ML102370390
| ML102370390 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 07/16/2010 |
| From: | Dominion Energy Kewaunee |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| 10-428 | |
| Download: ML102370390 (169) | |
Text
ITS NRC Questions Id1591NRC Question Number KAB-069 Category Technical ITS Section 3.3 ITS Number 5.5.16 DOC Number JFD Number JFD Bases Number Page Number(s) 102 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 102 of Attachment 1, volume 16, ins ert 8 is not consistent with TSTF-493, Revision 4, including applicable errata. Please correct the TS 5.5.16, Setpoint Control Program or provide an explanation of the changes. Attach File 1 Attach File 2 Issue Date 1/26/2010 Added By Kristy Bucholtz Date Modified Modified By Date Added 1/26/2010 10:36 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1591 Licensee Response/NRC Response/NRC Question Closure Id2101 NRC Question Number KAB-069 Select Application Licensee Response Response Date/Time 2/9/2010 7:20 AM Closure Statement Response Statement The Kewaunee Power Station (KPS) ITS Amendment was based upon the most current revision of TSTF-493 at the time of submittal. Since the date of the submittal, a newer revision (Rev. 4) of the TSTF has been sent to the NRC for review. KPS has reviewed this revision and appropriate changes will be made. 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 1 KAB-069 Markup.pdf (754KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 2/9/2010 7:20 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2101 5.5 Insert Page 5.5-18a INSERT 8 5.5.18 Setpoint Control Program This program shall establish the requirements for ensuring that setpoints for automatic protective devices are initially within and remain within the technical specification requirements. This program provides a means for processing changes to instrumentation setpoints and identifies setpoint methodologies to ensure instrumentation will function as required. The program also ensures that testing of automatic protective devices re lated to variables having significant
safety functions as delineated by 10 CFR 50.36(c)(1)(ii)(A) verify that instrumentation will function as required.
- a. The program shall list the Functions in the following specifications to which it applies:
- 1. LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation";
Instrumentation Functions";
- 4. LCO 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation";
Actuation Instrumentation;" 6. LCO 3.3.8, "Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation;" 7. LCO 3.3.9, "Boron Dilution Protection System (BDPS)." b. The program shall require the Nominal Trip Setpoint (NTSP), Allowable Value (AV), As-Found Tolerance (AFT), and As-Left Tolerance (ALT) (as applicable) of the Functions described in Paragraph a. are calculated using the NRC approved setpoint methodology, as listed below. In addition, the program shall contain the value of the NTSP, AV, AFT, or ALT (as applicable) for each Function described in parag raph a. and shall identify the setpoint methodology used to calculate these values.
1 25 26 16 Protection P Offsite O Post Accident Recirculation (CRPAR) CTS DOC M11 Vent ." and assumptions of the applicable safety analyses, shall 5.5 Insert Page 5.5-18b INSERT 8 (continued)
Reviewer's Note ---------------------------------------
List the NRC safety evaluation report by letter, date, and ADAMS accession
number that approved the setpoint methodologies.
- 1. [Insert reference to NRC safety evaluation that approved the setpoint methodology.]
- c. The program shall establish methods to ensure that Functions described in Paragraph a. will function as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology.
REVIEWERS NOTE --------------------------------------
A license amendment request to implement a Setpoint Control Program must list the instrument functions to which the program requirements of paragraph
- d. will be applied. Paragraph d shall apply to all Functions in the Reactor Trip System and Engineered Safety Feature Actuation System specifications unless one or more of the following exclusions apply: 1. Manual actuation circuits, automatic actuation logic circuits or to instrument functions that derive i nput from contacts which have no associated sensor or adjustable dev ice, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded. In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded. 2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program. 3. Functions and Surveillance Requirements which test only digital components are excluded. There is no expected change in result between SR performances for these components. Where separate as-left and as-found tolerance is established for digital component SRs, the requirements would apply. ----------------------------------------------------------------------------------------------------
13 1 15 1 CTS DOC M11 Technical Report EE-0116, Revision 5, "Allowable Values for North Anna Improved Technical Specifications (ITS) Table 3.3.1-1 and 3.3.2-1, Setting Limits for Surry Custom Technical Specifications (CTS), Sections 2.3 and 3.7, and Allowable Values for Kewaunee Power Station Improved Technical Specifications (ITS) Functions listed in Specification 5.5.16." (if available) d.6 5.5 Insert Page 5.5-18c INSERT 8 (continued)
- d. The program shall identify the Functi ons described in Paragraph a. that are automatic protective devices related to variables having significant safety
functions as delineated by 10 CFR 50.36(c)(1)(ii)(A). The NTSP of these Functions are Limiting Safety System Settings. These Functions shall be demonstrated to be functioning as required by applying the following requirements during CHANNEL CALIBRATIONS, CHANNEL OPERATIONAL TESTS, and TRIP ACTUATING DEVI CE OPERATIONAL TESTS that verify the NTSP.
- 1. The as-found value of the instrument channel trip setting shall be compared with the previous as-left value or the specified NTSP.
- 2. If the as-found value of the instrument channel trip setting differs from the previous as-left value or the specif ied NTSP by more than the pre-defined test acceptance criteria band (i.e., the specified AFT), then the instrument channel shall be evaluated before declaring the SR met and returning the instrument channel to service. This condition shall be entered in the plant corrective action program.
- 3. If the as-found value of the instrument channel trip setting is less conservative than the specified AV, then the SR is not met and the instrument channel shall be immediately declared inoperable.
- 4. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the NTSP at the completion of the surveillance test; otherwise, the channel is inop erable. Setpoints may be more conservative than the NTSP provided that the as-found and as-left
tolerances apply to the actual s etpoint used to confirm channel performance.
- e. Changes to the program shall be made in accordance with the requirements of 10 CFR 50.59.
- 1. Revisions or supplements to the program shall be provided to the NRC.
1 CTS DOC M11 (setpoints
)upon issuance Licensee Response/NRC Response/NRC Question Closure Id2231 NRC Question Number KAB-069 Select Application NRC Response Response Date/Time 2/18/2010 6:00 PM Closure Statement Response Statement Kewaunee's markup is consistent with TSTF 493 revision 4 and errata, with a few exceptions. Please change TS 5.5.16.b.1 to the following phrase, "NRC safety evaluation dated " and move the proposed insert to 5.5.16.b.1 into paragraph 5.5.16.e. Please change TS 5.5.16.e to the following phrase, "The program shall be specified in [insert technical report insert from TS 5.5.16.b.1]" from Attachment 1, Volume 8, Pages 103 and 104 of 517 to be consistent with TSTF 493 errata. Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 2/18/2010 7:57 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2231 Licensee Response/NRC Response/NRC Question Closure Id2361 NRC Question Number KAB-069 Select Application Licensee Response Response Date/Time 3/1/2010 3:30 PM Closure Statement Response Statement KPS has reviewed the errata to TSTF-493, Rev. 4 and determined that the draft markup attached to the previous KPS response to KAB-069 did not include the NRC reviewer's requested change. In lieu of the NRC reviewer recommended wording for ITS 5.5.16.e to include the program name from what is specified in the originally submitted ITS 5.5.16.b.1 (i.e., Technical Report EE-0116), the TSTF errata allows the name of a document incorporated by reference into the facility FSAR. KPS will specify the Technical Requirements Manual (TRM) as the document. The TRM is currently referenced in the KPS USAR. Using the TRM as the reference document is also consistent with many other CTS requirements that are being relocated to the TRM as part of the ITS conversion. A draft markup regarding these changes is attached, and supersedes the previous draft markup. Changes from the previous markup are identified in green (see pages 2 and 3 of the attachment). These changes will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1 KAB-069 Rev 1 Markup (7).pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Robert Hanley Jerry Jones Bryan Kays Added By David Mielke Date Added 3/1/2010 3:33 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2361 5.5 Insert Page 5.5-18a INSERT 8 5.5.18 Setpoint Control Program This program shall establish the requirements for ensuring that setpoints for automatic protective devices are initially within and remain within the technical specification requirements. This program provides a means for processing changes to instrumentation setpoints and identifies setpoint methodologies to ensure instrumentation will function as required. The program also ensures that testing of automatic protective devices re lated to variables having significant
safety functions as delineated by 10 CFR 50.36(c)(1)(ii)(A) verify that instrumentation will function as required.
- a. The program shall list the Functions in the following specifications to which it applies:
- 1. LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation";
Instrumentation Functions";
- 4. LCO 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation";
Actuation Instrumentation;" 6. LCO 3.3.8, "Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation;" 7. LCO 3.3.9, "Boron Dilution Protection System (BDPS)." b. The program shall require the Nominal Trip Setpoint (NTSP), Allowable Value (AV), As-Found Tolerance (AFT), and As-Left Tolerance (ALT) (as applicable) of the Functions described in Paragraph a. are calculated using the NRC approved setpoint methodology, as listed below. In addition, the program shall contain the value of the NTSP, AV, AFT, or ALT (as applicable) for each Function described in parag raph a. and shall identify the setpoint methodology used to calculate these values.
1 25 26 16 Protection P Offsite O Post Accident Recirculation (CRPAR) CTS DOC M11 Vent ." and assumptions of the applicable safety analyses, shall 5.5 Insert Page 5.5-18b INSERT 8 (continued)
Reviewer's Note ---------------------------------------
List the NRC safety evaluation report by letter, date, and ADAMS accession
number that approved the setpoint methodologies.
- 1. [Insert reference to NRC safety evaluation that approved the setpoint methodology.]
- c. The program shall establish methods to ensure that Functions described in Paragraph a. will function as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology.
REVIEWERS NOTE --------------------------------------
A license amendment request to implement a Setpoint Control Program must list the instrument functions to which the program requirements of paragraph
- d. will be applied. Paragraph d shall apply to all Functions in the Reactor Trip System and Engineered Safety Feature Actuation System specifications unless one or more of the following exclusions apply: 1. Manual actuation circuits, automatic actuation logic circuits or to instrument functions that derive i nput from contacts which have no associated sensor or adjustable dev ice, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded. In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded. 2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program. 3. Functions and Surveillance Requirements which test only digital components are excluded. There is no expected change in result between SR performances for these components. Where separate as-left and as-found tolerance is established for digital component SRs, the requirements would apply. ----------------------------------------------------------------------------------------------------
13 1 15 1 CTS DOC M11 Technical Report EE-0116, Revision 5, "Allowable Values for North Anna Improved Technical Specifications (ITS) Table 3.3.1-1 and 3.3.2-1, Setting Limits for Surry Custom Technical Specifications (CTS), Sections 2.3 and 3.7, and Allowable Values for Kewaunee Power Station Improved Technical Specifications (ITS) Functions listed in Specification 5.5.16." (if available) d.6 NRC Safety Evaluation dated [ ].
5.5 Insert Page 5.5-18c INSERT 8 (continued)
- d. The program shall identify the Functi ons described in Paragraph a. that are automatic protective devices related to variables having significant safety
functions as delineated by 10 CFR 50.36(c)(1)(ii)(A). The NTSP of these Functions are Limiting Safety System Settings. These Functions shall be demonstrated to be functioning as required by applying the following requirements during CHANNEL CALIBRATIONS, CHANNEL OPERATIONAL TESTS, and TRIP ACTUATING DEVI CE OPERATIONAL TESTS that verify the NTSP.
- 1. The as-found value of the instrument channel trip setting shall be compared with the previous as-left value or the specified NTSP.
- 2. If the as-found value of the instrument channel trip setting differs from the previous as-left value or the specif ied NTSP by more than the pre-defined test acceptance criteria band (i.e., the specified AFT), then the instrument channel shall be evaluated before declaring the SR met and returning the instrument channel to service. This condition shall be entered in the plant corrective action program.
- 3. If the as-found value of the instrument channel trip setting is less conservative than the specified AV, then the SR is not met and the instrument channel shall be immediately declared inoperable.
- 4. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the NTSP at the completion of the surveillance test; otherwise, the channel is inop erable. Setpoints may be more conservative than the NTSP provided that the as-found and as-left
tolerances apply to the actual s etpoint used to confirm channel performance.
- e. Changes to the program shall be made in accordance with the requirements of 10 CFR 50.59.
- 1. Revisions or supplements to the program shall be provided to the NRC.
1 CTS DOC M11 (setpoints
)upon issuance The program shall be specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by
reference].
the Technical Requirements Manual Licensee Response/NRC Response/NRC Question Closure Id2921 NRC Question Number KAB-069 Select Application Licensee Response Response Date/Time 5/11/2010 2:10 PM Closure Statement Response Statement As requested by the NRC Reviewer on a recent phone call, KPS has reviewed the second errata to TSTF-493, Rev. 4 and will make the changes specified in the errata. A draft markup regarding these changes is attached, and supersedes the previous draft markup. Changes from the previous markup are identified by the notation "Errata 2 change" (See pages 1 and 2). These changes will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1 KAB-069 Second Markup.pdf (2MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 5/11/2010 2:16 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2921 5.5 Insert Page 5.5-18a INSERT 8 5.5.18 Setpoint Control Program This program shall establish the requirements for ensuring that setpoints for automatic protective devices are initially within and remain within the technical specification requirements. This program provides a means for processing changes to instrumentation setpoints and identifies setpoint methodologies to ensure instrumentation will function as required. The program also ensures that testing of automatic protective devices re lated to variables having significant
safety functions as delineated by 10 CFR 50.36(c)(1)(ii)(A) verify that instrumentation will function as required.
- a. The program shall list the Functions in the following specifications to which it applies:
- 1. LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation";
Instrumentation Functions";
- 4. LCO 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation";
Actuation Instrumentation;" 6. LCO 3.3.8, "Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation;" 7. LCO 3.3.9, "Boron Dilution Protection System (BDPS)." b. The program shall require the Nominal Trip Setpoint (NTSP), Allowable Value (AV), As-Found Tolerance (AFT), and As-Left Tolerance (ALT) (as applicable) of the Functions described in Paragraph a. are calculated using the NRC approved setpoint methodology, as listed below. In addition, the program shall contain the value of the NTSP, AV, AFT, or ALT (as applicable) for each Function described in parag raph a. and shall identify the setpoint methodology used to calculate these values.
1 25 26 16 Protection P Offsite O Post Accident Recirculation (CRPAR) CTS DOC M11 Vent ." and assumptions of the applicable safety analyses, shall list Errata 2 change 5.5 Insert Page 5.5-18b INSERT 8 (continued)
Reviewer's Note ---------------------------------------
List the NRC safety evaluation report by letter, date, and ADAMS accession
number that approved the setpoint methodologies.
- 1. [Insert reference to NRC safety evaluation that approved the setpoint methodology.]
- c. The program shall establish methods to ensure that Functions described in Paragraph a. will function as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology.
REVIEWERS NOTE --------------------------------------
A license amendment request to implement a Setpoint Control Program must list the instrument functions to which the program requirements of paragraph
- d. will be applied. Paragraph d shall apply to all Functions in the Reactor Trip System and Engineered Safety Feature Actuation System specifications unless one or more of the following exclusions apply: 1. Manual actuation circuits, automatic actuation logic circuits or to instrument functions that derive i nput from contacts which have no associated sensor or adjustable dev ice, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded. In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded. 2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program. 3. Functions and Surveillance Requirements which test only digital components are excluded. There is no expected change in result between SR performances for these components. Where separate as-left and as-found tolerance is established for digital component SRs, the requirements would apply. ----------------------------------------------------------------------------------------------------
13 1 15 1 CTS DOC M11 Technical Report EE-0116, Revision 5, "Allowable Values for North Anna Improved Technical Specifications (ITS) Table 3.3.1-1 and 3.3.2-1, Setting Limits for Surry Custom Technical Specifications (CTS), Sections 2.3 and 3.7, and Allowable Values for Kewaunee Power Station Improved Technical Specifications (ITS) Functions listed in Specification 5.5.16." (if available) d.6 NRC Safety Evaluation dated [ ].
If the as-found value of the instrument channel trip setting is less conservative than
the specified AV, then the SR is not met and
the instrument channel shall be immediately
declared ino p erable.Errata 2 change 5.5 Insert Page 5.5-18c INSERT 8 (continued)
- d. The program shall identify the Functi ons described in Paragraph a. that are automatic protective devices related to variables having significant safety
functions as delineated by 10 CFR 50.36(c)(1)(ii)(A). The NTSP of these Functions are Limiting Safety System Settings. These Functions shall be demonstrated to be functioning as required by applying the following requirements during CHANNEL CALIBRATIONS, CHANNEL OPERATIONAL TESTS, and TRIP ACTUATING DEVI CE OPERATIONAL TESTS that verify the NTSP.
- 1. The as-found value of the instrument channel trip setting shall be compared with the previous as-left value or the specified NTSP.
- 2. If the as-found value of the instrument channel trip setting differs from the previous as-left value or the specif ied NTSP by more than the pre-defined test acceptance criteria band (i.e., the specified AFT), then the instrument channel shall be evaluated before declaring the SR met and returning the instrument channel to service. This condition shall be entered in the plant corrective action program.
- 3. If the as-found value of the instrument channel trip setting is less conservative than the specified AV, then the SR is not met and the instrument channel shall be immediately declared inoperable.
- 4. The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the NTSP at the completion of the surveillance test; otherwise, the channel is inop erable. Setpoints may be more conservative than the NTSP provided that the as-found and as-left
tolerances apply to the actual s etpoint used to confirm channel performance.
- e. Changes to the program shall be made in accordance with the requirements of 10 CFR 50.59.
- 1. Revisions or supplements to the program shall be provided to the NRC.
