ML101890242

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Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) - Kewaunee ITS Conversion Database
ML101890242
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 06/02/2010
From:
Dominion Energy Kewaunee
To:
Office of Nuclear Reactor Regulation
References
Download: ML101890242 (29)
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Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 1 of 29 ITS NRC Questions Id 1161 NRC Question ALK-005 Number Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number JFD Number JFD Bases Number Page Section 4.2.1 Number(s)

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

Requested NRC Section 5.3.a of the CTS contains the statement, Limited substitutions of Question zirconium alloy, ZIRLOTM, or stainless steel filler rods for fuel rods, in accordance with NRC-approved [emphasis added] applications of fuel rod configurations, may be used. Section 4.2.1 of the proposed ITS contains the statement, Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved [emphasis added] applications of fuel rod configurations, may be used. Eliminating NRC- in front of approved could be interpreted to mean that KPS can now use fuel rod configurations that have not been approved by the NRC but may have been approved by other organizations or entities. Please provide justification for why eliminating NRC- in front of approved does not constitute a less restrictive change.

Attach File 1

Attach File 2

Issue Date 11/23/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/23/2009 8:44 AM Notification NRC/LICENSEE Supervision Audrey Klett http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1161 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 2 of 29 Licensee Response/NRC Response/NRC Question Closure Id 901 NRC Question ALK-005 Number Select Licensee Response Application

Response

11/24/2009 12:40 PM Date/Time Closure Statement Response The words "NRC-approved" in CTS 5.3.a (Page 7) and "approved" in ITS Statement 4.2.1 Page 15) have the identical meaning. The words in the KPS proposed ITS 4.2.1 are identical to the approved ISTS 4.2.1. KPS does not believe that the NRC's intent in ISTS 4.2.1 is to allow other organizations or entities to approve fuel configurations. Since the Technical Specifications are approved and issued by the NRC, it is KPS position that the word "approved" means approved by the NRC.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 11/24/2009 12:42 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=901 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 3 of 29 Licensee Response/NRC Response/NRC Question Closure Id 1161 NRC Question ALK-005 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 12/3/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/3/2009 12:55 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1161 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 4 of 29 Licensee Response/NRC Response/NRC Question Closure Id 1211 NRC Question ALK-005 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 12/14/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/14/2009 8:26 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1211 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 5 of 29 ITS NRC Questions Id 1171 NRC Question ALK-006 Number Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number JFD Number JFD Bases Number Page Section 4.2.1 Number(s)

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

Requested NRC Section 5.3.a of the CTS states in part, Each assembly shall consist of a matrix of Question zircaloy or ZIRLOTM clad fuel rods []. Limited substitutions of zirconium alloy, ZIRLOTM, or stainless steel [] may be used. Section 4.2.1 of the proposed ITS states, in part, Each assembly shall consist of a matrix of Zircalloy or ZIRLO fuel rods []. Limited substitutions of zirconium alloy or stainless steel [] may be used. (1) Please clarify whether there are any differences between ZIRLO and ZIRLOTM, such as differences in chemical composition and/or manufacturer. (2)

Eliminating ZIRLOTM from the statement, Limited substitutions of zirconium alloy, ZIRLOTM, or stainless steel [] may be used, in the TS could be interpreted to mean that KPS may use substitution filler rods for fuel rods of zirconium alloy having a different chemical composition than ZIRLOTM (or ZIRLO). Please provide justification for why eliminating ZIRLOTM from the referenced statement does not constitute a less restrictive change.

Attach File 1

Attach File 2

Issue Date 11/23/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/23/2009 8:46 AM http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1171 06/02/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 6 of 29 Notification NRC/LICENSEE Supervision Audrey Klett http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1171 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 7 of 29 Licensee Response/NRC Response/NRC Question Closure Id 911 NRC Question ALK-006 Number Select Licensee Response Application

Response

11/24/2009 12:45 PM Date/Time Closure Statement Response The term ZIRLO is a trademarked name. Thus in the KPS CTS, the term Statement "TM" follows the word ZIRLO. However, the ISTS wording does not include the "TM" term, since using the words ZIRLO (all in capital letters) implies that this is the title of a special type of fuel. That is, the NRC decided not to include the term "TM" to annotate the word ZIRLO is a trademarked name.

