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Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, ITA NRC Questions
	ML102580709
Person / Time
Site:	Kewaunee
Issue date:	09/08/2010
From:	; Dominion, Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
References
	10-521, LAR 249, TAC ME2139
	Download: ML102580709 (24)
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ITS NRC Questions Id2221NRC Question Number KAB-085 Category Technical ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number(s) 70 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 70 of Attachment 1, Volume 8, function 16.b of Table 3.3.1-1 is the P-7 low power reactor trips block interlock. Please explain why SR 3.3.1.5 testing cannot be completed above 10% RTP for P-7. Include how your plant design is different, in which, it doesn't allow testing above 10% RTP.

Attach File 1 Attach File 2 Issue Date 8/24/2010 Added By Kristy Bucholtz Date Modified Modified By Date Added 8/24/2010 6:00 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 08/24/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2221 Licensee Response/NRC Response/NRC Question Closure Id4091NRC Question Number KAB-085 Select Application Licensee Response Response Date/Time 8/25/2010 9:05 AM Closure Statement Response Statement During the procedure development phase, KPS noted that the ACTUATION LOGIC TEST (SR 3.3.1.5) for ITS Table 3.3.1-1 Function 16.b, for P-7 receives 4 inputs from nuclear instrumentation and 2 inputs from turbine impulse pressure. These i nputs are combined such th at the actual P-7 has a single channel per RPS logic train.

In addition, ITS Table 3.3.1-1, Functi on 16.b, P-7 Interlo ck, requires SR 3.3.1.5 to be performed every 92 days on a STAGGERED TEST BASIS. At KPS, this SR cannot be performed wh en > approximately 10% RTP, since the Turbine Impulse Pressure relays cannot be cycled at power. Therefore, a Note has been added for this Function that states "For Function 16.b, when > 10% RTP, the SR consists only of verifying the P-7 interlock is in its required state. However, all the applicable requirements of an ACTUATION LOGIC TEST are required to be perf ormed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of reducing THERMAL POWER to < 10%

RTP." This will allow the SR to not be performed when > 10% RTP except for verifying that the interlock is in the required state, but will still require the SR to be met. Furthermore, anytime power is reduced below 10% RTP, then all requirements of an ACTUATION LOGIC TEST would either h ave to be current (i.e., performed within the last 92 days on a STAGGERED TEST BASIS) or be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the power reduction to below 10% RTP. In a ddition, prior to entering the Applicability of Function 16.b (which is MODE 1), the SR would also have to be current. This ensures the P-7 interlock is properly tested prior to entering MODE 1 and when in MODE 1 with THERMAL POWER < 10% RTP for an extended time. A dr aft markup regarding these changes is attached.

These changes will be reflect ed in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-085 Markup.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Pa ge 1of 2 Kewaunee ITS Conversion Database 08/25/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=4091 Gerald Riste Ray Schiele Added By Robert Hanley Date Added 8/25/2010 9:10 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 08/25/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=4091 TABLE TS 3.5-2 INSTRUMENT OPERATION CONDITIONS FOR REACTOR TRIP Amendment No. 195 Page 4 of 4 03/28/2008 ITS 3.3.1 A01 ITS NOTES (1) One additional channel may be taken out of service for zero power physics testing.

(2) Deleted

(3) When a block condition exists, maintain normal operation.

(4) Underfrequency on the 4-kV buses trips the Reactor Coolant Pump breakers, which in turn trips the reactor when power is above P-7. Permissive/Interlock Channels Coincidence Setting Limit P-6 Intermediate Range Nuclear Instrument 1 of 2 > 10-5% RATED POWER P-7 Power Range Nuclear Instrument 3 of 4 AND 2 of 2 12.2% RATED POWER Turbine Impulse Pressure 12.2% RATED POWER (a) P-8 Power Range Nuclear Instrument 3 of 4 < 10% RATED POWER P-10 Power Range Nuclear Instrument 2 of 4 7.8% RATED POWER (a) Setting Limit is converted to an equivalent turbine impulse pressure Page 5 of 15 Table 3.3.1-1 Function 16.a 16.b 16.c 16.d A05 L04 Add proposed Applicability Add proposed ACTIONS P and Q 11.a, 11.b M07 L01 See ITS 3.1.8 LA02 LA02 16.e P-13 Low Power Reactor Trips Block A10 A11 REQUIRED CHANNELS A03 A ttachment 1, Volume 8, Rev. 1, Page 9 of 528 A ttachment 1, Volume 8, Rev. 1, Page 9 of 528 1 per train DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 2 of 32 A03 CTS Table TS 3.5-2, Column 3 specifies the "MINIMUM OPERABLE CHANNELS" associated with each RPS Functional Unit and CTS 3.5.2 specifies the actions to take when the number of channels for a particular Functional Unit is less than the Column 3 requirements. Additionally, the Notes for Table