1 CTS DOC M11 (setpoints
)upon issuance The program shall be specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by
reference].
the Technical Requirements Manual Licensee Response/NRC Response/NRC Question Closure Id2561NRC Question Number KAB-069 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 Date 3/15/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 3/15/2010 10:41 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/10/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2561 Licensee Response/NRC Response/NRC Question Closure Id2981NRC Question Number KAB-069 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 Date 5/13/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 5/13/2010 8:48 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2981 ITS NRC Questions Id931 NRC Question Number VGC-001 Category Editorial ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number 13l15 JFD Bases Number Page Number(s) 103 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question "In Attachment 1, Vol 16, Rev 0, Page 103 of 167 for ISTS 5.5.16 Setpoint Control Program a reviewer's Note is struck in accordance with JFD 13. It appears that the correct JFD for this item is JFD 15. JFD 13 was previously used to justify deletion of a Reviewer's Note and two non-applicable procedures in ISTS 5.5.9 Steam Generator (SG) Program on page 88 of 167. Please confirm what appears to be a typo." Attach File 1 Attach File 2 Issue Date 11/3/2009 Added By Victor Cusumano Date Modified Modified By Date Added 11/3/2009 12:11 PM Notification NRC/LICENSEE Supervision Kristy Bucholtz Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=931 Licensee Response/NRC Response/NRC Question Closure Id551 NRC Question Number VGC-001 Select Application Licensee Response Response Date/Time 11/3/2009 1:10 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) agrees that in , Volume 16, Page 103 of 167, the JFD referenced for the deletion of the ISTS 5.5.18 (ITS 5.5.16) Reviewer's Note is a typographical error and should be JFD 15, not JFD 13. 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 1 VGC-001 Markup.pdf (291KB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Robert Hanley Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 11/3/2009 1:12 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=551 5.5 Insert Page 5.5-18b INSERT 8 (continued)
Reviewer's Note ---------------------------------------
List the NRC safety evaluation report by letter, date, and ADAMS accession
number that approved the setpoint methodologies.
- 1. [Insert reference to NRC safety evaluation that approved the setpoint methodology.]
- c. The program shall establish methods to ensure that Functions described in Paragraph a. will function as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology.
REVIEWERS NOTE --------------------------------------
A license amendment request to implement a Setpoint Control Program must list the instrument functions to which the program requirements of paragraph
- d. will be applied. Paragraph d shall apply to all Functions in the Reactor Trip System and Engineered Safety Feature Actuation System specifications unless one or more of the following exclusions apply: 1. Manual actuation circuits, automatic actuation logic circuits or to instrument functions that derive i nput from contacts which have no associated sensor or adjustable dev ice, e.g., limit switches, breaker position switches, manual actuation switches, float switches, proximity detectors, etc. are excluded. In addition, those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function are excluded. 2. Settings associated with safety relief valves are excluded. The performance of these components is already controlled (i.e., trended with as-left and as-found limits) under the ASME Code for Operation and Maintenance of Nuclear Power Plants testing program. 3. Functions and Surveillance Requirements which test only digital components are excluded. There is no expected change in result between SR performances for these components. Where separate as-left and as-found tolerance is established for digital component SRs, the requirements would apply. ----------------------------------------------------------------------------------------------------
13 1 15 1 CTS DOC M11 Technical Report EE-0116, Revision 5, "Allowable Values for North Anna Improved Technical Specifications (ITS) Table 3.3.1-1 and 3.3.2-1, Setting Limits for Surry Custom Technical Specifications (CTS), Sections 2.3 and 3.7, and Allowable Values for Kewaunee Power Station Improved Technical Specifications (ITS) Functions listed in Specification 5.5.16." 15 Licensee Response/NRC Response/NRC Question Closure Id561NRC Question Number VGC-001 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed. The response and draft corrected markup are adequate. Vic Cusumano Response Statement Question Closure Date 11/6/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Robert Elliott Added By Victor Cusumano Date Added 11/6/2009 7:47 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=561 ITS NRC Questions Id1041NRC Question Number VGC-002 Category Technical ITS Section 5.0 ITS Number 5.6 DOC Number JFD Number JFD Bases Number Page Number(s) Attachment 1, Volume 16 page 126 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In specification 5.6.4, Post Accident Monitoring Report, tw o conditions are identified from LCO 3.3.3, Condition B or F. In LCO 3.3.3, Condition F is shown as being deleted, (Attachment 1 Volume 8). Is condition F of LCO 3.3.3 being deleted or should it be removed from specification 5.6.4 or is there another explanation, please explain.
Attach File 1 Attach File 2 Issue Date 11/13/2009 Added By Victor Cusumano Date Modified Modified By Date Added 11/13/2009 2:46 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1041 Licensee Response/NRC Response/NRC Question Closure Id791 NRC Question Number VGC-002 Select Application Licensee Response Response Date/Time 11/16/2009 4:10 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) agrees that in , Volume 16, Page 126 of 167, the reference to ITS 3.3.3 Condition F should be deleted, as it is not being included in ITS 3.3.3. A new JFD (JFD 8) has been written to justify the change. Furthermore, a typographical error was noted in the CTS reference for ITS 5.6.4. The CTS cross reference should be M02, not M01. 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 1 VGC-002 Markup.pdf (733KB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 11/16/2009 4:12 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=791 Reporting Requirements 5.6 WOG STS 5.6-4 Rev. 3.1, 12/01/05 5.6 Reporting Requirements
5.6.5 Post Accident Monitoring Report
When a report is required by Condition B or F of LCO 3.3.[3], "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for
restoring the instrumentation channels of the Function to OPERABLE status.
5.6.6 [ Tendon Surveillance Report
Any abnormal degradation of the containment structure detected during the tests required by the Pre-stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a description of the tendon condition, the condi tion of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken. ]
5.6.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, "Steam Generator (SG) Program." The report shall include:
- a. The scope of inspections performed on each SG,
- b. Active degradation mechanisms found,
- c. Nondestructive examination techniques utilized for each degradation mechanism, d. Location, orientation (if linear), and m easured sizes (if available) of service induced indications, e. Number of tubes plugged [or repaired] during the inspection outage for each active degradation mechanism,
- f. Total number and percentage of tubes plugged [or repaired] to date,
- g. The results of condition monitoring, including the results of tube pulls and in-situ testing, [h. The effective plugging percentage for all plugging [and tube repairs] in each SG, and] [i. Repair method utilized and the number of tubes repaired by each repair method.]
DOC M01 2 4 4 5 6.9.b.4 7 7 2 2 2 2 * ; ; ; ; ; ; ; and 5 5 6 6 6 6 6 6 6 6 02 8 JUSTIFICATION FOR DEVIATIONS ITS 5.6, REPORTING REQUIREMENTS Kewaunee Power Station Page 1 of 1 1. Kewaunee Power Station (KPS) is a single unit site. Therefore, the allowance provided by this reviewers Note is not needed and has not been adopted in the KPS ITS. 2. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.
- 3. Changed the ISTS 5.6.2 submittal date to be consistent with the current KPS submittal date in CTS 6.9.b.2.
- 4. ISTS 5.6.4, "Reactor Coolant System (RCS) PRESSURE A ND TEMPERATURE LIMITS REPORT (PTLR)," is not adopted in the ITS. CTS Figures TS 3.1-1 and TS 3.1-2, which provide Reactor Coolant System heatup and cooldown limitations, respectively, were adopted in ITS 3.4.3, "RCS Pressure and Temperature (P/T) Limits." Subsequent Specifications are renumbered accordingly.
- 5. The bracketed ISTS 5.6.6, "Tendon Surveillance Report," is not included in the Kewaunee Power Station (KPS) ITS since KPS does not have pre-stressed
concrete tendons. Subsequent Specifications are renumbered accordingly.
- 6. The 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.
- 7. ISTS 5.5.3, "Post Accident Sampling," and ISTS 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program," are not included in the KPS ITS.
As a result, subsequent programs in ITS Section 5.5 have been renumbered and
Specification 5.5.9 is now 5.5.7.
- 8. Changes have been made due to changes made to another Specification. Condition F in ITS 3.3.3 has not been adopted, thus it is being deleted in ITS 5.6.4.
Licensee Response/NRC Response/NRC Question Closure Id1131NRC Question Number VGC-002 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 Date 12/3/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 12/3/2009 8:37 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1131 ITS NRC Questions Id1051NRC Question Number VGC-003 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number 8 JFD Bases Number Page Number(s) Attachment 1, Volume 16 page 20 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Attachment 1, Volume 16 page 20 of 167, A04 page 22 of 167, L02 page 28 of 167, JFD8 Each of these referen ces cite ITS 5.5.2. These items discussed appea r to be contained in ITS section 5.2. ITS 5.5.2 is associated with Primary Coolant Sources Outside Containment which does not appear to be what the items in question should reference. Please explain Attach File 1 Attach File 2 Issue Date 11/13/2009 Added By Victor Cusumano Date Modified Modified By Date Added 11/13/2009 2:49 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1051 Licensee Response/NRC Response/NRC Question Closure Id801 NRC Question Number VGC-003 Select Application Licensee Response Response Date/Time 11/16/2009 4:15 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) agrees that in , Volume 16, Pages 20 (DOC A0 4), 22 (DOC L02), and 28 (JFD 8) of 167, the Specification number referenced is a typographical error and should be 5.2.2.e, 5.2.2.c, and 5.2.2.f, respectively. 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 1 VGC-003 Markup.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 11/16/2009 4:14 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=801 DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION 10 CFR 50.54(m)(2)(iv). This change is designated as administrative because it does not result in technical changes to the CTS.
A03 CTS 6.2.d states that changes not affecting safety may be made to the off-site and facility organizations and that such changes that are described in the Technical Specifications shall be reported to the NRC in the form of an application for license amendment within 60 days of the implementation of the change. This allowance is not being maintained in the ITS. This changes the CTS by deleting an allowance to make certain changes to the CTS prior to actually receiving a Technical Specification change.
The purpose of CTS 6.2.d was to allow Dominion Energy Kewaunee (DEK) to make changes to the unit staff organization, such as title changes, without waiting for prior NRC approval. However, License Amendment 193 (ADAMS Accession No. ML072880065) changed the CTS by deleting all plant specific
titles and replacing them with generic titles, and specifying that the plant specific titles are in administrative documents. Furthermore, as stated in CTS 6.2.a and b, the off-site and facility organization is described in the quality assurance program. Thus, with the approval of License Amendment 193, this CTS 6.2.d allowance is unnecessary - no changes that do not affect safety are necessary, since all plant-specific titles have been removed from the CTS. Therefore, this
change is acceptable and is considered administrative since KPS does not believe the current CTS 6.2.d allowance can be used at this time.
A04 CTS 6.3.b states that "The shift technical advisor shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in the design of the Kewaunee Plant and plant transients. ITS 5.5.2.e states that "An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift." This changes the CTS by referencing the Commission Policy Statement on Engineering Expertise on Shift for qualification requirements instead of specific qualifications.
The purpose of 6.3.b requirements is to specify the minimum qualification requirements for the shift technical advisor. This change is acceptable because
the qualification requirements included in the Commission Policy Statement on Engineering Expertise on Shift (Generic Letter 86-04, dated February 13, 1986) encompass the current shift technical advisor qualification requirements. This change is designated as administrative because it does not result in a technical
change to the CTS.
MORE RESTRICTIVE CHANGES M01 CTS 6.1.a describes that the plant manager is responsible for overall plant operation. CTS 6.2.a states that the off-site organization for plant management and technical support shall be as described in the quality assurance manual. CTS 6.2.b states that the plant organization shall be as described in the quality assurance program. ITS 5.2.1 states:
Kewaunee Power Station Page 2 of 5 2
DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION RELOCATED SPECIFICATIONS None
REMOVED DETAIL CHANGES
None
LESS RESTRICTIVE CHANGES
L01 (Category 1 - Relaxation of LCO Requirements) CTS 6.2.b.1.B requires two licensed reactor operators to be on duty at all times as part of the shift complement. This requirement is being deleted from the Technical Specification since it is duplicative of 10 CFR 50.54(m)(2)(i). This is discussed in DOC A02. However, 10 CFR 50.54(m)(2)(i) only requires one licensed Operator to be on duty when in MODE 5 or 6 or defueled. This changes the CTS by only requiring
one licensed Operator to be on duty when in MODE 5 or 6 or defueled.
The purpose of CTS 6.2.b.1.B is to ensure the proper number of licensed Operators are on duty as required by NRC regulations. This change is acceptable since the NRC has already approved, as documented in 10 CFR 50.54(m)(2)(i), the minimum number of Licensed Operators required to be on duty in MODES 5 and 6 and defuled. This change is designated as a less restrictive change since the LCO requirements are less restrictive than are currently required in the CTS.
L02 (Category 1 - Relaxation of LCO Requirements) CTS 6.2.b.1.E requires one radiation technologist to be on duty at all times as part of the shift complement.
ITS 5.5.2.c only requires one radiation technologist to be on duty when there is
fuel in the reactor vessel. This changes the CTS by not requiring a radiation technologist to be on duty when the reactor is defueled.
The purpose of CTS 6.2.b.1.E is to ensure the proper number of radiation technologists are duty when required. This change is acceptable since the NRC has already approved, as documented in ISTS NUREG-1431, Rev. 3.0 (as well as the other four ISTS NUREGs), allowing no radiation technologists to be on duty when the reactor is defueled. This change is designated as a less restrictive change since the LCO requirements are less restrictive in the ITS than in the CTS.
L03 (Category 1 - Relaxation of LCO Requirement) CTS 6.2.b.7 states that "When the reactor is above the COLD SHUTDOWN condition, a qualified shift technical advisor shall be within 10 minutes of the control room." ITS 5.2.2.e requires the shift technical advisor to be on duty when the unit is in MODE 1, 2, 3, or 4, but does not require the individual to be within 10 minutes of the control room. This changes the CTS by deleting the requirement that the shift technical advisor be within 10 minutes of the control room.
Kewaunee Power Station Page 4 of 5 2
JUSTIFICATION FOR DEVIATIONS ITS 5.2, ORGANIZATION
- 1. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current Technical
Specifications.
- 2. CTS 6.2.c allows the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in the Technical Specifications to be maintained in appropriate plant documents, in lieu of the ISTS requirement that
they be in the FSAR/QA Plan. This allowance was approved by the NRC as part of License Amendment 193, dated 10/31/07 (ADAMS Accession No. ML072880065). Therefore, ISTS 5.2.1.a has been changed to reflect this allowance.
- 3. Kewaunee Power Station includes only one unit. Therefore, the words in ITS 5.2.2.a have been modified to reflect a single unit site.
- 4. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.
- 5. Typographical error corrected.
- 6. ITS 5.2.2.b has been revised to allow additional time for the shift crew composition to be below the minimum requirements of 10 CFR 50.54 "when
severe weather conditions exist." ITS 5.2.2.c has been revised to allow additional time for a vacant radiation protection technician when severe weather conditions exits. This change is consistent with current Kewaunee Power Station (KPS) licensing requirements.
- 7. The generic positions have been used. Also, the terms in 10 CFR 55.4 and 10 CFR 50.54(m) are "Senior Operator" and "Operator," not "Senior Reactor
Operator" and "Reactor Operator."
- 8. ISTS 5.5.2.f has been modified to require the shift technical advisor only in MODES 1, 2, 3, and 4, consistent with the current Technical Specifications Requirements.
Kewaunee Power Station Page 1 of 1 2
Licensee Response/NRC Response/NRC Question Closure Id1141NRC Question Number VGC-003 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 Date 12/3/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 12/3/2009 8:38 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1141 ITS NRC Questions Id1481 NRC Question Number VGC-004 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number M-7 JFD Number 16 JFD Bases Number Page Number(s) VOL 16 Page 95 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In TS Section 5.5.10 "Explosive Gas and Storage Tank Radioactivity Monitoring Program" (VOL 16 Page 95 of 167) you have chosen to delete the ISTS paragraph stating the methodology used to determine the quantities of radioactive gasses and liquid radwaste materials. While the methodology cited in that paragraph is bracketed, the paragraph itself is not. Please explain how, without a defined methodology, you ensure that this determination provides accurate and reliable results. As you state in DOC M07, your CTS does not have this program. Since there is no current method in use to retain from CTS, please describe the methodology you plan to use, and the basis for not including it in the program description.
In JFD16 you justify the deletion by stating that the program details are described in ITS 5.5.10 parts a, b, and c. These parts do not define a methodology.
Attach File 1 Attach File 2 Issue Date 1/15/2010 Added By Victor Cusumano Date Modified Modified By Date Added 1/15/2010 1:45 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1481 Licensee Response/NRC Response/NRC Question Closure Id1961 NRC Question Number VGC-004 Select Application Licensee Response Response Date/Time 1/29/2010 2:25 PM Closure Statement Response Statement The current methodology used at Kewaunee Power Station is the methodology described in the bracketed ISTS paragraph. This methodology is currently under KPS control; it is not in the CTS. The ITS submittal did not include this information for that reason, and this same reason has been previously accepted by the NRC during a recent ITS conversion (Davis-Besse, NRC SER dated November 20, 2008).
However, after further review, Kewaunee Power Station (KPS) will agree to put the methodology into the ITS, since it is not believed that the methodology will change in the near future. 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 1 VGC-004 Markup.pdf (756KB) Attachment 2 Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 1/29/2010 2:24 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1961 Programs and Manuals 5.5 WOG STS 5.5-12 Rev. 3.1, 12/01/05 CTS 5.5 Programs and Manuals
5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program
This program provides controls for potentially explosive gas mixtures contained in the [Waste Gas Holdup System], [the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of
radioactivity contained in unprotected outdoor liquid storage tanks]. The gaseous radioactivity quantities shall be determined following the methodology in [Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure"]. The liquid radwaste quantities shall be determined in accordance with [Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures"].