The statement in the CTS discussing limited substitutions includes a ZIRLO allowance. The ISTS does not include this term because it is already covered by the term "zirconium alloy." ZIRLO is a zirconium alloy type fuel. Therefore, since the term in the ISTS (and ITS) zirconium alloy encompasses the ZIRLO brand of fuel, it is redundant and is not necessary to be included in the allowance.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 11/24/2009 12:44 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=911 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 8 of 29 Licensee Response/NRC Response/NRC Question Closure Id 1221 NRC Question ALK-006 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 12/14/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/14/2009 8:27 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1221 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 9 of 29 ITS NRC Questions Id 1441 NRC Question ALK-007 Number Category Technical ITS Section 4.0 ITS Number 4.0 DOC M-1 Number JFD Number 4 JFD Bases Number Page Vol 15; page 17 of 20 Number(s)

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

Requested NRC KPS proposed to replace WOG STS 4.3.1.1.e and f with, Spent fuel assemblies Question stored in the north and south pools and the canal pool in accordance with LCO 3.7.15, Spent Fuel Pool Storage., in the KEW ITS. The STS address storage of both new and spent fuel assemblies, but the proposed statement appears to only address storage of spent fuel assemblies. Please clarify if the spent fuel storage pools would contain any new fuel assemblies or if all new fuel assemblies are stored in the new fuel storage pit. Please also clarify if and/or how Figure 3.7.15-1 of the KEW ITS applies to storage of new fuel assemblies.

Attach File 1 Attach File 2 Issue Date 1/6/2010 Added By Audrey Klett Date Modified Modified By Date Added 1/6/2010 3:58 PM Notification NRC/LICENSEE Supervision Audrey Klett http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1441 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 10 of 29 Licensee Response/NRC Response/NRC Question Closure Id 1811 NRC Question ALK-007 Number Select Licensee Response Application

Response

1/20/2010 10:40 AM Date/Time Closure Statement Response Currently, there are no specific requirements in the KPS CTS for the Statement storage of new fuel assemblies. However, after further review, Kewaunee Power Station will add this new requirement into the ITS. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment, as well as the supplement to Section 3.7 of the ITS conversion amendment.

Question Closure Date Attachment ALK-007 Markup.pdf (2MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 1/20/2010 10:43 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1811 06/02/2010

Attachment 1, Volume 15, Rev. 0, Page 11 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 11 of 29 DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev.

3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 5.4.a.1.a and 5.4.a.2.a states that the spent fuel storage racks and the new fuel storage racks, respectively, are designed and shall be maintained with the fuel assemblies having a maximum enrichment of 56.067 grams Uranium-235 per axial centimeter. ITS 4.3.1.1.a and 4.3.1.2.a states that the spent fuel storage racks and the new fuel storage racks, respectively, are designed and shall be maintained with the fuel assemblies having a maximum U-235 enrichment of 4.9776 weight percent. This changes the CTS by specifying the weight percent of the U-235 enrichment instead of the actual weight per axial centimeter.

The purpose of CTS 5.4.a.1.a and 5.4.a.2.a is to specify the maximum amount of uranium for a fuel assembly per axial centimeter. Based on Westinghouse letter BD-03-193, Rev. 0, dated December 11, 2003, 56.067 grams of U-235 per axial centimeter corresponds to 4.9776 weight percent of U-235. Therefore, the ITS percent weight is the same as the CTS actual weight. This change is acceptable and is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 ITS 4.3.1.1.c requires that spent fuel storage racks in the Fuel Transfer Canal Pool are designed and maintained to have a nominal 8.3 inch rack cell lattice spacing between fuel assemblies in order to prevent criticality of the spent fuel assemblies. ITS 4.3.1.1.d requires that spent fuel storage racks in the North and South Pools Combined are designed and maintained to have a minimum 10 inch center to center distance between fuel assemblies in order to prevent criticality of the spent fuel assemblies. ITS 4.3.1.1.e provides the requirements for loading new and spent fuel assemblies in accordance with ITS LCO 3.7.15. The CTS does not contain this information. This changes the CTS by adding specific requirements for the design and maintenance of the spent fuel storage racks.

