ML101890237

Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) - Kewaunee ITS Conversion Database

ML101890237
Person / Time
Site:	Kewaunee
Issue date:	06/07/2010
From:	Dominion Energy Kewaunee
To:	Office of Nuclear Reactor Regulation
References
Download: ML101890237 (40)

Text

Kewaunee ITS Conversion Database Page 1 of 3 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 1 of 40 ITS NRC Questions Id 1881 NRC Question RPG-005 Number Category Technical ITS Section 3.0 ITS Number 3.4.16 DOC Number JFD Number JFD Bases Number Page Att 1, Vol 9, Page 380, 381 Number(s)

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

Requested NRC Question The NRC staff is reviewing Dominion Energy Kewaunee's application to convert the current Kewaunee custom Tech Spec into the Improved Standard Tech Spec (ITS) format. As part of its review, the NRC staff has determined that additional information, set forth below, is needed to complete its review of the issue regarding the proposed adoption of TSTF-490-A.

[PLEASE NOTE, LICENSEE MAY RESPOND TO THE ISSUES STATED BELOW VIA THE WEB PAGE, HOWEVER, A FORMAL RESPONSE IS REQUIRED FROM THE LICENSEE WHEN THE STAFF ISSUE THE REQUEST FOR ADDITIONAL INFORMATION (RAI) LETTER TO THE LICENSEE.]

1. In the subject license amendment application, the licensee proposed to adopt industry standard technical specifications which include proposed Limiting Condition for Operation (LCO) 3.4.16, "RCS Specific Activity," APPLICABILITY requirements to specify that the LCO is applicable in MODES 1, 2, 3, and 4. In accordance with this proposal, the licensee also proposed to add the NOTE that states, "Only required to be performed in MODE 1" to the surveillance requirements of the TS, thus removing the applicability of the surveillance requirements to other MODES.

http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1881 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 3 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 2 of 40 The NRC staff has a concern about the proposed addition of the aforementioned NOTE. The proposed change revises the conditions for sampling, and may exclude sampling during the plant conditions where LCO 3.4.16 may be exceeded. After transient conditions (i.e. reactor trip, plant depressurization, shutdown or startup) that end in MODES 2, 3, or 4, the SR is not required to be performed. Isotopic spiking and fuel failures are more likely during transient conditions than during steady-state plant operations.

Because LCO 3.4.16 could potentially be exceeded after plant transient or power changes, please justify why sampling is no longer needed in the plant MODES that are proposed to be eliminated and justify how the LCO 3.4.16 remains consistent with the design bases analysis from which the LCO limits are derived (i.e. main steamline break, steam generator tube rupture, etc.). Furthermore, please justify why there is an apparent disparity between the modes of applicability (MODES 1, 2, 3, and 4) and the limited mode (MODE 1) under which the surveillance is required. In addition, please provide marked up TS pages identifying your proposed changes.

2. The licensee stated:

The Dose Conversion Factors used in the determination of DOSE EQUIVALENT I-131 AND Xe-133 are consistent with the Dose Conversion factors used in the applicable dose consequence analysis.

Consistent with the model safety evaluation for TSTF-490, please confirm that the site-specific limits for both DEI and DEX, and the dose conversion factors (DCFs) used for the determination of DEI and DEX surveillances, are consistent with the Kewaunee current design-basis radiological dose consequence analyses (i.e. steam generator tube rupture and main steamline break). Also, for both DEI and DEX, please provide the information necessary (dose conversion factors and reactor coolant system radioisotopic concentrations) for the NRC staff to verify the proposed value in the LCO. In addition, please provide marked up TS pages identifying your proposed changes.

Attach File 1

Attach File 2

http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1881 06/07/2010

Kewaunee ITS Conversion Database Page 3 of 3 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 3 of 40 Issue Date 3/11/2010 Added By Ravinder Grover Date Modified Modified By Date Added 3/11/2010 12:53 PM Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1881 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 4 of 40 Licensee Response/NRC Response/NRC Question Closure Id 2961 NRC Question RPG-005 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 5/13/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 5/13/2010 8:37 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2961 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 5 of 40 ITS NRC Questions Id 1951 NRC Question RPG-007 Number Category Technical ITS Section 3.4 ITS Number 3.4.5 DOC Number JFD Number JFD Bases Number Page 90 of 479 Number(s)

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

Requested NRC Attachment 1, Volume 9, Rev. 0, Page 90 of 479 proposed ITS Section 3.4.5 Question RCS Loops - MODE 3 With loss of both RCS loops (LCO 3.4.5, CONDITION D), ISTS REQUIRED ACTION D.1 specifies placing the Rod Control System Immediately in a condition incapable of rod withdrawal. SAFETY ANALYSES in ISTS BASES state, Whenever the reactor trip breakers (RTBs) are in the closed position and the control rod drive mechanisms (CRDMs) are energized, an inadvertent rod withdrawal from subcritical, resulting in a power excursion, is possible. Such a transient could be caused by a malfunction of the rod control system. In addition, the possibility of a power excursion due to the ejection of an inserted control rod is possible with the breakers closed or open. Such a transient could be caused by the mechanical failure of a CRDM of rod withdrawal.

Issue: KPS proposed change deletes the REQUIRED ACTION. Please explain, how an inadvertent rod withdrawal from subcritical condition event, with two RCS loops inoperable, would be within the analyzed conditions addressed in Chapter 14.1.1 of the USAR.

Attach File 1

Attach File 2

Issue Date 4/29/2010 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1951 06/07/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 6 of 40 Added By Ravinder Grover Date Modified Modified By Date Added 4/29/2010 11:59 AM Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1951 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 7 of 40 Licensee Response/NRC Response/NRC Question Closure Id 2871 NRC Question RPG-007 Number Select Licensee Response Application

Response

5/3/2010 10:25 AM Date/Time Closure Statement Response Kewaunee Power Station (KPS) deleted this Required Action since it was Statement assumed that it was in the ISTS because of the LCO requirements, which specify how many RCS loops must be in operation based on whether or not the Rod Control System is in a condition capable of rod withdrawal.