The program shall include:
- a. The limits for concentrations of hydrogen and oxygen in the [Waste Gas Holdup System] and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion),
- b. A surveillance program to ensur e that the quantity of radioactivity contained in [each gas storage tank and fed into the offgas treatment system] is less than the amount that would result in a whole body exposure of 0.5 rem to any individual in an unrestricted ar ea, in the event of [an uncontrolled release of the tanks' contents], and
- c. A surveillance program to ensur e that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tank s' contents and that do not have tank overflows and surrounding area drains connected to the [Liquid Radwaste Treatment System] is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface
water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.
1 10 Gaseous Radioactive Waste Disposal Gaseous Radioactive Waste Disposal Waste Disposal 1 16 1 1 1 6 DOC M07 ; ; 3 3 7 7 Stet, with changes JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS Kewaunee Power Station Page 3 of 4 final version of the plant specific subm ittal. Therefore, the Reviewer's Note has been deleted.
- 16. The program details of the Explosive Gas and Storage Tank Radioactivity Monitoring Program are described in ISTS 5.5.12 (ITS 5.5.10) part a, b, and c.
Therefore, the sentence in the introductory paragraph that specifies a method to determine the explosive gas and storage tank radioactivity is not necessary. Additionally, this change is consistent with the requirements in ODCM Sections 3/4.3 and 3/4.4.
- 17. ISTS 5.5.13.c requires the total particulate concentration of the fuel oil to be tested every 31 days. The current test frequency at KPS is 92 days (per plant procedures). ITS 5.5.11.c has been changed to be consistent with current KPS practices. KPS has reviewed the maintenance history of this test and determined that the proposed 92 day Frequency is sufficient to ensure total particulates stays within the new ITS 5.5.11.c limit of 10 mg/l. In addition, the KPS diesel storage tanks are outdoor tanks, subject to the weather. Thus, minimizing the number of times the tanks must be opened to obtain fuel oil samples will also benefit keeping snow, rain water, and other contaminants out of the storage tanks.
- 18. Changes are made to the ISTS which reflect the plant specific nomenclature.
- 19. Kewaunee Power Station (KPS) complies with Option B of 10 CFR 50, Appendix J. Therefore, the ISTS 5.5.16 Option A and combined Option A and B provisions
have been deleted.
- 20. ISTS 5.5.16.a (ITS 5.5.14.a) contains exceptions to Regulatory Guide (RG) 1.163. The KPS Containment Leak Rate Testing Program does not take any exceptions to the RG 1.163 requirements. Therefore, these exceptions are deleted.
- 21. ISTS 5.5.16.b contains a statement with a bracketed value for the containment design pressure. The containment design pr essure limit specified in ISTS 5.5.16.b has not been included because it currently does not exist in the KPS
CTS, and because this limit does not pr ovide any useful input to the Containment Leakage Rate Testing Program. Pa is the test pressure and thus is included in the ITS.
- 22. KPS does not include a separate overall air lo ck leakage limit; it is only included as part of the combined Types B and C leakage limit (0.60 L a). Therefore, ISTS 5.5.16.d.2.a) has not been included. Due to this, there is no reason to include the requirements of ISTS 5.5.16.d.2.b) separate from ISTS 5.5.16.d.2. Thus it
has been combined into ISTS 5.5.16.d.2. Furthermore, ISTS 5.5.16.d.2.b) states, in part, the air lock acceptance criteria for each door. The CTS 6.20.c states, in part, the air lock acceptance criteria for each air lock door seal. ITS 5.5.14.d.2) is written to address each air lock do or seal. This is acceptable since the ITS is edited to reflect the text in the CTS and for clarification. Lastly, ISTS 5.5.16.d.2.b) (ITS 5.5.14.d) contains a bracketed value for the air lock door seal containment leakage rate acceptance criteria and the pressure to which each door seal is tested. The brackets have been removed for the pressure to which each door seal is tested and an acceptance criteria value of < 0.005 L a has been Not used.
Licensee Response/NRC Response/NRC Question Closure Id1971NRC Question Number VGC-004 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 Date 1/29/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 1/29/2010 4:34 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1971 ITS NRC Questions Id1541 NRC Question Number VGC-005 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number 20 JFD Bases Number Page Number(s) VOL 16 Page 100 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In VOL 16 Page 100 of 167 you delete 5.5.14.f under Containment Leakage Rate Testing Program. This section reads: " Nothing in these Technical Specifications shall be construed to modify the
testing Frequencies required by 10 CFR 50, Appendix J
." The justification for this deletion is in your JFD 23 and reads: " This phrase is not consistent with the allowances in ISTS 5.5.16.a (ITS
5.5.14.a), which states that the program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-
Based Containment Leak-Test Program," dated September, 1995, as modified by the following exceptions." These exceptions stated in ITS 5.5.14.a are modifications to the testing Frequencies required by 10 CFR 50, Appendix J
." The exceptions cited as the rationale for deleting ITS 5.5.14.f were themselves deleted in accordance with JFD 20. Given that, please explain the raional for the deletion of ITS 5.5.14.f.
Attach File 1 Attach File 2 Issue Date 1/26/2010 Added By Victor Cusumano Date Modified Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1541 Modified By Date Added 1/26/2010 9:38 AM Notification NRC/LICENSEE Supervision Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1541 Licensee Response/NRC Response/NRC Question Closure Id2041 NRC Question Number VGC-005 Select Application Licensee Response Response Date/Time 2/4/2010 6:45 AM Closure Statement Response Statement KPS agrees that no exceptions were added to the ITS and that the ISTS exceptions were not included. However, ISTS specifically allows exceptions to 10 CFR 50 Appendix J to be specified in the ISTS Program, which is in the Technical Specifications. Thus, a statement that nothing in
the Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J is incorrect. The ISTS allows exceptions to be made. If in the future an exception is requested by KPS, this statement could imply that it cannot be allowed. Furthermore, the statement itself is not necessary, even if there are no exceptions. The Program clearly states the requirements, and states that it is required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. Thus, the CTS already states it must comply with 10 CFR 50 Appendix J (as modified by approved exemptions). Thus a statement that this cannot be modified by another Specification is unnecessary. It appears that it may be here to ensure the Frequency exceptions of SR 3.0.2 (i.e., the 25% extension allowance) are not applied.
However, SR 3.0.2 is not applicable to the Administrative Controls Chapter (or any other chapter other than Chapter 3.0) unless a specific allowance is provided (i.e., SR 3.0.2 is applicable), similar to that provided in ITS 5.5.11, Diesel Fuel Oil testing Program.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 2/4/2010 6:49 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2041 Licensee Response/NRC Response/NRC Question Closure Id2071 NRC Question Number VGC-005 Select Application Licensee Response Response Date/Time 2/8/2010 3:25 PM Closure Statement Response Statement This response supersedes the previous KPS response.
KPS agrees that no exceptions were added to the ITS and that the ISTS exceptions were not included. However, the point is that the ISTS specifically allows exceptions to 10 CFR 50 A ppendix J to be specified in the ISTS Program, which is in the Technical Specifications. Thus, a
statement that nothing in the Technical Spe cifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J is incorrect. The first sentence of ISTS 5.5.16.a (ITS 5.5.14.a) states "A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions." (Italics added for emphasis) Thus, the ISTS clearly allows exceptions to be made, and a further statement saying
that nothing in the Technical Specifications can be construed to modify 10 CFR 50 Appendix J is incorrect. However, KPS does note that the referenced Justification for Deviation discusses the second part of the ITS 5.5.14.a paragraph and the deleted exceptions to RG 1.163. Therefore, KPS will clarify JFD 23 to discuss the first part f the statement, as described above. Furthermore, it is believed that the deleted ISTS 5.5.16.f requirement was included in the ISTS to ensure the Frequency exceptions of SR 3.0.2 (i.e., the 25% extension allowance) are not applied. However, SR 3.0.2 is not applicable to the Administrative Controls Chapter (or any other chapter other than Chapter 3.0) unless a specific allowance is provided (i.e., SR 3.0.2 is applicable), similar to that provided in ITS 5.5.11, Diesel Fuel Oil
Testing Program. In addition, the IS TS clearly states that "This program shall be in accordance with the guidelines contained in Regulatory Guide
1.163," and RG 1.163 includes the appropriate Surveillance test Frequencies and how they can be adjusted.
Question Closure Date Attachment 1 VGC-005 Markup.pdf (721KB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2071 Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 2/8/2010 3:31 PM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2071 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS Kewaunee Power Station Page 4 of 4 provided consistent with CTS 6.20. This is acceptable since the generic specific information/value is revised to reflect the current plant design.
- 23. ISTS 5.5.16 (ITS 5.5.14) provides the requirements for the Containment Leakage Rate Testing Program. The statement in ISTS 5.5.16.f that "Nothing in these Technical Specifications shall be co nstrued to modify the testing Frequencies required by 10 CFR 50, Appendix J" has been deleted. This phrase is not consistent with the allowances in ISTS 5.5.16.a (ITS 5.5.14.a), which states that the program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated
September, 1995, as modified by the following exceptions." These exceptions stated in ITS 5.5.14.a are modifications to the testing Frequencies required by
- 24. Changes made to be consistent with proposed TSTF-500, Revision 1.
- 25. ISTS 5.5.18, "Setpoint Control Program (SCP)," has been added consistent with proposed TSTF-493, Revision 4. Any changes to the proposed program are discussed in other Justification for Deviations. In addition, the bracketed ISTS 5.5.3, "Post Accident Sampling," and the ISTS 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program," are not included in the Kewaunee Power Station (KPS) ITS. Therefore, this Specification has been renumbered in the KPS ITS as 5.5.16.
- 26. Changes are made to be consistent with the LCO title in Section 3.3. In addition, ISTS 3.3.8 and 3.3.9 have not been adopted in the KPS ITS.
"A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions." Thus the ISTS clearly allows exemptions to be made. In addition, the ISTS clearly states (in the remainder of ITS 5.5.14.a) that "This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163," and RG 1.163 includes the appropriate Surveillance test Frequencies and how they can be adjusted.
Licensee Response/NRC Response/NRC Question Closure Id2721NRC Question Number VGC-005 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 Date 4/5/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 4/5/2010 3:10 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2721 ITS NRC Questions Id1621NRC Question Number VGC-006 Category Editorial ITS Section 5.0 ITS Number 5.6 DOC Number LA-4 JFD Number JFD Bases Number Page Number(s) Vol 16 Page 163 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Vol 16 Page 163 of 167, DOC LA04 describes the rationale behind relocating the Radiological Environmental Monitoring Program described in CTS 6.16.b.2 to the TRM. This includes: "ITS 5.6.2 still requires an annual report of the results of the Radiological Environmental Monitoring Program
." It appears that the correct ITS reference should be ITS 5.6.1. Please confirm Attach File 1 Attach File 2 Issue Date 1/27/2010 Added By Victor Cusumano Date Modified Modified By Date Added 1/27/2010 1:08 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1621 Licensee Response/NRC Response/NRC Question Closure Id2051 NRC Question Number VGC-006 Select Application Licensee Response Response Date/Time 2/4/2010 6:50 AM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) agrees that in , Volume 16, Pages 163 (DOC LA04), the Specification number referenced is a typographical error and should be 5.6.1, not 5.6.2. 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 1 VGC-006 Markup.pdf (718KB) Attachment 2 Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 2/4/2010 6:53 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2051 DISCUSSION OF CHANGES CTS 6.0, ADMINISTRATIVE CONTROLS changes the CTS by moving the requirements for the Radiological Environmental Monitoring Program to the Offsite Dose Calculation Manual (ODCM).
The purpose of CTS 6.16.b.2 is to provide representative measurements of radioactivity in the highest potential exposure pathways, and verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The removal of the requirements for this program from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 5.6.2 still requires an annual report of the results of the "Radiological Environmental Monitoring Program." Also, this change is acceptable because these requirements will be adequately controlled in the ODCM. Changes to the ODCM are controlled by the ODCM change control process in ITS 5.5.1, which ensures changes are properly evaluated.
This change is designated as a less restrictive removal of requirement change
because the requirements for a program are being removed from the Technical Specifications.
LA05 (Type 4 - Removal of LCO, SR, or other TS Requirements to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS Definition 1.0.o.3 contains the definition for the Process Control Program (PCP). CTS 6.16.a.1 requires written procedures for the PCP. CTS 6.17 describes the control for changes to the PCP. The ITS does not include these requirements. This changes the CTS by moving the requirements of the PCP to the USAR.
The removal of these requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The PCP implements the requirements of 10 CFR 20, 10 CFR 61, and 10 CFR 71. Compliance with these regulations is required by Kewaunee Power Station (KPS) Operating Licenses, and procedures are the method to ensure compliance with the program. Regulations provide an adequate level of control for the affected requirements and inclusion of this requirement in the Technical Specification is not necessary. Also, this change is acceptable because these details will be adequately controlled in the USAR. Any changes to the USAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of requirements because details for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.
LA06 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS 6.19 requires reporting major modifications to the liquid, gaseous, and solid radwaste treatment system to the Commission as part of the Radioactive Effluent Release Report and explains what needs to be included in the report and the approval process. The ITS does not contain this requirement.
This changes the CTS by moving the requirement for reporting major modifications to the liquid, gaseous, and solid radwaste treatment system to the Offsite Dose Calculation Manual (ODCM).
Kewaunee Power Station Page 3 of 5 5.6.1 Licensee Response/NRC Response/NRC Question Closure Id2521NRC Question Number VGC-006 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 Date 3/11/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 3/11/2010 7:05 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2521 ITS NRC Questions Id1631NRC Question Number VGC-007 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number A-8 JFD Number JFD Bases Number Page Number(s) Vol 16, Page 73 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Vol 16, Page 73 of 167 DOC A08 states that CTS 6.20 Containment Leakage Rate Testing Program includes a statement that the provisions of CTS 4.0.b do not apply. This prevents the 25% extension allowed by CTS 4.0.b from applying to this test program..
DOC A08 further states that removing this statement is an administrative change because it does not result in technical changes to the CTS.
ITS 5.5.14 Containment Leakage Rate Testing Program includes a statement that provisions of ITS SR 3.0.2 are applicable to this program, thus allowing a 25% extension be added to tests in the program.
Please explain why this is not a less restrictive change to the CTS; and if it is less restrictive, how it is consistent with the licensing basis for Kewaunee.
Attach File 1 Attach File 2 Issue Date 1/27/2010 Added By Victor Cusumano Date Modified Modified By Date Added 1/27/2010 1:12 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1631 Licensee Response/NRC Response/NRC Question Closure Id2131 NRC Question Number VGC-007 Select Application Licensee Response Response Date/Time 2/9/2010 9:05 AM Closure Statement Response Statement KPS has re-reviewed ITS 5.5.14 and cannot find any statement in the Containment Leakage Rate Testing Program that SR 3.0.2 is applicable to the program. KPS is adopting the Option B portion of the Program, consistent with current licensing basis. KPS does note that ITS 5.5.14.e (Page 100 of 167) states that the provisions of SR 3.0.3 are applicable to the Containment Leakage rate Testing Program.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 2/9/2010 9:07 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2131 Licensee Response/NRC Response/NRC Question Closure Id2141NRC Question Number VGC-007 Select Application NRC Question Closure Response Date/Time Closure Statement Based on clarification from the licensee, the original question is withdrawn. Response Statement Question Closure Date 2/10/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 2/10/2010 1:27 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2141 ITS NRC Questions Id1761NRC Question Number VGC-008 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number 17 JFD Bases Number Page Number(s) Vol 16 Page 96 of 167 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Singh Matharu Conf Call Requested N NRC Question The attached questions have been provided by the Electrical Engineering Branch in NRR's Division of Engineering. Attach File 1 Kewaunee Diesel Fuel Oil Testing Program RAIs.doc (31KB) Attach File 2 Issue Date 2/24/2010 Added By Victor Cusumano Date Modified Modified By Date Added 2/24/2010 2:16 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1761 Kewaunee Diesel Fuel Oil Testing Program.
Improved Standard Technical Specification (ISTS) Section 5.5.13c requires the total particulate
concentration of the emergency diesel generator fuel oil to be tested every 31 days. The current test frequency at KPS is 92 days. The licensee has proposed a deviation to ISTS to maintain the test frequency at 92 days based on:
- 1. Minimizing the number of times the outdoor fuel oil storage tanks (FOSTS) are opened, minimizes the potential for introduction of foreign materials into the tanks. 2. Past history indicates that 92 day test frequency was adequate for maintaining particulate content within TS limits.
Majority of the nuclear plants have a TS requirement to test fuel oil at 31 day interval.
- 1) Has KPS evaluated industry operating experience (OE) to substantiate that there is a higher incidence of introduction of foreign materials into the storage tanks at the plants with 31 day frequency?
into the FOSTS?
- 3) Provide details on fuel oil vendor(s) and refine ry used for the last 10 years to obtain fuel oil. 4) Provide details on the specification, testing and quality assurance requirements imposed on the fuel oil vendor. 5) Provide details on measures taken to assure that future fuel oil purchases will maintain the pedigree of fuel oil received on site. 6) ASTM D-975 "Standard Specification for Diesel Fuel Oils" has been revised to permit up to 5% bio-diesel to be included in commercial diesel fuel without notification to the end-user. Bio-diesel is hydrophilic (attracts water) and oxidizes rapidly in storage to form corrosive acids and insoluble polymers that can adversely affect components in the EDG system and cause rapid fuel oil filter plugging. Provide details on evaluations performed to consider impact of inadvertent introduction of bio-diesel in fuel oil for 92 days. 7) Provide details on the material, age and the last inspection performe d on the storage tank liner.
