ML083290653

License Amendment, Issuance of Amendment No. 201 Shield Building and Auxiliary Building Special Ventilation Train Filter Heater Requirements

ML083290653
Person / Time
Site:	Kewaunee
Issue date:	12/30/2008
From:	Tam P Plant Licensing Branch III
To:	Christian D Dominion Energy Kewaunee
Tam P
References
TAC MD8545
Download: ML083290653 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 30, 2008 Mr. David A. Christian President and Chief Nuclear Officer Dominion Energy 5000 Dominion Boulevard Glen Allen, VA 23060-6711 SUB..IECT: KEWAUNEE POWER STATION - ISSUANCE OF AMENDMENT TO REMOVE SHIELD BUILDING AND AUXILIARY BUILDING SPECIAL VENTILATION TRAIN FILTER HEATER REQUIREMENTS (TAC NO. MD8545)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 201 to Facility Operating License No. DPR-43 for the Kewaunee Power Station. This amendment revises the Technical Specifications (TS) in response to your application April 4, 2008.

The amendment revises the TS by removing the operability and surveillance requirements for the shield building ventilation (SBV) and auxiliary building special ventilation filter train heaters, and reducing the operating time required to verify the SBV system operability from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

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v Peter S. Tam, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosures:

1. Amendment No. 201 to License No. DPR-43

2. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DOMINION ENERGY KEWAUNEE, INC.

DOCKET NO. 50-305 KEWAUNEE POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 201 License No. DPR-43

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Dominion Energy Kewaunee, Inc., dated April 4, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-43 is hereby amended to read as follows:

-2 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 201, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

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Lois M. James, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: December 30, 'Z008

ATTACHMENT TO LICENSE AMENDMENT NO. 201 FACILITY OPERATING LICENSE NO. DPR-43 DOCKET NO. 50-305 Replace the following page of the Facility Operating License No. DPR-43 with the attached revised page. The changed area is identified by a marginal line.

REMOVE INSERT Page 3 Page 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.6-3 3.6-3 4.4-1 4.4-1 4.4-2 4.4-2 4.4-3 4.4-3

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR, Chapter I: (1) Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70, (2) is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and (3) is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 1772 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 201, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection The licensee shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the licensee's Fire Plan, and as referenced in the Updated Safety Analysis Report, and as approved in the Safety Evaluation Reports, dated November 25, 1977, and December 12, 1978 (and supplement dated February 13, 1981) subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission, only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(4) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Nuclear Management Company Kewaunee Nuclear Power Plant Physical Security Plan (Revision 0)" submitted by letter dated October 18, as supplemented by letter dated October 21,2004, July 26,2005, and May 15, 2006.

(5) Deleted Amendment No. 4--tRR:f 201 Revised by letter dated May 7, 20013, August 22, 20013 3

2. Verify the affected flow path is isolated:

a) For isolation devices outside containment, at least once per 31 days, or b) For isolation devices inside containment, prior to entering INTERMEDIATE SHUTDOWN from COLD SHUTDOWN if not performed within the previous 92 days.

D. Valves and blind flanges in high radiation areas may be verified, as required by TS 3.6.b.3.A.2, TS 3.6.b.3.B.2, and TS 3.6.b.3.C.2, by use of administrative means.

4. If CONTAINMENT SYSTEM INTEGRITY is required and the OPERABILITY requirements of TS 3.6.b.3 are not met within the times specified, then initiate action to:

A. Achieve HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, B. Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and C. Achieve COLD SHUTDOWN within the subsequent 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

c. All of the following conditions shall be satisfied whenever CONTAII\JME I'JT SYSTEM INTEGRITY, as defined by TS 1.0.g, is required:

1. Both trains of the Shield Building Ventilation System, including filters, shall be OPERABLE or the reactor shall be shut down within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, except that when one of the two trains of the Shield Building Ventilation System is made or found to be inoperable for any reason, reactor operation is permissible only during the succeeding 7 days.

2. Both trains of the Auxiliary Building Special Ventilation System, including filters, shall be OPERABLE or the reactor shall be shut down within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, except that when one of the two trains of the Auxiliary Building Special Ventilation System is made or found to be inoperable for any reason, reactor operation is permissible only during the succeeding 7 days.

