Text

Technical Specifications Bases Changes and Technical Requirements Manual Changes
	ML14106A450
Person / Time
Site:	Kewaunee
Issue date:	04/03/2014
From:	Stafford J; Dominion, Dominion Energy Kewaunee
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	14-123
	Download: ML14106A450 (185)
	v • d • e

Dominion Energy Kewaunee, Inc.

N490 Hwy 42, Kewaunee, WI 54216 o ilw Web Address: www.dom.com APR 0 3 2014 ATTN: Document Control Desk Serial No.14-123 U. S. Nuclear Regulatory Commission LIC/NW/RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION TECHNICAL SPECIFICATIONS BASES CHANGES AND TECHNICAL REQUIREMENTS MANUAL CHANGES Pursuant to Kewaunee Power Station (KPS) Technical Specification 5.5.12, "Technical Specifications (TS) Bases Control Program," Dominion Energy Kewaunee, Inc. (DEK) changes to the TS Bases implemented without prior NRC approval shall be provided to the Nuclear Regulatory Commission (NRC) on a frequency consistent with 10 CFR 50.71(e). There have not been any changes to the TS Bases since our April 5, 2013 submittal (reference 1).

Also, DEK submits changes to the KPS Technical Requirements Manual (TRM). 10 CFR 50.71(e)(4) states the requirements for submittal of the KPS Updated Safety Analysis Report (USAR). As the KPS TRM is considered a part of the USAR by reference, it is required to be submitted to the NRC.

The attachments provide copies of the TRM pages and TRM current page list reflecting the changes implemented since April 2013.

The changes to the TRM were made in accordance with the provisions of 10 CFR 50.59 and approved by the KPS Facility Safety Review Committee.

If you have questions or require additional information, please feel free to contact Mr.

Richard Repshas at 920-388-8217.

Very truly yours, Jeffrey T. Stafford Director Safety and Licensing Kewaunee Power Station

Serial No.14-123 Page 2 of 2

Reference:

1. Letter from Jeffrey T. Stafford (DEK) to NRC Document Control Desk, "Technical Specifications Bases Changes and Technical Requirements Manual Changes," dated April 5, 2013 (ADAMS Accession No. ML13108A183).

Attachments:

1. Kewaunee Power Station Technical Requirements Manual Changes

2. Kewaunee Power Station Technical Requirements Manual Current Page List Commitments made by this letter: NONE cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352

Serial No.14-123 ATTACHMENT I TECHNICAL SPECIFICATIONS BASES CHANGES AND TECHNICAL REQUIREMENTS MANUAL CHANGES KEWAUNEE POWER STATION TECHNICAL REQUIREMENTS MANUAL CHANGES TRM PAGES:

TRM 8.1.1-1 through 8.1.1-3 Rev 0 Deleted 5/28/13 TRM 8.3.1-1 through 8.3.1-6 Rev 0 Deleted 5/28/13 TRM 8.3.3-1 through 8.3.3-5 Rev 1 Deleted 5/28/13 TRM 8.3.5-1 through 8.3.5-6 Rev 1 Deleted 5/28/13 TRM 8.3.8-1 through 8.3.8-7 Rev 0 Deleted 5/28/13 TRM 8.3.9-1 through 8.3.9-8 Rev 1 Deleted 5/28/13 TRM 8.4.1-1 through 8.4.1-6 Rev 0 Deleted 5/28/13 TRM 8.4.3-1 through 8.4.3-4 Rev 0 Deleted 5/28/13 TRM 8.5.1-1 through 8.5.1-3 Rev 1 Deleted 5/28/13 TRM 8.5.2-1 through 8.5.2-6 Rev 1 Deleted 5/28/13 TRM 8.6.1-1 through 8.6.1-3 Rev 0 Deleted 5/28/13 TRM 8.7.4-1 through 8.7.4-6 Rev 0 Deleted 5/28/13 TRM 8.7.6-1 through 8.7.6-2 Rev 0 Deleted 5/28/13 TRM 8.8.4-1 through 8.8.4-11 Rev 0 Deleted 5/28/13 TRM 8.9.3-1 through 8.9.3-2 Rev 1 Deleted 5/28/13 TRM 10.1-1 Rev 0 Deleted 5/28/13 TRM 8.3.4-1 through 8.3.4-2 Rev 0 Deleted 7/1/13 TRM 8.4.2-1 through 8.4.2-3 Rev 0 Deleted 7/1/13 TRM 8.7.1-1 through 8.7.1-2 Rev 0 Deleted 7/1/13 TRM 8.8.2-1 through 8.8.2-6 Rev 3 Issued 7/1/13 TRM 8.8.5-1 through 8.8.5-3 Rev 0 Issued 71/13 TRM 8.8.1-1 through 8.8.1-7 Rev 2 Issued 9/16/13 TRM 7.0-1 through 7.0-5 Rev 1 Issued 10/15/13 TRM 8.7.8-1 through 8.7.8-4 Rev 0 Issued 10/15/13 TRM 8.9.1-1 through 8.9.1-4 Rev 1 Issued 10/15/13 TRM 8.9.2-1 through 8.9.2-2 Rev 1 Issued 10/15/13 TRM 8.9.4-1 through 8.9.4-2 Rev 2 Issued 10/15/13 TRM 8.9.6-1 through 8.9.6-7 Rev 0 Deleted 10/15/13 TRM 8.3.7-1 through 8.3.7-5 Rev 1 Deleted 1/28/14 TRM 8.7.5-1 through 8.7.5-29 Rev 1 Deleted 1/28/14 TRM 8.7.7-1 through 8.7.7-4 Rev 0 Deleted 1/28/14 TRM 8.8.3-1 through 8.8.3-10 Rev 2 Issued 1/28/14 TRM 8.3.6-1 through 8.3.6-6 Rev 1 Deleted 2/24/14 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION TRM 8.1.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.1 REACTIVITY CONTROL SYSTEMS 8.1.1 Chemical and Volume Control System TNC 8.1.1 The Chemical and Volume Control System shall be FUNCTIONAL consisting of EITHER:

a. A flow path from the RWST or BAST via a FUNCTIONAL Charging pump to the Reactor Coolant System (RCS);

OR

b. A flow path from the RWST or BAST via a )NAL Safety Injection pump to/gae- ctor Coolant Sys APPLICABILITY: All MbES.

CONTINGENCY MEASU'S 8.1.1-1

KEWAUNEE POWER STATION TRM 8.1.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.1.1.1 Verify each valve (manual, power operated or 31 days automatic) in the required boron injection flow path that is not locked, sealed or otherwise secured in position, is in its correct position.

8.1.1-2

KEWAUNEE POWER STATION TRM 8.1.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The Chemical and Volume Control System provides control of the Reactor Coolant System boron inventory. This is normally accomplished by using any one of the three charging pumps. Also, the Safety Injection pumps can take a suction from the Refueling Water Storage Tank and provide borated water to the Reactor Coolant System.

The quantity of boric acid stored in the Refueling Water Storage Tank is sufficient to achieve COLD SHUTDOWN at any time during core life.

8.1.1-3

KEWAUNEE POWER STATION TRM 8.3.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.3 INSTRUMENTATION 8.3.1 Movable Incore Detectors TNC 8.3.1 The Movable Incore Detection System shall be FUNCTIONAL.

------- NOTES---------------------------

1. Power operation may be continued until the next refueling period provided best efforts are utilized to restore the FUNCTIONALITY of the system or systems.

2. At least 75% thimble FUNCTIONALITY is required at the startup qf{ah cycle.

- ~\ 2fR APPLICABILITY: MODES 1 and 2 -: '

CONTINGENCY MEASURES NONCON FORMNE§, > CONTINGENCY MEASURES RESTORATION TIME A. Thimble/FUNCTIONALITY A..1Ift*himble.,EUNCTIONALITY Prior to mapping with 2is > 50% then apply total < 75% FUNCTIONAL

/ measurement uncertainties thimbles e linearl using Basis

\. ,/~ Equations 8.3.1-1 and 8.3.1 2.

< A.2 Ifthimble FUNCTIONALITY Prior to mapping with is 50% then apply a total 50% FUNCTIONAL measurement uncertainty of thimbles 5% and 6% to FAH and FQ respectively.

8.3.1-1

KEWAUNEE POWER STATION TRM 8.3.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME B. Thimble FUNCTIONALITY B.1 Suspend use of the Movable Immediately

< 75% and > 50% ,Incore Detection System for monitoring and calibration of AND the excore axial offset detection system.

< 3 FUNCTIONAL thimbles detcton.ysem per quadrant C. Thimble FUNCTIONALITY C1,i Suspend.use of the Mdvable lImediately

<50%. In.!re Detection System for

/ m\onitoring and calitration of tC ex'core axia offset detection system.

AND C.2 Initiate a ion, torestoreImeitl

""oyeab*Ie Incore Detection SSystem to:Ž' 0%

FU ..

_ _ _ _ _ _ONAL status.

D.\>\0% Incore ýD<*

,!\ Submit report to Commission. 30 days instrurfientation is 0172 NonF 6 NCTIONAL gre6ateer' ,>AN than 7 days.

D.2 Submit additional reports of Every 30 days status until nonconformance is corrected.

8.3.1-2

KEWAUNEE POWER STATION TRM 8.3.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME E. < 2 movable detector E.1 Suspend use of the Movable Immediately thimbles per quadrant Incore Detection System for FUNCTIONAL. monitoring and calibration of the excore axial offset detection system.

AND /

E.2 JIitiatectioni to restore Immediately Moeal "nc Detecion< ~rmditl j.System to&FUNCTIONAL TECHNICAL VERIFICAT!IONREQUIREME NTS VERIFICATION FREQUENCY TVR &3.l'1 Confirn 75% thimbles FUNCTIONAL Prior to entering MODE S2 from MODE 3 after each refueling outage.

TVR 8.3.1.2 Confirm power distribution Prior to exceeding 75%

power following each refueling outage.

8.3.1-3

KEWAUNEE POWER STATION TRM 8.3.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The moveable detector system is used to measure the core fission power density distribution. A power map made with this system following each fuel loading will confirm the proper fuel arrangement within the core. The moveable detector system is designed with substantial redundancy so that part of the system could be out of service without reducing the value of a power map.

The moveable detector system is not an integral part of the Reactor Protection System, this system is rather a surveillance system which may be required in the event of an abnormal ioccurrence such as a power tilt or a control rod misalignment. Since such: occurrences cannot be predicted a priorin it is prudent to have the surveillance systems in an operable state,.

TNC and The movable incore detection system is considered fully FUNCTIONAL APPLICABILITY when sufficient detectors, drives; and readout equipment is available.

An individual thimble is considered FUNCTIONAL when sufficient detectors, drives, and readout equipment is available to read the flux through the active length-of the thimble.

Thepercentage of thimbles available is meant in terms of the total number of thimbles originally available in the movable detector system.

Thus 100% thimble avaijability and 50% availability correspond to 36 and 18 available thimbles, respectively.

Two notes modify the TNC. The first note states that there is no minimum number of thimbles required to continue power operation.

The second n1ot!,e attempts to prevent the system from reaching a condition where not enough thimbles are available.

The movable detector system is required to be FUNCTIONAL following the initial fuel loading and each subsequent reloading. To confirm power distribution sufficient neutron flux must be available to ensure the incore detection system is indicating the neutron flux produced from power operation. Thus the MODES of applicability are MODES 1 and 2.

8.3.1-4

KEWAUNEE POWER STATION TRM 8.3.1 TECHNICAL. REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES CONTINGENCY A.1 and A.2 MEASURES Ifthe system is severely degraded, large measurement uncertainty factors must be applied. The uncertainty factors would necessarily depend on the operable configuration. Between 75% and 50% availability, the total measurement uncertainties are applied linearly using Equations 8.3.1-1 and 8.3.1-2 shown below.

FAH measurement uncertainty (%) = 7 - (T / 9 ) (Eq 8:321-1)

FQ measurement uncertainty (%o) = 8 - ( T / 9 ) (Eq. 8.3.1-2)-

where T = number of thimbles used for flux traces*\ (.<

(N 75'*an aiii When operatingtbetween 75%'and 50% thie, avai each of the core quadrants, ias dfined'-by both the m`ajor anOrmior axes (the minor axes are at 45.to the*.rjor axes), m ust{coainAt~le ast 3 available thimbles,(allthimbleseven those otn the' quadrant axes, are to be counted as whol e values),.,,,,

Thee puorposeof the measurement uncertainty factor is to provide a means to account.for statisticalvanation inthe flux measurement process. A K*standard:percentage value wasud-in the equations used in the COLR.

SThe To'chnical Requirements.Manual is not prescriptive as to the required c(,I"arns when using, less than 75% of the thimbles. Based on the Uncertainty analysis performed by Westinghouse (reference NF-WP-05-19, "Kewaunee Thimble Dlefeion Analysis," dated October 31, 2005), the additional. uncerainty factor provides conservatism to the calculated values when operatinigrith less than 75% and greater than 50% of the thimbles available,1" T' eunc6rtinties in Equations 8.3.1-1 and 8.3.1-2 were determined from Kewaa'!uee Power Station Cycle 26 and 27 data. Given that the different fueI types in Cycles 26 and 27. are distributed in distinct patterns (for

\example, in Cycle 27, fuel type 1 is loaded in peripheral core locations), the use of the maximum sensitivity over all these fuel types ensures the peaking factor penalties are conservative. Further, these penalties discussed in this section can be applied to future cycles (of similar general fuel management strategy to Cycles 26 and 27) without regard for how the fuel types are distributed in the core. These penalties will bound future cycles where fewer fuel types are present. The basis for the uncertainty analysis is in WCAP-7308-L-P-A.

8.3.1-5

KEWAUNEE POWER STATION TRM 8.3.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES CONTINGENCY B.1 MEASURES (continued) The study performed by Westinghouse shows that the probability of having less than 3 thimbles per quadrant, as a result of random thimble deletion, is about 11%. This suggests that if less than three thimbles remain in each quadrant when only 50% of thimbles-are available, it is likely that these deletions were made systematically rather than randomly. Systematic thimble deletion which results in large un-instrumented regions of the core may result in larger penalties than described herein.

C. and C.2 TNC 8.3.1(C) is nrecessa'y to avoid issues rega&i'gte ability of the core m onitoring systein to e . rd i-//1,, ... l o .

montoin , letectue misload'ev6ent. In atddition, this requirement helps tpreyept long-term dLterio9on of the flux mapping system. / K instrumentation is NonFUNCTIONAL for

]uires to be informed of the situation and the thimbles to service.

iles per quadrant, and sufficient detectors, drives, and to map these thimbles, are sufficient to provide data for f the excore detector system's axial power offset TECHNICAL TVR 8,3..1.1 VERIFICATION REQUIREMENTS This verification requirement confirms the number of FUNCTIONAL incore moveable detectors prior to startup from a refueling outage.

TVR 8.3.1.2 This verification requirement confirms power distribution is within limits prior to exceeding 75% rated power.

8.3.1-6

KEWAUNEE POWER STATION TRM 8.3.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 April 19,2011 8.3 INSTRUMENTATION 8.3.3 Auxiliary Feedwater (AFW) Pump Low Suction Pressure Trip Channels TNC 8.3.3 One low suction pressure trip channel shall be FUNCTIONAL for each AFW pump.

APPLICABILITY: Whenever the associated AFW pump is required to be OPERABLE.

CONTINGENCY MEASURES A. AFW pump low suction L ETQýTION Immediately TIME pressure trip channel or one or more AFW pugil NonFUNCTIONAL.//

8.3.3-1

KEWAUNEE POWER STATION TRM 8.3.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 April 19,2011 TP:('WK11('A1 X/F=P1P1r'AT1(-)K1 PF=nH1PF=KAP:K1T(Z VERIFICATION FREQUENCY

,NOTE -------------

Verification of relay setpoints is not required.

TVR 8.3.3.1 Perform CHANNEL FUNCTIONAL TEST on each 92 AFW pump low suction pressure trip channel.

TVR 8.3.3.4 Deletedl <

8.3.3-2

KEWAUNEE POWER STATION TRM 8.3.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 April 19,2011 BASES BACKGROUND AFW pump low suction pressure trip protects pump internals from damage that could result from loss of the required net positive suction head (NPSH), which could be caused by loss of the normal water supply from the condensate storage tanks (CSTs) following a tornado or seismic event.

Three pressure'switches (one per pump) are located on the AFW pump suction line from the CST. The set point of each pressure switch is designed to preclude pump operation with sub-atmospheric pressure at the AFW pump suctionz Aý low-pressure signal se6sedby.any one of the switches will cause the'associated AFW pump to trip."Operator action is required t',bypass the trip circuit oaign to thge~srvice water source and relstar theýssocjated AFW pump. Service water alignment and restart ofthe AFW pum'ps ensure ah-daequatesupply of water to maintaintt, leasto6ne ofthe steam generators (SGs) as the heat sink for reactqr ýecay heat and sensible* heatr~hovald A/ic'vitating' ienturi is installed in the'discharge of each AFW pump. At Shigh/SG pressures, the venturi opertes' in resistance mode as a flow cnýritrl element in copjunction with the AFW pump discharge throttle eval~ve.

F/or low SG(ýresures (associated with accidents or transients)

Strough the ventuns cavitates and limits flow through the AFW pjumps precluding pumpraunout. At the maximum possible flow rate thru the ventur; th* pump's required NPSH is maintained less than atmospheric pressure. /Since the AFW pump low suction pressure trips

/7 are set to stop pumnp-peration prior to suction pressure dropping below

' '\ X* atmospherib\,margin to required NPSH continues to be maintained.

TIe requirement for AFW pump low suction pressure trip was relocated frormthe:.previoUs Custom TS during the conversion to Improved TS. In tLice'his,5,Amendment 183 (Reference 1), the NRC approved a four hour alio*w"ance to defer applying the AFW TS requirements for the condition 6*f one low suction pressure trip channel inoperable. This amendment s'tipulated that when only a single trip channel was inoperable, the AFW pump associated with that trip channel was allowed to be considered OPERABLE for up to four hours, provided the AFW train was otherwise OPERABLE. In License Amendment 207 (Reference 2), the NRC approved relocating this 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allowance to the TRM. However, since this trip function is required for AFW pump OPERABILITY, TS LCO 3.7.5 is not met with an AFW pump low suction pressure trip channel NonFUNCTIONAL. Therefore, this relocated allowance is not applicable.

8.3.3-3

KEWAUNEE POWER STATION TRM 8.3.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 April 19,2011 BASES TNC and AFW pump low suction pressure trip channels (one per pump) support APPLICABILITY OPERABILITY of the AFW system (Reference 3) by providing automatic protection for the pumps. The low pressure trip is necessary in order to prevent damageto the AFW pumps if the normal water supply (from the CSTs) is lost following a tornado or seismic event.

Therefore each channel must be FUNCTIONAL whenever its associated (supported) AFW train is required to be OPERABLE.

One low suction pressure trip channel must be FUNCTIONAL for each AFW pump whenever its supported AFW pump is :required to be OPERABLE per TSZ, 7.5 (R.eference 3). ,

CONTINGENCY A.1 \

MEASURES / ' " ,/ - \

Loss ofpressure tpr channel unacceptbly, degrades AFW pump protection capability. If one or more A FWpump low suction pressure tni channels.are NonFUNCTIONALthe associated AFW train(s) shall

.immediately be declared INOPERABLE and the applicable r,*eq.irtemhts of TS 3 7:5\applied. Contingency Measure A. 1 thereby lmits that a/hetime channel may be removed from service.

TECHNICAL 8.3.3.1 VERIFICATION REQ RE ..S A CHANNE~L FUNCTIONAL TEST is required to be performed on each AFW pUtipp's*low suction pressure trip channel every 92 days.

Ver-ffi&tiof-relay setpoints is not required to be performed during the

,c&,/dq'clof this test.

TV.R 8.3.33 SA' CHANNEL CALIBRATION is required to be performed on each AFW pump's low suction pressure trip channel every 18 months.

8.3.3-4

KEWAUNEE POWER STATION TRM 8.3.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 April 19,2011 BASES REFERENCES 1. License Amendment 183, "Kewaunee Nuclear Power Plant -

Issuance of Amendment Re: Auxiliary Feedwater System (TAC No.

MC6916", dated June 20, 2005.

2. License Amendment 207, "Kewaunee Power Station (KPS) -

Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond Scope Issues (TAC Nos.

ME2139, ME2419, ME2420, ME2421, ME3122, ME3460, and ME3544)", dated February 2, 2011.

3. TS 3.7.5, AFW 8.3.3-5

KEWAUNEE POWER STATION TRM 8.3.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 6, 2012 8.3 INSTRUMENTATION 8.3.5 Post Accident Monitoring (PAM) Instrumentation TNC 8.3.5 The PAM instrumentation for each Function in Table 8.3.5-1 shall be FUNCTIONAL.

APPLICABILITY: MODES 1 and 2.

CONTINGENCY MEASURES

3. One*or moe F.ctions

..4ithto.reqqiired Kchanne>4 NonFUNCTIONAL. >

C. Required < "

CONTINGE 9YX\

MEASURESad associated Restbriation Time of Nonconformance A or B not met.

8.3.5-1

KEWAUNEE POWER STATION TRM 8.3.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 6, 2012 TECHNICAL VERIFICATION REQUIREMENTS

NO These TVRs apply to each PAM instrumentation Function in Table 8.3.5-1.

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

Verification of auxiliary feedwater (AFW) flow rate indicator is only required dunng urtlstartup and shutdown.

8.3.5-2

KEWAUNEE POWER STATION TRM 8.3.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 6, 2012 Table 8.3.5-1 (page 1 of 1)

Post Accident Monitoring Instrumentation FUNCTION REQUIRED CHANNELS

1. AFW Flow Rate indication 1 per SG

2. Pressurizer Power Operated Relief Valve Position (One Common 2 per valve Channel Temperature, One Channel Limit Switch per Valve)

3. Pressurizer Power Operated Relief Block Valye Position (One Common Channel Temperature, OneChanne-l*Limit Switch pe

4. Pressurizer Safety Valve Position,*(One Channel Temperature, One Acoustic Sensor) .

7

8.3.5-3

KEWAUNEE POWER STATION TRM 8.3.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 6, 2012 BASES BACKGROUND The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. Post Accident Monitoring Instruments are divided into one or more of five (5) types of variables (A, B, C, D, & E). Type A variables are those variables to be monitored that provide the primary information required to permit the control room operators to take the-specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety:4uction for design basis accident events., Types B, C, D, and E'are)variables for following the course ofa*n accident and are to be used (1) todidetermine ifthe plant is respondi*ng to the safety measuresnh, operation ,ýand (2) to inform the operatot*of the necesýsity for unplanned actions to mitigate the consequenc<s ofuan a6cide'nt. Further"defi*rtion 6fVType B, C, D, and E variablesar.be found in the KPSI§G 1.97. Accident Monitoring Instrumeneatton Plan (Rdference 17-" < )

The of the accide'nt monitring instrumentation

,IUNCTIONALITY ensures that the 'r is sufficient information available on selected unit param*t*rs to monitor and to assess unit status and behavior following an a~cidenti..

, ..,..-1 4/< " Only/those instrulments monitoitiig Type A and Category 1 variables

/'

</< /. ~arerequired

.ý IV, to beincluded

.. /11infTechnical Specifications (TS). The

-/ -instruments in this Technl.cal Requirement do not meet the criteria for

, - inclusion into<[S. The'*quirements for PAM instrumentation that did

'" not meet TypeA or Category 1 variables were relocated from the previousb uCuitom, TS Table 3.5-6, "Accident Monitoring Instrumentation Operating Conditions for Indication," during the conversion to Improved TS.in License Amendment 207 (Reference 2). That "converionalso deleted the previous requirement for the unit to be

<>. sh.utdown if a required channel.was nonfunctional and not restored

~K 'th'n the allowed restoration time.

TNC and The PAM instrumentation TNC is applicable in MODES 1 and 2.

APPLICABILITY The PAM instrumentation TNC provides FUNCTIONALITY requirements for the monitors listed in Table 8.3.5-1 (Regulatory Guide 1.97 monitors other than Type A or Category 1), which provide information required by the control room operators to perform certain manual actions specified in the unit Emergency Operating Procedures.

The FUNCTIONALITY of the PAM instrumentation ensures there is sufficient information available on selected unit parameters to monitor and assess unit status following an accident.

8.3.5-4

KEWAUNEE POWER STATION TRM 8.3.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 6, 2012 BASES CONTINGENCY A Note has been added in the CONTINGENCY MEASURES to clarify MEASURES the application of Restoration Time rules. The conditions of this requirement may be entered independently for each Function listed on Table 8.3.5-1. The Restoration Time(s) of the inoperable channel(s) of a Function will -be tracked separately for each Function starting from the time the condition was entered for that Function. When the Required Channels -in Table 8.3.5-1 are specified (e.g., on a per steam generator, per valve, etc., basis), then the condition may be entered separately for each steam generator, valve, etc., as appriate.

A.1 Nonconformance-Pk applieS\when one or,6ire.I-unctions have one required chqapt-thki'"s NonFUNCTION~L. CONTINGENCY MEASUREA.1 requires,*restoring th6ioeFVNCTIONAL channel to FUNCTI6'AL status -within 14 day. NonF C Noncon frmance B apolie 'When one or more Functions have two N*on.FUNCTIONAL eqir~`e- chnels (i.e., two channels

> No.F.UNCTIONA* in the sam6 Function). CONTINGENCY V EASURE B.1 requirpes/estoring all but one required channel in the

/, \'* /'Function(s) to\FUNCTiIONAL status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Nunconforimance C applies when the CONTINGENCY MEASURE and asociat6d completion time of Nonconformance A or B is not met.

..<C-.

zcb'N*NGENCY MEASURE C.1 requires initiating the action specified

\*in'TNC 7.5.3 immediately. Each time a nonfunctional channel has not

met the CONTINGENCY MEASURE of either Nonconformance A or B, and the associated completion time has expired, Condition C is entered for that channel and provides for transition to TNC 7.5.3.

TECHNICAL TVR 8.3.5.1 VERIFICATION REQUIREMENTS This verification is modified by a Note that alters the frequency requirement for checking the AFW flow rate indicator. Rather than at the normally specified 31 day interval, AFW flow. rate indication is required to be checked during each startup and shutdown of the unit (unless it was performed in the previous 31 days).

8:3.5-5

KEWAUNEE POWER STATION TRM 8.3.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 6, 2012 BASES TECHNICAL Performance of the CHANNEL CHECK once every 31 days ensures VERIFICATION that a gross instrumentation failure has not occurred.

REQUIREMENTS (continued) Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. Ifa channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. Ifthe channels are within the criteria, it is an indication that the channels are FUNCTIONAL.

As specified in the TVR,a -CHANNEL CHECK is only required for those channels that are normally, energized. k The Frequencyvf 31 day i6sed on op'e*.ting expeijence that demonstrates, that ql6nnelfailure is rare.,\VThe",d ANNEL CHECK supplements lessformal(1'but more que*.t,,che` ks of channels during normal .operational u*e'of the displays 0 soci'at*d with the TNC required channels. H TVR 8,3.5e20

,,,A CHANNEL CALIbRATIO,.N is'performed every 18 months for all S "F~urctions, or applroximately-at every refueling. CHANNEL

\ /7 ,CALIBRATION is a compllte check of the instrument loop, including

/he sensor. The test v.ifies that the channel responds to measured

/ '*.. parameter with\the necessary range and accuracy.

REFERENCES (1- KW-PLAN-000-RG 1.97, "Regulatory Guide 1.97 Accident

\*m\Moni'itng Instrumentation Plan".

'2`.%1` Safety Evaluation by the Office of Nuclear Reactor Regulation

~~* Related to Amendment No. 207 to Facility Operating License No.

DPR-43, Dominion Energy Kewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2, 2011.

8.3.5-6

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.3 INSTRUMENTATION 8.3.8 Reactor Protection System (RPS)

TNC 8.3.8 Reactor Trip Breakers and Logic Cabinets shall be OPERABLE.

APPLICABILITY: Whenever the associated Reactor Trip Breakers and Logic Cabinets are required to be OPERABLE by Technical Specifications (TS).

CONTINGENCY MEASURES I

8.3.8-1

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 CONTINGENCY MEASURES (continued) 8.3.8-2

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY None N/A

) by c-I

~-$~>' \

V H 0~-> 101t,

~,/1 7,

K '1/

N

/ 1/4 A

/ K) 8.3.8-3

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND In its approval of the policy statement on the use of probabilistic risk analysis (PRA) methods in nuclear regulatory activities, the Commission stated an expectation that "the use of PRA technology should be increased in all regulatory matters... in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy". The NRC staff has defined an acceptable approach to analyzing and evaluating proposed TS changes (reference 1).

The NRC staff has identified a three-tiered approarch fdticensees to evaluate the risk assocpated with proposed TS*,allowed outage time (AOT) changes (refer'ence

. 7\ 1))A -)ier1 is an evaluation

/ -,

j:. oftb'e impact on plant risk of the-proposedI\TS ihange as expressed-.by the change in core damage/frequency (A&DF), the irnr&&ental coiditional core damage( P), and, whep.....appr\\riate, the change in large early release freqUency (ALERF) ndthieincrdmental conditional large early*.e.*1.s .probability (ICLERP). Tier 2 is-an identification of pofntially high-risk configurations that could exist if equipment in addition, to that associated with the change were to be taken out of ser*vce simultaneously;:or- other risk significant operational factors such as Gýoncurrent systeniorequipment testing were also involved. The re~itobj objetie of son th mis this part ofthe evluation is too ensure ant.s nsr that appropriate N restrctions e on irant,*sk-significant configurations associated with

/

< t*change are4n place Tier 3 is the establishment of an overall Sconfiguration risk m.at/gement program to ensure that other potentially

lower probability, bu nonetheless risk-significant, configurations

" resulting from maintenance and other operational activities are identified and compensated for.