Licensee Response/NRC Response/NRC Question Closure Id2551 NRC Question Number VGC-008 Select Application Licensee Response Response Date/Time 3/12/2010 10:25 AM Closure Statement Response Statement KPS is adopting the requirement in ISTS 5.5.13.c to determine the total particulate concentration of the diesel fuel oil is within the limit. The ISTS Frequency for this test is every 31 days. However, this requirement is currently being performed at KPS every 92 days. KPS evaluated the maintenance history and has determined that the current licensing basis Frequency of 92 days is sufficient to ensure the total particulates stays within the new 10 mg/l limit. Therefore, KPS has submitted a 92 day
Frequency in ITS 5.5.11.c, in lieu of the ISTS Frequency of 31 days.
It is the KPS position that this proposed ITS Frequency is acceptable for ensuring the total particulates remains within the 10 mg/limit. The NRC reviewer requested further information concerning the fuel oil at KPS. The following are the NRC questions and the KPS responses to the questions:
- 1. Has KPS evaluated industry operating experience (OE) to substantiate that there is a higher incidence of introduction of foreign materials into the storage tanks at the plants with 31 day frequency?
KPS response: There was no OE on the INPO web site that documents foreign material introduction into the fuel oil storage tanks from sampling. However, in KPS's situation, there is neither a sample valve nor a low point drain on the fuel oil storage tanks, which are located underground. Chemistry must remove the 4 inch flange on the top of each tank and lower the sampling equipment down into the associated tank for sampling. The connection for each tank is outside of the plant buildings (i.e., the tanks are not inside any plant building) in a gravel area with the turbine building exhaust directed to the sample area.
While KPS has not had a situation where foreign material was introduced into the tanks, there have been some near-misses. The carbon steel pipe is approximately 6 feet to the top of the tanks and is beginning to show signs of corrosion in the portion of the pipe that does not see fuel oil. Any increase in the sampling frequency will increase the possibility of introducing foreign material.
- 2. Has KPS investigated OE methods used to exclude introduction of foreign materials into the FOSTS?
Pa ge 1of 3 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2551 KPS response: See response to question number 1 above.
- 3. Provide details on fuel oil vendor(s) and refinery used for the last 10 years to obtain fuel oil.
KPS response: For the last 10 years, KPS has used two vendors. The current vendor is being used only because the first vendor went out of business. Both the current vendor and the previous vendor provide KPS fuel oil from the British Petroleum (BP) refinery in Whiting, Indiana.
The fuel oil is piped from the refinery to Milwaukee, Wisconsin, where it
is trucked to the KPS site.
- 4. Provide details on the specification, testing and quality assurance requirements imposed on the fuel oil vendor.
KPS response: The purchase order for Amoco Premium fuel oil includes
the requirement that the fuel oil must meet the requirements of ASTM D975-06 and that the vendor must provid e laboratory res ults of the fuel oil from the tank that is used to supply KPS. Each fuel oil delivery is sampled and sent to an approved qualified laboratory for confirmation analysis. Over the last 30 years there have been no parameters found out of specification from the applicable revision of ASTM D975.
- 5. Provide details on measures taken to assure that future fuel oil purchases will maintain the pedigree of fuel oil received on site.
KPS response: The purchase specification for diesel fuel oil is a QA document and requires a Procurement Technical Evaluation performed to any changes. This document includes the references (ASTM, Calculations, basis). The changes to this document would require a full QA evaluation for revision. Furthermore, the ITS Bases for SR 3.8.3.3 provides the various required ASTM Standards to which the fuel oil is to be tested. Changes to the ITS Bases are controlled by the Bases Control Program in ITS Chapter 5. Furthermore, ITS 5.5.11 requires the diesel fuel oil program to include sampling, testing requirements, and acceptance criteria, all in accordance with applicable ASTM standards. Thus, fuel oil purchases would have to continue to meet the ITS 5.5.11 program requirements.
- 6. ASTM-975 Standard Specificat ion for Diesel Fuel Oils has been revised to permit up to 5% bio-diesel to be included in commercial diesel fuel without notification to the end-user. Bio-diesel is hydrophilic (attracts water) and oxidizes rapidly in storage to form corrosive acids and insoluble polymers that can adversely affect components in the EDG system and cause rapid fuel oil filter plugging. Provide details on evaluations performed to consider impact of inadvertent introduction of bio-diesel in fuel oil for 92 days.
KPS response: This concern over Bio-diesel was communicated to KPS Pa ge 2of 3 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2551 in the form of an Information Notice and the response to this IN was documented in the KPS corrective action program. The KPS fuel oil purchase order specifically states that Bio-diesel will not be allowed. KPS is purchasing laboratory equipment to analyze for Bio-diesel and the contract laboratory also analyzes for Bio-diesel as part of each shipment. All results indicate less than detectable Bio-diesel.
- 7. Provide details on the material, age and the last inspection performed on the storage tank liner.
KPS response: The two fuel oil storage tanks are made of carbon steel and are original equipment (i.e., circa 1971). The last inspection of the
two fuel oil storage tanks was completed in 2001. The results of the inspection only found some indications from initial installation and no other concerns.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 3/12/2010 10:23 AM Modified By Date Modified Pa ge 3of 3 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2551 Licensee Response/NRC Response/NRC Question Closure Id2881 NRC Question Number VGC-008 Select Application Licensee Response Response Date/Time 5/5/2010 4:00 PM Closure Statement Response Statement Kewaunee Power Station (KPS) recently had an informal phone conversation with the NRC reviewer discussing his comment provided in VGC-008 and the subsequent KPS response. During the conversation, many issues were discussed concerning the sampling of diesel fuel oil at KPS. The following is a list, provided by the NRC, of the various issues discussed, including the NRC's understanding of what transpired during the phone call. For each of the listed issues, KPS is providing a confirmation or follow-up response to the issue.
- 1. Sampling method, I believe the licensee said according to ASTM D4057, "Standard Practice for Manual Sampling of Petroleum and Petroleum Products." KPS Response: Both SP-10-225, the relevant KPS-specific surveillance procedure, and CY-AA-AUX-310, the relevant Dominion fleet procedure include reference to ASTM D4057. A comparison of SP-10-225 with ASTM D4057 indicates that this sampling methodology is in accordance with ASTM D4057.
- 2. "All- level" sample method is used every 92 days.
KPS Response: KPS surveillance procedure SP-10-225 specifies a quarterly sampling frequency for each Diesel Fuel Oil Storage Tank.
The Dominion fleet procedure CY-AA-AUX-310 specifies a 92 day sampling frequency and in accordance with the KPS surveillance procedure (i.e., SP-10-225). The "All-level" sample method is used for the fuel oil storage tanks.
- 3. By procedure, delivery tank is steam cleaned prior to filling by supplier.
KPS Response: By purchase order, the following quality assurance
requirement is invoked: "Prior to filling, transporters and hoses are to be steam cleaned and dried. Vendor shall provide documented evidence of cleaning prior to or with shipment. All hoses to be used for off load shall be capped to prevent road contaminates from entering during transit." Pa ge 1of 3 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2881
- 4. A certificate is provided by the fuel oil supplier indicating conformance with purchase order.
KPS Response: The purchase order requires that the fuel oil shall be supplied in accordance with the requirements, analysis, and limits specified in Dominion fleet procedure CY-AA-AUX-310. Per the purchase order requirement, the supplier provides a laboratory analysis report for the last shipment received at the local fuel oil facility at or before the shipment to Kewaunee, and documented evidence of steam cleaning and drying of transporter compartments prior to, or with, shipment of fuel.
- 5. Fuel oil sample from delivery truck taken by onsite Chemistry personnel prior to filling the fuel oil storage tank.
KPS Response: KPS surveillance procedure SP-10-225 requires a fuel oil sample to be taken from the transporter, and the Immediate Fuel Oil Acceptance Criteria confirmed acceptable prior to transferring (i.e.,
offloading) fuel oil into a fuel oil storage tank.
- 6. Fuel sample from every new delivery is sent to a recognized lab for analyses and response is required within 20 days.
KPS Response: KPS surveillance procedure SP-10-225 requires fuel oil samples to be sent to the offsite vendor laboratory for analysis within 5 days of obtaining the samples. The procedure states that analytical results should be received from the offsite vendor within 14 days of the vendors receipt of the sample. Kewaunees review and evaluation of sample analytical results are required to be completed within 30 days of sampling new diesel fuel receipt.
- 7. The fuel sample from the fuel oil storage tank is taken using a tygon tube and no canisters, bacon bombs, glass containers, etc., are introduced into the tank.
KPS Response: The fuel oil sample from each fuel oil storage tank is taken using tygon tubing and a peristaltic pump. No sample canisters, sample thieves, bacon bombs, glass containers, etc., are introduced into the tank during the acquisition of these samples.
- 8. Day tank oil is sampled every 30 days.
KPS Response: The current KPS Preventive Maintenance Procedure PMP-10-02 includes the DG A/B Day Tanks fuel oil sampling, and is scheduled on a monthly basis. This is consistent with the proposed ITS SR 3.8.1.5; a new surveillance procedure is in development for this purpose. 9. Tanks are directly buried carbon steel. Check on corrosion protection Pa ge 2of 3 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2881 (cathodic protection, coating, etc.).
KPS Response: The fuel oil storage tanks are buried, coal tar mastic coated carbon steel tanks. Additional corrosion protection is provided by a cathodic protection system.
- 10. The 'sump' part of the tank is not known, i.e. if the tank is built on a slant, the water and debris will settle at one end, which may be the suction end for the transfer pumps. Need to identify the height elevation of the suction line in relation to the elevation of the bottom of the tank to provide assurance that water and sediment will not be introduced into the EDG. 10 year cleaning did not show any concerns.
KPS Response: The fuel oil storage tanks are horizontal right circular cylinders, with no sump. Calculation C10033, Rev. 2, Safeguards Diesel Fuel Oil Storage Volume Calculation, indicates that the installed fuel oil transfer pump suction is 4 3/8 inches above the bottom of the tank, providing reasonable assurance that water and other sediment will not be introduced into the suction of the fuel oil transfer pumps. Additionally, the quarterly fuel oil sampling (i.e., KPS surveillance procedure SP-10-225) includes a bottom sample which serves to remove settled contaminants and water. Further, the most recent cleaning and visual inspection of the underground fuel oil storage tanks indicated no unacceptable degradation.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 5/5/2010 3:58 PM Modified By Date Modified Pa ge 3of 3 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2881 Licensee Response/NRC Response/NRC Question Closure Id2891NRC Question Number VGC-008 Select Application NRC Question Closure Response Date/Time Closure Statement this question is closed per the below e mail. The JFD is acceptable based on the additional information docketed with this database.
V Cusumano From: Matharu, Gurcharan To: Cusumano, Victor
- Mathew, Roy Cc
- Tam, Peter
- Bucholtz, Kristy
- Waig, Gerald
- Wilson, George
- Wolfgang, Robert
- Elliott, Robert
Subject:
RE: ME 2139 - Kewaunee TS 5.5 Diesel Fuel Oil Testing Program RAI Close-out Date: Thursday, May 06, 2010 9:58:54 AM Vic, This e-mail confirms my concurrence to the responses provided by Kewaunee for LAR converting Current Technical Specification (CTS) requirements to Standard Technical Specification (STS) format related to Emergency Diesel Generator (EDG)
Fuel Oil Storage Tank (FOST) sampling.
Specifically, Kewaunee CTS does not require sampling of EDG fuel oil in
the FOSTs. The licensee currently has plant procedures (non-TS) that call out testing the particulate concentration of the fuel every 92 days, and they would like to maintain that frequency rather than adopting the 31 days in the STS.
The licensee has provided details on current procedures that ensure that new particulate or bio-diesel products are not introduced into the FOSTs. The licensee
has not noticed significant moisture or particulate accumulation in the FOSTs during the clean up required every 10 years. The licensee will sa mple the day tanks every month (per STS requirement) providing assurance that any excessive moisture and sediment build up
in the FOSTs that gets carried into the day tanks will be detected during the monthly surveillance.
Based on the licensee's responses to staff 's request for additional
information and subsequent supplemental question s related to fuel oil sampling methods, the staff finds the proposed sampling of fuel oil in the FOSTs, every 92 days instead of 31 days, as acceptable.
Please retain all the responses provided by the licensee, related to this Pa ge 1of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2891 discussion, as part of the supporting documentation.
Roy Mathew is currently acting Branch Chief. I am forwarding this e-mail to him for EEEB concurrence.
Gurcharan Singh Matharu NRR-DE-EEEB Response Statement Question Closure Date 5/6/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 5/6/2010 9:22 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2891 ITS NRC Questions Id1891NRC Question Number VGC-009 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number JFD Bases Number Page Number(s) In Vol 16, on page 90 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In Vol 16, on page 90 of 167 in TS 5.5.9 (several places) you reference Reg Guide 1.52 Revision 1. The Standard Tech Specs reference Revision
- 2. What justification is there for not using Rev 2 or Rev 3, and going back to Rev 1 of this Reg Guide?
Attach File 1 Attach File 2 Issue Date 3/18/2010 Added By Victor Cusumano Date Modified Modified By Date Added 3/18/2010 9:42 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1891 Licensee Response/NRC Response/NRC Question Closure Id2821 NRC Question Number VGC-009 Select Application Licensee Response Response Date/Time 4/22/2010 2:10 PM Closure Statement Response Statement The current Kewaunee Power Station (KPS) commitment is to Regulatory Guide (RG) 1.52, Rev 1, with respect to replacement HEPA filters and charcoal adsorbers. Therefore, this is the current version of the RG KPS uses as guidance to perform the inplace HEPA filters and charcoal adsorbers. However, KPS has reviewed Revision 2 of the RG and will adopt the Revision 2 testing methods for these two tests. A draft markup regarding this change is attached. Note that this attached change includes changes due not only to this response, but also includes changes identified in the KPS responses to VGC-010 and VGC-011. This change will be reflected in the supplement to this section of the ITS conversion amendment. In addition, a clean draft markup of ITS 5.5.9, which shows how the ISTS Markup will look when the revision to the ITS submittal is made (i.e., the Rev. 1 version of the ISTS Markup), is also included to assist in understanding the changes.
Question Closure Date Attachment 1 VGC-009, 10, 11 Markup.pdf (1MB) Attachment 2 draft ITS 5.5.9, Rev. 1 markup.pdf (76KB) Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 4/22/2010 2:11 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/29/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2821 Amendment No. 190 TS 3.6-4 03/08/2007 3. Performance Requirements A. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show 99% DOP removal and 99% halogenated hydrocarbon removal.
B. The results of laboratory carbon sample analysis from the Shield Building Ventilation System and the Auxiliary Building Special Ventilation System carbon shall show 97.5% radioactive methyl i odide removal when tested in accordance with ASTM D3803-89 at conditions of 30C, 95% RH for the Shield Building Ventilation System and 30C, 95% RH for the Auxiliary Building Special Ventilation System.
C. Fans shall operate within +/- 10% of design flow when tested.
- d. If the internal pressure of the reactor containment vessel exceeds 2 psi, the condition shall be corrected within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the reactor shall be placed in a subcritical condition.
- e. The reactor shall not be taken above the COLD SHUTDOWN condition unless the containment ambient temperature is > 40F. ITS 5.5 A01 ITS Page 10 of 17 5.5.9.c 5.5.9.a, 5.5.9.b See ITS 3.6.4 See ITS 3.6.5 5.5.9.a 5.5.9.b Add proposed 5.5.9 generic program statement and SR 3.0.2 and SR 3.0.3 applicability statement A05 5.5.9.c 5.5.9.a, 5.5.9.b 5.5.9.a, 5.5.9.b A dd p ro p osed desi g n flow values M13 A01 ITS 5.5 ITS 3.12 CONTROL ROOM POST-ACCIDENT RECIRCULATION SYSTEM APPLICABILITY Applies to the OPERABILITY of the Control Room Post-Accident Recirculation System.
OBJECTIVE To specify OPERABILITY requirements for the Control Room Post-Accident Recirculation System. SPECIFICATION
- a. The reactor shall not be made critical unless both trains of the Control Room Post-Accident Recirculation System are OPERABLE.
- b. Both trains of the Control Room Post-Accident Recirculation 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 Control Room Post-Accident Recirculation System is made or found to be inoperable for any reason, reactor operation is permissible only during the
succeeding 7 days. See ITS 3.3.7 and 3.7.10 c. During testing the system shall meet the following performance requirements:
- 1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filter and charcoal adsorber banks shall show 99% DOP removal and 99% halogenated hydrocarbon removal.
Add proposed 5.5.9 generic program statement and SR 3.0.2 and SR 3.0.3 applicability statement A05 5.5.9.a, 5.5.9.b 2. The results of the laboratory carbon sample analysis from the Control Room Post-Accident Recirculation System carbon shall show 95% radioactive methyl iodide removal when tested in accordance with ASTM D3803-89 at conditions of 30C, and 95% RH.
5.5.9.c 3. Fans shall operate within +/-10% of design flow when tested.
5.5.9.a, 5.5.9.b Amendment No. 152 TS 3.12-1 02/28/2001 Page 11 of 17 A dd p ro p osed desi g n flow values M13 Amendment No. 204 TS 4.4-1 04/27/2009 ITS 5.5 A01 ITS 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 exception to the Containment Leakage Rate testing Program, the first Type A test following the Type A test performed in April 1994 shall be required no later than October 2009.