Amendment No. ~ 201 TS 3.6-3

4.4 CONTAINMENT TESTS APPLICABILITY Applies to integrity testing of the steel containment, shield building, auxiliary building special ventilation zone, and the associated systems including isolation valves.

OBJECTIVE To verify that leakage from the containment system is maintained within allowable limits in accordance with 10 CFR Part 50, Appendix J.

SPECIFICATION

a. Integrated Leak Rate Tests (Type A)

Perform required visual examinations and leakage rate testing in accordance with the Containment Leakage Rate Testing Program.

As a one-time change, the Type A test frequency specified in t\lEI 94-01, Revision 0, Paragraph 9.2.3, as " at least once per 10 years based on acceptable performance history" is changed to " at least once per 15 years based on acceptable performance history." This change applies only to the interval following the Type A test performed in April 1994.

b. Local Leak Rate Tests (Type B and C)

Perform required air lock, penetration, and containment isolation valve leakage testing in accordance with the Containment Leakage Rate Testing Program.

c. Shield Building Ventilation System

1. At least once per operating cycle or once every 18 months, whichever occurs first, the following conditions shall be demonstrated:

a. Pressure drop across the combined HEPA filters and charcoal adsorber banks is

< 10 inches of water and the pressure drop across any HEPA filter bank is

< 4 inches of water at the system design flow rate (+/-10%).

b. Automatic initiation of each train of the system.

c. Deleted Amendment No. ~ 201 TS 4.4-1

2. Shield Building Ventilation System Filter Testing

a. The in-place DOP test for HEPA filters shall be performed (1) at least once per 18 months and (2) after each complete or partial replacement of a HEPA filter bank or after any maintenance on the system that could affect the HEPA bank bypass leakage.

b. The laboratory tests for activated carbon in the charcoal filters shall be performed (1) at least once per 18 months for filters in a standby status or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of filter operation, and (2) following painting, fire, or chemical release in any ventilation zone communicating with the system.

c. Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of a charcoal adsorber bank or after any maintenance on the system that could affect the charcoal adsorber bank bypass leakage.

d. Each train shall be operated at least 15 minutes every month.

3. An air distribution test on these HEPA filter banks will be performed after any maintenance or testing that could affect the air distribution within the systems. The test shall be performed at design flow rate (+/-1 0%). The results of the test shall show the air distribution is uniform within +/-20%.(1)

4. Each train shall be determined to be operable at the time of its periodic test if it produces measurable indicated vacuum in the annulus within 2 minutes after initiation of a simulated safety injection signal and obtains equilibrium discharge conditions that demonstrate the Shield Building leakage is within acceptable limits.

(1) In WPS letter of August 25, 1976 to Mr. AI Schwencer (NRC) from Mr. E. W. James, we relayed test results for flow distribution for tests performed in accordance with ANSI N510 1975. This standard refers to flow distribution tests performed upstream of filter assemblies.

Since the test results upstream of filters were inconclusive due to high degree of turbulence, tests for flow distribution were performed downstream of filter assemblies with acceptable results (within 20%). The safety evaluation attached to Amendment 12 references our letter of August 25, 1976 and acknowledges acceptance of the test results.

Amendment l'Jo. 69, 106, 136 201 TS 4.4-2

d. Auxiliary Building Special Ventilation System

1. Periodic tests of the Auxiliary Building Special Ventilation System, including the door interlocks, shall be performed in accordance with TS 4.4.c.1 through TS 4.4.c.3, except for TS 4.4.c.2.d.

2. Each train of Auxiliary Building Special Ventilation System shall be operated at least 15 minutes every month.

3. Each system shall be determined to be operable at the ti'me of periodic test if it starts with coincident isolation of the normal ventilation ducts and produces a measurable vacuum throughout the special ventilation zone with respect to the outside atmosphere.

e. Containment Vacuum Breaker System The power-operated valve in each vent line shall be tested during each refueling outage to demonstrate that a simulated containment vacuum of 0.5 psig will open the valve and a simulated accident signal will close the valve. The check and butterfly valves will be leak tested in accordance with TS 4.4.b during each refueling, except that the pressure will be applied in a direction opposite to that which would occur post-LOCA.

f. Containment Isolation Device Position Verification

1. When the reactor is critical, verify each 36 inch containment purge and vent isolation valve is sealed closed every 31 days.