The purpose of ITS 4.3.1.1.c and 4.3.1.1.d is to prevent criticality in the Fuel Transfer Canal spent fuel pool and the North and South Pools Combined spent fuel pool. USAR Section 9.5.1.1 describes KPS General Design Criterion (GDC) 66, Prevention of Fuel Storage Criticality, which states, in part, that criticality in the new and spent fuel storage pools shall be prevented by physical systems or processes. Such means, as geometrically safe configurations shall be emphasized over procedural controls. The establishment of minimum spacing design requirements for the spent fuel storage racks assists in meeting the Kewaunee Power Station Page 1 of 3 Attachment 1, Volume 15, Rev. 0, Page 11 of 20

Attachment 1, Volume 15, Rev. 0, Page 12 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 12 of 29 DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. This change is acceptable because it provides appropriate limits for the spent fuel storage racks.

The purpose of ISTS 4.3.1.1.e is to provide requirements for loading spent fuel new and assemblies in accordance with ISTS Figure 3.7.15-1 into the appropriate spent fuel pool. License Amendment 150 allows KPS to store only those spent fuel assemblies prior to or from the 1984 refueling outage in the Canal Pool storage racks. The design of the Canal Pool is fixed and the storage of spent fuel assemblies is restricted by the licensing requirements of License Amendment 150. Therefore, ITS 4.3.1.1.e has been revised to state that the new and spent fuel assemblies in both the North and South Pools and the Canal Pool shall be in accordance with LCO 3.7.15. LCO 3.7.15 is more applicable for placement of the requirements of the spent fuel assemblies in the spent fuel pools at KPS than ITS 4.0. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

M02 ITS 4.3.1.2.d requires that new fuel storage racks are designed and maintained to have a nominal 21 inch center to center distance between fuel assemblies in order to prevent criticality of the spent fuel assemblies. The CTS does not contain this information. This changes the CTS by adding specific requirements for the design and maintenance of the new fuel storage racks.

The purpose of ITS 4.3.1.2.d is to prevent criticality in the new fuel storage pool.

USAR Section 9.5.1.1 describes KPS GDC 66, Prevention of Fuel Storage Criticality, which states, in part, that criticality in the new fuel storage pit and the spent fuel storage pools shall be prevented by physical systems or processes.

Such means, as geometrically safe configurations shall be emphasized over procedural controls. The establishment of minimum spacing design requirements for the new fuel storage racks assists in meeting the requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. Furthermore, USAR Table 9.5-1 states that the center to center spacing of assemblies is 21 inches for the new fuel storage pit. This change is acceptable because it provides appropriate limits for the new fuel storage racks. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 5.2 describes the various design features of the containment. The ITS does not contain this information. This changes the CTS by moving the description of the containment to the USAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not Kewaunee Power Station Page 2 of 3 Attachment 1, Volume 15, Rev. 0, Page 12 of 20

Attachment 1, Volume 15, Rev. 0, Page 17 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 13 of 29 CTS All changes are 1 Design Features 4.0 unless otherwise noted 4.0 DESIGN FEATURES New and Spent fuel assemblies stored in the north and south pools and the 4.3 Fuel Storage (continued) canal pool in accordance with LCO 3.7.15, "Spent Fuel Pool Storage."

DOC M01 [ e. New or partially spent fuel assemblies with a discharge burnup in 4

the "acceptable range" of Figure [3.7.17-1] may be allowed unrestricted storage in [either] fuel storage rack(s), and ]

[ f. New or partially spent fuel assemblies with a discharge burnup in the "unacceptable range" of Figure [3.7.17-1] will be stored in compliance with the NRC approved [specific document containing 4 the analytical methods, title, date, or specific configuration or figure]. ]

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

5.4.a.2.a a. Fuel assemblies having a maximum U-235 enrichment of

[4.5] weight percent, 3 4.9776  ;

5.4.a.2.b b. keff 0.95 if fully flooded with unborated water, which includes an 2 allowance for uncertainties as described in [Section 9.1 of the 5 U FSAR], ; 2 3 5.4.a.2.c c. keff 0.98 if moderated by aqueous foam, which includes an 2 allowance for uncertainties as described in [Section 9.1 of the 5 U FSAR], and 2 3

21 DOC M02 d. A nominal [10.95] inch center to center distance between fuel assemblies placed in the storage racks.

4.3.2 Drainage 5

The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft].

