ML042300418

Response to NRC Request for Additional Information License Amendment Request 203 to Plant Technical Specifications. Rod Position Indication.

ML042300418
Person / Time
Site:	Kewaunee
Issue date:	08/06/2004
From:	Coutu T Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-04-092
Download: ML042300418 (4)

Text

Committed to a n Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC August 6, 2004 NRC-04-092 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Kewaunee Nuclear Power Plant Docket 50-305 License No. DPR-43 Response to NRC Request for Additional information re: License Amendment Request 203 To The Kewaunee Nuclear Power Plant Technical Specifications. "Rod Position Indication."

Reference:

1) Letter from NMC to NRC, "License Amendment Request 203 To The Kewaunee Nuclear Power Plant Technical Specifications, "Rod Position Indication," dated May 25, 2004 The Nuclear Management Company, LLC, (NMC) submitted a license amendment request (LAR), number 203, to the Kewaunee Nuclear Power Plant (KNPP) Technical Specifications (TS) to revise Section 3.10.f, "Inoperable Rod Position Indicator Channels," reference 1. This LAR requested changes to KNPP TS to add an allowed outage time (AOT) for the IRPI system of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with more than one IRPI per group inoperable. The current TS do not have an AOT for this condition. Reference 1 also requested additional changes to the KNPP TS. Those additional changes include adding the demand step counters, adding a note to allow for a soak time subsequent to substantial rod motion for the rods that exceed their position limits before invoking the TS requirements, and defining "immediately" in TS section 1.0.

Subsequently the NRC staff has requested additional information to clarify parts of the submittal. This letter is the NMC response to the NRC staff's request. Enclosure 1 to this letter contains the NRC staff's questions with NMC's response. The information contained in this response does not alter the conclusions reached in the no significant hazards determination and environmental considerations contained in reference 1.

N490 Highway 42 . Kewaunee, Wisconsin 54216-9511 Telephone: 920.388.2560 pc1

Docket 50-305 NRC-04-062 Page 2 A complete copy of this submittal has been transmitted to the State of Wisconsin as required by 10 CFR 50.91(b)(1).

NMC requests approval as delimitated in reference 1.

This letter makes the no new commitments or revisions to previous commitments.

Ifyou have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 6, 2004.

Thomas Coutu Site Vice President Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosures (1) cc: Administrator, Region III, USNRC Senior Resident Inspector, Kewaunee, USNRC Project Manager, Kewaunee, USNRC Public Service Commission of Wisconsin

ENCLOSURE 1 NUCLEAR MANAGEMENT COMPANY, LLC NMC RESPONSE TO NRC STAFFS' REQUEST FOR ADDITIONAL INFORMATION RE: EVALUATION OF LICENSE AMENDMENT REQUEST 203 TO KEWAUNEE NUCLEAR POWER PLANT, OPERATING LICENSE NO. DPR-43 DOCKET NO. 50-305 NRC Staff Question #1 The technical analysis section for the proposed change no. 6 states that the rod position will be verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as part of the new action statement. However, in the markup and revised pages (TS 3.10-6), it is stated that the rod position is verified by movable incore detectors every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Please clarify which time duration is correct for performing this action.

NMC Response:

The rod position verification will be performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as stated in the technical specification. Originally, NMC thought the intent of the verificatidn pebiodicity was to be performed on a operations shift basis. As the operations crew at KNPP is on a 12-hour shift rotation, once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was thought to be the intent. On further review the decision to stay with the NUREG 1431 8-hour frequency was made without changing the time period in the technical analysis section.

NRC Staff Question #2 Inthe markup page (TS 3.10-6), it is stated for item D that either the inoperable IRPI be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the plant be placed in HOT SHUTDOWN (MODE 4) in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The WOG STS requires the plant to be placed in HOT STANDBY (MODE 3) in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when any action items cannot be completed in the given time. Please justify this deviation from the STS and whether the plant can successfully be placed into MODE 4 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if that option is chosen.

NMC Response:

This is not a deviation from STS just a difference in the mode description between STS and KNPP's custom technical specifications (CTS). NUREG 1431 Rev 3, states that Mode 3, "Hot Standby," is where the plant is in a condition where keff is < 0.99 (Reactor Shutdown) and the average reactor coolant temperature is 2 3500F. In KNPP Technical Specifications definitions, item 1.0.j, "Modes", Hot Shutdown is the KNPP similar to STS Mode 3, Hot Standby.

Page 1 of 2

Table 1 STS to KNPP CTS Mode Comnarison STS Mode # STS Mode Title KNPP CTS Mode Title 1 Power Operation Operating 2 Startup Hot Standby 3 Hot Standby Hot Shutdown 4 Hot Shutdown Intermediate Shutdown 5 Cold Shutdown Cold Shutdown 6 Refueling Refueling The table below is from KNPP CTS that describes the Plant Modes.

Table 2 Kewaunee Nuclear Power Plant Technical Specification 1.0.j - Modes.

lMODE MOER lREACTIVITY AC II Y kkTavg k lCOOLANTOFTEMP FISSION POWER %

REFUELING < -5% 5140 -0 COLD SHUTDOWN < -1% < 200 -0 INTERMEDIATE (1) > 200 < 540 -0 SHUTDOWN HOT SHUTDOWN (1) 2 540 -0 HOT STANDBY < 0.25% -Toper <2 OPERATING < 0.25% -Toper >2 PHYSICS TESTING (To be specified by specific tests)

(1) Refer to the required SHUTDOWN MARGIN as specified in the Core Operating Limits Report.

Page 2 of 2