AP-15376 identified restrictions on concurrent removal of certain ipment when an RTB is out of service. These recommended Tier 2 1ctions are provided in Section 8.5 of WCAP-1 5376 (reference 2).

8.3.8-4

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND Additionally, 10CFR50.62 provides requirements for reduction of risk (continued) from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants. This rule states that each pressurized water reactor must have equipment from sensor output to final actuation device, that is diverse from the reactor trip system, to automatically initiate the auxiliary (or emergency) feedwater system and initiate a turbine trip under conditions indicative of an ATWS. For PWR designs other than Westinghouse designs (i.e., CE and B&W) the rule requires that they must have a diverse scram system from thtsensor output to interruption of power to-the~control rods. Althougl ot)-u ired by the rule, in 1998 Kewaun e rec '~ted NRC approval for in tall*!on of a Diverse Scram S s' (OSS) reference 4). c-2' During an e 'nee 4igrevi* of the A tem, aunee staff determined'/tht AFW PUMPS ma trip on 1 suction pressure during apostue AdA eyent initiat by L-so ormal Feedwater transiAit*"( NF). With prompt era r ac*:to restore AFW pump o0 tion, re or conditions would r rllaiwithin acceptance criteria, w t less pr mary coolant system pressure margin than "gifally ,9 lculated. .esolvethis concern, Kewaunee staff dete'A d that the dit*&,f iverse Scram System (DSS) will resto the orig9i m in.

e DSS chan m1 ified the exciter field circuits of the motor/generator(M ts which powers trains A and B control rod cabinets. (*ntacts m the existing AMSAC relay are installed in series

- with au#liar ,relays contacts, such that upon opening, it will de-energize the etfield after a 2-second delay. The de-energization of the ex er d res*Its in a loss of generator output voltage, causing the

t a ipl r coils to de-energize, causing the control rods to drop tl.actor core, shutting down the reactor.

a part of the 7.4% stretch power uprate License Amendment (LA) 1 2, the ATWS event had to be reanalyzed. A conservative approach was taken supporting LA 172 showed that the analytical basis for the final ATWS rule continues to be met, wherein no credit was taken for the DSS. An ATWS analysis was also performed to address the steam generator pressure criterion. Since the DSS was installed at KPS to address NPSH concerns, the DSS in conjunction with the AMSAC system was credited for event mitigation. The results of the analysis crediting the DSS in conjunction with the AMSAC system show that the steam generator pressure is greater than 640 psig subsequent to AFW pump initiation and prior to the time of reactor trip (reference 5).

8.3;8-5

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES TNC and The Reactor Trip Breakers and Logic Cabinets shall be OPERABLE APPLICABILITY when required by Technical Specifications (TS) to be OPERABLE.

CONTINGENCY Al, A.2, and A.3 MEASURES This contingency. implements tier two of the three tiered approach to evaluate risk-informed AOT changes in Regulatory Guide 1.177 (reference 1). The objective of the second tier is tpride reasonable assurance not occur whenthat risk-siapipi~t equ. *ent is plant equipment ou 9ae.gurations will

'*t of service. I*iks?1g .t configurations do'c -ur then* hhancements echn e"Specifications or procedures/ ali ,punavail "ity of baup systems, increased crvil Eefrequencies, or( p2 g procedures or training, can be rný etoht avQ idimit, or I e im'Drtance of these configqTaia ,s. P1 g' these re/'*fic s\t] nt operation avoids risk-si *idzant pco* n igurations ANot .s added to allow one.AFW pu to be placed in pullout h itt9 for mai ce. At Kewaunee the ATWS/LONF accident was*n zed for fiv as Fefence 6) Each of the cases changed the ' ut assur 0 0Ffloassuming 800 gpm, 400 gpm, 3 AFW ps flow, 2 FWI! un* w, and 1 AFW pumps flow. All five cases emonstrated acce tbJ results. Additionally, the diverse scram system at Kewaune .I...vides additional risk benefit for an ATWS event in that the babilit of an ATWS requiring immediate AFW is reduced.

The ris kna9 is performed by Westinghouse in WCAP-15376-P-A, whic~o m~nded not degrading AFW when a reactor trip breaker Swakin IIIabledid not assume a diverse scram system was available.

knefiof the diverse scram system will result is a risk neutral k,1 dtier for one AFW pump in pullout during maintenance when priared to the risk analysis assumed by the Tier 2 restrictions from CAP 15376-P-A. Therefore, Kewaunee meets the intent of WCAP 15376-P-A Tier 2 Restrictions with one AFW pump in pullout for maintenance.

8.3.8-6

KEWAUNEE POWER STATION TRM 8.3.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES CONTINGENCY B1, B.2, and B.3 MEASURES (continued) The objective of the second tier is to provide reasonable assurance that risk-significant plant equipment outage configurations will not occur when equipment is out of service. If risk-significant configurations do occur, then enhancements to Technical Specifications or procedures, such as limiting unavailability of backup systems, increased surveillance frequencies, or upgrading procedures or training, can be made that avoid, limit, or lessen the importance of these conf/i-a tions. Placing these restrictions on plant-operation avoids risk-si ~ifi Qt-lant configurations (\ "F C._1 When it s re'd tta TNC has hbt be6npmet and the associated

-NC '*I__URES ar otsa""sfied (or an associated CONTII CON' *NCY ME'*SURE is r(, t pr hidhe equipment subject to in\onconforming condit cnn this situation, appropriate II bý(taken as necessary t rovide assurance of continued perations.,/-TflC 7.5.3 provides direction for these

-actions.(cQ)

)erformed in accordance with Technical no additional TVRs specified in this TRM REFE "ES 1 0 1.177, "An Approach for Plant-Specific, Risk-Il ed Decisionmaking: Technical Specifications" August 1998.

CAP-1 5376-P-A, Revision 1, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times" March 2003.

3. Kewaunee Power Station License Amendment Request 249, "Conversion to Improved Standard Technical Specifications."

4. Letter from William 0. Long (NRC) to M.L. Marchi (WPSC),

"Kewaunee Safety Evaluation - AMSAC Modification," dated July 29, 1998.

5. Calculation - CN-TA-02-1 10, Revision 1, ATWS Evaluation for Kewaunee Uprate Program, dated November 6, 2003.

6. Calculation - CN-TA-02-1 10, Revision 0, ATWS Evaluation for Kewaunee Uprate Program, dated November 6, 2003.

8.3.8-7

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 8.3 INSTRUMENTATION 8.3.9 Reactor Thermal Output Monitoring TNC 8.3.9 The Plant Process Computer System (PPCS) Reactor Thermal Output (RTO) monitoring program shall be FUNCTIONAL with the following provisions:

a. Steam generator conductivity shall be < 20 pmhos;

b. Ultrasonic Flow Measurement Device (UFMD) feedwater flow correction factors shall be in service;

c. UFMD feedwater tep6rfrure correction factors *hafrb~e',n service.

APPLICABILITY: THERMAL POWER > 1749 MWth.

CONTINGENCY MEASURE~>~

-- - N O T E -- - --- - - - - - - - - - - - - -

Multiple Nonconforman_ res arellowed. >/

NONCONFO N*INGEN MEASURES RESTORATION TIME A. Stem iity nerat 0 pmhos. A1 Initiate temperature actioncorrection to insert Immediately

factors.

/AND

)

\ A.2 Initiate action to reduce Immediately UFMD Operating Limit to

<1769 MWth.

AND A.3 Reduce THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the last POWER to_< 1769 MWth (15 performance of a minute average) and to secondary

_<1768.7 MWth (8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months calorimetric average), calculation 8.3.9-1

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME B. Feedwater flow B.1 Initiate action to reduce Immediately correction factor not in UFMD Operating Limit to service. < 1749 MWth.

O__R AND Feedwater flow correction factor has B.2 Red ce THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the last inserted value. ,ROWER to ,1749 MWth t perrormrance of a 0 *Ji5sbtet*verage),:pdto secondary OR <4748"7*MWth (8 h"'ur calorimetric aeac). \ calculation Feedwater flow * " J correction factor

questionable. "

C. Feedwater tdperaturemC. Initiate--action toLreduce Immediately correctionfact6i'not ipn " Limit to seKcy***

servicef -7 *<1769 M*Wth.

t9 OR~

'V / AND Feedwater temperature K77!\

crrection factor has \C 2(ý., Reduce THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the last ins'e'Ydý value. e> POWER to < 1769 MWth performance of a OR (15 minute average) and to secondary OR ' *1768.7 MWth (8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months calorimetric t'* . , r... average), calculation Feedwater temperature correction facto&'y questionable.

8.3.9-2

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME D. RTO monitoring program D.1 Reduce THERMAL POWER 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the last NonFUNCTIONAL. to

1749 MWth. performance of a secondary calorimetric calculation TECHNICAL VERIFICATION REQUIREMENTS\ /J >

K%>

RIFIC tION FREQUENCY TVR 8.3.9.1 Perform signal conditioning/processing unit ef 6 months test. /

AND S After calibration TVR-83,,9.2 Reboot the UFM a;nd UTM'"/ 6 months TVR 8 . Perform refle6tdsignal strength indication scan. 12 months TVR 8.3.9.4 q.caiijrato the signal conditioning/processing unit. 18 months 8.3.9-3

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 BASES BACKGROUND Feedwater flow is measured using the venturi flow meters on each of the feedwater line headers. The venturi feedwater flow is corrected using the Crossflow ultrasonic flow measurement devices (UFMDs) that are located on the A and B feedwater lines. Feedwater flow provides input into the secondary calorimetric calculation. In the event that the feedwater flow correction factors from the UFMD system become questionable, reactor thermal power output must be reduced in a specified time period to a power output consistent with secondary calorimetric power measurement uncertainty of 2.0f1pcent. If power level has been reducededue to questionable feedwatefflow correction factors from the UED system, the feedwateFrflow venturis may be corrected for foulingkqsing the~full flow feedwt~ r bypasne (FBL).

The total FBI-flow se6tio fjeedwater flo. mesorment uncertainty is 0.45 percenthowe(ver, reactor therma power output is limited to a power outipou1LcbsistentPwith a 2.0 ntseconda calorimetric wer*

me rtuncertain I.frenb14)/

sur. \-,

Correcting venturi feedwater flow with theCrossflow System is the basis or the measurement uncertain:ytrecapture (MUR) power uprate, wPhilKincreased licensed rated reactor thermal power output.

A Ca"loimetric power rfieasurement'uncertainty is used in the SU d rmination~of reactorthemal power output. Secondary calorimetric power measurement is obtained from measurement of feedwater flow, feedwater inlet temperrature to the steam generator and steam

%heýM*UR TI.*, power uprate was achieved by installation of AMAG prossf ow U trasonic Flow Measurement Devices (UFMDs) on the A and B Feedwater Loops, which allow reactor thermal power output to be measured more accurately. Each UFMD consists of an ultrasonic flow meter (UFM) and ultrasonic temperature monitor (UTM). The Crossflow UFMDs derive feedwater flow and feedwater temperature correction factors that are input *into the Plant Process Computer System (PPCS). Use of the UFMD correction factors along with the relaxation of the 10 CFR 50, Appendix K rule regarding power for operation at a power level measurement uncertainty, allowsmeasurement consistent with the actual power uncertainty (reference 2).

8.3.9-4

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 BASES BACKGROUND When the UFM and UTM are providing reliable correction factors, total (continued) secondary calorimetric power measurement uncertainty is 0.6%. Ifa UTM correction factor becomes questionable, the total secondary calorimetric power measurement uncertainty is 0.8%. Ifa UFM correction factor becomes questionable, the total secondary calorimetric power measurement uncertainty is 2.0% (reference 2).

Reactor thermal power output must be reduced in a specified time period to,a power output consistent with the appropriate secondary calorimetric power measurement uncertainty ifthecorrection factors from the UFMD system-specified above become upes'ionable.

Additional informati .o\gn ensqtring adherence4o the maxirhu THERMAL POWESR lImit~yV,,vided via~a.safetvaluation discussed in NRC RegulatoryJssue ummary (RfS)2007-21, Revision 1 (reference 3). * .K\ \

TNC and The Plant PWrd\ess Computer System I(P.PCS)Reactor Thermal Output APPLICABILITY <1(T.) monitoring program is required/to be FUNCTIONAL whenever Yra'tor thW'mal powetf-id> 1749 MWth (98.7%; as indicated by the 15 '.ine average)

/ />peration up to themaximum licensed reactor power level (1772

ý6'*IWth) requires the&UFMD feedwater flow and temperature correction factors to be in service. Therefore, the following provisions must be met whenever the PPCS RTO monitoring program is required to be F ' ONAL: a) Steam generator conductivity shall be < 20 pmhos;

""FUNCT b) toe. UFMD.feedwater flow correction factors shall be in service; and,

\ .*v c) the UFMD fdedwater temperature correction factors shall be in

',service.

K~>A questionable feedwater flow or temperature correction factor is the

' '* *ast good correction factor received from the UFMD system prior to a condition that causes the system to stop providing automatic updates.

Since the questionable correction factor is good, the PPCS RTO monitoring program remains FUNCTIONAL when using a questionable correction factor. However, since questionable correction factors are not updated, operation with their use is limited to the time stated in the ACTIONS section for the respective questionable correction factor.

8.3.9-5

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 BASES CONTINGENCY The CONTINGENCY MEASURES are modified by a Note allowing for MEASURES multiple Condition entries to be entered concurrently.

The various CONTINGENCY MEASURES direct reducing reactor power and the Ultrasonic Flow Measurement Device (UFMD)

Operating Limit to specified values within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the last performance of .a secondary calorimetric calculation (i.e., the last calorimetric using a valid UFMD correction factor that was performed before the associated Nonconformance occurred) (reference 4).

Secondary calorimetric calculations are performed, in apordance with plant procedures (reft ee$). "

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months alloWance is bard on the ,daily aucflar power range surveillance .jii-.(3rne2 'itialso I5ksed on unit operating/expel6ri6ice, instmentreliability uonsidering and operating historyd'ta fos drift. -gther-jheee factors demonstrate that adiffe'rence b06teen the calorimetric t balance calculation and th'power range channel output of mor1re'than + 2% reactor thermal

ýo)werls not e6pected in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months !eriod.

A. 1 , *

.. / Uncertainty of/-he lftrasonic;temperature monitors (UTM) is impacted if

/ 7 eedwater totaidissolved hgids (TDS) are greater than 20 ppm (steam

.".-:

r generator conductivity '20 pmhos). The.UTMs are NonFUNCTIONAL

-,7,\ -7' when TDS'is greater'than 20 ppm. In this condition, the associated Actions require immediate initiation of action to insert current temperatupýecorrection factors and to reduce the UFMD Operating Limit to ! 1769 MWth. Although the UFMD Operating Limit is automatically

~.set to 17.69 MWth if any temperature correction factor is questionable,

~the system does not automatically detect high steam generator

',conductivity; therefore, the last good correction factors must be inserted

,Vmanually.

Additionally, the associated CONTINGENCY MEASURES require reducing reactor power to < 1769 MWth (as indicated by the 15 minute average) and to < 1768.7 MWth (as indicated by the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months average) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the last performance of a secondary calorimetric calculation (that was performed before this Nonconformance was entered).

Since the UTMs are rendered NonFUNCTIONAL when feedwater TDS

> 20 ppm, this condition needs to. be evaluated for simultaneous entry into Nonconformance C.

8.3.9-6

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 BASES CONTINGENCY B. 1 MEASURES (continued) If any feedwater flow correction factor is either not in service, has an inserted value, or is questionable, the power measurement uncertainty may be higher than the ideal Value. In this condition, the associated Actions require immediate initiation of action to reduce the UFMD Operating Limit to < 1749 MWth. This action is performed on the plant process computer system (PPCS). Note that the UFMD Operating Limit is automatically set to 1749 MWth if any flow-co*rrection factor is questionable. "-

Additionally, the,/ssociated ,ONTINGENCYýI MEASURýES` require reducing reactor powe'rto ,<749 MWth(asmindidated by the 15 minute average) ando <o1748. th (as irdcte by tl8 hour average) within 24 h`ours-ofthe Jast performand" of a 'scondary calorimetric calculation (thatlwas :performed befe this Nonconformance was entere~d). N 1/,

Ifaýny feedwater temperature correction factor is either not in service, has an inserted value,-orlisquetina le, the power measurement S uncertainty may`biehigh6e-4hn the ideal value. In this condition, the associated Actins require immediate initiation of action to reduce

/> the UFMD OperatingLi- it to < 1769 MWth. This action is performed

. */ on the PPCtS. Note that the UFMD Operating Limit is automatically set to 1769 MWth if any temperature correction factor* is questionable.

Additionally, the associated CONTINGENCY MEASURES require

'redducing reactor power to _<1769 MWth (as indicated by the 15 minute

\ýavetage) and to<* 1768.7 MWth (as indicated by the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months average)

-*v<Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the last performance of a secondary calorimetric calculation (that was performed before this Nonconformance was entered).

D..1 If the RTO monitoring program is NonFUNCTIONAL, the primary method for accurately monitoring RTO is unavailable. In this condition, the associated CONTINGENCY MEASURES require reducing reactor power to < 1749 MWth (as indicated by calorimetric (reference 4))

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the last performance of a secondary calorimetric calculation (that was performed before this Nonconformance was entered).

8.3.9-7

KEWAUNEE POWER STATION TRM 8.3.9 TECHNICAL REQUIRMENTS MANUAL Revision 1 July 9, 2012 BASES TECHNICAL TVR 8.3.9.1 VERIFICATION REQUIREMENTS A self test of the signal conditioning/processing unit is required to be performed every 6 months. This test is performed automatically by installed software (reference 4). A self test must also be performed following calibration of the unit prior to returning it to service.

TVR 8.3.9.2 The UFM and UTM s inditioning/processi uired to be rebooted every 6 moj TVR 8.3.9.3 A reflect( ired to be performed annually

/

ocessing urit is required to be recalibrated E :alibration is typically performed every i*r.g the unit to the vendor (reference 4).

REFE 1. USAR Section 1022.7, Main Feedwater System.

V

2. USAR Se~ction 14.0.4.1, Calorimetric Error Instrumentation RC Regulatory Issue Summary (RIS) 2007-21, Rev. 1, kdherence to Licensed Power Limits," February 9, 2009.

.KPS License Amendment 168 and associated NRC safety evaluation, dated July 8, 2003.

5. Procedure SP-87-125, "Shift Instrument Channel Checks -

Operating."

8.3.9-8

KEWAUNEE POWER STATION TRM 8.4.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.4 REACTOR COOLANT SYSTEM (RCS) 8.4.1 Chemistry TNC 8.4.1 Reactor Coolant System chemistry shall be maintained within the limits specified in Table 8.4.1-1 and Table 8.4.1-2.

APPLICABILITY: All MODES.

CONTINGENCY MEASURES If a reactor shutdown is required as a resul reactor restart and continued reactor ope Safety Review Committee. /

8.4.1-1

KEWAUNEE POWER STATION TRM 8.4.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 CONTINGENCY MEASURES (continued)

C. Chemistry parameter C.1 Restore concentration limits 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months not within normal established in Table 8.4.1-2.

concentration limits of Table 8.4.1-2.

D. CONTINGENCY MEASURE and associated Restoration Time of Condition C not met.

OR Chemistry parame);>j not within transie 6 limits of Table 8.4.1 8.4.1-2

KEWAUNEE POWER STATION TRM 8.4.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.4.1.1 -- --------------- NOTE-- NOTE------- -

Only required when reactor coolant temperature Maximum time between

> 2500F. tests is 4 days Determine by analysis, the 3 Q. week Table 8.4.1-1 are within the

'I TVR 8.4.1.2 ------------- -

)Maximum time between tests is 4 days Determibybnnalyis, 11 3 times per week Table 8<.4. 'l Iarameters araifthin ir (ý~edI 8.461-3

KEWAUNEE POWER STATION TRM 8.4.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 Table 8.4.1-1 (page 1 of 1)

Concentration of Contaminants Reactor Coolant Temperature > 2500 F NORMAL STEADY STATE CONTAMINANT OPERATION TRANSIENT LIMITS Oxygen < 0.10 ppm < 1.00 ppm Chloride Fluoride To meet the above Iii provided the coolant 8.4.1-4

KEWAUNEE POWER STATION TRM 8.4.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TABLE 8.4.1-2 (Page 1 of 1)

Concentration of Contaminants Reactor Coolant Temperature < 2500 F NORMAL CONTAMINANT CONCENTRATION TRANSIENT LIMITS Oxygen Saturated Saturated Chloride Fluoride To meet the above limi provided the coolant te 8.4.1-5

KEWAUNEE POWER STATION TRM 8.4.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND By maintaining the oxygen, chloride and fluoride concentrations in the reactor coolant below the limits as specified in TRM 8.4.1, the integrity of the Reactor Coolant System is ensured under all OPERATING conditions (reference 1).

If these limits are exceeded, measures can be taken to correct the condition, e.g., replacement of ion exchange resin or adjustment of the hydrogen concentration in the volume control tank (reference 2).

Because of the time-dependent nature of any adv effects arising from oxygen, chloride andfluoride concentratione, n i ;s of the limits, it is unnecessary to4-hbt do i mmediately since the con, tion can be corrected. Thus thk ti iepe pids for correct y*actio estore concentration iithin'tLe lir stShave bee escab]bi ed. If the corrective action has r/bee6ýeffei7 e at the ec ot e time eriod, reactor and swill continue.

)n"dminants in t'$e re ctor-bc lant are temperature

ýreactor may be res* reand operation resumed ifthe intration of any of thý %*ntaminants did not exceed the ent vj; otherwise a safety review by the Facility

,om

__s eqred before startup.

8.4.1-6

KEWAUNEE POWER STATION TRM 8.4.3 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.4 REACTOR COOLANT SYSTEM (RCS) 8.4.3 Reactor Coolant Vent System TNC 8.4.3 The following reactor coolant system vent paths shall be FUNCTIONAL and closed:

a. Reactor vessel head vent path.

b. Pressurizer steam space vent path.

Req red CONTINGENCY MEASU Ra* \

associated Ro n Time of Nonconformance A or B not met.

8.4.3-1

KEWAUNEE POWER STATION TRM 8.4.3 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.4.3.1 Cycle each solenoid operated valve in each vent Once per operating path through at least one complete cycle of full cycle or once every 18 travel. months, whichever occurs first TVR 8.4.3.2 Verify unobstructed flow e) 0 nGe(pD orating coolant system vent paths ycle o~ro every 18 venting operations follo>* ths, whichever ccuoufirst 8.4.3-2

KEWAUNEE POWER STATION TRM 8.4.3 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The function of the High Point Vent System is to vent noncondensible gases from the high points of the RCS to ensure that core cooling during natural circulation will not be inhibited. The FUNCTIONALITY of at least one vent path from both the reactor vessel head and pressurizer steam space ensures the capability exists tcyperform this function.

The vent path from the reactor vessel head and the vent path from the pressurizer each contain two independently emer n-a powered, energize to open, valv rn arallel, and connect t a -on header that discharges eift r'to th 3ontainment at sphere or t the pressurizer reliefta The I es to the conti ent auýosphere and powerederi r pressurizer inkeacl

, c ntain anindep-ri nd y emergency powered, eegiz op isolation -v.'. his re -Undancy provides 1/2#

protectioJr, hefai1'e of a sint e t pa valve rendering an entire5n*lVlt JNCTIOI*IZ 5)

TNC and \L vent path consists 6f4"he piping and valves necessary APPLICABILITY onde gases from the reactor head or the he p r~f tank or the containment

/

Wort for FUNCTIONAL reactor vessel head vent e -4e'5 RC-45B must be FUNCTIONAL and either RC9st be FUNCTIONAL. Accordingly, for a pre, zer vent path, either PR-33A or PR-33B must be and ither RC-46 or RC-49 must be FUNCTIONAL.

K

)n orifice in each vent path limits the flow from an iation of the vent system to less than theflow capacity I pump.

K 8.4.3-3

KEWAUNEE POWER STATION TRM 8.4.3 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES TECHNICAL TVR 8.4.3.1 VERIFICATION REQUIREMENTS The cycling of each solenoid operated valve once each refueling ensures that the valves are capable of opening, if required to vent the reactor coolant system. More frequent cycling of these valves is not practical since it would provide unnecessary challenges to the reactor coolant pressure boundary during plant operation.

TVR 8.4.3.2 Flow verification is the reactor coolant<

noncondensib ja verification *(peif50 assuring At.vwxi*"

and ventrog of tIh, 8.4.3-4

KEWAUNEE POWER STATION TRM 8.5.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 July 18, 2011 8.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 8.5.1 Accumulators TNC 8.5.1 Accumulator check valves and block valves shall be FUNCTIONAL.

APPLICABILITY: MODES I and 2, MODE 3 with RCS pressure > 1000 psig.

CONTINGENCY MEASURES 8.5.1-1

KEWAUNEE POWER STATION TRM 8.5.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 July 18, 2011 BASES BACKGROUND The requirement for accumulator check valves and block valves was relocated from the previous Custom Technical Specifications (TS) during the conversion to Improved TS in License Amendment 207 (Reference 1),

The accumulator discharge check valves (SI-21A(B) and SI-22A(B))

have both an open and closed function. They are considered FUNCTIONAL when they have the ability to pass flow from the accumulator to the RCS. Additionally, the accum discharge check valves are considere F NCTIONAL, during noral toperation with the safety inje*nt*(S'l) stem in standy*when the heck valves are closed and isoln the ýctor coolant I mefr he SI accumulators, J The "va l~jy'j\<requ is) isrn6n ftment the acfor t e c.bdcumb *tor block valves (SI-290 q nýru t 6ŽbloA valve open indication in trof'room is*erified to a &ura ly in Icate that the block valve is ythep ssing of water from t l >umulator to the reactor system (RCS) when the controom indicator indicates the Ilýd block valves shall be FUNCTIONAL Mi.lators are required to be OPERABLE in X.1(i.e., in MODES 1 and 2, and in MODE 3 with psig) (Reference 2).

CONTINOEIS MEASURES Ya~ccumulator check valve or block valve is not FUNCTIONAL,

RABILITY of the associated accumulator(s) must be evaluated per 3.5.1.

TECHNICAL TVR 8.5.1.1 VERIFICATION REQUIREMENTS A verification that each accumulator check valve is FUNCTIONAL is required to be performed every 18 months.

TVR 8.5.1.2 A verification that each accumulator block valve is checked for "valve open" requirements is required to be performed every 18 months.

8.5.1-2

KEWAUNEE POWER STATION TRM 8.5.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 July 18, 2011 BASES REFERENCES 1. License Amendment 207, "Kewaunee Power Station (KPS) -

Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond Scope Issues (TAC Nos.

ME2139, ME2419, ME2420, ME2421, ME3122, ME3460, and ME3544)", dated February 2, 2011.

2. Technical Specification 3.5.1, Accumulators.

8.5.1-3

KEWAUNEE POWER STATION TRM 8.5.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 January 11, 2013 8.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 8.5.2 Emergency Core Cooling System (ECCS), Residual Heat Removal System, and Internal Containment Spray System Gas Accumulation TNC 8.5.2 All required Safety Injection (SI), Residual Heat Removal (RHR) and Internal Containment Spray (ICS) trains shall be sufficiently full of water.

APPLICABILITY: Whenever the associated SI, RHR and ICS trains are required to be OPERABLE by Technical Specifications (TS).

CONTINGENCY MEASURES < N K

IE /

Separate Nonconformance entry is aJI6wedfor eachECCS and ICS train.

NONC( RESTORATION TIME A. One or mor 1 Evaluate OPERABILITY of Immediately ECCS train,, -CCS-train('s) per Technical sufficientlSf S *Seýifi t*t"/ 3.5.2.

4ID

, Evaluate OPERABILITY of Immediately

\ ECCS train(s) per Technical

\: Specification 3.5.3.

B. One or more reqdie*& B.1 Evaluate OPERABILITY of Immediately RHR trai nsot,,1 " RHR train(s) per Technical sufficiently full.of water. Specification 3.4.6.

AND B.2 Evaluate OPERABILITY of Immediately RHR train(s) per Technical Specification 3.4.7.

AND B.3 Evaluate OPERABILITY of Immediately RHR train(s) per Technical Specification 3.4.8.

8.5.2-1

KEWAUNEE POWER STATION TRM 8.5.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 January 11, 2013 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURE RESTORATION TIME C. One or more ICS train(s) C.1 Evaluate OPERABILITY of Immediately not sufficiently full of ICS train(s) per Technical water. Specification 3.6.6.

8.5.2-2

KEWAUNEE POWER STATION TRM 8.5.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 January 11, 2013 BASES BACKGROUND The U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (reference 3) to address the issue of gas accumulation in the emergency core cooling, decay heat removal (DHR), and containment spray systems. At Kewaunee the DHR function is performed by the RHR system. Because the RHR system serves two functions, ECCS and DHR, it is listed separately, covering each function, as appropriate.

