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Kewaunee, Enclosure (7 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3)
	ML102371269
Person / Time
Site:	Kewaunee
Issue date:	08/18/2010
From:	; Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
References
	10-457, TAC ME2139
	Download: ML102371269 (501)
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ITS NRC Questions Id1551NRC Question Number KAB-065 Category Technical ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number(s)76-143 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Pages 76 through 143 of Attachment 1, volume 8, ar e the proposed TS 3.3.1 Bases. TS 3.3.1 Bases are not consistent with the Bases in TSTF-493, Revision 4, incl uding applicable errata. Please correct the TS 3.3.1 Bases or provide an exp lanation of the changes.

Attach File 1 Attach File 2 Issue Date 1/26/2010 Added By Kristy Bucholtz Date Modified Modified By Date Added 1/26/2010 10:33 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=1551 Licensee Response/NRC Response/NRC Question Closure Id2011NRC Question Number KAB-065 Select Application Licensee Response Response Date/Time 2/4/2010 6:30 AM Closure Statement Response Statement The Kewaunee Power Station (KPS)

ITS Amendment was based upon the most current revision of TSTF-493 at the time of submittal. Since the date of the submittal, a newer revision (Rev. 4) of the TSTF has been sent to the NRC for review. KPS has reviewed this revision and appropriate changes will be made. A draft markup regarding this change is attached. This change will be reflected in the suppl ement to this se ction of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-065 Markup.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 2/4/2010 6:34 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/10/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2011 RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-1 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 B 3.3 INSTRUMENTATION

B 3.3.1 Reactor Trip System (RTS) Instrumentation

BASES BACKGROUND The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and Reactor Coolant System (RCS) pressure boundary during anticipated operational occurrences (AOOs) and to assist the Engineered Safety Features (ESF) Systems in mitigating accidents.

The protection and monitoring systems have been designed to assure safe operation of the reactor. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the RTS, as well as specifying LCOs on other reactor system parameters and equipment performance.

Technical Specifications are required by 10 CFR 50.36 to contain LSSS

defined by the regulation as "...s ettings for automatic protective devices...so chosen that automatic protective action will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytic Limit is the limit of the process variable at which a safety action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytic Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protective devices must be chosen to be more conservative than the Analytic Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.

The trip setpoint is a predetermined setting for a protective device chosen to ensure automatic actuation prior to the process variable reaching the Analytic Limit and thus ensuring that the SL would not be exceeded. As such, the trip setpoint accounts for uncertainties in setting the device (e.g., calibration), uncertainties in how the device might actually perform (e.g., repeatability), changes in the point of action of the device over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the trip setpoint plays an important role in ensuring that SLs are not exceeded. As such, the trip setpoint meets the definition of an LSSS (Ref. 1) and could be used to meet the requirement that they be contained in the Technical Specifications.

Protection P P P 2 include LSSS are Analytical protective Analytical protection channels Analytical INSERT 1 INSERT 2 Analytical [Nominal Trip Setpoint (NTSP)] specified in the SCP protection channel [NTSP] channel [NTSP] ensures Therefore [NTSP] for variables that have significant safety functions.

2 7 Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that actions B 3.3.1 Insert Page B 3.3.1-1 INSERT 1 The LSSS values are identified and maintained in the Setpoint Control Program (SCP) controlled by 10 CFR 50.59.

INSERT 2 ------------------------------------------- REVIEWER'S NOTE ------------------------------------------- The term "Limiting Trip Setpoint (LTSP)" is generic terminology for the calculated setting (setpoint) value calculated by means of the plant-specific setpoint methodology documented in a document controlled under 10 CFR 50.59. The term [LTSP] indicates that no additional margin has been added between the Analytical Limit and the calculated trip setting.

For most Westinghouse plants the term Nominal Trip Setpoint (NTSP) is the terminology

for the setpoint value calculated by means of the plant-specific setpoint methodology documented in a document subject to 10 CFR 50.59. The term NTSP indicates that no

additional margin has been added between the Analytical Limit and the calculated trip setting. The NTSP would replace LTSP in the Bases descriptions. The term field setting is terminology for the actual setpoint implemented in the plant surveillance procedures which is standard terminology for the NTSP with additional margin applied. The as-found and as-left tolerances will apply to the actual setpoint (field setting) implemented in the Surveillance procedures to confirm channel performance.