Since KPS CTS only required one RCS loop to be in operation irrespective of the condition of the Rod Control System, this Required Action was not included. However, based on a further review, KPS has determined that this Required Action should be maintained in the ITS. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment RPG-007 Markup.pdf (892KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 5/3/2010 10:32 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2871 06/07/2010

Attachment 1, Volume 9, Rev. 0, Page 87 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 8 of 40 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 operation when a reduction in boron concentration is being made, the CTS 3.0.c requirement does not provide any relevant compensatory measures (i.e., it does not require boron concentration reductions to be suspended). ITS 3.4.5 ACTION C specifies the Required Actions for a required RCS loop not in operation as immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and initiation of action to restore one RCS loop to operation. This changes the CTS by adding a new ACTION.

place the Rod Control System in a condition The purpose of CTS LCO 3.0.c is to place the unit outside of the Applicability of incapable of rod the Specification. ITS 3.4.5 ACTION C effectively places the unit outside of the withdrawal, Applicability for a loop not in operation by requiring the plant to immediately suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and to initiate action to restore one RCS loop to operation. These proposed Required Actions reflect the importance of maintaining operation for heat removal and boron mixing. This change is designated as more restrictive because a new proposed ACTION has been added.

M04 CTS 3.1.a.1.A requires one RCP to be in operation under certain conditions, but does not provide a Surveillance Requirement to periodically verify the RCP is in operation. This changes the CTS by adding a new Surveillance Requirement.

The purpose of ITS SR 3.4.5.1 is to ensure that the RCS loops are in operation providing forced flow of the reactor coolant for heat removal. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. This will ensure the LCO requirement is periodically verified to be met. This change is designated as more restrictive because a new Surveillance Requirement has been added.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 3 of 3 Attachment 1, Volume 9, Rev. 0, Page 87 of 479

Attachment 1, Volume 9, Rev. 0, Page 90 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 9 of 40 CTS RCS Loops - MODE 3 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. [ One required RCS loop C.1 Restore required RCS loop 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> not in operation with Rod to operation.

Control System capable 2

of rod withdrawal. OR C.2 Place the Rod Control 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ]

System in a condition incapable of rod withdrawal.

DOC M01, D. [Two] [required] RCS D.1 Place the Rod Control Immediately 5 1 2 DOC M03 loops inoperable. System in a condition C

incapable of rod withdrawal.

C.1 OR AND Stet 2 Required RCS loop(s) not in operation. D.2 Suspend operations that Immediately would cause introduction of 5 C.1 coolant into the RCS with C.2 boron concentration less than required to meet SDM of LCO 3.1.1.

AND D.3 Initiate action to restore Immediately 5 C.3 one RCS loop to C.2 OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY one is 2

DOC M04 SR 3.4.5.1 Verify required RCS loops are in operation. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> WOG STS 3.4.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 90 of 479

Attachment 1, Volume 9, Rev. 0, Page 98 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 10 of 40 All changes are 1 RCS Loops - MODE 3 B 3.4.5 unless otherwise noted BASES ACTIONS (continued) C.1. C.2, and C.3 C.1 and C.2 Stet 5 D.1, D.2, and D.3 the 4 If [two] [required] RCS loops are inoperable or a required RCS loop is not in operation, except as during conditions permitted by the Note in the LCO section, the Rod Control System must be placed in a condition 4 incapable of rod withdrawal (e.g., all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets). All operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and opening the RTBs or de-energizing the MG sets 4 removes the possibility of an inadvertent rod withdrawal. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.5.1 one REQUIREMENTS is 4

This SR requires verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the required loops are in operation. Verification includes flow rate, temperature, and pump status or 10 monitoring, which help ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop performance.

SR 3.4.5.2 SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY the is verified by ensuring that the secondary side narrow range water level is

[17]% for required RCS loops. If the SG secondary side narrow range 5 5

water level is < [17]%, the tubes may become uncovered and the 5

associated loop may not be capable of providing the heat sink for removal of the decay heat. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room to alert the operator to a loss of SG level.

WOG STS B 3.4.5-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 9, Rev. 0, Page 98 of 479

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 11 of 40 Licensee Response/NRC Response/NRC Question Closure Id 2971 NRC Question RPG-007 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 5/13/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 5/13/2010 8:46 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2971 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 4 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 12 of 40 ITS NRC Questions Id 1981 NRC Question RPG-008 Number Category Technical ITS Section 3.4 ITS Number DOC Number JFD Number JFD Bases Number Page Number(s)

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

Requested NRC Question Attachment 1, Volume 9, Rev. 0, Page 352 of 479 proposed ITS Section 3.4.15 RCS Leakage Detection Instrumentation

1) One of the RCS leakage detection instrumentation specified in ISTS LCO 3.4.15c is [One containment air cooler condensate flow rate monitor]. KPS JFD #2 states that KPS has no containment air cooler condensate flow rate monitor, therefore KPS proposed change replaces the ISTS specified containment air cooler condensate flow rate monitor with KPSs humidity detector. The ISTS BASES state, The containment sump used to collect unidentified LEAKAGE [is] [(or) and air cooler condensate flow rate monitor] [are] instrumented to alarm for increases of 0.5 to 1.0 gpm in the normal flow rates. This sensitivity is acceptable for detecting increases in unidentified LEAKAGE.

Requested Information: Explain how the alarm capability function of KPSs TS humidity detector for increases of 0.5 to 1.0 gpm in the normal flow rates, compares with ISTS specified containment air cooler condensate flow rate monitor, and how it satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1981 06/17/2010

Kewaunee ITS Conversion Database Page 2 of 4 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 13 of 40

2) ISTS LCO 3.4.15 CONDITION B is entered when required containment atmosphere radioactivity monitor becomes inoperable. The CONDITION requires performance of 4 specific REQUIRED ACTIONS connected with logical connectors AND, OR. KPS proposed change deletes two of the REQUIRED ACTIONS B.2.1 and B.2.2. KPS JFD #3 states, ISTS Required Actions B.2.1 and B.2.2 are bracketed Required Actions that require certain actions within 30 days. However, these required Actions are only necessary if the LCO 3.4.15.c option is not included in the ITS. Since KPS is including this option, these bracketed Required Actions are not included.