The ECCS and ICS System pumps are normally in5astandby non-operating mode. As such,-some flow path pipingias*{he, potential to develop pockets of entrained gases. Plant operating experience and analysis has sho,.nthat after proper system filhing (follewing maintenance o~r'efueli~,gouýges), some-entrain\d non-condensable gases remaitfi. Thlie gae' will formrifil[ voids, wich remain stable in the systemi ing"6th ni(rmal and transient operation. Mechanisms postuv.ed to inokeas[e'he void sizer'. grad4ual in nature, and the syst 'm i o)perated in accordanie with procedures to preclude growth i "Akthesee into voids\

th Intann addition,systems other mechanisms, fr""I such as valve seat eaa intohe stagnant s sfro other gas-laden sources, sys em fluid velocitie~s,and physical geometries can cause a gradual inore ýii the size of gas voids A/lfsystem isuulciently.ftof water when the voids and pockets of 5Th syte <suf. etI .

7_ntrained ases in thlle ECCS, RHR, and ICS piping are small enough in size and number to inot'titerfere with the proper operation of the ECCS,

'Xý"C7< *RHR, or ICIS systemsh. Verification that the ECCS, RHR, and ICS piping is sufficiently full of water can be performed by venting the necessay*ya6,essible high point ECCS, RHR, and ICS vents, using NDE, orrusin-*bther engineering-justified means.

Maihiaifiing the piping and components from the ECCS pump suction sources to the final isolation valve before connection to the RCS sufficiently full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent pump cavitation and air binding, water hammer, and pumping of excess non-condensable gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an Sl signal or during shutdown cooling.

Exceptions to the ECCS system being sufficiently full of water are discussed in USAR Section 6.2.2.3 (Reference 1). These exceptions are designed such that they can accommodate a void without affecting the operability of the associated systems.

8.5.2-3

KEWAUNEE POWER STATION TRM 8.5.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 January 11,2013 BASES BACKGROUND Maintaining the piping and components from the ICS pump suction (continued) sources to the discharge to containment sufficiently full of water ensures that the system will perform properly, injecting its full capacity into containment upon demand.

TNC and All required SI, RHR and ICS trains shall be sufficiently full of water to APPL ICABILITY be FUNCTIONAL whenever the associated SI, RHR and ICS trains are required to be OPERABLE by Technical Specificaons (TS).

CON'[TINGENCY

The Actions armodified bya 1 Note. The Noti rovides'clarification MEAS URES that each train allows separate entry intofaCondi*tin. This is allowed based upon'the FU.NCJIONAL independence'of each train. The SI and RHR systems together comprise4heEC*CS s stem. These systems worl*n' tandem to6provide core ýooling and negative reactivity to ens5ure that4he reactor core is pr'otectbd. Thus, the SI/RHR system Snsists of two trains and the ICS sy,,rt consists of two trains.

l~ n$- d"V2 _

A. 1 and A.'2'.

With one or meierCCnS,trai, not sufficiently full of water, it is not capable of delieen~gl design flow to the RCS. When a train is not

,. "sufficiently full of wpter.the appropriate TS ACTION(S) must be entered immediately:.lndividual components are NonFUNCTIONAL if they are not capable of performing their design function or supporting systen{.'are not available.

'* /1( \ N*.

B 'BandB. 3 Condition B is applicable when one or more trains of RHR are not

':,.suffibiently full of water. In this condition, the RHR system needs to be

'considered c for decay heat removal requirements. When a train is not sufficiently full of water, the appropriate TS ACTION(S) must be entered immediately.

8.5.2-4

KEWAUNEE POWER STATION TRM 8.5.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 January 11,2013 BASES CONTINGENCY C.1 MEASURES (continued) Condition C is applicable when one or more trains of ICS are not sufficiently full of water and not capable of delivering design flow to containment. When a train is not sufficiently full of water, it is considered NonFUNCTIONAL and the appropriate TS ACTION must be entered immediately.

TECHNICAL TVR 8.5.2.1 .

V'ERIFICATION 3 R EQUIREMENTS The ECCS and ICS System pumps are norn1aily in a standby non-operating mode. As such,,4o'me flow p.athpiping has the potential to develop podketsof entrai'ned gases. Flant'oerating experience and analysis has shown

~~maintenf..*e thIkafter or ref.*,ng ouapsproper.stemr

,s:m.et*,e illing (following non-condensable gaases r*"eraiq The~se gases wii~on sm~ voids, which remain stable

)n.Sthe systermin both normal and tra~nient a eW operation. Mechanisms Qpoti[tdt ini increase the void size are graduale' i-.n..in nature, and the Mc sys.tm is~ perated in"*.*ordance with procedures to preclude growth inttiese~voids. In additien,.othehnechanisms, gas-laden such as valve seat sources, mleakige nto thesitagnant systems from other fluid velocities and4lahysical geometries can cause a gradual

1. **-*.s*.sfemg.increase inthTheszef gas voids .

S//

6 :*< K<- / To provide ~ddition~al assurances that the system will function, verification iSperformed every 92 days that the system is sufficiently full

.*. .#*of water**of 'The~system issuffi inciently water and full of RHR, the ECCS, whenICS voids are thepiping and S,, phdkets en~ained gases

\\\"

aqlle J nouegh

- size andannum ber to not interfere w ith the proper

':X.sm Verification that the

'\ o~era~ion of the ECCS, RHR, or ICS systems. of water can

{ECgS, RHR, andC piping

..< is sufficientlymfull p*<{erformed by venting the necessary accessible high point ECCS, RHR, means.

and 1CSvents, using NDE, or using other Engineering-justified Maintaining the piping and components from the ECCS pump suction sources to the final isolation valve before connection to the RCS sufficiently full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent pump cavitation and air binding, water hammer, and pumping of excess non-condensable gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SI signal or during shutdown cooling.

The 92-day frequency takes into consideration the gradual nature of the postulated gas accumulation mechanisms.

8.5.2-5

KEWAUNEE POWER STATION TRM 8.5.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 January 11, 2013 BASES TECHNICAL Maintaining the piping and components from the ECCS pump suction VERIFICATION sources to the final isolation valve before connection to the RCS REQUIREMENTS sufficiently full of water ensures that the system will perform properly, (continued) injecting its full capacity into the RCS upon demand. This will also prevent pump cavitation and air binding, water hammer, and pumping of excess non-condensable gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SI signal or during shutdown cooling.

The 92-day frequency takes into consideration the gradual nature of the postulated gas accumulation mechanisms.

Exceptions to the ECCS system being sufficiently fulr'of water are discussed in USAR Section 6=92.2.3 (Reference 1). These exceptions are designed such that they an accommodate ayoid without affecting the operability of the assd*cated systeaI..,i ', >

Maintaiifýrcg the pipipg and comp nehi ts'frome ICS pump suction

/ i , * *.'*

1. - * , ,4.-, ,

sources t*ebe dis'charge to containmnt sufficiently full of water ensbres tha't the system will perform rorOrly, injecting its full capacity

/.into conta nnt upon demand. The 92-day frequency takes into

'ý,,,ideration the gradual nature of the postulated gas accumulation mechansms. .. "%a...

REFEENCE

'iSa 6.2, Safety Injection System."

REFERENCES 'a,,,1

necin yte.

2. \[,SAR 6.4, "Internal Containment Spray System."

3ý NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.

8.5.2-6

KEWAUNEE POWER STATION TRM 8.6.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.6 CONTAINMENT SYSTEMS 8.6.1 Containment Hydrogen Monitoring System TNC 8.6.1 Containment Hydrogen Monitoring System, consisting of two trains and associated containment dome fans, shall be FUNCTIONAL.

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

A change in operational MODES or conditions is acceptable with one or both trains of the Containment Hydrogen Monitoring System and its associated- Containment Dome Vent Fan NonFUNCTIONAL.

APPLICABILITY: MODE 1 and 2.

CONTINGENCY MEASURES"n NONCONFORM CE >ýNTINGENCY MEASWS RESTORATION TIME aim AA. tort Co inment 30 days ydr Mon Hoyý y0 og nitoring System SystNm t. I UNCTIONAL status.

B. - s of B. Restore one Containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Co tainment H g9 Hydrogen Monitoring System Monitoring Syste train to FUNCTIONAL status.

NonFUN C NA C. CONTINGENCY C.1 Enter condition into the Immediately MEASURE and corrective action process to associated Restoration address why the hydrogen Time of Nonconformance monitors were not restored to A or B not met. FUNCTIONAL status within the allotted time.

8.6.1-1

KEWAUNEE POWER STATION TRM 8.6.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS TVR 8.6.1.1 Perform CHANNEL CHECK.

8.6.1-2

KEWAUNEE POWER STATION TRM 8.6.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The TS requirements for a Containment Hydrogen Monitoring System have been removed from TS as listed in the Federal Register on September 25, 2003. Guidance for the Consolidated Line Item Improvement Process (CLIIP) has been incorporated in the Technical Specification Task Force (TSTF) Change Traveler 447, Rev.1. Part of the requirements for removing Containment Hydrogen Monitoring System from TS was to place any remaining requirements in a Licensee controlled document (Technical Requirements Manual) with the requirements that a hydrogen monitoring syste-e available for beyond design-bas ac.*en monitoring of contnIld rogen levels. NM Even though dr gen'lo*hjers were taken out of TS, the syst r I{'f)beyo n design-basis accident4r*f .oge levels. In the event CONTIGEN S A et, the condition will be ram immediately to address why

ýq4jo FUNCTIONAL status within

)Xmented in a timely manner to etermined by plant management.

on program is to assure prompt oversight to minimize the

are NonFUNCTIONAL.

The USAR credits *l&6eration of the Containment Dome Vent Fans in section 5.A .17. T"* sample ports are located near the discharge of the Co ai* ent Dome Fans, which permit rapid detection of hydrogen esc il lcrd the reactor. The fans draw suction from the upper areas of io met which prevents the formation of a stratified atmosphere.

it for the containment dome vent fans as a support or the hydrogen monitors.

REFERENCES 1. PORC meeting 97-097

2. KAP 01-527

3. Commitment 97-115

4. Inspection Report 97-10 IFI 305/97010-01 8.6.1-3

KEWAUNEE POWER STATION TRM 8.7.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.7 PLANT SYSTEMS 8.7.4 Main Turbine Overspeed Protection TNC 8.7.4 Main Turbine Overspeed Protection shall be FUNCTIONAL with at least two of the following turbine overspeed protection systems:

a. Mechanical overspeed trip mechanism,

b. Electro-hydraulic control,

c. Redundant overspeed t rip (ROST) protection. i .

APPLICABILITY: MODE 1.. \

CONTINGENCY MEASURES /

- -NOTE ------ -

When one turbine overspeedprotectio~h system is NonFUNC~tIONAL, a second turbine overspeed protection sytem'nray be blocked for up to 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s*to allow for testing without requiring entry into Nonconformabnce A, providedW ,at least one system remains FUNCTIONAL.

NONCO\NF.ORMANCE

.-. , .:. I. **.*z CONTINGENCY MEASURES RESTORATION TIME A.One, reaired turbine A 1* Reduce power to less than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months overspeed protection 50% rated power.

systems NonFUNCTIONAL.

B. Two required turbine B.1 Isolate the turbine from the 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months overspeed protection steam supply.

systems NonFUNCTIONAL.

8.7.4-1

KEWAUNEE POWER STATION TRM 8.7.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.7.4.1 Perform turbine redundant overspeed trip test. 31 days TVR 8.7.4.2 Perform turbine trip mechanism test. 92 days TVR 8.7.4.3 Perform turbine mchani t A mnths, calibration check.

TVR 8.7.4.4 Perform turbine/l.~actr6.ýhydrau'ic overspeed--tri .test. }18 months TVR 8.7.4.4 Perform turbine elctr-hy'd rau li overspeed trip et ~18 months TVR 8.7.4.5 Perform urinecr-hydalcoesee

~ V i 8mnh calibra6iin. V TVR 8.7.4.6 Perft'rm Eeindant overspaed turbine trip system 18 months

.. tijon.

cbilibr*____.__,___-__-- 79.

A*.* '--.,*.,, " .. . ) .

8.7.4-2

KEWAUNEE POWER STATION TRM 8.7.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The main function of the Main Turbine Overspeed Protection System is to prevent the generation of potentially damaging missiles from the turbine due to turbine overspeed. The potential effects of missile ejection from the turbine are explained in USAR Section, Appendix B.9, "Turbine Missile Effects" (reference 1).

Turbine overspeed, upon loss of electrical load, is prevented by the rapid cutoff of steam admission to the turbine. Turbine main steam and reheat steam admission are both controlled by serin;'alignments of main turbine stop, control,-reheat, and intercept valvesH;Which are held open against strong spring ressure by high-pressure hydraulic fluid.

Overspeed control and prot'etion is by releas'e'of hydfaul1c fluid pressure to thesteam

,' \* admission

\NV valves,-Three

/ i '/",ependent overspeed protection systems and reelundant hydrAladiicJluid prssure release valves assurdeahighlyv/eliable preyen'tibn of turbine overspeed.

The E/H Control System incorporates an Overspeed Protection Controller tohimit the overspeed of thie turbine during a loss of electrical lo1ad.,"A turbine shaft speed transduceriprovides a signal to the E/H Cortrol System and ,at:lO03 percent of rated shaft speed, this system redase'sthe actuating hy'draulic'fluid pressure to close the control and

\ intercept valves (reference 2)i Once speed is reduced, the main

\ System to retunm the,turbine generator to 1800 rpm.

/>-'*'/w./ The main ov'ersped system is the mechanical overspeed

'protecion mecanism etrip which is backed up by two separate overspeed

.protectosystems. p However, actuaton of any of the three systems dump~sthe E/Hfluid and therefore itiates closure of all fourteen steam

IIiletsvalves. In addition to closing the steam inlet valves, dumping E/H

\fpud i'a closes thea valve to the extraction lne non-return K' \yvates to Feedwater Heaters No. 14 and 15, thereby closing the

<nonreturn valves. Baffles in Feedwater Heaters No. 11, 12, and 13 minimize flashback of water in these heaters. Even though the 14 steam inlet valves and the extraction line non-return valves are relied upon for overspeed protection, a Westinghouse analysis (WCAP-11525, "Probabilistic Evaluation of Reduction in Turbine Valve Test Frequency" and WCAP-16054-P, "Probabilistic Analysis of Reduction in Turbine Valve Test Frequency for Nuclear Plants with Siemens-Westinghouse BB-95/96 Turbines," determined certain valve failures would not result in a design overspeed situation.

The main overspeed protection system consists of an overspeed oil trip valve and a mechanical overspeed mechanism which consists of a spring-loaded eccentric weight mounted in the end of the turbine shaft.

8.7.4-3

KEWAUNEE POWER STATION TRM 8.7.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND At a maximum of 109.28 percent of rated shaft speed, centrifugal force (continued) moves the weight outward to mechanically actuate the overspeed trip valve which dumps auto stop oil pressure and in turn releases the actuating hydraulic fluid pressure to close the main turbine stop, control, reheat stop, and intercept valves. The supply steam pressure acts to hold the main turbine stop valves closed.

One of the backup overspeed protection systems is provided by the E/H Control System if turbine speed reaches 109.5;percent of rated speed. At this point, the-solenoid trip is energized to dump the auto stop oil which releases actuating hydraulic fluid pressure to ensure closing of the main turbie s{dp, control, reheat stop, and.Aintercept valves.

Another backup overspeed protection\System is the Redundant Channel Overspeedd Trip System'(RSTT)-, This system provides a completely'ýiidependent and physically separate redundant sensing and trip'ing cirduiitto trip closed all steamnsuyp5ly valves at 109.5 percent of

<,eated speed. Speed signals originate from three turbine speed-sensing 4rnag .etic'pickups located in the exciter enclosure. The three pickups prd'vide/W'signal to tl res'peed switches each containing frequency converters, compara tors d triiprelays. The unit works by comparing the signals from thef requency converters to the overspeed trip

/2 ~sbtpoint. An overspeedtrip signal is generated by 2 out of 3 (2/3) relay trip logic which energizes redundant auto stop oil trip solenoids. When energized,(the redudndant auto stop oil trip devices release auto stop oil pressure which releases E/H fluid system pressure on the valve main turbine stop, control, reheat stop, and intercept

'actuat~r*of.the "valves,'allowing the heavy spring pressure to slam the valves closed.

<- Power, ifothew magnetic speed pickups, frequency converters and

\\mrr arjators is provided by the exciter's permanent magnet generator.

-* -'Powyer for the trip relays is provided by 125 VDC battery BRC-101 and

> power for the redundant auto stop oil solenoids is provided by 125VDC battery BRA-1 01. Individual channels can be checked on line without loss of the emergency protective function.

8.7.4-4

KEWAUNEE POWER STATION TRM 8.7.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES TNC and During power operation, Turbine Overspeed Protection is required to be APPLICABILITY FUNCTIONAL, including at least two of the following turbine overspeed protection systems: mechanical overspeed trip mechanism; electrohydraulic control; and, redundant overspeed trip (ROST) protection.

Reactor power shall not exceed 50 percent of rated power unless two of the three turbine overspeed protection systems are FUNCTIONAL.

C ONTINGENCY The CONTINGENGV'MEASIURES are modified by a Note that allows MIEASURES blocking an indJvidual-oversp'eed protection system fo6.ui;Nto 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to allow for testing (reference 3,). The provision's of'this Note are applicable When only one of the turbine ovrspeed protection systems is NonFUNicYib`LO*OL/ne of thexremrrJianing two FUNCTIONAL systems rnay bý-l l-cled for up lo 4Thours.to,6ilow for testing without requiring etry into Noriconform~nce(',

If two.(A the three tL rtbioversplaed protection systems are X\ NonFUNCTIONAL, power must b* reduced below 50 percent of rated power within 6hours. *'

If all three tbrbine overspeed protection systems are Non*UICTl.*NAL, the turbine overspeed protection systems cannot automatically effect a turbine isolation. This Nonconformance requires a.

that fhe f*rbine be isolated from its steam supply within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

8.7.4-5

KEWAUNEE POWER STATION TRM 8.7.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES TECHNICAL Testing of the turbine overspeed protection system is discussed in VERIFICATION reference 3.

REQUIREMENTS TVR 8.7.4.1 TVR 8.7.4.1 requires the performance of a turbine redundant overspeed trip test every 31 days.

TVR 8.7.4.2 TVR 8.7.4.2 requires the performance of a turbine trip mechanism test every 92 days.

TVR 8.7.4.3/

TVR 8.7.4.3 reqUireqAhe performac of', turbine mechanical overspeeditrip calibration check& 8 mbnths:'-

</IVR 8>7-4.4 TVR--8'.44 requires[the:,performance of a turbine electro-hydraulic overspeed trip test eery 18'months.

/ ~ YTVR 8.7.4.5

!/ oTVR 8"7"4"5 requires the performance of a turbine electro-hydraulic overspeed1 trip calibration every 18 months.

TV 8.7,.4.6>--

V,,14Rj7-.4.6 requires the performance of a redundant overspeed M'ttitnne trip system calibration every 18 months.

REFERENCES 1. USAR Section B.9, Turbine Missile Effects.

2. USAR Section 10.2.2.10, Turbine Overspeed Control.

3. USAR Section 10.4.

8.7.4-6

KEWAUNEE POWER STATION TRM 8.7.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.7 PLANT SYSTEMS 8.7.6 Guard Pipes TNC 8.7.6 Guard pipes shall be FUNCTIONAL.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

TECHN16AL VEIIý" IET VERIFICATION FREQUENCY TVR 8.7.6.1 Perform visual inspection of Guard Pipes. After maintenance on equipment that could affect the operation of the guard pipe AND 18 months 8.7.6-1

KEWAUNEE POWER STATION TRM 8.7.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The purpose of guard pipes is to prevent jet impingement from directly impacting vulnerable needed equipment. A guard pipe is used to totally enclose either the main steam line or feedwater line to prevent steam or water from damaging equipment.

Visual inspections will be made of the accessible portions of the hot process pipeline guard pipes once during each operating cycle or once every 18 months, whichever occurs first.

8.7.6-2

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 8.8 ELECTRICAL SYSTEMS 8.8.4 Reserve Auxiliary Transformer (RAT) / Reserve Supply Transformer (RST) and Tertiary Auxiliary Transformer (TAT) / Tertiary Supply Transformer (TST)

TNC 8.8.4 The following AC electrical sources shall be FUNCTIONAL:

a. RAT/RST; AND

b. TAT / TST APPLICABILITY: Whenever the main geneator'js in operation CONTINGENCY MEASURES if A. Main feedwater pu! Immediately (FWP) trip on fasti transfer circuit unavailable When b FWPs areaDeY~tini (TS) 3.8.1.

IF RST LTC is in automatic Immediately koperation with Delta-V (%)

,above 0.45%, then declare the offsite circuit associated with the RAT inoperable per TS 3.8.1.

8.8.4-1

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME B. Automatic RST LTC B.1 Operate RST LTC in manual. Immediately operation with Delta-V

(%) monitoring capability AND unavailable.

B.2 Evaluate OPERABILITY of the Immediately offsite circuit associated with the RAT per TS 3.8.1.

C. Automatic TST LTC C.1 Operate TSTTLTC in manual. Immediately operation with Delta-V ,\ "

(%) monitoring capability AND N"\\,,*//

unavailable.*. u" 't C.2 ~Evý'uat§-OPERABILITY of th'e Immediately 1, offsite: circuit associated'with *

-the**TAT per TS l':.ý8 D. Automatic RST LTC DA Declar*t!he offsite circuit Immediately operation with Delta-V associated with the RAT

(%) above 1.-2%, while \i n'po percbIe p4 T-S3.8. 1.

Buses 1.,3/,AND 4 ar4d>

aligned/to themmalin' auxiharytransformer.

IE\Automatic RST LTC <E7,ýI, Declare the offsite circuit Immediately pIeratiri' with Delta-VK-: \"-associated with the RAT (o)/4b6ve 2.7%owhile** K* ' inoperable per TS 3.8.1.

Bus 1-3 OR Bus'1,"-is y, ,

aligned to the RAT.

F. Automatic RST LTC F.1 Declare the offsite circuit Immediately operation with Delta-V associated with the RAT

(%) above 4.5%, while inoperable per TS 3.8.1.

Buses 1-3 AND 1-4 are aligned to the RAT.

G. Automatic TST LTC G.1 Declare the offsite circuit Immediately operation with Delta-V associated with the TAT

(%) above 5.0%. inoperable per TS 3.8.1.

8.8.4-2

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 CONTINGENCY MEASURES (continued)

NONCONFORMANCE 1 H.1 CONTINGENCY MEASURES RESTORATION TIME H. Manual RST LTC Declare the offsite circuit Immediately operation with calculated associated with the RAT post trip voltage below inoperable per TS 3.8.1.

minimum required post trip voltage for existing tap position.

I. Manual TST LTC I*1 Evaluat-OPIE RABILI y operation (with RST the~ofsite r6uit assc LTC in automatic) with with the TAT er TS" Delta-V (%) above 1.2%.

J. Manual TST LTC offsit6 circuit Immediately operation (with RST LTC with the TAT' in manual) with / per TS 3.8.1 calculated post trip* "

voltage below minimum., V required post'trip voltage.. 1 %I for existinirtap"bsition K. P Evaluate OPERABILITY of the Immediately offsite circuit associated with the RAT per TS 3.8.1.

mo unE L. Manual TST LTC.. L.1 Evaluate OPERABILITY of the Immediately operation with albuilated offsite circuit associated with post trip voltage6\ the TAT per TS 3.8.1.

monitoring capability unavailable.

M. RST unavailable. M.1 Declare the offsite circuit Immediately associated with the RAT inoperable per TS 3.8.1.

N. TST unavailable. N.1 Declare the offsite circuit Immediately associated with the TAT inoperable per TS 3.8.1.

8.8.4-3

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.8.4.1 Verify status light 'FWP TRIP ON FAST BUS XFER' 7 days located on mechanical vertical panel 'A' is ON when both FWPs are operating.

TVR 8.8.4.2 Verify generator lockout auxiliary relays associated 36 months with ,main FWP trip on fast bus transfer are "

FUNCTIONAL.

TVR 8.8.4.3 Perform a FUNCTIONAL test of theRST LTC and days TST LTC to verify sepind capability (only reqIuirt,ed, "

if no stepping o turreinprior period). ,"

TVR 8.8.4.4 PerformA, FUNCTIONAL test of the RST LT1C and 3 months TST Lit in mnianual to verify stepping capablity (only required,!if no manual stepping occurred within the period).

-6r TVR 8.8.* erfrr,/a FUNCTIONAL test ofthe RST LTC and 3 months

,,;TST}TC in automatic to verify$stepping capability an:*d automatic response ofkth' LTC voltage regulators (only required if no automatic high speed return steppingýouqrred within the period).

TVR 8.8.4.6 Perforhn a diagnostic maintenance calibration and 18 months "test to'verfy settings and functionally check the LTC voltag e regulators of the RST LTC and TST LTC.

TVR 8.8.4.7 Perform the recommended maintenance-free interval 18 months complementing checks of the RST and TST on-line tap changers (OLTCs) and the LTC control cabinets.

TVR 8.8.4.8 Perform a maintenance test to check the internals of 36 months the RST and TST OLTCs.

8.8.4-4

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES BACKGROUND When a fast bus transfer occurs as a result of energizing relays 86/T1A and 86/T1 B (instantaneous generator lockout) or 86/TI C and 86/T1 D (time delay turbine trip), a large amount of electrical load is rapidly applied to the reserve auxiliary transformer (RAT). Upgrades to the RAT / reserve supply transformer (RST) system increase the system voltage drop and make it more difficult for the RAT / RST to support the added load during a fast bus transfer.

The RST and tertiary supply transformer (TST) are each equipped with an on-line tap changer (OLTC). The load tap changer (LTC) allows plant operators the capability of correcting bus / li6 voltage. The maximum and minimumrainge of the LTC is +/- 110% (of,thl secondary voltage of the RST*[r TST anbi includes 33 tas (nominall,'16 taps to lower voltage and 164aps to raise voltage) toj'djust tle ':01tage. The LTC can operte inethrtomatic or. 4nual."mboes.

AmericapTransmissioniCompany(,AT\C) ana"d,, idwest Independent System ,peratbr (VMISO) have thlt1abilityto monitor Delta-V (%), used with a/uVtatic LTC'6 peration, and p66t tripwoltage, used with manual LT' operatioin. ATC has the capabilitt"omonitor if either LTC is in

',Autom~aticor manual operating moderdi to monitor both LTC tap

'Z\ /61/ of a transformer-LTCi, Opeiation automatic is predicated on having s> ' the-a6ility to mo~itbr, b~eta-y' (%) (138kV bus voltage % change) for any

' auto LTC tap Aston. T\r-t'/soItage change (%) is the predicted voltage j hange, after any pdsttiip voltage drop, with any transmission system configuration.

Operation 6f a transformer LTC in manual is predicated on having the ability eto-monitor post trip voltage (138kV bus voltage) for the fixed tap positibonof the,,LTC. This voltage is the predicted voltage, after any

p6t-t'*ripýltage drop, with any transmission system configuration.

TNC and The RAT I RST shall be FUNCTIONAL.

APPLICABILITY With both feedwater pumps (FWPs) operating, when the RST LTC is operated in manual, control room operators are required to select a single FWP ('A' or 'B') to trip in the event a fast bus transfer occurs.

With both FWPs operating, when the RST LTC is operated in automatic and Delta-V (%) is above 0.45% (Reference 2), control room operators are required to select a single FWP ('A' or 'B') to trip in the event a fast bus transfer occurs.

Tripping a selected FWP during initiation of a fast bus transfer of non-safety related buses to the RAT ensures that during a loss of power from the main auxiliary transformer (MAT) adequate voltage will remain at the RAT during a transfer.

8.8.4-5

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES TNC and For automatic RST LTC operation, ATC has established a Delta-V (%)

APPLICABILITY alarm of 1.2% to alert Kewaunee Power Station (KPS) of an abnormal (continued) distribution system condition associated with the RAT / RST that could lead to an extended degraded voltage condition on the connected safeguard bus, if KPS was to experience a unit trip. Above a Delta-V of 1.2%, concurrent with unit trip, a degraded voltage actuation could exist that would disconnect the safeguard bus from the preferred offsite circuit and start and load the emergency diesel generator to repower the safeguard bus.

For manual RST LTC operation, ATC has establi~hed post trip voltage alarms for each RST'LTC tap position, to alert KPS of an abnormal distribution systemIcondition a-ssociated withfe RATJ.RST that could lead to an extendd p i~gradepd voltageI onditi ý.the connected safeguard bus if K'.S w";to experiene- a unit tri ivWith an analyzed post tripvolttebe 1 lowthe required po~st trip*,Itage for the selected tap position, concurrentAh unit tripagraadedvoltage actuation could exist~tha't'ould disconnect the afe abus from the preferred offsite cir-6it and' tart and load the em'ergencyýdiesel generator to repower the safeguar us.

TheT triary auxiliary transformer (TAT) / TST shall be FUNCTIONAL.

