ML12023A057

NRR E-mail Capture - ME7110 Kewaunee Amendment Request Re_ Chi-over-Q - Ahpb Request for Additional Information (RAI) - Firm RAI Items

ML12023A057
Person / Time
Site:	Kewaunee
Issue date:	01/13/2012
From:	Feintuch K Division of Operating Reactor Licensing
To:	Sly C Dominion Energy Kewaunee
References
TAC ME7110
Download: ML12023A057 (10)

Text

From:

Feintuch, Karl To:

Craig D Sly; Jack Gadzala Cc:

Lapinsky, George

Subject:

ME7110 Kewaunee Amendment Request Re: Chi-over-Q - AHPB Request for Additional Information (RAI) - firm RAI items Date:

Friday, January 13, 2012 1:02:00 PM Attachments:

ME7110 RAII-AHPB 2012-01-13.docx ME7110 Chi-over-Q RAI status Tracking 2012-02-13.xlsx On January 12, 2012, A clarification conference call was held to discuss the AHPB RAI items originally sent Monday, January 09, 2012 1:48 PM (see below). Specifically, the licensee requested discussion of items 6, 7, and 8.

Attending the conference call were:

For NRC (firm attendance): Karl Feintuch, George Lapinsky For Kewaunee / Dominion (attendance subject to confirmation of absent individuals):

Craig Sly, Jack Gadzala, John Holly, Stuart Torf, Bill Kohlroser, William Eakin, Brian OConnell, Alan Ford, Doug Gilliatt The attached items contain the specific outcomes of the call, and the changes are summarized below:

1 - The request date is changed to February 13, 2012, to correspond to Monday of that week. The tracing numbers are changed accordingly.

2 - The reference to 45 minutes in item 6 has been modified to 60 minutes by Reviewer Lapinsky after further review of the existing submittal..

3 - Item 7 has been deleted. The clarification made this item unnecessary.

4 - Item 8 has been modified to clarify that the Reviewer seeks information about the affected emergency operating procedures.

5 - From the foregoing comments the items in this RAI are now firm. Note the strikethrough in the message below and use of brackets [ ] to update the RAI message to convey the firm RAI items.

========== message of January 9, 2012, as updated for firm RAI items, follows

====

From: Feintuch, Karl Sent: Monday, January 09, 2012 1:48 PM To: Craig D Sly Cc: Lapinsky, George

Subject:

ME7110 Kewaunee Amendment Request Re: Chi-over-Q - AHPB Request for Additional Information (RAI)

(DRAFT) REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE POWER STATION LICENSE AMENDMENT REQUEST (TAC No. ME7110):

MODIFYING THE TECHNICAL SPECIFICATIONS (TS) AND THE CURRENT LICENSING BASIS (CLB)

TO INCORPORATE CHANGES TO THE CURRENT RADIOLOGICAL ACCIDENT ANALYSIS (RAA) OF RECORD (KNOWN AS CHI-OVER-Q)

DOCKET NO. 50-305 By letter dated August 30, 2011, Dominion Energy Kewaunee (DEK) submitted a license

amendment request (LAR)-244 (ADAMS Accession No. ML11252A521) to revise the Kewaunee Power Station (KPS) Operating License by modifying the Technical Specifications (TS) and the current licensing basis (CLB) to incorporate changes to the current radiological accident analysis (RAA) of record. This proposed amendment would revise the current RAA for the design-basis accidents (DBAs) described in Chapter 14 of the KPS Updated Safety Analysis Report (USAR). This amendment would also fulfill a commitment made to the NRC in response to Generic Letter 2003-01, Control Room Habitability.

In the course of their technical review, the Health Physics and Human Performance Branch (AHPB, formerly designated as IHPB) has requested further information items to enable completion of its respective Safety Evaluation efforts. These items are provided in draft form for you to review for clarification. We seek to confirm your understanding of the items and the determination of a firm date for response, typically within 30 days of the date of this Request for Additional Information (RAI). The items we seek are attached.

Please contact me by 02/12/2012 to confirm: (1) that the items are clear to you and to the responsive DEK staff without further discussion or (2) that a clarifying conference call is needed. Upon determination that the RAI items are clear and confirmation of when responses to these items are due, these draft RAI items will be considered to be in final form. [A clarification conference call was held on January 12, 2012. The attachments reflect the results of the call. The agreed date for response is February 13, 2012. The tracking numbers for each item were modified accordingly.]

ME7110 is a complex project and we (Craig Sly of DEK and myself) have discussed methods for (1) improved movement of RAI information, (2) improved responsiveness to NRC staff requests, and (3) more flexibility for DEK to schedule RAI response activity, over that associated with more rigidly defined RAI milestone events. This group of AHPB RAIs will be managed by the attached spreadsheet. This and subsequent RAI traffic will be tracked by an individual identifier to provide the associated response by the individualized request by date.

