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Attachment 1 - Volume 7, Kewaunee Power Station, Improved Technical Specifications Conversion, ITS Section 3.2, Power Distribution Limits, Revision 0
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Issue date:	08/24/2009
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ATTACHMENT 1 VOLUME 7 KEWAUNEE POWER STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 0

, Volume 7, Rev. 0, Page 1 of 102, Volume 7, Rev. 0, Page 1 of 102

LIST OF ATTACHMENTS

1.

ITS 3.2.1

2.

ITS 3.2.2

3.

ITS 3.2.3

4.

ITS 3.2.4

, Volume 7, Rev. 0, Page 2 of 102, Volume 7, Rev. 0, Page 2 of 102

ATTACHMENT 1 ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z)), Volume 7, Rev. 0, Page 3 of 102, Volume 7, Rev. 0, Page 3 of 102

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 7, Rev. 0, Page 4 of 102, Volume 7, Rev. 0, Page 4 of 102

3.10 CONTROL ROD AND POWER DISTRIBUTION LIMITS APPLICABILITY Applies to the limits on core fission power distributions and to the limits on control rod operations.

OBJECTIVE To ensure: 1) core subcriticality after reactor trip, 2) acceptable core power distribution during power operation in order to maintain fuel integrity in normal operation transients associated with faults of moderate frequency, supplemented by automatic protection and by administrative procedures, and to maintain the design basis initial conditions for limiting faults, and 3) limited potential reactivity insertions caused by hypothetical control rod ejection.

SPECIFICATION

a.

Shutdown Reactivity When the reactor is subcritical prior to reactor startup, the SHUTDOWN MARGIN shall be at least that as specified in the COLR

b.

Power Distribution Limits

1. At all times, except during Low Power Physics Tests, the hot channel factors defined in the basis must meet the following limits:

A. FQ N(Z) Limits shall be as specified in the COLR.

B. FH N Limits shall be as specified in the COLR.

2. If FH N not within limits:

A. Perform the following:

i.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months either, restore FH N to within its limit or reduce thermal power to less than 50% of RATED POWER.

ii. Reduce the Power Range Neutron Flux-High Trip Setpoint to 55% of RATED POWER within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

iii. Verify FH N within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

B. If the actions of TS 3.10.b.2.A are not completed within the specified time, then reduce thermal power to 5% of rated power within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ITS A01 ITS 3.2.1 Page 1 of 3 ITS A01 ITS A01 See ITS 3.1.1 A02 Applicability LCO 3.2.1 See ITS 3.2.2 See ITS 3.2.2 Amendment No. 167 TS 3.10-1 04/04/2003, Volume 7, Rev. 0, Page 5 of 102, Volume 7, Rev. 0, Page 5 of 102

A01 ITS 3.2.1 ITS C. Identify and correct the cause of the out-of-limit condition prior to increasing thermal power above the reduced thermal power limit required by action A and/or B, above.

Subsequent power increases may proceed provided that FH N is demonstrated, through incore flux mapping, to be within its limits prior to exceeding the following thermal power levels:

i.

50% of RATED POWER, ii. 75% of RATED POWER, and iii. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining 95% of RATED POWER See ITS 3.2.2

3. If the FQ N(Z) equilibrium relationship is not within its limit:

A. Reduce the thermal power 1% RATED POWER for each 1% the FQ N(Z) equilibrium relationship exceeds its limit within 15 minutes after each determination and similarly reduce the Power Range Neutron Flux-High Trip Setpoints and the Overpower T Trip Setpoints within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by 1% for each 1% FQ N(Z) equilibrium relationship exceeds its limit.

ACTION A ACTION C B. If the actions of TS 3.10.b.3.A are not completed within the specified time, then reduce thermal power to 5% of RATED POWER within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

C. Verify the FQ N(Z) equilibrium relationship and the FQ N(Z) transient relationships are within limits prior to increasing thermal power above the reduced thermal power limit required by action A, above.

Required Action A.4 and Note to Condition A

4. Power distribution maps using the movable detection system shall be made to confirm that the hot channel factor limits of TS 3.10.b.1 are satisfied. (Note: time requirements may be extended by 25%)

LA01 A. For FQ N(Z) equilibrium relationship, once after each refueling prior to thermal power exceeding 75% of RATED POWER; and once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions, after exceeding, by 10% of RATED POWER, the thermal power at which the FQ N(Z) equilibrium relationship was last verified; and 31 effective full power days thereafter.

Add proposed Surveillance Requirements Note A04 A03 SR 3.2.1.1 B. For FH N, following each refueling prior to exceeding 75% RATED POWER and 31 effective full power days thereafter.

See ITS 3.2.2

5. The measured FQ N(Z) under equilibrium conditions shall satisfy the FQ N(Z) transient relationship for the central axial 80% of the core as specified in the COLR.

LCO 3.2.1

6. Power distribution maps using the movable detector system shall be made to confirm the transient relationship of FQ N(Z) specified in the COLR according to the following schedules with allowances for a 25% grace period:

LA01 A03 A. Once after each refueling prior to exceeding 75% RATED POWER and every 31 effective full power days thereafter.

Add proposed Surveillance Requirements Note A04 SR 3.2.1.2 B. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving equilibrium conditions after reaching a thermal power level > 10% higher than the power level at which the last power distribution measurement was performed in accordance with TS 3.10.b.6.A.

M01 Amendment No. 196 TS 3.10-2 03/28/2008 Page 2 of 3, Volume 7, Rev. 0, Page 6 of 102, Volume 7, Rev. 0, Page 6 of 102

A01 ITS 3.2.1 ITS C. If a power distribution map measurement indicates that the FQ N(Z) transient relationships margin to the limit, as specified in the COLR, has decreased since the previous evaluation, then either of the following actions shall be taken:

L01

i.

FQ N(Z) transient relationship shall be increased by the penalty factor specified in the COLR for comparison to the transient limit as specified in the COLR and reverified within the transient limit, or SR 3.2.1.2 Note ii.

Repeat the determination of the FQ N(Z) transient relationship once every seven effective full-power days until either i. above is met, or two successive maps indicate that the FQ N(Z) transient relationships margin to the transient limit has not decreased.

7. If, for a measured FQ N(Z), the transient relationship of FQ N(Z) specified in the COLR is not within limits, then take the following actions:

A. Reduce the axial flux difference limits 1% for each 1% the FQ N(Z) transient relationship exceeds its limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each determination and similarly reduce the Power Range Neutron Flux-High Trip Setpoints and Overpower T Trip Setpoints within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by 1% that the maximum allowable power of the axial flux difference limits is reduced.

ACTION B B. If the actions of TS 3.10.b.7.A are not completed within the specified time, then reduce thermal power to 5% of rated power within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION C C. Verify the FQ N(Z) equilibrium relationship and the FQ N(Z) transient relationship are within limits prior to increasing thermal power above the reduced thermal power limit required by action A, above.

Required Action B.4 and Note to Condition B

8. Axial Flux Difference NOTE: The axial flux difference shall be considered outside limits when two or more operable excore channels indicate that axial flux difference is outside limits.

A.

During power operation with thermal power 50 percent of RATED POWER, the axial flux difference shall be maintained within the limits specified in the COLR.

i.

If the axial flux difference is not within limits, reduce thermal power to less than 50% RATED POWER within 30 minutes.

See ITS 3.2.3 Amendment No. 196 TS 3.10-3 03/28/2008 Page 3 of 3, Volume 7, Rev. 0, Page 7 of 102, Volume 7, Rev. 0, Page 7 of 102

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

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).

Furthermore, it should be noted that the terms

( )

Z FN Q

( )

Z FN Q

equilibrium, and transient are being changed to

( )

Z FN Q

( )

Z FQ

( )

Z C

Q F

, and

( )

Z FT Q

respectively.

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

A02 CTS 3.10.b.1 requires the CTS 3.10.b.1.A

( )

Z FN Q

limits to be met "at all times, except during Low Power Physics Tests." However, CTS 3.10.b.3.B and 3.10.b.7.B, which provides the actions when the

( )

Z FN Q

limits are not met, only requires the unit to reduce reactor power to 5% RTP. ITS 3.2.1 requires the FQ(Z) limits to be met in MODE 1, with no exception for low power physics tests.

This changes the CTS by clearly stating the Applicability of the limits to be consistent with the actions.

( )

Z FN Q

The purpose of the FQ(Z) Specification is to limit the local peak power density.

This is essentially a MODE 1 limit, since the reactor must be at power for this limit to be exceeded. While the CTS requires the

( )

Z FN Q

limits to be met at all times, the actions only requires reducing power to 5% RTP, which meets the intent of the LCO requirement and is consistent with the THERMAL POWER limit for MODE 1 operations in the ITS. Furthermore, the CTS previously defined OPERATING as 2% RTP. Since Low Power Physics Tests could be performed at up to 5% RTP, the exception was needed. Since the ITS now defines MODE 1 as > 5% RTP, a Low Power Physics Test exception is not needed. This change is acceptable since the requirements have not changed; if the LCO is not met, power is required to be reduced to 5% RTP (i.e., MODE 2). This change is designated as administrative since it does not result in any technical changes.

A03 CTS 3.10.b.4 provides the Surveillance Requirement for periodically verifying equilibrium relationship is within limit. A Note to CTS 3.10.b.4 states that the time requirements may be extended by 25%. ITS SR 3.2.1.1, which confirms the equilibrium relationship is within limits (i.e., the

( )

Z FN Q

FN Q( )

Z

( )

Z FC Q

limit), does not include this specific allowance. CTS 3.10.b.6 provides the Surveillance Requirement for periodically verifying

( )

Z FN Q

transient relationship is within limit and includes a similar allowance for a 25% grace period. ITS SR 3.2.1.2, which confirms the transient relationship is within limit (i.e., the limit), does not include this specific allowance. This change deletes the specific 25%

allowance of CTS 3.10.b.4 and 3.10.b.6.

( )

Z FN Q

( )

Z T

Q F

Kewaunee Power Station Page 1 of 4, Volume 7, Rev. 0, Page 8 of 102, Volume 7, Rev. 0, Page 8 of 102

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

This change is acceptable since ITS SR 3.0.2 provides the same allowance. ITS SR 3.0.2 provides a 25% grace period for all periodic Surveillances, not just this specific one. This change is considered administrative since it does not result in any technical changes.

A04 CTS 3.10.b.4 provides the Surveillance Requirement for periodically verifying equilibrium relationship is within limit. CTS 3.10.b.4.A requires the Surveillance to be performed once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving equilibrium conditions, after exceeding, by

( )

Z FN Q

> 10% of RATED POWER, the thermal power at which the equilibrium relationship was last verified. CTS 3.10.b.6 provides the Surveillance Requirement for periodically verifying

( )

Z FN Q

( )

Z FN Q

transient relationship is within limit. CTS 3.10.b.6.B requires the Surveillance to be performed once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving equilibrium conditions after reaching a thermal power level > 10% higher than the power level at which the last power distribution measurement was performed in accordance with CTS 3.10.b.6.A.

ITS SR 3.2.1.1 and SR 3.2.1.2 require similar Surveillances, except both SRs are modified by a Note to the Surveillance Requirements Table which states that during power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained. This changes the CTS by clearly stating that 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit to perform the 10% RTP power change Frequency for verifying the equilibrium relationship and the (Z)

FN Q

( )

Z FN Q

transient relationship only starts after equilibrium power is attained - not immediately after a 10% RTP power change.

The purpose of this Surveillance Frequency is to determine the equilibrium and transient relationships are within limit after a THERMAL POWER change that could affect the value. This change is acceptable since it clarifies the current requirement in that equilibrium power must be first obtained before the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit starts. Furthermore, this is acceptable since another required Frequency (once after each refueling prior to thermal power exceeding 75% of RATED POWER required by CTS 3.10.b.4.A and 3.10.b.6.A) ensures the limits are verified before reaching 100% RTP. This change is considered administrative since it does not result in any technical changes.

( )

Z FN Q

MORE RESTRICTIVE CHANGES M01 CTS 3.10.b.6 provides the Surveillance Requirement for periodically verifying transient relationship is within limit. CTS 3.10.b.6.B requires the Surveillance to be performed once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving equilibrium conditions after reaching a thermal power level > 10% higher than the power level at which the last power distribution measurement was performed in accordance with CTS 3.10.b.6.A. ITS SR 3.2.1.2, which requires a similar Surveillance Requirement, is required after a THERMAL POWER change of

( )

Z FN Q

Kewaunee Power Station Page 2 of 4, Volume 7, Rev. 0, Page 9 of 102, Volume 7, Rev. 0, Page 9 of 102

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

> 10% RTP. This changes the CTS by requiring the Surveillance to be performed after a power change of > 10% RTP, in lieu of > 10% RTP.

The purpose of this Surveillance Frequency is to determine the transient relationship is within limit after a THERMAL POWER change that could affect the value. This change is acceptable since it requires the Surveillance to be performed after a slightly lower power change, i.e.,

( )

Z FN Q

> 10% RTP in lieu of the current > 10% RTP. This change is more restrictive since it is now required to be performed under more conditions in the ITS than in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.10.b.4 requires the

( )

Z FN Q

equilibrium relationship to be determined to be within its limit by using the movable incore detectors to obtain a power distribution map. ITS SR 3.2.1.1 just requires verification that (i.e., the equilibrium relationship) is within its limit.

CTS 3.10.b.6 requires the

( )

Z FC Q

( )

Z FN Q

transient relationship to be determined to be within its limit by using the movable incore detectors to obtain a power distribution map. ITS SR 3.2.1.2 just requires verification that (i.e., the transient relationship) is within its limit. This changes the CTS by relocating to the ITS Bases the manner in which the

( )

Z FT Q

( )

Z FN Q

equilibrium and transient relationship determination is performed.

The removal of these details for performing actions and a Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to determine

( )

Z FC Q

and

( )

Z FT Q

are within limits. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

Kewaunee Power Station Page 3 of 4, Volume 7, Rev. 0, Page 10 of 102, Volume 7, Rev. 0, Page 10 of 102

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

Kewaunee Power Station Page 4 of 4 LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation of Surveillance Frequency) CTS 3.10.b.6.C requires an additional Surveillance Frequency to verify

the Z

F transient limit is within the limit specified in the COLR i

NQ f the Z

F transient relationship's margin to the limit decreases since the previous evaluation. ITS SR 3.2.1.2 maintains this additional Frequency as specified in the Note to the SR, but ties it to

NQ the Z

F equilibrium (i.e.,

) relationship's margin to the limit. This changes the CTS by requiring the additional Surveillance Frequency i

NQ

( )

Z FC Q

f the Z

F equilibrium relationship's margin to the limit decreases since the previous evaluation in lieu o NQ f the

Z

F transient relationship's margin to the limit.