TS 3.5-2 contain a table that pertains to the RPS Permissives and Interlocks.

This Note table contains a column titles "Coincident," which describes the coincidence logic needed for each permissive/interlock. ITS LCO 3.3.1 requires the RPS Instrumentation to be OPERABLE, and includes only one column in Table 3.3.1-1 titled "REQUIRED CHANNELS." This changes the CTS by changing the title of the MINIMUM OPERABLE CHANNELS" and "Coincidence" columns to "REQUIRED CHANNELS."

This change is acceptable because the ITS Table 3.3.1-1 "REQUIRED CHANNELS" column reflects the requirements for when actions are required to be taken, consistent with the CTS Table TS 3.5-2 column when actions must be taken. In addition, the change is acceptable for the RPS Permissives and Interlocks Note table since the description of the coincidence logic that is required (e.g., 1 of 2 for P-6) implies that all the Permissives and Interlock channels are required. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS Table TS 3.5-2 Column 6 specifies the "OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET." CTS Table TS 3.5-2 Column 6 requires maintaining HOT SHUTDOWN for Functional Units 1, 2, 3, 4, 5, 6, 8, 9, 10, 12, 13, 14, 16, and 17. Based on the CTS Table TS 3.5-2 requirement to maintain HOT SHUTDOWN, the Mode of Applicability would be considered OPERATING and HOT STANDBY for Functional Units 1(Manual), 2, (Nuclear Flux Power Range (High Setting, Positive Setting, and Negative Setting)), 5 (Overte Pressure), 12 (Lo-Lo Steam Generator Water Level), 16 (Steam Flow/Feedwater Flow Mismatch), and 17 (Reactor Trip Breaker (RTB) and (Independently Test Shunt and Undervoltage Trip Attachments). For Functional Unit 2 (Nuclear Flux Power Range (Low Setting)), the Mode of Applicability is OPERATING below the P-10 interlock and HOT STANDBY for the Nuclear Flux Power Range (Low Setting) because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-10. This means that the Nuclear Flux Power Range (Low Setting) channels are blocked above the P-10 setting. With the P-10 Setting Limit of

< 7.8% RATED POWER, Nuclear Flux Power Range (Low Setting) would be required to be OPERABLE in the OPERATING MODE below the P-10 limit and in HOT STANDBY. For Functional Unit 3 (Nuclear Flux Intermediate Range), the MODE of Applicability is OPERATING below the P-10 interlock and HOT STANDBY because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-10. This means that the Nuclear Flux Intermediate Range channels are blocked above the P-10 setting. With the P-10 Setting Limit of < 7.8% RATED POWER, Nuclear Flux Intermediate Range would be required to be OPERABLE in the OPERATING MODE below the P-10 limit. Furthermore, since the Nuclear Flux Intermediate Range are not required until above the P-6 setting, then the HOT STANDBY requirement would only be above the P-6

setting. Therefore, the MODE of Applicability, for the Nuclear Flux Intermediate Range, would be OPERATING below the P-10 interlock and HOT STANDBY above the P-6 interlock. For Functional Unit 4 (Nuclear Source Range), the A ttachment 1, Volume 8, Rev. 1, Page 21 of 528 A ttachment 1, Volume 8, Rev. 1, Page 21 of 528 In addition, the P-7 channel description has

been changed to 1 per

train.Furthermore, the P-7

receives 4 inputs from

nuclear instrumentation

and 2 inputs from turbine

impulse pressure. These

inputs are combined such

that the actual P-7 has a

single channel per RPS

logic train. The ITS

reflects this design.

DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 18 of 31 (Function 16.a) every 18 months. Additionally, ITS Table 3.3.1-1 requires performance of an ACTUATION LOGIC TEST (ITS SR 3.3.1.5) for the Power Range Neutron Flux, P-7 (Function 16.b). ITS SR 3.3.1.5 requires performance of an ACTUATION LOGIC TEST every 92 days on a STAGGERED TEST BASIS. ITS SR 3.3.1.11 requires performance of CHANNEL CALIBRATION in accordance with the Setpoint Control Program every 18 months. This surveillance is modified by a Note which excludes the neutron detectors from the CHANNEL CALIBRATION. ITS SR 3.3.1.13 requires performance of a COT every 18 months. This changes the CTS by requiring performance of a COT, CHANNEL CALIBRATION and an ACTUATION LOGIC TEST on the Permissive/Interlocks that was not required in the CTS.

The addition of these test is acceptable because the COT, CHANNEL CALIBRATION and ACTUATION LOGIC TEST will verify that the Permissive/Interlocks are functioning properly and will perform their required safety functions. A COT injects a signal into the channel to verify the OPERABILITY of all the devices. A CHANNEL CALIBRATION adjusts the output of the channel so that it will respond within the parameters that the channel monitors. An ACTUATION LOGIC TEST verifies that the output logic is appropriate for the input parameters. This change is designated as more

restrictive because Surveillance Requirements are being added to the ITS that were not required in the CTS.

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES

LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits)

CTS Table TS 3.5-2 has four columns stating various requirements for each Functional Unit. These columns are titled "NO. OF

CHANNELS," "NO. OF CHANNELS TO TRIP," "MINIMUM OPERABLE CHANNELS," and "MINIMUM DEGREE OF REDUNDANCY." ITS Table 3.3.1-1 does not contain the "NO. OF CHANNELS," "NO. OF CHANNELS TO TRIP,"

and "MINIMUM DEGREE OF REDUNDANCY" columns. This changes the CTS by moving the information provided in the "NO. OF CHANNELS," "NO. OF CHANNELS TO TRIP," and "MINIMUM DEGREE OF REDUNDANCY" columns to the Bases. Note that Discussion of Changes M01 describes the changes to the number of channels required by the LCO and Discussion of Change A03 describes the change in the title of the "MINIMUM OPERABLE CHANNELS" column.

The removal of these details, which relate to system design, 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 maintains the requirement for the number of required channels (which includes all of the installed channels) and the appropriate Condition to enter if a required channel is inoperable. In addition, A ttachment 1, Volume 8, Rev. 0, Page 37 of 517 A ttachment 1, Volume 8, Rev. 0, Page 37 of 517 (as modified by the Note to the

SR)

RTS Instrumentation 3.3.1 WOG STS 3.3.1-10 Rev. 3.0, 03/31/04 CTS P All changes are unless otherwise noted 1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.3 -----------------------------NOTE------------------------------- Not required to be performed until [24] hours after THERMAL POWER is [15]% RTP. ---------------------------------------------------------------------

Compare results of the incore detector measurements to Nuclear Instrumentation System (NIS) AFD. Adjust NIS channel if absolute difference is 3%.

31 effective full

power days (EFPD)

SR 3.3.1.4 ------------------------------NOTE-------------------------------

This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. ---------------------------------------------------------------------

Perform TADOT.

62 days on a

STAGGERED TEST BASIS SR 3.3.1.5 Perform ACTUATION LOGIC TEST.

92 days on a

STAGGERED TEST BASIS

Table TS 4.1-1 Channel Description 1 Table TS 4.1-3 Equipment Test 1.a Table TS 4.1-1 Channel Description 26 2 31 11 A ttachment 1, Volume 8, Rev. 0, Page 61 of 517 A ttachment 1, Volume 8, Rev. 0, Page 61 of 517

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

For Function 16.b, when > 10% RTP, the SR consists only of verifying the P-7

interlock is in its required state. However, all the applicable requirements of an A CTAUTION LOGIC TEST are required to be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of reducing

THERMAL POWER to < 10% RTP.