- 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 Page 12 of 17 See ITS 3.6.1 5.5.9.d 5.5.9 A06 See ITS 3.6.10 See ITS 3.6.1, 3.6.2, and 3.6.3 A dd p ro p osed desi g n flow values M13 L02 Amendment No. 201 TS 4.4-2 12/30/2008 ITS 5.5 A01 ITS 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 (+/-10%
). 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. Al 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.
Page 13 of 17 See ITS 3.6.10 5.5.9 5.5.9 5.5.9 See ITS 3.6.8 A07 5.5.9.e 5.5.9.e 5.5.9 A dd p ro p osed desi g n flow values M13 Amendment No. 137 TS 4.17-1 06/09/98 4.17 CONTROL ROOM POSTACCIDENT RECIRCULATION SYSTEM APPLICABILITY Applies to testing and surveillance require ments for the Control Room Postaccident Recirculation System in TS 3.12.
OBJECTIVE To verify the performance capability of the C ontrol Room Postaccident Recirculation System. SPECIFICATION
- a. At least once per operating cycle or once every 18 months, whichever occurs first, the following conditions shall be demonstrated:
- 1. Pressure drop across the combined HEPA filters and charcoal adsorber banks is < 6 inches of water and the pressure drop across any HEPA bank is < 4 inches of water at the system design flow rate (+/- 10%).
- 2. Automatic initiation of the system on a high radiation signal and a safety injection signal. b. 1. The in-place DOP test for HEPA filters shall be performed (1) at least once per 18 months and (2) after each complete or par tial replacement of a HEPA filter bank or after any maintenance on the system that could affect the HEPA bank bypass leakage. 2. 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.
- 3. 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.
- 4. Each train shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month.
ITS 5.5 A01 ITS Page 15 of 17 5.5.9.d 5.5.9 A06 See ITS 3.7.10 5.5.9 5.5.9 5.5.9 See ITS 3.7.10 A dd p ro p osed desi g n flow values M13 L02 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS Kewaunee Power Station Page 7 of 8 found in ITS 5.5.13. This change is designated as more restrictive because it imposes additional programmatic require ments in the Technical Specifications.
M10 The CTS does not include a requirement for Battery Monitoring and Maintenance Program. The ITS includes a require ment for this program. This changes the CTS by adding the ITS 5.5.15, "Battery Monitoring and Maintenance Program."
The Battery Monitoring and Maintenance Pr ogram is included to provide for battery restoration and maintenance. The specific wording associated with this program may be found in ITS 5.5.15. This change is acceptable because it supports implementation of the requirements of the ITS. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.
M11 The CTS does not have a program for Setpoint Control. ISTS 5.5.18 (ITS 5.5.16) requires a program to satisfy the regulatory requirement of 10 CFR 50.36(c)(1)(ii)(A) that Technical Specifications will include items in the category of limiting safety system settings (LSSS), which are settings for automatic protective devices related to those variables having significant safety functions. This changes the CTS by incorporating the requirements of
The purpose of the program is to establish, implement, and maintain instrument setpoint controls for automatic protective devices related to those variables having significant safety functions. This change is designated as more restrictive because it imposes new programmatic requirements in the Technical Specifications.
RELOCATED SPECIFICATIONS
None REMOVED DETAIL CHANGES
LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.18.b.1 requires changes to the ODCM to be documented and records of reviews perform ed to be retained as required by the quality assurance program. CTS 6.
18.b.2 requires changes to the ODCM to be effective after review and acceptance by the PORC. ITS 5.5.1.c.1 requires changes to the ODCM to be documented and records of reviews performed to be retained. ITS 5.5.1.c.2 requires changes to the ODCM to become effective after the approval of the plant manager. This c hanges the CTS by moving the record retention requirements reference an d the PORC review and approval requirements to the Nuclear Facility Quality Assurance Program Description (NFQAPD). DOC M01 describes the addition of the plant manager approval.
The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical NSERT DOC M13 INSERT M13 CTS 3.6.c.3.A, 3.6.c.3.C, 3.8.a.9.b.1, 3.8.a.9.b.3, 3.12.c.1, 3.12.c.3, 4.4.c.1.a, 4.4.c.3, 4.4.d.1, 4.12.a.1, and 4.17.a.1 require certain Ventilation System filter tests to be performed at the system design flow rate. However, no specific value of the various Ventilation System design flow rates is provided. ITS 5.5.9.a, b, d, and e require performance of similar Ventilation System filter tests, and include the specific value of the design flow rate for each required Ventilation System. This changes the CTS by adding the specific design flow rate values into the filter test requirements of the ITS. The various Ventilation System filter tests are performed at the system design flow rate. However, the specific values are currently controlled in plant procedures and the USAR. This change will add the values into the Technical Specifications, and thus any change will require NRC approval in lieu of changing it by the 10 CFR 50.59 process. Therefore, this change is considered acceptable. This change is designated as more restrictive because new Ventilation System design flow rate values are being included in the ITS that are not required in the CTS.
DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS Kewaunee Power Station Page 8 of 8 Specifications to provide adequate protection of public health and safety. ITS 5.5.1 still retains the requirement for changes to the ODCM to be
documented and retained. Also, this change is acceptable because these types of procedural details will be adequately controlled in the NFQAPD. Any changes to the NFQAPD are made under 10 CFR 50.54(a), which ensure changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specifications requirements are being removed from the Technical Specifications.
LA02 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS 4.2.a and 4.2.a.1 provide requirements for the In-Service Inspection Program. The ITS does not include In-Service Inspection Program requirements. This changes the CTS by moving these requirements from the Technical Specifications to the In-Service Inspection (ISI) Program.
The removal of these requirements is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The Technical Specifications still retain requirements for the affected components to be OPERABLE. Also, this change is acceptable because these requirements will be adequately controlled by the ISI Program, which is required by 10 CFR 50.55a.
Compliance with 10 CFR 50.55a is required by the Kewaunee Operating License. This change is designated as a less restrictive removal of requirement change because requirements are being removed from the Technical
Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements)
CTS 6.20.b states, in part, that the leakage rate acceptance criteria prior to unit startup for the Type A test is
< 0.75 L a. ITS 5.5.14.d.1 states, in part, that the leakage rate acceptance criteria prior to unit startup for the Type A test is 0.75 L
- a. This changes the CTS by allowing the leakage rate to be exactly equal to 0.75 L a in lieu of being < 0.75 L
- a.
The purpose of ITS 5.5.14.d.1 is to ensure that prior to a unit startup the overall containment leakage rate with a certain amount of margin, does not exceed the value assumed in the accident analysis. This change is acceptable because the acceptance criteria limit in ITS 5.5.14.d.1 (the 1.0 L a limit) continues to ensure the containment leakage is within the value assumed in the accident analysis. The 10CFR50 Appendix J Option B states that for Type A tests the leakage rate must not exceed the allowable leakage rate (L a) with margin, as specified in the Technical Specifications. The ITS now provides a margin that includes allowing
the limit to be exactly 0.75 L
- a. This change is designated as less restrictive because the acceptance criteria applicable prior to a unit startup for the Type A leakage tests is now allowed to be exactly equal to 0.75 L a in lieu of being
< 0.75 L a. INSERT L02 L02(Category 1 - Relaxation of LCO Requirements)
CTS 4.4.c.1.a provides the pressure drop test acceptance criteria for the Shield Building Ventilation System (SBVS) and the Auxiliary Building Special Ventilation (ASV) System. The acceptance criteria are a pressure drop across the combined HEPA filters and charcoal adsorber banks < 10 inches of water and a pressure drop across any HEPA filter bank < 4 inches of water. CTS 4.17.a.1 provides the pressure drop test acceptance criteria for the Control Room Post Accident Recirculation (CRPAR) System. The acceptance criteria are a pressure drop across the combined HEPA filters and charcoal adsorber banks < 6 inches of water and a pressure drop across any HEPA filter bank < 4 inches of water. ITS 5.5.9.d provides the pressure drop test acceptance criteria for all three systems, and requires the pressure drop across the combined prefilters, HEPA filters, and charcoal adsorber banks to be < 6.3 inches of water for the SBVS and the ASV System, and < 2.4 inches of water for the CRPAR System. This changes the CTS by reducing the acceptance criteria for the combined dP, including the prefilters as part of the combined dp test, and deleting the HEPA filter only dP criteria. Performance testing demonstrating that dP is within prescribed limits assures that fans operate within +/- 10% of design flow, and thus ensures that filters perform adequately to satisfy the accident analyses. That is, if the performances
are as specified, the calculated doses would be less than the guidelines stated in 10CFR Part 100 for the accidents analyzed.
During the development of Design Basis Documents for these ventilation systems it was identified that the analytical basis for the CTS dP acceptance criteria could not be verified. KPS has recently performed calculations, based on a newly developed analytical basis. These calculations have determined that the current dP acceptance criteria are non-conservative. KPS has implemented, in procedures, these more restrictive acceptance criteria. This change to the CTS replace the non-conservative dp acceptance criteria with the current acceptance criteria from the recent calculation. This change is acceptable because it will incorporate newly calculated, and more conservative, dP acceptance criteria. Combined dP testing across the prefilter, HEPA filter and charcoal adsorber banks, per the ISTS format, in lieu of CTS combined HEPA filter and charcoal adsorber bank and HEPA-only dP testing, will still adequately demonstrate that the filters are not clogged and capable of performing their design function. The change related to the reduction of the combined dP limit is more restrictive, since it is reducing the limit and adding another component (prefilter) to the testing. However, the change related to removing the HEPA filter only dP limit is less restrictive. Therefore, this change is designated as less restrictive because the acceptance criteria applicable to the HEPA filter only dP test is being deleted.
Programs and Manuals 5.5 WOG STS 5.5-10 Rev. 3.1, 12/01/05 CTS 5.5 Programs and Manuals
5.5.11 Ventilation Filter Testing Program (VFTP) 6 A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].
- a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. ESF Ventilation System Flowrate
[ ] [ ]
- b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].
ESF Ventilation System Flowrate
[ ] [ ]
- c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.
ESF Ventilation System Penetration RH Face Velocity (fps)
[ ] [See Reviewer's [See [See Reviewer's Note] Reviewer's Note] Note]
REVI EWER'S NOTE---------------------------------------- The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility is indeterminate.
3< 1.0 1975 as guidance3.6.c.3.A, 3.6.c.3.C, 3.8.a.9.b.1, 3.8.a.9.b.3, 3.12.c.1, 3.12.c.3 3.6.c.3.A, 3.6.c.3.C, 3.8.a.9.b.1, 3.8.a.9.b.3, 3.12.c.1, 3.12.c.3 3.6.c.3.B, 3.8.a.9.b.2, 3.12.c.2 9 ASTM D3803-1989 and AG-1, and using 11975 as guidance
< 1.0 of 95% 1 15 INSERT 5DOC A05, 4.4.c.1.a, 4.12.a.1, 4.17.a.1 INSERT 2 ANSI ANSI ANSI1, and 1 1safety related safety related safety related safety related listed belowusing design 10INSERT 3 listed below using INSERT 4 10design listed below and AG-1 14 11 1as guidance 14 1975, 11 14 11 14 11 14 14 Stet 1 1 Stet Stet A TSM D3803-1989
, Stet Regulatory Positions C.5.c and C.5.d of Stet Regulatory
Position C.5.c of Stet Regulatory
Position C.5.d of 5.5 Insert Page 5.5-10a INSERT 2 The test described in Specification 5.5.9.a s hall be performed once per 18 months and
after each complete or partial replacement of the high efficiency particulate air (HEPA) filter bank and any maintenance on the system that could affect the HEPA bank bypass
leakage.
The test described in Specification 5.5.9.b shall be performed after each complete or partial replacement of a charcoal adsorber bank or maintenance on the system that could affect the charcoal ads orber bank bypass leakage.
The test described in Specification 5.5.9.c s hall be performed once per 18 months for filters in a standby status or after 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> s of filter operation, and following painting, fire, or chemical release in any vent ilation zone communicating with the system.
The test described in Specification 5.5.9.d s hall be performed once per 18 months.
The test described in Specification 5.5.9.e shall be performed after any maintenance or testing that could affect the air distribution within the systems.
INSERT 3 Safety Related System Shield Building Ventilation System (SBVS) Auxiliary Building Special Ventilation (ASV) System
Control Room Post Accident Recirculation (CRPAR)
System INSERT 4 Safety Related System SBVS ASV System CRPAR System 14 4.4.c.2.a, 4.4.d.1, 4.17.b.1 4.4.c.2.c, 4.4.d.1, 4.17.b.3 14 4.4.c.2.b, 4.4.d.1, 4.17.b.2 4.4.c.1.a, 4.4.d.1, 4.17.a.1 4.4.c.3, 4.4.d.1 CTS 14 Flow Rate (cfm) 5700 9000 2500 Flow Rate (cfm) 5700 9000 2500 5.5 Insert Page 5.5-10b INSERT 5 Safety Related System Penetration SBVS < 2.5% ASV System
< 2.5% CRPAR System
< 5%
14 Programs and Manuals 5.5 WOG STS 5.5-11 Rev. 3.1, 12/01/05 CTS 5.5 Programs and Manuals
5.5.11 Ventilation Filter Testing Program (continued)
ASTM D 3803-1989 is a more stringent testing standard because it does not differentiate between used and new charcoal, it has a longer equilibration period
performed at a temperature of 30°C (86°F) and a relative humidity (RH) of 95%
(or 70% RH with humidity control), and it has more stringent tolerances that improve repeatability of the test.
Allowable Penetration = [(100% - Methyl Iodide Efficiency
- for Charcoal Credited in Licensee's Accident Analysis) / Safety Factor]
When ASTM D3803-1989 is used with 30°C (86°F) and 95% RH (or 70% RH with humidity control) is used, the staff will accept the following:
Humidity control can be provided by heaters or an NRC-approved analysis that demonstrates that the air entering the charc oal will be maintained less than or equal to 70 percent RH under worst-case design-basis conditions.
If the system has a face velocity greater than 110 percent of 0.203 m/s (40 ft/min), the face velocity should be specified.
- This value should be the efficiency that was incorporated in the licensee's accident analysis which was reviewed and approved by the staff in a safety evaluation. ------------------------------------------------------------------------------------------------------------
- d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate
specified below [+/- 10%].
ESF Ventilation System Delta P Flowrate
[ ] [ ] [ ]
[ e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below [+/- 10%] when tested in accordance with
[ASME N510-1989].
ESF Ventilation System Wattage ]
[ ] [ ]
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.
9 15 1 4.4.c.1.a, 4.4.d.1, 4.12.a.1, 4.17.a.1 DOC A05 INSERT 7 safety related listed below design INSERT 6 10 11 6 14 14 12 Stet 1 A NSI N510-1975 Stet 5.5 Insert Page 5.5-11 INSERT 6 Safety Related System Combined Delta P (in. wc) HEPA only Delta P (in. wc)
SBVS < 10 < 4 ASV System < 10 < 4 CRPAR System < 6 < 4 INSERT 7 Demonstrate for each of the safety related systems listed below that when tested at the system design flowrate (+/- 10%) the air distribution is uniform within +/- 20%.
Safety Related System SBVS ASV System 14 14 Flow Rate (cfm) 5700 9000 2500 specified below Flow Rate (cfm) 5700 9000 6.3 4 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS Kewaunee Power Station Page 2 of 4 9. The Inservice Testing Program (ISTS 5.5.8) has been modified to state that the IST Program provides control for AS ME Code Class 1, 2, and 3 "pumps and valves" in place of the current "components." 10 CFR 50.55a(f) provides the regulatory requirements for the IST Program. It specifies that ASME Code Class 1, 2, and 3 pumps and valves are the only components covered by an IST Program. 10 CFR 50.55a(g) provides regulatory requirements for an Inservice Inspection (ISI) Program. It specifies that ASME Code Class 1, 2, and 3 components are covered by the ISI Pr ogram, and that pumps and valves are covered by the IST Program in 10 CF R 50.55a(f). The ISTS does not include ISI Program requirements as these requirements have been relocated to a plant specific document. Therefore, the components to which the IST Program applies (i.e., pumps and valves) have been added for clarity. In addition, the statement "The program shall include the following:" has been deleted because not all of the statements that follow are really part of the program requirements.
Furthermore, the terms weekly, semi annually, and every 9 months have been
deleted since these terms are not used in the ASME OM Code.
- 10. ITS 5.5.9.a, b, and d include a requirement for the system nominal flowrate value to be specified. ITS 5.5.9.a, b, and d do not include the specific nominal flowrate.
ITS 5.5.9.a, b, and d specify that the flowrate is the "system design flowrate."
This is consistent with the CTS, since the CTS does not include specific values for each of the safety related ventilati on systems. The CTS (CTS 3.6.c.3.C, 3.12.c.3, 4.4.c.1.a, 4.4.c.3, and 4.17.a.1) only includes the requirement that the tests be conducted at the system design flowrate (+
10%). 11. ISTS 5.5.11 uses the term "Engineered Safety Feature (ESF)" to describe the ventilation systems tested as part of this Specification. The three ventilation systems covered in ITS 5.5.9 are the Shield Building Ventilation System (SBVS), Auxiliary Building Special Ventilation (ASV) System, and Control Room Post Accident Recirculation (CRPAR) System. The KPS CRPAR System is not an ESF. Therefore, the term has been changed to "safety related," since all three of
the ventilations system s are safety related.
- 12. The Reviewer's Note to ISTS 5.5.9.c and the subsequent wording states alternate tube repair criteria that are currently permitted by the plant technical specifications should be provided in the ITS. ISTS 5.5.9.f (ITS 5.5.7.f), including the Reviewer's Note, states, in part, the tube repair methods currently permitted by plant technical specifications should be provided in the ITS. The bracketed allowance to provide steam generator tube repair criteria and methods are not included since the current KPS Steam Generator Program does not allow repair; only plugging is allowed.
