ML102580709

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)

Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 1 of 24 ITS NRC Questions Id 2221 NRC Question KAB-085 Number Category Technical ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 70 (s)

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

Requested 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 doesnt 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 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 1 of 24 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2221 08/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 2 of 24 Licensee Response/NRC Response/NRC Question Closure Id 4091 NRC Question KAB-085 Number Select Licensee Response Application

Response

8/25/2010 9:05 AM Date/Time Closure Statement Response During the procedure development phase, KPS noted that the ACTUATION Statement 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 inputs are combined such that the actual P-7 has a single channel per RPS logic train.

In addition, ITS Table 3.3.1-1, Function 16.b, P-7 Interlock, requires SR 3.3.1.5 to be performed every 92 days on a STAGGERED TEST BASIS. At KPS, this SR cannot be performed when > 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 performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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. A draft markup regarding these changes is attached.

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

Question Closure Date Attachment KAB-085 Markup.pdf (1MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 2 of 24 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4091 08/25/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 3 of 24 Gerald Riste Ray Schiele Added By Robert Hanley Date Added 8/25/2010 9:10 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 3 of 24 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4091 08/25/2010

ITS A01 ITS 3.3.1 TABLE TS 3.5-2 Table 3.3.1-1 Function INSTRUMENT OPERATION CONDITIONS FOR REACTOR TRIP NOTES See ITS (1) One additional channel may be taken out of service for zero power physics testing. 3.1.8 (2) Deleted M07 (3) When a block condition exists, maintain normal operation. L01 A11 11.a, (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. LA02 11.b Attachment 1, Volume 8, Rev. 1, Page 9 of 528 REQUIRED Permissive/Interlock Channels Coincidence CHANNELS Setting Limit 16.a P-6 Intermediate Range Nuclear Instrument 1 of 2 > 10-5% RATED POWER A03 16.b P-7 3 of 4 Power Range Nuclear Instrument d 12.2% RATED POWER Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 4 of 24 Low Power Reactor Trips Block AND 1 per train 16.e P-13 Turbine Impulse Pressure 2 of 2 d 12.2% RATED POWER (a)

A10 16.c P-8 Power Range Nuclear Instrument 3 of 4 < 10% RATED POWER 16.d P-10 Power Range Nuclear Instrument 2 of 4 t 7.8% RATED POWER (a)

Setting Limit is converted to an equivalent turbine impulse pressure Add proposed Applicability A05 LA02 Add proposed ACTIONS P and Q L04 Attachment 1, Volume 8, Rev. 1, Page 9 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 4 of 24 Amendment No. 195 Page 4 of 4 03/28/2008 Page 5 of 15

Attachment 1, Volume 8, Rev. 1, Page 21 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 5 of 24 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION 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 In addition, the P-7 the RPS Instrumentation to be OPERABLE, and includes only one column in channel description has Table 3.3.1-1 titled "REQUIRED CHANNELS." This changes the CTS by been changed to 1 per train.

changing the title of the MINIMUM OPERABLE CHANNELS" and "Coincidence" columns to "REQUIRED CHANNELS."

Furthermore, the P-7 This change is acceptable because the ITS Table 3.3.1-1 "REQUIRED receives 4 inputs from CHANNELS" column reflects the requirements for when actions are required to nuclear instrumentation be taken, consistent with the CTS Table TS 3.5-2 column when actions must be and 2 inputs from turbine taken. In addition, the change is acceptable for the RPS Permissives and impulse pressure. These Interlocks Note table since the description of the coincidence logic that is inputs are combined such that the actual P-7 has a required (e.g., 1 of 2 for P-6) implies that all the Permissives and Interlock single channel per RPS channels are required. This change is designated as administrative because it logic train. The ITS does not result in technical changes to the CTS.

reflects this design.