Docketing of this information by submittal under oath or affirmation will be managed by a reference to the associated ADAMS Accession No. (ML#) on the spreadsheet. Docketing will take place on groups of RAI item responses based on close completion schedules rather than close issuance schedules, as is now customary. Thus, if DEK can respond with individual information in 5 days, the request by date will be shortened and will be received sooner than the rest of the items, although its docketing event might coincide with the original set of items or with those RAI items originating from another Technical Branch.

We will periodically assess whether this new process continues to be of mutual benefit while conforming to the regulation for processing amendment requests and their associated RAI responses.

The attached AHPB RAI items are assigned the following tracking numbers. The associated entries are defined in the Legend tab of the spreadsheet:

1. ME7110-RAII-AHPB-Lapin-001-2012-02-13

2. ME7110-RAII-AHPB-Lapin-002-2012-02-13

3. ME7110-RAII-AHPB-Lapin-003-2012-02-13

4. ME7110-RAII-AHPB-Lapin-004-2012-02-13

5. ME7110-RAII-AHPB-Lapin-005-2012-02-13

6. ME7110-RAII-AHPB-Lapin-006-2012-02-13

7. ME7110-RAII-AHPB-Lapin-007-2012-02-13 [item deleted]

8. ME7110-RAII-AHPB-Lapin-008-2012-02-13

9. ME7110-RAII-AHPB-Lapin-009-2012-02-13

========== end message of January 9, 2012, as updated for firm RAI items

====

REQUEST FOR ADDITIONAL INFORMATION REGARDING KEWAUNEE POWER STATION REVISION TO RADIOLOGICAL ACCIDENT ANALYSIS AND ASSOCIATED TECHNICAL SPECIFICATIONS (TAC# ME7110)

FIRM ITEMS AS A RESULT OF CONFERENCE CALL OF JANUARY 13, 2012 NOTE: BRACKETS [ ] INDICATE A CHANGE DISCUSSED DURING CONFERENCE CALL

[The request by date is moved to Monday, February 13, 2012, by PM Feintuch.

Therefore, the last three fields of the RAI item tracking number now are 2012-02-13]

Health Physics and Human Performance Branch (AHPB):

1. (ME7110- RAII-AHPB-Lapin-001-2012-02-13) Explain why it was found to be preferable to add manual actions rather than upgrade the quality classification and redundancy of Radiation Monitor R-23.

2. (ME7110- RAII-AHPB-Lapin-002-2012-02-13) Among the proposed changes is a change to LCO 3.9.6.a to allow the containment equipment hatch to be open during handling of recently irradiated fuel when measures are in place which ensure the capability to close equipment hatch in the event of a fuel handling accident (FHA). As described, closing the equipment hatch requires special tools and equipment, such as, a trolley, a jactuator, chainfalls, etc.

a. How will personnel ensure that all required tools and equipment needed to close the equipment hatch are pre-staged/available and operable?

b. How will personnel know whether and what kind of radiation protection equipment and clothing is needed?

c. Is a written procedure required and available?

d. Is training provided to all personnel who may be called upon to close the equipment hatch?

3. (ME7110- RAII-AHPB-Lapin-003-2012-02-13) A proposed new Note, applicable to LCO 3.9.6.c, would allow penetration flow paths providing direct access from the containment to outside atmosphere to be opened under administrative controls. How will each of the administrative controls be implemented:

a. How will containment penetration status be communicated? (to the CR and in-plant personnel)

b. How will designated personnel know their assigned penetration(s)?

c. How will designated personnel be cautioned about obstructions?

d. How will Operations know that designated personnel are at their posts?

4. (ME7110- RAII-AHPB-Lapin-004-2012-02-13)

a. Does Radiation Monitor R-23 perform any functions other than the isolation function that is being removed?

b. If yes, what functions will remain?

c. If no, will all controls, displays, and logic interfaces associated with R-23 be physically removed?

5. (ME7110- RAII-AHPB-Lapin-005-2012-02-13) In Attachment 5 of the licensees revised submittal, it is stated that: Operations personnel were included in the walkdown of the control room.

a. Was at least one crew included in the walkdown?

b. If not, what plans are being made to validate the procedures, training, and physical interfaces with a representative sample of operators, i.e., at least one crew.

6. (ME7110- RAII-AHPB-Lapin-006-2012-02-13) The revised RAA credits manual initiation of the CRE isolation within 60 minutes of the occurrence of an LRA, and initiation of the Control Room Post Accident Recirculation (CRPAR) system within 20 minutes of occurrence of a FHA and within [60] minutes of an LRA. [In its response the licensee will clarify the differences between the current and requested licensing bases.