2. When the reactor is critical, verify each 2 inch containment vent isolation valve is closed every 31 days, except when the 2 inch containment vent isolation valves are open for pressure control, ALARA, or air quality considerations for personnel entry, or Surveillances that require the valves to be open.

3. Containment isolation manual valves and blind flanges shall be verified closed as specified in TS 4.4.f.3.a and TS 4.4.f.3.b, except as allowed by TS 4.4.f.3.c.

a. When greater than COLD SHUTDOWN, verify each containment isolation manual valve and blind flange that is located outside containment and required to be closed during accident conditions is closed every 31 days, except for containment isolation valves that are locked, sealed, or otherwise secured closed or open as allowed by TS 3.6.b.2.

Amendment No. +00 201 TS 4.4-3

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO AMENDMENT NO. 201 TO FACILITY OPERATING LICENSE NO. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION DOCKET NO. 50-305

1.0 INTRODUCTION

By letter dated April 4, 2008 (Agencywide Document Access and Management System (ADAMS) Accession No. ML080950469), Dominion Energy Kewaunee, Inc. (DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS).

This proposed amendment would modify the Technical Specifications (TS) to remove the operability and surveillance requirements (SRs) for the shield building ventilation (SBV) and auxiliary building special ventilation (ABSV) filter train heaters. Additionally, DEK is requesting a reduction in the operating time required to verify the SBV system operability from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes.

2.0 REGULATORY EVALUATION

The licensee addressed the regulatory requirements applicable to the proposed amendment in Section 5.2 of Attachment 1 to the application dated April 4, 2008. As described in this section and confirmed by the KPS Updated Safety Analysis Report (USAR), Section 1.3, "General Design Criteria", KPS was designed and constructed to meet the intent of the Atomic Energy Commission (AEC) General Design Criteria (GDC), as originally proposed in July 1967. Plant construction was about 50 percent complete and the Final Safety Analysis Report (FSAR) had been filed with the AEC before publication of the AEC Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, GDC in February 1971 and the present version of the GDC in July 1971. As a result, the AEC did not require DEK to reanalyze the plant or resubmit the FSAR. However, the AEC's Safety Evaluation (SE) of the KPS, dated 1972 and the supplements issued in 1973, did assess the plant against the GDC in effect at that time and concluded that the plant design generally conforms to the intent of the criteria. The licensee applied the following GDC that KPS is licensed to, as noted in the USAR:

Criterion 10- Containment Containment shall be provided. The containment structure shall be designed to sustain the initial effects of gross equipment failures, such as a large coolant boundary break Enclosure

-2 without loss of required integrity and, together with other engineered safety features as may be necessary, to retain for as long as the situation requires the functional capability to protect the public.

Criteria 37 - Engineered Safety Features Basis for Design Engineered Safety Features shall be provided in the facility to back up the safety provided by the core design, the reactor coolant pressure boundary, and their protection systems. As a minimum, such Engineered Safety Design Features shall be designed to cope with any size reactor coolant pressure boundary break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

The NRC staff also considered relevant information from the following:

Regulatory Guide (RG) 1.52, "Design, Inspections, and Testing Criteria for Air Filtration and Absorption Units of Post Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revision 3 (June 2001).

NRC Generic Letter (GL) 99-02, "Laboratory Testing of Nuclear Grade Activated Charcoal" (June 1999).

Requirements of 10 CFR 50.67, "Accident Source Term."

RG 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors."

American Society for Testing Materials (ASTM) Standard D3803-89, "Standard Test Method for Nuclear-Grade Activated Carbon."