NQ The purpose of the CTS 3.10.b.6.C additional Surveillance Frequency is to ensure that if the margin decreases

, the Z

F transient limit will not exceed the limit specified in the COLR prior to the next routine verification. The current requirements in this case allow for either a penalty factor to be applied to trans

NQ ient Z

F and for trans

NQ ient Z

F to be reverified to be within limits, or for more frequent FQ N(z) transient limit verification. Either of these alternative requirements prevent trans

NQ Z

ient

F from exceeding its limit for any significant period of time without detection. ITS SR 3.2.1.2 maintains this additional Frequency as specified in the Note to the SR, and includes equivalent requirements. However, ITS SR 3.2.1.2 bases the test of decrea

NQ sing Z

F margin on equilib

NQ rium Z

F rather than transient FQ N(z) as in CTS 3.10.b.6.C.

This change is acceptable since the additional Surveillance test requirement in the ITS SR 3.2.1.2 Note is an essentially equivalent test of decreasing FQ margin, since the equilibrium and trans

NQ ient Z

F values are both based on the same measu

NQ red Z

F

. Therefore any difference between the two test results would be due to only differences in the applied N(Z) transient multiplier for two consecutive Surveillances. Under the Dominion RPDC methodology (DOM-NAF-5), the N(Z) transient FQ multiplier changes relatively slowly with core burnup.

Hence, a decrea

NQ sing Z

F margin test based on equilib

NQ rium Z

F will most often yield the same result as a test based on transient NQ

Z

F

. However, a decrea

NQ sing Z

F margin test based on equilib

NQ rium Z

F could result in the same, slightly less, or slightly more margin change than a test based on transient

NQ Z

F NQ

. The different test results could therefore result in the same, a less restrictive, or a more restrictive determination of decreasing margin with corresponding differences in the Actions. This change is designated as less restrictive since the ITS may allow a current Surveillance to be performed less frequently than is currently required.

, Volume 7, Rev. 0, Page 11 of 102, Volume 7, Rev. 0, Page 11 of 102

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 12 of 102, Volume 7, Rev. 0, Page 12 of 102

FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-1 Rev. 3.0, 03/31/04 CTS 1

3.2 POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology)

LCO 3.2.1B FQ(Z), as approximated by F and F

, shall be within the limits specified in the COLR.

)

Z

(

C Q

)

Z

(

Q W

T 5

3.10.b.1.A APPLICABILITY:

MODE 1.

3.10.b.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

Required Action A.4 shall be completed whenever this Condition is entered.

A.

not within limit.

)

Z

(

FC Q

)

Z

(

C Q

A.1 Reduce THERMAL POWER 1% RTP for each 1% F exceeds limit.

AND A.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% F exceeds limit.

)

Z

(

C Q

AND A.3 Reduce Overpower T trip setpoints 1% for each 1% F exceeds limit.

)

Z

(

C Q

AND A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

15 minutes after each determination

)

Z

(

FC Q

)

Z

(

FC Q

)

Z

(

FC Q

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each determination Prior to increasing THERMAL POWER above the limit of Required Action A.1 3.10.b.3, 3.10.b.3.A, 3.10.b.3.C, Volume 7, Rev. 0, Page 13 of 102, Volume 7, Rev. 0, Page 13 of 102

FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-2 Rev. 3.0, 03/31/04 CTS 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

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

Required Action B.4 shall be completed whenever this Condition is entered.

B.

not within limits.

)

Z

(

FQ

)

Z

(

Q B.1 Reduce AFD limits 1% for each 1% F exceeds limit.

W W

AND B.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1%

that the maximum allowable power of the AFD limits is reduced.

AND B.3 Reduce Overpower T trip setpoints 1% for each 1%

that the maximum allowable power of the AFD limits is reduced.

AND B.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits C. Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 5

T T

3.10.b.7, 3.10.b.7.A, 3.10.b.7.C 5

3.10.b.3.B, 3.10.b.7.B

, Volume 7, Rev. 0, Page 14 of 102, Volume 7, Rev. 0, Page 14 of 102

FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-3 Rev. 3.0, 03/31/04 1

SURVEILLANCE REQUIREMENTS

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

During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.

SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify is within limit.

)

Z

(

FC Q

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within

[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which Q

was last verified

)

Z

(

FC AND 31 EFPD thereafter 3.10.b.4, 3.10.b.4.A 3.10.b.4.A, 3.10.b.6.A CTS 4, Volume 7, Rev. 0, Page 15 of 102, Volume 7, Rev. 0, Page 15 of 102

CTS FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-4 Rev. 3.0, 03/31/04 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2

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

If measurements indicate that the maximum over z [ F

/ K(Z) ]

)

Z

(

C Q

)

Z

(

FC Q

)

Z

)

Z

(

W Q

)

Z

(

C Q

)

Z Q

has increased since the previous evaluation of

a. Increase

(

FQ by the greater of a factor of

[1.02] or by an appropriate factor specified in the COLR and reverify F is within limits or W

b. Repeat SR 3.2.1.2 once per 7 EFPD until either

a. above is met or two successive flux maps indicate that the maximum over z [F

/ K(Z) ]

has not increased.

Once after each refueling prior to THERMAL POWER exceed-ing 75% RTP AND Once within

[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which Q

was last verified Verify

(

F is within limit.

W

)

Z

(

FW AND 31 EFPD thereafter 3.10.b.6.C 3.10.b.6, 3.10.b.6.A, 3.10.b.6.B T

T T

5 2

5 3

5 4

T 5, Volume 7, Rev. 0, Page 16 of 102, Volume 7, Rev. 0, Page 16 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

1. The type of methodology (Relaxed Axial Offset Control (RAOC) - W(Z) Methodology) and the Specification designator "B" are deleted since they are unnecessary (only one FQ(Z) Specification is used in the Kewaunee Power Station (KPS) ITS). This information is provided in NUREG-1431, Revision 3.0, to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-Fxy and RAOC-W(Z) methodology Specifications (ISTS 3.2.1A and 3.2.1C) are not used and are not shown.

2. The ISTS SR 3.2.1.2 Note, part "a" requirement to increase the limit by "the greater of a factor of [1.02] or by" an appropriate factor specified in the COLR has been changed to delete the 1.02 requirement. The CTS provides the value in the COLR, and it is currently 2% (i.e., 1.02). Thus, since the value is consistent with the value in the COLR, the additional limit is not required.

3. This punctuation correction has been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. 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 requirements, as shown in CTS 3.10.b.4.A and 3.10.b.6.B.

5. KPS is changing from the Westinghouse RAOC methodology to the Dominion Relaxed Power Distribution Control (RPDC) methodology. The RPDC methodology, DOM-NAF-5-0.0.A, is one of the analytical methods listed in the COLR requirements (CTS 6.9.a.4.B.(16)). Therefore, the terminology has been changed to reflect the Dominion preferred terminology.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 17 of 102, Volume 7, Rev. 0, Page 17 of 102

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 18 of 102, Volume 7, Rev. 0, Page 18 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-1 Rev. 3.0, 03/31/04 1

)

Z Q

B 3.2 POWER DISTRIBUTION LIMITS 1

B 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology)

BASES BACKGROUND The purpose of the limits on the values of FQ(Z) is to limit the local (i.e., pellet) peak power density. The value of FQ(Z) varies along the axial height (Z) of the core.

FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions. Therefore, FQ(Z) is a measure of the peak fuel pellet power within the reactor core.

During power operation, the global power distribution is limited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO(QPTR)," which are directly and continuously measured process variables. These LCOs, along with LCO 3.1.6, "Control Bank Insertion Limits," maintain the core limits on power distributions on a continuous basis.

FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution.

FQ(Z) is measured periodically using the incore detector system. These measurements are generally taken with the core at or near equilibrium conditions.

Using the measured three dimensional power distributions, it is possible to derive a measured value for FQ(Z). However, because this value represents an equilibrium condition, it does not include the variations in the value of FQ(Z) which are present during nonequilibrium situations such as load following or power ascension.

To account for these possible variations, the equilibrium value of FQ(Z) is adjusted as F by an elevation dependent factor that accounts for the calculated worst case transient conditions.

(

W T

10 Core monitoring and control under non-equilibrium conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion., Volume 7, Rev. 0, Page 19 of 102, Volume 7, Rev. 0, Page 19 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-2 Rev. 3.0, 03/31/04 1

BASES APPLICABLE This LCO precludes core power distributions that violate the following SAFETY fuel design criteria:

ANALYSES

a.

During a large break loss of coolant accident (LOCA), the peak cladding temperature must not exceed 2200°F (Ref. 1),

2

b.

During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a departure from nucleate boiling (DNB) condition,

c.

During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and

d.

The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (Ref. 3).

maximum average fuel pellet enthalpy at the hot spot must remain below 200 cal/gm 2

3 INSERT 1 11 12 2

Limits on FQ(Z) ensure that the value of the initial total peaking factor assumed in the accident analyses remains valid. Other criteria must also be met (e.g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling). However, the peak cladding temperature is typically most limiting.

FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the FQ(Z) limit assumed in safety analyses for other postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents FQ(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The Heat Flux Hot Channel Factor, FQ(Z), shall be limited by the following relationships:

FQ(Z) (CFQ / P) K(Z) for P > 0.5 FQ(Z) (CFQ / 0.5) K(Z) for P 0.5 where: CFQ is the FQ(Z) limit at RTP provided in the COLR, K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and P = THERMAL POWER / RTP

, Volume 7, Rev. 0, Page 20 of 102, Volume 7, Rev. 0, Page 20 of 102

ITS B 3.2.1 12 INSERT 1 One of the reactivity control systems provided shall be capable of making the core subcritical under any anticipated operating condition (including anticipated operational transients) sufficiently fast enough to prevent exceeding acceptable fuel damage limits.

SDM should assure subcriticality with the most restrictive rod cluster control assembly (RCCA) fully withdrawn Insert Page B 3.2.1B-2, Volume 7, Rev. 0, Page 21 of 102, Volume 7, Rev. 0, Page 21 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-3 Rev. 3.0, 03/31/04 1

FC Q

)

Z

)

Z

(

C Q

)

Z

)

Z Q

)

Z

(

FC Q

)

Z

)

Z

(

FC Q

)

Z

(

)

Z FQ

)

Z

(

C Q

)

Z

(

C Q

)

Z

(

C Q

)

Z Q

BASES LCO (continued)

For this facility, the actual values of CFQ and K(Z) are given in the COLR; however, CFQ is normally a number on the order of [2.32], and K(Z) is a function that looks like the one provided in Figure B 3.2.1B-1.

9 For Relaxed Axial Offset Control operation, FQ(Z) is approximated by and F

. Thus, both F and F must meet the preceding limits on FQ(Z).

)

Z

(

W Q

(

W Q

An F evaluation requires obtaining an incore flux map in MODE 1.

From the incore flux map results we obtain the measured value (

) of FQ(Z). Then,

)

Z

(

C Q

(

FM

= F

[1.0815]

(

M Q

where [1.0815] is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.

is an excellent approximation for FQ(Z) when the reactor is at the steady state power at which the incore flux map was taken.

The expression for F is:

W Q

(

W

= F W(Z) where W(Z) is a cycle dependent function that accounts for power distribution transients encountered during normal operation. W(Z) is included in the COLR. The F is calculated at equilibrium conditions.

The FQ(Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA.

This LCO requires operation within the bounds assumed in the safety analyses. Calculations are performed in the core design process to confirm that the core can be controlled in such a manner during operation that it can stay within the LOCA FQ(Z) limits. If F cannot be maintained within the LCO limits, reduction of the core power is required and if F cannot be maintained within the LCO limits, reduction of the AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.

(

W Violating the LCO limits for FQ(Z) produces unacceptable consequences if a design basis event occurs while FQ(Z) is outside its specified limits.

1.03 4

4 4

10 T

Power Distribution Control T

and

)

F (Z

T Q

s N

10 x (1.03) x (1.05)

N 10 1.05 is a factor that accounts for T

x N x F(P)

T 3

10 N

and F(P) is the penalty factor required by the SR 3.2.1.2 Note and F(P) are N

T 10, Volume 7, Rev. 0, Page 22 of 102, Volume 7, Rev. 0, Page 22 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-4 Rev. 3.0, 03/31/04 1

BASES APPLICABILITY The FQ(Z) limits must be maintained in MODE 1 to prevent core power distributions from exceeding the limits assumed in the safety analyses.

Applicability in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require a limit on the distribution of core power.

ACTIONS A.1 Reducing THERMAL POWER by 1% RTP for each 1% by which exceeds its limit, maintains an acceptable absolute power density.

is F multiplied by a factor accounting for manufacturing tolerances and measurement uncertainties.

is the measured value of FQ(Z).

The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of and would require power reductions within 15 minutes of the F determination, if necessary to comply with the decreased maximum allowable power level.

Decreases in F would allow increasing the maximum allowable power level and increasing power up to this revised limit.

)

Z

(

FC Q

)

Z

(

FC Q

)

Z

)

Z

(

C Q

)

Z

(

C Q

(

M Q

)

Z

(

FM Q

)

Z

(

FC Q

A.2 A reduction of the Power Range Neutron Flux - High trip setpoints by 1% for each 1% by which F exceeds its limit, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1. The maximum allowable Power Range Neutron Flux - High trip setpoints initially determined by Required Action A.2 may be affected by subsequent determinations of F and would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in F would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

)

Z

(

C Q

)

Z

(

C Q

)

Z

(

C Q

)

Z

(

C Q

10 s

N N, Volume 7, Rev. 0, Page 23 of 102, Volume 7, Rev. 0, Page 23 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-5 Rev. 3.0, 03/31/04 1

BASES ACTIONS (continued)

A.3 Reduction in the Overpower T trip setpoints (value of K4) by 1% for each 1% by which exceeds its limit, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1. The maximum allowable Overpower T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of and would require Overpower T trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the determination, if necessary to comply with the decreased maximum allowable Overpower T trip setpoints. Decreases in F would allow increasing the maximum allowable Overpower T trip setpoints.