5.4.b 4.3.3 Capacity 6 2

The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than [1737] fuel assemblies. 1205 WOG STS 4.0-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 17 of 20

Attachment 1, Volume 12, Rev. 0, Page 331 of 415 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 14 of 29 3.7.15 2

INSERT 1 the spent fuel pool shall be in accordance with the following:

a. Irradiated fuel assemblies discharged prior to or during the 1984 refueling outage with a combination of burnup and initial nominal enrichment in the "Acceptable Domain" of Figure 3.7.15-1 shall be stored in the transfer canal New fuel assemblies, spent fuel pool or the north and south combined spent fuel pools; and
b. Irradiated fuel assemblies discharged after the 1984 refueling outage and discharged prior to or during irradiated fuel assemblies with a combination of burnup and initial nominal the 1984 refueling outage enrichment in the "Unacceptable Domain" of Figure 3.7.15-1 shall be stored in the north and south combined spent fuel pools.

Insert Page 3.7.17-1 Attachment 1, Volume 12, Rev. 0, Page 331 of 415

Attachment 1, Volume 12, Rev. 0, Page 336 of 415 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 15 of 29 1

[Spent Fuel Pool Storage] 2 All changes are B 3.7.17 5 unless otherwise noted 15 B 3.7 PLANT SYSTEMS B 3.7.17 [ Spent Fuel Pool Storage ] 5 2 15 BASES INSERT 1 BACKGROUND In the Maximum Density Rack (MDR) [(Refs. 1 and 2)] design, the spent fuel storage pool is divided into two separate and distinct regions which, for the purpose of criticality considerations, are considered as separate The north and pools. [Region 1], with [336] storage positions, is designed to 990 are south pools (combined) accommodate new fuel with a maximum enrichment of [4.65] wt% U-235, 4.9776 or spent fuel regardless of the discharge fuel burnup. [Region 2], with The canal which have been stet 2 discharged prior 215 [2670] storage positions, is designed to accommodate fuel of various pool to or during the 15 initial enrichments which have accumulated minimum burnups within the 1984 refueling within the Unacceptable acceptable domain according to Figure 3.7.17-1, in the accompanying 15 2 outage and 5 Domain region LCO. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall 2 be stored in accordance with paragraph 4.3.1.1 in Section 4.3, Fuel 4 Storage. the north and south New fuel assemblies, spent pools (combined) fuel assemblies which have been discharged after the The water in the spent fuel storage pool normally contains soluble boron, 1984 outage, or spent which results in large subcriticality margins under actual operating conditions. However, the NRC guidelines, based upon the accident condition in which all soluble poison is assumed to have been lost, the spent specify that the limiting keff of 0.95 be evaluated in the absence of soluble fuel pool boron. Hence, the design of both regions is based on the use of separate pool and the three separate unborated water, which maintains each region in a subcritical condition transfer pools during normal operation with the regions fully loaded. The double canal contingency principle discussed in ANSI N-16.1-1975 and the April 1978 2

NRC letter (Ref. 3) allows credit for soluble boron under other abnormal 3 the inadvertent placement of a fresh (unirradiated) or accident conditions, since only a single accident need be considered at fuel assembly into a one time. For example, the most severe accident scenario is associated location restricted to a burned assembly with the movement of fuel from [Region 1 to Region 2], and accidental misloading of a fuel assembly in [Region 2]. This could potentially this reactivity increase the criticality of [Region 2]. To mitigate these postulated 2 the north and south combined pools criticality related accidents, boron is dissolved in the pool water. Safe all three operation of the MDR with no movement of assemblies may therefore be separate pools achieved by controlling the location of each assembly in accordance with the accompanying LCO. Prior to movement of an assembly, it is necessary to perform SR 3.7.16.1. 5 14 WOG STS B 3.7.17-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 336 of 415

Attachment 1, Volume 12, Rev. 0, Page 338 of 415 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 16 of 29