- 13. Kewaunee Power Station has steam generators with Alloy 690 thermally treated tubing. Therefore the third option is maintained, consistent with the current Technical Specifications.
- 15. The Reviewer's Note contains information for the NRC reviewer to be keyed into what is needed to meet this requirement.
This is not meant to be retained in the Not used.
Programs and Manuals 5.5 WOG STS 5.5-10 Rev. 3.1, 12/01/05 CTS 5.5 Programs and Manuals
5.5.11 Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].
- a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. ESF Ventilation System Flowrate
[ ] [ ]
- b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].
ESF Ventilation System Flowrate
[ ] [ ] c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.
ESF Ventilation System Penetration RH Face Velocity (fps)
[ ] [See Reviewer's [See [See Reviewer's Note] Reviewer's Note] Note]
REVI EWER'S NOTE---------------------------------------- The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility is indeterminate.
3< 1.0 19753.6.c.3.A, 3.6.c.3.C, 3.8.a.9.b.1, 3.8.a.9.b.3, 3.12.c.1, 3.12.c.3 3.6.c.3.A, 3.6.c.3.C, 3.8.a.9.b.1, 3.8.a.9.b.3, 3.12.c.1, 3.12.c.3 3.6.c.3.B, 3.8.a.9.b.2, 3.12.c.2 9 1 1975< 1.0 of 95% 1 15 INSERT 5DOC A05, 4.4.c.1.a, 4.12.a.1, 4.17.a.1 INSERT 2 6 ANSI ANSI ANSIsafety related safety related safety related safety related listed belowINSERT 3 listed below Regulatory Position C.5.d of INSERT 4 listed below and AG-1 11 11 11 11 14 14 14 14 14 14 1 1975, ASTM D3803-1989,Regulatory Position C.5.c ofRegulatory Positions C.5.c and C.5.d of 5.5 Insert Page 5.5-10a INSERT 2The test described in Specification 5.5.9.a shall be performed once per 18 months and after each complete or partial replacement of the high efficiency particulate air (HEPA) filter bank and any maintenance on the system that could affect the HEPA bank bypass leakage. The test described in Specification 5.5.9.b shall be performed after each complete or partial replacement of a charcoal adsorber bank or maintenance on the system that could affect the charcoal adsorber bank bypass leakage. The test described in Specification 5.5.9.c shall be performed 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 following painting, fire, or chemical release in any ventilation zone communicating with the system.The test described in Specification 5.5.9.d shall be performed once per 18 months.
The test described in Specification 5.5.9.e shall be performed after any maintenance or testing that could affect the air distribution within the systems.
INSERT 3Safety Related System Flow Rate (cfm)
Shield Building Ventilation System (SBVS) 5700Auxiliary Building Special Ventilation (ASV) System 9000 Control Room Post Accident Recirculation (CRPAR)
System 2500 INSERT 4Safety Related System Flow Rate (cfm)
SBVS 5700 ASV System 9000 CRPAR System 2500 14 4.4.c.2.a,4.4.d.1, 4.17.b.1 4.4.c.2.c,4.4.d.1, 4.17.b.3 14 4.4.c.2.b,4.4.d.1, 4.17.b.2 4.4.c.1.a,4.4.d.1, 4.17.a.1 4.4.c.3, 4.4.d.1CTS 14 Programs and Manuals 5.5 WOG STS 5.5-11 Rev. 3.1, 12/01/05 CTS 5.5 Programs and Manuals
5.5.11 Ventilation Filter Testing Program (continued)
ASTM D 3803-1989 is a more stringent testing standard because it does not differentiate between used and new charcoal, it has a longer equilibration period
performed at a temperature of 30°C (86°F) and a relative humidity (RH) of 95%
(or 70% RH with humidity control), and it has more stringent tolerances that improve repeatability of the test.
Allowable Penetration = [(100% - Methyl Iodide Efficiency
- for Charcoal Credited in Licensee's Accident Analysis) / Safety Factor]
When ASTM D3803-1989 is used with 30°C (86°F) and 95% RH (or 70% RH with humidity control) is used, the staff will accept the following:
Humidity control can be provided by heaters or an NRC-approved analysis that demonstrates that the air entering the charcoal will be maintained less than or equal to 70 percent RH under worst-case design-basis conditions.
If the system has a face velocity greater than 110 percent of 0.203 m/s (40 ft/min), the face velocity should be specified.
- This value should be the efficiency that was incorporated in the licensee's accident analysis which was reviewed and approved by the staff in a safety
evaluation. ------------------------------------------------
- d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate
specified below [+/- 10%].
ESF Ventilation System Delta P Flowrate
[ ] [ ] [ ]
[ e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below [+/- 10%] when tested in accordance with
[ASME N510-1989].
ESF Ventilation System Wattage ]
[ ] [ ]
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.
9 15 1 4.4.c.1.a, 4.4.d.1, 4.12.a.1, 4.17.a.1 DOC A05 INSERT 7safety related listed below INSERT 6 11 6 14 14 ANSI 1975 5.5 Insert Page 5.5-11 INSERT 6Safety Related System Combined Delta P (in. wc) Flow Rate (cfm)SBVS < 6.35700 ASV System < 6.3 9000 CRPAR System < 4 2500 INSERT 7Demonstrate for each of the safety related systems listed below that when tested at the system flowrate specified below (+/- 10%) the air distribution is uniform within +/- 20%. Safety Related System Flow Rate (cfm)
SBVS 5700 ASV System 9000 14 14 Licensee Response/NRC Response/NRC Question Closure Id3361NRC Question Number VGC-009 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. Review conducted by Harold Walker of SCVB. Response Statement Question Closure Date 6/2/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 6/2/2010 6:34 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/29/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=3361 ITS NRC Questions Id1901NRC Question Number VGC-010 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number JFD Bases Number Page Number(s) Vol 16, on page 90 of 167 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In Vol 16, on page 90 of 167 in TS 5.5.9 (several places) when discussing your proposed use of Reg Guide 1.52 you have replaced the words "in accordance with" with "using". What is the justification for this substitution, and how do you interpret the two differently in how they affect your commitment to and application of the subject document.
Attach File 1 Attach File 2 Issue Date 3/18/2010 Added By Victor Cusumano Date Modified Modified By Date Added 3/18/2010 9:43 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1901 Licensee Response/NRC Response/NRC Question Closure Id2831 NRC Question Number VGC-010 Select Application Licensee Response Response Date/Time 4/22/2010 2:15 PM Closure Statement Response Statement Currently, Kewaunee Power Station (KPS) conducts ventilation filter tests (as applicable) in accordance with ASTM D3803-1989 and AG-1 and using the guidance of Regulatory Guide (RG) 1.52, Rev. 1, and ANSI N510-1975.
However, KPS has reviewed the current licen sing basis and will delete the term "using the guidance." The tests will be in accordance with the listed documents, as applicable (i.e., RG 1.52, Rev.
2 (note that the revision has changed as stated in the KPS response to VGC-009) and ANSI N510-1975).
A draft markup regarding this change is attached to the KPS response to VGC-009. Note that the attached change includes changes due not only to this response, but also includes changes identified in the KPS responses to VGC-009 and VGC-011. This change will be reflected in the supplement to this section of the ITS conversion amendment. In addition, a clean draft markup of ITS 5.5.9, which shows how the ISTS Markup will look when the
revision to the ITS submittal is made (i.e., the Rev. 1 version of the ISTS Markup), is also included and attached to the KPS response to VGC-009 to assist in understanding the changes.
Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Robert Hanley Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 4/22/2010 2:15 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/29/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2831 Licensee Response/NRC Response/NRC Question Closure Id3371NRC Question Number VGC-010 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. Review conducted by Harold Walker of SCVB. Response Statement Question Closure Date 6/2/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Victor Cusumano Date Added 6/2/2010 6:35 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/29/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=3371 ITS NRC Questions Id1911NRC Question Number VGC-011 Category Technical ITS Section 5.0 ITS Number 5.5 DOC Number JFD Number JFD Bases Number Page Number(s) In Vol 16, on page 90 of 167 in TS 5.5.9 (several places) when discussing your proposed use of Reg G NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In Vol 16, on page 90 of 167 in TS 5.5.9 (and several other places throughout the submittal) you have deleted the reference to plant-specific flowrates. I understand that work is in process for the recalculation of these values at Kewaunee. Please provide a justification for their exclusion, or a plan for their inclusion.
Attach File 1 Attach File 2 Issue Date 3/18/2010 Added By Victor Cusumano Date Modified Modified By Date Added 3/18/2010 9:44 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=1911 Licensee Response/NRC Response/NRC Question Closure Id2841 NRC Question Number VGC-011 Select Application Licensee Response Response Date/Time 4/22/2010 2:15 PM Closure Statement Response Statement The current Kewaunee Power Station (KPS) licensing basis is as the proposed ISTS markup shows. That is, the specific flow rates are not identified in the CTS; only a statement that the flow rates are the design flows. However, KPS has re-reviewed the issue and will include the current design flows in the ITS. Furthermore, due to a recent calculation that recalculated the design flows, the dp acceptance criteria for ITS 5.5.9.d has also been affected. Therefore, the dp acceptance criteria has also been changed and is included as part of this change. A draft markup regarding this change is attached to the KPS Response to VGC-009. Note that the attached change includes changes due not only to this response, but also includes changes identified in the KPS responses to VGC-009 and VGC-010. This change will be reflected in the supplement to this section of the ITS conversion amendment. In addition, a clean draft markup of ITS 5.5.9, which shows how the ISTS Markup will look when the revision to the ITS submittal is made (i.e., the Rev. 1 version of the ISTS Markup), is also included and attached to the KPS response to VGC-009 to assist in understanding the changes. Furthermore, the calculations that support the design flows and the dp acceptance criteria for the three affected systems (Shield Building Ventilation System, Auxiliary Building Special Ventilation System, and Control Room Post Accident Recirculation System) are attached to this response.
Question Closure Date Attachment 1 Calcs for VGC-011 Response.pdf (5MB) Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 4/22/2010 2:21 PM Modified By Date Pa ge 1of 2 Kewaunee ITS Conversion Database 06/29/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2841 Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/29/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT yp e=areaIte mPrint&itemId=2841 CLIENT: PROJECT: ZACHRY NUCLEAR ENGINEERING, INC.CALCULATION TITLE SHEET Dominion Energy Kewaunee, Inc HV AC Calculations CALCULATION TITLE: Shield Building Ventilation Pressure Loss KPS CALCULATION NO.: 12123 Revision 1 PPC CALCULATION NO.: 09-059 Revision A JOB NO.: 051470 COMPUTER CODE&VERSION (if applicable):
PROTO-BY AC v.1.01 ZACHRY NUCLEAR ENGINEERING, INC.PROPERTY CODE (if applicable):
000551 QA CLASSIFICATION:
Safety Related IZI Yes 0 No REV 1 TOTAL NO.OF PAGES 371 ORIGINATORIDATE
/YY)......r_,.,..." I (J/',oP Mattliew Andel VERIFIERIDATE APPROV AL/DATE\,\**DO NOT REVISE THIS CALCULATION
- OBTAIN ORIGINAL FROM CLIENT**Page i ofiv Form No.: P030101 sheet 1 of 1 Rev.: 0-01 Date: 5/09 Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE ii OF iv GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael NOlWood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss Revision History Revision Revision Description 0 Original Issue 1 Revised to detennine maximum allowed DP for HEP A and Charcoal filters at tech spec flow rates as well as at recommended flow rates as detennined by calculation C11858 Form No.: P030102 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE iii OF iv GROTON, CONNECTICUT ORIGrnATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss CALCULATION VERIFICATION FORM 2.EXTENT OF VERIFICATION:
Complete calculation (including attachments
/appendices) has been reviewed to determine impact of revision on un-revised areas.1.VERIFICATION METHOD: Yes N/A A.Approach CheckedB.Logic Checked[8]C.Arithmetic Checked[8]*D.Alternate Method D*(Provide documentation)
E.Other D**Describe below.A.IDV of Complete calculation (including attachments/appendices)
.B.IDV of revised areas of Calculation only.C.Other (describe below):[8]D D A.IDV documentation as attachment with Calc Errors Detected See Attachment J 3.DOCUMENTATION OF VERIFICATION
[8]B.IDV documentation D C.IDV documentation is this fonn forwarded to QAandany continuation pages only.Error Resolution See Attachment J D*Verification Method: Verified that Inputs are correct and correctly used, outputs are reasonable, and calculations of SCFM and sums of pressure drops are correct.Verified that PROTO-HVAC cases are aligned correctly.
Other Comments Extra References Used (Attach extra sheets ifneeded (Use Form P030114>>THE APPROACH,LOGIC,AND METHODOLOGY OF THE CALCULATION IS ACCEPTABLE.
THE GUIDELINES DEFINED IN PARA.7.5.4 (AS APPLICABLE)
OF P 3-1 HAVE BEEN MET.THE OVERALL CALCULATION IS FOUND TO BE VALID AND CONCLUSIONS TO BE CORRECT AND REASONABLE:
IDV Signature:7/Printed Name: Michael Norwood Date: 10/6)Q9 Form No.: P030103 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE iv OF iv GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss TABLE OF CONTENTS TITLE SHEET I REVISION HISTORY.............................................................................................*...............................................................
ll VERIFICATION FORM III TABLE OF CONTENTS..............................................................................*.........................................................................
IV LIST OF ATTACIIMENTS
.................................*................*................................................................................*...............
IV Total number of pages in Preface ofealc.4 1.0 PURPOSE 1 2.0 BACKGROUND 1 3.0 INPUTS AND ASSUMPTIONS 1 4.0 METHODOLOGY 4
5.0 REFERENCES
...*...................................................*........*..............................................................*............................
6 6.0 CALCULATIONS AND RESULTS...................................................................*........*.............................................
8
7.0 CONCLUSION
S AND RECOMMENDATIONS 12 Total number of pages in Body of Calc.16 LIST OF ATTACHMENTS Attachment Subject Matter Total Pa2:es A Calculation 12123, Revision1-PROTO-HV AC Model Inputs 138 B Calculation 12123, Revision1-Output Reports for Benchmark 39 C Calculation 12123, Revision 1-Output Reports for Vendor Supplied Pressure 39 Drops D Calculation 12123, Revision1-Output Reports for Design Flow Rate-10%39 E Calculation 12123, Revision1-Work Order Data Referenced in Calculation 67 F Calculation 12123, Revision1-E-mail"RE: RAS for SBV system" 2 G Calculation 12123, Revision 1-Excerpts from HV AC Systems Duct Design 2 H Calculation 12123, Revision1-Filter Component Infonnation from PO#K300 8 I Calculation 12123, Revision1-Visio Schematic of Model 2 J Calculation 12123, Revision 1 illV Comment and Resolution Fonn 2 K Calculation 12123, Revision1-Client Comments for Revision 1 13 Total number of pages in Attachments Complete Calculation (total number of pages)351 371 Form No.: P030104 sheet 1 of 1 Rev.: 0-01 Date: 5/09 Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 1 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 1.0 PURPOSE The purpose of this calculation is to determine the recommended system flow rate for the Shield Building Ventilation (SBY)system and to compare the filter component pressure drops at this flow rate to the technical specification filter component pressure drops.2.0 BACKGROUND Currently there is conflicting infonnation regarding the proper design flow rate of the SBV system.Reference 5.1 states that the SBV System Design Flow rate is 5,000 SCFM.Reference 5.2 states that the SBV System flow rate is 6,000 CFM+/-10%.The Reference 5.33 and 5.34 SBV filter test procedures state that the SBV fan flow during SBV filter testing should be between 4,500 and 6,600 CFM.The technical specifications (tech spec)state that the allowable SBV system flow rate is the system design flow rate+/-10%.The maximum permissible value of 6,600 CFM given in the test procedures is higher than the Reference 5.1 design flow rate of5,000 CFM+10%(5,500 CFM).Further, the Reference 5.24 through 5.27 test data show that the actual SBV flow rates are around 5,700 SCFM, which is also above 5,500 CFM.From this conflicting information, the recommended system design flow rate needs to be determined.
AHV AC model of the SBV system will be constructed and used to determine the required system design flow rate.After the correct SBV design flow rate is determined, the pressure drops across the filter and certain filter components at the design flow rate and the design flow rate-10%(tech spec minimum permissible value)will be compared to the current tech spec pressure drops.3.0 INPUTS AND ASSUMPTIONS 3..1 DESIGN INPUTS 3.1.1 Duct physical infonnation, such as lengths, number and type of fittings, and damper information, was taken from References 5.1 through 5.8 and Reference 5.21.3.1.2 Fan curve data was provided by Reference 5.9.3.1.3 Test data filter pressure drop and flow information for all filter components was provided by References 5.24 through 5.27.An uncertainty analysis was not perfonned for this calculation because test data uncertainty infonnation was not available.
3.1.4 Vendor supplied pressure drop values for clean filter conditions for the electric heating coil, prefilter, and charcoal filter were provided by Reference 5.19.Reference 5.19 includes components purchased for the filter assemblies in this calculation.