3.0 TECHNICAL EVALUATION

The containment at KPS consists of a primary containment system and a secondary containment system. The primary containment, also known as the reactor containment vessel, consists of a low leakage steel shell, including all its penetrations, designed to confine the radioactive materials that could be released by a loss of integrity of the reactor coolant pressure boundary. The primary containment also houses the engineered safety feature (ESF) systems, including the containment isolation system. The principal function of the containment isolation system is to confine the fission products within the primary containment system boundary during post-accident conditions.

The secondary containment consists of the shield building, its associated ESF systems, and a special ventilation zone in the auxiliary building. The shield building is a reinforced concrete structure surrounding the reactor containment vessel. As stated in the KPS USAR, the shield building is designed to provide biological shielding for design-basis accident (DBA) conditions, and to house the reactor coolant system during normal operation. In addition, it provides a

-3 means for collection and filtration of fission-product leakage from the reactor containment vessel following a DBA. The SBV is the ESF used for this function. The ABSV system is designed to collect any potential containment system leakage that might bypass the shield building annulus (SBA) and pass it through HEPAIcharcoal filters before exhausting to the environment.

The SBV system consists of two full-capacity redundant fan and filter trains. Each train consists of a demister, pre-filter, electric heater, absolute filter, charcoal filter, a final absolute "filter, and one fan. The system takes suction from the SBA and is designed with the capability to either exhaust or recirculate the air, or perform a combination of both. The discharge for each fan splits into two flow paths, Le., the exhaust and recirculation paths. The exhaust flow is directed to the outside environment through the vent stack located in the SBA and the recirculation flow is returned to the SBA. The system is started automatically on a safety injection signal following a loss-of-coolant accident, or by manual initiation from the control room. The initiating signal starts the SBV fan, energizes the heater, places the system dampers in the required positions and rapidly draws down the annulus pressure operating in the exhaust mode. At a pressure of 1.0 inch water column in the shield building, the control dampers in the recirculation and exhaust paths will receive a permissive signal to modulate. The dampers will modulate to compensate for any increased annulus in-leakage, thus maintaining a slight vacuum in the SBA.

The heating elements in the filter train are designed to increase the temperature of the incoming air by a sufficient amount to assure a maximum 70 percent relative humidity entering the charcoal bed with an assumed 100 percent saturated air entering the demisters at rated conditions.

The ABSV system serves the areas within the auxiliary building where there is potential for any inleakage from the SBA. Such areas in the auxiliary building are designated as Zone SV. The ABSV system also consists of redundant fan and filter trains. Each train consists of a pre-filter, electric heater, absolute filter, charcoal filter, a final absolute filter, and an exhaust fan. Zone SV pressure is controlled by weighted back-draft dampers that recirculate a portion of the exhaust air at a pressure of approximately 0.25 inch water column, thus maintaining a slight negative pressure in Zone SV. The ABSV system is started automatically on a safety injection signal, a high radiation signal in the auxiliary building exhaust stack or a steam exclusion Zone SV area isolation signal. Activation of the ABSV system automatically isolates the normal supply and exhaust ducts and the associated fans to the auxiliary building. The ABSV electric heating elements are capable of sufficiently increasing the incoming air temperature to ensure a maximum 70 percent relative humidity entering the charcoal filter bed assuming an entering relative humidity of 80 percent entering the heaters.

The licensee proposed an amendment to the KPS TS to remove the operability and SRs for the heaters in the SBV and ABSV filter trains. In addition, the licensee requested a reduction in the operating time required to demonstrate the SBV system operability from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes.

The licensee stated that the proposed changes are part of its efforts to increase margin in the post-accident loading of the KPS emergency diesel generators. The licensee also stated that de-energizing the ABSV heaters will increase the margin between the ambient temperature limitations of certain safety-related equipment and the calculated maximum post-accident ambient temperature for this equipment. The NRC staff reviewed the licensee's regulatory and technical analyses in support of the proposed change and the results of the review are provided below.

-4 3.1 Propose Changes to TS 3.6. "Containment System" The licensee proposed to change the conditions to be satisfied whenever "containment system integrity," as defined by TS 1.0.g, is required. One of the conditions (TS 1.0.g.6) specifies that the "Shield Building Ventilation System and the Auxiliary Building Special Ventilation System satisfy the requirements of TS 3.6.c." The licensee proposed to revise TS 3.6.c.1 as follows:

"both trains of the Shield Building Ventilation system, including filters, and heaters shall be OPERABLE" (i.e., deleting reference to heaters). Similarly, the licensee proposed to revise TS 3.6.c.2 as follows: "both trains of the Auxiliary Building Special Ventilation System, including filters, and heaters shall be OPERABLE" (i.e., deleting reference to heaters).