Reviewer Lapinsky corrected the time to 60 minutes.]

a. How were these completion times estimated?

b. What are the actual times or the estimated required times for these actions?

c. How much margin is built into the estimates of completion times?

7. (ME7110- RAII-AHPB-Lapin-007-2012-02-13) [Deleted item] For FHA and LRA, how was ALARA factored into the mitigation strategies? Will operator training address the integration of ALARA into the mitigation strategies? [This item is deleted by Reviewer Lapinski]

8. (ME7110- RAII-AHPB-Lapin-008-2012-02-13) The licensee stated in Attachment 5 of the revised submittal, that The appropriate modifications to plant procedures will be made as part of the implementation of this amendment request. Identify all procedure changes that will be made in support of this LAR. Include the procedure numbers and titles of the affected [emergency operating] procedures. [With the additional words emergency operating Reviewer Lapinski clarified the scope of the requested procedures]

9. (ME7110- RAII-AHPB-Lapin-009-2012-02-13) Describe any changes to training that are necessary to support this LAR.

ME7110 Chi-over-Q RAI status Tracking 2012-02-13.xlsx 1

2 3

A B

C D

E F

G H

TAC Doc type Source TB Source TB Reviewer Request by date Status RAI Response ML#

MLnnnnnnnnn Description ME7110 RAII EICB Alva-001 1/20/2012 firm 1, In DEKs License Amendment Request (LAR)-210, DEK proposed incorporating the control room envelope operability and surveillance requirements, R-23 operability requirements, and the control room post-accident recirculation (CRPAR) system requirements into the KPS Technical Specification (TS) ensures the systems, structures, or components (SSCs) credited for mitigating the consequences of an accident for control room occupants were included in the TS. At the same time, DEK requesting removing crediting R-23 and the control room envelope boundary from the KPS Waste Gas Decay Tank (GDT) and Volume Control (VCT) rupture accident analysis, since it determined that occupant dose consequences are achieved without crediting the control room envelope boundary or the CRPAR system. Later DEK withdrew LAR-210. However, based on the information provided in LAR-210, it is not clear why DEK in LAR-244 is requesting deleting R-23 from the TS, even though in the accident analysis performed for both LARs, DEK stated that R-23 was not credited in the proposed accident analysis. Please explain the reason to remove R-23 and replace with analysis and manual operation of the isolation dampers.

ME7110 RAII EICB Alva-002 1/20/2012 firm

2. NUREG-0737, Clarification of TMI Action Plan Requirements, Item III.D.3.4, Control Room Habitability Requirements, required licensees to assure that control room operators will be adequately protected against the effects of accidental release of toxic and radioactive gas and that the plant can be safely operated or shutdown under design basis accident conditions. LAR proposed removing radiation monitor channel R-23 as a required channel for CRPAR initiation, modifying DEK previously approved by the NRC compliance with NUREG-0737. Please describe if R-23 is removed, how DEK will comply with NUREG-0737.

ME7110 Chi-over-Q RAI status Tracking 2012-02-13.xlsx 1

A B

C D

E F

G H

TAC Doc type Source TB Source TB Reviewer Request by date Status RAI Response ML#

MLnnnnnnnnn Description 4

5 6

ME7110 RAII EICB Alva-003 1/20/2012 firm

3. During the NRC staff review of LAR-210, EICB issued RAI January 30, 2008 letter (ADAMS Accession No. ML080280107). DEK provided a response on its April 3, 2008 letter (ADAMS Accession No. ML080950096); the response to question 1b included a logic diagram for operation of the control room ventilation radiation monitor. To assist NRC staff review, please address the following:

a. Section 3.1.1 of Attachment 1 of LAR-244 (ADAMS Accession No. ML11252A521) states that radiation monitor R-23, as a single channel, initiates both trains of the CRPAR system and each SI train initiates the associated CRPAR fan and filtration unit train. If R-23 is removed from the logic, will it be necessary that both SI trains be actuated to initiate CRPAR fans, filtration unit trains, and close dampers ACC-1A, ACC-1B, ACC-2, and ACC-5?

b. This logic shows that safety injection (SI) train A closes dampers ACC-1A and ACC-1B, and SI train B closes dampers ACC-2 and ACC-5. If R-23 is removed, how will dampers ACC-2 and ACC-5 close if the SI train B actuation signal fails?

c. Provide a marked logic for the control room ventilation radiation monitor assuming that R-23 is removed from the logic.

ME7110 RAII EICB Alva-004 1/20/2012 firm

4. LAR-244 is requesting removal of R-23 from the CRPAR system. Please describe how DEK would reflect removal of R-23 from the CRPAR system in an update of the FSAR for the following items:

a. Figure 9.6-6, Control Room Air Conditioning System-Flow Diagram, in the Final Safety Analysis Report (FSAR) shows R-23 location in the CRPAR system. Provide a marked diagram for an update of the FSAR after removal of R-23.

b. Section 7.7.1, Control Room, in the FSAR describes how R-23 monitors and activates the control room ventilation.