IrForutomatic.TST\LT(CaopeAtion,

, KPS has established a Delta-V (%)

'requirement of-5.0 %,-to lire action to prevent an abnormal distribution system condition associated with the TAT / TST that could lead to an extended degraded, vltage condition on the connected safeguard bus, if KPS wa st experience a unit trip. Above a Delta-V of 5.0%,

concurrent with unit trip, a degraded voltage actuation could exist that wouldediscon'nct the safeguard bus from the preferred offsite circuit an stbrlfand~ldad the emergency diesel generator to repower the A' ,:'..:, .

For manual TST LTC operation, KPS has established a requirement to maintain the TST LTC tap position at or above five (5) taps below the RST LTC tap position. This will ensure that the ATC alarm set for automatic RST LTC operation associated with Delta-V, and the ATC alarms set for manual RST LTC tap positions based on minimum required post trip voltages will be conservative for the manual TST LTC tap positions. With the alarm associated with Delta-V, and the alarms associated with the RST LTC tap positions (concurrent with the analysis between the minimum required post trip voltages for the TST LTC and RST LTC tap positions), ATC would be able to alert KPS of an abnormal distribution system condition associated with the TAT / TST that could lead to an extended degraded voltage condition on the connected safeguard bus, if KPS was to experience a unit trip. With an analyzed post trip voltage below the required post trip voltage for the 8.8.4-6

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES TNC and selected tap position, concurrent with unit trip, a degraded voltage APPLICABILITY actuation could exist that would disconnect the safeguard bus from the (continued) preferred offsite circuit and start and load the emergency diesel generator to repower the safeguard bus.

CONTINGENCY A. 1 MEASURES With both FWPs operating, if the main FWP trip on fast bus transfer circuit is unavailable while the RST LTC is in mara ,Wtleability to obtain a fast bus trai'fer from the MAT to the RA witbioiit actuating safeguard degraded voltagelaying would nbt be guaraent:*ed. The KPS GDC 39 (rrfeetihg4he intent of GDC 17).ddscribe'd-i the Updated Safety Analysis Report (iSAR) (Referle.3) maynot be met.

Because th&o*ffsite power source could potentia ly not be relied upon under this condition,, CONTINGENCY MEASURE A.1 requires imme iafte.actio;..

,2~

Withýboth FWPs operating*,fthe*main FWP trip on fast bus transfer

*. circuit is unavailib1e while tht RST LTC is in automatic with Delta-V

" \ greater than 0A5%/., the abilty to obtain a fast bus transfer from the

"'MAT to the RAT withouftactuating safeguard degraded voltage relaying

/ would not be guarantýed. The KPS GDC 39 (meeting the intent of GDC 17) described in the USAR (Reference 3) may not be met.

<, "Becaus theoffsite power source could potentially not be relied upon

./j und6rthis condition, CONTINGENCY MEASURE A.2 requires

' ir eliate action.

1 aB.and B.2, C.1 and C.2 Ifthe Delta-V monitoring capability is unavailable from both ATC and MISO, automatic RST.LTC and TST LTC operation would be considered Non-FUNCTIONAL and CONTINGENCY MEASURES B.1 and C.1 would be required. Because the offsite power source could potentially not be relied upon under this condition, CONTINGENCY MEASURES B.2 and C.2 require immediate action.

8.8.4-7

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES CONTINGENCY D.1 MEASURES (continued) Ifthe Delta-V (%) is greater 1.2% while Buses 1-3 and 1-4 are aligned to the MAT, Automatic RST LTC operation may not meet the analytical requirements to maintain the RAT / RST offsite circuit operable and CONTINGENCY MEASURE D.1 would be immediately required.

E. 1 Ifthe Delta-V (%) is greater 2.7% while Bus 1-3 or(BusA-4 is aligned to the RAT, automatic RST [TO operation mayýnot meet the-analytical requirements to mainitain the'RAT / RST offsite~circuiop'rable and CONTINGENCY MEASUR:E, E.1 wouldbe immedately required.

F.1 If the DeltaV (0/o) is greater 4.5% while Buses 1-3 and 1-4 are aligned to the RAT, automatic RST LTC operation may not meet the analytical requirements to maintain the RAT / RST offsite circuit operable and CONTINGENCY MEASURE F.1mould be immediately required.

.... 'i '!-"

If the DeltaW., (%) isgreater 5.0%, automatic TST LTC operation may

( not meet tifSanalytical requirements to maintain the TAT / TST offsite circuit op'6ra'ble and CONTINGENCY MEASURE G.1 would be imdi'ýately required.

\\ If the calculated post trip voltage is below the minimum required post trip voltage for the operating tap position, manual RST LTC operation may not meet the analytical requirements to maintain the RAT / RST offsite circuit operable and CONTINGENCY MEASURE H.1 would be immediately required.

8.8.4-8

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES CONTINGENCY 1.1 MEASURES (continued) If the Delta-V (%) is greater than 1.2% (conservative to the analysis specified in Reference 7), manual TST LTC operation (with the RST LTC in automatic) may not meet the analytical requirements to maintain the TAT / TST offsite circuit operable and CONTINGENCY MEASURE 1.1 would be immediately required.

J.1 If the calculated postýtrfipv'*tage is below the mmibium reqnuired post trip voltage for thle operating tap position, ma

. II TST LTC operation (with the RSTLTC in manuaEl/)lmay not meet theanalytical requirements to maintain the TAT*/ TST6ffsite circjt-i6 rable and CONTINGENCY MEASURE, J' iWuld be, immediatelyrequired, K4 and L.1

,,thýecalcrlated post/trl~voltage monitoring capability is unavailable frorn b ATC and MISO,-manual RST LTC or TST LTC operation may not meet the analytical requirements to maintain the RAT / RST or TAT/

/ , "\ TST 1/ offsite cirFt'operable'nd

.!",i-. * - CONTINGENCY MEASURES K.1 and Swould be immediately required.

\ *Y ~M.11, and NA*I, "

Ifthe RST or TST is unavailable, the RAT / RST or TAT / TST offsite circuit would be considered inoperable and CONTINGENCY MEASURE M.1 or N.1 would be immediately required.

8.8.4-9

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES TECHNICAL All TECHNICAL VERIFICATION REQUIREMENTS tests, calibrations VERIFICATION and checks associated with the LTCs are per the correspondence REQUIREMENTS found in References 4 and 5.

TVR 8.8.4.1 The status light 'FWP TRIP ON FAST BUS XFER' should be illuminated when. the FWP trip on fast bus transfer selector switch is selected to trip FWP 'A' or 'B'.

TVR 8.8.4.2 Generator lockout "relaysand generator auxiliaryrelays-ar functionally tested every 3ý6months in acdordanceyjth th"e plant's maintenance testing procedure for FUNCTIONAL trippi~ng of gerie'rator zone lockout relayutt'\ \t

,,A FUNCTIONAL test should be perforfred weekly in manual to verify

l~bw~rand Jaise stepping. capability of the LTC (only required if no stepping occurred in priop-week),, Auto stepping of the LTC within the

\, pri&,oeek also satief;,thi req'uireement.

S TVR 8.8.4.4 A FUNCTIONAL test should be performed quarterly in manual to verify stepping capability of the LTC. Manual stepping of the LTC within the prior quarter also satisfies this requirement.

TVR 8.8.4.5 A FUNCTIONAL test should be performed quarterly in automatic to

",v-erify stepping capability of the LTC and automatic response of the LTC

'/ltage ov regulators. Auto stepping of the LTC, along with high speed return stepping, within the prior quarter also satisfies this requirement.

TVR 8.8.4.6 A diagnostic maintenance calibration and test should be performed every refueling outage to verify settings and functionally check the LTC voltage regulators. This includes verification of the OLTC motor drive operation for both normal expected operation (voltage in and outside the normal control bandwidth) and abnormal operation (voltage outside the voltage limit band).

8.8.4-10

KEWAUNEE POWER STATION TRM 8.8.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 January 29, 2013 BASES TECHNICAL TVR 8.8.4.7 VERIFICATION REQUIREMENTS The vendor recommended maintenance-free interval complementing (continued) checks of oil sampling, vacuum interrupter system test, motor drive condition checks, dehydrating breather checks, and checks for oil leaks should be performed every refueling outage. Additionally, LTC cabinets are to be visually inspected to check for loose connections, damage, overheating, deterioration, and relay degradation.

TVR 8.8.4.8 -,

A maintenance test-shZouid b performed eve.y other~refueling outage to check the internals.of the Q'LTC cabinet, including vacuum interrupter, ass6*iate'dýhmotor&drive circuiitry And euipment, and monitoring s.,stemiThe mclintenance tes-bhould' beperformed per the vendor ran ua~ifTr'L gType RMV-II, which includes a vacuum interrupfer examihatlon for mechanial' test, c,ýntact erosion indicator chece'an'Hi-PoRif required); bypass switch check; and preparation of the LTC foý'ervice checks. Additionjallyjperform checks for loose ponneOctions, damage and contact we'".

REFERENCES 1, TS381

,-,/ r Calculation Cl 1450-Rev. 2, Addendum D, Attachments 3 & 5

/ 3USAR

. Section 8 1.2

4. License Amendment Request 236, and Supplement dated 1/18/11 License 15.

) Aendment No. 209 dated 7/29/11 (KW-CORR-SER-K-1 1-

-6. alculation C1 1450 Rev. 2, Attachment 51 7' Calculation Cl 1450 Rev. 2, Addendum I 8.8.4-11

KEWAUNEE POWER STATION TRM 8.9.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 21, 2011 8.9 REFUELING OPERATIONS 8.9.3 Decay Time TNC 8.9.3 The reactor shall be subcritical for > 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months .

APPLICABILITY: During movement of irradiated fuel assemblies within the reactor vessel.

CONTINGENCY MEASURES T~ FICATION RE6Q ,EMEKT

\'

tIFICATION FREQUENCY

>eactor is subcritical for > 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . Prior to initial movement of irradiated fuel assemblies within the reactor vessel.

8.9.3-1

KEWAUNEE POWER STATION TRM 8.9.3 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 21, 2011 BASES BACKGROUND The 100 hour0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months decay time following plant shutdown bounds the assumption used in the dose calculation for the fuel handling accident in USAR Section 14.2.1.

A cycle-specific cooling analysis will be performed to verify that the spent fuel pool cooling system can maintain the pool temperature within allowable limits based on the 100 hour0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months decay time. In the unlikely event that the analysis determines this time is not sufficient to maintain acceptable pool temperature, the analysis will dei7ie the additional in core hold time reqyLjrd, Each refueling needed, for the conditions. (/

8.9.3-2

KEWAUNEE POWER STATION TRM 10.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 10.0 ADMINISTRATIVE CONTROLS 10.1 Miscellaneous Closure Times When tested in accordance with the applicable technical specification, the closure times for the components listed in Table 10.1-1 shall be met.

Table 10.1-1 Miscellaneous Closure Times 10.1-1

KEWAUNEE POWER STATION TRM 8.3.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.3 INSTRUMENTATION 8.3.4 Residual Heat Removal (RHR) Pump Flow Instrumentation TNC 8.3.4 RHR Pump Flow Channel F626 shall be FUNCTIONAL.

APPLICABILITY: When RHR Pump is in operation for decay heat removal.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. RHR pump flow channel A.1 Initiate acton restoe Immediately F626 NonFUNCTIONAL. instrument,6h~anlt FUNCTIeN;/status' TECHNICAL VERIFICATION REQU(R,ME/NTS (

> 'V\RFICATIQN FREQUENCY

//"/

\ -NOTE --------------------------

Verificdtio, only requirý6ýwýAr, Residual Heat Remov'al"Pump is in .pe /tiofordecay heat removal. \ \. \

TVR 8.3.4.1 Perform CHANNEL CHECK on Residual Heat 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Removal Pump flow instrument.

TVR 8.3.4.2 Perform CHANNEL CALIBRATION on Residual 18 months Heat Removal Pump flow instrument.

8.3.4-1

KEWAUNEE POWER STATION TRM 8.3.4 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND RHR pumps flow outlet loop provides indication, controls and alarms of RHR flow to the RCS during the decay heat removal phase of plant cooldown.

APPLICABILITY When an RHR pump is in operation in the decay heat removal lineup, RHR pump flow channel F626 is required to be FUNCTIONAL to measure RHR flow.

// ,'~

/ / \

/ K'

/

//

" '2 (N

)

/

/' ./

6. <-~.

\ /

) .Q.'

3'

('

8.3.4-2

KEWAUNEE POWER STATION TRM 8.4.2 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.4 REACTOR COOLANT SYSTEM (RCS) 8.4.2 Pressurizer TNC 8.4.2 The pressurizer shall be limited to:

a. A maximum heatup of 100OF in any one hour period;

b. A maximum cooldown of 200OF in any one hour period;

c. A maximum pressurizer to spray water temperature differential of 320 0 F.

APPLICABILITY: At all times.

CONTINGENCY MEASURES NONCONFORMANCE CON SURE *`TORATION TIME A. Pressurizer temperature Immediately

,values in excess of any of the above limits.

Immediately gfiatinningctionevaluation the by to determine s exceeding the surizer temperature limits

-or the structural integrity of the pressurizer.

AND A.3 Evaluate OPERABILITY of Immediately Pressurizer per Technical Specification 3.4.9.

B. Engineering evaluation B.1 Evaluate OPERABILITY of Immediately of the Pressurizer Pressurizer per Technical structural integrity is Specification 3.4.9.

unacceptable.

8.4.2-1

KEWAUNEE POWER STATION TRM 8.4.2 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.4.2.1 - ------------------ NOTE --------------

Only required during heatup or cooldown operation.

Determine pressurizer temperature within limits. 30 minutes TVR 8.4.2.2 Verify differential temperature between spray water 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months temperature<30F

< 3200 F. and pressurizer wate ure is 8.4.2-2

KEWAUNEE POWER STATION TRM 8.4.2 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND Although the pressurizer operates at temperature ranges above those for which there is reason for concern about brittle fracture, operating limits are provided to ensure compatibility of operation with the fatigue analysis performed in accordance with Code requirements. In-plant testing and calculations have shown that a pressurizer heatup rate of 100 0 F/hr cannot be achieved with the installed equipment.

8.4.2-3

KEWAUNEE POWER STATION TRM 8.7.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.7 PLANT SYSTEMS 8.7.1 Steam Generator Pressure / Temperature Limitation TNC 8.7.1 Temperature of the secondary coolant in the steam generator shall be

> 70°F when the pressure of the secondary coolant in the steam generator is > 200 psig.

APPLICABILITY: At all times.

CONTINGENCY MEASURES A. Temperature of the Jiately secondary coolant in the steam generator is

< 70°F when the pressure of the secondary coolant in the steam generator is > 200 Prior to4ncreasing psig. tithe eects of the steam generator enizatiO on the pressure > 200 psig iral% rity of the generator and that the

,generator remains

ýble for continued TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.7.1.1 Verify steam generator secondary coolant is > 70 0 F Prior to increase steam prior to increasing steam generator pressure > 200 generator pressure psig. > 200 psig 8.7.1-1

KEWAUNEE POWER STATION TRM 8.7.1 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND To provide the necessary high degree of integrity for the components in the reactor coolant system, transient conditions are selected for fatigue evaluation based on a conservative estimate of the magnitude and frequency of the temperature and pressure transients resulting from normal operation, normal and abnormal load transients and accident conditions. To a large extent, the specific transient operating conditions to be considered for equipment fatigue analyses are based upon engineering judgment and experience. Those transients are chosen which are representative of transients to be expected during plant operation and which are sufficiently severe or frequent to be of possible significance to component cyclic behavior.

The secondary side of the stea enerator is pressurized to 1356 psig with a minimum water tempture \f 70F coincident w ith the primary side at 0 psig. The steage eratog is analyz d- .5 cycles of this test (reference 1).

The 701F limitatio* l zation e eS'nsures operation within the analyzed bnber cycles.

REFERENCE 1. Uý?ýe tb4.1.5 8.7.1-2

KEWAUNEE POWER STATION TRM 8.8.2 TECHNICAL REQUIREMENTS MANUAL Revision 3 July 1, 2013 8.8 ELECTRICAL SYSTEMS 8.8.2 AC Sources TNC 8.8.2 a. One circuit between the offsite transmission network and the onsite AC electrical power distribution subsystem(s) required by TRM 8.8.5.

Distribution Systems shall be FUNCTIONAL.

b. Specified Emergency Diesel Generator (EDG) support activities shall be met.

APPLICABILITY: Whenever any irradiated fuel assembly is stored in the spent fuel pool and during movement of irradiated fuel assemblies (TNC 8.8.2.a);

Whenever the associated EDG is required to be OPERABLE (TNC 8.8.2.b)

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. TNC 8.8.2.a not met. A.1 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2 Initiate action to restore Immediately required offsite power circuit to FUNCTIONAL status.

B. TNC 8.8.2.b not met. B.1 Enter TNC 7.5.3. Immediately AND B.2 Evaluate OPERABILITY of Immediately EDG(s) per Technical Specifications 3.8.2.

8.8.2-1

KEWAUNEE POWER STATION TRM 8.8.2 TECHNICAL REQUIREMENTS MANUAL Revision 3 July 1, 2013 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.8.2.1 Verify correct breaker alignment and indicated 7 days power availability for the offsite circuit TVR 8.8.2.2 For each EDGI verify fuel oil properties for water, 92 days sediment, and particulates in the EDG day tank are tested and maintained within limits.

TVR 8.8.2.3 Perform NACE surveys of the cathodic protection 12 months system associated with the fuel oil storage tanks and protected portions of the fuel oil lines.

TVR 8.8.2.4 For each EDG, perform inspection in accordance 24 months with procedures prepared in conjunction with its manufacture's recommendations.

8.8.2-2

KEWAUNEE POWER STATION TRM 8.8.2 TECHNICAL REQUIREMENTS MANUAL Revision 3 July 1,2013 BASES BACKGROUND Onsite electrical power is normally supplied from the offsite transmission network by one of two separate sources. The preferred source is the Tertiary Auxiliary Transformer. The Reserve Auxiliary Transformer is also available if necessary. Either of these sources is sufficient to supply the necessary electrical load from one of four available transmission lines.

Because of the continued need for electric power to supply equipment needed for cooling of irradiated fuel stored in the spent fuel pool and as defense in depth for ensuring normal electrical power availability during a response to a Fuel Handling Accident (FHA), the pertinent requirements of TS 3.8.2 "AC Sources Shutdown" for a single FUNCTIONAL AC circuit were relocated to the TRM. The requirements for performance of EDG inspections were relocated from the previous Custom Technical Specification TS 4.6.1.3, during the conversion to Improved TS in License Amendment 207 (Reference 3).

TNC and Offsite power is supplied to the unit substation from the transmission APPLICABILITY network by four transmission lines. These four transmission lines support FUNCTIONALITY of the required qualified circuit between the offsite transmission network and the onsite electrical power system.

To be FUNCTIONAL, the AC circuit must be must be properly aligned (i.e. required breakers closed) such that off-site transmission grid is connected to and able to supply Bus 5 or Bus 6 as required.

The requirement for an AC circuit was relocated from the previous TS 3.8.2. It is required to be FUNCTIONAL whenever irradiated fuel is stored in the spent fuel pool and also during the movement of irradiated fuel assemblies.

To ensure EDG reliability, activities specified by Technical Verification Requirements TVR 8.8.2.2, TVR 8.8.2.3, and TVR 8.8.2.4 must be met whenever the associated EDG is required to be OPERABLE.

8.8.2-3

KEWAUNEE POWER STATION TRM 8.8.2 TECHNICAL REQUIREMENTS MANUAL Revision 3 July 1,2013 BASES CONTINGENCY A.1 and A.2 MEASURES If neither of the circuits are FUNCTIONAL (i.e., TNC 8.8.2.a is not met),

reliability of the normal power supply to equipment needed for cooling of irradiated fuel stored in the spent fuel pool and defense in depth for mitigation of a fuel handling accident is degraded. Therefore, CONTINGENCY MEASURE A.1 requires immediate action to suspend the movement of irradiated fuel in the spent fuel pool and CONTINGENCY MEASURE A.2 requires initiating action to restore an offsite power supply to FUNCTIONAL.

B.1 and B.2 If the Emergency Diesel Generator (EDG) support activities required by TNC 8.8.2.b are not met, the reliability of the associated EDG may be adversely affected. In response, CONTINGENCY MEASURE B.1 requires initiating the action specified in TNC 7.5.3 immediately. This action provides for transition to TNC 7.5.3 to address the condition.

Failure to meet a specified EDG support activity does not necessarily render the associated EDG inoperable. However, because such a failure has the potential to adversely affect EDG performance, CONTINGENCY MEASURE B.2 requires that an evaluation be immediately initiated to determine whether this condition has impacted EDG operability.

TECHNICAL TVR 8.8.2.1 VERIFICATION REQUIREMENTS This TVR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.

TVR 8.8.2.2 License Renewal Commitment 30 (Reference 5) requires that quarterly laboratory testing of fuel oil samples for water, sediment, and particulates will be performed on the emergency diesel generator 8.8.2-4

KEWAUNEE POWER STATION TRM 8.8.2 TECHNICAL REQUIREMENTS MANUAL Revision 3 July 1, 2013 BASES TECHNICAL (EDG) day tanks and on the technical support center diesel generator VERIFICATION (TSC DG) day tank. TVR 8.8.2.2 addresses the EDG portion of this REQUIREMENTS commitment. The testing acceptance criteria will be consistent with the (continued) requirements specified in American Society for Testing and Materials (ASTM) D975-06b for water and sediment and ASTM D6217 for particulates.

Fuel oil in the EDG day tanks shall be sampled for water and sediment on a quarterly (92-day) basis in accordance with ASTM D975-06b.

Particulate concentrations shall be determined on a quarterly (92-day) basis in accordance with ASTM D6217. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a maximum limit of 10 mg/I. ASTM D6217 provides the sample analysis methodology and states that the corresponding particulate limits are as specified in several military fuel specifications (which provide a maximum limit for particulate content of 10 mg/I). The particulate limit of 10 mg/I is consistent with the sampling requirements in ASTM D6217. NRC Information Notice (IN) 91-46, "Degradation of Emergency Diesel Generator Fuel Oil Delivery Systems," had identified that certain earlier testing methods were inappropriate. IN 91-46 stated that the particulate contamination test of ASTM-D2276 was an appropriate test for particulate contamination of stored fuel oil and discussed a limit of 10 mg/I. ASTM-D2276 was supplemented by ASTM-D6217 (Particulate Contamination in Middle Distillate Fuels by Laboratory Filtration) because it is more appropriate for Number 2 diesel fuel. This method is also consistent with EPRI NP-6317.

TVR 8.8.2.3 License Renewal Commitment 48 (Reference 5) states that the cathodic protection system associated with the diesel generator fuel oil storage tanks and protected portions of the fuel oil lines will. each be maintained available a minimum of 90% of the time during the period of extended operation (starting December 22, 2013). In addition, National Association of Corrosion Engineers (NACE) cathodic protection system surveys will be performed at least annually during the period of extended operation.

This verification addresses the cathodic protection survey requirements associated with the EDG aspect of this commitment.

8.8.2-5

KEWAUNEE POWER STATION TRM 8.8.2 TECHNICAL REQUIREMENTS MANUAL Revision 3 July 1, 2013 BASES TECHNICAL TVR 8.8.2.4 VERIFICATION REQUIREMENTS EDG inspections are performed at 24 month intervals in order to (continued) maintain the diesel generators in accordance with the manufacturers' recommendations. The inspection procedure is periodically updated to reflect experience gained from past inspections and new information as it isavailable from the manufacturer.

REFERENCES 1. USAR8.1.1.2.1.

2. USAR Figure 8.2-1 and 8.2-2.

3. Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 207 to Facility Operating License No.

DPR-43, Dominion Energy Kewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2, 2011.

4. NRC Safety Evaluation Related to License Amendment 67, dated July 3, 1986.

5. KPS Renewed Facility Operating License, § 2.C(15)(b), NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," Appendix A, dated January 2011, License Renewal Commitments 30 and 48.

6. License Amendment Request 256, Permanently Defueled License and Technical Specifications.

8.8.2-6

KEWAUNEE POWER STATION TRM 8.8.5 TECHNICAL REQUIREMENTS MANUAL Revision 0 July 1, 2013 8.8 ELECTRICAL SYSTEMS 8.8.5 Distribution Systems TNC 8.8.5 The necessary portion of AC, DC and AC Instrument bus electrical power distribution subsystems shall be FUNCTIONAL to support equipment required to be FUNCTIONAL for management of irradiated fuel.

APPLICABILITY: Whenever any irradiated fuel assembly is stored in the spent fuel pool, During movement of irradiated fuel assemblies CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. Required AC, DC or AC A.1 Initiate actions to restore Immediately Instrument bus electrical required AC, DC or AC power distribution Instrument electrical power subsystems distribution subsystems to NONFUNCTIONAL. FUNCTIONAL status.

AND A.2 Suspend movement of Immediately irradiated fuel assemblies.

TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.8.5.1 Verify correct breaker alignments and voltage to 7 days required AC, DC and AC Instrument electrical power distribution subsystems.

8.8.5-1

KEWAUNEE POWER STATION TRM 8.8.5 TECHNICAL REQUIREMENTS MANUAL Revision 0 July 1, 2013 BASES BACKGROUND The onsite AC, DC and AC Instrument bus electrical power distribution system is divided into electrical power distribution subsystems.

The AC electrical power subsystems consists of 4.16 kV buses and secondary 480 V buses, distribution panels, motor control centers and load centers. Each required 4.16 kV bus has at least one offsite source of power. Additional description of AC distribution system may be found in the Bases for TNC 8.8.2, "AC Sources."

The 4.16 kV portion of the AC electrical power distribution system powers service water pumps while the 480 V portion of the system powers the spent fuel pool pumps and component cooling pumps.

The DC electrical power subsystem provides the control power for 4.16 kV switchgear, and 480 V load centers. The DC electrical power subsystem also provides DC electrical power to the inverters, which in turn power the AC instrument buses.

The requirements for onsite AC, DC and AC Instrument electrical power distribution were previously contained in Technical Specification (TS) 3.8.10 "Distribution Systems - Shutdown." Because of the continued need for electric power to supply equipment needed for cooling of irradiated fuel stored in the spent fuel pool, the pertinent requirements of TS 3.8.10 are being relocated to the TRM during the conversion to Permanently Defueled TS (Reference 1).

TNC and The AC, DC and AC Instrument electrical power distribution systems APPLICABILITY are designed to provide sufficient electrical power to support Functionality of equipment needed for safe management (e.g., storage and movement) of irradiated fuel that is stored in the spent fuel pool and for pool inventory makeup. This TNC requires that those portions of the electrical power distribution system, which are necessary to support forced cooling, a source of coolant inventory makeup, and temperature and level monitoring , be FUNCTIONAL. Depending on specific plant conditions, various combinations of systems, equipment, and components may be used to satisfy this TNC.

A FUNCTIONAL electrical power distribution system is also required during movement of irradiated fuel assemblies. Although the permanently defueled fuel handling accident (FHA) analysis shows that the dose consequences are acceptable without relying on any systems, structures, or components to remain functional during and following the event (following 90 days of irradiated fuel decay time after reactor shutdown and compliance with the spent fuel pool water level requirements of TS 3.7.13), the requirement for a FUNCTIONAL 8.8.5-2

KEWAUNEE POWER STATION TRM 8.8.5 TECHNICAL REQUIREMENTS MANUAL Revision 0 July 1, 2013 BASES TNC and electrical power distribution system is maintained to provide defense in APPLICABILITY depth by providing electrical power to equipment that may be employed (continued) to mitigate the consequences of a FHA.

To be FUNCTIONAL, the AC circuit must be capable of maintaining nominal voltage (+/-10%), and accepting required loads.

CONTINGENCY A.1 and A.2 MEASURES With a required AC, DC or AC Instrument electrical subsystem NONFUNCTIONAL, action to restore the system to FUNCTIONAL status shall be initiated immediately. This action shall continue until restoration is accomplished in order to energize the necessary bus(es) such that power is available to equipment needed to provide forced cooling, coolant inventory makeup, and temperature and level monitoring of irradiated fuel. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the facility is without forced cooling of irradiated fuel.

If movement of irradiated fuel assemblies is in progress with TNC 8.8.5 not met, action must immediately be initiated to suspend movement of irradiated fuel assemblies. With no movement of fuel assemblies in progress, a fuel handling accident is not possible. Suspension of fuel handling activities does not preclude completion of actions to establish a safe conservative condition, such as movement of fuel to a safe position.

TECHNICAL TVR 8.8.5.1 VERIFICATION REQUIREMENTS This TVR verifies that the required AC, DC and AC Instrument bus electrical power distribution systems are functioning properly, with the required buses energized. The verification of nominal voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for system loads connected to these buses. The 7 day Frequency takes into account other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. License Amendment Request 256, Permanently Defueled License and Technical Specifications.

8.8.5-3

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 8.8 ELECTRICAL SYSTEMS 8.8.1 Technical Support Center (TSC) Diesel Generator (DG)

TNC 8.8.1 TSC DG shall be FUNCTIONAL with:

a. Usable fuel oil supply > 200 gallons;

b. Lube oil supply within limits; and,

c. Starting battery FUNCTIONAL. I .

APPLICABILITY: At all times.

CONTINGENCY MEASURES

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

Changes may be made in plant conditions with the TSC DG NonFUNCTIONAL.

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. TSC DG A.1 Initiate action to restore to Immediately NonFUNCTIONAL. FUNCTIONAL status.