12 RTS Instrumentation 3.3.1 WOG STS 3.3.1-18 Rev. 3.0, 03/31/04 Table 3.3.1-1 (page 4 of 7)

Reactor Trip System Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS

CONDITIONS

SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL (j) TRIP SETPOINT 17. Safety Injection (SI)

Input from Engineered Safety Feature Actuation System (ESFAS) 1,2 2 trains O SR 3.3.1.14 NA NA 18. Reactor Trip System Interlocks a. Intermediate Range Neutron Flux, P-6 2 (d) 2 Q SR 3.3.1.11 SR 3.3.1.13

[1E-10] amp

b. Low Power Reactor Trips

Block, P-7 1 1 per train R

SR 3.3.1.5 NA NA c. Power Range Neutron Flux,

P-8 1 4 R SR 3.3.1.11 SR 3.3.1.13 P [48]% RTP

d. Power Range Neutron Flux, P-9 1 4 R SR 3.3.1.11 SR 3.3.1.13 P [50]% RTP

e. Power Range Neutron Flux,

P-10 1,2 4 Q SR 3.3.1.11 SR 3.3.1.13 P 2]% RTP [10]% RTP

f. Turbine Impulse Pressure, P-13 1 2 R

[SR 3.3.1.1] SR 3.3.1.10 SR 3.3.1.13 turbine power 10]% turbine power 19. Reactor Trip Breakers (i) (RTBs) 1,2 2 trains P SR 3.3.1.4 NA NA 3 (b), 4 (b), 5 (b) 2 trains C SR 3.3.1.4 NA NA (b) With Rod Control System capable of rod withdrawal or one or more rods not fully inserted.

(d) Below the P-6 (Intermediate Range Neutron Flux) interlocks.

(i) Including any reactor trip bypass breakers that are racked in and closed for bypassing an RTB.

REVIEWERS NOTE-------------------------------------------------------------------------------------- (j) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Table TS 3.5-2 Functional Unit 17, DOC M09 Table TS 3.5-2 Permissive/

Interlock P-6, DOC M14 Table TS 3.5-2 Permissive/ Interlock P-7, DOC M14 Table TS 3.5-2 Permissive/

Interlock P-8, Table TS 4.1-1 Channel Description 1, DOC M14 Table TS 3.5-2 Permissive/

Interlock P-10, Table TS 4.1-1 Channel Description 1, DOC M14 Table TS 3.5-2 Permissive/

Interlock P-7, Table TS 4.1-1 Channel Description 24 e d Protection 16 17 P Q Q P Q O (g) (g) 5 5 4 4 4 4 4 4 4 4 4 5 5 5 5 5 5 5 5 5 P All changes are unless otherwise noted 1 CTS 5 5 4 2 Protection A ttachment 1, Volume 8, Rev. 1, Page 70 of 528 A ttachment 1, Volume 8, Rev. 1, Page 70 of 528 stet JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 2 of 2 (increasing times), that could impact s afety, do not normally vary such that they would not be detected during other required surveillances (e.g., CHANNEL CALIBRATIONS). Since the addition of these tests would be a major burden (plant design does not readily lend itself to such testing) with little gain in safety, ISTS SR 3.3.1.16 has not been added.

8. A Note to ISTS SR 3.3.1.10 requires the CHANNEL CALIBRATION to include verification that time constants are adjusted to the prescribed values. ITS SR 3.3.1.10 does not include this Note since it does not apply to any ITS Table 3.3.1-1 Functions that include time constants.

9. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. Required Actions for Conditions D, E, and K are

modified by a Note that provides two options for bypassing a channel for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for the purpose of performing surveillance testing without requiring entry into the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for plants that do not have installed bypass testing capabilities.

KPS does not have installed bypass testing capabilities. Therefore, the Note for plants that do not have bypass testing capabilities is retained for Conditions D, E, and K.

10. ISTS Table 3.3.1-1 Function 16 (including Note h) provides the requirements for the Turbine Trip Function. This Function is not included in the KPS ITS. This Function is not assumed in any accident or transient in USAR Chapter 14.

Therefore, it is not being added to the KPS ITS. This is also consistent with the current Technical Specifications, which does not include this RPS Function.