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 (Overtemperature T), 6 (Overpower T), 8 (High Pressurizer 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 Kewaunee Power Station Page 2 of 32 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 5 of 24 Attachment 1, Volume 8, Rev. 1, Page 21 of 528

Attachment 1, Volume 8, Rev. 0, Page 37 of 517 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 6 of 24 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION (Function 16.a) every 18 months. Additionally, ITS Table 3.3.1-1 requires (as modified by the Note to the performance of an ACTUATION LOGIC TEST (ITS SR 3.3.1.5) for the Power SR) 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, Kewaunee Power Station Page 18 of 31 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 6 of 24 Attachment 1, Volume 8, Rev. 0, Page 37 of 517

Attachment 1, Volume 8, Rev. 0, Page 61 of 517 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 7 of 24 CTS All changes are 1 RTS Instrumentation unless otherwise noted P 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Table TS 4.1-1 SR 3.3.1.3 -----------------------------NOTE-------------------------------

Channel Description 1 Not required to be performed until [24] hours 2

after THERMAL POWER is t [15]% RTP.

Compare results of the incore detector 31 effective full measurements to Nuclear Instrumentation System power days (NIS) AFD. Adjust NIS channel if absolute (EFPD) difference is t 3%.

Table TS 4.1-3 SR 3.3.1.4 ------------------------------NOTE-------------------------------

Equipment Test 1.a This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service.

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31 Perform TADOT. 62 days on a 11 STAGGERED TEST BASIS Table TS 4.1-1 SR 3.3.1.5 Perform ACTUATION LOGIC TEST. 92 days on a 12 Channel Description 26 STAGGERED TEST BASIS

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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 ACTAUTION LOGIC TEST are required to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of reducing THERMAL POWER to < 10% RTP.

WOG STS 3.3.1-10 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 7 of 24 Attachment 1, Volume 8, Rev. 0, Page 61 of 517

Attachment 1, Volume 8, Rev. 1, Page 70 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 8 of 24 CTS All changes are 1 RTS Instrumentation unless otherwise noted P 3.3.1 5

Table 3.3.1-1 (page 4 of 7) 5 Reactor Trip System Instrumentation Protection APPLICABLE MODES (j)

OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP 5 FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

17. Safety Injection (SI) 1,2 2 trains O SR 3.3.1.14 NA NA 5 Input from 4 Engineered Safety Feature Actuation System (ESFAS)

Protection 16 18. Reactor Trip System Interlocks (d)

Table TS 3.5-2

a. Intermediate 2 2 P Q SR 3.3.1.11  [6E-11] amp [1E-10] amp 4 5 Permissive/

Interlock P-6, Range Neutron SR 3.3.1.13 DOC M14 stet Flux, P-6 Table TS 3.5-2 b. Low Power 1 1 per train Q R SR 3.3.1.5 NA NA 4 5 Permissive/

Interlock P-7, Reactor Trips 4 DOC M14 Block, P-7 Table TS 3.5-2 c. Power Range 1 4 Q R SR 3.3.1.11  [50.2]% RTP [48]% RTP 4 5 Permissive/ Neutron Flux, SR 3.3.1.13 Interlock P-8, Table TS 4.1-1 P-8 Channel Description 1, DOC M14 d. Power Range 1 4 R SR 3.3.1.11  [52.2]% RTP [50]% RTP 4 5 Neutron Flux, SR 3.3.1.13 Table TS 3.5-2 P-9 Permissive/

Interlock P-10, Table TS 4.1-1 e. Power Range 1,2 4 P Q SR 3.3.1.11  [7.8]% RTP [10]% RTP 4 Channel Neutron Flux, SR 3.3.1.13 and  [12.2]% 5 Description 1, d RTP DOC M14 P-10 Table TS 3.5-2 Permissive/ f. Turbine Impulse 1 2 Q R [SR 3.3.1.1]  [12.2]% 10]% turbine 2 4 Interlock P-7, Pressure, P-13 SR 3.3.1.10 turbine power power Table TS 4.1-1 e 5

Channel SR 3.3.1.13 Description 24 17 (g)

Table TS 3.5-2 19. Reactor Trip (i) 1,2 2 trains O P SR 3.3.1.4 NA NA 4 5 Functional Unit 17, Breakers (RTBs)

DOC M09 (b) (b) (b) 3 ,4 ,5 2 trains C SR 3.3.1.4 NA NA 5 (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.

