity. This increase in canal pool racks) reactivity is unacceptable with unborated water in the storage pool. Thus, areas for these accident occurrences, the presence of soluble boron in the storage pool prevents criticality in both regions. The postulated accidents are basically of two types. A fuel assembly could be incorrectly loaded in the canal pool racks transferred from [Region 1 to Region 2] (e.g., an unirradiated fuel assembly or an insufficiently depleted fuel assembly). The second type of postulated accidents is associated with a fuel assembly which is dropped adjacent to the fully loaded [Region 2] storage rack. This could have a small positive reactivity effect on [Region 2]. However, the negative reactivity effect of the soluble boron compensates for the increased reactivity caused by either one of the two postulated accident scenarios. 3 Holtec Report 2 3 No. HI-992208 The accident analyses is provided in the FSAR, Section [15.7.4] (Ref. 4).

are 5 INSERT 2 The concentration of dissolved boron in the fuel storage pool satisfies 240 Criterion 2 of 10 CFR 50.36(c)(2)(ii). spent stet INSERT 3 2 LCO spent The fuel storage pool boron concentration is required to be [2300] ppm.

The specified concentration of dissolved boron in the fuel storage pool preserves the assumptions used in the analyses of the potential critical 3 3

accident scenarios as described in Reference 4. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the fuel storage pool.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel storage pool, until a complete spent fuel storage pool verification has been performed following the last movement of fuel assemblies in the spent fuel storage pool. This LCO does not apply following the verification, since the verification would confirm that there are no misloaded fuel assemblies. With no further fuel assembly movements in progress, there is no potential for a misloaded fuel assembly or a dropped fuel assembly.

ACTIONS A.1, A.2.1, and A.2.2 The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply.

WOG STS B 3.7.16-2 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 40 of 55 Attachment 1, Volume 12, Rev. 0, Page 317 of 415

Attachment 1, Volume 12, Rev. 0, Page 318 of 415 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 41 of 55 B 3.7.14 This report also concluded that no boron was necessary (i.e., a fuel assembly to ensure subcriticality during 1 INSERT 2 misloaded in the canal a dropped fuel assembly concluded pool racks) event in the spent fuel pool.

This report assumes a minimum of 240 ppm of boron is sufficient to ensure criticality does not occur during the worst case fuel loading accident in the spent fuel pool racks.

However, since the fuel pool is connected to the refueling cavity during refueling operations, the spent fuel pool boron concentration is maintained at the same concentration as the refueling cavity to preclude dilution of the refueling cavity. This boron concentration value is greater than the concentration required by Ref. 3.

2 INSERT 3 greater than or equal to the limit specified in LCO 3.9.1, "Boron Concentration."

Insert Page B 3.7.16-2 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 41 of 55 Attachment 1, Volume 12, Rev. 0, Page 318 of 415

ITS A01 ITS 3.9.1 See CTS TABLE TS 4.1-2 3.1.e See ITS MINIMUM FREQUENCIES FOR SAMPLING TESTS 3.4.16 SAMPLING TESTS TEST FREQUENCY (1)

1. Reactor Coolant a. Gross Radioactivity Determination (excluding tritium) 5/week Samples b. DOSE EQUIVALENT I-131 Concentration 1/14 days(2)

c. Tritium activity Monthly

d. Chemistry (Cl, F, O2)(3) 3/week(4 )

e. 1/6 months(5)

f. RCS isotopic analysis for Iodine Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in accordance with TS 3.1.c.2.C.

2. Reactor Coolant Boron(6) Boron Concentration(3) 2/week L01 See ITS SR 3.9.1.1 3.4.16 INSERT new CTS Markup Page 4 of 4 after this page , Volume 14, Rev. 0, Page 7 of 175 Attachment 1, Volume 14, Rev. 0, Page 7 of 175 (1)

Maximum time between tests is 3 days. See ITS (2) 3.4.16 Sample required only when in the OPERATING MODE.