The [NTSP] and field setting are located in the SCP.

2 2 5 7 in place of the term LTSP and NTSP will replace LTSP in the Bases descriptions. "Field setting" is the suggested terminology for the actual setpoint where margin has been added to the calculated.

RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-2 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

BACKGROUND (continued)

Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as "...being capable of performing its safety functions(s)." For automatic protective devices, the required safety function is to ensure that a SL is not exceeded and therefore the LSSS as defined by 10 CFR 50.36 is the same as the OPERABILITY limit for these devices. However, use of the trip setpoint to define OPERABILITY in Technical Specifications and its corresponding designation as the LSSS

required by 10 CFR 50.36 would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as found" value of a protective device setting during a surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety. For example, an automatic protective device with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE since drift is to be expected. This

expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as found" setting of the protective device. Therefore, the device would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the device to the trip setpoint to account for further drift during the next surveillance interval.

Use of the trip setpoint to define "as found" OPERABILITY and its designation as the LSSS under the expected circumstances described above would result in actions required by both the rule and Technical Specifications that are clearly not warranted. However, there is also some point beyond which the device would have not been able to perform its function due, for example, to greater than expected drift. This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the devices and is designated as the Allowable Value which, as stated above, is the same as the LSSS.

The Allowable Value specified in Table 3.3.1-1 serves as the LSSS such that a channel is OPERABLE if the trip setpoint is found not to exceed the Allowable Value during the CHANNEL OPERATIONAL TEST (COT). As

such, the Allowable Value differs from the trip setpoint by an amount primarily equal to the expected instrument loop uncertainties, such as drift, during the surveillance interval. In this manner, the actual setting of the device will still meet the LSSS definition and ensure that a SL 2 2 Relying solely on [NTSP] protection channel [NTSP] protection channelchannel [NTSP] 2 - - channel within established as-left tolerance around the RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-5 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

BACKGROUND (continued)

Signal Process Control and Protection System

Generally, three or four channels of process control equipment are used for the signal processing of unit parameters measured by the field instruments. The process control equipment provides signal conditioning, comparable output signals for instruments located on the main control board, and comparison of measured input signals with setpoints established by safety analyses. These setpoints are defined in FSAR, Chapter [7] (Ref. 2), Chapter [6] (Ref. 3), and Chapter [15] (Ref. 4). If the measured value of a unit parameter exceeds the predetermined setpoint, an output from a bistable is forwarded to the SSPS for decision evaluation. Channel separation is maintained up to and through the input bays. However, not all unit parameters require four channels of sensor measurement and signal processing. Some unit parameters provide input only to the SSPS, while others provide input to the SSPS, the main control board, the unit computer, and one or more control systems.

Generally, if a parameter is used only for input to the protection circuits, three channels with a two-out-of-three logic are sufficient to provide the required reliability and redundancy. If one channel fails in a direction that would not result in a partial Function trip, the Function is still OPERABLE with a two-out-of-two logic. If one channel fails, such that a partial Function trip occurs, a trip will not occur and the Function is still OPERABLE with a one-out-of-two logic.

Generally, if a parameter is used for input to the SSPS and a control function, four channels with a two-out-of-four logic are sufficient to provide

the required reliability and redundancy. The circuit must be able to withstand both an input failure to the control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Again, a single failure will neither cause nor prevent the protection function actuation.

These requirements are described in IEEE-279-1971 (Ref. 5). The actual number of channels required for each unit parameter is specified in Reference 2.

Two logic channels are required to ensure no single random failure of a logic channel will disable the RTS. The logic channels are designed such that testing required while the reactor is at power may be accomplished without causing trip. Provisions to allow removing logic channels from service during maintenance are unnec essary because of the logic system's designed reliability.