)

Z

(

FC Q

)

Z

(

FC Q

)

Z

(

FC Q

)

Z

(

C Q

A.4 Verification that has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the limit imposed by Required Action A.1, ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.

)

Z

(

FC Q

Condition A is modified by a Note that requires Required Action A.4 to be performed whenever the Condition is entered. This ensures that SR 3.2.1.1 and SR 3.2.1.2 will be performed prior to increasing THERMAL POWER above the limit of Required Action A.1, even when Condition A is exited prior to performing Required Action A.4.

Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.

B.1 If it is found that the maximum calculated value of FQ(Z) that can occur during normal maneuvers,

, exceeds its specified limits, there e a potential for

)

Z

(

FC Q

t come excessively high if a normal operati transient occurs. Reducing the AFD by 1% for each 1% by which

)

Z

(

F W Q

ds its limit within the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded.

)

Z

(

F W Q

xists o be onal excee T

10 T

10, Volume 7, Rev. 0, Page 24 of 102, Volume 7, Rev. 0, Page 24 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-6 Rev. 3.0, 03/31/04 1

)

Z

(

C Q

BASES ACTIONS (continued)

The implicit assumption is that if W(Z) values were recalculated (consistent with the reduced AFD limits), then F times the recalculated W(Z) values would meet the FQ(Z) limit. Note that complying with this action (of reducing AFD limits) may also result in a power reduction. Hence the need for Required Actions B.2, B.3 and B.4.

B.2 A reduction of the Power Range Neutron Flux-High trip setpoints by 1%

for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.3 Reduction in the Overpower T trip setpoints value of K4 by 1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.4 Verification that has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.1 ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.

)

Z FQ (

W N

10 N

10 T

10, Volume 7, Rev. 0, Page 25 of 102, Volume 7, Rev. 0, Page 25 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-7 Rev. 3.0, 03/31/04 1

BASES ACTIONS (continued)

Condition B is modified by a Note that requires Required Action B.4 to be performed whenever the Condition is entered. This ensures that SR 3.2.1.1 and SR 3.2.1.2 will be performed prior to increasing THERMAL POWER above the limit of Required Action B.1, even when Condition A is exited prior to performing Required Action B.4.

Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.

C.1 If Required Actions A.1 through A.4 or B.1 through B.4 are not met within their associated Completion Times, the plant must be placed in a mode or condition in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

any This allowed Completion Time is reasonable based on operating experience regarding the amount of time it takes to reach MODE 2 from full power operation in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.2 are modified by a Note. The Note applies REQUIREMENTS during the first power ascension after a refueling. It states that THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained.

This allowance is modified, however, by one of the Frequency conditions that requires verification that and are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits.

Because and could not have previously been measured in this reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of and are made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of F and following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved. In the absence of these Frequency conditions, it is possible to

)

Z

(

FC Q

)

Z

(

F W Q

)

Z

(

FC Q

)

Z

(

F W Q

)

Z

(

FC Q

)

Z

(

F W Q

)

Z

(

C Q

)

Z

(

F W Q

5 and 6

is not met MODE T

10 T

10, Volume 7, Rev. 0, Page 26 of 102, Volume 7, Rev. 0, Page 26 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-8 Rev. 3.0, 03/31/04 1

)

Z

(

FC Q

)

Z BASES SURVEILLANCE REQUIREMENTS (continued) increase power to RTP and operate for 31 days without verification of and F

. The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.

(

W Q

SR 3.2.1.1 Verification that is within its specified limits involves increasingF to allow for manufacturing tolerance and measurement uncertainties in order to obtain F

. Specifically, is the measured value of FQ(Z) obtained from incore flux map results and

= F

[1.0815] (Ref. 4). F is then compared to its specified limits.

)

Z

(

FC Q

)

Z

(

M Q

)

Z

(

C Q

)

Z Q

)

Z

(

FC Q

)

Z

(

M Q

)

Z

(

C Q

)

Z

)

Z

(

FC Q

)

Z

(

FC Q

(

FM The limit with which F is compared varies inversely with power above 50% RTP and directly with a function called K(Z) provided in the COLR.

(

C Q

Performing this Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the limit is met when RTP is achieved, because peaking factors generally decrease as power level is increased.

)

Z

(

FC Q

If THERMAL POWER has been increased by 10% RTP since the last determination of

, another evaluation of this factor is required

[12] hours after achieving equilibrium conditions at this higher power level (to ensure that values are being reduced sufficiently with power increase to stay within the LCO limits).

The Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup because such changes are slow and well controlled when the plant is operated in accordance with the Technical Specifications (TS).

x 1.03 x 1.05 4

4 T

10 N

10, Volume 7, Rev. 0, Page 27 of 102, Volume 7, Rev. 0, Page 27 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-9 Rev. 3.0, 03/31/04 1

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.2 The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor,

, by W(Z) gives the maximum FQ(Z) calculated to occur in normal operation, F

)

Z

(

FC Q

)

Z

(

W Q

)

Z

)

Z

)

Z

(

F W Q

)

Z

(

M Q

)

Z

(

C Q

)

Z Q

The limit with which F is compared varies inversely with power above 50% RTP and directly with the function K(Z) provided in the COLR.

(

W Q

The W(Z) curve is provided in the COLR for discrete core elevations.

Flux map data are typically taken for 30 to 75 core elevations. F evaluations are not applicable for the following axial core regions, measured in percent of core height:

(

W Q

a.

Lower core region, from 0 to 15% inclusive and

b.

Upper core region, from 85 to 100% inclusive.

The top and bottom 15% of the core are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making a precise measurement in these regions.

This Surveillance has been modified by a Note that may require that more frequent surveillances be performed. If is evaluated, an evaluation of the expression below is required to account for any increase to F that may occur and cause the FQ(Z) limit to be exceeded before the next required FQ(Z) evaluation.

If the two most recent FQ(Z) evaluations show an increase in the expression maximum over z [ F

/ K(Z) ], it is required to meet the FQ(Z) limit with the last F increased by the greater of a factor of

[1.02] or by an appropriate factor specified in the COLR (Ref. 5)

(

W 91 9

9 3

2 3

3 7

10 10 N

T T

N T

T T

N 10 10 10 (F(P)), Volume 7, Rev. 0, Page 28 of 102, Volume 7, Rev. 0, Page 28 of 102

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-10 Rev. 3.0, 03/31/04 1

BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control and FQ Surveillance Technical Specification," February 1994, or other appropriate plant specific methodology, is to be listed in the COLR description in the Administrative Controls Section 5.0 to address the methodology used to derive this factor.

8 or to evaluate FQ(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.

Performing the Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the FQ(Z) limit is met when RTP is achieved, because peaking factors are generally decreased as power level is increased.

FQ(Z) is verified at power levels 10% RTP above the THERMAL POWER of its last verification, [12] hours after achieving equilibrium conditions to ensure that FQ(Z) is within its limit at higher power levels.

4 The Surveillance Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup. The Surveillance may be done more frequently if required by the results of FQ(Z) evaluations.

The Frequency of 31 EFPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS, to preclude adverse peaking factors between 31 day surveillances.

REFERENCES

1.

10 CFR 50.46, 1974.

2.

Regulatory Guide 1.77, Rev. 0, May 1974.

3 USAR, Section 14.2.6.1.

3.

10 CFR 50, Appendix A, GDC 26.

4.

WCAP-7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.

5. WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control (and) FQ Surveillance Technical Specification," February 1994.

USAR, Section 3.1.2.5, GDC 29, "Reactivity Shutdown Capability."

3, Volume 7, Rev. 0, Page 29 of 102, Volume 7, Rev. 0, Page 29 of 102

F (Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-11 Rev. 3.0, 03/31/04 Q

1 9, Volume 7, Rev. 0, Page 30 of 102, Volume 7, Rev. 0, Page 30 of 102 FT.

(') %

0.4 0.2 f---

o o

THIS FIGURE FOR ILLUSTRATION ONLY.

DO NOT USE FOR OPERATION 2

16.6 4

6 33.3 50.0 CORE HEIGHT 8

66.7

'For core heig t of 12 feet Figure B 3.2.1B-1 (page 1 cf 1) 1 0 83.3 1 2 100 K(Z) - Normalized FQ(Z) as a Function of Core Height

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

1. The type of methodology (Relaxed Axial Offset Control (RAOC) - W(Z) Methodology) and the Specification designator "B" are deleted since they are unnecessary (only one FQ(Z) Specification is used in the Kewaunee Power Station (KPS) ITS). This information is provided in NUREG-1431, Revision 3.0, to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-Fxy and RAOC-W(Z) methodology Bases (ISTS B 3.2.1A and B 3.2.1C) are not used and are not shown.

2. These 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.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. 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.

5. These changes have been made to be consistent with similar phrases in other parts of the ITS Bases. As written, the words imply that all Required Actions of a given ACTION must not be met prior to requiring entry into Condition C.

6. Typographical/grammatical error corrected.

7. The Bases have been changed to be consistent with changes made to the Specification. As stated in ITS 3.2.1 JFD 2 the ISTS SR 3.2.1.2 Note, part "a" requirement to increase the limit by "the greater of a factor of [1.02] or by" an appropriate factor specified in the COLR has been changed to delete the 1.02 requirement. The CTS provides the value in the COLR, and it is currently 2% (i.e.,

1.02). Thus, since the value is consistent with the value in the COLR, the additional limit is not required.

8. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

9. This generic statement is not necessary. The LCO Section of the Bases already states that certain values are specified in the COLR, and providing a "normal" value or Figure that is not the actual one in the COLR can lead to confusion that results in improper limits being applied. Furthermore, putting the actual value and Figure in the Bases is also not needed since it is in the COLR, and any changes to the COLR with respect to this value and Figure would necessitate a change to the Bases.

Therefore, the statement and Figure B 3.2.1B-1 have been deleted.

10. KPS is changing from the Westinghouse RAOC methodology to the Dominion Relaxed Power Distribution Control (RPDC) methodology. The RPDC methodology, DOM-NAF-5-0.0.A, is one of the analytical methods listed in the COLR requirements Kewaunee Power Station Page 1 of 2, Volume 7, Rev. 0, Page 31 of 102, Volume 7, Rev. 0, Page 31 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

Kewaunee Power Station Page 2 of 2 (CTS 6.9.a.4.B.(16)). Therefore, the terminology has been changed to reflect the Dominion preferred terminology.

11. This fuel design criteria is applicable for all Condition 2 events, not just a loss of forced reactor coolant flow accident (which is one of the Condition 2 events).

Therefore, the words "During a loss of forced reactor coolant flow accident" have been deleted. Furthermore, it is noted that the deletion is consistent with similar words in the ISTS 3.2.2 Bases.

12. ISTS 3.2.1 Bases references 10 CFR 50, Appendix A, General Design Criteria.

Kewaunee Power Station (KPS) was designed prior to promulgation of 10 CFR 50, Appendix A. Therefore, the Applicable Safety Analyses Bases has been revised to discuss the design standards used by KPS. Additionally, Bases references to 10 CFR 50, Appendix A have been replaced with references to the appropriate section of the USAR.

, Volume 7, Rev. 0, Page 32 of 102, Volume 7, Rev. 0, Page 32 of 102

Specific No Significant Hazards Considerations (NSHCs), Volume 7, Rev. 0, Page 33 of 102, Volume 7, Rev. 0, Page 33 of 102

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 34 of 102, Volume 7, Rev. 0, Page 34 of 102

ATTACHMENT 2 ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR

(

)

N H

F, Volume 7, Rev. 0, Page 35 of 102, Volume 7, Rev. 0, Page 35 of 102

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 7, Rev. 0, Page 36 of 102, Volume 7, Rev. 0, Page 36 of 102

ITS 3.2.2 ITS A01 3.10 CONTROL ROD AND POWER DISTRIBUTION LIMITS APPLICABILITY Applies to the limits on core fission power distributions and to the limits on control rod operations.

OBJECTIVE To ensure: 1) core subcriticality after reactor trip, 2) acceptable core power distribution during power operation in order to maintain fuel integrity in normal operation transients associated with faults of moderate frequency, supplemented by automatic protection and by administrative procedures, and to maintain the design basis initial conditions for limiting faults, and 3) limited potential reactivity insertions caused by hypothetical control rod ejection.

SPECIFICATION

a.

Shutdown Reactivity When the reactor is subcritical prior to reactor startup, the SHUTDOWN MARGIN shall be at least that as specified in the COLR See ITS 3.1.1

b.

Power Distribution Limits A02

1. At all times, except during Low Power Physics Tests, the hot channel factors defined in the basis must meet the following limits:

Applicability See ITS 3.2.1 A. FQ N(Z) Limits shall be as specified in the COLR.

B. FH N Limits shall be as specified in the COLR.

LCO 3.2.2

2. If FH N not within limits:

A. Perform the following:

i.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months either, restore FH N to within its limit or reduce thermal power to less than 50% of RATED POWER.

ii. Reduce the Power Range Neutron Flux-High Trip Setpoint to 55% of RATED POWER within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

iii. Verify FH N within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

B. If the actions of TS 3.10.b.2.A are not completed within the specified time, then reduce thermal power to 5% of rated power within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Page 1 of 2 ACTION A ACTION B M01 Add proposed Condition A Note A03 Amendment No. 167 TS 3.10-1 04/04/2003, Volume 7, Rev. 0, Page 37 of 102, Volume 7, Rev. 0, Page 37 of 102

A01 ITS 3.2.2 ITS C. Identify and correct the cause of the out-of-limit condition prior to increasing thermal power above the reduced thermal power limit required by action A and/or B, above.

Subsequent power increases may proceed provided that FH N is demonstrated, through incore flux mapping, to be within its limits prior to exceeding the following thermal power levels:

i.

50% of RATED POWER, ii. 75% of RATED POWER, and iii. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining 95% of RATED POWER

3. If the FQ N(Z) equilibrium relationship is not within its limit:

A. Reduce the thermal power 1% RATED POWER for each 1% the FQ N(Z) equilibrium relationship exceeds its limit within 15 minutes after each determination and similarly reduce the Power Range Neutron Flux-High Trip Setpoints and the Overpower T Trip Setpoints within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by 1% for each 1% FQ N(Z) equilibrium relationship exceeds its limit.