AND A.2 Protect Bus 1-46. Immediately AND A.3 Ensure dose assessment can Immediately be performed from the control room.

AND A.4 Notify Security that backup Immediately power to protected area lighting is unavailable.

8.8.1-1

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.8.1.1 Verify TSC DG is synchronized and loaded and 92 days operates for > 60 minutes at a load _ 500 kW.

TVR 8.8.1.2 Verify TSC DG fuel oil storage tank contains _>200 31 days gallons of usable fuel.

TVR 8.8.1.3 Verify TSC DG lube oil level is > 1 inch below "F" 31 days mark on engine oil dipstick when engine has been shutdown > 20 minutes.

TVR 8.8.1.4 Verify fuel oil properties for water, sediment, and 92 days particulates in the TSC DG day tank are tested and maintained within limits.

TVR 8.8.1.5 Verify TSC DG starts from standby condition in *<40 18 months seconds and achieves required voltage and frequency.

TVR 8.8.1.6 Verify TSC DG auto start and load circuitry is 18 months FUNCTIONAL.

TVR 8.8.1.7 ----------------- NOTE ----------------

Replacing the battery meets this TVR.

Verify required starting battery capacity. 36 months 8.8.1-2

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 BASES BACKGROUND The TSC DG is an independent, non-class 1E, 600 kW (1000 hr/year standby rating) power source that provides AC power to 480V Bus 1-46 through breaker 14604.

The TSC DG starts automatically on loss of voltage to Bus 1-46 and automatically connects to the bus after attaining voltage and frequency provided that Source Breaker 14601 has tripped.

The TSC DG provides power to the TSC Building, security lighting system, and other non-ESF plant systems which are required to operate upon loss of off-site electrical sources. Auxiliaries for fuel supply, engine radiator heat rejection, and ventilation are energized from bus 1-46.

TNC and The TSC DG is required to be FUNCTIONAL at all times, to provide APPLICABILITY backup AC power to TSC equipment for Emergency Preparedness (EP) response.

The TSC DG is FUNCTIONAL when it is capable of meeting its TSC supply requirements. It must be capable of automatically starting and available to power required loads within 30 minutes after loss of power to Bus 1-46 to meet EP activation requirements.

The 10,000 gallon capacity fuel oil storage tank for the TSC DG is maintained with sufficient fuel oil to allow operation for an extended period, within which normal power can reasonably be expected to be restored. A minimum indicated level of 2000 gallons is procedurally required to maintain defense in depth beyond the minimum needed for extended operation and thereby assures that the required 200 gallons of usable fuel is available. The 200 gallon requirement originated when the TSC Diesel Generator was previously credited as the Station Blackout Alternate AC Source To be FUNCTIONAL, the lube oil supply must be within established quality and quantity limits. Required oil quantity is determined using the engine oil dipstick, which can only be used when the engine is shutdown. Oil level must be > 1 inch below "F" mark on dipstick (i.e.,

1 inch below "F" mark is the lowest allowable oil level) when engine has been shutdown > 20 minutes. When the engine is running, proper oil levels are monitored on the oil level sight glass. Oil quality is maintained via normal station processes for lube oil procurement.

8.8.1-3

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 BASES TNC and The starting battery must be maintained in a high state of readiness to APPLICABILITY ensure it remains capable of starting the TSC SBO DG in < 40 seconds (continued) of a start signal. The battery is connected to a battery charger that maintains it continuously charged.

CONTINGENCY. AI. I. . .

MEASURES If the TSC DG is NonFUNCTIONAL, action must immediately be initiated to restore it to FUNCTIONAL status. While it is being restored, the following additional compensatory actions (A.2 thru A.4) are needed to ensure availability of electrical power and the capability to respond to a loss of power event.

A.2 With the TSC DG NonFUNCTIONAL, the backup power supply to Bus 1-46 is degraded. Except for emergent circumstances, work and testing relative to Bus 46 should not be undertaken.

A.3 From an EP perspective, with the TSC DG out of service, the intent of the compensatory and mitigation measures is to:

" Have adequate measures in place to minimize the probability of creation of a loss-of-power event.

Have adequate measures in place to deal with an event requiring activation and manning of the TSC, preceded by or followed by a loss of offsite power, rendering the TSC NonFUNCTIONAL.

During the time the TSC diesel is NonFUNCTIONAL, if the emergency response organization is activated and there is a loss of offsite power to the TSC, it may be necessary to relocate the TSC due to loss of the TSC ventilation and loss of the ability to acquire data. If it becomes necessary to relocate the TSC, the following functions/activities are covered by the Emergency Plan Implementing Procedures:

Communications/notifications will be performed from the Control Room until the emergency operations facility (EOF) is activated.

" Classification will be maintained in the Control Room.

8.8.1-4

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 BASES CONTINGENCY " Protective Action Recommendations will be maintained in the MEASURES Control Room until the EOF is activated.

(continued)

Dose assessment will be performed from the Control Room until the EOF is activated.

A.4 With the TSC DG NonFUNCTIONAL, the backup power supply to Protected Area Lighting is unavailable.

TECHNICAL TVR 8.8.1.1 VERIFICATION REQUIREMENTS Verifying that the TSC DG is synchronized with its bus, loaded, and operates for > 60 minutes at a load _ 500 kW ensures the availability of the TSC DG as a backup power source for the TSC. The 92 day frequency is consistent with NUMARC 87-00 guidance.

TVR 8.8.1.2 Required usable fuel oil quantity is verified by checking indicated level on the TSC DG fuel oil storage tank. The 200 gallon limit was based on the fuel needed for operation at the SBO load output for the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months coping duration. However, a minimum indicated level of 2000 gallons is procedurally required to maintain defense in depth and assures that the required 200 gallons of usable fuel is available. This TVR is satisfied if indicated level is > 2000 gallons or if 200 usable gallons is otherwise determined. The 31 day frequency is adequate to ensure that a sufficient supply of usable fuel oil is available, since unit operators would be aware of any large uses of fuel oil during this period.

TVR 8.8.1.3 Required lube oil quantity is verified by checking that level does not decrease lower than 1 inch below "F" mark on engine oil dipstick when engine has been shutdown > 20 minutes. This verification is typically performed in conjunction with DG load testing. The 31 day frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run times are closely monitored by unit staff.

8.8.1-5

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 BASES TECHNICAL TVR 8.8.1.4 VERIFICATION REQUIREMENTS License Renewal Commitment 30 (Reference 2) requires that quarterly (continued) laboratory testing of fuel oil samples for water, sediment, and particulates will be performed on the emergency diesel generator (EDG) day tanks and on the technical support center diesel generator (TSC DG) day tank. TVR 8.8.1.4 addresses the TSC DG portion of this commitment. The testing acceptance criteria will be consistent with the requirements specified in American Society for Testing and Materials (ASTM) D975-06b for water and sediment and ASTM D6217 (D6217-98) for particulates.

Fuel oil in the TSC DG day tank shall be sampled for water and sediment on a quarterly (92-day) basis in accordance with ASTM D975-06b.

Particulate concentrations shall be determined on a quarterly (92-day) basis in accordance with ASTM D6217. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a maximum limit of 10 mg/l. ASTM D6217 provides the sample analysis methodology and states that the corresponding particulate limits are as specified in several military fuel specifications (which provide a maximum limit for particulate content of 10 mg/I). The particulate limit of 10 mg/I is consistent with the sampling requirements in ASTM D6217. NRC Information Notice (IN) 91-46, "Degradation of Emergency Diesel Generator Fuel Oil Delivery Systems," had identified that certain earlier testing methods were inappropriate. IN 91-46 stated that the particulate contamination test of ASTM-D2276 was an appropriate test for particulate contamination of stored fuel oil and discussed a limit of 10 mg/l. ASTM-D2276 was supplemented by ASTM-D6217 (Particulate Contamination in Middle Distillate Fuels by Laboratory Filtration) because it is more appropriate for Number 2 diesel fuel. This method is also consistent with EPRI NP-6317.

TVR 8.8.1.5 Diesel Generator Start Timing was required by NUMARC 87-00 (Paragraph B. 10) when the TSC Diesel Generator was previously credited as the Station Blackout Alternate AC Source. Verifying the TSC SBO DG starts from standby condition in < 40 seconds and achieves required voltage and frequency is being maintained as a good practice. Although normally performed with each start, the 18 month frequency is consistent with the periodicity specified in NUMARC 87-00.

8.8.1-6

KEWAUNEE POWER STATION TRM 8.8.1 TECHNICAL REQUIREMENTS MANUAL Revision 2 September 16, 2013 BASES TECHNICAL TVR 8.8.1.6 VERIFICATION REQUIREMENTS This TVR ensures that the auto start and load circuitry is capable of (continued) supporting the TSC DG function to provide automatic emergency power to TSC equipment for EP response. This verification is only performed on the associated circuitry components (auto loading of the DG onto the bus is not required to be performed as part of the test).

TVR 8.8.1.7 Every 36 months, the starting battery must be either replaced with a new battery or tested to verify that it maintains required capacity needed to start the TSC DG in < 40 seconds. Battery replacement is typically performed rather than capacity testing based on economics (i.e., cost). The 36 month frequency is based on the vendor's recommendation contained in a letter from the engine manufacturer, Western Engine (Reference 3).

REFERENCES 1. NUMARC 87-00 (Rev 0), Appendix B, Alternate AC Power Criteria.

2. KPS Renewed Facility Operating License, § 2.C(15)(b), NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," Appendix A, dated January 2011, License Renewal Commitment 30.

3. Commitment 95-090, Periodic Capacity Testing of the TSC SBO Diesel Starting Batteries per Letter from Western Engine dated July 26, 1988.

4. NUREG-0696 Functional Criteria for Emergency Response Facilities.

5. NUREG-0737 Clarification of TMI Action Plan Requirements.

6. Calculation C1 1450 Auxiliary Power System Modeling and Analysis Rev. 2.

8.8.1-7

KEWAUNEE POWER STATION TRM 7.0 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 7.0 USE AND APPLICATION 7.1 Definitions

NOTES ------------------------------

1. Terms are defined in Section 1.1 of the Technical Specifications and are applicable throughout the Technical Requirements Manual (TRM) and Bases. Only definitions specific to the TRM are defined in this section.

2. The defined terms of this section and the Technical Specifications (TS) appear in capitalized type and are applicable throughout the TRM and the TRM Bases.

Term Definition CHANNEL FUNCTIONAL A CHANNEL FUNCTIONAL TEST consists of injecting a TEST simulated signal into the channel as close to the primary sensor as practicable to verify that it is FUNCTIONAL, including alarm and/or trip initiating action.

CONTINGENCY MEASURES CONTINGENCY MEASURES shall be that part of a Requirement that prescribes CONTINGENCY MEASURES to be taken under designated Nonconformances within specified Restoration Times.

FUNCTIONAL - A structure, system or component (SSC), shall be FUNCTIONALITY FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified function(s) as set forth in the Current License Basis. FUNCTIONALITY does not apply to specified safety functions, but does apply to the ability of non-TS SSCs to perform other specified functions that have a necessary support function.

TECHNICAL NORMAL Specify minimum requirements for ensuring safe CONDITIONS (TNC) management (storage and movement) of irradiated fuel. The CONTINGENCY MEASURES associated with a TNC state Nonconformances that typically describe the ways in which the requirements of the TNC can fail to be met. Specified with each stated Nonconformance are CONTINGENCY MEASURES and Restoration Time(s).

TECHNICAL VERIFICATION TVRs are requirements relating to test, calibration, or REQUIREMENTS (TVR) inspection to assure that the necessary FUNCTIONALITY of systems and components are maintained, that facility operation will be maintained within the current licensing basis, and that the TNC for operation will be met.

7.0-1

KEWAUNEE POWER STATION TRM 7.0 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 7.2 Logical Connectors Logical Connectors are discussed in Section 1.2 of the Technical Specifications and are applicable throughout the Technical Requirements Manual and Bases.

7.3 Restoration Times Restoration Times are analogous to Completion Times as discussed in Section 1.3 of the Technical Specifications and are applicable throughout the Technical Requiremenis Manual.

When "Immediately" is used as a Restoration Time, the CONTINGENCY MEASURE should be pursued without delay in a controlled manner.

7.4 Frequency Frequency is discussed in Section 1.4 of the Technical Specifications and is applicable throughout the Technical Requirements Manual and Bases, with the exception that TECHNICAL VERIFICATION REQUIREMENTS are used in the place of Surveillance Requirements.

7.0-2

KEWAUNEE POWER STATION TRM 7.0 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 7.5 Technical Normal Condition (TNC) Applicability TNC 7.5.1 TNCs shall be met during the specified conditions in the Applicability.

TNC 7.5.2 Upon discovery of a failure to meet the TNC, the CONTINGENCY MEASURES of the associated Nonconformance shall be met.

TNC 7.5.3 When it is discovered that a TNC has not been met and the associated CONTINGENCY MEASURES are not satisfied (or an associated CONTINGENCY MEASURE is not provided), the equipment subject to the TNC is in a nonconforming condition. In this situation, appropriate actions shall be taken as necessary to provide assurance of continued safe management of irradiated fuel. In addition, the condition shall be entered into the corrective action process and assessment of reasonable assurance of safety shall be conducted. Items to be considered for this assessment include the following:

Availability of redundant or backup equipment;

Compensatory measures, including limited administrative controls;

Safety function and events protected against;

Probability of needing the safety function;

Conservatism and margins; and

Risk Assessment or Individual Plant Evaluation results that determine how operating the facility in the manner proposed will impact management of irradiated fuel.

TNC 7.5.4 When a TNC is not met, entry into a specified condition in the Applicability shall only be made:

a. When the associated CONTINGENCY MEASURES to be entered permit continued operation in the specified condition in the Applicability for an unlimited period of time.

b. After performance of a risk assessment addressing NonFUNCTIONAL systems and components, consideration of the results, determination of the acceptability of entering the specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this TNC are stated in the individual TNC; or

c. When an allowance is stated in the individual value, parameter, or other TNC.

This TNC shall not prevent entry into specified conditions in the Applicability that are required to comply with CONTINGENCY MEASURES.

7.0-3

KEWAUNEE POWER STATION TRM 7.0 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 TNC 7.5.5 Equipment removed from service or declared NonFUNCTIONAL to comply with CONTINGENCY MEASURES may be returned to service under administrative control solely to perform testing required to demonstrate its FUNCTIONALITY or the FUNCTIONALITY of other equipment. This is an exception to TNC 7.5.2 for the system returned to service under administrative control to perform the testing required to demonstrate FUNCTIONALITY.

7.0-4

KEWAUNEE POWER STATION TRM 7.0 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 7.6 Technical Verification Requirements (TVR) Applicability TVR 7.6.1 TVRs shall be met during the specified conditions in the Applicability for individual TNCs, unless otherwise stated in the TVR. Failure to meet a TVR, whether such failure is experienced during the performance of the TVR or between performances of the TVR, shall be failure to meet the TNC. Failure to perform a TVR within the specified Frequency shall be failure to meet the TNC except as provided in TVR 7.6.3. TVRs do not have to be performed on NonFUNCTIONAL equipment or variables outside specified limits.

TVR 7.6.2 Each TVR shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified TECHNICAL VERIFICATION REQUIREMENT interval.

TVR 7.6.3 When it is discovered that a TVR frequency (including the 25% extension) has not been met, the TNC must immediately be declared not met and the applicable nonconformance entered for the equipment subject to the TVR. In this situation, the condition shall be entered into the corrective action process and, if indicated, determination to evaluate the impact on plant safety shall be performed in a timely fashion and in accordance with plant procedures.

Actions should be taken to restore conformance with the TNCs / TVRs in a timely fashion.

7.0-5

KEWAUNEE POWER STATION TRM 8.7.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 October 15, 2013 8.7 PLANT SYSTEMS 8.7.8 Spent Fuel Pool (SFP) Temperature TNC 8.7.8 SFP temperature shall be < 150cF.

APPLICABILITY: Whenever any irradiated fuel assembly is stored in the SFP.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. SFP Temperature not A.1 Initiate actions to restore SFP Immediately within limit, temperature to within limit.

AND A.2 Verify that a SFP makeup Immediately water source is available.

TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.7.8.1 Verify that SFP temperature is < 150'F 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 8.7.8-1

KEWAUNEE POWER STATION TRM 8.7.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 October 15, 2013 BASES BACKGROUND The water temperature in the fuel storage pool is normally controlled by the SFP Cooling system. This system is designed to maintain the pool temperature < 1507F.

In the unlikely event that cooling is interrupted for an extended period of time, the volume of water in the SFP provides an adequate heat sink for the heat generated by the irradiated fuel. The potential for an extended loss of forced cooling has been evaluated and is described in the USAR. Conservative calculations were performed to determine the time to boil from an initial temperature of 150'F. The results indicate that the time to boil will increase from an initial value of 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months immediately after core offload to greater than 113 hours0.00131 days 0.0314 hours 1.868386e-4 weeks 4.29965e-5 months after one year.

Boiling and evaporation at the surface of the pool would continue to provide an adequate heat sink for the irradiated fuel assemblies stored in the pool as long as the fuel assemblies remain covered with water.

For the worst-case scenario, the boil-off rate of SFP water is 42 gpm.

Since there is a large capacity for heat absorption in the spent fuel pool, active cooling system components are not redundant. Alternate cooling capability can be made available under anticipated malfunctions or failures. Sufficient time exists to either repair a failed SFP cooling pump or to connect a temporary pump in the system. Heat exchanger failure is not considered to be likely; however, heat exchanger repair (e.g., tube plugging) is a short-term operation and can be accomplished before a significant increase in pool temperature occurs. Both temperature and level indicators in the pool would alert operator to a loss of cooling. Local and remote alarms are provided. This allows the operator to take corrective measures in a timely manner to restore cooling capability to the spent fuel pool cooling loop.

Two sources of water (the refueling water storage tank and a 6" service water supply line) are available to provide a cooling water source until the failed pump is placed into service. In an event of a loss of both SFP pumps and/or SFP heat exchanger, alternate cooling is provided by evaporative cooling process.

The spent fuel pool cannot be drained as a result of component failure due to valving and piping arrangements. The spent fuel pool pump suction line connections extend no more than 2 feet below normal water level (this leaves a margin of 23 feet above the top of the fuel assemblies), thus there is no possibility of inadvertently draining pool water below that level due to a cooling system failure. The SFP cooling system return lines enter the pool above the top of the fuel assemblies and the lines contain check valves at the point of entry into the pool shielding concrete. Thus, line failure outside of the spent fuel pool cannot cause a loss of pool water due to-siphon action.

8.7.8-2

KEWAUNEE POWER STATION TRM 8.7.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 October 15, 2013 BASES BACKGROUND If the normal heat removal capability for the SFP (SFP cooling system)

(continued) is lost for an extended period, decay heat produced by the spent fuel will heat the SFP coolant to a point of boiling and then boil the coolant down to the top of the fuel. DEK assessed the decay heat load over time and calculated the times required for boiling to occur in the SFP and for the time available to take actions before any fuel uncovery occurs. This assessment was based -on the fuel assembly characteristics following permanent shutdown of the reactor that occurred May 7, 2013.

The SFP contains 805.3 gallons of water per inch, with canal weir gate removed (681.4 gal/in with the weir gate installed), of height above the top of the fuel assemblies. Technical Specification (TS) 3.7.13 specifies a minimum of 23 feet of water above the top of the fuel assemblies in the SFP. A worst case boil off rate (freshly discharged core) had previously been calculated to be 42 gallons/min. Under such conditions, fuel uncovery would begin to occur approximately 88 hours0.00102 days 0.0244 hours 1.455026e-4 weeks 3.3484e-5 months (74 hours8.564815e-4 days 0.0206 hours 1.223545e-4 weeks 2.8157e-5 months with the weir gate installed) after the pool water was heated to saturation temperature.

The Reactor Data Manual contains information that can be used to show the amount of time required for the water in the SFP to reach saturation temperature (212TF) and begin to boil fol lowing a loss heat removal capability (loss of cooling) that was not recovered. A starting SFP water temperature of 100'F was chosen because SFP temperature is annunciated when temperature rises to 100*F, requiring an operator response. Time to boil curves were developed for the SFP based on the permanent shutdown on May 7, 2013. As the fission products in the fuel decay over time, the decay heat being produced continuously lessens and the length of time required to achieve boiling in the SFP increases correspondingly. These curves can be used to show the time required for all the water in the SFP above the top of the fuel assemblies to boil off. Sufficient heat is removed from the fuel during the boiling process, such that no fuel damage occurs, while the water level remains above the top of the fuel.

Because of the lengthy period available until fuel uncovery would occur and because of the relative ease with which alternative means of supplying cooling water to the SFP can be restored, it is not reasonable to postulate that fuel damage can occur due to loss of normal cooling capability to the SFP.

8.7.8-3

KEWAUNEE POWER STATION TRM 8.7.8 TECHNICAL REQUIREMENTS MANUAL Revision 0 October 15, 2013 BASES TNC and This TNC requires SFP temperature to be maintained less than or APPLICABILITY equal to the design value of 150'F while spent fuel is stored in the SFP.

Based on SFP heat load calculations, the SFP cooling system is capable of maintaining this temperature following the initial 100 hour0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months in-core hold time. SFP bulk temperatures that are greater than 150cF indicate the need for corrective actions.

CONTINGENCY A. 1 MEASURES An increase in the temperature of water in the SFP above the specified limit could indicate that the cooling system is not in service. Therefore Action A.1 requires immediate action be taken to restore the SFP temperature to within limit. Should temperature increase to the point that the water level in the SFP decreases to less than 23 feet above the top of the fuel, LCO 3.7.13 prohibits movement of irradiated fuel assemblies in the SFP.

A.2 Since a continued increase in the temperature of the water could eventually lead to a loss of water inventory due to increased evaporation and subsequent boiling, contingency measure requires that a source of make-up water be made available to replenish SFP water inventory.

For the worst-case scenario, the boil-off rate of the SFP water is 42 gpm.

TECHNICAL TVR 8.7.8.1 VERIFICATION REQUIREMENTS This TVR verifies that the SFP temperature is within limits on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency is -appropriate since the temperature of the SFP is not subject to rapid changes. This frequency ensures than an increasing temperature is detected prior to the beginning of a loss of SFP inventory due to boiling and evaporation of the coolant.

REFERENCES 1. Calculation C12026 Kewaunee Offload Specific SFP Heat Removal Calculation for Cycle 32

2. ER-AA-RXE-103 Spent Fuel Pool Heatup

3. ETE-KW-2013-0016 TRM 8.7.8 Fuel Uncovery Times 8.7.8-4

KEWAUNEE POWER STATION TRM 8.9.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 8.9 FUEL HANDLING OPERATIONS 8.9.1 Spent Fuel Pool - Control of Heavy Loads TNC 8.9.1 Heavy loads greater than the weight of a fuel assembly, including its heaviest insert and handling tool, will not be transported over or placed in either spent fuel pool when spent fuel is stored in that pool, unless:

a. The heavy load does not traverse directly above spent fuel stored in the pool's spent fuel storage racks, and

b. The load handling system (e.g., crane, associated lifting devices, and interfacing lift points) used for these lifts meets the single-failure-proof handling system criteria.

APPLICABILITY: Whenever a load greater than the weight of a fuel assembly, including its heaviest insert and handling tool, is lifted in or around the spent fuel pool.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. TNC 8.9.1 not met. A.1 Place load in a safe condition Immediately no longer suspended over the spent fuel pool.

AND A.2 Cease further movement in Immediately or over the spent fuel pool.

AND A.3 Initiate actions to restore Immediately compliance to TNC 8.9.1.

8.9.1-1

KEWAUNEE POWER STATION TRM 8.9.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY None N/A 8.9.1-2

KEWAUNEE POWER STATION TRM 8.9.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 BASES BACKGROUND A "heavy load" is defined as any load (a mass or weight suspended from the crane's hook) greater than the weight of a fuel assembly, including its heaviest insert and handling tool. The purpose of this administrative limiting condition for operation is to control the movement of heavy loads in or around the spent fuel pool.

This administrative limiting condition. for operations was relocated frorm the Kewaunee Power Station Technical Specifications because it no longer meets any of the four criteria 10 CFR 50.36 lists for items required in technical specifications.

The Auxiliary Building crane (part of the load handling system1) was modified to meet the criteria of a single-failure-proof crane found in NUREG-0612, Section 5.1.6(2) and the crane is designed, fabricated, installed, and tested to the guidance of NUREG-0554, as approved for KPS. The crane will be inspected, tested, and maintained in accordance with ASME B30.2-1976. In addition, the modified Auxiliary Building crane was load-tested to 156.25 tons (125%). The lifting devices and interfacing lift points associated with the Auxiliary Building crane also meet the guidance in NUREG-0612 to be considered a single-failure-proof lifting system. Specifically, special lifting devices will meet the guidance in NUREG-0612, Section 5.1.6(1)(a) and lifting devices not specifically designed will meet the guidance in NUREG-0612, Section 5.1.6(1)(b). Interfacing lift points will meet the guidance in NUREG-0612, Section 5.1.6(3). A single-failure-proof AB crane lifting system allows for the removal of the cask-drop accident from the licensing basis of the Kewaunee Power Station, as the accident is no longer credible.

With the cask-drop accident removed from the licensing basis, Criterion 2 of 10 CFR 50.36 no longer applied, and the crane load limits were relocated from the TSs to the TRM.

1 All load bearingcomponents used to lift the load, including the crane or hoist, the lifting device, and the interfacing load lift points.

8.9.1-3

KEWAUNEE POWER STATION TRM 8.9.1 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 BASES BACKGROUND Crane interlocks are utilized to ensure safe load handling. Crane (continued) interlocks and administrative procedures will prevent the movement of heavy loads over-spent fuel in the storage racks in spent fuel pool.

Movement of necessary heavy loads over irradiated fuel in the spent fuel canister during cask handling operations will only be performed as required by the design of the spent fuel cask system. Removal /

placement of additional spent fuel racks and support hardware will be controlled by procedures to prevent movement to directly above spent fuel. Handling of spent fuel storage casks and associated other heavy loads is controlled by procedures to prevent movement to directly above spent fuel, except as necessary to correctly load the cask system in accordance with the cask vendor's operating procedure.

REFERENCES 1. License Amendment No. 200, dated November 20, 2008 and License Amendment No. 205, dated April 30, 2009.

2. Kewaunee Power Station Updated Safety Analysis Report (USAR) section 9.5, "Fuel Handling System."

3. USAR section 14.2.1, "Fuel Handling Accidents."

4. NUREG 0612, "Control of Heavy Loads at Nuclear Power Plants."

5. Letter from Darrell G. Eisenhut (NRC) to All Licensees of Operating Plants, Applicants for Operating Licenses, and Holders of Construction Permits, "Control of Heavy Loads," dated December 22, 1980.

6. Letter from Darrell G. Eisenhut (NRC) to Licensees, "Control of Heavy Loads (Generic Letter 81-07)," dated February 3, 1981.

7. Letter from Steven A. Varga (NRC) to C.W. Geisler (WPSC),

"Control of Heavy Loads (Phase I)," dated March 16, 1984.

8. Letter from C.W. Geisler (WPSC) to D.G. Eisenhut (NRC),

"Control of Heavy Loads - Nine-Month Response," dated March 9, 1983.

9. Letter from C.W. Geisler (WPSC) to D.G. Eisenhut (NRC),

"Control of Heavy Loads," dated April 4, 1983.

10. Letter from A. Schwencer (NRC) to E.W. James (WPSC), dated March 6, 1979 (License Amendment 26).

11. 52 FR 3788, "Nuclear Regulatory Commission - Proposed Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," dated February 6, 1987.

12. WCAP-11618, "Methodically Engineered, Restructured and Improved, Technical Specifications," dated November 1987.

13. NUREG 0554, "Single-Failure-Proof Cranes for Nuclear Power Plants."

8.9.1-4

KEWAUNEE POWER STATION TRM 8.9.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 8.9 FUEL HANDLING OPERATIONS 8.9.2 Spent Fuel Pool Bridge Crane TNC 8.9.2 Spent fuel pool bridge crane shall be FUNCTIONAL.

APPLICABILITY: During movement of irradiated fuel assemblies or fuel assembly

- components.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. Spent fuel pool bridge A.1 Suspend movement of fuel or Immediately crane fuel assembly components.

NonFUNCTIONAL.

TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.9.2.1 ------------------- NOTE---------------

The load assumed by the crane must be equal to or greater than the maximum load assumed by the crane during fuel movement.

Perform dead load test on spent fuel pool bridge Prior to movement of crane. fuel assemblies TVR 8.9.2.2 Perform visual inspection of spent fuel pool bridge After every dead load crane. test AND Prior to movement of fuel assemblies 8.9.2-1

KEWAUNEE POWER STATION TRM 8.9.2 TECHNICAL REQUIREMENTS MANUAL Revision 1 October 15, 2013 BASES BACKGROUND The spent fuel pool bridge crane is required for movement of fuel and fuel assembly components. A dead-load test shall be successfully performed on the spent fuel pool bridge crane before movement of fuel or fuel assembly components begins. The load assumed by the crane for this test must be equal to or greater than the maximum load to be assumed by the crane during fuel handling (fuel or assembly component). A thorough visual inspection of the crane shall be made after the dead-load test and prior to fuel handling.

TNC and This TNC requires the spent fuel pool bridge crane be FUNCTIONAL.