(g) (i) Including any reactor trip bypass breakers that are racked in and closed for bypassing an RTB. 4

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

(j) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. 5 WOG STS 3.3.1-18 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 8 of 24 Attachment 1, Volume 8, Rev. 1, Page 70 of 528

Attachment 1, Volume 8, Rev. 0, Page 74 of 517 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 9 of 24 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION (increasing times), that could impact safety, 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 licensing requirement and the TADOT will be performed on a 31 day frequency.

12. 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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.

Kewaunee Power Station Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 9 of 24 Attachment 1, Volume 8, Rev. 0, Page 74 of 517

Attachment 1, Volume 8, Rev. 1, Page 108 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 10 of 24 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) x 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, 3

and x 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 x 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 s The Low Power Reactor Trips Block, P-7 interlock is actuated by input from either the Power Range Neutron Flux, P-10, or the and 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:

WOG STS B 3.3.1-28 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 10 of 24 Attachment 1, Volume 8, Rev. 1, Page 108 of 528

Attachment 1, Volume 8, Rev. 1, Page 109 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 11 of 24 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 No changes this page -

for info only BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

• Pressurizer Pressure - Low,  ; 3

• Pressurizer Water Level - High,  ; 3

• Reactor Coolant Flow - Low (low flow in two or more RCS loops), ; 3

• RCPs Breaker Open (Two Loops),  ; 3

• 3

• Undervoltage RCPs, and  ;

• Underfrequency RCPs.  ; Turbine Trip - Low Fluid Oil Pressure; and Turbine Trip - Turbine Stop Valve Closure.

These reactor trips are only required when operating above the P-7 setpoint (approximately 10% power). The reactor or, in the case of trips provide protection against violating the DNBR limit. the Turbine Trip Functions, provide a Below the P-7 setpoint, the RCS is capable of providing backup reactor trip sufficient natural circulation without any RCP running. during a loss of load event (2) on decreasing power, the P-7 interlock automatically blocks reactor trips on the following Functions:

• Pressurizer Pressure - Low,  ; 3

• Pressurizer Water Level - High,  ; 3

• Reactor Coolant Flow - Low (low flow in two or more RCS loops), ; 3

• RCP Breaker Position (Two Loops),  ; 3

• Undervoltage RCPs, and  ; 3

• Underfrequency RCPs.  ; Turbine Trip - Low Fluid Oil Pressure; and Turbine Trip - Turbine Stop Valve Closure.

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.

WOG STS B 3.3.1-29 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 11 of 24 Attachment 1, Volume 8, Rev. 1, Page 109 of 528

Attachment 1, Volume 8, Rev. 1, Page 133 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 12 of 24 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of every 31 days is acceptable, The Frequency of every 62 days on a STAGGERED TEST BASIS is based on unit operating experience. justified in Reference 13. 5 SR 3.3.1.5 SR 3.3.1.5 is the performance of an ACTUATION LOGIC TEST. The RPIR 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 The SR is modified by a Note, applicable permissives, are tested for each protection function, including that states that for Function 16.b, operation of the P-7 permissive which is a logic function only. The when > 10% RTP, the SR consists only of verifying the P-7 Frequency of every 92 days on a STAGGERED TEST BASIS is justified interlock is in its required state. in Reference 13. 10 5 12 However, all the applicable requirements of an ACTAUTION LOGIC TEST are required to be SR 3.3.1.6 performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of reducing THERMAL POWER to <

10% RTP. For Function 16.b, the SR 3.3.1.6 is a calibration of the excore channels to the incore channels.

SR cannot be completely If the measurements do not agree, the excore channels are not declared performed in MODE 1 when > inoperable but must be calibrated to agree with the incore detector 10% RTP since the relays cannot measurements. If the excore channels cannot be adjusted, the channels be tested at power (changing are declared inoperable. This Surveillance is performed to verify the f(

state would result in bypassing all input to the overtemperature   

RPS trips associated with the P-7 interlock).

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 4 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.