(3) A02 See CTS See ITS Test required in all plant modes. 3.1.e 3.4.16 (4)

Maximum time between tests is 4 days.

(5)

Sample after a minimum of 2 EFPD and 20 days of OPERATING MODE operation have elapsed since the reactor was last subcritical for Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 42 of 55 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 42 of 55 t 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

(6)

A reactor coolant boron concentration sample does not have to be taken when the core is completely unloaded.

A02 Amendment No. 119 Page 1 of 2 04/18/95 Page 3 of 3

Enclosure, New CTSQ&A MarkuptoPage Attachment 4 of 4 1, Volume 12 (Section 3.7) Page 43 of 55 ITS A01 ITS 3.9.1 5.4 FUEL STORAGE APPLICABILITY Applies to the capacity and storage arrays of new and spent fuel.

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

SPECIFICATION

a. Criticality

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

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

b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties See ITS 4.0

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

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

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

c. keff < 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties LCO 3.9.1

3. The spent fuel pool is filled with borated water at a concentration to match that used in the reactor REFUELING cavity and REFUELING canal during REFUELING A03 OPERATIONS or whenever there is fuel in the pool.

Applicability See ITS 3.7.14

b. Capacity See ITS The spent fuel storage pool is designed with a storage capacity of 1205 assemblies and 4.0 shall be limited to no more than 1205 fuel assemblies.

c. Canal Rack Storage Fuel assemblies stored in the canal racks shall meet the minimum required fuel See ITS 3.7.15 assembly burnup as a function of nominal initial enrichment as shown in Figure TS 5.4-1. These assemblies shall also have been discharged prior to or during the 1984 REFUELING outage.

Add proposed ACTION A M03 Amendment No. 162 TS 5.4-1 09/19/2002 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 43 ofPage 55 4 of 4

Attachment 1, Volume 14, Rev. 0, Page 8 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 44 of 55 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev.

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

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

A02 CTS Table TS 4.1-2 Sample Test 2 footnote (3) states that the boron concentration test is required in all plant modes. CTS Table TS 4.1-2 Sample Test 2 footnote (6) states that a reactor coolant boron concentration sample does not have to be taken when the core is completely unloaded. ITS 3.9.1 is applicable in MODE 6. This changes the CTS by specifically stating that the Applicability is in MODE 6. In addition, ITS 3.1.1, "SHUTDOWN MARGIN (SDM)" discusses the remaining plant modes.

This change is acceptable because the Applicability has not changed. ITS 3.9.1 covers the MODE 6 requirements only. Other MODES are covered by ITS 3.1.1.

This change results in a format change only to comply with the ISTS presentation of the Applicability. Therefore, the change is acceptable because the boron concentration requirements have not changed. This change is designated as administrative since it does not result in any technical changes to the CTS.

INSERT DOC A03 MORE RESTRICTIVE CHANGES M01 CTS 3.8.a.5 is applicable during REFUELING OPERATIONS. CTS 3.8.a.5 also states, in part, that a minimum boron concentration shall be maintained when there is fuel in the reactor and during reactor vessel head removal or while loading and unloading fuel from the reactor. ITS 3.9.1 is applicable at all times while in MODE 6. This changes the CTS by requiring the boron concentration be maintained at all times while in MODE 6 and not just during those refueling activities/conditions contained within the CTS.

The purpose of CTS 3.8.a.5 is to ensure the boron concentration of the Reactor Coolant System (RCS) is sufficient to maintain the reactor subcritical during REFUELING OPERATIONS. As defined in CTS Section 1.0, REFUELING OPERATIONS is movement of reactor vessel internal components that could affect the reactivity of the core within the containment when the vessel head is unbolted or removed. CTS 3.8.a.5 also requires the boron concentration be maintained during reactor vessel head removal and when there is fuel in the reactor. ITS 3.9.1 requires the boron concentration of the RCS, fuel transfer canal, and refueling cavity be maintained at all times while in MODE 6, with the exception of the conditions listed in the Applicability NOTE. MODE 6 is defined as when one or more reactor vessel head closure bolts are less than fully tensioned. As a result, MODE 6 encompasses all the aforementioned CTS conditions and, in addition, those times when there is no movement of reactor internal components. This change is acceptable because the requirements Kewaunee Power Station Page 1 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 44 of 55 Attachment 1, Volume 14, Rev. 0, Page 8 of 175

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 45 of 55 A03 CTS 5.4.a.3, in part, requires the spent fuel pool boron concentration to match that used in the reactor refueling cavity and refueling canal during REFUELING OPERATIONS.

