ML101890236

Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) - Kewaunee ITS Conversion Database

ML101890236
Person / Time
Site:	Kewaunee
Issue date:	06/07/2010
From:	Dominion Energy Kewaunee
To:	Office of Nuclear Reactor Regulation
References
Download: ML101890236 (7)

Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 1 of 7 ITS NRC Questions Id 1941 NRC Question RPG-006 Number Category Technical ITS Section 3.1 ITS Number 3.1.8 DOC Number JFD Number JFD Bases Number Page 190 Number(s)

NRC Reviewer Carl Schulten Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Attachment 1, Volume 6, Rev. 0, Page 190 of 213 proposed ITS LCO 3.1.8, Question PHYSICS TESTS Exceptions - MODE 2 Proposed ITS LCO 3.1.8 change (second paragraph) states, Functions 2, 3, 6 and 16e may be reduced to 3 required channels.

Please also refer to marked-up change on page 181 for ITS LCO 3.1.8. However, per Attachment 1, Volume 8, Rev. 0, Page 9 of 517, CTS Table 3.3.1-1, lists function 16e as 16d for Permissive/Interlock P-10, Power Range Nuclear Instrument. Please correct /explain the change.

Attach File 1 Attach File 2 Issue Date 4/19/2010 Added By Ravinder Grover Date Modified Modified By Date Added 4/19/2010 3:13 PM Notification NRC/LICENSEE Supervision Ravinder Grover http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1941 06/07/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 2 of 7 Licensee Response/NRC Response/NRC Question Closure Id 2801 NRC Question RPG-006 Number Select Licensee Response Application

Response

4/21/2010 7:05 AM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement this is a typographical error. The referenced ITS Table 3.3.1-1 Function should be 16.d, not 16.e or 18.e. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 RPG-006 Markup.pdf (1MB)

Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 4/21/2010 7:09 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2801 06/07/2010

Attachment 1, Volume 6, Rev. 0, Page 181 of 213 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 3 of 7 ITS A01 ITS 3.1.8

f. Minimum Conditions for Criticality Add proposed suspension of LCO 3.4.2 requirement L01

1. The reactor shall not be brought to a critical condition until the pressure-temperature See ITS 3.4.3 state is to the right of the criticality limit line shown in Figure TS 3.1-1.

2. The reactor shall be maintained subcritical by at least 1% k/k until normal water See ITS 3.4.9 level is established in the pressurizer.

LCO 3.1.8 and

3. When the reactor is critical the moderator temperature coefficient shall be as initiated in MODE 2 Applicability specified in the COLR, except during LOW POWER PHYSICS TESTING. The maximum upper moderator temperature coefficient limit shall be 5 pcm/°F for A03 power levels 60% RATED POWER and 0 pcm/ºF for power levels > 60% RATED POWER.

4. If the limits of 3.1.f.3 cannot be met, then power operation may continue provided the following actions are taken:

See ITS 3.1.3 A. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, develop and maintain administrative control rod withdrawal limits sufficient to restore the moderator temperature coefficient to within the limits specified in TS 3.1.f.3. These withdrawal limits shall be in addition to the insertion limits specified in TS 3.10.d.

B. If the actions specified in TS 3.1.f.4.A are not satisfied, then be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Add proposed LCO 3.1.8.a L01 Add proposed LCO 3.1.8.b and LCO 3.1.8.c M01 During performance of PHYSIC TESTS, the number of required channels for LCO 3.3.1, Functions 2, 3, 6, and 18.e may be reduced to 3. A02 16.d Add proposed ACTIONS A and B M01 Add proposed ACTIONS C and D L01 Add proposed SR 3.1.8.1 L01 Add proposed SR 3.1.8.2 and SR 3.1.8.3 M01 Amendment No. 165 TS 3.1-10 03/11/2003 Page 1 of 5 Attachment 1, Volume 6, Rev. 0, Page 181 of 213

Attachment 1, Volume 6, Rev. 0, Page 186 of 213 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 4 of 7 DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS Exceptions - MODE 2 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 3.1.f.3, CTS 3.10.d.3, and CTS 3.10.e state that the limitations of certain specifications may be suspended during the performance of PHYSICS TESTS.

CTS Table TS 3.5-2, Functional Units 2, Nuclear Flux Power Range, states the minimum OPERABLE channel requirement is 3, except as modified by Note (1).

ITS LCO 3.1.8 includes an allowance to reduce the required number of channels for ITS LCO 3.3.1, "RPS Instrumentation," Functions 2 (Power Range Neutron Flux), 3 (Power Range Neutron Flux Rate), 6 (Overtemperature T), and 16.e d (Power Range Neutron Flux, P-10) from "4" to "3" during PHYSICS TESTS. This changes the CTS by stating the specific number of RPS channels from that have to be OPERABLE during PHYSICS TESTS.