WOG STS B 3.3.1-53 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 12 of 24 Attachment 1, Volume 8, Rev. 1, Page 133 of 528

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 13 of 24 Licensee Response/NRC Response/NRC Question Closure Id 4111 NRC Question KAB-085 Number Select Licensee Response Application

Response

8/31/2010 11:05 AM Date/Time Closure Statement Response During a review of the attachment included in the 8/25/2010, 9:05 AM response to RAI Statement KAB-085 an error was found. The attached markup replaces the previous markup in its entirety.

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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 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 13 of 24 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4111 08/31/2010

ITS A01 ITS 3.3.1 TABLE TS 3.5-2 Table 3.3.1-1 Function INSTRUMENT OPERATION CONDITIONS FOR REACTOR TRIP NOTES See ITS (1) One additional channel may be taken out of service for zero power physics testing. 3.1.8 (2) Deleted M07 (3) When a block condition exists, maintain normal operation. L01 A11 11.a, (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. LA02 11.b Attachment 1, Volume 8, Rev. 1, Page 9 of 528 REQUIRED Permissive/Interlock Channels Coincidence CHANNELS Setting Limit 16.a P-6 Intermediate Range Nuclear Instrument 1 of 2 > 10-5% RATED POWER A03 16.b P-7 3 of 4 Power Range Nuclear Instrument d 12.2% RATED POWER Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 14 of 24 Low Power Reactor Trips Block AND 1 per train 16.e P-13 Turbine Impulse Pressure 2 of 2 d 12.2% RATED POWER (a)

A10 16.c P-8 Power Range Nuclear Instrument 3 of 4 < 10% RATED POWER 16.d P-10 Power Range Nuclear Instrument 2 of 4 t 7.8% RATED POWER (a)

Setting Limit is converted to an equivalent turbine impulse pressure Add proposed Applicability A05 LA02 Add proposed ACTIONS P and Q L04 Attachment 1, Volume 8, Rev. 1, Page 9 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 14 of 24 Amendment No. 195 Page 4 of 4 03/28/2008 Page 5 of 15

Attachment 1, Volume 8, Rev. 1, Page 21 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 15 of 24 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION 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 In addition, the P-7 the RPS Instrumentation to be OPERABLE, and includes only one column in channel description has Table 3.3.1-1 titled "REQUIRED CHANNELS." This changes the CTS by been changed to 1 per train.

changing the title of the MINIMUM OPERABLE CHANNELS" and "Coincidence" columns to "REQUIRED CHANNELS."

Furthermore, the P-7 This change is acceptable because the ITS Table 3.3.1-1 "REQUIRED receives 4 inputs from CHANNELS" column reflects the requirements for when actions are required to nuclear instrumentation be taken, consistent with the CTS Table TS 3.5-2 column when actions must be and 2 inputs from turbine taken. In addition, the change is acceptable for the RPS Permissives and impulse pressure. These Interlocks Note table since the description of the coincidence logic that is inputs are combined such that the actual P-7 has a required (e.g., 1 of 2 for P-6) implies that all the Permissives and Interlock single channel per RPS channels are required. This change is designated as administrative because it logic train. The ITS does not result in technical changes to the CTS.

reflects this design.

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 (Overtemperature T), 6 (Overpower T), 8 (High Pressurizer 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 Kewaunee Power Station Page 2 of 32 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 15 of 24 Attachment 1, Volume 8, Rev. 1, Page 21 of 528

Attachment 1, Volume 8, Rev. 0, Page 37 of 517 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 16 of 24 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION (Function 16.a) every 18 months. Additionally, ITS Table 3.3.1-1 requires (as modified by the Note to the performance of an ACTUATION LOGIC TEST (ITS SR 3.3.1.5) for the Power SR) 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, Kewaunee Power Station Page 18 of 31 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 16 of 24 Attachment 1, Volume 8, Rev. 0, Page 37 of 517

Attachment 1, Volume 8, Rev. 0, Page 61 of 517 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 17 of 24 CTS All changes are 1 RTS Instrumentation unless otherwise noted P 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Table TS 4.1-1 SR 3.3.1.3 -----------------------------NOTE-------------------------------

Channel Description 1 Not required to be performed until [24] hours 2

after THERMAL POWER is t [15]% RTP.