CTS 3.8.a.5 provides the boron concentration limit for the RCS during fuel movement, and states that the limit is specified in the COLR. ITS 3.9.1, in part, requires the boron concentration of the spent fuel pool to be within the limit specified in the COLR during MODE 6 operations (which encompass refueling operations), but a NOTE to the Applicability limits this requirement to only when the spent fuel pool is connected to the RCS. This changes the CTS by clearly stating when the spent fuel pool limit is to be maintained consistent with the RCS limit.

The purpose of CST 5.4.a.3, in part, is to ensure the spent fuel pool boron is within the limits required by the RCS during REFUELING OPERATIONS. Since REFUELING OPERATIONS can only be achieved when the spent fuel pool is connected to the RCS, the added clarification in the Applicability is not changing the current requirements, with respect to REFUELING OPERATIONS. Therefore, this change is acceptable and is designated as administrative since the technical requirements are not changing. Note that the spent fuel pool boron concentration limit when not connected to the RCS is governed by ITS 3.7.14.

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 45 of 55

Attachment 1, Volume 14, Rev. 0, Page 9 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 46 of 55 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION continue to ensure that process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis.

This change is designated more restrictive because the boron concentration requirements for ITS are more restrictive than the conditions stated in the CTS.

M02 CTS 3.8.a.5 states, in part, that a minimum boron concentration as specified in the COLR shall be maintained in the Reactor Coolant System. ITS LCO 3.9.1 in part, states, that the boron concentrations of the Reactor Coolant System (RCS), the fuel transfer canal, and the refueling cavity shall be maintained within the limit specified in the COLR. ITS 3.9.1 Applicability contains a NOTE that states the LCO is only applicable to the fuel transfer canal and the refueling cavity when connected to the RCS. This changes the CTS by including the boron concentration of the fuel transfer canal and the refueling cavity in the LCO and adds a NOTE to the Applicability stating that the LCO is only applicable to the fuel transfer canal and the refueling cavity when connected to the RCS.

The purpose of CTS 3.8.a.5 is to ensure the boron concentration of the water surrounding the reactor fuel is sufficient to maintain the reactor subcritical during refueling. When the reactor head is removed for refueling of the reactor, the refueling cavity is open to the reactor itself. The refueling cavity is flooded with borated water from the Refueling Water Storage Tank and when the cavity is filled, the fuel transfer canal, refueling cavity, and the reactor vessel all share the same volume of water. As a result, the soluble boron concentration is relatively the same in each of these volumes. The NOTE to ITS 3.9.1 Applicability states that the limits on boron concentration are only applicable to the fuel transfer canal and the refueling cavity when those volumes are connected to the RCS.

When the fuel transfer canal and the refueling cavity are isolated from the RCS (i.e., the reactor vessel head is on the vessel), no potential path for boron dilution exists. In addition, prior to connecting the refueling cavity and the fuel transfer canal to the RCS, a boron concentration verification will be performed (as required by SR 3.0.4) to ensure the newly connected portions cannot decrease the boron concentration below the limit. These changes are acceptable because the requirements continue to ensure that process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. This change is designated more restrictive because the LCO requirements are applicable in more operating conditions than in the CTS.