[Spent Fuel Pool Storage] 2 All changes are 1 B 3.7.17 5 15 unless otherwise noted BASES APPLICABLE The hypothetical accidents can only take place during or as a result of 3 3 SAFETY the movement of an assembly (Ref. 4). For these accident occurrences, ANALYSES the presence of soluble boron in the spent fuel storage pool (controlled by LCO 3.7.16, "Fuel Storage Pool Boron Concentration") prevents criticality Irradiated fuel assemblies discharged prior in both regions. By closely controlling the movement of each assembly to or during the 1984 refueling outage with a and by checking the location of each assembly after movement, the time combination of burnup and initial nominal period for potential accidents may be limited to a small fraction of the total enrichment in the Acceptable Domain of Figure 3.7.15-1 are allowed to be stored in operating time. During the remaining time period with no potential for the transfer canal spent fuel pool or the accidents, the operation may be under the auspices of the accompanying north and south combined spent fuel pools LCO.

New fuel assemblies, irradiated fuel spent assemblies discharged after the 1984 refueling outage, or spent The configuration of fuel assemblies in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO 15 The restrictions on the placement of fuel assemblies within the spent fuel pool, in accordance with Figure 3.7.17-1, in the accompanying LCO, 5 ensures the keff of the spent fuel storage pool will always remain < 0.95, 5

the north or south pools (combined) assuming the pool to be flooded with unborated water. Fuel assemblies in the Acceptable Domain not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance 5 4 with Specification 4.3.1.1 in Section 4.3. 15 APPLICABILITY spent This LCO applies whenever any fuel assembly is stored in [Region 2] of 2 the fuel storage pool.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

LCO 3.7.15 and When the configuration of fuel assemblies stored in [Region 2] the spent 2 15 fuel storage pool is not in accordance with Figure 3.7.17-1, or 4 5 paragraph 4.3.1.1, the immediate action is to initiate action to make the 4 necessary fuel assembly movement(s) to bring the configuration into compliance with Figure 3.7.17-1 or Specification 4.3.1.1. 5 4 LCO 3.7.15 and 15 If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

WOG STS B 3.7.17-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 338 of 415

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 17 of 29 Licensee Response/NRC Response/NRC Question Closure Id 2001 NRC Question ALK-007 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 2/2/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Audrey Klett Added By Audrey Klett Date Added 2/2/2010 8:48 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2001 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 18 of 29 ITS NRC Questions Id 1451 NRC Question ALK-008 Number Category Technical ITS Section 4.0 ITS Number 4.0 DOC Number JFD Number 5 JFD Bases Number Page Vol. 15; page 17 of 20 Number(s)

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

Requested NRC KPS proposed to not adopt STS 4.3.2 regarding drainage of the spent fuel storage pool Question (SFP), which states, The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft]. Although the SFP may be designed to prevent inadvertent draining, the STS also require that the pool be maintained to prevent inadvertent draining of the SFP below [23 ft]. STS 4.3.2 also appears to be applicable when fuel is present in the SFP, regardless of whether or not there is movement of irradiated fuel assemblies in the SFP. Without this design feature requirement, there is no TS requirement to maintain SFP level for when KPS ITS LCO 3.7.13 is not applicable.

Although KPS stated that the current TS have no requirements for SFP level, the current KPS TS 5.4.3 requires, in part, that the SFP is filled with borated water whenever there is fuel in the pool.

Given the available operating experience associated with the draining of SFPs, ITSB staff is concerned about: (1) the effect on the SFP level if the check valves in the SFP cooling return lines failed and how the failure would be identified; (2) how defects or cracks in the SFP liner would be identified; (3) how the licensee verifies the SFP level in accordance with the analysis in Revision 21.5 of the KPS USAR, Section 9.5.3.1.2, which credits 20 feet (or 25 feet, which needs clarification) of water covering the spent fuel as protection for the fuel from tornado missiles; and (4) what level is required to be maintained in the SFP at all times for radiation protection purposes. The NRC staff is requesting a teleconference with Kewaunee staff regarding adopting STS 4.3.2 in the KPS ITS.