The purpose of CTS 3.1.f.3, CTS 3.10.d.3, and CTS 3.10.e is to allow some flexibility during the performance of PHYSIC TESTS. This change is acceptable because the minimum number of channels required for OPERABILITY for the Reactor Trip Functions in CTS Table TS 3.5-2 is currently "3." This allowance is needed since the Required Channels in ITS 3.3.1, Reactor Trip System Instrumentation, is "4." This change from the CTS is discussed in the Discussion of Changes for ITS 3.3.1. Furthermore, the exception identified in CTS Table TS 3.5-2 Note (1) is discussed in DOC M02. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.1.f.3 states that the Moderator Temperature Coefficient requirement specified in the COLR may be suspended during the performance of LOW POWER PHYSICS TESTING. CTS 3.10.d.3 states that the Rod Insertion Limits do not apply during the performance of PHYSICS TESTS. CTS 3.10.e states that the Rod Misalignment Limitations do not apply during the performance of PHYSICS TESTS. ITS 3.1.8 is applicable "During PHYSICS TESTS initiated in MODE 2." This changes the CTS such that the Specification is applicable in MODE 2 only when a PHYSICS TEST is initiated.

The purpose of ITS 3.1.8 Applicability is to ensure that the Actions contained in the Specification are followed. The CTS applicability does not specifically state what MODE the PHYSICS TEST is performed in. The ITS Applicability states emphatically the MODE that the PHYSICS TEST will be performed. This change is designated as administrative because it clarifies the current wording in the Specification with no change in intent.

Kewaunee Power Station Page 1 of 3 Attachment 1, Volume 6, Rev. 0, Page 186 of 213

Attachment 1, Volume 6, Rev. 0, Page 190 of 213 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 5 of 7 CTS PHYSICS TESTS Exceptions - MODE 2 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 PHYSICS TESTS Exceptions - MODE 2 LCO 3.1.8 During the performance of PHYSICS TESTS, the requirements of:

3.1.f LCO 3.1.3, "Moderator Temperature Coefficient,"

3.10.e LCO 3.1.4, "Rod Group Alignment Limits,"  ;

3.10.d LCO 3.1.5, "Shutdown Bank Insertion Limits," 1 3.10.d LCO 3.1.6, "Control Bank Insertion Limits," and  ;

DOC L01 LCO 3.4.2, "RCS Minimum Temperature for Criticality" DOC A02 may be suspended and the number of required channels for LCO 3.3.1, RPS "RTS Instrumentation," Functions 2, 3, 6 and 18.e, may be reduced to 3 4 required channels, provided: 16.d 16 530 DOC L01 a. RCS lowest loop average temperature is [531]°F, 2

1 DOC M01 b. SDM is within the limits specified in the COLR, and DOC M01 c. THERMAL POWER is < 5% RTP.

3.1.f, 3.10.e, 3.10.d, APPLICABILITY: During PHYSICS TESTS initiated in MODE 2.

DOC L01 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. SDM not within limit. A.1 Initiate boration to restore 15 minutes SDM to within limit.

AND A.2 Suspend PHYSICS TESTS 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> exceptions.

DOC M01 B. THERMAL POWER not B.1 Open reactor trip breakers. Immediately within limit.

DOC L01 C. RCS lowest loop C.1 Restore RCS lowest loop 15 minutes average temperature not average temperature to within limit. within limit.

WOG STS 3.1.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 6, Rev. 0, Page 190 of 213

Attachment 1, Volume 6, Rev. 0, Page 199 of 213 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 6 of 7 PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 BASES APPLICABLE SAFETY ANALYSES (continued)

The PHYSICS TESTS include measurement of core nuclear parameters or the exercise of control components that affect process variables.

Among the process variables involved are AFD and QPTR, which represent initial conditions of the unit safety analyses. Also involved are the movable control components (control and shutdown rods), which are required to shut down the reactor. The limits for these variables are specified for each fuel cycle in the COLR.

As described in LCO 3.0.7, compliance with Test Exception LCOs is optional, and therefore no criteria of 10 CFR 50.36(c)(2)(ii) apply. Test Exception LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

Reference 6 allows special test exceptions (STEs) to be included as part of the LCO that they affect. It was decided, however, to retain this STE as a separate LCO because it was less cumbersome and provided additional clarity.

LCO This LCO allows the reactor parameters of MTC and minimum temperature for criticality to be outside their specified limits. In addition, it allows selected control and shutdown rods to be positioned outside of their specified alignment and insertion limits. One power range neutron flux channel may be bypassed, reducing the number of required channels from 4 to 3. Operation beyond specified limits is permitted for the purpose of performing PHYSICS TESTS and poses no threat to fuel integrity, provided the SRs are met.

16.d The requirements of LCO 3.1.3, LCO 3.1.4, LCO 3.1.5, LCO 3.1.6, and LCO 3.4.2 may be suspended and the number of required channels 16 RPS for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, 6 and 18.e may be 4 reduced to 3 required channels during the performance of PHYSICS TESTS provided:

530

a. RCS lowest loop average temperature is [531]°F, 3 1

b. SDM is within the limits provided in the COLR, and 1

c. THERMAL POWER is 5% RTP.

WOG STS B 3.1.8-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 6, Rev. 0, Page 199 of 213

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure - Q&A to Attachment 1 Volume 06 (Section 3.1) Page 7 of 7 Licensee Response/NRC Response/NRC Question Closure Id 2811 NRC Question RPG-006 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 4/21/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Added By Ravinder Grover Date Added 4/21/2010 7:24 AM Modified By Date Modified http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2811 06/07/2010