The licensee's analysis in support of the proposed change is contained in section 4.1 of to the April 4, 2008, application. The licensee stated that the TS provides acceptance criteria for the performance of the SBV and ABSV filters to ensure post-accident consequences remain within the regulatory criteria, and for KPS, these criteria are contained in 10 CFR 50.67, "Accident Source Term." This regulation provides the criteria for dose limits for individuals located in the exclusion area, low population zone, and to permit access to and occupancy of the control room for licensees who wish to use an alternate source term methodology. To meet these criteria, the licensee has used a method acceptable to the Nuclear Regulatory Commission (NRC) staff that is contained in RG 1.183. The licensee was previously granted approval of the alternate radiological accident analysis in Amendment No. 190 (ADAMS Accession No. ML070430020). In this analysis, the licensee used a maximum charcoal adsorber filter iodine removal efficiency of 95 percent for the SBV and ABSV filter trains.

NRC Generic Letter (GL) 99-02 stated that (1) the laboratory test acceptance criteria contain a safety factor to ensure that the efficiency assumed in the radiological consequence analysis is still valid at the end of the operating cycle; (2) because ASTM 03803-1989 "Standard Test Method for Nuclear-Grade Activated Carbon" is a more accurate and demanding test than older tests, licensees that upgrade their TS to this new protocol will be able to use a safety factor as low as 2 for determining the acceptance criteria for charcoal filter efficiency; and (3) this safety factor can be used for systems with or without humidity control because the lack of humidity control is already accounted for in the test conditions (systems without humidity control can test at 95 percent relative humidity and systems with humidity control can test at 70 percent relative humidity). KPS TS 3.6.c.3.B acceptance criteria for iodine removal efficiency for SBV and ABSV charcoal is ~ 97.5 percent when tested in accordance with ASTM 03803-89 at conditions of 30° C and 95 percent relative humidity, while the KPS radiological analyses assumed 95 percent iodine removal. Therefore, the NRC staff finds that OEK has upgraded to ASTM 03803-1989 and that the penetration and relative humidity acceptance criteria resulted from, and is reflective of, OEK using a safety factor of 2 in accordance with the guidance provided in GL 99-02, without crediting the heaters. The NRC staff finds that the offsite and control room dose analyses are not affected by the proposed change, and that they will remain within the limits of 10 CFR 50.67 and RG 1.183. Therefore, the staff finds that the requested change to delete the operability requirements for the SBV and ABSV heaters acceptable.

3.1.2 Proposed Changes to TS 4.4, "Containment Tests" The licensee proposed to delete the SBV system heater SR TS 4.4.c.1.c, which specifies that "Operability of heaters at rating and the absence of defects by visual observation" in its entirety.

-5 According to SR 4.4.c.1, this requirement shall be demonstrated at least once per operating cycle or once every 18 months, whichever occurs first.

The purpose of TS 4.4.c.1.c is to demonstrate the capability of humidity control for the SBV system. As stated above, the licensee has shown that there is no need for humidity control and the NRC staff has found the requested change to delete the operability requirements for the SBV system filter train heater acceptable. It is, therefore, logical to delete the associated SR for testing the heaters. The NRC staff finds the requested change acceptable.

The licensee proposed to revise the SR for the SBV filter testing in TS 4.4.c.2.d from "each train shall be operated with the heaters on at least 1a hours every month" to "each train shall be operated at least 15 minutes every month." The licensee also proposed to revise the SR for the ABSV system in TS 4.4.d.2 from "each train of Auxiliary Building Special Ventilation System shall be operated with the heaters on at least 15 minutes every month" to "each train of Auxiliary Building Special Ventilation System shall be operated at least 15 minutes every month."