INSERT DOC M03 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.a.5 requires the boron concentration of the Reactor Coolant System be determined "by chemical analysis" daily. ITS SR 3.9.1.1 requires verification that boron concentration is within the limit specified in the COLR. ITS SR 3.9.1.1 does not specify that the boron concentration be determined by chemical analysis. This changes the CTS by moving details of Kewaunee Power Station Page 2 of 3 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 46 of 55 Attachment 1, Volume 14, Rev. 0, Page 9 of 175

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 47 of 55 M03 CTS 5.4.a.3 does not provide any ACTIONS to take when the spent fuel pool boron concentration is not within limit during REFUELING OPERATIONS. When the spent fuel pool boron concentration is not within limit, ITS 3.9.1 ACTION A requires the immediate suspension of positive reactivity additions and immediate action to restore the boron concentration to within limit. This changes the CTS by providing specific ACTIONS when the spent fuel pool boron concentration is not within limit during refueling operations (i.e., in MODE 6 when connected to the RCS).

The purpose of CTS 5.4.a.3 is to ensure adequate dissolved boron is in the spent fuel pool water to maintain the required subcriticality margin in the RCS, when connected to the RCS during MODE 6 (i.e., refueling operations). ITS 3.7.14 ACTION A effectively places the unit outside of the Applicability by requiring the plant to immediately suspend any operations that would further decrease the subcriticality margin and to initiate actions to restore the boron concentration to within limits. The proposed Required Actions reflect the importance of maintaining the boron concentration within the required limit. This change is designated more restrictive because a new proposed ACTION has been added.

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 47 of 55

Attachment 1, Volume 14, Rev. 0, Page 12 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 48 of 55 CTS Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration (RCS) fuel transfer 3.8.a.5 1 2 LCO 3.9.1 Boron concentrations of the Reactor Coolant System, the refueling canal, and the refueling cavity shall be maintained within the limit specified in the 3

, 5.4.a.3 COLR.

, and the spent fuel pool 3.8.a, APPLICABILITY: MODE 6.

3.8.a.5

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

DOC M02 Only applicable to the refueling canal and refueling cavity when 3 connected to the RCS. fuel transfer 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.8.b A. Boron concentration not A.1 Suspend CORE Immediately within limit. ALTERATIONS.

, DOC M03 AND TSTF-A.2 1 Suspend positive reactivity Immediately 471 additions.

AND A.3 2 Initiate action to restore Immediately boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.8.a.5 SR 3.9.1.1 Verify boron concentration is within the limit 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months specified in the COLR.

WOG STS 3.9.1-1 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 48 of 55 Attachment 1, Volume 14, Rev. 0, Page 12 of 175

Attachment 1, Volume 14, Rev. 0, Page 13 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 49 of 55 JUSTIFICATION FOR DEVIATIONS ITS 3.9.1, BORON CONCENTRATION

1. Editorial change made for consistency.

2. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description INSERT JFD 3 Kewaunee Power Station Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 49 of 55 Attachment 1, Volume 14, Rev. 0, Page 13 of 175

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 50 of 55 JFD 3

3. The spent fuel pool boron concentration requirement when the spent fuel pool is connected to the RCS has been added to the LCO 3.9.1 statement for clarity and ease of use. CTS 5.4.a.3 requires the boron concentration to be consistent with the RCS during refueling operations. Since refueling operations can only take place when the spent fuel pool is connected, this allowance has also been added into the Applicability Note.

Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 50 of 55

Attachment 1, Volume 14, Rev. 0, Page 15 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 51 of 55 All changes are 1 Boron Concentration B 3.9.1 unless otherwise noted B 3.9 REFUELING OPERATIONS B 3.9.1 Boron Concentration BASES , and the spent fuel pool 6

BACKGROUND The limit on the boron concentrations of the Reactor Coolant System fuel transfer (RCS), the refueling canal, and the refueling cavity during refueling ensures that the reactor remains subcritical during MODE 6. Refueling boron concentration is the soluble boron concentration in the coolant in each of these volumes having direct access to the reactor core during refueling.