ME7110 RAII EICB Alva-005 1/20/2012 firm

5. LAR-244, Attachment 1, Section 4.2.3 and Attachment 4, Section 2.7 state that revised radiological accident analysis (RAA) credits R-23 to limit consequences of the Locked Rotor Action (LRA) and Fuel Handling Accident (FHA). However, the RAA approved in license amendment 190 (current radiological analysis of record for KPS) credited R-23 high radiation signal for mitigating the radiological consequences to control room occupants for the LRA, GDT and VCT Rupture, and FHA. Please explain why the revised RAA (submitted in LAR-244) does not state whether credit for R-23 is considered for mitigating GDT and VCT rupture.

ME7110 Chi-over-Q RAI status Tracking 2012-02-13.xlsx 1

A B

C D

E F

G H

TAC Doc type Source TB Source TB Reviewer Request by date Status RAI Response ML#

MLnnnnnnnnn Description 7

8 9

ME7110 RAII EICB Alva-006 1/20/2012 firm

6. LAR-244, Section 4.2.3 describes that removal of R-23 would require manual actions to ensure post-accident control room dose is maintained within limits and are required to limit consequences of the FHA and LRA events. Note that the current accident analysis does not credit operator action to isolate the control room during for FHA. Attachment 3, Section B.3.3.7 states that manual actuation of the CRPAR System is a backup for the SI signal actuation. To assist NRC staff review, please address the following:

a. Manual actuation is not part of the logic diagram for operation of the control room ventilation radiation monitor (FSAR Figure 9.6-6). Please clarify if this would be included in the logic diagram.

b. SI signal is not considered for all accident events (i.e., FHA, LRA, and GDT/VCT ruptures dont consider SI). In these cases manual action would be required. Please clarify if this would be included in the logic diagram.

ME7110 RAII EICB Alva-007 1/20/2012 firm

7. LAR-244, Attachment 4, Section 2.7, 3.3.1, and 3.6.1, state that full control room isolation require action by the operator to close monitor dampers that are not included in the isolation logic (of the control room ventilation radiation monitor). This was not discussed in previous LARs or in FSARs. Please explain the following:

a. Where is this information described? Provide a logic diagram and a description for operation of all dampers required for the control room ventilation radiation system.

b. Are these monitor dampers closed by the SI signal? If not, what signal actuates them?

ME7110 RAII AHPB Lapin-001 2/13/2012 firm

1. Explain why it was found to be preferable to add manual actions rather than upgrade the quality classification and redundancy of Radiation Monitor R-23.

ME7110 Chi-over-Q RAI status Tracking 2012-02-13.xlsx 1

A B

C D

E F

G H

TAC Doc type Source TB Source TB Reviewer Request by date Status RAI Response ML#

MLnnnnnnnnn Description 10 ME7110 RAII AHPB Lapin-002 2/13/2012 firm

2. Among the proposed changes is a change to LCO 3.9.6.a to allow the containment equipment hatch to be open during handling of recently irradiated fuel when measures are in place which ensure the capability to close equipment hatch in the event of a fuel handling accident (FHA). As described, closing the equipment hatch requires special tools and equipment, such as, a trolley, a jactuator, chainfalls, etc.

a. How will personnel ensure that all required tools and equipment needed to close the equipment hatch are pre-staged/available and operable?

b. How will personnel know whether and what kind of radiation protection equipment and clothing is needed?

c. Is a written procedure required and available?

d. Is training provided to all personnel who may be called upon to close the equipment hatch?

TAC Doc type Source Tech Branch Source Reviewer and Ser#

Request by date Status ML#

Description ME7110 RAII EICB Alva-001 12/29/2011 draft MLnnnnnnnnn Assigned TAC No. This may be different than ME7110 if future sub-projects need other TAC No.

RAII RAII = Request for information item RAIR = Request for information response Suppl = docketed supplement EICB EICB = Instrumentation and Control Branch AHPB = Health Physics and Human Performance Branch AADB = Accident Dose Branch ITSB = Technical Specifications Branch Alva-001 Alva-nnn = Items from Reviewer Alvarado Lapin-nnn = Items from Reviewer Lapinsky 12/29/2011 Request by date (updated as mutually understood by PM, Reviewer and Licensee; maintained by PM and Licensee) draft draft = as issued prior to clarification firm = as mutually understood and to be respond to by licensee resp = contains docketed response ML#

If blank, then = not yet docketed in ADAMS If RAIR, then = docketed ML#

If RAII, then = issued RAI If Suppl, then = docketed supplement letter containing no RAIR information