Compare results of the incore detector 31 effective full measurements to Nuclear Instrumentation System power days (NIS) AFD. Adjust NIS channel if absolute (EFPD) difference is t 3%.

Table TS 4.1-3 SR 3.3.1.4 ------------------------------NOTE-------------------------------

Equipment Test 1.a This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service.

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31 Perform TADOT. 62 days on a 11 STAGGERED TEST BASIS Table TS 4.1-1 SR 3.3.1.5 Perform ACTUATION LOGIC TEST. 92 days on a 12 Channel Description 26 STAGGERED TEST BASIS

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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 ACTUATION LOGIC TEST are required to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of reducing THERMAL POWER to < 10% RTP.

WOG STS 3.3.1-10 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 17 of 24 Attachment 1, Volume 8, Rev. 0, Page 61 of 517

Attachment 1, Volume 8, Rev. 1, Page 70 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 18 of 24 CTS All changes are 1 RTS Instrumentation unless otherwise noted P 3.3.1 5

Table 3.3.1-1 (page 4 of 7) 5 Reactor Trip System Instrumentation Protection APPLICABLE MODES (j)

OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP 5 FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

17. Safety Injection (SI) 1,2 2 trains O SR 3.3.1.14 NA NA 5 Input from 4 Engineered Safety Feature Actuation System (ESFAS)

Protection 16 18. Reactor Trip System Interlocks (d)

Table TS 3.5-2

a. Intermediate 2 2 P Q SR 3.3.1.11  [6E-11] amp [1E-10] amp 4 5 Permissive/

Interlock P-6, Range Neutron SR 3.3.1.13 DOC M14 stet Flux, P-6 Table TS 3.5-2 b. Low Power 1 1 per train Q R SR 3.3.1.5 NA NA 4 5 Permissive/

Interlock P-7, Reactor Trips 4 DOC M14 Block, P-7 Table TS 3.5-2 c. Power Range 1 4 Q R SR 3.3.1.11  [50.2]% RTP [48]% RTP 4 5 Permissive/ Neutron Flux, SR 3.3.1.13 Interlock P-8, Table TS 4.1-1 P-8 Channel Description 1, DOC M14 d. Power Range 1 4 R SR 3.3.1.11  [52.2]% RTP [50]% RTP 4 5 Neutron Flux, SR 3.3.1.13 Table TS 3.5-2 P-9 Permissive/

Interlock P-10, Table TS 4.1-1 e. Power Range 1,2 4 P Q SR 3.3.1.11  [7.8]% RTP [10]% RTP 4 Channel Neutron Flux, SR 3.3.1.13 and  [12.2]% 5 Description 1, d RTP DOC M14 P-10 Table TS 3.5-2 Permissive/ f. Turbine Impulse 1 2 Q R [SR 3.3.1.1]  [12.2]% 10]% turbine 2 4 Interlock P-7, Pressure, P-13 SR 3.3.1.10 turbine power power Table TS 4.1-1 e 5

Channel SR 3.3.1.13 Description 24 17 (g)

Table TS 3.5-2 19. Reactor Trip (i) 1,2 2 trains O P SR 3.3.1.4 NA NA 4 5 Functional Unit 17, Breakers (RTBs)

DOC M09 (b) (b) (b) 3 ,4 ,5 2 trains C SR 3.3.1.4 NA NA 5 (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.

(g) (i) Including any reactor trip bypass breakers that are racked in and closed for bypassing an RTB. 4

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

(j) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. 5 WOG STS 3.3.1-18 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 18 of 24 Attachment 1, Volume 8, Rev. 1, Page 70 of 528

Attachment 1, Volume 8, Rev. 0, Page 74 of 517 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 19 of 24 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION (increasing times), that could impact safety, 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 licensing requirement and the TADOT will be performed on a 31 day frequency.

12. 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 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 performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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, then 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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.