B. If the actions of TS 3.10.b.3.A are not completed within the specified time, then reduce thermal power to 5% of RATED POWER within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

C. Verify the FQ N(Z) equilibrium relationship and the FQ N(Z) transient relationships are within limits prior to increasing thermal power above the reduced thermal power limit required by action A, above.

4. Power distribution maps using the movable detection system shall be made to confirm that the hot channel factor limits of TS 3.10.b.1 are satisfied. (Note: time requirements may be extended by 25%)

A. For FQ N(Z) equilibrium relationship, once after each refueling prior to thermal power exceeding 75% of RATED POWER; and once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions, after exceeding, by 10% of RATED POWER, the thermal power at which the FQ N(Z) equilibrium relationship was last verified; and 31 effective full power days thereafter.

B. For FH N, following each refueling prior to exceeding 75% RATED POWER and 31 effective full power days thereafter.

5. The measured FQ N(Z) under equilibrium conditions shall satisfy the FQ N(Z) transient relationship for the central axial 80% of the core as specified in the COLR.

6. Power distribution maps using the movable detector system shall be made to confirm the transient relationship of FQ N(Z) specified in the COLR according to the following schedules with allowances for a 25% grace period:

A. Once after each refueling prior to exceeding 75% RATED POWER and every 31 effective full power days thereafter.

B. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving equilibrium conditions after reaching a thermal power level > 10% higher than the power level at which the last power distribution measurement was performed in accordance with TS 3.10.b.6.A.

Page 2 of 2 ACTION A SR 3.2.2.1 Add proposed Required Action A.4 Note See ITS 3.2.1 See ITS 3.2.1 SR 3.2.2.1 See ITS 3.2.1 LA01 A05 A04 A06 LA01 Amendment No. 196 TS 3.10-2 03/28/2008, Volume 7, Rev. 0, Page 38 of 102, Volume 7, Rev. 0, Page 38 of 102

DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR N

H F

(

)

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 3.10.b.1 requires the CTS 3.10.b.1.B limits to be met "at all times, except during Low Power Physics Tests." However, CTS 3.10.b.2.B, which provides the actions when the limits are not met, only requires the unit to reduce reactor power to 5% RTP. ITS 3.2.2 requires the limits to be met in MODE 1, with no exception for low power physics tests. This changes the CTS by clearly stating the Applicability of the F limits to be consistent with the actions.

N H

F N

H

N H

F N

H F

The purpose of the Specification is to preclude core power distributions from exceeding the fuel design limits for DNBR and PCT. These are essentially MODE 1 limits, since the reactor must be at power for these limits to be exceeded. While the CTS required the limits to be met at all times, the actions only required reducing power to 5% RTP, which meets the intent of the LCO requirement and is consistent with the THERMAL POWER limit for MODE 1 operations in the ITS. Furthermore, the CTS previously defined OPERATING as 2% RTP. Since Low Power Physics Tests could be performed at up to 5%

RTP, the exception was needed. Since the ITS now defines MODE 1 as

> 5% RTP, a Low Power Physics Test exception is not needed. This change is acceptable since the requirements have not changed; if the LCO is not met, power is required to be reduced to 5% RTP (i.e., MODE 2). This change is designated as administrative since it does not result in any technical changes.

N H

F N

H F

A03 When is exceeding its limit, CTS 3.10.b.2.A.i requires that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either restoring to within its limit or reducing thermal power to < 50% RTP.

ITS 3.2.2 does not state the requirement to restore to within its limit, but includes the other compensatory Required Action to take within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (i.e.,

reduce THERMAL POWER to < 50% RTP). This changes the CTS by not explicitly stating the requirement to restore to within its limit.

N H

F N

H F

N H

F N

H F

This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in any technical changes to the CTS.

Kewaunee Power Station Page 1 of 4, Volume 7, Rev. 0, Page 39 of 102, Volume 7, Rev. 0, Page 39 of 102

DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR N

H F

(

)

A04 CTS 3.10.b.2.C states that with exceeding its limit, must be demonstrated to be within its limit prior to exceeding 50% RTP and 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining 95% RTP. ITS 3.2.2 Required Action A.4 contains the same requirements. However, ITS 3.2.2 Required Action A.4 is modified by a Note which states "THERMAL POWER does not have to be reduced to comply with this Required Action." This modifies the CTS by adding a Note stating that THERMAL POWER does not have to be reduced to comply with the Required Action.

N H

F N

H F

This change is acceptable because the requirements have not changed. The Note is included in the ITS to clarify that THERMAL POWER does not have to be reduced to perform the Required Action. For example, if exceeded its limit and power was reduced to 60% RTP before is demonstrated to be within its limit, under the Note THERMAL POWER does not have to be reduced to less than 50% RTP for a measurement. However, must still be measured prior to exceeding 75% RTP and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining 95% RTP. The Note is needed because the ITS contains a Note in ITS 3.2.2 Condition A that states "Required Actions A.2 and A.4 must be completed whenever Condition A is entered." The Condition A Note does not exist in the CTS and could be construed as requiring THERMAL POWER to be reduced to comply with Required Action A.4. The Condition A Note is described in Discussion of Change M01. As a result, the Required Action A.4 Note makes the ITS and CTS actions consistent. This change is designated as administrative because it does not result in technical changes to the CTS.

N H

F N

H F

N H

F N

H F

A05 CTS 3.10.b.2.C states that with exceeding its limit "Identify and correct the cause of the out-of-limit condition prior to increasing thermal power above the reduced thermal power limit required by action A and/or B, above." ITS 3.2.2 does not include this requirement. This changes the CTS by eliminating the statement that the cause of the out-of-limit condition must be identified and corrected prior to increasing power.

N H

F This change is acceptable because the requirements have not changed. Stating that the cause of the limit violation must be identified and corrected prior to increasing power (i.e., exiting the Action which required power reduction) is unnecessary. Restoration of compliance with the LCO is always an option and allows exiting the ACTION per ITS 3.0.2. Therefore, it does not have to be stated. In addition, CTS 3.10.b.2.C and ITS 3.2.2 Required Action A.4 require to be within limit prior to exceeding 50% RTP and 75% RTP, which ensures limit is identified and corrected. This change is designated as administrative because it does not result in technical changes to the CTS.

N H

F N

H F

N H

F A06 CTS 3.10.b.4 provides the Surveillance Requirement for periodically verifying is within limit. A Note to CTS 3.10.b.4 states that the time requirements may be extended by 25%. ITS SR 3.2.2.1 does not include this specific allowance.

This change deletes the specific 25% allowance of CTS 3.10.b.4.

N H

F Kewaunee Power Station Page 2 of 4, Volume 7, Rev. 0, Page 40 of 102, Volume 7, Rev. 0, Page 40 of 102

DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR N

H F

(

)

This change is acceptable since ITS SR 3.0.2 provides the same allowance. ITS SR 3.0.2 provides a 25% grace period for all periodic Surveillances, not just this specific one. This change is considered administrative since it does not result in any technical changes.

MORE RESTRICTIVE CHANGES M01 CTS 3.10.b.2.A.iii requires that with exceeding its limit, a verification that is within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and CTS 3.10.b.2.C, in part, states that with F exceeding its limit "Subsequent power increases may proceed provided that is demonstrated, through incore mapping, to be within its limits prior to exceeding the following thermal power levels: 50% of RATED POWER, 75% of RATED POWER, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining 95% of RATED POWER." However, under CTS 3.0.b, these measurements do not have to be completed if compliance with the LCO is reestablished. ITS 3.2.2 Condition A contains a Note which states, "Required Actions A.2 and A.4 must be completed whenever Condition A is entered." ITS Required Actions A.2 and A.4 require performance of a measurement within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and prior to exceeding 50% RTP and 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is 95% RTP. This changes the CTS by requiring the measurements to be made even if is restored to within its limit.

N H

F N

H

N H

F N

H N

H F

N H

F N

H F

F This change is acceptable because it establishes appropriate compensatory measurements for violation of the limit. As power is reduced under ITS Required Action A.1, the margin to the limit increases. Therefore, compliance with the LCO could be reestablished during the power reduction.

Verifying that the limit is met as power is increased ensures that the limit continues to be met and does not remain unmeasured for up to 31 EFPD. This change is designated as more restrictive because it imposes requirements in addition to those in the CTS.

N H

F N

H F

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.10.b.2.C requires to be determined to be within its limit through incore mapping and CTS 3.10.b.4 requires to be determined to be within its limit by using the movable incore detectors to obtain a power distribution map. ITS SR 3.2.2.1 just requires verification that is N

H F

N H

F FN H

Kewaunee Power Station Page 3 of 4, Volume 7, Rev. 0, Page 41 of 102, Volume 7, Rev. 0, Page 41 of 102

DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (

N H

F )

Kewaunee Power Station Page 4 of 4 within its limit. This changes the CTS by relocating to the ITS Bases the manner in which the determination is performed.

N H

F The removal of these details for performing actions and a Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to determine is within its limit. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

N H

F LESS RESTRICTIVE CHANGES None

, Volume 7, Rev. 0, Page 42 of 102, Volume 7, Rev. 0, Page 42 of 102

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 43 of 102, Volume 7, Rev. 0, Page 43 of 102

N H

F 3.2.2 WOG STS 3.2.2-1 Rev. 3.0, 03/31/04 N

H

N H

F 3.2 POWER DISTRIBUTION LIMITS 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (F

)

LCO 3.2.2 shall be within the limits specified in the COLR.

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NOTE------------

Required Actions A.2 and A.3 must be completed whenever Condition A is entered.

not within limit.

N H

F A.1.1 Restore to within limit.

N H

F OR A.1.2.1 Reduce THERMAL POWER to < 50% RTP.

AND A.1.2.2 Reduce Power Range Neutron Flux - High trip setpoints to 55% RTP.

AND A.2 Perform SR 3.2.2.1.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 4 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 24 hours 4

3.10.b.2.A 3.10.b.1 3

1 3.10.b.1.B CTS, Volume 7, Rev. 0, Page 44 of 102, Volume 7, Rev. 0, Page 44 of 102

N H

F 3.2.2 WOG STS 3.2.2-2 Rev. 3.0, 03/31/04 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3

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

THERMAL POWER does not have to be reduced to comply with this Required Action.

Perform SR 3.2.2.1.

Prior to THERMAL POWER exceeding 50% RTP AND Prior to THERMAL POWER exceeding 75% RTP AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER reaching 95% RTP B. Required Action and associated Completion Time not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 1

4 3.10.b.2.C 3.10.b.2.B

, Volume 7, Rev. 0, Page 45 of 102, Volume 7, Rev. 0, Page 45 of 102

N H

F 3.2.2 WOG STS 3.2.2-3 Rev. 3.0, 03/31/04 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify is within limits specified in the COLR.

N H

F Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND 31 EFPD thereafter 3.10.b.4, 3.10.b.4.B

, Volume 7, Rev. 0, Page 46 of 102, Volume 7, Rev. 0, Page 46 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR N

H F

(

)

1. ISTS 3.2.2 Required Action A.1.1 requires restoration of to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or performance of a number of other actions, such as a power reduction to

< 50% RTP. The Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.g, states "A Required Action which requires restoration, such that the Condition is no longer met, is considered superfluous. It is only included if it would be the only Required Action for the Condition or it is needed for presentation clarity." Neither exception applies in this case. In fact, the inclusion of ISTS 3.2.2 Required Action A.1.1 requires an additional level of indenting and numbering for the remaining Required Actions in Condition A, which reduces its clarity. Therefore, ISTS 3.2.2 Required Action A.1.1 is deleted and the subsequent Required Actions renumbered accordingly and placed in the correct order, based on their associated Completion Times.

N H

F Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 47 of 102, Volume 7, Rev. 0, Page 47 of 102

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 48 of 102, Volume 7, Rev. 0, Page 48 of 102

H N

F B 3.2.2 WOG STS B 3.2.2-1 Rev. 3.0, 03/31/04 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (

HH)

N F

H N

F uel is a ecreases H

F H

N

H N

BASES BACKGROUND The purpose of this LCO is to establish limits on the power density at any point in the core so that the fuel design criteria are not exceeded and the accident analysis assumptions remain valid. The design limits on local (pellet) and integrated fuel rod peak power density are expressed in terms of hot channel factors. Control of the core power distribution with respect to these factors ensures that local conditions in the fuel rods and coolant channels do not challenge core integrity at any location during either normal operation or a postulated accident analyzed in the safety analyses.

is defined as the ratio of the integral of the linear power along the f rod with the highest integrated power to the average integrated fuel rod power. Therefore, H

N F

measure of the maximum total power produced in a fuel rod.

H N

F H

N F

N is sensitive to fuel loading patterns, bank insertion, and fuel burnup.

typically increases with control bank insertion and typically d with fuel burnup.

is not directly measurable but is inferred from a power distribution map obtained with the movable incore detector system. Specifically, the results of the three dimensional power distribution map are analyzed by a computer to determine F

. This factor is calculated at least every 31 EFPD. However, during power operation, the global power distribution is monitored by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," which address directly and continuously measured process variables.

The COLR provides peaking factor limits that ensure that the design basis value of the departure from nucleate boiling (DNB) is met for normal operation, operational transients, and any transient condition arising from events of moderate frequency. The DNB design basis precludes DNB and is met by limiting the minimum local DNB heat flux ratio to [1.3] using the [W3] CHF correlation. All DNB limited transient events are assumed to begin with an F value that satisfies the LCO requirements.

1.17 1

WRB-1 DNB Operation outside the LCO limits may produce unacceptable consequences if a DNB limiting event occurs. The DNB design basis ensures that there is no overheating of the fuel that results in possible cladding perforation with the release of fission products to the reactor coolant., Volume 7, Rev. 0, Page 49 of 102, Volume 7, Rev. 0, Page 49 of 102

H N

F B 3.2.2 WOG STS B 3.2.2-2 Rev. 3.0, 03/31/04 BASES APPLICABLE Limits on H

F preclude core power distributions that exceed the following N

H N

SAFETY fuel design limits:

ANALYSES

a.

There must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hottest fuel rod in the core does not experience a DNB condition, 2

b.

During a large break loss of coolant accident (LOCA), peak cladding temperature (PCT) must not exceed 2200°F,

c.

During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm [Ref. 1], and

d.

Fuel design limits required by GDC 26 (Ref. 2) for the condition when control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn.