ISTS BASES state (page 362) With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors.

Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system (for KPS, Humidity Detector (issue#1)) is OPERABLE, provided grab samples are taken or water inventory balances performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Requested Information: Since the LCO CONDITION B concerns inoperability of the radioactivity monitor, REQUIRED ACTIONS B.2.1 and B.2.2 need to be performed. The ISTS Bases do not discuss the LCO 3.4.15c option stated in KPS JFD#3.

Please provide additional justification for not performing the LCO Condition B REQUIRED ACTIONS.

3) ISTS LCO 3.4.15 CONDITION C concerns inoperability of containment air cooler condensate flow rate monitor. REQUIRED ACTION C.1 for the CONDITION requires performance of CHANNEL CHECK of the required containment atmosphere radioactivity monitor per SR 3.4.15.1. KPS proposal changes the REQUIRED ACTION from "Perform SR 3.4.15.1" to "Analyze grab samples of the containment atmosphere," when in CONDITION C.

LCO 3.4.15 CONDITION C BASES state, With the required containment air cooler condensate flow rate monitor inoperable, alternative action is again required. Either SR 3.4.15.1 must be http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1981 06/17/2010

Kewaunee ITS Conversion Database Page 3 of 4 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 14 of 40 performed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

Requested Information: Please explain how KPS proposed change, i.e., analyzing grab samples of the containment atmosphere is equivalent to the performance of channel check per ISTS specified SR 3.4.15.1 for REQUIRED ACTION C1.

4) KPS JFD #5 further states, The Completion Time of this Required Action is "Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." SR 3.4.15.1 is the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitors. The Surveillance Frequency of SR 3.4.15.1 is every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ISTS 3.4.15 Required Action does not add any additional requirements since, as written, while ISTS 3.4.15 Required Action C.1 Completion Time is "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," ISTS 3.4.15 Required Action C.2 provides an optional requirement (it is connected to ISTS 3.4.15 Required Action C.1 with an "OR") and is required "Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." Thus, this essentially means ISTS 3.4.15 Required Action C.1 can be performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This change to ITS 3.4.15 Required Action C.1 is consistent with the Required Actions (B.1.1 and B.1.2) necessary when the required containment atmosphere radioactivity monitor is inoperable. These changes are necessary since when ITS 3.4.15 Condition C is entered either Required Action C.1 or Required Action C.2 is required to be met.

Requested Information: REQUIRED ACTION C1 is to perform SR 3.4.15.1 (Channel Check) with a COMPLETION TIME of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. REQUIRED ACTION C2 concerns performance of SR 3.4.13.1 (RCS water inventory balance) with a COMPLETION TIME of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Both REQUIRED ACTIONS concern different SRs.

Please provide justification for the proposed longer COMPLETION TIME of Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> versus that of shorter ISTS COMPLETION TIME of Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for REQUIRED ACTION C1.

http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1981 06/17/2010

Kewaunee ITS Conversion Database Page 4 of 4 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 15 of 40 Attach File 1

Attach File 2

Issue Date 5/11/2010 Added By Ravinder Grover Date Modified Modified By Date Added 5/11/2010 3:18 PM Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1981 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 16 of 40 Licensee Response/NRC Response/NRC Question Closure Id 3051 NRC Question RPG-008 Number Select Licensee Response Application

Response

5/18/2010 9:05 AM Date/Time Closure Statement Response The NRC reviewer asked four questions related to the Kewaunee Power Statement Station (KPS) humidity monitor being added to ITS 3.4.15. The first question was related to its monitoring capability. This monitor was being added to the ITS to replace a bracketed air cooler condensate flow rate monitor requirement. However, the humidity monitor is not currently in the KPS CTS, and it cannot perform in the manner described in the ISTS Bases for the air cooler condensate flow rate monitor. Therefore, after informal discussions with the NRC reviewer, KPS has decided to withdraw the added humidity monitor requirement. Based on this removal, the remaining three questions were related to the manner in which the ISTS wording was adopted based on the humidity monitor addition. Since the monitor is being removed, the three other questions are now moot as the ACTIONS discussed in the questions have all been deleted or modified accordingly. 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 RPG-008 Markup.pdf (1MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Ravinder Grover Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 5/18/2010 9:06 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3051 06/17/2010

Attachment 1, Volume 9, Rev. 0, Page 341 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 17 of 40 ITS ITS 3.4.15 A01

d. RCS Operational LEAKAGE

1. When the average RCS temperature is > 200°F, RCS operational leakage shall be limited to:

A. No pressure boundary LEAKAGE, B. 1 gpm unidentified LEAKAGE, C. 10 gpm identified LEAKAGE, and D. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG). See ITS 3.4.13

2. If the limits contained in TS 3.1.d.1 are exceeded for reasons other than pressure boundary LEAKAGE or primary-to-secondary LEAKAGE, then reduce the LEAKAGE to within their limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3. If the limits contained in TS 3.1.d.1 for pressure boundary or primary to secondary LEAKAGE are exceeded, or the time limit contained in TS 3.1.d.2 is exceeded, then initiate action to:

- Achieve HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

- Achieve COLD SHUTDOWN within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Stet M01 Three Applicability

4. When the reactor is critical and above 2% power, two reactor coolant leak detection M02 LCO 3.4.15 systems of different operating principles shall be in operation with one of the two ACTION A, systems sensitive to radioactivity. Either system may be out of operation for up to ACTION B, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provided at least one system is OPERABLE. L01 ACTION D L02 Add proposed ACTION C M02 C

Add proposed ACTION E M03 Add proposed ACTION F A02 D

Amendment No. 188 TS 3.1-8 Revised by letter dated August 29, 2006 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 341 of 479

ITS ITS 3.4.15 A01 TABLE TS 4.1-1 MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS CHANNEL CHECK CALIBRATE TEST REMARKS DESCRIPTION

18. a. Containment Each shift Each refueling cycle Monthly(a) (a) Isolation Valve Signal Pressure (SIS signal)

b. Containment Each shift(a) Each refueling cycle(a) Monthly(a) (a) Narrow range containment pressure Pressure See ITS