Kewaunee Power Station Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 19 of 24 Attachment 1, Volume 8, Rev. 0, Page 74 of 517

Attachment 1, Volume 8, Rev. 1, Page 108 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 20 of 24 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) x 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, 3

and x 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 x 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 s The Low Power Reactor Trips Block, P-7 interlock is actuated by input from either the Power Range Neutron Flux, P-10, or the and 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:

WOG STS B 3.3.1-28 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 20 of 24 Attachment 1, Volume 8, Rev. 1, Page 108 of 528

Attachment 1, Volume 8, Rev. 1, Page 109 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 21 of 24 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 No changes this page -

for info only BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

• Pressurizer Pressure - Low,  ; 3

• Pressurizer Water Level - High,  ; 3

• Reactor Coolant Flow - Low (low flow in two or more RCS loops), ; 3

• RCPs Breaker Open (Two Loops),  ; 3

• 3

• Undervoltage RCPs, and  ;

• Underfrequency RCPs.  ; Turbine Trip - Low Fluid Oil Pressure; and Turbine Trip - Turbine Stop Valve Closure.

These reactor trips are only required when operating above the P-7 setpoint (approximately 10% power). The reactor or, in the case of trips provide protection against violating the DNBR limit. the Turbine Trip Functions, provide a Below the P-7 setpoint, the RCS is capable of providing backup reactor trip sufficient natural circulation without any RCP running. during a loss of load event (2) on decreasing power, the P-7 interlock automatically blocks reactor trips on the following Functions:

• Pressurizer Pressure - Low,  ; 3

• Pressurizer Water Level - High,  ; 3

• Reactor Coolant Flow - Low (low flow in two or more RCS loops), ; 3

• RCP Breaker Position (Two Loops),  ; 3

• Undervoltage RCPs, and  ; 3

• Underfrequency RCPs.  ; Turbine Trip - Low Fluid Oil Pressure; and Turbine Trip - Turbine Stop Valve Closure.

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.

WOG STS B 3.3.1-29 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 21 of 24 Attachment 1, Volume 8, Rev. 1, Page 109 of 528

Attachment 1, Volume 8, Rev. 1, Page 133 of 528 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 22 of 24 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of every 31 days is acceptable, The Frequency of every 62 days on a STAGGERED TEST BASIS is based on unit operating experience. justified in Reference 13. 5 SR 3.3.1.5 SR 3.3.1.5 is the performance of an ACTUATION LOGIC TEST. The RPIR 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 The SR is modified by a Note, applicable permissives, are tested for each protection function, including that states that for Function 16.b, operation of the P-7 permissive which is a logic function only. The when > 10% RTP, the SR consists only of verifying the P-7 Frequency of every 92 days on a STAGGERED TEST BASIS is justified interlock is in its required state. in Reference 13. 10 5 12 However, all the applicable requirements of an ACTUATION LOGIC TEST are required to be SR 3.3.1.6 performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of reducing THERMAL POWER to <

10% RTP. For Function 16.b, the SR 3.3.1.6 is a calibration of the excore channels to the incore channels.

SR cannot be completely If the measurements do not agree, the excore channels are not declared performed in MODE 1 when > inoperable but must be calibrated to agree with the incore detector 10% RTP since the Turbine measurements. If the excore channels cannot be adjusted, the channels Impulse Pressure relays cannot are declared inoperable. This Surveillance is performed to verify the f(

be cycled at power.

input to the overtemperature   

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 4 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.

WOG STS B 3.3.1-53 Rev. 3.0, 03/31/04 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 22 of 24 Attachment 1, Volume 8, Rev. 1, Page 133 of 528

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 23 of 24 Licensee Response/NRC Response/NRC Question Closure Id 4101 NRC Question KAB-085 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 8/25/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 8/25/2010 10:11 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 23 of 24 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4101 08/25/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 24 of 24 Licensee Response/NRC Response/NRC Question Closure Id 4121 NRC Question KAB-085 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 8/31/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 8/31/2010 11:21 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 8 (Section 3.3) Rev 2, Page 24 of 24 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=4121 08/31/2010