For transients that may be DNB limited, the Reactor Coolant System flow and F are the core parameters of most importance. The limits on F ensure that the DNB design basis is met for normal operation, operational transients, and any transients arising from events of moderate frequency.

The DNB design basis is met by limiting the minimum DNBR to the 95/95 DNB criterion of [1.3] using the [W3] CHF correlation. This value provides a high degree of assurance that the hottest fuel rod in the core does not experience a DNB.

The allowable limit increases with decreasing power level. This functionality in is included in the analyses that provide the Reactor Core Safety Limits (SLs) of SL 2.1.1. Therefore, any DNB events in which the calculation of the core limits is modeled implicitly use this variable value of F in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial F as a function of power level defined by the COLR limit equation.

H N

F H

N F

The LOCA safety analysis indirectly models F as an input parameter.

The Nuclear Heat Flux Hot Channel Factor (FQ(Z)) and the axial peaking factors are inserted directly into the LOCA safety analyses that verify the acceptability of the resulting peak cladding temperature [Ref. 3].

maximum average fuel pellet enthalpy at the hot spot must remain below 200 cal/gm 2

(Ref. 3) 1.17 WRB-1 DNB

(

)

, temperature, and pressure 2

1 3

)

(

7 INSERT 1 3

3 1

1, Volume 7, Rev. 0, Page 50 of 102, Volume 7, Rev. 0, Page 50 of 102

ITS B 3.2.2 7

INSERT 1 One of the reactivity control systems provided shall be capable of making the core subcritical under any anticipated operating condition (including anticipated operational transients) sufficiently fast enough to prevent exceeding acceptable fuel damage limits.

SDM should assure subcriticality with the most restrictive rod cluster control assembly (RCCA) fully withdrawn (Ref. 2).

Insert Page B 3.2.2-2, Volume 7, Rev. 0, Page 51 of 102, Volume 7, Rev. 0, Page 51 of 102

H N

F B 3.2.2 WOG STS B 3.2.2-3 Rev. 3.0, 03/31/04 BASES APPLICABLE SAFETY ANALYSES (continued)

The fuel is protected in part by Technical Specifications, which ensure that the initial conditions assumed in the safety and accident analyses remain valid. The following LCOs ensure this: LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (

," and LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))."

)

F H

N

H N

F H

N F

H N

F H

N

H N

F N

and FQ(Z) are measured periodically using the movable incore detector system. Measurements are generally taken with the core at, or near, steady state conditions. Core monitoring and control under transient conditions (Condition 1 events) are accomplished by operating the core within the limits of the LCOs on AFD, QPTR, and Bank Insertion Limits.

satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO shall be maintained within the limits of the relationship provided in the COLR.

The F limit identifies the coolant flow channel with the maximum enthalpy rise. This channel has the least heat removal capability and thus the highest probability for a DNB.

The limiting value of

, described by the equation contained in the COLR, is the design radial peaking factor used in the unit safety analyses.

A power multiplication factor in this equation includes an additional margin for higher radial peaking from reduced thermal feedback and greater control rod insertion at low power levels. The limiting value of is allowed to increase 0.3% for every 1% RTP reduction in THERMAL POWER.

H N

F 4

APPLICABILITY The H

F limits must be maintained in MODE 1 to preclude core power distributions from exceeding the fuel design limits for DNBR and PCT.

Applicability in other modes is not required because there is either insufficient stored energy in the fuel or insufficient energy being

, Volume 7, Rev. 0, Page 52 of 102, Volume 7, Rev. 0, Page 52 of 102

H N

F B 3.2.2 WOG STS B 3.2.2-4 Rev. 3.0, 03/31/04 All changes are 5 unless otherwise noted BASES APPLICABILITY (continued) transferred to the coolant to require a limit on the distribution of core power. Specifically, the design bases events that are sensitive to F in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict F in these modes.

H N

ACTIONS A.1.1 With exceeding its limit, the unit is allowed 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring within its power dependent limit. When the limit is exceeded, the DNBR limit is not likely violated in steady state operation, because events that could significantly perturb the value (e.g., static control rod misalignment) are considered in the safety analyses. However, the DNBR limit may be violated if a DNB limiting event occurs. Thus, the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to restore to within its limits without allowing the plant to remain in an unacceptable condition for an extended period of time.

H N

F H

N F

H N

F H

N F

H N

F H

N F

A.1 and A.2 Condition A is modified by a Note that requires that Required Actions A.2 and A.3 must be completed whenever Condition A is entered. Thus, if power is not reduced because this Required Action is completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time period, Required Action A.2 nevertheless requires another measurement and calculation of F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with SR 3.2.2.1.

H N

However, if power is reduced below 50% RTP, Required Action A.3 requires that another determination of F must be done prior to exceeding 50% RTP, prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching or exceeding 95% RTP. In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

A.1.2.1 and A.1.2.2 even if F is restored to within limits H

N

4 4

If the value of F is not restored to within its specified limit either by adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in accordance with Required Action A.1.2.1 and reduce the Power Range Neutron Flux - High to 55% RTP in accordance with Required H

N

, Volume 7, Rev. 0, Page 53 of 102, Volume 7, Rev. 0, Page 53 of 102

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F B 3.2.2 WOG STS B 3.2.2-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued)

Action A.1.2.2. Reducing RTP to < 50% RTP increases the DNB margin and does not likely cause the DNBR limit to be violated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptable low power level with adequate DNBR margin. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Required Action A.1.2.1 is consistent with those allowed for in Required Action A.1.1 and provides an acceptable time to reach the required power level from full power operation without allowing the plant to remain in an unacceptable condition for an extended period of time. The Completion Times of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Required Actions A.1.1 and A.1.2.1 are not additive.

The allowed Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to reset the trip setpoints per Required Action A.1.2.2 recognizes that, once power is reduced, the safety analysis assumptions are satisfied and there is no urgent need to reduce the trip setpoints. This is a sensitive operation that may inadvertently trip the Reactor Protection System.

A.2 Once the power level has been reduced to < 50% RTP per Required Action A.1.2.1, an incore flux map (SR 3.2.2.1) must be obtained and the measured value of verified not to exceed the allowed limit at the lower power level. The unit is provided 20 additional hours to perform this task over and above the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allowed by either Action A.1.1 or Action A.1.2.1. The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is acceptable because of the increase in the DNB margin, which is obtained at lower power levels, and the low probability of having a DNB limiting event within this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. Additionally, operating experience has indicated that this Completion Time is sufficient to obtain the incore flux map, perform the required calculations, and evaluate F H

N F

H N

All changes are 5 unless otherwise noted Required 3

3 3

Trip If F continues to be not within limits, the Power Range Neutron Flux - High trip setpoints must be reduced to <

H N

55% RTP per Required Action A.3.

6, Volume 7, Rev. 0, Page 54 of 102, Volume 7, Rev. 0, Page 54 of 102

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F B 3.2.2 WOG STS B 3.2.2-6 Revision No. 2.2 BASES ACTIONS (continued)

A.3 Verification that is within its specified limits after an out of limit occurrence ensures that the cause that led to the F exceeding its limit is corrected, and that subsequent operation proceeds within the LCO limit. This Action demonstrates that the F limit is within the LCO limits prior to exceeding 50% RTP, again prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is 95% RTP.

H

H N

N F

This Required Action is modified by a Note that states that THERMAL POWER does not have to be reduced prior to performing this Action.

B.1 When Required Actions A.1.1 through A.3 cannot be completed within their required Completion Times, the plant must be placed in a mode in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The value of F is determined by using the movable incore detector system to obtain a flux distribution map. A data reduction computer program then calculates the maximum value of from the measured flux distributions. The measured value of F must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the F limit.

H N

H

H N

N F

After each refueling, F must be determined in MODE 1 prior to exceeding 75% RTP. This requirement ensures that F limits are met at the beginning of each fuel cycle.

The 31 EFPD Frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup. Accordingly, this Frequency is short enough that the F limit cannot be exceeded for any significant period of operation.

All changes are 5 unless otherwise noted 4

through incore flux mapping 3

and associated any 6

is not met, Volume 7, Rev. 0, Page 55 of 102, Volume 7, Rev. 0, Page 55 of 102

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F B 3.2.2 WOG STS B 3.2.2-7 Rev. 3.0, 03/31/04 BASES 3

REFERENCES

1.

Regulatory Guide 1.77, Rev. [0], May 1974.

USAR, Section 14.2.6.1.

3

2.

10 CFR 50, Appendix A, GDC 26.

USAR, Section 3.1.2.5, GDC 29, "Reactivity Shutdown Capability."

3.

10 CFR 50.46.

, Volume 7, Rev. 0, Page 56 of 102, Volume 7, Rev. 0, Page 56 of 102 I

/

I Z

7 z

H H

o o

JUSTIFICATION FOR DEVIATIONS ITS 3.2.2 BASES, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR N

H F

(

)

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. These 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.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. ISTS LCO 3.2.2 Bases, last sentence in the LCO section, states "The limiting value of is allowed to increase 0.3% for every 1% RTP reduction in THERMAL POWER." This sentence is removed. The first sentence of the LCO Bases states shall be maintained within the limits of the relationship provided in the COLR."

Part of the relationship specified in the COLR describes how the limit changes as a function of power. Describing part of the limit relationship in the Bases is inconsistent and does not provide any value without the rest of the relationship contained in the COLR. Therefore, the sentence is removed.

N H

F N

H F

N H

F N

H F

5. The Bases have been changed to be consistent with changes made to the Specification. Refer to ITS 3.2.2 JFD 1 for more information as to the specific change.

6. Typographical/grammatical error corrected.

7. ISTS 3.2.2 Bases references 10 CFR 50, Appendix A, General Design Criteria.

Kewaunee Power Station (KPS) was designed prior to promulgation of 10 CFR 50, Appendix A. Therefore, the Applicable Safety Analyses Bases has been revised to discuss the design standards used by KPS. Additionally, Bases references to 10 CFR 50, Appendix A have been replaced with references to the appropriate section of the USAR.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 57 of 102, Volume 7, Rev. 0, Page 57 of 102

Specific No Significant Hazards Considerations (NSHCs), Volume 7, Rev. 0, Page 58 of 102, Volume 7, Rev. 0, Page 58 of 102

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (

N H

F )

There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 59 of 102, Volume 7, Rev. 0, Page 59 of 102

ATTACHMENT 3 ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD), Volume 7, Rev. 0, Page 60 of 102, Volume 7, Rev. 0, Page 60 of 102

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 7, Rev. 0, Page 61 of 102, Volume 7, Rev. 0, Page 61 of 102

ITS 3.2.3 ITS A01 C. If a power distribution map measurement indicates that the FQ N(Z) transient relationships margin to the limit, as specified in the COLR, has decreased since the previous evaluation, then either of the following actions shall be taken:

i.

FQ N(Z) transient relationship shall be increased by the penalty factor specified in the COLR for comparison to the transient limit as specified in the COLR and reverified within the transient limit, or ii.

Repeat the determination of the FQ N(Z) transient relationship once every seven effective full-power days until either i. above is met, or two successive maps indicate that the FQ N(Z) transient relationships margin to the transient limit has not decreased.

7. If, for a measured FQ N(Z), the transient relationship of FQ N(Z) specified in the COLR is not within limits, then take the following actions:

A. Reduce the axial flux difference limits 1% for each 1% the FQ N(Z) transient relationship exceeds its limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each determination and similarly reduce the Power Range Neutron Flux-High Trip Setpoints and Overpower T Trip Setpoints within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by 1% that the maximum allowable power of the axial flux difference limits is reduced.

B. If the actions of TS 3.10.b.7.A are not completed within the specified time, then reduce thermal power to 5% of rated power within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

C. Verify the FQ N(Z) equilibrium relationship and the FQ N(Z) transient relationship are within limits prior to increasing thermal power above the reduced thermal power limit required by action A, above.

See ITS 3.2.1

8. Axial Flux Difference NOTE: The axial flux difference shall be considered outside limits when two or more operable excore channels indicate that axial flux difference is outside limits.

LCO 3.2.3 Note A.

During power operation with thermal power 50 percent of RATED POWER, the axial flux difference shall be maintained within the limits specified in the COLR.

Applicability LCO 3.2.3

i.

If the axial flux difference is not within limits, reduce thermal power to less than 50% RATED POWER within 30 minutes.

ACTION A Amendment No. 196 TS 3.10-3 03/28/2008 Page 1 of 2, Volume 7, Rev. 0, Page 62 of 102, Volume 7, Rev. 0, Page 62 of 102

TABLE TS 4.1-1 MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS Amendment No. 183 Page 7 of 7 6/20/2005 CHANNEL DESCRIPTION CHANNEL DESCRIPTION CHECK CHECK CALIBRATE CALIBRATE TEST TEST REMARKS REMARKS

43. AFW Pump Low Discharge Pressure Trip Not Applicable Each refueling cycle Quarterly (a)

(a) Verification of relay setpoints not required.

44. Axial Flux Difference (AFD)

Weekly Verify AFD within limits for each OPERABLE excore channel

45. Service Water Turbine Header Isolation Logic Trip (SW 4 A/B)

Not Applicable Each refueling cycle Each refueling cycle

46. AFW Pump Low Suction Pressure Trip Not Applicable Each refueling cycle Quarterly (a)

(a) Verification of relay setpoints not required.

A01 ITS 3.2.3 See ITS 3.3.2 SR 3.2.3.1 See ITS 3.7.5 See ITS 3.7.5 ITS Page 2 of 2, Volume 7, Rev. 0, Page 63 of 102, Volume 7, Rev. 0, Page 63 of 102

DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

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.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 64 of 102, Volume 7, Rev. 0, Page 64 of 102

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 65 of 102, Volume 7, Rev. 0, Page 65 of 102

AFD (RAOC Methodology) 3.2.3B WOG STS 3.2.3B-1 Rev. 3.0, 03/31/04 CTS 1

3.2 POWER DISTRIBUTION LIMITS 3.2.3B AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC)

Methodology) 1 LCO 3.2.3 The AFD in % flux difference units shall be maintained within the limits specified in the COLR.

3.10.b.8.A

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

The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits.

3.10.b.8 NOTE APPLICABILITY:

MODE 1 with THERMAL POWER 50% RTP.

3.10.b.8.A ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. AFD not within limits.

A.1 Reduce THERMAL POWER to < 50% RTP.