(-3.0, +3.0 psig excluded) 3.3.2 (Steamline Isolation)

c. Containment Each shift Each refueling cycle Monthly Pressure (Containment Spray Act)

d. Annulus Not applicable Each refueling cycle Each refueling See ITS 3.6.9 Pressure cycle (Vacuum LA01 Breaker)

SR 3.4.15.1,

19. Radiation Monitoring Daily (a,b) A03 Each refueling cycle (a) Quarterly (a) (a) Includes only channels R11 thru R15, R19, SR 3.4.15.2, System R21, and R23 SR 3.4.15.4, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (b) Channel check required in all plant modes A03

20. Deleted

21. Containment Sump Not applicable Not applicable Each refueling M04 SR 3.4.15.3 Level cycle

22. Accumulator Level Each shift Deleted Not applicable See ITS , Volume 9, Rev. 0, Page 343 of 479 Attachment 1, Volume 9, Rev. 0, Page 343 of 479 and Pressure 3.5.1

23. Steam Generator Each shift Each refueling cycle Monthly See ITS Pressure 3.3.2 Discussion of Change LA01 is for channels Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 18 of 40 R11, R12, and R21. For the other channels, see ITS 3.3.2, 3.3.6, 3.3.7, and CTS 3.8.a.9.

Add proposed SR 3.4.15.5 M02 Amendment No. 182 Page 4 of 7 4/06/2005 Page 3 of 4

Attachment 1, Volume 9, Rev. 0, Page 345 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 19 of 40 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION 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 3.1.d.4 does not contain a specific ACTION for all required monitors inoperable. With all required monitors inoperable, CTS 3.0.c would be entered.

D ITS 3.4.15 ACTION F directs entry into LCO 3.0.3 when all monitors are inoperable. This changes the CTS by specifically stating to enter LCO 3.0.3, which is the equivalent requirement in the ITS, in this System Specification.

Changes to CTS 3.0.c are discussed in Section 3.0.

This change is acceptable because the actions taken when all monitors are inoperable are unchanged. Adding this ACTION is consistent with the ITS conversion of directing entry into LCO 3.0.3 when multiple ACTIONS are presented in the ITS, and entry into these multiple ACTIONS could result in a loss of safety function. This change is designated as administrative because it does not result in any technical changes to the CTS.

A03 Note (b) to CTS Table TS 4.1-1, Item 19 in the Remarks Section states that the Channel Check is required in all plant modes. ITS SR 3.4.15.1, the equivalent CHANNEL CHECK requirement, is only applicable in MODES 1, 2, 3, and 4, consistent with the Applicability of the LCO. This changes the CTS by deleting this specific Note.

While the purpose of the Note appears to require the Channel Check requirement to be performed in all plant modes, CTS 4.0.a, which provides the general requirements of all Surveillance Requirements, specifically states that Surveillances are only required to be met during the operational MODES or other specified conditions in the LCO. While it does state that this can be modified as stated in an individual Surveillance, it further states that if the Surveillance is not met, then the actions of the LCO are to be taken. However, as shown in CTS 3.1.d.4, since the equipment is only required when critical above 2% RTP, when declared inoperable, the plant only has to get out of this specific Applicability, as stated in CTS 3.0.c. Thus, while this Note appears to require the Channel Check in all plant modes, in actuality, it only is required when the LCO has to be met; i.e., when critical above 2% RTP. Therefore, the deletion of this is acceptable and considered administrative, since the technical requirements have not been changed.

A04 CTS 4.1.b requires the equipment tests to be performed as specified in Table TS 4.1-3. CTS Table TS 4.1-3 Equipment Test 8 requires a weekly OPERABILITY test on the RCS Leakage Detection. The test is modified by Note 1, which states that following maintenance on equipment that could affect the operation of the equipment, tests should be performed to verify OPERABILITY.

Kewaunee Power Station Page 1 of 6 Attachment 1, Volume 9, Rev. 0, Page 345 of 479

Attachment 1, Volume 9, Rev. 0, Page 346 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 20 of 40 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION The Weekly Frequency is modified by a Note (Note 4) that states the Frequency is applicable when the reactor is at power or in the HOT SHUTDOWN condition.

The ITS does not include this requirement. This changes the CTS by deleting this weekly OPERABILITY check of the RCS Leak Detection Instrumentation.

CTS 3.1.d.4 requires two RCS leak detection systems to be OPERABLE. Thus, this CTS Table 4.1-3 Equipment Test 8 is met by verifying that there are two RCS leak detection instruments OPERABLE. This is the manner in which Kewaunee Power Station is meeting this requirement. Since ITS LCO 3.4.15 continues to require RCS leak detection systems to be OPERABLE, and ACTIONS are provided when the required systems are inoperable, there is no purpose to having a requirement to verify weekly that the required systems are OPERABLE. Operations staff is constantly aware of equipment that has been declared inoperable. Thus, this requirement serves no purpose and is redundant to both the LCO and the applicable ACTIONS. Furthermore, LCO 3.0.2 requires entry into the ACTIONS when the LCO is no longer met. To meet this requirement, Operations staff would have to know at all times whether an LCO is being met, not just on a weekly basis. Therefore, deletion of this redundant check is acceptable. Furthermore, if a component is inoperable, prior to calling the component OPERABLE, KPS would have to determine if any tests are required to be performed as part of returning the component to OPERABLE status. ITS LCO 3.0.1 and SR 3.0.1 would ensure any required tests are performed or are current. Furthermore, Note (4) is unnecessary since it is duplicative of the Applicability statement for the RCS leak detection systems in CTS 3.1.d.4. This change is designated as administrative since it does not result in any technical changes.

MORE RESTRICTIVE CHANGES M01 The CTS Applicability of the RCS leak detection system is when the reactor is critical and above 2% power (equivalent to ITS MODE 1 and part of MODE 2).