Reference 5.20 confinns that the data pages in Attachment H are from Reference 5.19..Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09 Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 2 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 3.1.5 The acceptable airflow range for the SBV charcoal filters is 4,510 SCFM-6,600 SCFM per Reference 5.23.3.1.6 Where duct sections contained more than 2 different angled bends, subsequent bends were input as Misc.K fixed resistances, as calculated per Reference 5.28.3.2 ASSUMPTIONS 3.2.1 For all analyses in this calculation, it is assumed thattheSBV system is operating with the modulating dampers positioned to maintain an annulus pressure of-0.6" WC based on Reference 5.10, section 1.4.3.2.2 It is assumed that dampers CD34124 and CD34127 in the recirculation lines are positioned at 5/8 open (33.75°from centerline in PROTO-HVAC model)and dampers CD34125 and CD34128 in the exhaust lines are positioned at 3/8 open (56.25°from centerline in PROTO-HVAC model)when these dampers are in service.The SBV Monthly test data in References 5.11 through 5.17 all list the dampers positioned thusly.All other dampers are either fully opened or fully closed based on the train being run.3.2.3 It is assumed that atmospheric pressure at Kewaunee Power Station is 14.375 psia based on the analysis in Reference 5.18.3.2.4 The clean pressure drop across the moisture separator is assumed to be 0.09" WG at 5,776 SCFM (.067" WG at 5,000 SCFM)because this is the lowest value for this component from the Reference 5.24 through 5.27 test data.This is a reasonable clean DP because it is considerably less than the value of 0.5" WG given in Reference 5.32 for when the moisture separator should be changed due to a dirty filter.3.2.5 For all analyses, air conditions of 70°F and 50%relative humidity were assumed, which are typical conditions for HV AC applications.
3.2.6 Reference 5.1 shows four backdraft dampers downstream of fans 1A and 1B without tags.For the PROTO-HV AC model, these dampers were labeled as"BD" followed by the number of the duct in which they are located.The backdraft damper in duct 17.1 is given the number 171 to avoid complications in using a decimal point in the label.3.2.7 Reference 5.8 shows dampers without tags just upstream of the duct outlets.For theHV AC model, these dampers were labeled as"Damper" followed by the number of the duct in which they are located.3.2.8 It is assumed that all filter components, with the exception of the heater and charcoal filter, become clogged at the same rate.This is conservative because if only one filter component Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 3 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss became clogged rather than all becoming clogged, the reported pressure drop for the clogged filter would be higher than what is reported when the clogging is distributed among all components.
3.2.9Themaximum combined filter pressure drop permissible across the charcoal and REP A filter banks is assumed to be lOin WG and the maximum pennissible pressure drop across a REP A filter bank is 4 in WG, per Reference 5.29.3.2.10 The Reference 5.26 test data does not contain a DP for the moisture separator (demister), so the pressure drop for this component was assumed the same as that given in the Reference 5.24 data.3.2.11 It is assumed that the flow resistance of the heaters will not increase above the value given in Reference 5.19.The heaters are heating coils and not filters and are thus not likely to become clogged with debris the way filters become clogged.Thus, for all analyses, the Reference 5.19 pressure drop and flow values, or the equivalent resistance at a different flow rate, were used for the heater.3.2.12 It is assumed that the pressure drop across the charcoal filters will not increase beyond the values given in the Reference 5.24 through 5.27 test data because the charcoal filters do not filter particulate matter.3.2.13 The pressure drop across the REP A filters for vendor specified clean conditions is assumed to be 0.789" WG since the Reference 5.19 data did not specify a pressure drop for the REPA filters.This value was obtained as follows: The total filter pressure drop for clean conditions through the filters is 3+/-0.3in WG per Reference 5.20, which means the lowest pressure drop can be 2.7" WG.This value will be used to detennine the HEP A pressure drop because the minimum possible DP will yield the highest flow rate, and for case run in section 6.2 where this value is used, the objective is to maximize the flow rate.The sum of the pressure drops across the filter components, excluding the REP A filters is 1.122 in WG per Reference 5.19 and Assumptions 3.2.4 and 3.2.11.The pressure drop across the REP A filters is calculated as the difference between the total pressuredropand the non-REPA pressure drop, 2.7" WG-1.122" WG=1.578" WO.The pressure drop for each REP A filter bank is half this value, 0.789" WG.3.2.14Themaximum SBV system flow rate is assumed to be the design flow rate+10%and the minimum is assumed to be the design flow rate-10%, per Reference 5.29.3.2.15 All analysis was done for one train operation because filter testing is done one train at a time per References 5.33 and 5.34 and all test data is thus for one train operation.
Flow rate and pressure drop values are specified on a per train basis.3.2.16 The material for all ducts except duct#1 and 7 was assumed to be"Galvanized Sheet Duct (12 joints!!00 ft)" from the PROTO-HV AC library.The material for duct#1 and 7 is"Spiral Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1--
ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 4 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss Galvanized Duct (12 joints/IOO ft)" from the PROTO-HVAC library per Reference 5.7.It was assumed that this material applied to the entire duct section, not just the section shown on the Referenced drawing.This reference also indicates that several other duct sections are constructed of spiral galvanized duct.However, during the benchmarking process, the roughness of these ducts was changed from galvanized sheet duct to spiral galvanized duct, and this change had a negligible impact on the calculated flow rates;the flow rates were reduced very slightly.Since the calculated flows were already below the test flows, the galvanized sheet duct was used to better match the test flow rates.3.2.17 Flow rate values in Reference 5.19 were assumed to be in SCFM, as this is typical for fan curve flow rates.3.2.18 The location of the heaters in the filter assembly is assumed to be after the 2 nd bank of HEP A filters.The arrangement of the filter components in the flow path is inconsequential since the components are all in series and total pressure drop is simply the sum of component pressure drops.4.0 METHODOLOGY This calculation has been developed using PROTO-HVAC Version 1.01.The PROTO-HVAC software was developed and validated in accordance with Zachry's Nuclear Software Quality Assurance Program (SQAP), Reference 5.22.This program meets the requirements of IOCFR50 Appendix B, 10CFR21, and ANSI NQA-l, and was developed according to the guidelines and standards contained in ANSI/IEEE Standard 730/1984 and ANSI NQA-2b-1991.
The creation of the Shield Building Ventilation System model database consisted of the following steps: 1.Define the system from a schematic as a network of connecting node points.2.Gather detailed data including duct lengths, fitting and component infonnation for the ducting and components between each node point.3.Enter this information into the appropriate field within PROTO-HVAC.
Once this system data has been entered into the database, system operation can be evaluated for the desired operating conditions.
Three case files were created to complete the analyses in the calculation.
FileBENCHMARK.DBD was used for the analysis in section 6.1 to compare the PROTO-HVAC results to test data.After the model was benchmarked, this case was used to determine the recommended system design flow rate.File SBV-VENDCLEAN.DBD was used in section 6.2 Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1 (equation 1)ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 5 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss to detennine system flow rates under vendor-specified clean filter pressure drops and to detennine whether these flow rates were considerably higher than the benchmark flow rates in order to determine the maximum anticipated system flow rate.File SBV-MINFLOW.DBD was used in section 6.4 to determine the filter component pressure drops that would yield the minimum flow rate of the recommended design flow rate-10%.Fan performance is modeled with the fan curve on page 135 of Attachment A.On the fan curve, several pressure data points for flow values lower than4,500SCFM were artificially added to the curve to create a fan curve that had a continuously decreasing discharge pressure with increasing flow.This type of fan curve is required for PROTO-HV AC to converge successfully.
The actual fan curve does not have continuously decreasing discharge pressure with increasing flow for flow rates below approximately 4,500 SCFM, so below this value the curve was modified to create a constantly decreasing discharge pressure.For flow rates above 4,500 SCFM, the fan curve in the PROTO-HV AC model is accurate.Since in the model the fan is operating on its curve at a value above 4,500 SCFM, when the model converges the fan operating point will be on the accurate portion of the fan curve and model accuracy will not be affected.If the model is used in the future for flow rates less than 4,500 SCFM, the fan curve will have to be changed to obtain accurate results.Once the model was created, it was benchmarked against the Reference 5.24 through 5.27 test data.Model Filter component DPs were set to match the filter DPs given in the test data at the flow rates given in the test data.The model was run to obtain a calculated system flow rate and a comparison was made between the calculated flow rates and the test flow rates.With the model adequately benchmarked, the calculated flows and test flows were used to determine the proper design flow rate for the system.Once the design flow rate was detennined, the component filter pressure drops that yielded the minimum pennissible system flow of the design value-10%were detennined to compare these values to the tech.spec.component filter pressure drop values.PROTO-HV AC calculates flow in ACFM, so calculated flows were corrected to SCFM as follows: Pf Qs=Qfx-Ps Where, Qf==actual volume flow rate (ACFM)Qs==standard volume flow rate (SCFM)Ps==air density at standard conditions, 0.075 Ib m/ft3 (Reference 5.30)Pf==air density at the applicable duct section (lb m/ft3)Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 6 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 1015/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss
5.0 REFERENCES
5.1 Kewaunee Power Station Drawing M-602,"Flow Diagram Reactor&Shield Bldg Ventilation", RevisionBD
5.2 Calculation
CN-CRA-00-2,"Kewaunee-LOCA Doses with Increased Control Room Unfiltered Inleakage", Revision 3 5.3 Kewaunee Power Station Drawing M-627,"Ventilation
-Aux Bldg Elevation 657'-6"", RevisionAK 5.4 Kewaunee Power Station Drawing M-628,"Ventilation
-Aux Bldg Elevation 642'-3"", RevisionAH 5.5 Kewaunee Power Station Drawing M-637,"Ventilation Sections&Details", Revision X 5.6 Kewaunee Power Station Drawing M-638,"Ventilation Sections&Details", Revision W 5.7 Kewaunee Power Station Drawing M-652,"Ventilation Shield Building", Revision H 5.8 Kewaunee Power Station Drawing M-653,"Ventilation Shield Building", Revision F 5.9 Kewaunee Power Station Drawing XK-362-6,"Performance Curve For Shield Bldg Vent RecirclA&lB", Revision 0 5.10 KNPP System Description KW-MANUAL-000-SD-24,"Shield Building Ventilation System (SBV)", Revision 2.5.11 KW100413455,"SBV Train A Monthly Test" dated January 27, 2009 (see Attachment E)5.12 KW100419813,"SBV Train A Monthly Test, dated February 24, 2009 (see Attachment E)5.13 KWI00440529,"SBV Train A Operability Test", dated April 23, 2009 (see Attachment E)5.14 KWI00406423,"SBV Train B Monthly Test",datedJanuary 6, 2009 (see Attachment E)5.15 KW100414763,"SBV Train B Monthly Test", dated February 3,2009 (see Attachment E)5.16 KW100421209,"SBV Train B Monthly Test", dated March 3, 2009 (see Attachment E)5.17 KW100429722,"SBV Train B Monthly Test", dated April 3, 2009 (see Attachment E)Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1 iZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 7 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael NOIWood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 5.18 Calculation C10021, Revision 1,"Method for Detennining Diesel Generator Damper Operating Times After Loss of Air-Start Compressors" 5.19 Purchase order PO#K300 (see Attachment H)5.20 E-mail from Jennifer Mueller to Matthew Fallacara,"RE: Fw: Charcoal Filters" dated 12/22/08.(see Attachment H)5.21 Kewaunee Power Station Drawing XK-300-2,"Shield Building Vent Filter Assem-lA&lB Kewaunee Nuclear Plant Wisconsin Public Service Corp", Revision G 5.22 Proto-Power Corporation SQAP-93948,"Software Quality Assurance Plan (SQAP)", Revision H 5.23 Calculation C11858,"Allowable Design Airflow Rates Through Charcoal Filters", Revision 0 5.24 Work Order KW100294113,"PM24-545:
Charcoal and HEPA Filter Testing", dated 4/21/09 (see Attachment E)5.25 Work Order 100272062,"PM24-546:
Charcoal&HEPA Filter Testing", dated 4/16/09 (see Attachment E)5.26 Work Order 07-5404, dated 10/26/07 (see Attachment E)5.27 Work Order 07-5405, dated 10/15/07 (see Attachment E)5.28 HVAC Systems Duct Design, Sheet Metal and Air Conditioning Contractors' National Association, Inc., 1981 Edition (see Attachment G)5.29 Technical Specifications for Kewaunee Power Station, Amendment 206, dated 6/01/2009 5.30 Proto-Power Document UD-93948-03,"User Documentation (UD)for Ventilation System Thennal Hydraulic Modeling Software-PROTO-HV AC" 5.31 E-mail from Brian O'Connell to Matthew Andel,"RE: RAS for SBV system", dated 8/17/2009 (see Attachment F)5.32 Vendor Technical Manual KW-VTM-000-FARR-0001 (XK-300-53), Revision 4 5.33 Procedure SP-24-122A,"Shield Building Vent (SBV)Train A Filter Testing", Revision 5 5.34 Procedure SP-24-122B,"Shield Building Vent (SBV)Train B Filter Testing", Revision 5 Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1--
ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 8 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 5.35 Zachry Nuclear Engineering Quality Assurance Manual, Revision 18 5.36 Kewaunee Power Station Drawing XK-362-4,"Axivane Fan Model 21 1/4-17 1/2 3450 2 Stage With Accessories", Revision A.6.0 CALCULATIONS AND RESULTS 6.1 BENCHMARK C011PARISON The Reference 5.24 through 5.27 test data was used to benchmark the PROTO-HV AC model to measured flow and pressure drop information.
Benchmarking was done for each train, A and B.Benchmarking was done by setting the filter component pressure drop and corresponding flow rate in the model to match the test data (see Table 2 and Table 4 for measured flow rates), and then running the model and comparing the calculated fanflowrate to the measured fan flow rate.The DP and flow values for each train were averaged together, and the average values were used in the PROTO-HVAC model.A verification was done to compare the equivalent component DPs at the average flow rates to the average DP values in Table 1 and Table 2 and this showed that the error introduced in averaging these values was less than the amount of significant figures reported in the tables.For Train A, the pressure drop test data for the filter components is listed in Table 1 and the benchmarking results are in Table 2.For Train B, the pressure drop test data is listed in Table 3 and the benchmarking results are in Table 4.The model fileBENCHMARK.DBD" was used for this analysis, and pertinent output reports are included in Attachment B.Table1-Test Data For Train A Filter Component Pressure Drop Filter Component 4/21/09 DP 10/26/07 DP AvgDP (in WG)(in WG)(in WG)Moisture Separator (Demister) 0.09 0.09 1 0.09 Pre-Filter 0.13 0.15 0.14 HEPAFilter 1 0.9 1.0 0.95 Charcoal Bank 0.9 0.9 0.9 HEP A Filter 2 0.9 0.9 0.9 O.1@5000 0.1@5000 0.1@5000 Heater SCFM 2 SCFM 2 SCFM 2 1.See Assumption 3.2.10 2.See Assumption 3.2.11 Table 2: Benchmark Results for Train A Measured Flow Measured Flow Average Measured Calc.Flow Calc.Flow%Error 4/21/09 (SCFM)10/26/07 (SCFM)Flow (SCFM)(ACFM)(SCFM)5776 5694 5735 5,891 5,624-1.94 Form No.: P030105 sheet 1 of 1 Rev.:_0_-0_1__Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 9 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael NOlWood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss Table3-Test Data For Train B Filter Component Pressure Drop Filter Component 4/16/09 DP 10/15/07 AvgDP (in WG)DP (in WG)(in WG)Moisture Separator (Demister) 0.1 0.1 1 0.1 Pre-Filter 0.1 0.1 0.1 HEP A Filter 1 0.8 0.9 0.85 Charcoal Bank 0.9 0.95 0.93 HEP A Filter 2 0.8 0.9 0.85 0.1@5000 0.1@5000 0.1@5000 Heater SCFM 2 SCFM 2 SCFM 2 1.See Assumption 3.2.10 2.See Assumption 3.2.11 Table 4: Benchmark Results for Train B Measured Flow Measured Flow Average Measured Calc.Flow Calc.Flow%Error 4/16/09 (SCFM)10/15/07 (SCFM)Flow (SCFM)(ACFM)(SCFM)5911 5590 5751 5,837 5,572-3.11 The above benchmark results serve as a general indication of the validity of the model, since the percent error in the calculated values is less than 5%.6.2 FLOW RATE WITH VENDOR-SUPPLIED COMPONENT PRESSURE DROPS Each train of the SBV system was run with the vendor component pressure drops given for clean filter conditions.
The flow rate entered into the model corresponding to the pressure drop is 5,000 SCFM.Where the vendor data gave a component pressure drop at a flow rate other than 5,000 SCFM, the pressure drop was converted to a value at 5,000 SCFM using the following fonnula: (equation 2)where: Ql=given flow rate LlPl=pressure drop at Ql Q2=flow rate for which pressure drop is desired LlP 2=pressure drop at Q2 The pressure drops used for both trains are given in Table 5, below: Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1--
ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 10 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss t 5000 SCFM D tP a e-en or upp Ie ean 1 er omponen res sure raps a , Moist.Sep.Prefilter DP Hepa 1 DP Charcoal DP Hepa2DP Heater DP DP (in WG)(in WG)(in WG)(in WG)(in WG)0.067 1.037 0.789 2 0.918 0.789 2 0.1 T bl5VdS 1*d CI F*lt C 1.See Assumption 3.2.4 2.See Assumption 3.2.13 The model was run using the Table 5 pressure drops to determine the system flow rate under these filter conditions.