30 minutes 3.10.b.8.A.i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AFD within limits for each OPERABLE excore channel.

7 days Table 4.1-1 CHANNEL DESCRIPTION 44

, Volume 7, Rev. 0, Page 66 of 102, Volume 7, Rev. 0, Page 66 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

1. The type of methodology (Relaxed Axial Offset Control (RAOC) Methodology) and the Specification designator "B" are deleted since they are unnecessary (only one Axial Flux Difference Specification is used in the Kewaunee Power Station (KPS)

ITS). This information is provided in NUREG-1431, Revision 3.0, to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC methodology Specification (ISTS 3.2.3A) is not used and is not shown.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 67 of 102, Volume 7, Rev. 0, Page 67 of 102

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 68 of 102, Volume 7, Rev. 0, Page 68 of 102

AFD (RAOC Methodology)

B 3.2.3B WOG STS B 3.2.3B-1 Rev. 3.0, 03/31/04 1

B 3.2 POWER DISTRIBUTION LIMITS 1

B 3.2.3B AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC Methodology)

BASES BACKGROUND The purpose of this LCO is to establish limits on the values of the AFD in order to limit the amount of axial power distribution skewing to either the top or bottom of the core. By limiting the amount of power distribution skewing, core peaking factors are consistent with the assumptions used in the safety analyses. Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in axial power distribution control.

5 RAOC is a calculational procedure that defines the allowed operational space of the AFD versus THERMAL POWER. The AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of the AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidate the conclusions of the accident and transient analyses with regard to fuel cladding integrity.

Relaxed Power Distribution Control (RPDC)

The AFD is monitored on an automatic basis using the unit process computer, which has an AFD monitor alarm. The computer determines the 1 minute average of each of the OPERABLE excore detector outputs and provides an alarm message immediately if the AFD for two or more OPERABLE excore channels is outside its specified limits.

Although the RAOC defines limits that must be met to satisfy safety analyses, typically an operating scheme, Constant Axial Offset Control (CAOC), is used to control axial power distribution in day to day operation (Ref. 1). CAOC requires that the AFD be controlled within a narrow tolerance band around a burnup dependent target to minimize the variation of axial peaking factors and axial xenon distribution during unit maneuvers.

5 The CAOC operating space is typically smaller and lies within the RAOC operating space. Control within the CAOC operating space constrains the variation of axial xenon distributions and axial power distributions.

RAOC calculations assume a wide range of xenon distributions and then confirm that the resulting power distributions satisfy the requirements of the accident analyses.

5, Volume 7, Rev. 0, Page 69 of 102, Volume 7, Rev. 0, Page 69 of 102

AFD (RAOC Methodology)

B 3.2.3B WOG STS B 3.2.3B-2 Rev. 3.0, 03/31/04 1

BASES APPLICABLE The AFD is a measure of the axial power distribution skewing to either the SAFETY top or bottom half of the core. The AFD is sensitive to many core related ANALYSES parameters such as control bank positions, core power level, axial burnup, axial xenon distribution, and, to a lesser extent, reactor coolant temperature and boron concentration.

The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements.

The RAOC methodology (Ref. 2) establishes a xenon distribution library with tentatively wide AFD limits. One dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requirements.

The limits on the AFD ensure that the Heat Flux Hot Channel Factor (FQ(Z)) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents. The most important Condition 4 event is the LOCA. The most important Condition 3 event is the loss of flow accident. The most important Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents.

Condition 2 accidents simulated to begin from within the AFD limits are used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.

The RPDC methodology (Ref. 1) establishes a xenon distribution library with tentatively wide AFD limits. Axial power distribution calculations are then performed to demonstrate that normal power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requirements.

5 The limits on the AFD satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

ies 2

LCO The shape of the power profile in the axial (i.e., the vertical) direction is largely under the control of the operator through the manual operation of the control banks or automatic motion of control banks. The automatic motion of the control banks is in response to temperature deviations resulting from manual operation of the Chemical and Volume Control System to change boron concentration or from power level changes.

Signals are available to the operator from the Nuclear Instrumentation System (NIS) excore neutron detectors (Ref. 3). Separate signals are taken from the top and bottom detectors. The AFD is defined as the difference in normalized flux signals between the top and bottom excore detectors in each detector well. For convenience, this flux difference is converted to provide flux difference units expressed as a percentage and labeled as % flux or %I.

2 5

, Volume 7, Rev. 0, Page 70 of 102, Volume 7, Rev. 0, Page 70 of 102

AFD (RAOC Methodology)

B 3.2.3B WOG STS B 3.2.3B-3 Rev. 3.0, 03/31/04 BASES LCO (continued)

The AFD limits are provided in the COLR. Figure B 3.2.3B-1 shows typical RAOC AFD limits. The AFD limits for RAOC do not depend on the target flux difference. However, the target flux difference may be used to minimize changes in the axial power distribution.

Violating this LCO on the AFD could produce unacceptable consequences if a Condition 2, 3, or 4 event occurs while the AFD is outside its specified limits.

APPLICABILITY The AFD requirements are applicable in MODE 1 greater than or equal to 50% RTP when the combination of THERMAL POWER and core peaking factors are of primary importance in safety analysis.

For AFD limits developed using RAOC methodology, the value of the AFD does not affect the limiting accident consequences with THERMAL POWER < 50% RTP and for lower operating power MODES.

ACTIONS A.1 As an alternative to restoring the AFD to within its specified limits, Required Action A.1 requires a THERMAL POWER reduction to

< 50% RTP. This places the core in a condition for which the value of the AFD is not important in the applicable safety analyses. A Completion Time of 30 minutes is reasonable, based on operating experience, to reach 50% RTP without challenging plant systems.

SURVEILLANCE SR 3.2.3.1 REQUIREMENTS This Surveillance verifies that the AFD, as indicated by the NIS excore channel, is within its specified limits. The Surveillance Frequency of 7 days is adequate considering that the AFD is monitored by a computer and any deviation from requirements is alarmed.

REFERENCES

1.

WCAP-8403 (nonproprietary), "Power Distribution Control and Load Following Procedures," Westinghouse Electric Corporation, September 1974.

2.

R. W. Miller et al., "Relaxation of Constant Axial Offset Control: FQ Surveillance Technical Specification," WCAP-10217(NP), June 1983.

3. FSAR, Chapter [15].

7.4 5

5 5

5 Section DOM-NAF-5.0.0.A, "Application of Dominion Core Design and Safety Analysis Methods to the Kewaunee Power Station (KPS)."

U 4

2 5

RPDC RPDC 3

1

2., Volume 7, Rev. 0, Page 71 of 102, Volume 7, Rev. 0, Page 71 of 102

AFD (RAOC Methodology)

B 3.2.3B WOG STS B 3.2.3B-4 Rev. 3.0, 03/31/04 1

3, Volume 7, Rev. 0, Page 72 of 102, Volume 7, Rev. 0, Page 72 of 102 Z

d 0 o

I I I

(-15,100)

(6,100) 100 I

UNACCEP T BLE V

\\

UNACCEPTABLE OPERA T ON OPERATION

/

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w 3:

80 0

/

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<t w

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vv ACCEPTABLE I

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w

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f-OPERATION

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0 0\\0 40

-31,50 (20 50) 20 THI FIGURE IS FOR ILL 5 TRATION ONLY.

DO OT USE FOR OPE A TION.

0 -50

-30

-10 10 30 50

- 0

-20 0

20 40 AXIAL FLUX DIFFERENCE (%)

Figure B 3.2.3B-1 (page 1 0 f 1)

AX IAL FLUX DIFFERENCE Acceptable Ope ration Limits as a Function of RATED TH\\RMA L POWER

JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL FLUX DIFFERENCE (AFD)

1. The type of methodology (Relaxed Axial Offset Control (RAOC) Methodology) and the Specification designator "B" are deleted since they are unnecessary (only one Axial Flux Difference Specification is used in the Kewaunee Power Station (KPS)

ITS). This information is provided in NUREG-1431, Revision 3.0, to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC methodology Specification (ISTS 3.2.3A) is not used and is not shown.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. Since the ITS states the actual AFD target band and operation limits are specified in the COLR, the "typical" example is not needed in the Bases and has been deleted.

4. 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.

5. The Relaxed Axial Offset Control (RAOC) Methodology has been changed to the Relaxed Power Distribution Control (RPDC). KPS will be performing AFD calculations using the Dominion RPDC methodology DOM-NAF-5-0.0.A. This methodology is one of the analytical methods listed in the COLR requirements (CTS 6.9.a.4.B.(16) and ITS 5.6.3.b.15). Therefore, all references to RAOC have been changed to RPDC. Additionally, the references were changed to reflect the use of the RPDC methodology and renumbered as necessary.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 73 of 102, Volume 7, Rev. 0, Page 73 of 102

Specific No Significant Hazards Considerations (NSHCs), Volume 7, Rev. 0, Page 74 of 102, Volume 7, Rev. 0, Page 74 of 102

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 75 of 102, Volume 7, Rev. 0, Page 75 of 102

ATTACHMENT 4 ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR), Volume 7, Rev. 0, Page 76 of 102, Volume 7, Rev. 0, Page 76 of 102

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 7, Rev. 0, Page 77 of 102, Volume 7, Rev. 0, Page 77 of 102

ITS 3.2.4 ITS A01

c.

Quadrant Power Tilt Limits

1. Except for physics tests, whenever the indicated quadrant power tilt ratio > 1.02, one of the following actions shall be taken within two hours:

A02 Add proposed LCO 3.2.4 and Applicability ACTION A A.

Eliminate the tilt.

B.

Restrict maximum core power level 2% for every 1% of indicated power tilt ratio

> 1.0.

2. If the tilt condition is not eliminated after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , then reduce power to 50% or lower.

3. Except for Low Power Physics Tests, if the indicated quadrant tilt is > 1.09 and there is simultaneous indication of a misaligned rod:

A. Restrict maximum core power level by 2% of rated values for every 1% of indicated power tilt ratio > 1.0.

B. If the tilt condition is not eliminated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , then the reactor shall be brought to a minimum load condition (30 Mwe).

4. If the indicated quadrant tilt is > 1.09 and there is no simultaneous indication of rod misalignment, then the reactor shall immediately be brought to a no load condition (5% reactor power).

d.

Rod Insertion Limits

1. The shutdown rods shall be withdrawn to within the limits, specified in the COLR, when the reactor is critical or approaching criticality.

2. The control banks shall be limited in physical insertion; insertion limits are specified in the COLR. If any one of the control bank insertion limits is not met:

A. Within one hour, initiate boration to restore control bank insertion to within the limits specified in the COLR, and B. Restore control bank insertion to within the limits specified in the COLR within two hours of exceeding the insertion limits.

C. If any one of the conditions of TS 3.10.d.2.A or TS 3.10.d.2.B cannot be met, then within one hour action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

3. Insertion limit does not apply during physics tests or during periodic exercise of individual rods. However, the shutdown margin, as specified in the COLR, must be maintained except for the Low Power Physics Test to measure control rod worth and shutdown margin. For this test, the reactor may be critical with all but one high worth rod inserted.

See ITS 3.1.6 See ITS 3.1.5 See ITS 3.1.5, 3.1.6, and 3.1.8 Page 1 of 3 ACTIONS A and B ACTIONS A and B ACTIONS A and B A03 3

M01 L01 Add proposed Required Actions A.2, A.3, A.4, A.5, and A.6 and ACTION B A02 M01 3

L01 Add proposed Required Actions A.1, A.2, A.3, A.4, A.5, and A.6 and ACTION B L01 Add proposed Required Actions A.2, A.3, A.4, A.5, and A.6 and ACTION B See ITS 3.1.5, 3.1.6, and 3.1.8 M02 Add proposed SR 3.2.4.1 (including Note 2) and SR 3.2.4.2 Amendment No. 165 TS 3.10-4 03/11/2003, Volume 7, Rev. 0, Page 78 of 102, Volume 7, Rev. 0, Page 78 of 102

ITS 3.2.4 A01

g.

Inoperable Rod Limitations

1. An inoperable rod is a rod which does not trip or which is declared inoperable under TS 3.10.e or TS 3.10.h.

2. Not more than one inoperable full length rod shall be allowed at any time.

3. If reactor operation is continued with one inoperable full length rod, the potential ejected rod worth and associated transient power distribution peaking factors shall be determined by analysis within 30 days unless the rod is made OPERABLE earlier. The analysis shall include due allowance for nonuniform fuel depletion in the neighborhood of the inoperable rod. If the analysis results in a more limiting hypothetical transient than the cases reported in the safety analysis, the plant power level shall be reduced to an analytically determined part power level which is consistent with the safety analysis.

h.

Rod Drop Time At OPERATING temperature and full flow, the drop time of each full length rod cluster control shall be no greater than 1.8 seconds from loss of stationary gripper coil voltage to dashpot entry. If drop time is > 1.8 seconds, the rod shall be declared inoperable.

i.

Rod Position Deviation Monitor If the rod position deviation monitor is inoperable, individual rod positions shall be logged at least once per eight hours and after a load change > 10% of rated power or after > 24 steps of control rod motion.

See ITS 3.1.4

j.

Quadrant Power Tilt Monitor If one or both of the quadrant power tilt monitors is inoperable, individual upper and lower excore detector calibrated outputs and the quadrant tilt shall be logged once per shift and after a load change > 10% of rated power or after > 24 steps of control rod motion. The monitors shall be set to alarm at 2% tilt ratio.

L02

k.

Core Average Temperature During steady-state power operation, Tavg, shall be maintained within the limits specified in the COLR, except as provided by TS 3.10.n.

l.

Reactor Coolant System Pressure During steady-state power operation, Reactor Coolant System pressure shall be maintained within the limits specified in the COLR, except as provided by TS 3.10.n.

See ITS 3.4.1 Amendment No. 181 TS 3.10-7 Revised by letter dated 11/03/06 Page 2 of 3, Volume 7, Rev. 0, Page 79 of 102, Volume 7, Rev. 0, Page 79 of 102

TECHNICAL SPECIFICATIONS AND BASES 1.0 DEFINITIONS The following terms are defined for uniform interpretation of the specifications.

a. QUADRANT-TO-AVERAGE POWER TILT RATIO The QUADRANT-TO-AVERAGE POWER TILT RATIO is defined as the ratio of maximum-to-average of the upper excore detector currents or that of the lower excore detector currents, whichever is greater. If one excore detector is out-of-service, then the three in-service units are used in computing the average.

b. SAFETY LIMITS SAFETY LIMITS are the necessary quantitative restrictions placed upon those process variables that must be controlled in order to reasonably protect the integrity of certain of the physical barriers which guard against the uncontrolled release of radioactivity.

c. LIMITING SAFETY SYSTEM SETTINGS LIMITING SAFETY SYSTEM SETTINGS are setpoints for automatic protective devices responsive to the variables on which SAFETY LIMITS have been placed.