The soluble boron concentration offsets the core reactivity and is measured by chemical analysis of a representative sample of the coolant in each of the volumes. The refueling boron concentration limit is specified in the COLR. Plant procedures ensure the specified boron concentration in order to maintain an overall core reactivity of keff 0.95 during fuel handling, with control rods and fuel assemblies assumed to be in the most adverse configuration (least negative reactivity) allowed by plant procedures. Updated Safety Analysis Report (USAR), General Design Criteria (GDC) 27, "Redundancy of Reactivity Control" preferably GDC 26 of 10 CFR 50, Appendix A, requires that two independent shall reactivity control systems of different design principles be provided 2

(Ref. 1). One of these systems must be capable of holding the reactor core subcritical under cold conditions. The Chemical and Volume Control INSERT 1 System (CVCS) is the system capable of maintaining the reactor subcritical in cold conditions by maintaining the boron concentration.

The reactor is brought to shutdown conditions before beginning operations to open the reactor vessel for refueling. After the RCS is and cooled and depressurized and the vessel head is unbolted, the head is is slowly removed to form the refueling cavity. The refueling canal and the refueling cavity are then flooded with borated water from the refueling water storage tank through the open reactor vessel by gravity feeding or by the use of the Residual Heat Removal (RHR) System pumps.

The pumping action of the RHR System in the RCS and the natural circulation due to thermal driving heads in the reactor vessel and refueling fuel transfer cavity mix the added concentrated boric acid with the water in the refueling canal. The RHR System is in operation during refueling (see 4

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High 3 Water Level," and LCO 3.9.6, "Residual Heat Removal (RHR) and 5

Coolant Circulation - Low Water Level") to provide forced circulation in the RCS and assist in maintaining the boron concentrations in the RCS, the refueling canal, and the refueling cavity above the COLR limit. 6 fuel transfer

, and the spent fuel pool WOG STS B 3.9.1-1 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 51 of 55 Attachment 1, Volume 14, Rev. 0, Page 15 of 175

Attachment 1, Volume 14, Rev. 0, Page 17 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 52 of 55 All changes are 1 Boron Concentration unless otherwise noted B 3.9.1 BASES APPLICABLE During refueling operations, the reactivity condition of the core is SAFETY consistent with the initial conditions assumed for the boron dilution ANALYSES accident in the accident analysis and is conservative for MODE 6. The boron concentration limit specified in the COLR is based on the core reactivity at the beginning of each fuel cycle (the end of refueling) and includes an uncertainty allowance.

The required boron concentration and the plant refueling procedures that verify the correct fuel loading plan (including full core mapping) ensure that the keff of the core will remain 0.95 during the refueling operation.

Hence, at least a 5%

fuel During refueling, the water volume in the spent fuel pool, the transfer canal, the refueling canal, the refueling cavity, and the reactor vessel form a single mass. As a result, the soluble boron concentration is relatively the same in each of these volumes.

The limiting boron dilution accident analyzed occurs in MODE 5 (Ref. 2).

4 A detailed discussion of this event is provided in Bases B 3.1.1, "SHUTDOWN MARGIN (SDM)."

The RCS boron concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). , and the spent fuel pool 6 LCO The LCO requires that a minimum boron concentration be maintained in fuel transfer the RCS, the refueling canal, and the refueling cavity while in MODE 6.

The boron concentration limit specified in the COLR ensures that a core keff of 0.95 is maintained during fuel handling operations. Violation of the LCO could lead to an inadvertent criticality during MODE 6.

APPLICABILITY This LCO is applicable in MODE 6 to ensure that the fuel in the reactor vessel will remain subcritical. The required boron concentration ensures a keff 0.95. Above MODE 6, LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," ensures that an adequate amount of negative reactivity is available to shut down the reactor and maintain it subcritical. ,

fuel transfer The Applicability is modified by a Note. The Note states that the limits on boron concentration are only applicable to the refueling canal and the refueling cavity when those volumes are connected to the RCS. When the refueling canal and the refueling cavity are isolated from the RCS, no potential path for boron dilution exists.