11. ISTS Table 3.3.1-1 Functions 17 (Reactor Trip Breakers (RTBs)) and 18 (Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms) requires performance of a TADOT (ISTS SR 3.3.1.4) every 62 days on a STAGGERED TEST BASIS. Based on KPS's review of 15376, Revision 1 ("Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times"), dated March 2003, the justification used to extend the Surveillance Test Interval from monthly on a STAGGERED TEST BASIS (i.e., each breaker tested every two months) to 62 days on a

STAGGERED TEST BASIS (i.e., each breaker tested every four months) is not applicable to KPS since KPS tests the breakers monthly. Therefore, ITS SR 3.3.1.4 will contain the KPS current licen sing requirement and the TADOT will be performed on a 31 day frequency.

A ttachment 1, Volume 8, Rev. 0, Page 74 of 517 A ttachment 1, Volume 8, Rev. 0, Page 74 of 517 ISTS Table 3.3.1-1, Function 18.b, P-7 Interlock, requires SR 3.3.1.5 to be performed. SR 3.3.1.5 is an ACTUATION LOGIC TEST that is required to be performed every 92 days on a STAGGERED TEST BASIS. At KPS, this SR

cannot be performed when > 10% RTP, since the relays cannot be tested at power (changing state would result in bypassing all RPS trips associated with the P-7 interlock). Therefore, a Note has been added for this Function that

states "For Function 16.b, when > 10% RTP, the SR consists only of verifying the P-7 interlock is in its required state.

However, all the applicable requirements of an ACTAUTION LOGIC TEST are required to be performed within 12

hours of reducing THERMAL POWER to < 10% RTP." This will allow the SR to not be performed when > 10% RTP except for verifying that the interlock is in the required state, but still require the SR to be met. Furthermore, anytime

power is reduced below 10% RTP, the all requirements of an ACTUATION LOGIC TEST would either have to be

current (i.e., performed within the last 92 days on a STAGGERED TEST BASIS) or be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

the power reduction to below 10% RTP. In addition, prior to entering the Applicability of Function 16.b (which is

MODE 1), the SR would also have to be current. This ensures the P-7 interlock is properly tested prior to entering

MODE 1 and when in MODE 1 with THERMAL POWER < 10% RTP for an extended time.

12.

RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-28 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) on increasing power, the P-6 interlock allows the manual block of the NIS Source Range, Neutron Flux reactor trip.

This prevents a premature block of the source range trip and allows the operator to ensure that the intermediate range is OPERABLE prior to leaving the source range. When the

source range trip is blocked, the high voltage to the detectors is also removed, on decreasing power, the P-6 interlock automatically energizes the NIS source range detectors and enables the NIS Source Range Neutron Flux reactor trip, and on increasing power, the P-6 interlock provides a backup block signal to the source range flux doubling circuit.

Normally, this Function is manually blocked by the control

room operator during the reactor startup.

The LCO requires two channels of Intermediate Range Neutron Flux, P-6 interlock to be OPERABLE in MODE 2 when below the

P-6 interlock setpoint.

Above the P-6 interlock setpoint, the NIS Source Range Neutron Flux reactor trip will be blocked, and this Function will no longer be necessary.

In MODE 3, 4, 5, or 6, the P-6 interlock does not have to be OPERABLE because the NIS Source Range is providing core

protection.

b. Low Power Reactor Trips Block, P-7 The Low Power Reactor Trips Block, P-7 interlock is actuated by

input from either the Power Range Neutron Flux, P-10, or the Turbine Impulse Pressure, P-13 interlock. The LCO requirement for the P-7 interlock ensures that the following Functions are

performed:

(1) on increasing power, the P-7 interlock automatically enables reactor trips on the following Functions:

3 ; and A ttachment 1, Volume 8, Rev. 1, Page 108 of 528 A ttachment 1, Volume 8, Rev. 1, Page 108 of 528 s and RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-29 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Pressurizer Pressure - Low,

Pressurizer Water Level - High,

Reactor Coolant Flow - Low (low flow in two or more RCS loops),

RCPs Breaker Open (Two Loops),

Undervoltage RCPs, and

Underfrequency RCPs.