These setpoints are so chosen that automatic protective actions will correct the most severe, anticipated abnormal situation so that a SAFETY LIMIT is not exceeded.

d. LIMITING CONDITIONS FOR OPERATION LIMITING CONDITIONS FOR OPERATION are those restrictions on reactor operation, resulting from equipment performance capability that must be enforced to ensure safe operation of the facility.

e. OPERABLE-OPERABILITY A system or component is OPERABLE or has OPERABILITY when it is capable of performing its intended function within the required range. The system or component shall be considered to have this capability when: (1) it satisfies the LIMITING CONDITIONS FOR OPERATION defined in TS 3.0, and (2) it has been tested periodically in accordance with TS 4.0 and has met its performance requirements.

Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that is required for the system or component to perform its intended function is also capable of performing their related support functions.

f.

OPERATING A system or component is considered to be OPERATING when it is performing the intended function in the intended manner.

ITS 3.2.4 ITS See ITS Chapter 1.0 and THERMAL POWER 75% RTP M03 SR 3.2.4.1 Note 1 See ITS Chapter 1.0 A01 Amendment No. 162 TS 1.0-1 09/19/2002 Page 3 of 3, Volume 7, Rev. 0, Page 80 of 102, Volume 7, Rev. 0, Page 80 of 102

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

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 3.10.c provides actions to be taken if the QPTR is not within limits (i.e.,

> 1.02), but does not provide an actual LCO type of statement or an Applicability statement. Furthermore, CTS 3.10.c.1 and CTS 3.10.c.3 states that the actions are not required during Physics Tests. If the QPTR is not restored to 1.02 as required by CTS 3.10.c.1, then CTS 3.10.c.2 requires the unit to reduce power to 50% RTP. Thus, the effective Applicability for the QPTR limit is when the reactor is > 50% RTP except during a Physics Test. ITS 3.2.4 requires the QPTR to be 1.02 in MODE 1 with THERMAL POWER > 50% RTP.

The purpose of CTS 3.10.c is to ensure the gross radial power distribution remains consistent with the design values used in the safety analyses. The proposed change is acceptable because it clearly presents the QPTR limit requirement that is currently required by the CTS. Furthermore, Kewaunee Power Station does not currently perform any Physics Tests above 50% RTP that requires the QPTR limit to be not met. Therefore, this allowance deletion is also acceptable. This change is designated as administrative since it does not result in any technical changes to the CTS.

A03 When the QPTR is exceeding its limit, CTS 3.10.c.1 requires that within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months either "Eliminate the tilt" (i.e., restore the QPTR to within limit) or restrict maximum core power level 2% for every 1% of indicated power tilt ratio > 1.0.

ITS 3.2.4 does not contain a specific requirement to restore the QPTR to within its limit, but includes the other compensatory Required Action to take within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (i.e., reduce THERMAL POWER 3% from RTP for each 1% of QPTR

> 1.00 - Note: See Discussion of Change M01 for change from 2% to 3%). This changes the CTS by not explicitly stating the requirement to restore the QPTR to within its limit.

This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in any technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 When the QPTR is > 1.02, CTS 3.10.c.1.B requires the restriction of the maximum thermal power level 2% for every 1% of indicated QPTR > 1.0. This Kewaunee Power Station Page 1 of 4, Volume 7, Rev. 0, Page 81 of 102, Volume 7, Rev. 0, Page 81 of 102

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR) same restriction is also required by CTS 3.10.c.3.A. ITS 3.2.4 Required Action A.1 requires a 3% reduction in THERMAL POWER from RTP for each 1% of QPTR > 1.00. This changes the CTS by requiring the THERMAL POWER reduction from RTP to be 3% in lieu of the current 2% for each 1% of QPTR

> 1.00.

The purpose of the CTS 3.10.c.1.B and 3.10.c.3.A restrictions is to provide a conservative tradeoff of total core power with peak linear power. A 3% reduction in power provides a more conservative reduction than 2%. Therefore, this change is acceptable and is more restrictive because the THERMAL POWER reduction is greater for each 1% of QPTR > 1.00.

M02 CTS 3.10.c does not provide any Surveillance Requirements for verifying QPTR is within limits. ITS SR 3.2.4.1 requires verifying the QPTR is within limit by calculation every 7 days. If one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER > 75% RTP, then ITS SR 3.2.4.2 (and associated Note) requires verifying QPTR is within limit using the movable incore detectors every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (after the Power Range Neutron Flux channels are inoperable). Furthermore, ITS SR 3.2.4.1 is modified by a Note that states ITS SR 3.2.4.2 may be performed in lieu of ITS SR 3.2.4.1. This changes the CTS by adding specific Surveillance Requirements to verify the LCO limit is met.

The purpose of ITS SR 3.2.4.1 and SR 3.2.4.2 is to ensure the QPTR is periodically verified to be within the specified limit. This ensures that the gross radial power distribution remains consistent with the design values used in the safety analyses. Therefore, this change is considered acceptable and is more restrictive because new Surveillance Requirements have been added.

M03 CTS 1.0.a, the definition of QPTR, states, in part, that "If one excore detector is out-of-service, then the three in-service units are used in computing the average." ITS SR 3.2.4.1 Note 1 states that with input from one Power Range Neutron Flux channel (i.e., an excore detector) inoperable and THERMAL POWER 75% RTP, the remaining three Power Range Neutron Flux channels can be used for calculating QPTR. This changes the CTS by specifying that the allowance can only be used when 75% RTP.

The purpose of the CTS is to state when fewer than the normal complement of excore detectors can be used to determine QPTR. In the ITS, the operation of the plant at high power (above 75%) with one or more power range channel inputs to QPTR inoperable requires that the movable incore detectors be used to measure QPTR (ITS SR 3.2.4.2 - see DOC M02) to compensate for the loss of radial power monitoring capability (i.e., input(s) from the power range channels).

Therefore, since the ITS allows three excore detectors to be used to compute the QPTR only when THERMAL POWER is 75% RTP, this change is considered acceptable. This change is designated as more restrictive because the allowance is now only allowed to be used when 75% RTP.

RELOCATED SPECIFICATIONS None Kewaunee Power Station Page 2 of 4, Volume 7, Rev. 0, Page 82 of 102, Volume 7, Rev. 0, Page 82 of 102

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.10.c.2 states that with QPTR > 1.02, eliminate the tilt condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or reduce power to 50% RTP. CTS 3.10.c.3.B states that when QPTR is > 1.09 due to misalignment of a rod, eliminate the tilt condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or reduce power to a minimum load condition ( 30 Mwe). CTS 3.10.c.4 states that when QPTR is > 1.09 for reasons other than misalignment of a rod, the reactor shall immediately be brought to a no load condition ( 5% RTP). When the QPTR is

> 1.02, ITS 3.2.4, Required Action A.2 requires the QPTR to be determined once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , Required Action A.3 requires FQ(Z) and to be verified to be within limits (i.e., by performing SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after the power reduction and every 7 days thereafter, Required Action A.4 requires the safety analyses to be reevaluated to confirm the results are still valid for the duration of operation under this condition prior to increasing power, Required Action A.5 requires (after completion of Required Action A.4) the excore detectors to be normalized to restore QPTR within limit prior to increasing power, and Required Action A.6 requires FQ(Z) and to be verified to be within limits (i.e., by performing SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium condition at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing power. In addition, for the condition of QPTR > 1.09 for reasons other than misalignment of a rod, ITS 3.2.4 Required Action A.1 requires THERMAL POWER to be reduced N

H F

N H

F 3% from RTP for each 1% of QPTR > 1.00, similar to the CTS 3.10.c.1.B and CTS 3.10.c.3.A requirements (changed from 2% to 3% as described in DOC M01). Furthermore, ITS 3.2.4 ACTION B states that with a Required Action and associated Completion Time (of Condition A) not met, reduce THERMAL POWER to < 50% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This changes the CTS by eliminating requirements to be < 50% RTP, minimum load condition, or no load condition within a specified time of exceeding the LCO and substituting compensatory measures in ITS 3.2.4 ACTION A, which if not met, result in a reduction in power per ITS 3.2.4 ACTION B.

The purpose of the CTS actions is to lower reactor power to 50% or less when QPTR is not within its limit and cannot be restored to within its limit within a reasonable time period. This action is taken because with QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical core parameters such as FQ(Z) and may not be within their limits. A QPTR not within limit may be an acceptable condition if the critical core parameters such as FQ(Z) and are within their limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features or restore out of limit parameters. The Required Actions are consistent with safe N

H F

N H

F Kewaunee Power Station Page 3 of 4, Volume 7, Rev. 0, Page 83 of 102, Volume 7, Rev. 0, Page 83 of 102

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Kewaunee Power Station Page 4 of 4 operation under the specified Condition, considering the status of the redundant indications, the capacity and capability of remaining features, a reasonable time for repairs or restoration of required features, and the low probability of a DBA occurring during the repair period. The ITS requires measurement of FQ(Z) and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and every 7 days thereafter to verify that those parameters are within limit. In addition, the ITS requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, the ITS allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures that the core is operated within the safety analyses. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

N H

F L02 (Category 7 - Relaxation Of Surveillance Frequency) CTS 3.10.j states that if one or both of the quadrant power tilt monitors are inoperable, individual upper and lower excore detector calibrated outputs and the quadrant tilt shall be logged once per shift and after a load change > 10% of rated power or after > 24 steps of control rod motion. It also states the monitors shall be set to alarm at 2% tilt ratio. ITS SR 3.2.4.1 requires verification that QPTR is within limit every 7 days and the ITS does not include the monitor alarm setpoint. This changes the CTS by eliminating the requirement to verify QPTR more frequently when one or both QPTR alarms are inoperable.

The purpose of CTS 3.10.j is to periodically verify that QPTR is within limit more frequently if one or both monitors are inoperable. This change is acceptable because increasing the frequency of QPTR verification when the QPTR alarm is inoperable is unnecessary. The inoperability of the alarm does not increase the probability that QPTR is outside its limit. The routine 7 day Frequency (ITS SR 3.2.4.1) continues to ensure QPTR is within the limit. Furthermore, the QPTR alarm is for indication only. Its use is not credited in any of the safety analyses. Thus, any response determined necessary by plant personnel due to an inoperable alarm is more appropriately controlled by plant procedures, not Technical Specifications. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

, Volume 7, Rev. 0, Page 84 of 102, Volume 7, Rev. 0, Page 84 of 102

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 85 of 102, Volume 7, Rev. 0, Page 85 of 102

QPTR 3.2.4 WOG STS 3.2.4-1 Rev. 3.0, 03/31/04 CTS 3.2 POWER DISTRIBUTION LIMITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

LCO 3.2.4 The QPTR shall be 1.02.

DOC A02 APPLICABILITY:

MODE 1 with THERMAL POWER > 50% RTP.

DOC A02 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. QPTR not within limit.

A.1 Reduce THERMAL POWER 3% from RTP for each 1% of QPTR > 1.00.

AND A.2 Determine QPTR.

AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each QPTR determination Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 24 hours after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 AND Once per 7 days thereafter 3.10.c.1, 3.10.c.3, 3.10.c.4, Volume 7, Rev. 0, Page 86 of 102, Volume 7, Rev. 0, Page 86 of 102

QPTR 3.2.4 WOG STS 3.2.4-2 Rev. 3.0, 03/31/04 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.4 Reevaluate safety analyses and confirm results remain valid for duration of operation under this condition.

AND A.5

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

1. Perform Required Action A.5 only after Required Action A.4 is completed.

2. Required Action A.6 shall be completed whenever Required Action A.5 is performed.

Normalize excore detectors to restore QPTR to within limit.

AND A.6

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

Perform Required Action A.6 only after Required Action A.5 is completed.

Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

Prior to increasing THERMAL POWER above the limit of Required Action A.1 Prior to increasing THERMAL POWER above the limit of Required Action A.1 Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing THERMAL POWER above the limit of Required Action A.1 3.10.c.1, 3.10.c.3, 3.10.c.4, Volume 7, Rev. 0, Page 87 of 102, Volume 7, Rev. 0, Page 87 of 102

QPTR 3.2.4 WOG STS 3.2.4-3 Rev. 3.0, 03/31/04 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to 50% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 3.10.c.2, 3.10.c.3, 3.10.c.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1

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

1. With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channels can be used for calculating QPTR.

2. SR 3.2.4.2 may be performed in lieu of this Surveillance.

Verify QPTR is within limit by calculation.

7 days SR 3.2.4.2

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER

> 75% RTP.

Verify QPTR is within limit using the movable incore detectors.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 1.0.a DOC M02 DOC M02 DOC M02

, Volume 7, Rev. 0, Page 88 of 102, Volume 7, Rev. 0, Page 88 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

None Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 89 of 102, Volume 7, Rev. 0, Page 89 of 102

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs), Volume 7, Rev. 0, Page 90 of 102, Volume 7, Rev. 0, Page 90 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-1 Rev. 3.0, 03/31/04 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

BASES BACKGROUND The QPTR limit ensures that the gross radial power distribution remains consistent with the design values used in the safety analyses. Precise radial power distribution measurements are made during startup testing, after refueling, and periodically during power operation.

The power density at any point in the core must be limited so that the fuel design criteria are maintained. Together, LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, and LCO 3.1.6, "Control Rod Insertion Limits," provide limits on process variables that characterize and control the three dimensional power distribution of the reactor core. Control of these variables ensures that the core operates within the fuel design criteria and that the power distribution remains within the bounds used in the safety analyses.

Bank 15 APPLICABLE This LCO precludes core power distributions that violate the following fuel SAFETY design criteria:

ANALYSES

a.

During a large break loss of coolant accident, the peak cladding temperature must not exceed 2200°F (Ref. 1),

1

b.

During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 departure from nucleate boiling (DNB) criterion) that the hot fuel rod in the core does not experience a DNB condition,

c.