APPLICABILITY To be FUNCTIONAL, the crane must meet its respective TVRs. In the event that the crane cannot meet its respective TVRs, the crane is NonFUNCTIONAL.

The spent fuel pool bridge crane must be FUNCTIONAL to move fuel or fuel assembly components.

CONTINGENCY A.1 MEASURES If the spent fuel pool bridge crane is NonFUNCTIONAL, movement of fuel or fuel assembly components shall be stopped. This does not preclude movement of a fuel assembly or fuel assembly component to a safe position.

TECHNICAL TVR 8.9.2.1 VERIFICATION REQUIREMENTS Dead-load testing shall be successfully performed on the spent fuel pool bridge crane before fuel movement begins. Testing ensures the lifting device has adequate capacity to lift the weight of a fuel assembly and fuel assembly components.

TVR 8.9.2.2 Visual inspection shall be made after dead-load testing and prior to fuel movement. The inspection is performed to detect component defects.

REFERENCES 1. USAR 9.5, Fuel Handling System

2. USAR 14.2.1, Fuel Handling Accidents 8.9.2-2

KEWAUNEE POWER STATION TRM 8.9.4 TECHNICAL REQUIREMENTS MANUAL Revision 2 October 15, 2013 8.9 FUEL HANDLING OPERATIONS 8.9.4 Radiation Monitoring During Fuel Movement TNC 8.9.4 Monitor radiation levels in the fuel handling area:

a. Spent Fuel Pool APPLICABILITY: During movement of irradiated fuel assemblies or fuel.assembly components.

CONTINGENCY MEASURES NONCONFORMANCES CONTINGENCY MEASURES RESTORATION TIME A. Radiation levels not A.1 If movement of fuel or fuel Immediately continuously monitored. assembly components are in progress, place in safe condition.

TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.9.4.1 Verify radiation levels are continuously monitored in Prior to movement of spent fuel pool areas. fuel or fuel assembly components and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

8.9.4-1

KEWAUNEE POWER STATION TRM 8.9.4 TECHNICAL REQUIREMENTS MANUAL Revision 2 October 15, 2013 BASES BACKGROUND Continuous monitoring of radiation levels provides immediate indication of an unsafe condition.

TNC and This TNC requires that radiation levels be monitored in the spent fuel APPLICABILITY pool area during fuel movement or during movement of fuel assembly components. A minimnum of one radiation monitor capable of detecting releases from a postulated fuel handling accident must be in operation in this area during fuel movement or during movement of fuel assembly components.

Radiation monitors that are acceptable for satisfying this TNC are as follows.

Spent Fuel Pool R-5 Other radiation monitors may be used to satisfy this TNC provided that an evaluation determines that the monitor is capable of detecting releases from a postulated fuel handling accident.

CONTINGENCY A.1 MEASURES If at least one required radiation monitor is not in operation in the spent fuel pool area, actions must immediately be initiated to: place any fuel assemblies or fuel assembly components that are being moved into a safe condition and cease fuel movement TECHNICAL TVR 8.9.4.1 VERIFICATION REQUIREMENTS A verification that radiation levels are continuously monitored in the spent fuel pool area is required to be performed before fuel movement or movement of fuel assembly components begins and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

REFERENCES 1. USAR 14.2.1.3 Fuel Handling Accident Method of Analysis 8.9.4-2

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.9 REFUELING OPERATIONS 8.9.6 Spent Fuel Pool Sweep System TNC 8.9.6 Two spent fuel pool sweep trains including the charcoal absorbers and Radiation Monitors R-13 and R-14 shall be operating and FUNCTIONAL.

APPLICABILITY: During fuel handling if irradiated fuel in the pool has decayed less than 30 days, When any load is carried over the pool if irradiated fuel in the pool has decayed less than 30 days.

CONTINGENCY MEASURES Spent Fuel Pool Sweep System is not operating or NonFUNCTIONAL.

8.9.6-1

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 CONTINGENCY MEASURES (continued)

B. Radiation Monitors R-13 B.1.1 ------------- -NOTE and R-14 are not Fuel assemblies may be operating or are placed in a safe condition.

NonFUNCTIONAL -----------------------------------

Suspend any fuel assembly Immediately movements.

AND B.1.2 Relocate any load carried over the pool such that it is no longer, suspended ov*

the pool.

Immediately 8.9.6-2

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY

.5-TVR 8.9.6.1 Each HEPA filter shall be demonstrated 18 months FUNCTIONAL by performing an in place cold DOP test. The DOP removal capability for each train AND shall be > 99%.

After each complete or partial replacement of the HEPA filter bank AND Aý ny maintenance banke system that ci Idaffect the HEPA

)bank bypass leakage TVR 8.9.6.2 Verify each Spent F e't, o wee tnats 18 months automatically.

TVR 8.9.6.3 Verify th bd HEPA d charcoal 18 months adsorb r'b, n'k'fain a e drop < 5.5 inches of w,- 4e for eA Afilter and charcoal ad"' K trin at,0 system design flow rate.

TVR 8.9.6.4 Verify eac( t Fuel Pool Sweep train fan Whenever the fans are operates wit; n 10% of design flow rate. tested TVR 8.9.6.5 Verify each charcoal adsorber bank has After complete or partial Halogenated Hydrocarbon removal capability of replacement of

> 99%. charcoal adsorber bank OR After any maintenance on the system that could affect the charcoal adsorber bank bypass leakage 8.9.6-3

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 TECHNICAL VERIFICATION REQUIREMENTS (continued)

VERIFICATION FREQUENCY TVR 8.9.6.6 Verify air distribution flow within the system of the After any maintenance HEPA filter bank is uniform within + 20%. Air or testing that could distribution shall be performed at + 10% of design affect the air flow rate. distribution within the system TVR 8.9.6.7 ------------------- NOTE --------------

Testing of activated carbon shall be performed in accordance with ASTM D3803-89 at conditions of 30 0 C and 95% RH.

Verify activated carbon in th arcoal filter - 18 months for filters in removal capability of 95 ' methyl( standby status iodine.

<c OR After 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of filter operation AND Following painting, fire, or chemical release in any ventilation zone communicating with the system TVR 8.9.6.8 Test R-13 and R-14. In accordance with the ODCM 8.9.6-4

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The requirement for the spent fuel pool sweep system, including charcoal adsorbers, to be operating when spent fuel movement is being made provides added assurance that the off-site doses will be within acceptable limits in the event of a fuel handling accident. The spent fuel pool sweep system is designed to sweep the atmosphere above the refueling pool and release to the Auxiliary Building vent during fuel handling operations. Normally, the charcoal adsorbers are bypassed, but for purification operation, the bypass dampers are closed routing the air flow through the charcoal adsorbers. If the dampers do not close tightly, bypass leakage could exist to negate the usefulness of the charcoal adsorber. If the spent fuel pool sweep system is found not to be operating, fuel handling within the Auxiliary Building will be terminated until the system can be restored to toperating condition.

The bypass dampers are integral to the filter:*si. The test of the bypass leakage around the charcoal ads rirs'Will include the leakage through these dampers.

High efficiency p i ulat absolute (HE*A* filters are installed before the charcoal a or prev cloagging of the iodine adsorbers.

The charcoat . r rs ar in stl,- reduce the potential radioiodine releases at nspherePypss leakage for the charcoal adsorb s, nd p' rticulat removal efficiency for HEPA filters are determih'*l ,d halogen \d hydrocarbon and DOP, respectively. The 1a toyaarbon saL-*i "est results indicate a radioactive methyl e oval c under test conditions which are more severe 4.ccident( .'.ns.

peratiopf fans significantly different from the design flow will ch a moval efficiency of the HEPA filters and charcoal ad orbe . If the performances are as specified, the calculated doses wou] less than the guidelines stated in 10 CFR Part 50.67 for the accidents analyzed.

The spent fuel pool sweep system will be operated for the first month after the reactor is shutdown for refueling during fuel handling and crane operations with loads over the pool. The potential consequences of a postulated fuel handling accident without the system are a very small fraction of the guidelines of 10 CFR Part 50.67 after one month decay of the spent fuel. Heavy loads greater than one fuel assembly are not allowed over the spent fuel. .

In-place testing procedures will be established utilizing applicable sections of ANSI N510 - 1975 standard as a procedural guideline only.

8.9.6-5

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND Although committing to ASTM D3803-89, it was recognized that ASTM (continued) D3803-89 Standard references Military Standards MIL-F-51068D, Filter, Particulate High Efficiency, Fire Resistant, and MIL-F-51079A, Filter, Medium Fire Resistant, High Efficiency. These specifications have been revised and the latest revisions are, MIL-F-51068F and MIL-F-51079D. These revisions have been canceled and superseded by ASME AG-1, Code on Nuclear Air and Gas Treatment. ASME AG-1 is an acceptable substitution. Consequently, other referenced standards can be substituted if the new standard or methodology is shown to provide equivalent or superior performance to those referenced in ASTM D3803-89.

In WPS letter of August 25,1976 to Mr. Al Schwe ¢er (NRC) from Mr. E. W. James, KPS relayed test results for floIs*¶ibution for tests performed in accordance with ANSI N510-197L-Thiýstandard refers to flow distribution tests performed upstrea r tefr ssemblies. Since the test results upstream of filters were inc si due to high degree of turbulence, tests for f~owdistribution r pe rmed downstream of filter assemblies with acptab results (withi ) The safety evaluation attached to Am d e 2 ref-,eces the station's letter of August 25, 1976 and acJd¶o'wj#.dts ac eX pt

)c* 'the test results.

TECHNICAL Pre osLt"ombined HEPA filters and charcoal VERIFICATION adt n, e! of water at the system design flow rate REQUIREMENTS fýe't Ra the filters and adsorbers are not clogged by sX'f foreign matter (reference 2). A test frequency of

<1 g cycle establishes system performance capability.

p is approximately 2 inches of water when filters are cle, The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Replacement adsorbent should be qualified according to the guidelines of Regulatory Guide 1.52 (Rev. 1) dated July 1976, except that ASTM D3803-89 standard will be used to fulfill the guidelines of Table 2, item 5, "Radioiodine removal efficiency." The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly, and obtaining at least two samples. Each sample should be at least 2 inches in diameter and a length equal to the thickness of the bed. The use of multi-sample assemblies for test samples is an acceptable alternate to mixing one bed for a sample. If the iodine removal efficiency test results are unacceptable, all adsorbent in the system should be replaced. Any HEPA filters found defective should be 8.9.6-6

KEWAUNEE POWER STATION TRM 8.9.6 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES TECHNICAL replaced with filters qualified pursuant to Regulatory Position C.3.d of VERIFICATION Regulatory Guide 1.52 (Rev. 1) dated July 1976.

REQUIREMENT (continued) If painting, fire, or chemical release occurs such that the charcoal adsorbers become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis should be performed as required for operational use.

Degradation of the HEPA filters due to painting, fire or chemical release in a communicating ventilation zone would be detected by an increased pressure drop across the filters. Should the filters become contaminated, engineering judgment would be used to determine if further leakage and/or efficiency testing was required.

Demonstration of the automatic initiation

.icap, yi necessary to assure system performance capability. I In-place testing procqdues will be e a is ed utilizing applicable sections of ANSI I10 -'),1975 standardsa procedural guideline only.

REFERENCES 8.9.6-7

KEWAUNEE POWER STATION TRM 8.3.7 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 16, 2012 8.3 INSTRUMENTATION 8.3.7 Explosive Gas Monitoring System TNC 8.3.7 The Waste Gas Analyzer (WGA) shall be FUNCTIONAL and aligned to monitor the in service Waste Gas Decay Tank (WGDT) such that its oxygen concentration does not exceed 4% by volume.

APPLICABILITY: Whenever a WGDT is in service.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES ESTORATION TIME V

A. WGA NonFUNCTIONAL. A.1 Take and analyze sampl ,s )nce per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from in service WGD---,J) during degassing of OR primary system (other than normal gas WGA not aligned to stripping of the in service WGDT. /K)letdown flow)

OR Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during normal power

_operation B. Oxygen concentration 1 Suspend additions of waste Immediately the in service WGDT gas to affected WGDT.

> 4% by volume.

AND B.2 Initiate action to reduce the Immediately oxygen concentration to

< 4% by volume.

8.3.7-1

KEWAUNEE POWER STATION TRM 8.3.7 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 16, 2012 TECHNICAL VERIFICATION REQUIREMENTS

NOTE ....

Test consists of an analysis of a known gas standard.

TVR 8.3.7.1 Perform FUNCTIONAL TEST on Waste Gas Analyzer.

standard.

TVR 8.3.7.2 8.3.7-2

KEWAUNEE POWER STATION TRM 8.3.7 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 16, 2012 BASES BACKGROUND The Explosive Gas Monitoring System utilizes an inline Waste Gas Analyzer (WGA) to monitor the in service Waste Gas Decay Tank (WGDT) on a continuous basis. Grab sample analysis of the in service WGDT can be accomplished by obtaining a sample locally from the in service gas decay tank or from a sample point located on the WGA.

Grab samples are analyzed with chemistry laboratory analytical equipment. If inline or grab sample analysis indicates an explosive mixture, actions will be taken to reduce the oxygen concentration as soon as possible.

The WGA provides a method for monitoring the concentrations of potentially explosive gas mixtures in the waste gas holdup system (Reference 5). An explosive gas mixture consists q a hydrogen gas concentration above the lower flammability limit of . \ ND an oxygen gas concentration above 4%. Technical Specifrti&V'5.5.10r tg01.5s1 requiresa program that provides controls for potential. l0 ive gas mixtures in the gaseous radioactive waste disposal ,t*m,* Reference 6).

The WGA has alarr ac Iabty that will alelTJperations personnel of oxygen concentra.r), a roach fan explosive mixture and is set to 2% oxygen byl-ehe 2s%-A'ýtpoint on the WGA is based on the 4% o) co-entratinrre d for flammability. This allows ed*i*

for a 1000 s ty argin irthe W*oint. The WGA alarms in the control roo ar is loca onitored at least daily. Laboratory analysis of a~r~sa#pe is Pe im periodically to confirm instrument ac&urazct * \\,

TNC and The hydr o'ofcentration inside an in service (aligned for fill) WGDT APPLICABILITY alwaysd4f) potential to exceed 4% by volume. Therefore, the WGA is requir_'td be FUNCTIONAL whenever a WGDT is in service.

A FUNCTIONAL-WGA serves-to alert operators of oxygen . .....

concentrations that could cause an explosive gas mixture (when oxygen is mixed with hydrogen). To prevent an explosive gas mixture, oxygen concentration inside the in service WGDT is not allowed to exceed 4% by volume. Operator action ensures that the concentration of potentially explosive gas mixtures contained in the waste gas holdup system is maintained below the flammability limits for hydrogen and oxygen. This will minimize the probability of a WGDT rupture, thus, minimizing the probability of an accidental radioactive gas release (Reference 7).

8.3.7-3

KEWAUNEE POWER STATION TRM 8.3.7 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 16, 2012 BASES TNC and The WGA is FUNCTIONAL when it is operating properly and capable APPLICABILITY of monitoring oxygen concentration. The WGA shall normally be (continued) aligned to the in service WGDT. The WGA can be temporarily aligned to monitor various points in the waste gas holdup system and remain FUNCTIONAL. The duration of any temporary alignment to other points in the waste gas holdup system is limited by the Restoration Time specified for Nonconformance A (which depends on plant operating condition).

CONTINGENCY A.1 MEASURES If the WGA is NonFUNCTIONAL, manual grab samples must be periodically obtained and analyzed from the in servIi(aligned for fill)

WGDT..N If a FUNCTIONAL WGA is not aligned to in ervice WGDT, either a grab sample must be btained or the qA"i~ligned to the normal configuration (such th0tthe~lp service WG [;is monitored at the same periodicity as for aI£ 4F*CTIO L WGA).

During norma yererati (%tLal, sampling from the in service WGDT is rAuired t 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months int /als (grab sample or realigning the WGA to no -7q/l This s ing interval is sufficient since there shouyfxbe no gnificant*x n content in the tank during normal ii primars tft4 degassing operations, more frequent qo pensato rkspling is required when the WGA is not NC I L"(or not aligned to the in service WGDT). This manual samplin

quired at 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months intervals when degassing of the primary system .s'h progress. Primary system degassing refers to the intentional removal of hydrogen from the reactor coolant system by either mechanical or chemical means and displacement with an alternate gas (e.g. nitrogen). Degassing does not include normal gas stripping of the letdown flow in the volume control tank (Reference 8).

B.1 and B.2 If oxygen concentration in the in service WGDT > 4% by volume, the potential for an explosive gas mixture exists. This condition requires both immediate action to suspend additions of waste gas to the affected WGDT and immediate initiation of action to reduce the oxygen concentration below 4% by volume. Another tank may be placed in service while the source of oxygen is located and eliminated (Reference 8).

8.3.7-4

KEWAUNEE POWER STATION TRM 8.3.7 TECHNICAL REQUIREMENTS MANUAL Revision 1 February 16, 2012 BASES TECHNICAL TVR 8.3.7.1 VERIFICATION REQUIREMENTS A FUNCTIONAL TEST on the WGA must be performed every 31 days to confirm instrument accuracy. This test consists of an analysis of a known gas standard to perform an accuracy check of the WGA.

TVR 8.3.7.2 A CHANNEL CALIBRATION must be performed every 92 days. The WGA is calibrated using a known oxygen and hydrogen calibration gas standard.

REFERENCES 1. Comtrak Commitment Number 85-052, losive Gas Mixtures (DCR 1638).

2. Letter from Carl W. r (WPSC)- Denton (NRC),

"Proposed Amen a.t 1. 66 to the K P Technical Specifications " adt*%arch %Jt18.

3. Comtrak nt Nu 6'6422, Item D, Analyze for Explosiy~9>as ixtures with tte Gas Holdup System.

jtlle (NRC) to D.C. Hintz (WPSC),

, JJy 29, 1985.5. USAR 11.1.2.3, Waste Orocessing.

5.5.10, Explosive Gas and Storage Tank I Program.

.1, Gas Decay Tank Rupture.

12, (Chemical and Volume Control System (CVCS),

Design and Operation.

8.3.7-5

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 8.7 PLANT SYSTEMS 8.7.5 Snubbers TNC 8.7.5 Each snubber listed in Table 8.7.5-1 shall be FUNCTIONAL.

APPLICABILITY: When the associated supported system is required to be OPERABLE.

CONTINGENCY MEASURES

NOTE-Separate entry is allowed for each snubber.

A. One or more required Immediately snubbers NonFUNCTIONAL.

'Verify st one train (or Immediately sub em f systems su by the INCTIONAL snubber(s) yldremain capable of

\erforming its required safety or support function for postulated design loads other than seismic loads.

8.7.5-1

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 CONTINGENCY MEASURES (continued)

NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. (continued) A.3.1 -------- NOTE ---------

Only applicable if LCO 3.0.8.a is used.

Verify at least one AFW train Immediately not associated with the NonFUNCTIONAL snubber is available.

OR Immediately B. CONTINGENC" i\& biý'clare supported system Immediately MEASURE A.2 ani YICO not met and enter associated Restoration> applicable Required Action.

Time not met.

C. CONTINGENCY C.1 Initiate action to restore Immediately MEASURE A.3 and associated snubber to a associated Restoration FUNCTIONAL status.

Time not met.

AND C.2 Initiate action to manage risk. Immediately 8.7.5-2

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.7.5.1 Perform snubber examination and testing in In accordance with the accordance with the Snubber Test Program. Snubber Test Program

%o0 8.7.5-3

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected AC-H68 Seismic Component Cooling TS 3.7.7 1, 2, 3, 4 Dual AC-H78 Seismic Reactor Coolant System TS 3.4.8 5 Dual Containment TS 3.6.1 1, 2, 3,4 ECCS TS 3.5.2 1,2,3 CS-H33A Seismic ECCS TS 3.5.3 4 Internal Containment Spray TS 3.6.6 1, 2, 3, 4 Containment TS 3.6.1 t1,, 4 ECCS TS 3.5.2 t2 I, 3 CS-H39 Seismic ECCS TS 3.5.! 123 Dual Internal Containment Spray TS,. 1,2,3,4 Containment TS3.6*"j 1,2,3,4 ECCS TS352 1,2,3 CVC-H84 Seismic ECCS ' ý?.5.3 4 Dual Intern onta entS6o~Zz1ýS3.6.6 1,2,3,4 E TS3.5.2 1,2,3 CVC-H96 Seismic EC TS 3.5.3 4 Dual CVC-CH4 ray TS 3.6.6 1, 2,3,4 CVC-H 143 -Seisr ntain TS 3.6.1 1, 2, 3,4 Dual CVC-H 161 Seisn r \ TS 3.6.1 1,2,3,4 Dual CVC-H 162 Seismic ý'j 4ment TS 3.6.1 1,2,3,4 Dual CVC-H 173 Seismic Containment TS 3.6.1 1,2,3,4 Dual CVC-H355 Seismic CVCS TRM 8.1.1 1,2,3,4,5,6 Dual CVC-H356 Seismic CVCS TRM 8.1.1 1,2,3,4,5,6 Dual CVC-H357 Seismic CVCS TRM 8.1.1 1,2,3,4,5,6 Dual CVC-H449 Seismic Containment TS 3.6.1 1,2,3,4 Dual CVC-H450 Seismic Containment TS 3.6.1 1,2,3,4 Dual 8.7.5-4

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Support Associated System(s) Associated Applicable Trains Snubber Loads TS/TRM MODES Affected Seismic Internal Containment Spray TS 3.6.6 1, 2, 3, 4 Single Dynamic Containment TS 3.6.1 1, 2, 3, 4 Seismic Internal Containment Spray TS 3.6.6 1, 2, 3, 4 ICS-H8 Dynamic Containment TS 3.6.1 1, 2,3,4 Single ICS-H9 Seismic Internal Containment Spray TS 3.6.6 1, 2, 3, 4 Single Dynamic Containment TS 3.6.1 1, 2, 3,4 Seismic Internal Containment Spray TS 3.6.6 4 ICS-H10 Dynamic Containment TS 3.6.1 12, 3, 4 Seismic Internal Containment Spray TS3,.61f1o 1, 2, 3, 4 Single ICS-H1 1 Dynamic Containment TS .69 1,2,3,4 Seismic r le y'aetedwnt Spra IAnut S Dynamic Con ent Coolin T 3.6.1 1, 2, 3, 4 AS-H121 Seismic Alf A meedwt TS 3.7.5 1, 2, 3, 4 Dual ooling TS .7. 1, 2,3, 4 MVS-H-129 Seismic , f y/i*ary Feeýa' TS 3.7.5 1, 2, 3,4 Dual RAC-H38 Seisi Comn ooling TS 3.7.7 1, 2, 3, 4 Dual Containment TS 3.6.1 1,2, 3,4 RA--3 Sesi C'Vyponent Cooling C TS 3.7.7 1, 2,3,4 Dua RAC-37 e~s~c ontainment TS 3.6.1 1, 2, 3,4 Da RAC-H38 Seismic Component Cooling TS 3.7.7 1, 2, 3, 4 Dual Containment TS 3.6.1 1, 2, 3, 4 RAC-H39 Seismic Component Cooling TS 3.7.7 1, 2, 3,4 Dual Containment TS 3.6.1 1, 2, 3,4 RAC-H5Sesmic Component Cooling TS 3.7.7 1, 2, 3,4 Da RC115 Simc Containment TS 3.6.1 1, 2,3,4 Dua 8.7.5-5

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected RAC-H76NE Seismic Component Cooling TS 3.7.7 1, 2, 3, 4 Dual Containment TS 3.6.1 1, 2, 3, 4 RAC-H76SE Seismic Component Cooling TS 3.7.7 1, 2, 3,4 Dual Containment TS 3.6.1 1, 2, 3, 4 Reactor Coolant System TS 3.4.4 1 2 Reactor Coolant System TS 3.4.5 3 RC-H29A Seismic Reactor Coolant System TS 3.4.6>ý4 Dual Reactor Coolant System TS 3.4.;.5 Reactor Coolant System TS13* _, 5 Reactor Coo n s m TS 3.4V 1,2 Reactor S I S em S.4.5 3 RC-H72 Seismic ReactK\(oo0 yste - 3.4.6 4 Dual Reor -lant Systerf7It TS 3.4.7 5 Rcroolant System TS 3.4.8 5

,~jea~tor Cool 0$ter+ TS 3.4.4 1, 2 actor C oa. ystem TS3.4.5 -3 --..

RC-H86 ./.s Reacto.&ol t System TS 3.4.6 4 Dual RCH6 esReacr t3olant System TS 3.4.7 5 R, }Coolant System TS 3.4.8 5

.4 nment TS 3.6.1 1, 2, 3,4 Reactor Coolant System TS 3.4.4 1,2 Reactor Coolant System TS 3.4.5 3 RC-H87 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3'4.7 5 Reactor Coolant System TS 3.4.8 5 Containment TS 3.6.1 1,2,3,4 8.7.5-6

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Reactor Coolant System TS 3.4.4- 1, 2 Reactor Coolant System TS 3.4.5 3 RCVC-H31A Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Reactor Coolant System TS 3.4.4 1 2 Reactor Coolant System TS 3.4.5 3 RCVC-H31B Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.

Reactor Coolant System TS 3A, 5 Reactor Coo n.nysttm TS 3.4y1* 1,2 Reactor

S"I em (*T\SA.4.5 3 RCVC-H32 Seismic Reactor8oorlV41yste 10 3'.4.6 4 Dual 2

Reat.or 9ant Syster* l//* TS 3.4.7 5 R!cr~oolantSystom V TS 3.4.8 5 j or 6 Cool te TS 3.4.4 1,2 actor C stem TS 3.4.5 3 RCVC-H33A Seis c "Reacto ** t System TS 3.4.6 4 Dual Reac ,r o ant System TS 3.4.7 5 R R C oolant System TS 3.4.8 5 4actor Coolant System TS 3.4.4 1,2 Reactor Coolant System TS 3.4.5 3 RCVC-H33B Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Reactor Coolant System TS 3.4.4 1,2 Reactor Coolant System TS 3.4.5 3 RCVC-H34 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 8.7.5-7

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TSITRM MODES Affected Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RCVC-H35 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System. TS 3.4.8 5 RCVC-H36 Seismic Containment TS 3.6.1 1 2, 3, 4 Dual RCVC-H186 Seismic Containment TS 3.6.1 k1 4 Dual RCVC-H191 Seismic Containment TS 1,2, 3,4 Dual RCVC-H245 Seismic. Containmen TS 3.6 1,2, 3, 4 Dual Resid ~eaf Imova, "~3.5.3 1, 2, 3 Resjaual Rt Removal , TS 3.5.4 4 Rtor Coolant S m TS 3.4.6 4

\ .eac Coolant *ys~ TS 3.4.7 5 RHR-H10H Seismic 'I.'tor Cool nSister" TS 3.4.8 5 Dual

. "<.,--/ efueling -'-* '* TS 3.9.3- - 6---- ..

Refuelini \j- TS 3.9.4 6 Contiqm nt TS 3.6.1 1,2,3,4 nIn(*erý'ontainment Spray TS 3.6.6 1, 2, 3,4 esidual Heat Removal TS 3.5.3 1, 2, 3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 Reactor Coolant System TS 3.4.7 5 RHR-H12A Seismic Reactor Coolant System TS 3.4.8 5 Dual Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3,4 Internal Containment Spray TS 3.6.6 1., 2, 3, 4 8.7.5-8

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Residual Heat Removal TS 3.5.3 1, 2, 3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 Reactor Coolant System TS 3.4.7 5 RHR-H12B Seismic Reactor Coolant System TS 3.4.8 5 Dual Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1N ,4 Internal Containment Spray TS 3.6.6 4 Residual Heat Removal TS 1,2,3 Residual Heat Ref~al TSjI5(; 4 Reactor Coolý t'yst\ m TS3 4 Reactor C(_f] )t em 0-Sj..4.7 5 RHR-H16A Seismic Reacto-. ooi4 yster (JQ-?.4.8 5 Dual Refing 7 TS3.9.3 6 R u TS 3.9.4 6 Con't",,fient TS 3.6.1 1,2,3,4

. "ýe al Cont ,t ray TS 3.6.6 1,2,3,4

-/Resi dualý e emoval TS 3.5.3 1, 2, 3 Resi <a _eat Removal TS 3.5.4 4 Rla-" Coolant System TS 3.4.6 4 Gcbr Coolant System TS 3.4.7 5 RHR-H21A Seismic *6ctor Coolant System TS 3.4.8 5 Dual Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3,4 Internal Containment Spray TS 3.6.6 1, 2, 3, 4 Residual Heat Removal TS 3.5.3 1, 2, 3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 RHR-H35A Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Internal Containment Spray TS 3.6.6 1, 2, 3, 4 8.7.5-9

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TSITRM MODES Affected Residual Heat Removal TS 3.5.3 1,2,3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 Reactor Coolant System TS 3.4.7 5 RHR-H36A Seismic Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Internal Containment Spray TS 3.6.6 lý,ý 3. 4 Residual Heat Removal 3 Residual Heat Removal 4 Reactor Coolant$ ten2 4 Reactor Cool n "\Cystnrr 5 RHR-H38A Seismic Reactor CoI 9.t S 'enr 5 Dual Refuelij 7T /// 6 6

1,2,3,4 1,2,3,4 esidual Ha Oval TS 3.5.3 1,2,-3

'ý--Residualea"Removal TS 3.5.4 4 Reatq.ro"ant System TS 3.4.6 4 alRCoolant

-. System TS 3.4.7 5 RHR-H41A Seissmic "et*1)tir Coolant System TS 3.4.8 5 Dual 4fueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3,4 Internal Containment Spray TS 3.6.6 1, 2, 3, 4 Residual Heat Removal TS 3.5.3 1, 2, 3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 Reactor Coolant System TS 3.4.7 5 RHR-H49 Seismic Reactor Coolant System TS 3.4.8 5 Dual Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3,4 Internal Containment Spray TS 3.6.6 1, 2, 3, 4 8.7.5-10

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Residual Heat Removal TS 3.5.3 1, 2, 3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 Reactor Coolant System TS 3.4.6 4 RRHR-H14 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 Refueling TS 3.9.4 N6 Containment TS 3.6. 2,3,4 Internal Containment Spray TS 3 1,2,3,4 Residual Hea o TS 3.5of&' 1,2,3 Residual F e*a (aYTS,.5.4 4 6

Reacto " ool. yste 4 .4 1, 2 Re/a!r ant Syste TS 3.4.5 3 Ret/O3oolant Syst m TS 3.4.6 4 RRHR-H15 Seismic Rea>'(oolant - TS 3.4.7 5 Dual e*n or Cool apl teit TS 3.4.8 5

._ fueling TS 3.9.3 6 Refuelin TS 3.9.4 6 Con n- TS 3.6.1 1,2,3,4 In aontainment Spray TS 3.6.6 1,2,3,4

sidual Heat Removal TS 3.5.3 1,2,3 Residual Heat Removal TS 3.5.4 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RRHR-H18 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3,4 8.7.5-11

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 Reactor Coolant System TS 3.4.6 4 RRHR-H55 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 12 ,4 Reactor Coolant System TS 3.4.