ITS 3.4.15 requires the RCS leakage detection instrumentation to be OPERABLE in MODES 1, 2, 3, and 4. This changes the CTS by requiring the RCS leak detection instrumentation to be OPERABLE in more MODES in ITS than in CTS.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Due to the elevated RCS temperature and pressure conditions in MODES 1, 2, 3, and 4, the RCS leakage detection instrumentation is required to be OPERABLE. Since the RCS pressure and temperatures are much lower outside of MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation is much smaller. The addition of MODES 2, 3, and 4 is acceptable since the RCS pressure and temperature during these MODES increases the potential for reactor coolant pressure boundary leakage. This change is more restrictive because a new Applicability containing MODES 1, 2, 3, and 4 has been added.

M02 CTS 3.1.d.4 does not include the humidity monitor instrumentation as one of the RCS leakage detection functions. ITS LCO 3.4.15.c adds one humidity monitor as an OPERABLE RCS leakage detection instrumentation function. In addition, Not used.

Kewaunee Power Station Page 2 of 6 Attachment 1, Volume 9, Rev. 0, Page 346 of 479

Attachment 1, Volume 9, Rev. 0, Page 347 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 21 of 40 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION ITS adds an ACTION when the humidity monitor is inoperable (ITS 3.4.15 ACTION C) and a Surveillance Requirement (SR 3.4.15.5) to perform a CHANNEL CALIBRATION of the required humidity monitor every 18 months.

This changes the CTS by adding a new RCS leakage detection function and an associated ACTION and Surveillance Requirement to the Technical Specifications.

This change is acceptable because the added function provides an additional required diverse means of leakage detection. An increase in the humidity of the containment atmosphere would indicate release of water vapor to the containment. Although not as sensitive as the particulate monitor, the humidity detection instrumentation has the characteristics of being sensitive to vapor originating from all sources within the containment. Adding the appropriate ACTION provides compensatory measures when the humidity monitor is inoperable and the Surveillance Requirement provides additional assurance that the RCS leakage detection humidity instrumentation is capable of providing a reliable and accurate indication of containment humidity conditions that may be indicative of RCS leakage. This change is designated as more restrictive because a new LCO requirement and associated ACTION and Surveillance Requirement are added. one of the and not restored within M03 CTS 3.1.d.4 does not contain any ACTIONS to take if both required RCS leakage the allowed detection instruments are inoperable. As a result, CTS 3.0.c would be entered, Completion which requires action to be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and to be in HOT STANDBY C Time.

(equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.4.15 ACTION E states or that if the Required Action and associated Completion time of ACTIONS A, B, C, or D are not met, then the unit must be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This changes the CTS by adding a specific shutdown action.

The purpose of CTS LCO 3.0.c is to place the unit outside of the Applicability of C

the Specification. With the ITS Applicability being MODES 1, 2, 3, and 4, ITS 3.4.15 ACTION E effectively places the unit outside of the Applicability by requiring the unit to be in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Furthermore, the unit is required to be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, which is less than the current time to be in HOT STANDBY in CTS 3.0.c. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. This change is designated as more restrictive because a new proposed ACTION has been added.

M04 Item 19 of CTS Table TS 4.1-1 requires a Daily instrument check of the radiation monitoring system. ITS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment radioactivity monitor every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by requiring a check of the required containment radioactivity monitor more often in ITS than in CTS.

The purpose of the instrument check is to demonstrate that the required containment radioactivity monitor is OPERABLE and capable of providing an early indication of any abnormal leakage conditions in the containment. ITS SR 3.4.15.1 provides reasonable confidence that the channel is operating properly.

Kewaunee Power Station Page 3 of 6 Attachment 1, Volume 9, Rev. 0, Page 347 of 479

Attachment 1, Volume 9, Rev. 0, Page 349 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 22 of 40 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION The purpose of CTS 3.1.4.d is to ensure an approved method of monitoring RCS leakage is always available. The change is acceptable because ITS 3.4.15 ACTION A continues to provide assurance that an alternate and reliable means D

of detecting RCS leakage is available (since if both methods are inoperable the unit would also be in ITS 3.4.15 ACTION F, which requires a unit shutdown). In addition, the increase in the allowable time in which the required containment sump monitor is inoperable is acceptable since SR 3.4.13.1, which is normally performed every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, is now performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide periodic information that is adequate to detect leakage. The performance of the SR ensures that RCS Leakage is verified to be within limit, on a more frequent basis, thus performing the function of the instrumentation. This change is designated as less restrictive because a less restrictive Completion Time is being applied in the ITS than was applied in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.1.d.4 states that either reactor coolant leak detection system may be out of operation for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provided at least one system is OPERABLE. When the required containment atmosphere radioactivity monitor is inoperable, ITS 3.4.15 ACTION B requires an analysis of containment atmosphere grab samples be performed once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Required Action B.1.1) OR an RCS water inventory balance (i.e., SR 3.4.13.1) be performed once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Required Action B.1.2). In addition, if both the required containment atmosphere radioactivity monitor AND the required humidity monitor are inoperable, ITS 3.4.15 ACTION D requires B B.2 restoration of the required containment atmosphere radioactivity monitor to OPERABLE status within 30 days (Required Action D.1). During the 30 days allowed for restoration, Required Actions B.1.1 and B.1.2 will continue to be performed. This changes the CTS by allowing a longer period of time to restore the required containment atmosphere radioactivity monitor to OPERABLE in the ITS than was allowed in the CTS.

The purpose of CTS 3.1.4.d is to ensure an approved method of monitoring RCS leakage is always available. The change is acceptable because ITS 3.4.15 ACTION B continues to provide assurance that an alternate and reliable means of detecting RCS leakage is available (since if both methods are inoperable the D

unit would also be in ITS 3.4.15 ACTION F, which requires a unit shutdown).