Attach File 1

Attach File 2

Issue Date 1/6/2010 Added By Audrey Klett http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1451 06/02/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 19 of 29 Date Modified Modified By Date Added 1/6/2010 4:04 PM Notification NRC/LICENSEE Supervision Audrey Klett http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1451 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 20 of 29 Licensee Response/NRC Response/NRC Question Closure Id 1821 NRC Question ALK-008 Number Select Licensee Response Application

Response

1/20/2010 10:45 AM Date/Time Closure Statement Response After further review, Kewaunee Power Station will add this new Statement requirement into the ITS. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 ALK-008 Markup.pdf (803KB)

Attachment 2 Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 1/20/2010 10:47 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1821 06/02/2010

Attachment 1, Volume 15, Rev. 0, Page 8 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 21 of 29 ITS A01 ITS 4.0 5.4 FUEL STORAGE APPLICABILITY Applies to the capacity and storage arrays of new and spent fuel.

OBJECTIVE To define those aspects of fuel storage relating to prevention of criticality in fuel storage areas.

SPECIFICATION

a. Criticality
1. The spent fuel storage racks are designed and shall be maintained with the following:

4.3.1.1.a a. Fuel assemblies having a maximum enrichment of 56.067 grams Uranium-235 per axial centimeter 4.9776 weight percent A02 4.3.1.1.b b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties Add proposed 4.3.1.1.c, 4.3.1.1.d, and 4.3.1.1.e M01

2. The new fuel storage racks are designed and shall be maintained with:

4.3.1.2.a a. Fuel assemblies having a maximum enrichment of 56.067 grams Uranium-235 per axial centimeter 4.9776 weight percent A02 4.3.1.2.b b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties 4.3.1.2.c c. keff < 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties Add proposed 4.3.1.2.d M02

3. The spent fuel pool is filled with borated water at a concentration to match that used See ITS in the reactor REFUELING cavity and REFUELING canal during REFUELING 3.7.14 OPERATIONS or whenever there is fuel in the pool.

Add proposed 4.3.2

b. Capacity M03 4.3.2 3 The spent fuel storage pool is designed with a storage capacity of 1205 assemblies and shall be limited to no more than 1205 fuel assemblies.
c. Canal Rack Storage Fuel assemblies stored in the canal racks shall meet the minimum required fuel assembly burnup as a function of nominal initial enrichment as shown in See ITS 3.7.15 Figure TS 5.4-1. These assemblies shall also have been discharged prior to or during the 1984 REFUELING outage.

Amendment No. 162 TS 5.4-1 09/19/2002 Page 5 of 7 Attachment 1, Volume 15, Rev. 0, Page 8 of 20

Attachment 1, Volume 15, Rev. 0, Page 12 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 22 of 29 DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. This change is acceptable because it provides appropriate limits for the spent fuel storage racks.

The purpose of ISTS 4.3.1.1.e is to provide requirements for loading spent fuel assemblies in accordance with ISTS Figure 3.7.15-1 into the appropriate spent fuel pool. License Amendment 150 allows KPS to store only those spent fuel assemblies prior to or from the 1984 refueling outage in the Canal Pool storage racks. The design of the Canal Pool is fixed and the storage of spent fuel assemblies is restricted by the licensing requirements of License Amendment 150. Therefore, ITS 4.3.1.1.e has been revised to state that the spent fuel assemblies in both the North and South Pools and the Canal Pool shall be in accordance with LCO 3.7.15. LCO 3.7.15 is more applicable for placement of the requirements of the spent fuel assemblies in the spent fuel pools at KPS than ITS 4.0. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

M02 ITS 4.3.1.2.d requires that new fuel storage racks are designed and maintained to have a nominal 21 inch center to center distance between fuel assemblies in order to prevent criticality of the spent fuel assemblies. The CTS does not contain this information. This changes the CTS by adding specific requirements for the design and maintenance of the new fuel storage racks.

The purpose of ITS 4.3.1.2.d is to prevent criticality in the new fuel storage pool.

USAR Section 9.5.1.1 describes KPS GDC 66, Prevention of Fuel Storage Criticality, which states, in part, that criticality in the new fuel storage pit and the spent fuel storage pools shall be prevented by physical systems or processes.