Reactor Coolant System TS3.. 2 Reactor Coolant System TS 3 Reactor Coolantem TS .4 RRHR-H57 Seismic Reactor Cool n:yst m TS 3. Dual Reactor Cm a I (jJ. Sf 4.8 5 Refueli $ >~ 9.3 6 Refueing TS 3.9.4 6 C jta ment TS 3.6.1 1, 2, 3, 4 a jci TS 3.5.2 1,2,3 aŽ/,fety lnje ' rQŽ TS53.5.3 4 Reactor Cpt System TS 3.4.4 1,2 Reaoro ant System TS 3.4.5 3 RSI-.5A Seismic R a r\Coolant System TS 3.4.6 4 Dual ReeMý r Coolant System TS 3.4.7 5 44actor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3,4 Safety Injection TS 3.5.2 1,2,3 Safety Injection TS 3.5.3 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H2 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 8.7.5-12

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Support Associated System(s) Associated Applicable Trains Snubber Loads TS/TRM MODES Affected Safety Injection TS 3.5.2 1,2,3 Safety Injection TS 3.5.3 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H2A Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6'ý Refueling TS 3.9.4 6V Containment TS 3.6._.1 1,2, 3, 4 Safety Injection -. \ TS3.51,21 1, 2, 3 Safety lnjection TS 3.5.3 4 Reactor CoolaOt SPm 11/4TS 3.4.4 1, 2 Reactor'Coola.tystemi T,,S 3.4.5 3 RSI-H38 Seismic Ar,< Coolant System",

Reactor TS 3.4.6 4 Dual Re ct6' Coolant System TS 3.4.7 5

~React'prfCoolant 'System TS 3.4.8 5

/ efueling \

TS 3.9.3 6 Refueling /,. TS 3.9.4 6

*Containment< TS 3.6.1 1, 2, 3, 4 Safety nInjection TS 3.5.2 1,2,3 Safety injection TS 3.5.3 4 Ractor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H59 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 8.7.5-13

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Support Associated System(s) Associated Applicable Trains Snubber Loads TSITRM MODES Affected Safety Injection TS 3.5.2 1,2,3 Safety Injection TS 3.5.3 4 Reactor Coolant System TS 3.4-4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H61 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 63 Refueling TS 3.9.4 6, Containment TS 3.6y1.* 1,2,3,4 Safety Injection A TS3.5*2' 1, 2,3 Safety Injectiron' ) TS 3.5 3 4 Reactor Coolant S -semf,-*S ,*.4.4 1, 2 ReactotCoolantSystemr ': TS 3.4.5 3 RSI-H63 ^..

Seismic Reactor\'

/ C ant SysteA ...

TS 3.4.6 3.4Dual 4 React.r Coolant System TS 3.4.7 5 Reactor' oolant S-yste.m TS 3.4.8 5 k> .Reffuling ,#&\ TS 3.9.3 6

< Refueling % TS 3.9.4 6

',tContainment TS 3.6.1 1,2, 3, 4 Safety injection TS 3.5.2 1,2,3 Safety Injection TS 3.5.3 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H67 Seismic Reactor Coolant System TS 3.4.6 4Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.93 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 8.7.5-14

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Safety Injection TS 3.5.2 1,2,3 Safety Injection TS 35.3 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H78 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6C Refueling TS 3.9.4 ', 6 Containment TS 3.6.1, -, 1,32,3,4 Safety Injection//Z TS 3.51,2 1,2,3 Safety InjectionK,%ri TS 3.5.3, 4 Reactor Cob anSystem -,,TS34.4 1,2 Reactr Coolant gystem:z T 3.4.5 4 RSI-H83 Seismic R o a SysteA Dual Rectdr Coolant System TS 3.4.7 5 ReactorCoolant S/tem TS 3.4.8 5 Refu'eling -5 TS 3.9.3 6 S~Refueling d TS 3.9.4 6 TC~onta nmienk'/ TTS 3.6.1 1,2,3,4 Safe*

N jection TS 3.5.2 1,2, 3 "Sa*fýtInjection TS 3.5.3 4 R'eactor Coolant System TS 3.4.6 4 RSI-H94 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 Safety Injection TS 3.5.2 1,2,3 Safety Injection TS 3.5.3 4 Reactor Coolant System TS 3.4.6 4 RSI-H95 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 8.7.5-15

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Safety Injection TS 3.5.2 1,2,3 Safety Injection TS 3.5.3 4 Reactor Coolant System TS 3.4.6 4 RSI-H96 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1{ 2, 3 4 Safety Injection TS 3.5.2z1,, 2, 3 Safety Injection TS 35.53, 4 T S.. ..t ' 4 Reactor CoolantSYstem RSI-H97W Seismic Reactor Reco CoolariitSystim

- R*** t// TS 3.4VT7

. 8 55Dual Reactor CGO6an~t S~' (),TS,3.4.8 5 Refueling " ,e .- "S 3.9.3 6 Refueling r TS 3.9.4 6 Contaifment TS 3.6.1 1, 2, 3,4

-: Safety Injection>!" TS 3.5.3 1,2,3 Safety Injection,, TS 3.5.4 4 Riaeactor Coolant System TS 3.4.6 4 RS. H975React6CoI1nt System TS 3.4.7 Dual S elSmlC Re'bto'rCoolant System TS 3.4.8 5 effieling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 Safety Injection TS 3.5.3 1,2,3 Safety Injection TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 RSI-H98 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 8.7.5-16

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TSITRM MODES Affected Safety Injection TS 3.5.3 1,2,3 Safety Injection TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 RSI-H99 Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1.i2 3, 4 Safety Injection TS 3 .5 . 3 N 1%2, 3 Safety Injection TS 3--.t3'3 4 Reactor CoolanSysteem TS r -- 1, 2 Reactor Cool,nt>yst m TS 3.4e 3 Reactor Coolapt S TS*.4.6 4 RSI-H100 Seismic R /-oo/,yt--> 4-.7 Dual Reactor, Cool4VnSystem;=,C. *TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 R -ielhng 4

TS 3.9.3 6 Refu6l$ei TS 3.9.4 6 ontinment -< TS 3.6.1 1,2,3,4 Szafety In ction TS 3.5.3 1,2,3 Safety(WJedtion TS 3.5.4 4 ReatrCoolant System TS 3.4.4 1,2 Reqt~or Coolant System TS 3.4.5 3 RSI-H 101 Seismic Jeactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Containment TS 3.6.1 1, 2, 3, 4 8.7.5-17

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Sbb Support Associated System(s) Associated Applicable Trains nuer Loads TS/TRM MODES Affected Safety Injection TS 3.5.3 1,2,3 Safety Injection TS 3.5.4 4 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RSI-H-1102 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 63A Refueling TS 3.9.4 K 6, Containment TS 3.61. z. " 1*,1 2, 3, 4 Reactor Coolant.stem T 1,Q2 Reactor Coolti-Syst m TS 3.4l5 3 RTD-H2 Seismic Reactor Colapt Stem ( 1yJS 3.4.6 4 Dual Reactor-Cooa0' Sysem~kj 15,,3.4.7 5 Reactor Coant System TS 3.4.8 5 Rea-t*or'oolant Syistem TS 3.4.4 1, 2 NReacftor CoolantSystem TS 3.4.5 3 RTD-H-16 Seismic Reactor Co, Ant System TS 3.4.6 4 Dual Reac.kr Cpefant System TS 3.4.8 5 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RTD-H8 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 Reactor Coolant System TS 3.4.4 1, 2 Reactor Coolant System TS 3.4.5 3 RTD-H 11 Seismic Reactor Coolant System TS 3.4.6 4 Dual Reactor Coolant System TS 3.4.7 5 Reactor Coolant System TS 3.4.8 5 SGB-H189 Seismic Auxiliary Feedwater TS 3.7.5 1,2, 3 Dual 8.7.5-18

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Snubber Support Associated System(s) Associated Applicable Trains Loads TS/TRM MODES Affected Safety Injection TS 3.5.3 1,2,3 Safety Injection TS 3.5.4 4 Reactor Coolant System TS 3.4.6 4 SI-H6D Seismic Reactor Coolant System TS 3.4.7 5 Dual Reactor Coolant System TS 3.4.8 5 Refueling TS 3.9.3 6 Refueling TS 3.9.4 6 Internal Containment Spray TS 3.6.6 1 2\3, 4 Safety Injection TS 3.5.,- -,,2,3 St-H35 Seismic Safety Injection TS 3,5.,4 4 Dual Containment TS *.61* 1,2,3,4 Auxiliary Fe d<atSr TS,3.7.5 1,2,3 SS-H67 Seismic ReactoCoo* Syste

S a.4.4 1,2 Dual Reactor Coolant Systernii TS 3.4.5 3

<Auxilihaj Feedwat . TS 3.7.5 1,2, 3 SS-H73 Seismic / Rea6tor CoolantýSystem TS 3.4.4 1, 2 Dual

-' Reactor Coolant*ystem TS 3.4.5 3 Auxilia*6Reedwater TS 3.7.5 1, 2, 3 SS-H76 Seismi *RetgrCoolant System TS 3.4.4 1, 2 Dual Reai*ctor Coolant System TS 3.4.5 3 Auxiliary Feedwater TS 3.7.5 1, 2, 3 SS-H86 Seismic Reactor Coolant System TS 3.4.4 1,2 Dual Reactor Coolant System TS 3.4.5 3 Auxiliary Feedwater TS 3.7.5 1,2, 3 SS-H87 Seismic Reactor Coolant System TS 3.4.4 1, 2 Dual Reactor Coolant System TS 3.4.5 3 Auxiliary Feedwater TS 3.7.5 1, 2, 3 SS-H88 Seismic Reactor Coolant System TS 3.4.4 1, 2 Dual Reactor Coolant System TS 3.4.5 3 8.7.5-19

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 Table 8.7.5-1 Snubbers Support Associated System(s) Associated Applicable Trains Snubber Loads TS/TRM MODES Affected Auxiliary Feedwater TS 3.7.5 1, 2, 3 SS-H 103 Seismic Reactor Coolant System TS 3.4.4 1, 2 Dual Reactor Coolant System TS 3.4.5 3 Auxiliary Feedwater TS 3.7.5 1, 2, 3 SS-H 129 Seismic Reactor Coolant System TS 3.4.4 1, 2 Dual Reactor Coolant System TS 3.4.5 3 Auxiliary Feedwater TS 3.7.5 \i, SS-H 146 Seismic Reactor Coolant System TS 3.4.4 *'12 Dual Reactor Coolant System TS *;3,45 . 3 Auxiliary Feedwater") TS 3.7-5 1, 2, 3 SS-H150 Seismic Reactor Coolafft S tem Q TS3.4.4 1, 2 Dual Reactor* nSystemr f *,TS 3".4.5 3 A6.' Feedwater TS 3.7.5 1,2,3 SS-H156 Seismic <NReaco'6Coolants(stem TS 3.4.4 1, 2 Dual lkeag6or CoolaitSysterA TS 3.4.5 3 SW-H401 Seismic 'Service Water' TS 3.7.8 1, 2, 3, 4 Dual 8.7.5-20

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES BACKGROUND Shock suppressors (snubbers) are designed to prevent unrestrained pipe motion under dynamic loads, as might occur during seismic activity or severe plant transients, while allowing normal thermal motion during startup or shutdown. The consequence of a NonFUNCTIONAL snubber is an increase in the probability of structural damage to piping as a result of a seismic event or other events initiating dynamic loads.

It is therefore required that all snubbers designed to protect the reactor coolant and other safety-related systems or components be FUNCTIONAL during reactor operation. The intent of TRM 8.7.5 is to restrict reactor operation with defective safety-related shock suppressors.

The requirements for snubbers were relocated fr m the previous Custom Technical Specification (TS) 3.14, "Shock$Suppressors (Snubbers)", during the conversion to Improved TS' (Reference 1).

TRM 8.7.5 also specifies the snubbers applic ble to TS LCO 3.0.8, which establishes conditions under whi6h sy-tems are considered to remain capable of performing their intenlded safety function when associated snubbers are'not capable of providing their associated support function(sý).,<

A, LCO 3.0,.8 was'developed in 1STF-372, Revision 4, "Addition of LCO 3.0.8, Inoperability of SnUbbers" (Reference 2). TSTF-372 documents s -o!rmed analysis iof*NonFUNCTIONAL snubbers. The NRC

.issue&,arodel saf ty'levalidation (Reference 3) providing their acceptance of TST-I372 with the associated analysis. Probabilistic risk S4ýassessment(PýA`) results and insights were used, in combination with

-- deterministic ad defense-in-depth arguments, to identify and justify delay tirhmes\for entering the actions for the supported equipment assýdciatý'dlwith NonFUNCTIONAL snubbers at nuclear power plants.

This isnh accordance with guidance provided in Regulatory Guides (RGs) 1.174 and 1.177. The risk impact associated with the proposed delay times for entering the TS actions for the supported equipment can be assessed using the same approach as for allowed completion time (CT) extensions. Therefore, the risk assessment was performed following the three-tiered approach recommended in RG 1.177 for evaluating proposed extensions in currently allowed completion times.

The first tier involves the assessment of the change in plant risk due to a NonFUNCTIONAL snubber. Such risk change is expressed by:

(1) the change in the average yearly core damage frequency (ACDF) and the average yearly large early release frequency (ALERF); and, (2) the incremental conditional core damage probability (ICCDP) and the incremental conditional large early release probability (ICLERP).

8.7.5-21

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES BACKGROUND The assessed ACDF and ALERF values are compared to acceptance (continued) guidelines, consistent with the Commission's Safety Goal Policy Statement as documented in RG 1.174, so that the plant's average baseline risk is maintained within a minimal range. The assessed ICCDP and.ICLERP values are compared to acceptance guidelines provided in RG 1.177, which aim at ensuring that the plant risk does not increase unacceptably during the period the equipment is taken out of service.

This assessment was used to determine the delay times contained in TS LCO 3.0.8 for TSTF-372. Due to the low seismic activity at KPS, the LCO 3.0.8.b completion time was increased from the value listed in TSTF-372.

The second tier involves the identification of potentially high-risk configurations that could exist if equipment in addition to that associated with the change were to be taken out of service simultaneously, or other risk-significayit operational factors such as concurrent equipment testing were alsoignblved. The objective is to ensure that appropri astestrictios are in place to avoid any potential high-risk conBuratbons. ;

This assessment was used to determine the contingency measures in TSTF-372 *Nhich are contain,6d in TRM 8.7.5.

lThe tliirdtiber involves the establishment of an overall configuration risk management program (CRMP) to ensure that potentially risk-significant configurations*:,r~esIting from maintenance and other operational

.'ctivities ae'id1endtified. The objective of the CRMP is to manage

-4configurdtitonspecific risk by appropriate scheduling of plant activities andf7\r'aropriate compensatory measures. This activity is met by implementation of the Maintenance Rule (Reference 4).

The accident sequences contributing to the risk increase associated with NonFUNCTIONAL snubbers are assumed to be initiated by a seismically induced loss of offsite power (LOOP) event with concurrent loss of all safety system trains supported by the out of service snubbers. In the case of snubbers associated with more than one train (or subsystem) of the same system, it is assumed that all affected trains (or subsystems) of the supported system are failed.

8.7.5-22

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES BACKGROUND The risk impact associated with non-LOOP accident sequences (e.g.,

(continued) seismically initiated loss of coolant accident (LOCA) or anticipated transient without scram (ATWS) sequences) was not assessed.

However, this risk impact is small compared to the risk impact associated with the LOOP accident sequences modeled in the simplified bounding risk assessment. Therefore, the risk impact of NonFUNCTIONAL snubbers associated with non-LOOP accident sequences is small compared to the risk impact associated with the LOOP accident sequences.

The second tier of the three-tiered approach recommended in RG 1.177 involves the identification of potentially high risk configurations that could exist if equipment in addition to that associated with the NonFUNCTIONAL snubbers were to be taken out<f.service simultaneously. Insights from the risk assesstments, in conjunction with important assumptions made in the analysis anddefen:-dpth considerations, were used to identify such: c 'figurations. To avoid these potentially hig*rormst configuratn,* specific restrictions on operation with No F*NCUTIONAL snubbýrfs were identified. TRM 8.7.5 is based on thes'e Tierierestritns.

7/ \ V" * "

TNC and To ensurE)supported

' system OPERABILITY, each snubber listed in APPLICABILITY Table 8.7'.51&is required~re be FUNCTIONAL whenever the associated sup e~> system js required to be OPERABLE. Ifa supported system not rIuired to b*`OP1ERABLE (e.g., outside the TS MODE of

':kApp~ability forlht system), then its associated snubber is not a required snub"er during the period that the supported system is not

.required,to be OPERABLE. For consistency, those snubbers listed in Table &7.5,- 1"that are only associated with a TRM system (e.g., CVCS),

are treateed within the scope of TRM 8.7.5 applicability (i.e., the terms FUNCTIONAL and OPERABLE for these supported TRM systems are treated synonymously for purposes of TRM 8.7.5 compliance).

TRM Table 8.7.5-1 provides a listing of "required snubbers" within the application of LCO 3.0.8. LCO 3.0.8 does not apply to non-seismic snubbers. This table also lists the TS LCOs that are potentially affected by the FUNCTIONALITY of the listed snubbers. Although this table lists the potentially affected TS LCOs, the actual LCOs affected must be confirmed whenever the applicable specified period of LCO 3.0.8 is exceeded. Compliance with the CONTINGENCY MEASURES required by TNC 8.7.5 ensures that the risk associated with NonFUNCTIONAL "required snubbers" is "assessed and managed" as required by LCO 3.0.8.

8.7.5-23

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES TNC and The list in Table 8.7.5-1 contains those snubbers from the Snubber APPLICABILITY Test Program that are identified as safety related (QA Type 1). For (continued) each listed snubber, Table 8.7.5-1 identifies the type of load support provided by the snubber (seismic or dynamic), systems associated with that snubber, associated TS/TRM section, applicable MODE, and whether the snubber affects a single train or dual trains.

In determining the identified information, the snubbers were located on the associated isometric drawing listed on the snubber table found in the Snubber Test Program. The location was then identified on the related analytical part flow drawing (e.g., snubber RTD-H1 1 was located on M-1461 and APX-100-10). From this information, the boundaries of the analytical part were determined and affected systems identified. A system was determined to be relate`6'if, for a listed Non-FUNCTIONAL snubber, no means of isolatin,'the ssociated analytical part (i.e., isolated by a component that was-out~ide the analytical part boundary) from the interconnected sy ste'm M's found. Once the affected systems werezidentified, the polkblie TS and MODES were determined. Onlyjiternai containment (ICS) containment we,,Ae f'Un.o provide dynamic support in addition to seismic supp0rt (efehrence 5 A snub r is F NCTIONAL vhe~n it is capable of performing its specified esign functiont.

(.\ \/ <,

$n ubb~e~rsare cla~$ifiel as component standard supports, which are designed to transmitA oads from the pressure-retaining boundary of the

-sys9em compone"rt to the building structure. However, they require

,special consideration due to their unique function. Snubbers are designecitop rovide no transmission of force during normal plant operations. Rather, they function as a rigid support only when subjeýc4d to dynamic transient loadings. Snubbers are chosen in lieu of rigid supports where restricting thermal growth during normal operation would induce excessive stresses in the piping nozzles or other equipment. The location and size of the snubbers are determined by stress analysis. Depending on the design classification of the particular piping, different combinations of load conditions are established. These conditions combine loading during normal operation, seismic loading and loading due to plant accidents and transients to four different loading sets. These loading sets are designated as: normal, upset, emergency, and faulted conditions. The actual loading included in each of the four conditions depends on the design classification of the piping. These design requirements establish snubber FUNCTIONALITY criteria.

8.7.5-24

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES CONTINGENCY The CONTINGENCY MEASURES are modified by a Note that allows a MEASURES separate CONTINGENCY MEASURE entry for each NonFUNCTIONAL snubber. This is acceptable because the CONTINGENCY MEASURE for each Nonconformance provides appropriate compensatory actions for each NonFUNCTIONAL snubber.

A.1 TS LCO 3.0.2 and LCO'3.0.6 generally require immediate entry into the supported system Conditions and Required Actions when a snubber is found or made NonFUNCTIONAL. The only exceptions are:

1) Immediate entry may be delayed per LCO 3.0.8; or,

2) The supported system has been analyzedgndid determined to be OPERABLE without the snubber.,-

Whenever a requiredsnubber is founde-r -made NonFUNCTIONAL, compliance requirementswith LC..3. 0M8 must

°fo-'W31v be evalu*ated

-andtCO immediately.

3.0.6 are applicable The to this evaluation. I/fheo uported systiem hias been analyzed and determined to be OPERABLEwijhout rIi~ince on the snubber, then the snubber can be considered as not requir6d and LCO 3.0.8 remains satisfied.

TS 9CO 3.0;8.a applihsWen one or more snubbers are not capable of prowdingOheir assopikted support function(s) to a single train or

.ubsytstem of a<(u1#iple train or subsystem supported system or to a

.0singe train orasubsystem supported system. LCO 3.0.8.a allows 72

,hours to restore the snubber(s) before declaring the supported system inoperablil.,

The 7,_ýhour allowance in LCO 3.0.8.a is based, in part, on the availali'lity of the redundant train of the supported system (for multiple train systems) and on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function. This allowance is also applicable to snubbers associated with single train or subsystem supported systems because such single train systems are not required to have a redundant system.

TS LCO 3.0.8.b applies when one or more snubbers are not capable of

.providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system.

LCO 3.0.8.b allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the snubber(s) before declaring the supported system inoperable.

8.7.5-25

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES CONTINGENCY LCO 3.0.8 requires that risk be assessed and managed when one or MEASURES more snubbers are NonFUNCTIONAL, which may include (continued) compensatory measures for NonFUNCTIONAL snubbers. This is met by assessing and managing the risk in accordance with the Maintenance Rule Program (Reference 4). Additional information on this requirement is contained in the LCO 3.0.8 Bases.

A.2 The risk impact of dynamic loadings other than seismic loads was not assessed in the development of the delay times in LCO 3.0.8. These shock-type (non-seismic) loads include thrust loads, blowdown loads, water hammer loads, steam hammer loads, LOCA loads and pipe rupture loads. In general, the risk impact of the d6t-of-service snubbers is smaller for non-seismic loads than for seisrmic IaLs. Since dynamic loading was not generically assessed for'justifyihg LCO delay times, a specific assessment is required to be peformed to determine appropriate system capability based Qn equipmnent that may be out of service for maintenoncer due to failure4t<

Therefore, whnever*he provi nofLCO 3.0.8 are used, an engineerinassessment must'iminediately be initiated to show that at least one ~1in (or subsystem)of each system that is supported by the NonFUNCTIONAL snulbber(s) would remain capable of performing its required afety or suppor6functions for postulated design loads other

/ttihnj seismic loads. PThis verification must be documented (typically in

,,,operator logs). *. F'

'Atrain (or subsystem) that is supported by a NonFUNCTIONAL snubbe)tf at\does not provide dynamic support (as stated in the Supoqrt~loads" column of Table 8.7.5-1) would remain capable of perforqning its required safety or support function for postulated design loads other than seismic loads (provided it is otherwise capable of performing its required function). This means that a NonFUNCTIONAL snubber that is listed in Table 8.7.5-1 as only providing seismic support (in the "Support Loads" column) remains capable of performing its required support function for purposes of satisfying CONTINGENCY MEASURE A.2.

Conversely, a system supported by a snubber that provides dynamic support would not meet the capability requirement of CONTINGENCY MEASURE A.2 for the train supported by that snubber.

8&7.5-26

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES CONTINGENCY A.3.1 MEASURES (continued) For cases where all NonFUNCTIONAL snubbers are associated with only one train (or subsystem) of multiple train systems (i.e., when LCO 3.0.8.a applies), the analysis assumes that there will be unaffected redundant trains (or subsystems) available to mitigate the seismically initiated LOOP accident sequences (single train systems are not required to have a redundant system). To prevent potentially high risk configurations in this condition, a restriction was established to require at least one AFW train that is not associated with the NonFUNCTIONAL snubber(s).

Thus, when LCO 3.0.8.a is used, at least one AFW train (including a minimum set of supporting equipment required for.its successful operation) not associated with the NonFUNCTIONIAL snubber(s), must be available. N \*

A.3.2 For cases wherA~onatoriore of.the NonFUNCTIONAL snubbers are associated with mutiple tra.ns*,,f subsystems) of the same safety system (i.el, hen 0CO 3.i 8Nb aa'Plies), the bounding analysis assumes that all>safety systeng are unavailable to mitigate the seismic6lly initiated LOOP accident sequences. Credit is taken for usi gfeedaid bleed (F&,B) to provide core cooling when a snubber

\iAM.pacting more ftlaone train of the AFW system is NonFUNCTIONAL.

<*T6, prNvent hotetihigh risk configurations in this condition, a Sresmtrctio wa~e lished to require either, at least one AFW train that is not associatd-with the NonFUNCTIONAL snubber(s); or, an alternate' ans of core cooling.

Thus,,.hen LCO 3.0.8.b is used, one of the following two requirements must be met to mitigate a seismically initiated loss of offsite power (LOOP) accident:

1) At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the NonFUNCTIONAL snubber(s); or,

2) An alternative means of core cooling (e.g., feed and bleed, fire water system or "aggressive secondary cooldown" using the steam generators) must be available.

8.7.5-27

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES CONTINGENCY B.1 MEASURES (continued) CONTINGENCY MEASURE A.2 requires verification that at least one train (or subsystem) supported by the NonFUNCTIONAL snubber would remain capable of-performing its required safety or support function for postulated design loads other than seismic loads. If this requirement is not satisfied, then LCO 3.0.8 cannot be used to delay performing the Required Actions of the supported system LCO. In this case; the support system LCO is not. met ahd the applicable Required Action must be entered immediately in accordance with LCO 3.0.2 and 3.0.6.

C.1 and C.2 CONTINGENCY MEASURE A.3 (i.e., A.3.1 9A.3.2) requires verification of a means of providing core coolin'g.independent of the components directly supported by the NoniFUNCTIONAL snubber (either AFW or some alternate meant) if'another means of provid ng core cooling cannot be identified or becomes unavailable, the risk must be assessed andmahaged in accordance with the Maintenance Rule Program (Reference .4) as deýcibedin LCO 3.0.8 basis.

TECHNICAL TVR 8 7,54 VERIFICATION s fetyre,-ted REQUIREMENTS AilsafetyK\ elated hydrauhlishock suppressors are visually inspected for

<overal integrity~aficljEtuNCTIONALITY. The inspection will include evfifc/ation ofrproper orientation, adequate hydraulic fluid level and proper attad iQrni of snubber to piping and structures.

TheInspedtion frequency is based upon maintaining a constant level of snubbeY protection. Thus the required inspection interval varies with the obs'erved snubber failures. The number of NonFUNCTIONAL snubbers found during a required inspection determines the time interval for the next required inspection.

Experience at operating facilities has shown that the surveillance program should assure an acceptable level of snubber performance provided that the seal materials are compatible with the operating environment.

8.7.5-28

KEWAUNEE POWER STATION TRM 8.7.5 TECHNICAL REQUIREMENTS MANUAL Revision 1 December 10, 2012 BASES TECHNICAL To further increase the assurance of snubber reliability, FUNCTIONAL VERIFICATION tests are performed in accordance with sampling plans. These tests REQUIREMENTS include stroking of the snubbers to verify proper piston movement and (continued) snubbing action. Ten percent of the safety-related snubbers represents an adequate sample for such tests. Observed failures on these samples require testing of additional units.