P 2 Protection Instrumentation Rack (PPIR) 14 Analytical Limits (ALs)

U ALs 1968 2 reactor protection logic rack reactor protection lo gic rack reactor protection logic rack reactor protection logic rack At least NTSPs derived from the RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-6 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

BACKGROUND (continued)

Allowable Values and RTS Setpoints

The trip setpoints used in the bistabl es are based on the analytical limits stated in Reference 2. The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time

delays are taken into account. To al low for calibration tolerances, instrumentation uncertainties, instru ment drift, and severe environment errors for those RTS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6), the Allowable Values specified in Table 3.3.1-1 in the accompanying LCO are conservative with respect to the analytical limits. A detailed description of the methodology used to calculate the Allowable Values and trip setpoints, including their explicit

uncertainties, is provided in the "RTS/ESFAS Setpoint Methodology Study" (Ref. 7) which incorporates all of the known uncertainties applicable to each channel. The magnitudes of these uncertainties are

factored into the determination of each trip setpoint and corresponding Allowable Value. The trip setpoint entered into the bistable is more conservative than that specified by the Allowable Value (LSSS) to account for measurement errors detectable by the COT. The Allowable

Value serves as the Technical Specification OPERABILITY limit for the purpose of the COT. One example of such a change in measurement error is drift during the surveillance interval. If the measured setpoint does not exceed the Allowable Value, the bistable is considered OPERABLE.

The trip setpoint is the value at which the bistable is set and is the expected value to be achieved during ca libration. The trip setpoint value ensures the LSSS and the safety analysis limits are met for surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as left" setpoint value is within the band for CHANNEL CALIBRATION uncertainty allowance (i.e., +/- rack calibration +

comparator setting uncertainties). The trip setpoint value is therefore considered a "nominal" value (i.e., expressed as a value without inequalities) for the purposes of COT and CHANNEL CALIBRATION.

Trip setpoints consistent with the requirements of the Allowable Value ensure that SLs are not violated during AOOs (and that the consequences of DBAs will be acceptable, providing the unit is operated from within the LCOs at the onset of the AOO or DBA and the equipment functions as designed).

2 2 2 Nominal Trip Nominal Trip Setpoints The as-left tolerance and as-found tolerance band methodology is provided in Ref. xyz. [NTSP] [NTSP] [NTSP] is ensures the [NTSP] as-left tolerance and [NTSP] [Nominal ] , in conjunction with the use of as-found and as-left tolerances, together 7 the SCP - P calculation the the SCP as-found STET w/changes Note that the Allowable Values listed in the SCP are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, CHANNEL OPERATIONAL TEST, or a TRIP ACTUATING DEVICE OPERATIONAL TEST that requires trip setpoint verification.

RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-8 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

BACKGROUND (continued)

During normal operation the output from the SSPS is a voltage signal that energizes the undervoltage coils in the RTBs and bypass breakers, if in use. When the required logic matrix combination is completed, the SSPS output voltage signal is removed, the undervoltage coils are de-energized, the breaker trip lever is actuated by the de-energized undervoltage coil, and the RTBs and bypass breakers are tripped open. This allows the shutdown rods and control rods to fall into the core. In addition to the de-energization of the undervoltage coils, each breaker is

also equipped with a shunt trip device that is energized to trip the breaker open upon receipt of a reactor trip signal from the SSPS. Either the undervoltage coil or the shunt trip mechanism is sufficient by itself, thus providing a diverse trip mechanism.

The decision logic matrix Functions are described in the functional diagrams included in Reference 3. In addition to the reactor trip or ESF, these diagrams also describe the various "permissive interlocks" that are associated with unit conditions. Each train has a built in testing device that can automatically test the decision logic matrix Functions and the actuation devices while the unit is at power. When any one train is taken out of service for testing, the other tr ain is capable of providing unit monitoring and protection until the testing has been completed. The testing device is semiautomatic to minimize testing time.

APPLICABLE The RTS functions to maintain the SLs during all AOOs and mitigates SAFETY the consequences of DBAs in all MODES in which the Rod Control ANALYSES, LCO, System is c apable of rod withdrawal or one or more rods are not fully and APPLICABILITY inserted.