Such means, as geometrically safe configurations shall be emphasized over procedural controls. The establishment of minimum spacing design requirements for the new fuel storage racks assists in meeting the requirements of GDC 66 and provides assurance that no incident could occur that would result in a hazard to public health and safety. Furthermore, USAR Table 9.5-1 states that the center to center spacing of assemblies is 21 inches for the new fuel storage pit. This change is acceptable because it provides appropriate limits for the new fuel storage racks. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

Insert DOC M03 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 5.2 describes the various design features of the containment. The ITS does not contain this information. This changes the CTS by moving the description of the containment to the USAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not Kewaunee Power Station Page 2 of 3 Attachment 1, Volume 15, Rev. 0, Page 12 of 20

Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 23 of 29 M03 ITS 4.3.2 requires that spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 645 ft 2 inches (mean sea level).

The CTS does not contain this information. This changes the CTS by adding a new requirement for the design and maintenance of the spent fuel storage pool.

The purpose of ITS 4.3.2 is to prevent the spent fuel pool from being inadvertently drained such that an unanalyzed criticality event could occur in the spent fuel storage pool. USAR Table 9.5-2, Item 6 describes the KPS design conformance to Safety Guide

13. The proposed water level ensures this design conformance requirement is maintained. This change is acceptable because it provides an appropriate design requirement to prevent inadvertent draining of the spent fuel storage pool. This change is designated more restrictive because requirements have been added to the ITS that do not exist in the CTS.

Attachment 1, Volume 15, Rev. 0, Page 17 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 24 of 29 CTS All changes are 1 Design Features 4.0 unless otherwise noted 4.0 DESIGN FEATURES Spent fuel assemblies stored in the north and south pools and the 4.3 Fuel Storage (continued) canal pool in accordance with LCO 3.7.15, "Spent Fuel Pool Storage."

DOC M01 [ e. New or partially spent fuel assemblies with a discharge burnup in 4

the "acceptable range" of Figure [3.7.17-1] may be allowed unrestricted storage in [either] fuel storage rack(s), and ]

[ f. New or partially spent fuel assemblies with a discharge burnup in the "unacceptable range" of Figure [3.7.17-1] will be stored in compliance with the NRC approved [specific document containing 4 the analytical methods, title, date, or specific configuration or figure]. ]

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

5.4.a.2.a a. Fuel assemblies having a maximum U-235 enrichment of

[4.5] weight percent, 3 4.9776  ;

5.4.a.2.b b. keff 0.95 if fully flooded with unborated water, which includes an 2 allowance for uncertainties as described in [Section 9.1 of the 5 U FSAR], ; 2 3 5.4.a.2.c c. keff 0.98 if moderated by aqueous foam, which includes an 2 allowance for uncertainties as described in [Section 9.1 of the 5 U FSAR], and 2 3

21 DOC M02 Stet w/changes
d. A nominal [10.95] inch center to center distance between fuel assemblies placed in the storage racks.

4.3.2 Drainage 5

The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft].

Stet 5.4.b 4.3.3 Capacity 645 ft 2 inches (mean sea level) 6 2

The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than [1737] fuel assemblies. 1205 WOG STS 4.0-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 17 of 20

Attachment 1, Volume 15, Rev. 0, Page 18 of 20 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 25 of 29 JUSTIFICATION FOR DEVIATIONS ITS 4.0, DESIGN FEATURES

1. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.
2. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.
4. The spent fuel pool configuration at Kewaunee Power Station (KPS) consists of North and South Pools and a Canal Pool. Spent fuel assemblies of varying enrichment may be stored in the North and South Pools. However, with the creation of the Canal Pool, limitations on the enrichment of the spent fuel that could be stored in the Canal Pool were imposed via License Amendment 150 dated January 23, 2001 (ADAMS accession No. ML010240051). License Amendment 150 states that only assemblies which have been discharged prior to or during the 1984 refueling outage are permitted to be stored in the Canal Pool.

License Amendment 150 also utilized the concept of burnup reactivity equivalencing for the storage of the spent fuel in the Canal Pool. This concept is based on the reactivity decrease associated with fuel depletion and has been previously found acceptable by the NRC for use in PWR fuel storage analysis. A series of reactivity calculations is performed to generate a set of enrichment versus burnup ordered pairs which yield an equivalent k-eff of less than 0.95 (approximately 0.945) for fuel stored in the storage racks. The requirements of ISTS 4.3.1.1.e and 4.3.1.1.f, which address the applicable discharge burnup limitations, are addressed in LCO 3.7.15, "Spent Fuel Pool Storage," for the KPS ITS.