REFERENCES 1. Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 207 to Facility Operating License No.

DPR-43, Dominion Energy Kewaunee, Inc., Kewaunee Power Station, Docket No. 50-305, dated February 2, 2011.

2. TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers,"

Revision 4.

3. Federal Register Notice, 70 FR 2325Kd.adt*i May 4, 2005.

4. 10 CFR 50.65(a)(4), "Requirementsfor Monitoring the Effectiveness of Maintenance atANuclear Powe6Plants.`

5. USAR Section, 62.2,23, Protection Against Dynamic Effects.

8.7.5-29

KEWAUNEE POWER STATION TRM 8.7.7 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 8.7 PLANT SYSTEMS 8.7.7 Flooding Protection - Circulating Water Pump Trip Circuitry TNC 8.7.7 Two trains of circulating water pump trip circuitry shall be FUNCTIONAL.

APPLICABILITY: Whenever the circulating water system is in operation.

CONTINGENCY MEASURES

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

Separate Nonconformance entry is allowed for each circulating water pump train.

NONCONFORMANCE CONTINGENCY MEASURE ,ESTORATION TIME A. One channel of A.1 nnel in the tri 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months trip circuitrywater circulating pump per train -%9 NonFUNCTIONAL. C Dec** e afected train of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months CirinjWater pump trip c NonFUNCTIONAL.

Restore to FUNCTIONAL 90 days status.

B. Two or more channels of B.1 Declare the affected train of Immediately circulating water pump Circulating Water pump trip trip circuitry per train circuitry NonFUNCTIONAL.

NonFUNCTIONAL.

AND B.2 Restore to FUNCTIONAL 90 days status.

8.7.7-1

KEWAUNEE POWER STATION TRM 8.7.7 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 CONTINGENCY MEASURES 8.717-2

KEWAUNEE POWER STATION TRM 8.7.7 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES BACKGROUND The Circulating Water (CW) pump trip function is to provide a trip to both CW pump breakers whenever evidence of significant flooding in the Turbine Building (TB) basement could potentially impact operation of the emergency diesel generators, associated safety-related buses and motor control centers, and the auxiliary feedwater pumps and associated circuitry located in safeguards alley.

The detection, actuation, and logic circuitry used to actuate the CW Pump breaker trips, is designed and installed as non-safety-related, but with many attributes of a safety-related design such as redundancy, diversity, and separation. The outputs from the logic circuits and supplemental outputs from the actuation circuits will be used to electrically trip the CW pump breakers "dlindicate alarms to the operators. A supplemental alarm, inc.r"etector and associated circuitry, is installed to provi¶ eArly warning to the operators of potential flooding in th e s ment.

The design usest* in pendent trfainf detection, actuation, and logic circ ha ill de flooding on the TB basement in the vicinityth h oi1 2 out of 3 logic matrix outputs ,t6- roio CW prn c rcuit breakers. Additionally, any single et tor"ctuatiol or I ic matrix actuation will be alarmed in the Con 1olom to te~ the operators of the abnormal condition.

P B base igi water level (flooding) detectors are

- ts.

for Un de s Laboratories (UL) hazardous locations, are "eatherprf explosion proof, and have a leak proof lower ody and' n dependent waterproof conduit seal. They can Vwitt to 350 psig, can handle a minimum liquid specific gra. 6t0.7; and have temperature limits of -4cF to +220'F.

Thu , eir application to detect a water level due to flooding is assured. The float switch weighs approximately one pound. It is also sensitive to level changes of less than one-half inch.

Each of the three actuation relays (per train) will actuate an individual SER point to indicate to the operators that an individual actuation switch has tripped and associated actuation relay has energized. Thus, indication of a single switch actuation will be available to determine if the actuation occurred in the northwest (NW), north (N), or northeast (NE) section along the TB basement north wall. All six actuation relay SERs alarm the same annunciator window.

8.7.7-3

KEWAUNEE POWER STATION TRM 8.7.7 TECHNICAL REQUIREMENTS MANUAL Revision 0 February 12, 2011 BASES TNC and The CW trip consists of two trains of trip function, each with three APPLICABILITY channels. Each train requires a minimum of two channels to be FUNCTIONAL as long as the NonFUNCTIONAL channel is placed in the tripped position within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This allows the remaining 2 channels to function as a 1 out of 2 trip function to trip the pumps.

If two or more channels are NonFUNCTIONAL, the train is considered NonFUNCTIONAL.

Based on Probabilistic Risk Assessment (PRA) application (reference 1) and consistent with Regulatory Guide 1.177, one train can be NonFUNCTIONAL for up to 90 days and both trains can be NonFUNCTIONAL for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The core damage frequency for flooding from the CW System intqthe turbine building with one train inoperable is 1.92 x 10-7ý'e I". and 4.76 x 10 5/year for both trains inoperable. *4ie mr6 damage frequency results with one train NonFU 'O L equates to 990 days of NonFUNCTIONALITY potentia nd2 hours of NonFUNCTIONALl otential for t tr 's NonFUNCTIONAL.

If the train COh I CY SURE cannot.be met, the plant will begin to,5)D h wit*i r nd achieve MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months an /191"Z withi _rat

' 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The CW pumps will then bte~nov from qpera, within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of entering MODE

3. '/"

t.

K.

TECHNICAL VERIFICATION <

REQUIREMENT i)jn trip will require testing each refueling cycle to assý Itffunction as expected. This frequency is consistent with systems of similar or higher safety significance.

REFERENCES 1. PRA Application # 05-16 dated May 13, 2005.

8.7.7-4

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 8.8 ELECTRICAL SYSTEMS 8.8.3 Emergency Diesel Generator (EDG) Ventilation Damper Control Air Supply TNC 8.8.3 EDG ventilation damper control air supply shall be FUNCTIONAL with the following provisions:

a. Two compressed air cylinders aligned to the damper controllers;

b. Pressure in each required air cylinder and air leakage downstream of isolation check valve shall be maintained within limits specified in Figure 8.8.3-1.

APPLICABILITY: Whenever the associated EDG is required to be OPERABLE.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. Ventilation damper A.1 Evaluate OPERABILITY of Immediately control air supply on affected EDG per Technical EDG NonFUNCTIONAL Specification 3.8.2.

for reasons other than Nonconformance B or C.

B. Requirements of TNC B.1 Restore parameter(s) to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 8.8.3.b not met on EDG. within limits.

AND B.2 Evaluate OPERABILITY of Immediately affected EDG per Technical Specification 3.8.2.

8.8.3-1

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME C. Pressure < 1800 psig in C.1 Restore air cylinder pressure 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months one or more required air _ 1800 psig.

cylinders on EDG.

AND C.2 Evaluate OPERABILITY of Immediately affected EDG per Technical Specification 3.8.2.

8.8.3-2

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.8.3.1 Verify required air cylinder pressure > pressure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limits specified in Figure 8.8.3-1 for the existent air leakage downstream of isolatioD check valve.

TVR 8.8.3.2 ------------------ NOTE ---------------

Air supply in excess of a seven-day supply is not required for damper control air supply functionality.

Verify 30 day supply of compressed air cylinders 31 days available on site.

TVR 8.8.3.3 ------------------ NOTE---------------

TNC 8.8.3 remains met if leakage is within limits specified in Figure 8.8.3-1.

Verify EDG ventilation system leakage downstream 92 days of isolation check valve < 217 sccm.

TVR 8.8.3.4 Verify isolation check valve leakage within limits. In accordance with the Augmented Inservice Testing (IST) Program TVR 8.8.3.5 Perform calibration of backup air supply regulator. 18 months 8.8.3-3

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 Figure 8.8.3-1 EDG Ventilation Damper Control Air Sup-ply Pressure and System Leakage Limitation Curve 2400 2300 2200 2100 (A

2000 1900 1800 217 267 317 367 417 467 517 567 617 Air Leakage (sccm) 8.8.3-4

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 BASES BACKGROUND Emergency Diesel Generator (EDG) Rooms 1A and 1B are each provided with a ventilation system consisting of a normal-mode supply fan and a vent supply fan with automatic control dampers (reference 1).

These dampers are operated by compressed air. Vent supply fans provide both combustion air for the diesel engine and sufficient cooling air to maintain the design basis room temperature (reference 2).

Compressed air is normally supplied to EDG ventilation control dampers from the instrument air system. A safety-related backup air supply is provided by two redundant sets of compressed air cylinders (two cylinders per set) for each EDG. One of the two sets of air cylinders is normally aligned to its respective EDG's ventilation damper control air supply. The second set is normally maintained isolated (in reserve). The reserve air cylinder set provides enhanced system reliability as well as flexibility for conduct of maintenance or testing.

During normal operation, control air is supplied from the instrument air system at a higher pressure than the backup air supply output. This results in the backup air supply remaining in standby. The aligned (inservice) compressed air cylinders provide backup control air to the damper controllers in the event the normal (instrument) air supply is lost concurrent with a loss of off-site power. Either set of backup air supply cylinders (when placed in service) is capable of supplying compressed air to its respective EDG's damper actuators for seven days.

A pressure regulator, at the outlet of each compressed air cylinder set, supplies backup air at reduced pressure of approximately 80 psig. In the event instrument air pressure drops below 80 psig, air to the EDG ventilation damper actuators would continue to be provided from the backup air supply. An isolation check valve in the instrument air supply allows flow of instrument air to the damper controllers, but prevents backflow of backup air (and depletion of the air cylinders) in the event of pressure loss in the instrument air system.

Based on a design system leakage of 217 sccm downstream of the isolation check valve, and minimum allowed cylinder air pressure of 1800 psig, the backup air supply can provide control air to the damper actuators on its respective EDG for seven days.

TNC and The EDG ventilation damper control air supply supports EDG APPLICABILITY OPERABILITY. Therefore, the EDG ventilation damper control air supply must be FUNCTIONAL whenever the associated EDG it supports is required to be OPERABLE.

8.8.3-5

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 BASES TNC and To be FUNCTIONAL, the EDG ventilation damper control air supply APPLICABILITY must be capable of supplying air to its associated EDG ventilation (continued) damper controllers. The instrument air system provides the normal supply of control air, but is not required for EDG ventilation damper control air supply FUNCTIONALITY. The required control-air supply is provided by the compressed air cylinders that comprise the backup air supply. Two compressed air cylinders (one set) are required and must be aligned to provide backup air supply to the damper controllers. The second set of air cylinders enhance system reliability, but are not required for air supply FUNCTIONALITY (references 3 and 4).

To ensure the required seven day supply of control air from the aligned cylinders, air leakage downstream of the isolation check valves must not be excessive and the minimum pressure in each of the two required backup compressed air cylinders must be at least 1800 psig (pressure in the two inservice cylinders in each set remains equalized via their common air header).

Air leakage and corresponding pressure limits are specified in Figure 8.8.3-1 (and in procedures). Maximum allowable air system leakage varies depending on actual air cylinder pressure. The pressure and leakage limits specified in Figure 8.8.3-1 are based on maintaining a seven-day air supply. This correlates to an allowed leak rate of 217 sccm with air cylinder pressure at the minimum allowed value of 1800 psig, and 629 sccm with air cylinder pressure at 2400 psig.

Cylinder air pressure and system air leakage must be maintained in the Acceptable Operation portion of the limitation curve of Figure 8.8.3-1.

This figure is modified by two Notes. Note 1 permits operation with cylinder air pressure above 2400 psig, provided air leakage is < 629 sccm. Air pressure above 2400 psig results in a larger supply of air and is acceptable. The maximum allowable pressure is limited by system design and is administratively controlled. However, air leakage above 629 sccm indicates unacceptable system degradation and is not allowed. Such excessive leakage must be addressed in accordance with Nonconformance B. Note 2 permits operation with air leakage

< 217 sccm, provided cylinder air pressure is > 1800 psig.

Each EDG is supported by its associated ventilation damper control air supply. The ventilation damper control air supply for its associated EDG is required to be FUNCTIONAL whenever that EDG is required to be OPERABLE.

8.8.3-6

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 BASES CONTINGENCY A.1 MEASURES Ifthe ventilation damper control air supply on one EDG is NonFUNCTIONAL for reasons other than excessive system leakage downstream of the isolation check valve or pressure < 1800 psig in one or more required air cylinders, OPERABILITY of the associated EDG may have been adversely affected. Therefore, actions are immediately required to be initiated to evaluate EDG OPERABILITY per Technical Specification 3.8.2.

Because of the immediate completion time, performance of an evaluation that demonstrates the OPERABILITY of the affected EDG as required by CONTENGENCY MEASURE A.1 would need to be completed in advance of entering Condition A.

B.1 and B.2 Ifsystem leakage in the ventilation damper control air supply flow path downstream of the isolation check valve on one EDG exceeds limits specified in Figure 8.8.3-1, the capability of the system to supply backup control air for the required period of time is degraded. Action is needed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reduce leakage to acceptable values (or to raise air pressure to within limits if leakage < 629 sccm).

Because increases in air system leakage generally develop gradually, discovery of excessive air leakage is likely to occur prior to onset of significant leakage or gross system failure. As such, loss of control air to the dampers is not expected to be imminent under normal operating conditions. Therefore, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is an acceptable period of time for operators to identify and correct the source of leakage (or raise air pressure as appropriate). During this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, the system remains capable of supplying air to the ventilation damper controllers considering the heightened operator awareness and availability of the redundant (standby) compressed air cylinders to be placed in service (including availability of additional air cylinders stored onsite).

Additionally, to determine whether OPERABILITY of the associated EDG has been adversely affected by excessive control air leakage, actions are immediately required to be initiated to evaluate EDG OPERABILITY per Technical Specification 3.8.2. These additional actions address conditions where significant or abnormal types of air leakage (e.g., structural failure of air piping integrity) may have adversely impacted EDG OPERABILITY. Provided that air leakage is not gross (e.g., air supply pressure is reasonably capable of being 8.8.3-7

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 BASES CONTINGENCY maintained above 1800 psig and capable of supplying compressed air MEASURES to its respective EDG's damper actuators for seven days (allowing for (continued) replacement of air cylinders to maintain pressure)), then the EDG may be considered OPERABLE with this Nonconformance during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration time.

C.1 and C.2 Ifpressure is < 1800 psig in one or more required air cylinders on one EDG, the capability of the system to supply backup control air for the required period of time is significantly degraded. Action is needed within four hours to restore air cylinder pressure to acceptable values.

Because pressure in the compressed air cylinders generally decreases gradually and a low pressure alarm is provided to operators, discovery of low pressure is likely to occur prior to significant loss of air from the air cylinders. As such, loss of control air to the dampers is not expected to be imminent under normal operating conditions. Therefore, four hours is an acceptable period of time for operators to identify and correct the cause of the low air pressure. During this four hour period, the system remains capable of supplying air to the ventilation damper controllers considering the heightened operator awareness and availability of the redundant (standby) compressed air cylinders to be placed in service (including availability of additional air cylinders stored onsite). Nonconformance C provides defense in depth to the limits specified in Figure 8.8.3-1 against loss of required air supply.

Additionally, to determine whether OPERABILITY of the associated EDG has been adversely affected by significantly low air pressure, actions are immediately required to be initiated to evaluate EDG OPERABILITY per Technical Specification 3.8.2. These additional actions address conditions where significant or abnormal types of pressure loss (e.g., structural failure of air piping integrity) may have adversely impacted EDG OPERABILITY.

8.8.3-8

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 BASES TECHNICAL TVR 8.8.3.1 VERIFICATION REQUIREMENTS Verification that pressure in the required (aligned) air cylinders is

> minimum required pressure specified in Figure 8.8.3-1, corresponding to the existent air leakage downstream of isolation check valve, must be performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Although only the aligned (inservice) air cylinders are required tobe verified, pressure in the isolated (standby) compressed air cylinders is also typically monitored to maintain their availability for use.

TVR 8.8.3.2 Verification must be performed every 31 days that a 30-day supply of EDG ventilation control air, contained in appropriate compressed air cylinders, is available on site. This verification is modified by a Note that an air supply beyond a seven-day supply is not required for damper control air supply FUNCTIONALITY. This is an allowed exception to TVR 7.6.1. A 30-day supply is provided as defense in depth. Deficiency in the 30-day air supply would be addressed via the corrective action process.

TVR 8.8.3.3 Verification that EDG ventilation system leakage, downstream of the instrument air isolation check valve, is < 217 sccm, must be performed every 92 days.

This verification is modified by a Note, which states that TNC 8.8.3 remains met if system air leakage is within limits specified in Figure 8.8.3-1. This is an allowed exception to TVR 7.6.1. Since leakage limits are based on actual air cylinder pressure, leakage is permitted to exceed 217 sccm if air pressure is sufficiently high. However, Figure 8.8.3-1 allows a minimum cylinder air pressure of 1800 psig.

Therefore, leakage should not normally exceed 217 sccm. Leakage that exceeds 217 sccm, although allowed by Figure 8.8.3-1, is not desired long term. Undesired leakage would be addressed via the corrective action (or other appropriate) process.

The minimum required cylinder air pressure corresponding to the existent system air leakage (per Figure 8.8.3-1) must be administratively maintained (e.g., if system air leakage is 355 sccm, then a required minimum cylinder air pressure of 2000 psig must be administratively maintained).

8.8.3-9

KEWAUNEE POWER STATION TRM 8.8.3 TECHNICAL REQUIREMENTS MANUAL Revision 2 January 28, 2014 BASES TECHNICAL TVR 8.8.3.4 VERIFICATION REQUIREMENTS Verification that instrument air isolation check valve leakage is within (continued) limits must be performed In accordance with the periodicity specified in the Augmented IST Program.

TVR 8.8.3.5 The air pressure regulator on the outlet of each required set of compressed air cylinders must be calibrated every 18 months.

REFERENCES 1. USAR 9.6.7, Turbine Building and Screenhouse Ventilation System

2. USAR 8.2.3, Emergency Power

3. Design Change KW-10-01101, EDG Ventilation Air Supply Modification

4. Calculation C11965 8.8.3-10

KEWAUNEE POWER STATION TRM 8.3.6 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 16, 2011 8.3 INSTRUMENTATION 8.3.6 Seismic Monitoring Instrumentation TNC 8.3.6 Seismic monitoring instrumentation shall be FUNCTIONAL.

APPLICABILITY: At all times.

CONTINGENCY MEASURES NONCONFORMANCE CONTINGENCY MEASURES RESTORATION TIME A. Seismic monitoring instrumentation A.1 --------- NOTE--------------- X Seismic Monitoring instrumentation may be \,, \>

NonFUNCTIONAL.

NonFUNCTIONAL f'o6u0"i{J 12 ,/tin(

te bQhurs'\...for surveillancell

'* Initiate action tres Immediately

/ 'minstrumention to

"/7 FUNCI,*IONiAL status.

2\/A ND

" 2-',Establish other means to Immediately estimate Seismic Intensity of 7 ,/', "an earthquake felt at

N,Kewaunee Power Station.

8.3.6-1

KEWAUNEE POWER STATION TRM 8.3.6 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 16, 2011 TECHNICAL VERIFICATION REQUIREMENTS VERIFICATION FREQUENCY TVR 8.3.6.1 Perform CHANNEL CHECK. 6 months TVR 8.3.6.2 ------------------ NOTE ----------------

Freque.ncy not to exceed once per operating cycle.

Perform CHANNEL FUNCTIONAL TEST. 18 hionths XV v

S.\,,',

.-/

/

(

1"

/

8.3.6-2

KEWAUNEE POWER STATION TRM 8.3.6 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 16, 2011 BASES BACKGROUND Several different seismic loads were used in the design the Kewaunee Power Station. The three different loads are 1) an Operational Basis Earthquake (OBE) which is based upon a maximum horizontal ground acceleration of 0.06g and the response spectra are given on Plate 8-A in USAR, Appendix A, 2) a Design Basis Earthquake (DBE) which was based upon a maximum horizontal ground acceleration of 0.12g and the response spectra are given on Plate 8-B in USAR Appendix A, and

3) Uniform Building Code Earthquake Loads which specifies the location of the plant site to be in a "Zero" earthquake area. However, for conservatism, earthquake loads applicable to Zone 1 areas were used in the design under this category.

A seismic event is defined at two levels of severityr named the Operating Basis Earthquake (OBE) and the Sale S,\Utdown Earthquake (SSE), which is also referred to as*tn*\besign Basis Earthquake (DBE) or the Maximum Credible$ath `uake (MCE).

The licensing basis SSE design response )pectra horizontal components have apa` -ground accelerai6n of 0.12 g. The OBE was based upon mrnEd;m horiZ8ntal<ground acceleration of 0.06 g.

The plant is capoabj 6e"of eing l6fru*t~ko, and maintained in, a safe shutdown cofdition f*r 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months fqlowing a SSE (Reference 1).

Seismic',ýnoh'itoring instrumentation is used to provide data on seismic even1ts in oder to permr Ja.tinely determination of the need for shutting dpon9thlt4actor as-.(_.i"ult of the event. This system, which is fdearibed in US. .,Section 1.6.10 (Reference 2), is required to have aitaomatic reording capability, record multiple independent channels

".ofdata, a)e f theo)perator of an event in progress, and provide peak accelpratiýn o,'f the event.

Seismicmonitoring instrumentation provides data on frequency, amplitude and phase relationship of all accelerometer channels for future analytical review. The seismic instrumentation system consists of field mounted tri-axial accelerometers, field mounted seismic recorders, and Network Control Center (NCC) (Reference 3). The NCG contains a readout device and a port for interfacing with a personal computer (PC). The PC is used for performance of periodic system checks and to view data from the seismic event.

8.3.6-3

KEWAUNEE POWER STATION TRM 8.3.6 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 16, 2011 BASES BACKGROUND Normally the seismic sensing and recording system is in a quiescent (continued) state; the system will start recording data when the intensity of the acceleration reaches a preset level as detected by two of the three accelerometers. The system will return to the quiescent condition a short period after the intensity of the acceleration has gone below the preset level.

Each tri-axial accelerometer consists of three single channel accelerometers, which are mounted on mutually perpendicular axes.

One set of tri-axial accelerometers is located on the basement floor of the containment structure (Elevation 592 ft), another directly above the first on the refueling floor (Elevation 649 ft 6 in) and the third set on the floor of the Auxiliary Building (Elevation 657 ft 6 in)-.\ (Since the Auxiliary Building and Reactor Building share the s 0ebase slab, another accelerometer is not needed in the ba oem bf the Auxiliary Building.) The output of each accelerometer rovides an independent analog signal to its associated seismic recrr,,e, The seismic recorder provides input to the NCC via interconnectln~ electrical cables.

An annunciator wijmmediately alet.topprators when a seismic event has occurred../T e/ie~i\iic re¢-dji, used to record seismic data and time bas.0infot'pation for its associated accelerometer. Three seismic recorders provide sbismic event information to the NCC. Peak acceleratioos are displayed*60n the NCC's display monitor. More detailed sei~rhic data can'hoe 6btained from the PC. In the event of a sei"igsic'dis'urbance,) i ten administrative procedures are implemented top~ver.:6peration of the plant. Inspection of crucial

/'."ar§a'and components would be made immediately, with the

.inpection re-sultsdocumented. In the absence of any unusual obser/.at~oni the plant would. continue to be operated.

8.3.6-4

KEWAUNEE POWER STATION TRM 8.3.6 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 16, 2011 BASES TNC and Seismic instrumentation is FUNCTIONAL if it is capable of immediately APPLICABILITY alerting the operator when a seismic event has occurred. Additionally, it must be capable of automatically recording data on acceleration levels, including peak levels, from any accelerometer and providing the data within a few minutes after the seismic event.

Seismic events are independent of plant operating status. Should a seismic event occur, inspection of crucial areas and components would need to be made regardless of plant operating status.

Therefore, required seismic monitoring instrumentation must be FUNCTIONAL at all times.

CONTINGENCY If any required seismic monitoring instrument is, deteImined to be MEASURES NonFUNCTIONAL, action is immediately requiied-,t6 initiate restoration of the NonFUNCTIONAL instrumentation t**FUNCTIONAL status. A Note modifies the restoration CONTINNqýEý-,-MEASURE to allow TVRs to be performed-without the requireehfit to immediately initiate action to restore the1i~s-ti\mentatin.

The immediate> // et toration

.//

/1. Timberequires

,') that actions to initiate restoration sh6uld 't pursued wihout delay and in a controlled manner.",;Full restoration of~the instrument(s) to FUNCTIONAL status would beýnterolled in ak$'*ordance with the corrective action program, as reluiredtby*/ 10 CF(5,-'>Ap'pendix B, Corrective Action", Criterion XxjI ,-Cor#ectve Actifi*h:11.y

\ */ . '\ -

,eKthe seism) nstrumentation is NonFUNCTIONAL, measures 0 ~st be establshed to ensure an estimate of the Seismic Intensity of an e ,hquIi'e felt at Kewaunee Power Station can be obtained. This is nece/ssary to ensure the affect(s) on the felt earthquake on plant syste Ms, structures, and components can be assessed.

8.3.6-5

KEWAUNEE POWER STATION TRM 8.3.6 TECHNICAL REQUIREMENTS MANUAL Revision 1 March 16, 2011 BASES TECHNICAL Required seismic instrumentation must be periodically checked for VERIFICATION proper operation.

REQUIREMENTS TVR 8.3.6.1 This TVR requires performance of a CHANNEL CHECK of seismic monitoring instrumentation every 6 months.

TVR 8.3.6.2 This TVR requires performance of a CHANNEL FUNCTIONAL TEST of seismic monitoring instrumentation every 18 months or once per operating cycle, whichever occurs first.

REFERENCES 1. NRC Safety Evaluation Regarding USI *i*6,Pr'gram Implementation, Revision 1, dated 'a-y 998

2. USAR Section 1.6A*1, Seismograph'

3. DC KW-1 0-0j)00, 0", IIepmace iMonitonng System", June 8, 2010.

/

'N 6

< \~ "'Ij->

/2 /

//

.\ /;/

SZ\r K>

Kj 8.3.6-6

Serial No.14-123 ATTACHMENT 2 TECHNICAL SPECIFICATIONS BASES CHANGES AND TECHNICAL REQUIREMENTS MANUAL CHANGES KEWAUNEE POWER STATION TECHNICAL REQUIREMENTS MANUAL CURRENT PAGE LIST KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.14-123 Attachment 2 Page 1 of 1 KEWAUNEE POWER STATION TECHNICAL REQUIREMENTS MANUAL CURRENT PAGE LIST Page Revision Date Page Revision Date No.

No.5 i 57 February 24, 2014 8.9.2-2 1 October 15, 2013 ii 57 February 24, 2014 8.9.4-1 2 October 15, 2013 6.0-1 0 February 12, 2011 8.9.4-2 2 October 15, 2013 7.0-1 1 October 15, 2013 10.3-1 0 February 12, 2011 7.0-2 1 October 15, 2013 10.4-1 0 February 12, 2011 7.0-3 1 October 15, 2013 10.4-2 0 February 12, 2011 7.0-4 1 October 15, 2013 10.4-3 0 February 12, 2011 7.0-5 1 October 15, 2013 10.4-4 0 February 12, 2011 8.3.2-1 0 February 12, 2011 10.4-5 0 February 12, 2011 8.3.2-2 0 February 12, 2011 10.4-6 0 February 12, 2011 8.3.2-3 0 February 12, 2011 10.4-7 0 February 12, 2011 8.7.2-1 1 May 19, 2011 10.4-8 0 February 12, 2011 8.7.2.2 1 May 19, 2011 10.4-9 0 February 12, 2011 8.7.2-3 1 May 19, 2011 10.4-10 0 February 12, 2011 8.7.2-4 1 May 19, 2011 10.4-11 0 February 12, 2011 8.7.2-5 1 May 19, 2011 10.4-12 0 February 12, 2011 8.7.8-1 0 October 15, 2013 10.4-13 0 February 12, 2011 8.7.8-2 0 October 15, 2013 10.4-14 0 February 12, 2011 8.7.8-3 0 October 15, 2013 10.4-15 0 February 12, 2011 8.7.8-4 0 October 15, 2013 8.8.1-1 2 September 16, 2013 8.8.1-2 2 September 16, 2013 8.8.1-3 2 September 16, 2013 8.8.1-4 2 September 16, 2013 8.8.1-5 2 September 16, 2013 8.8.1-6 2 September 16, 2013 8.8.1-7 2 September 16, 2013 8.8.2-1 3 July 1, 2013 8.8.2-2 3 July 1, 2013 8.8.2-3 3 July 1, 2013 8.8.2-4 3 July 1, 2013 8.8.2-5 3 July 1, 2013 8.8.2-6 3 July 1, 2013 8.8.3-1 2 January 28, 2014 8.8.3-2 2 January 28, 2014 8.8.3-3 2 January 28, 2014 8.8.3-4 2 January 28, 2014 8.8.3-5 2 January 28, 2014 8.8.3-6 2 January 28, 2014 8.8.3-7 2 January 28, 2014 8.8.3-8 2 January 28, 2014 8.8.3-9 2 January 28, 2014 8.8.3-10 2 January 28, 2014 8.8.5-1 0 July 1,2013 8.8.5-2 0 July 1,2013 8.8.5-3 0 July 1,2013 8.9.1-1 1 October 15, 2013 8.9.1-2 1 October 15, 2013 8.9.1-3 1 October 15, 2013 8.9.1-4 1 October 15, 2013 8.9.2-1 1 October 15, 2013

ML14106A450

Text

Reference:

Navigation menu

Search