These reactor trips are only required when operating above the P-7 setpoint (approximately 10% power). The reactor

trips provide protection against violating the DNBR limit.

Below the P-7 setpoint, the RCS is capable of providing sufficient natural circulation without any RCP running.

(2) on decreasing power, the P-7 interlock automatically blocks reactor trips on the following Functions:

Pressurizer Pressure - Low,

Pressurizer Water Level - High,

Reactor Coolant Flow - Low (low flow in two or more RCS loops),

RCP Breaker Position (Two Loops),

Undervoltage RCPs, and

Underfrequency RCPs.

Trip Setpoint and Allowable Value are not applicable to the P-7 interlock because it is a logic Function and thus has no parameter with which to associate an LSSS.

The P-7 interlock is a logic Function with train and not channel identity. Therefore, the LCO requires one channel per train of Low Power Reactor Trips Block, P-7 interlock to be OPERABLE in MODE 1.

3 3 3 3 3;; ;; 3 3 3 3 3; ;; ;;;;;Turbine Trip - Low Fluid Oil Pressure; and Turbine Trip - Turbine Stop Valve Closure.Turbine Trip - Low Fluid Oil Pressure; and Turbine Trip - Turbine Stop Valve Closure. or, in the case of the Turbine Trip Functions, provide a backup reactor trip during a loss of load event A ttachment 1, Volume 8, Rev. 1, Page 109 of 528 A ttachment 1, Volume 8, Rev. 1, Page 109 of 528 No changes this page -

for info only RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-53 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

SURVEILLANCE REQUIREMENTS (continued)

The Frequency of every 62 days on a STAGGERED TEST BASIS is justified in Reference 13.

SR 3.3.1.5 SR 3.3.1.5 is the performance of an ACTUATION LOGIC TEST. The SSPS is tested every 92 days on a STAGGERED TEST BASIS, using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function, including operation of the P-7 permissive which is a logic function only. The Frequency of every 92 days on a STAGGERED TEST BASIS is justified

in Reference 13.

SR 3.3.1.6 SR 3.3.1.6 is a calibration of the excore channels to the incore channels.

If the measurements do not agree, the excore channels are not declared inoperable but must be calibrated to agree with the incore detector measurements. If the excore channels cannot be adjusted, the channels are declared inoperable. This Surveillance is performed to verify the f(

input to the

A Note modifies SR 3.3.1.6. The Note states that this Surveillance is

required only if reactor power is

> 50% RTP and that [24] hours is allowed for performing the first surveillance after reaching 50% RTP.

The Frequency of 92 EFPD is adequate. It is based on industry operating experience, considering instrument reliability and operating history data for instrument drift.

RPIR The Frequency of every 31 days is acceptable, based on unit operating experience.

12 5 10 4 A ttachment 1, Volume 8, Rev. 1, Page 133 of 528 A ttachment 1, Volume 8, Rev. 1, Page 133 of 528 The SR is modified by a Note, that states that for Function 16.b, when > 10% RTP, the SR consists only of verifying the P-7

interlock is in its required state.

However, all the applicable

requirements of an ACTAUTION

LOGIC TEST are required to be

performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of

reducing THERMAL POWER to <

10% RTP. For Function 16.b, the

SR cannot be completely

performed in MODE 1 when >

10% RTP since the relays cannot

be tested at power (changing

state would result in bypassing all

RPS trips associated with the P-7

interlock).

5 Licensee Response/NRC Response/NRC Question Closure Id4111NRC Question Number KAB-085 Select Application Licensee Response Response Date/Time 8/31/2010 11:05 AM Closure Statement Response Statement During a review of the attachment included in the 8/25/2010, 9:05 AM response to RAI KAB-085 an error was found. The attached markup replaces the previous markup in its entirety. Question Closure Date Attachment 1 KAB-085 Markup R1.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Gerald Riste Added By Gerald Riste Date Added 8/31/2010 11:03 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 08/31/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=4111 TABLE TS 3.5-2 INSTRUMENT OPERATION CONDITIONS FOR REACTOR TRIP Amendment No. 195 Page 4 of 4 03/28/2008 ITS 3.3.1 A01 ITS NOTES (1) One additional channel may be taken out of service for zero power physics testing.