The system flow rates calculated for each train, as determined using the PROTO-HV AC Fan Status Report (included in Attachment C), are given in Table 6, below.The model file"SBV-VENDCLEAN.DBD" was used for this analysis and the pertinent output reports are included in Attachment C.Table6-Calculated System Flow rates for Vendor Supplied Filter DPs flow rate flow rate (ACFM)(SCFM)TrainA 5837 5565 TrainB 5761 5523 The analysis in this section was completed to determine if the system flow rates when the filters were at clean conditions as specified in the vendor data would be substantially higher than the flow rates observed in the test data.When the component pressure drops in Table 5 are converted to the equivalent pressure drops at the test flow rates of 5,735 SCFM for Train A and 5,751 SCFM for Train B, the total filter resistance is higher than the filter resistance given in the test data, and thus the system flow rates are lower, as indicated in Table 6.If the flow rates determined here were substantially higher than the test data flow rates, the higher flow rates would be an indication of the maximum possible system flow rate.Since the calculated system flow rates obtained when using the vendor supplied clean filter DPs are less than the flow rates calculated when using the test data filter DPs in Section 6.1, this means that the current systemfiltersare less restrictive than the filters meeting the vendor specified flow and DP values for clean filters and it is conservative to use the benchmark case as the clean filter case.6.3 RECOMl\1ENDED SYSTEM DESIGN FLOW RATE The recommended SBV system design flow rate is 5,700 SCFM.In order for the charcoal filters to effectively remove contaminants from the air flow, the flow through the filters must be between 4,510 SCFM-6,600 SCFM, per Reference and 5,700 SCFM is soundly within this range.The Reference 5.2 accident analysis uses a SBV system flow rate of 6,000 SCFM+/-10%, which gives a range of 5,400 SCFM-6,600 SCFM, and 5,700 SCFM is within this range also.References 5.33 and 5.34 state that the fan flow must be between 4,500 SCFM and 6,600 SCFM when the system is tested, and 5,700 SCFM is also within this range.If+/-10%is applied to 5,700 SCFM, the flow range is 5,130 SCFM-6,270 SCFM, and this range is within the flow Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 11 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss limits discussed above for the charcoal filter effective contaminant removal, the accident analysis, and the actual operating point on the fan curve given the system resistance with clean filters.The PROTO-HV AC analyses and test data show that the SBV system flow is around 5,700 SCFM, and given the system resistance using vendor supplied component pressure drops for clean filters, it is unlikely that the system flow rate will be substantially above 5,700 SCFM in the current configuration.
Since the model and test data show system operation of approximately 5,700 8CFM and 5,700 SCFM meets all the requirements discussed for fan flow, charcoal filter flow, and accident analysis flow, it is recommended that 5,700 SCFM be the SBV system design flow rate.6.4 MINIMUM FLOW WITH DIRTY FILTERS The component pressure drops were increased above the test data values until the system flow was reduced to the minimum permissible value of the design flow rate-10%, which is 5,130 SCFM.The average test data pressure drops were used as the starting values rather than the vendor supplied clean pressure drops because the test data pressure drops are less restrictive than the vendor supplied clean pressure drops, as shown in Section 6.2.The test data pressure drops were converted to pressure drops at 5,130 SCFM from the average test data flow rates using equation 2 to facilitate the comparison in DP between design flow and minimum flow.The values used as the starting values for each component are given in Table 7.t 5 130 SCFM tDP I a e-a lng omponen va ues a , I Filter Component TrainA TrainB Moisture Separator (Demister) 0.072 0.08 Pre-Filter 0.112 0.08 HEP A Filter 1 0.76 0.676 Charcoal Bank 0.72 0.74 HEP A Filter 2 0.72 0.676 Heater0.1050.105 T hI 7 8t rf C The pressure drop across the heater was kept at its benchmarked value, as this component is not likely to become clogged with debris.The charcoal filter pressure drop was also kept at its benchmarked value because the charcoal filter does not remove particulate matter.All other filter component pressure drops were increased by the same percentage from their test data value until the system flow rate for each train reached the target of 5,130 SCFM.The pressure drops at this condition are reported in Table 8 for both trains.The model file"8BV-MINFLOW.DBD" was used for this analysis and the pertinent output reports are included in Attachment D.The pressure drop data in the table was obtained from the DP values input into the fixed resistance field oftheduct section data window in PROTO-HVAC.
Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 12 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss Table8-Filter Pressure Drops at 5,130 SCFM Moist.Hepa 1 Hepa2 HeaterDP HEPAand SepDP Prefilter DP DP CharcoalDP DP (in WG)CharcoalDP TotalDP Train (in WG)(in WG)(in WG)(in WG)(in WG)(in WG)(in WG)TrainA 0.217 0.337 2.288 0.72 2.167 0.105 5.175 5.834 TrainB 0.242 0.242 2.042 0.74 2.042 0.105 4.824 5.413 For both trains, both the total filter pressure drop and the HEPA filter pressure drops are considerably below the Assumption 3.2.9 maximum values.6.5 MOTOR HORSEPOWER REQUIRED Reference 5.9 shows that the SBV fan blade setting is halfway between#8 and#10.Using the horsepower curves for a#8 and#10 blade to extrapolate thefanBHP at 5,700 SCFM halfway between these 2 HP curves gives 20HP.Per Reference 5.10 and 5.36, the SBV fan serial number is SF 27913.Reference 5.10 states that the motor with this serial number is 25 HP, thus the SBV fan motor is sufficient for the recommended design flow rate of 5,700 SCFM.
7.0 CONCLUSION
S AND RECOMMENDATIONS 7.1
SUMMARY
OF RESULTS 7.1.1 FLOW RESULTS The proper design flow rate of the SBV system has been determined to be 5,700 SCFM based on the PROTO-HVAC analysis and system test data.5,700 SCFM is acceptable for the filter flow rate as it is within the acceptable range given in Design Input 3.1.5.It is also within the acceptable rangeforSBV fan flow that is given in References 5.33 and 5.34 of 4,500 and 6,600 CFM.5,700 SCFM is below the flow rate of 6,000 SCFM used in Reference 5.2, so this reference will need to be evaluated to determine the impact of this lower flow on the Reference 5.2 analysis.7.1.2 FILTER PRESSURE DROP RESULTS The technical specification for the SBV filterunitsstates that the pressure drop across the combined REP A filters and charcoal adsorber banks must be less than 10" WG and must be less than 4" WG across any HEP Afilterbank.
at the system design flow rate (+/-10%).The fan static pressure for the no-flow condition is 11" WG, as determined from Reference 5.9, and the filter components must be able to withstand this pressure.The pressure at the no-flow condition is less than the maximum fan total pressure of 14.5" WG which occurs at approximately 4,500 SCFM.The vendor technical manual (Reference 5.32)for the filters lists the following pressure drop Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 13 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss limits for when filter components should be replaced: Moisture Separator 0.5" WG Prefilter 0.5" WG HEPA filter 3.0" WG Charcoal adsorber n/a A table summarizing the train A and B PROTO-HV AC calculated values and the limiting DP values discussed above is below.Table9-Summary of Filter DP Values Moist.Prefilter Hepa 1 Charcoal Hepa 2 Heater HEPA and Total SepDP DP (in DP (in DP (in DP (in DP (in CharcoalDPDP (in Train (in WG)WG)WG)WG)WG)WG)(in WG)WG)Train A calculated 0.217 0.337 2.288 0.72 2.167 0.105 5.175 5.834 Train B calculated 0.242 0.242 2.042 0.74 2.042 0.105 4.824 5.413 Tech spec limit n/a n/a 4 n/a 4-nJa 10 n/a.Fan static pressure at 0 CFM (in WG)11 Vendor recommended max pressure 0.5 0.5 3 n/a 3 n/a nJa n/a Margin calculated from train with higher component DP and lower maximum allowable value 0.258 0.163 0.712 n/a 0.833 n/a 4.825 n/a Comparing the calculated values to the limiting values discussed above shows that all calculated values are below all pertinent limiting values.The Reference 5.33 and 5.34 procedures have administrative limits for filter DP values that were set due to CR 323062.The calculated pressure drops determined in this calculation should be used to replace the administrative DP limits in those references.
7.1.3 PROTO-HVAC Files Used The following PROTO-HV AC database files were used in the analyses for this calculation:
SBV-BENCHMARK.DBD, 478kb, 9/8/2009 1:38pm SBV-VENDCLEAN.DBD, 460kb, 9/8/2009 5:27pm SBV-MINFLOW.DBD, 460kb, 9/15/2009 4:06pm The files listed above have been prepared, documented and independently verified in accordance with Proto-Power's Quality Assurance Manual, Reference 5.35.These files are suitable for use with flow rates above 4,500 SCFM as discussed in section 4.0.The results in this calculation are valid for the as-modeled configuration which was benchmarked to test data.Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 14 OF 16 GROTON, CONNECTICUT ORIGlNATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 7.2 Lll\ffi1NG ACCIDENT SCENARIOS The SBV system is only in operation following a loss of coolant accident (LOCA)per Reference 5.10;thus a LOCA is the limiting accident scenario for the SBV system.7.3 ACCEPTANCE CRITERIA 7.3.1 The system flow rate for the SBV filter conditions should not exceed 6,600 SCFM per Design Input 3.1.5.The recommended system design flow rate of 5,700 SCFM is below this value, as are all calculated and test data flow rates.7.3.2 The maximum allowed filter DPs should not exceed the vendor recommended pressure drop values given.Table 9 shows that the calculated maximum allowable filter DPs at the minimum allowable system flow are below the vendor recommended values.7.4 00 ACT TO SYSlEMS, SlRUCTURES AND COMPONENTS This calculation impacts the Shield Building Ventilation System filter maximumDP.Documents impacted by this change are listed in section 7.14.7.5 CONSERVATIVENESS OF CALCULATION AND AVAILABLE MARGIN The calculation is conservative since it uses minimum allowable flow rates when calculating pressure drops.Based on the margin values calculated in Table 9, the filter component with the lowest margin available is the Train A prefilter, with a margin of 0.163" WO.7.6 UNCERTAINTY OF RESULTS An uncertainty analysis was not performed for this calculation.
Uncertainty may either be covered in the licensing basis or calculated in another calculation if needed in the future.7.7 CONSISlENCY wrrn DESIGN AND OPERATION OF PLANT There is currently an inconsistency between plant operation and the SBV system design flow rate.The SBV System Design Flow is listed differently in different documents as described in section 2.0 and the SBV test data flow rates show different values.The results of this calculation resolve this discrepancy by recommending a system design flow rate.This will also resolve CA081875 (CR106464) which addresses the issue of the different flow rate values.7.8 INPUT ASSUMPTIONS see section 3.2 Form No.: P030105 sheet 1 of 1 Rev.: 0-01---Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 15 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 10/5/09 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 7.9 EQ PROGRAM LICENSlNG BASIS REQUIREMENTS This calculation does not deal with area temperatures and therefore has no effect on the EQ Program..7.10 OPEN ITEMS (NEW OR CLOSURE)This calculation will resolve CA081875 (CRI06464) and CA).28813 (CR323062).
CA081875 addresses the discrepancies in SBV flow rate among the fan acceptance criteria given in SP-24...122A&B, filter design flow rate, and flow rate used in calculation CN-CRA-00-2.
The results of this calculation show that the actual flow rate is 5,700 SCFM.To resolve the discrepancy in flow rates, the SBV system design flow rate should be changed to 5,700 SCFM.This flow rate is within the range of the fan flow acceptance criteria.Reference 5.23 shows that 5,700 SCFM is an acceptable flow rate for the system filters.A new corrective action will need to be initiated to revise CN-CRA-00-2 as recommended in CA081875 since the 6,000 SCFM used in CN-CRA-OO-2 will need to be changed to 5,700 SCFM.A procedure change as recommended in CA081875 will need to be initiated for SP-24-122A and SP-24-122B to change the maximum DP values listed for the filters and the allowable flow rates.CA128813 calls for calculation 12123 to be revised to detennine the maximum allowed DP for the REP A and charcoal filters.The maximum allowed DPs for these components have been detennined and are presented in Table 9.The results in this table may be used to initiate afollow-onto revise tech spec 4.4.c.1.a as indicated in CA128813.7.11 REASONABLE ASSURANCE OF SAFETY There are no reasonable assurance of safety (RAS)issues associated with this calculation since RASs generally do not apply to the SBV system as it is tech spec equipment, per Reference 5.31.7.12 SUPERSEDED CALCULATIONS This calculation supersedes Revision 0 of calculation 12123 and calculation 1171.M3.7.13 lMPAClED CALCULATIONS Calculation CN-CRA-00-2 is impacted since the SBV flow rate used in that calculation is 6,000 SCFM and this calculation changes the SBV system flow rate to 5,700 SCFM.Based on a review of the Dominion Portal, this calculation does not impact any other calculations.
Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.12123 I REV 1 PAGE 16 OF 16 GROTON, CONNECTICUT ORIGINATOR Matthew Andel DATE 1015109 VERIFIED BY Michael Norwood JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Shield Building Ventilation Pressure Loss 7.14 IMPACTED PROCEDURES AND DOCUIv.1ENTS The results of this calculation may be used to update the USAR section 5.5.5 and Technical Specification 4.4.c.1 a.The results of this calculation may be used to resolve CA081875 (CRI06464) and CA128813 (CR323062).
Procedure SP-24-107C, SP-24-107D, SP-24-122A and SP-24-122B may require updates.Drawings M-602, OPERM-602 and XK-300-2 may require updates.7.15 ANOMALIES The fan curve in the PROTO-HV AC model does not match the actual fan curve for values below 4,500 SCFM.This was done to allow the PROTO-HV AC model to converge as discussed in section 4.0 and does not affect the accuracy of the calculation since the flow rates herein are above 4,500 SCFM.If this PROTO-HV AC model is used for SBV flow rates below 4,500 SCFM the fan curve will have to be modified to give accurate results.7.16 EFFECTIVENESS OF CALCULATION The purpose of the calculation has been met.Form No.: P030105 sheet 1 of 1 Rev.: 0-01 Date: 5/09----Ref.: P 3-1--
CLIENT: PROJECT: ZACHRY NUCLEAR ENGINEERING, INC.CALCULATION TITLE SHEET Dominion Energy Kewaunee, Inc HV AC Calculations CALCULATION TITLE: CALCULATION NO.: Control Room Post Accident Recirculation Filter Pressure Drop 09-047 Revision A JOB NO.: 051470 COMPUTER CODE&VERSION (if applicable):
PROTO-HVAC Vl.0l ZACHRY NUCLEAR ENGINEERING, INC.PROPERTY CODE (if applicable):
000586 QA CLASSIFICATION:
Safety-Related
/.\.REV TOTAL NO.OF PAGES A 257 Form No.: P030101 sheet 1 of 1 ORIGINATOR/DATE Rev.: 0-01Stuart R.Douglass Date: 5/09 APPROV AL/DATE Christopher M.D'Angelo Page i ofiv Ref.: P 3-1 ZACHRY NUCLEAR ENGINEERING, INC CALC NO.09-047 I REV A PAGE ii OF iv GROTON, CONNECTICUT ORIGINATOR Christopher J.Forrest DATE 10/1/2009 VERIFIED BY Stuart R.Douglass JOB NO.051470'CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Control Room Post Accident Recirculation Filter Pressure Drop Revision History Revision A Original Issue Revision Description Form No.: P030102 sheet 1 of 1 Rev.: 0-01 Date:_5/_09__
1.VERIFICATION METHOD: Yes N/A A.Approach CheckedB.Logic CheckedC.Arithmetic CheckedD D.Alternate Method D*(provide documentation)
E.Other D**Describe below./..\:-.ZACHRY NUCLEAR ENGINEERING, INC CALC NO.09-047 I REV A PAGE iii OF iv GROTON, CONNECTICUT ORIGINATOR Christopher J.Forrest DATE 10/1/2009 VERIFIED BY Stuart R.Douglass JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Control Room Post Accident Recirculation Filter Pressure Drop CALCULATION VERIFICATION FORM 2.EXTENT OF VERIFICATION:
Complete calculation (including attachments
/appendices) has been reviewed to determine impact of revision on un-revised areas.A.IDV of Complete calculation (includingattachments/appendices)
.B.IDV of revised areas of Calculation only.D C.Other (describe below): D A.IDV documentation as attachment with Calc Errors Detected See Attachment E.3.DOCUMENTATION OF VERIFICATION D B.IDV documentation D C.IDV documentation is this fonnforwarded to QA and any continuation pages only.Error Resolution See Attachment E.*Yerification Method: Yerified that methodology thoroughly and correctly satisfies calculation purpose.Verified accuracy of design inputs, assumptions, and calculations.
Other Comments None Extra References Used None (Attach extra sheets ifneeded (Use Form P030114>>THE APPROACH, LOGIC, AND METHODOLOGY OF THE CALCULATION IS ACCEPTABLE.
THE GUIDELINES DEFINED IN PARA.7.5.4 (AS APPLICABLE)
OF P 3-1 HAVE BEEN MET.THE OVERALL CALCULATION IS FOUND TO BE VALID AND CONCLUSIONS TO BE CORRECT AND REASONABLE:
mv Signature:Printed Name: Stuart R.Douglass Date: I ()(S/0'1 Form No.: P030103 sheet 1 of 1 Rev.;0-01 Date: 5/09----Ref.:P3..1 II ZACHRY NUCLEAR ENGINEERING, INC CALC NO.09-047 I REV A PAGE iv OF iv GROTON, CONNECTICUT ORIGINATOR Christopher J.Forrest DATE 10/1/2009 I VERIFIED BY Stuart R.Douglass JOB NO.051470 CLIENT Dominion Energy Kewaunee, Inc PROJECT HV AC Calculations TITLE Control Room Post Accident Recirculation Filter Pressure Drop TABLE OF CONTENTS TITLE SHEET i REVISION HISTORY.....*....*................**.............*.........**..............*.................*......*................*..........**..........*........*...............
ii VERIFICATION FORM iii TABLE OF CONTENTS.............*....................**..........*........................................*..........*......*....................**......*......***.*......*
iv LIST OF ATTACHMENTS
- ......**..................*.....*.*...*................*......................................................**..***...*..............**........*
iv Total number of pages in Preface of Calc.4 1.0 PURPOSE*******************************************************************************************************************************************************
1 2.0 BACKGROUND