The removal of the filter train heater from the SRs in TS 4.4.c.2.d for the SBV system and TS 4.4.d.2 for the ABSV system is acceptable, because the licensee has shown that there is no need for humidity control and the NRC staff has found the deletion of the heaters from the operability requirements of the TS to be acceptable.

The licensee stated that the requirement to operate the SBV train with the heaters on has been in the TS since Amendment No. 12, issued in January of 1977. Prior to the issuance of Amendment No. 12, a similar 1a-hour run for the ABSV system was reduced to 15 minutes as requested by KPS staff, and approved by the NRC staff (letter, A. Schwencer to E. W. James, January 18, 1977). The licensee requested this change back to 15 minutes because operating the ABSV system requires the shutdown of normal auxiliary building ventilation system causing other operational concerns.

The primary purpose of the requirement to operate the heaters for 1a continuous hours in humidity control systems is to remove moisture from charcoal adsorbers and to justify the operability of the system. The NRC staff has determined that carbon adsorbers in ESF systems will remain sufficiently moisture-free to perform as assumed in the radiological consequence analysis without conducting the heater test for 1a continuous hours each month, and that a 15 minute test each month is adequate to justify the operability of systems. This position is affirmed in RG 1.52, Rev. 3, Position 6.1, which states that "each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with heaters on (if so equipped), to justify the operability of the system and all its components." As indicated above, the licensee has proposed to remove the SBV heaters from the operability and SRs of the KPS TS, and the NRC staff has found the proposed changes acceptable. The currently required testing methodology for the ABSV and SBV verifies charcoal adsorber iodine removal efficiency is greater than assumed in the KPS radiological consequence analysis without crediting heaters. The NRC staff finds the proposed change to operate the SBV system train for 15 minutes is consistent with the position stated in RG 1.52, Rev. 3, and is, therefore, acceptable.

-6 3.2 Summary of Evaluation As set forth above, the NRC staff reviewed the regulatory and technical analyses used by the licensee in support of the proposed amendment. The NRC staff finds that the proposed TS changes will have no adverse impact on the contribution of SBV and ABSV systems in satisfying the GDCs noted in Section 2.0 of this safety evaluation. Further, the NRC staff finds that the proposed TS changes consistent with the guidance conveyed by the guidance documents listed in Section 2.0 of this SE. Therefore, the proposed TS changes to delete the SBV and ABSV filter train heaters from the operability and SRs are acceptable to the NRC staff.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Wisconsin State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (73 FR 31720). Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the pUblic.

Principal Contributor: N. Karipineri, NRR Date: December 30, 2008

Mr. David A. Christian December 30, 2008 President and Chief Nuclear Officer Dominion Energy 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

KEWAUNEE POWER STATION - ISSUANCE OF AMENDMENT TO REMOVE SHIELD BUILDING AND AUXILIARY BUILDING SPECIAL VENTILATION TRAIN FILTER HEATER REQUIREMENTS (TAC NO. MD8545)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 201 to Facility Operating License No. DPR-43 for the Kewaunee Power Station. This amendment revises the Technical Specifications (TS) in response to your application April 4, 2008.

The amendment revises the TS by removing the operability and surveillance requirements for the shield building ventilation (SBV) and auxiliary building special ventilation filter train heaters, and reducing the operating time required to verify the SBV system operability from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, IRA!

Peter S. Tam, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosures:

1. Amendment No. 201 to License No. DPR-43

2. Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:

PUBLIC RidsAcrsAcnw_MailCTR Resource LPL3-1 r/f RidsNrrDirsltsb Resource RidsNrrDorlDpr Resource RidsOgcRp Resource RidsNrrDorlLpl3-1 Resource RidsNrrPMKewaunee Resource N. Karipineni, NRR RidsNrrLABTully Resource RidsRgn31\.J1ailCenter Resource ADAMS Accession No. ML083290653 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRRlSCVB/BC NRR/ITSB/BC OGC NRRlLPL3-1/BC NAME PTam BTuily RDennig RElliott MBaty LJames DATE 12/11/08 12/9/08 11/13/08 12/17/08 12/15/08 12/30/08

• SE transmitted by memo of 11/13/08 OFFICIAL RECORD COpy