Each of the analyzed accidents and transients can be detected by one or more RTS Functions. The accident analysis described in Reference 4 takes credit for most RTS trip Functions. RTS trip Functions not specifically credited in the accident analysis are qualitatively credited in

the safety analysis and the NRC staff approved licensing basis for the unit. These RTS trip Functions may provide protection for conditions that

do not require dynamic transient analysis to demonstrate Function performance. They may also serve as backups to RTS trip Functions that were credited in the accident analysis.

The LCO requires all instrumentation performing an RTS Function, listed in Table 3.3.1-1 in the accompanying LCO, to be OPERABLE. A channel is OPERABLE with a trip setpoint value outside its calibration tolerance band provided the trip setpoint "as-found" value does not exceed its channels P P P P P P 2 2 RPIR RPIR RPIR 2 10 INSERT 3 2 panel Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses. These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before perventive or mitigating actions occur.

Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy.

B 3.3.1 Insert Page B 3.3.1-9 INSERT 4 The Allowable Value specified in the SCP is the least conservative value of the as-found setpoint that the channel can have when tested, such that a channel is OPERABLE if the as-found setpoint is conservative with respect to the Allowable Value during a CHANNEL CALIBRATION, or CHANNEL OPERATIONAL TEST (COT). As such, the Allowable Value differs from the [NTSP] by an amount [greater than or] equal to the expected instrument channel uncertainties, such as drift, during the surveillance interval. In this manner, the actual setting of the channel ([NTSP]) will ensure that a SL is not exceeded at any given point of time as long as the channel has not drifted beyond that expected during the surveillance interval. Note that, although the channel is OPERABLE

under these circumstances, the trip setpoint mu st be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).

However, there is also some point bey ond which the channel may not be able to perform its function due to, for example, greater than expected drift. This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the devices and is designated as the Allowable Value. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded because a potential degraded condition has been identified. During the SR performance the condition of the channel will be evaluated. This evaluation will consist of resetting the channel setpoint to the [NTSP] (within the allowed tolerance), and the channel's response evaluated. If the channel is functioning as required and is expected to pass the next surveillance, then the channel can be restored to service at the completion of the surveillance. If any of the above-described evaluations determine that the c hannel is not performing as expected the channel is degraded and its operability status cannot be verified, therefore it is inoperable because it may not perform its protective functions if needed before the next surveillance test. If the channel setpoint cannot be reset to the [NTSP], or if the actual setting of the channel is found to be non-conservative with respect to the Allowable Value, the channel is inoperable. After the surveillance is completed, the channel's as-found setting will be entered into the Corrective Action Program for further evaluation.

A trip setpoint may be set more conservative that the [NTSP] as necessary in response to plant conditions. However, in this case, the operability of this instrument must be verified based on the [field setting] and not the NT SP. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.

2 4 4 4 4 4 within the as-found tollerance and is tolerances In this manner, the actual setting of the channel (NTSP) will ensure that a SL is not exceeded at any given point of time as long as the channel has not drifted beyond expected tolerances during the surveillance intervals.. The degraded condition of the channel will be further evaluated during performance of the SR.evaluatiing is OPERABLE and RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-12 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

3. Power Range Neutron Flux Rate The Power Range Neutron Flux Rate trips use the same channels as discussed for Function 2 above.

a. Power Range Neutron Flux - High Positive Rate The Power Range Neutron Flux - High Positive Rate trip Function ensures that protection is provided against rapid increases in neutron flux that are characteristic of an RCCA drive rod housing rupture and the accompanying ejection of the RCCA. This Function compliments the Power Range Neutron Flux - High and Low Setpoint trip Functions to ensure that the criteria are met for a rod ejection from the power range.

The LCO requires all four of the Power Range Neutron Flux -

High Positive Rate channels to be OPERABLE.