During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and

d.

The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (Ref. 3).

The LCO limits on the AFD, the QPTR, the Heat Flux Hot Channel Factor (FQ(Z)), the Nuclear Enthalpy Rise Hot Channel Factor (

, and control bank insertion are established to preclude core power distributions that exceed the safety analyses limits.

)

F H

N

H N

F The QPTR limits ensure that and FQ(Z) remain below their limiting values by preventing an undetected change in the gross radial power distribution.

maximum average fuel pellet enthalpy at the hot spot must remain below 200 cal/gm 1

1 2

13 14 INSERT 1, Volume 7, Rev. 0, Page 91 of 102, Volume 7, Rev. 0, Page 91 of 102

B 3.2.4 14 INSERT 1 One of the reactivity control systems provided shall be capable of making the core subcritical under any anticipated operating condition (including anticipated operational transients) sufficiently fast enough to prevent exceeding acceptable fuel damage limits.

SDM should assure subcriticality with the most restrictive rod cluster control assembly (RCCA) fully withdrawn Insert Page B 3.2.4-1, Volume 7, Rev. 0, Page 92 of 102, Volume 7, Rev. 0, Page 92 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-2 Rev. 3.0, 03/31/04 BASES APPLICABLE SAFETY ANALYSES (continued)

In MODE 1, the and FQ(Z) limits must be maintained to preclude core power distributions from exceeding design limits assumed in the safety analyses.

H N

F 3

The QPTR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The QPTR limit of 1.02, at which corrective action is required, provides a margin of protection for both the DNB ratio and linear heat generation rate contributing to excessive power peaks resulting from X-Y plane power tilts. A limiting QPTR of 1.02 can be tolerated before the margin for uncertainty in FQ(Z) and (

is possibly challenged.

4 F

H N

F

)

APPLICABILITY The QPTR limit must be maintained in MODE 1 with THERMAL POWER

> 50% RTP to prevent core power distributions from exceeding the design limits.

Applicability in MODE 1 50% RTP and in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require the implementation of a QPTR limit on the distribution of core power. The QPTR limit in these conditions is, therefore, not important. Note that the and FQ(Z) LCOs still apply, but allow progressively higher peaking factors at 50% RTP or lower.

ACTIONS A.1 With the QPTR exceeding its limit, a power level reduction of 3% RTP for each 1% by which the QPTR exceeds 1.00 is a conservative tradeoff of total core power with peak linear power. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allows sufficient time to identify the cause and correct the tilt. Note that the power reduction itself may cause a change in the tilted condition.

from 5

The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of QPTR.

Increases in QPTR would require power reduction within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of QPTR determination, if necessary to comply with the decreased maximum allowable power level. Decreases in QPTR would allow increasing the maximum allowable power level and increasing power up to this revised limit.

, Volume 7, Rev. 0, Page 93 of 102, Volume 7, Rev. 0, Page 93 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-3 Rev. 3.0, 03/31/04 BASES ACTIONS (continued)

A.2 After completion of Required Action A.1, the QPTR alarm may still be in its alarmed state. As such, any additional changes in the QPTR are detected by requiring a check of the QPTR once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

A 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is sufficient because any additional change in QPTR would be relatively slow.

A.3 6

The peaking factors FQ(Z), as approximated by and

, and are of primary importance in ensuring that the power distribution remains consistent with the initial conditions used in the safety analyses.

Performing SRs on and FQ(Z) within the Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions from a Thermal Power reduction per Required Action A.1 ensures that these primary indicators of power distribution are within their respective limits. Equilibrium conditions are achieved when the core is sufficiently stable at intended operating conditions to support flux mapping. A Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions from Thermal Power reduction per Required Action A.1 takes into consideration the rate at which peaking factors are likely to change, and the time required to stabilize the plant and perform a flux map. If these peaking factors are not within their limits, the Required Actions of these Surveillances provide an appropriate response for the abnormal condition. If the QPTR remains above its specified limit, the peaking factor surveillances are required each 7 days thereafter to evaluate F and FQ(Z) with changes in power distribution. Relatively small changes are expected due to either burnup and xenon redistribution or correction of the cause for exceeding the QPTR limit.

)

Z

(

FC Q

)

Z

(

F W Q

H N

F H

N

H N

F 7

a 4

7 the applicable LCOs 8

A.4 Although F and FQ(Z) are of primary importance as initial conditions in the safety analyses, other changes in the power distribution may occur as the QPTR limit is exceeded and may have an impact on the validity of the safety analysis. A change in the power distribution can affect such reactor parameters as bank worths and peaking factors for rod H

N

, Volume 7, Rev. 0, Page 94 of 102, Volume 7, Rev. 0, Page 94 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-4 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) malfunction accidents. When the QPTR exceeds its limit, it does not necessarily mean a safety concern exists. It does mean that there is an indication of a change in the gross radial power distribution that requires an investigation and evaluation that is accomplished by examining the incore power distribution. Specifically, the core peaking factors and the quadrant tilt must be evaluated because they are the factors that best characterize the core power distribution. This re-evaluation is required to ensure that, before increasing THERMAL POWER to above the limit of Required Action A.1, the reactor core conditions are consistent with the assumptions in the safety analyses.

A.5 If the QPTR has exceeded the 1.02 limit and a re-evaluation of the safety analysis is completed and shows that safety requirements are met, the excore detectors are normalized to restore QPTR to within limits prior to increasing THERMAL POWER to above the limit of Required Action A.1.

Normalization is accomplished in such a manner that the indicated QPTR following normalization is near 1.00. This is done to detect any subsequent significant changes in QPTR.

With ing 12 can be Required Action A.5 is modified by two Notes. Note 1 states that the QPTR is not restored to within limits until after the re-evaluation of the safety analysis has determined that core conditions at RTP are within the safety analysis assumptions (i.e., Required Action A.4). Note 2 states that if Required Action A.5 is performed, then Required Action A.6 shall be performed. Required Action A.5 normalizes the excore detectors to restore QPTR to within limits, which restores compliance with LCO 3.2.4.

Thus, Note 2 prevents exiting the Actions prior to completing flux mapping to verify peaking factors, per Required Action A.6. These Notes are intended to prevent any ambiguity about the required sequence of actions.

9

. Any normalization must be performed via normalization of the excore detectors cannot be 9

7 A.6 Once the flux tilt is restored to within limits (i.e., Required Action A.5 is performed), it is acceptable to return to full power operation. However, as an added check that the core power distribution is consistent with the safety analysis assumptions, Required Action A.6 requires verification via normalization of the excore detectors QPTR 9, Volume 7, Rev. 0, Page 95 of 102, Volume 7, Rev. 0, Page 95 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued) 6 that FQ(Z), as approximated by F and F

, and are within their specified limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of achieving equilibrium conditions at RTP.

As an added precaution, if the core power does not reach equilibrium conditions at RTP within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , but is increased slowly, then the peaking factor surveillances must be performed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing THERMAL POWER above the limit of Required Action A.1.

These Completion Times are intended to allow adequate time to increase THERMAL POWER to above the limit of Required Action A.1, while not permitting the core to remain with unconfirmed power distributions for extended periods of time.

)

Z

(

C Q

)

Z

(

W Q

H N

F 4

Required Action A.6 is modified by a Note that states that the peaking factor surveillances may only be done after the excore detectors have been normalized to restore QPTR to within limits (i.e., Required Action A.5). The intent of this Note is to have the peaking factor surveillances performed at operating power levels, which can only be accomplished after the excore detectors are normalized to restore QPTR to within limits and the core returned to power.

4 4

B.1 If Required Actions A.1 through A.6 are not completed within their associated Completion Times, the unit must be brought to a MODE or condition in which the requirements do not apply. To achieve this status, THERMAL POWER must be reduced to < 50% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on operating experience regarding the amount of time required to reach the reduced power level without challenging plant systems.

and other specified any 10 is not met SURVEILLANCE SR 3.2.4.1 REQUIREMENTS SR 3.2.4.1 is modified by two Notes. Note 1 allows QPTR to be calculated with three power range channels if THERMAL POWER is 75% RTP and the input from one Power Range Neutron Flux channel is inoperable. Note 2 allows performance of SR 3.2.4.2 in lieu of SR 3.2.4.1.

This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits. The Frequency of 7 days takes into account other information and alarms available to the operator in the control room.

, Volume 7, Rev. 0, Page 96 of 102, Volume 7, Rev. 0, Page 96 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-6 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued)

For those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.

SR 3.2.4.2 This Surveillance is modified by a Note, which states that it is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the input from one or more Power Range Neutron Flux channels are inoperable and the THERMAL POWER is > 75% RTP.

With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased. Performing SR 3.2.4.2 at a Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months provides an accurate alternative means for ensuring that any tilt remains within its limits.

the input from one or more s

11 For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and four loop cores.

are s

the input from one or more 11 utilizing a minimum of 50% of the 36 installed detector locations, with at least two detectors in each of the core quadrants 16 The symmetric thimble flux map can be used to generate symmetric thimble "tilt." This can be compared to a reference symmetric thimble tilt, from the most recent full core flux map, to generate an incore QPTR.

Therefore, incore monitoring of QPTR can be used to confirm that QPTR is within limits.

With one NIS channel inoperable, the indicated tilt may be changed from the value indicated with all four channels OPERABLE. To confirm that no change in tilt has actually occurred, which might cause the QPTR limit to be exceeded, the incore result may be compared against previous flux maps either using the symmetric thimbles as described above or a complete flux map. Nominally, quadrant tilt from the Surveillance should be within 2% of the tilt shown by the most recent flux map data.

the input from one or more s

11

, Volume 7, Rev. 0, Page 97 of 102, Volume 7, Rev. 0, Page 97 of 102

QPTR B 3.2.4 WOG STS B 3.2.4-7 Rev. 3.0, 03/31/04 BASES REFERENCES

1.

10 CFR 50.46.

USAR, Section 14.2.6.1 2

2.

Regulatory Guide 1.77, Rev [0], May 1974.

3.

10 CFR 50, Appendix A, GDC 26.

USAR, Section 3.1.3.2

, Volume 7, Rev. 0, Page 98 of 102, Volume 7, Rev. 0, Page 98 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT RATIO (QPTR)

1. The punctuation corrections have been made consistent with Section 5.1.3 of the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. The statement concerning why N

H F and FQ(Z) limits must be maintained has been deleted, since it is duplicative of statements provided in the individual Bases for the two factors (ITS 3.2.2 and ITS 3.2.1). The Bases for QPTR is not appropriate for describing why other factors, covered by their own Technical Specifications, are required.

4. Typographical/grammatical error corrected.

5. Editorial changes are made for consistency with the Specification. ISTS 3.2.4 Required Action A.1 requires that THERMAL POWER be reduced " 3% from RTP" for each 1% of QPTR > 1.00. The ISTS Bases state that power is reduced "3%

RTP" for each 1% of QPTR > 1.00. The Bases are revised to be consistent with the Specification.

6. Although the peaking factors are of primary importance in ensuring that the power distribution remains consistent with the initial conditions used in the safety analyses, the approximation of the peaking factor FQ(Z) is not appropriate to be included in ISTS Bases 3.2.4. This information is provided in ISTS Bases 3.2.1, Heat Flux Hot Channel Factor.

7. Typographical error corrected. The terms "Thermal Power" and "Actions" are defined terms, thus they should be fully capitalized.

8. Typographical error corrected. The Required Actions are not considered part of the Surveillances but are part of the LCO of the Specification.

9. Editorial changes are made to the Bases for clarity and consistency with the Specification. ISTS Bases 3.2.4 Required Action A.6 refers to the "flux tilt" being restored to within limits. The "flux tilt" terminology has been revised to "QPTR". In addition, the phrase "via normalization of the excore detectors" has been added to Required Action A.6 for clarification of how the QPTR was restored to within limits.

The ISTS Bases are revised to be consistent with the Specification.

10. These changes have been made to be consistent with similar phrases in other parts of the ITS Bases and to be consistent with the Specification.

11. Changes are made to reflect the verbiage in the Note for SR 3.2.4.2 that states input from one or more Power Range Neutron Flux channels are inoperable. This is consistent with the wording in the actual Note.

12. The intent of Required Action A.5 is to convey the fact that the QPTR continues to exceed the limit versus exceeding the limit and returning to within the limit. The Kewaunee Power Station Page 1 of 2, Volume 7, Rev. 0, Page 99 of 102, Volume 7, Rev. 0, Page 99 of 102

JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT RATIO (QPTR)

Kewaunee Power Station Page 2 of 2 wording of Required Action A.5 has been revised to be consistent with that of Required Action A.1 to provide for clarity.

13. This fuel design criteria is applicable for all Condition 2 events, not just a loss of forced reactor coolant flow accident (which is one of the Condition 2 events).

Therefore, the words "During a loss of forced reactor coolant flow accident" have been deleted. Furthermore, it is noted that the deletion is consistent with similar words in the ISTS 3.2.2 Bases.

14. ISTS 3.2.4 Bases references 10 CFR 50, Appendix A, General Design Criteria.

Kewaunee Power Station (KPS) was designed prior to promulgation of 10 CFR 50, Appendix A. Therefore, the Applicable Safety Analyses Bases has been revised to discuss the design standards used by KPS. Additionally, Bases references to 10 CFR 50, Appendix A have been replaced with references to the appropriate section of the USAR.

15. The correct LCO title has been provided.

16. The Bases for SR 3.2.4.2 describes that incore detector monitoring is performed with a full incore flux map "or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and four loop cores." KPS is a two loop plant and does not have enough thimble locations to provide "quarter core" symmetry. Therefore, the KPS specific words "utilizing a minimum of 50% of the 36 installed detector locations, with at least two detectors for each of the core quadrants" has been provided in lieu of the ISTS Bases words. Furthermore, for KPS, there is no need to list every one of the 36 thimble locations that can be used. The thimble locations in the ISTS Bases are only listed to differentiate between quarter core symmetry and the core as a whole., Volume 7, Rev. 0, Page 100 of 102, Volume 7, Rev. 0, Page 100 of 102

Specific No Significant Hazards Considerations (NSHCs), Volume 7, Rev. 0, Page 101 of 102, Volume 7, Rev. 0, Page 101 of 102

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1, Volume 7, Rev. 0, Page 102 of 102, Volume 7, Rev. 0, Page 102 of 102

ML092440417

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