WOG STS B 3.9.1-2 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 52 of 55 Attachment 1, Volume 14, Rev. 0, Page 17 of 175

Attachment 1, Volume 14, Rev. 0, Page 19 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 53 of 55 Boron Concentration B 3.9.1 BASES SURVEILLANCE SR 3.9.1.1 , and the spent fuel pool REQUIREMENTS 6 This SR ensures that the coolant boron concentration in the RCS, and 1

connected portions of the refueling canal and the refueling cavity, is within fuel transfer the COLR limits. The boron concentration of the coolant in each required volume is determined periodically by chemical analysis. Prior to re- ,

1 connecting portions of the refueling canal or the refueling cavity to the RCS, this SR must be met per SR 3.0.4. If any dilution activity has , or the 6

occurred while the cavity or canal were disconnected from the RCS, this spent fuel SR ensures the correct boron concentration prior to communication with pool the RCS.

A minimum Frequency of once every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is a reasonable amount of time to verify the boron concentration of representative samples. The Frequency is based on operating experience, which has shown 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to be adequate. USAR, Section 3.1.2.3, General Design Criteria (GDC) 27, "Redundancy of Reactivity Control."

2 REFERENCES 1. 10 CFR 50, Appendix A, GDC 26.

2. USAR, Section 3.1.2.6, GDC 30, "Reactivity Holddown Capability." 2

2. FSAR, Chapter [15]. 4 WOG STS B 3.9.1-4 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 53 of 55 Attachment 1, Volume 14, Rev. 0, Page 19 of 175

Attachment 1, Volume 14, Rev. 0, Page 20 of 175 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 54 of 55 JUSTIFICATION FOR DEVIATIONS ITS 3.9.1 BASES, BORON CONCENTRATION

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 ISTS lists GDC 26 of Appendix A to 10 CFR 50 as the reference document for the requirement that there be two independent reactivity control systems of different design principles. Per the information contained in USAR Section 1.8, Kewaunee Power Station (KPS) was designed, constructed, and is being operated to comply with the Atomic Energy Commission (AEC) General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Since the plant was approximately 50% complete prior to the February 20, 1971 issuance of 10 CFR 50 Appendix A General Design Criteria, KPS was not required to be reanalyzed and the Final Safety Analysis Report (FSAR) was not required to be revised to reflect these later criteria. However, the AEC Safety Evaluation Report (SER), issued July 24, 1972, acknowledged that the AEC staff assessed the plant, as described in the FSAR (Amendment No. 7), against the Appendix A design criteria and determined that the plant design generally conforms to the intent of the Appendix A criteria. As a result, KPS utilizes AEC GDC 27, Redundancy of Reactivity Control and GDC 30, Reactivity Holddown Capability, as the licensing reference documents for the requirement that there be two independent reactivity control systems of different design principles.

3. ISTS 3.9.5 and ISTS 3.9.6 has been renumbered to ITS 3.9.4 and ITS 3.9.5, respectively, since ISTS 3.9.2 has not been included in the KPS ITS.

4. The paragraph in the Applicable Safety Analyses states the limiting boron dilution accident occurs in MODE 5. The Applicability of the Specification for Boron Concentration is MODE 6. Therefore, the paragraph and associated reference in the Applicable Safety Analyses have been deleted since the Specification for boron concentration is applicable to MODE 6 only.

5. Changes have been made to be consistent with similar wording in the Specification.

6. Changes have been made to be consistent with changes made to the Specification.

Kewaunee Power Station Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 54 of 55 Attachment 1, Volume 14, Rev. 0, Page 20 of 175

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 55 of 55 Licensee Response/NRC Response/NRC Question Closure Id 3451 NRC Question MEH-004 Number Select NRC Question Closure Application

Response

Date/Time Closure Based on the licensee response for MEH-004 dated 6/7/2010, this question is closed and Statement no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 6/9/2010 Date Attachment 1 Attachment 2 Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Victor Cusumano Added By Matthew Hamm Date Added 6/9/2010 12:45 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 12 (Section 3.7) Page 55 of 55 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3451 06/25/2010

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