5. ISTS 4.3.2 states the spent fuel pool is designed and shall be maintained to prevent inadvertent draining of the pool. The information in Item 6 of Kewaunee Power Station (KPS) Updated Safety Analysis Report (USAR) Table 9.5-2, "Design Conformance with Safety Guide 13," reflects that no drains have been provided for the spent fuel storage pool. In addition, the USAR states that since the pump suction connections extend no more than two feet below normal water level, there is also no possibility of inadvertently draining pool water below that level. As an additional measure to ensure against inadvertent draining of the spent fuel pool by a siphon effect, each spent fuel pool cooling return line contains a check valve to prevent reverse flow. Therefore, the information in ISTS 4.3.2 has been deleted as it is considered not applicable to the design of KPS.
6. ISTS 4.3.2 has been deleted as discussed in Justification For Deviations (JFD) 5.

As a result, Section 4.3.3 has been appropriately renumbered.

Kewaunee Power Station Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 18 of 20

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 26 of 29 Licensee Response/NRC Response/NRC Question Closure Id 1991 NRC Question ALK-008 Number Select NRC Response Application

Response

2/2/2010 6:00 PM Date/Time Closure Statement Response The level in WOG STS 4.3.2 corresponds to [23 feet] over the top of irradiated fuel Statement assemblies. KPS proposed a value corresponding to 645'2" (mean sea level). Please clarify why this level was chosen and how many feet over the top of irradiated fuel assemblies this level corresponds to.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Audrey Klett Added By Audrey Klett Date Added 2/2/2010 8:41 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1991 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 27 of 29 Licensee Response/NRC Response/NRC Question Closure Id 2171 NRC Question ALK-008 Number Select Licensee Response Application

Response

2/15/2010 3:45 PM Date/Time Closure Statement

Response

Statement ISTS 4.3.2, "Drainage" states "The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation [23 ft.]" The 23 ft limit is in brackets and it does not specifically state the 23 ft limit is 23 ft above the top of the irradiated fuel assemblies.

It uses the term "elevation," which implies a level based on an external value, such as mean sea level. The bracketed requirement means that KPS is to put in the plant specific design requirement for the KPS spent fuel storage pool.

Kewaunees design is discussed in the following USAR references.

UFSAR Section 9.3.4.2.3, Leakage Provisions, Spent Fuel Pool Cooling states: Since the pump suction connections extend no more than 2 feet below normal water level, there is no possibility of inadvertently draining pool water below that level. UFSAR 9.3.4.3.3, Incident Control, Spent Fuel Pool Cooling states: The possibility of a line failure causing complete drainage is precluded by the fact that the suction lines do not extend more than 2 feet below normal operating level. This leaves a margin of 22 feet above the top of the fuel assemblies.

From UFSAR Figure 9.5-2, Spent Fuel Pool and New Fuel Storage Plan (drawing M-234), Detail X, Skimmer Intake, the elevation at which pump suction is lost (bottom of the skimmer intake) is 645 feet 2 inches.

Therefore, the elevation of 645 feet 2 inches is the elevation KPS specifies in ITS 4.3.2, Drainage, associated with system design.

Regarding relative elevations:

649 6 Refueling Floor 647 4 SFP High Level Alarm

< 647 4 > 646 2 Normal SFP level 646 2 SFP Low Level Alarm 645 6 23 feet above fuel 645 2 Bottom of Skimmer Intake 644 6 22 feet above fuel 622 6 Top of the fuel 608 Spent Fuel Pool floor As shown above, an elevation of 645 2 is 22 8 above the top of the fuel.

http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2171 06/02/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 28 of 29 Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 2/15/2010 3:47 PM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2171 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 15 (Chapter 4.0) Page 29 of 29 Licensee Response/NRC Response/NRC Question Closure Id 2531 NRC Question ALK-008 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 3/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Audrey Klett Added By Audrey Klett Date Added 3/12/2010 7:54 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2531 06/02/2010

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