Required Actions B.1.1 and B.1.2 are used to establish remedial measures taken in response to degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The analysis of the grab samples of the containment atmosphere or the check of the RCS water inventory balance (i.e., SR 3.4.13.1) once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provides periodic information that is adequate to detect any change in containment conditions that may be attributed to RCS leakage. Furthermore, while only in ACTION B, the humidity monitor is OPERABLE and can provide information on the containment atmosphere. Thus, it is acceptable to allow continued operation 30 days for an unlimited period of time with the containment radioactivity monitor inoperable under these conditions. If the humidity monitor is not OPERABLE, continued operation is only allowed for 30 days. The increase in the allowable time in which the required containment atmosphere radioactivity monitor is inoperable (from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 30 days) is acceptable since SR 3.4.13.1, which is normally performed every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, is now performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (per Required Action B.1.2) to provide periodic information that is adequate to detect Kewaunee Power Station Page 5 of 6 Attachment 1, Volume 9, Rev. 0, Page 349 of 479

Attachment 1, Volume 9, Rev. 0, Page 350 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 23 of 40 Info only, no changes DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION leakage, or an analysis of a containment atmosphere grab sample is performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (per required Action B.1.1). The analysis of the containment atmosphere grab samples or performance of the SR ensures that RCS Leakage is verified to be within limit, on a more frequent basis, thus performing the function of the instrumentation during the proposed 30 day restoration time. This change is designated as less restrictive because a less restrictive Completion Time is being applied in the ITS than was applied in the CTS.

Kewaunee Power Station Page 6 of 6 Attachment 1, Volume 9, Rev. 0, Page 350 of 479

Attachment 1, Volume 9, Rev. 0, Page 352 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 24 of 40 CTS RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation 3.1.d.4 LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE: hi or hi-hi and

a. One containment sump (level or discharge flow) monitor,  ; 4 1

b. One containment atmosphere radioactivity monitor (gaseous or particulate), and .

humidity

[ c. One containment air cooler condensate flow rate monitor. ] 2 3.1.d.4 APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.1.d.4 A. Required containment A.1 --------------NOTE--------------

sump monitor Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable. after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND A.2 Restore required 30 days containment sump monitor to OPERABLE status.

WOG STS 3.4.15-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 352 of 479

Attachment 1, Volume 9, Rev. 0, Page 353 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 25 of 40 CTS RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.1.d.4 B. Required containment B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere radioactivity the containment monitor inoperable. atmosphere. 3 stet OR B.1.2 --------------NOTE--------------

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

[ AND stet, with change B.2.1 Restore required 30 days containment atmosphere radioactivity monitor to 2 OPERABLE status.

3 OR B.2.2 Verify containment air 30 days ]

cooler condensate flow rate monitor is OPERABLE.

24 5 DOC M02 C. [ Required containment C.1 Perform SR 3.4.15.1. Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 4 air cooler condensate Analyze grab samples of the 5 2 flow rate monitor OR containment atmosphere.

inoperable.

humidity C.2 --------------NOTE-------------- 2 Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

4 Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ]

WOG STS 3.4.15-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 353 of 479

Attachment 1, Volume 9, Rev. 0, Page 354 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 26 of 40 CTS RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3.1.d.4 1 D. [ Required containment D.1 Restore required 30 days atmosphere radioactivity containment atmosphere monitor inoperable. radioactivity monitor to 2 OPERABLE status.

AND humidity 2 OR Required containment humidity 2 air cooler condensate D.2 Restore required 30 days ] 1 flow rate monitor containment air cooler inoperable. condensate flow rate monitor to OPERABLE status.

DOC M04 E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 2 3

associated Completion C C Time not met. AND of Condition 6 2 A, B, C or D E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B

DOC A02 F. All required monitors F.1 Enter LCO 3.0.3. Immediately 2

D inoperable. D SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.1.a, Table TS 4.1-1, SR 3.4.15.1 Perform CHANNEL CHECK of the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Item 19 containment atmosphere radioactivity monitor.

4.1.a, Table TS 4.1-1, SR 3.4.15.2 Perform COT of the required containment 92 days Item 19 atmosphere radioactivity monitor.

4.1.a, Table SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required [18] months 4 TS 4.1-1, containment sump monitor.

Item 21 WOG STS 3.4.15-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 354 of 479

Attachment 1, Volume 9, Rev. 0, Page 355 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 27 of 40 CTS RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.1.a, Table TS 4.1-1, SR 3.4.15.4 [ Perform CHANNEL CALIBRATION of the required [18] months ] 4 Item 19 containment atmosphere radioactivity monitor.

DOC M02 SR 3.4.15.5 [ Perform CHANNEL CALIBRATION of the required [18] months ] 4 2

containment air cooler condensate flow rate monitor. 2 humidity WOG STS 3.4.15-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 355 of 479

Attachment 1, Volume 9, Rev. 0, Page 356 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 28 of 40 JUSTIFICATION FOR DEVIATIONS is a bracketed requirement and ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. ISTS LCO 3.4.15.c states that one containment air cooler condensate flow rate monitor is required to be OPERABLE. Kewaunee Power Station (KPS) has no containment air cooler condensate flow rate monitor. According to Section 6.5 of the Updated Safety Analysis Report (USAR), KPS uses the following five methods of detecting Reactor Coolant System leakage to containment: containment system air particulate monitor, containment radiogas monitor (2 monitors), humidity detector, containment sump leakage measuring system, and liquid inventory. Therefore, where applicable, the word "humidity" has replaced "containment air cooler condensate flow rate" in the ITS Specification.

Not used.

3. ISTS Required Actions B.2.1 and B.2.2 are bracketed Required Actions that require certain actions within 30 days. However, these required Actions are only necessary if the LCO 3.4.15.c option is not included in the ITS. Since KPS is including this option, these bracketed Required Actions are not included. Also, due to their deletion, the previous Required Actions have been renumbered.

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

Not used.

5. ISTS 3.4.15 Required Action C.1 has been changed from "Perform SR 3.4.15.1" to "Analyze grab samples of the containment atmosphere." The Completion Time of this Required Action is "Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." SR 3.4.15.1 is the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitors.

The Surveillance Frequency of SR 3.4.15.1 is every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ISTS 3.4.15 Required Action does not add any additional requirements since, as written, while ISTS 3.4.15 Required Action C.1 Completion Time is "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," ISTS 3.4.15 Required Action C.2 provides an optional requirement (it is connected to ISTS 3.4.15 Required Action C.1 with an "OR") and is required "Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." Thus, this essentially means ISTS 3.4.15 Required Action C.1 can be performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This change to ITS 3.4.15 Required Action C.1 is consistent with the Required Actions (B.1.1 and B.1.2) necessary when the required containment atmosphere radioactivity monitor is inoperable. These changes are necessary since when ITS 3.4.15 Condition C is entered either Required Action C.1 or Required Action C.2 is required to be met.

ISTS 3.4.15 , ITS 3.4.15 ACTION D

6. The specific Conditions the ACTION applies to have been added, since there is one ACTION it does not apply to (ACTION F). This is consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii. This is also consistent with the words in the ISTS Bases for this ACTION.

The KPS CTS 3.1.d.4 only requires two types of leakage detection instrumentation; sump monitoring and containment atmospheric monitor. Therefore, the bracketed ISTS 3.4.15.c requirement has not been included in the KPS ITS. Due to this deletion, ISTS ACTIONS C and D and optional Required Action B.2.2 have been deleted, since they apply to the air cooler condensate flow rate monitor.

Subsequent ACTIONS have been renumbered due to these deletions. Furthermore, ISTS SR 3.4.15.5 has been deleted since it applies only to the air cooler condensate flow rate monitor.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 356 of 479

Attachment 1, Volume 9, Rev. 0, Page 358 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 29 of 40 Info only, no changes RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation Updated Safety Analysis Report (USAR) General Design Criteria (GDC) 16 (Ref. 1) requires that means shall be provided to detect significant 2 BASES uncontrolled leakage from the reactor coolant pressure boundary.

BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for USAR, Section 6.5, detecting and, to the extent practical, identifying the location of the source Leakage Detection of RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable 1 and Provisions for the Primary and methods for selecting leakage detection systems.

Auxiliary Coolant Loops Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE.

Industry practice has shown that water flow changes of 0.5 to 1.0 gpm can be readily detected in contained volumes by monitoring changes in A is water level, in flow rate, or in the operating frequency of a pump. The .

containment sump used to collect unidentified LEAKAGE [is] [(or) and air cooler condensate flow rate monitor] [are] instrumented to alarm for 1

increases of 0.5 to 1.0 gpm in the normal flow rates. This sensitivity is 3 INSERT 1 acceptable for detecting increases in unidentified LEAKAGE.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.

Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. Instrument sensitivities of 10-9 Ci/cc radioactivity for particulate monitoring and of 10-6 Ci/cc radioactivity for gaseous monitoring are practical for these leakage detection systems.

Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.

An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE.

A 1°F increase in dew point is well within the sensitivity range of available 4 instruments.

Although not as sensitive as the air particulate monitor, the humidity detection instrumentation has the characteristics of being sensitive to vapor originating from all sources within the containment and plots of air dew point variations should be sensitive to an incremental leakage equivalent to 2 to 10 gpm.

WOG STS B 3.4.15-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 358 of 479

Attachment 1, Volume 9, Rev. 0, Page 360 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 30 of 40 RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued)

Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment sump [and condensate flow from air 1 coolers]. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. 5 stet Humidity monitors are not required by this LCO. 6 Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressure monitors are not required by this LCO.

APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY to the operators, and the ability to compare and verify with indications ANALYSES from other systems is necessary. The system response times and U 1 sensitivities are described in the FSAR (Ref. 3). Multiple instrument locations are utilized, if needed, to ensure that the transport delay time of the leakage from its source to an instrument location yields an acceptable overall response time.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

LCO One method of protecting against large RCS leakage derives from the ability of instruments to rapidly detect extremely small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

WOG STS B 3.4.15-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 360 of 479

Attachment 1, Volume 9, Rev. 0, Page 361 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 31 of 40 RCS Leakage Detection Instrumentation All changes are 1 B 3.4.15 unless otherwise noted BASES LCO (continued)

(the hi or hi-hi alarm )

(Channel R12 or (Channel R11)

The LCO is satisfied when monitors of diverse measurement means are Channel R21 when available. Thus, the containment sump monitor, in combination with a 7 aligned to the containment) gaseous or particulate radioactivity monitor [and a containment air cooler 6 humidity condensate flow rate monitor], provides an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be  200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2 With the required containment sump monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, [and RCP seal injection and return flows]). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Restoration of the required sump monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

WOG STS B 3.4.15-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 361 of 479

Attachment 1, Volume 9, Rev. 0, Page 362 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 32 of 40 RCS Leakage Detection Instrumentation All changes are 1 B 3.4.15 unless otherwise noted BASES ACTIONS (continued) and 8

stet, with changes B.1.1, B.1.2, B.2.1, and B.2.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be for radioactivity taken and analyzed or water inventory balances, in accordance with 6 SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance stet performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity 8 monitors. Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system is OPERABLE, provided grab samples are taken or water inventory balances performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, [and RCP seal injection and return flows]). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30 day 8 Completion Time recognizes at least one other form of leakage detection stet is available.

grab samples of the 8

[ C.1 and C.2 containment atmosphere humidity 6

With the required containment air cooler condensate flow rate monitor taken and analyzed for radioactivity inoperable, alternative action is again required. Either SR 3.4.15.1 must be performed or water inventory balances, in accordance with 8 6 grab sample SR 3.4.13.1, must be performed to provide alternate periodic information.

analysis Provided a CHANNEL CHECK is performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or a water inventory balance is performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, reactor operation may continue while awaiting restoration of the containment air cooler 6 humidity condensate flow rate monitor to OPERABLE status.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect RCS LEAKAGE. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, [and RCP seal injection and return flows]).

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. ]

WOG STS B 3.4.15-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 362 of 479

Attachment 1, Volume 9, Rev. 0, Page 363 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 33 of 40 RCS Leakage Detection Instrumentation All changes are 1 B 3.4.15 unless otherwise noted BASES ACTIONS (continued)

[ D.1 and D.2 humidity With the required containment atmosphere radioactivity monitor and the 6

required containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monitor.

This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period. ]

C or E.1 and E.2 6 If a Required Action of Condition A, B, [C], or [D] cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D F.1 6

With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on instrument reliability and is reasonable for detecting off normal conditions.

WOG STS B 3.4.15-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 363 of 479

Attachment 1, Volume 9, Rev. 0, Page 364 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 34 of 40 RCS Leakage Detection Instrumentation 1

B 3.4.15 All changes are unless otherwise noted BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

and SR 3.4.15.3, [SR 3.4.15.4, and SR 3.4.15.5] 6 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of [18] months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

REFERENCES 1. 10 CFR 50, Appendix A, Section IV, GDC 30.

USAR, Section 4.1.3.2, GDC 16, 2

2. Regulatory Guide 1.45. "Monitoring Reactor Coolant Leakage."

U USAR, Section 6.5, Leakage Detection and Provisions

3. FSAR, Section [ ]. 6.5 for the Primary and Auxiliary Coolant Loops WOG STS B 3.4.15-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 9, Rev. 0, Page 364 of 479

Attachment 1, Volume 9, Rev. 0, Page 365 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 35 of 40 JUSTIFICATION FOR DEVIATIONS ITS 3.4.15 BASES, RCS LEAKAGE DETECTION INSTRUMENTATION

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

2. The ISTS lists GDC 30 of Appendix A to 10 CFR 50 as the reference document for the requirement that a means shall be provided for detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage. Per the information contained in USAR Section 1.8, 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 16, Monitoring Reactor Coolant Pressure Boundary, as the licensing reference document for the requirement that a means shall be provided for detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage.

3. Additional descriptive information has been added to the ITS Bases Background relative to the containment sump leakage measuring system.

4. The ISTS states that a 1°F increase in dew point is well within the sensitivity range of available instruments. The information in USAR Section 6.5.1.2.4 reflects that the humidity detection instrumentation should be sensitive to an incremental leakage equivalent of 2 to 10 gallons per minute (gpm).

5. The ISTS refers to the humidity level monitoring as an indirect alarm of indication to alert the operator to a potential problem. The humidity detection instrumentation at KPS is an indication only loop and provides no alarm function. Hence the deletion of the words "alarm or" in the sentence.

6. The ISTS states, in part, that the containment sump monitor in combination with a gaseous or particulate radioactivity monitor and a containment air cooler condensate flow rate monitor provide an acceptable minimum for meeting the LCO requirement of monitoring using diverse measurement means. At KPS, there is no air cooler condensate flow rate monitor. According to Section 6.5 of the Updated Safety Analysis Report (USAR), KPS uses the following five methods of detecting RCS leakage to containment: containment system air particulate monitor, containment radiogas monitor, humidity detector, containment sump leakage measuring system, and liquid inventory. Therefore, where applicable, the word "humidity" has replaced "air cooler condensate flow rate monitor" in the ISTS Bases and the humidity instrumentation is added to the Technical Specifications as a result of the conversion to ITS.

Therefore, all references to the air cooler condensate flow rate monitor, including ACTIONS and Surveillances, have been deleted. These changes are also consistent with changes made to the actual Specification.

Kewaunee Power Station Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 365 of 479

Attachment 1, Volume 9, Rev. 0, Page 366 of 479 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 36 of 40 JUSTIFICATION FOR DEVIATIONS ITS 3.4.15 BASES, RCS LEAKAGE DETECTION INSTRUMENTATION

7. The containment atmosphere radioactivity monitor channel designations for the gaseous monitor (Channel R12 or R21) and the particulate monitor (Channel R11) have been relocated from Item 19 Remarks column of CTS Table TS 4.1-1 to the ITS Bases LCO as a result of DOC LA01.

8. Change made to be consistent with change made to the Specification.

Kewaunee Power Station Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 366 of 479

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 37 of 40 Licensee Response/NRC Response/NRC Question Closure Id 3271 NRC Question RPG-008 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 5/26/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Added By Ravinder Grover Date Added 5/26/2010 2:39 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3271 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 38 of 40 ITS NRC Questions Id 2051 NRC Question RPG-009 Number Category Technical ITS Section 3.4 ITS Number 3.4.16 DOC Number JFD Number JFD Bases Number Page 380 Number(s)

NRC Reviewer Carl Schulten Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC In reviewing the consequential dose related RAI response provided by the Question licensee in ADAMS document ML101060517, the NRC needs further clarification and/or verification regarding the licensees response to RAI #2. The NRC staffs technical concern is related to the verification of the site specific TS value of 595

µCi/gm for DEX, as indicated in Attachment 1, Page 4, of the licensees response.

Specifically, the staff is NOT able to verify the values provided in Colum 2, AST Primary Coolant Noble Gas Concentrations. The values for the indicated radionuclides are not specifically indicated in the licensees AST submittal dated March 19, 2002 (ML0208705653), nor any supplements to this submittal.

Therefore, please indicate what docketed document do the above referenced values list in Column 2 come from for verification by the staff, or specifically explain how these values were calculated using docketed information from the licensees current dose analyses of record.

Attach File 1 Attach File 2 Issue Date 5/21/2010 Added By Ravinder Grover Date Modified Modified By Date Added 5/21/2010 8:14 AM Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2051 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 39 of 40 Licensee Response/NRC Response/NRC Question Closure Id 3211 NRC Question RPG-009 Number Select Licensee Response Application

Response

5/25/2010 10:20 AM Date/Time Closure Statement Response These values used in Column 2, AST Primary Coolant Noble Gas Statement Concentrations, are from the Stretch Power Uprate submittal (License Amendment Request (LAR) 195) which revised the alternate source term radiological analysis for Kewaunee. The submittal is located in ADAMS under package ML031540080. The specific information is located in Table 6.7-5 of the document identified by ADAMS Accession Number ML031530424, refer to page 40/141. This request was approved as License Amendment 172 on February 27, 2004 (ML040430633). DEK revised the Kewaunee radiological accident analysis another time under license amendment 190 (ML070430020) [LAR 211 (ML060540217)], which referenced the stretch uprate concentrations.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 5/25/2010 10:19 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3211 06/17/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 09 (Section 3.4) 40 of 40 Licensee Response/NRC Response/NRC Question Closure Id 3281 NRC Question RPG-009 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 5/26/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Ravinder Grover Added By Ravinder Grover Date Added 5/26/2010 2:40 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3281 06/17/2010