In MODE 1 or 2, when there is a potential to add a large amount of positive reactivity from a rod ejection accident (REA), the Power Range Neutron Flux - High Positive Rate trip must be OPERABLE. In MODE 3, 4, 5, or 6, the Power Range Neutron Flux - High Positive Rate trip Function does not have to be OPERABLE because other RTS trip Functions and administrative controls will provide protection against positive

reactivity additions. Also, si nce only the shutdown banks may be

withdrawn in MODE 3, 4, or 5, the remaining complement of control bank worth ensures a sufficient degree of SDM in the event of an REA. In MODE 6, no rods are withdrawn and the SDM is increased during refueling operations. The reactor vessel head is also removed or the closure bolts are detensioned preventing any pressure buildup. In addition, the NIS power range detectors cannot detect neutron levels present in this mode. b. Power Range Neutron Flux - High Negative Rate The Power Range Neutron Flux - High Negative Rate trip Function ensures that protection is provided for multiple rod drop accidents. At high power levels, a multiple rod drop accident could cause local flux peaking that would result in an unconservative local DNBR. DNBR is defined as the ratio of the P nonconservative RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-16 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) pressurizer pressure - the Trip Setpoint is varied to correct for changes in system pressure, and account for imbalances in the axial power distribution as detected by the NIS upper and lower power range detectors. If axial peaks are greater than the desi gn limit, as indicated by the difference between the upper and lower NIS power range

detectors, the Trip Setpoint is redu ced in accordance with Note 1 of Table 3.3.1-1.

Dynamic compensation is included for system piping delays from the core to the temperature measurement system.

The Overtedescribed in Note 1 of Table 3.3.1-1. Trip occurs if Overtemperature temperature signals are used for other control functions. For those units, the actuation logic must be able to withstand an input failure to the control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Note that this Function also provides a signal to generate a turbine runback prior to reaching the Trip Setpoint. A turbine runback will reduce turbine power and reactor power. A reduction in power will normally alleviate the Overtemperature d may prevent a reactor trip.

The LCO requires all four channels of the Overtemperature Function to be OPERABLE for two and four loop units (the LCO requires all three channels on the Overtemperature to be OPERABLE for three loop units). Note that the Overtewith other RTS Functions. Failures that affect multiple Functions require entry into the Conditions ap plicable to all affected Functions.

prevent DNB. In MODE 3, 4, 5, or 6, this trip Function does not have to be OPERABLE because the reactor is not operating and there is insufficient heat production to be concerned about DNB.

P 2 2 3 ; 5 the SCP the SCP STET w/changes STET w/changes RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-17 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

7. Overpower The Overpoto ensure the integrity of the fuel (i.e., no fuel pellet melting and less than 1* cladding strain) under all possible overpower conditions.

This trip Function also limits the required range of the OvertePower Range Neutron Flux - High Se trip Function ensures that the allowable heat generation rate (kW/ft) of the fuel is not exceeded. It uses the of reactor power with a setpoint that is automatically varied with the following parameters; reactor coolant average temperatur e - the Trip Setpoint is varied to correct for changes in cool ant density and specific heat capacity with changes in coolant temperature, and rate of change of reactor coolant average temperature - including dynamic compensation for the delays between the core and the temperature measurement system.

The OverpoNote 2 of Table 3.3.1-1. Trip occurs if Overpower two loops. At some units, the temperature signals are used for other control functions. At those units, the actuation logic must be able to withstand an input failure to the control system, which may then require the protection function actuation and a single failure in the remaining channels providing the protection function actuation. Note that this Function also provides a signal to generate a turbine runback prior to reaching the Allowable Value. A turbine runback will reduce turbine power and reactor power. A reduction in power will reactor trip.

The LCO requires four channels for two and four loop units (three channels for three loop units) of the Overpower OPERABLE. Note that the Overpower input from channels shared with other RTS Functions. Failures that affect multiple Functions require entry into the Conditions applicable to all affected Functions.

P 2 3 ; 5 the SCP STET w/changes RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-34 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

ACTIONS -----------------------------------REVIEWERS NOTE----------------------------------- In Table 3.3.1-1, Functions 11.a and 11.b were not included in the generic evaluations approved in either WCAP-10271, as supplemented, WCAP-15376, or WCAP-14333. In order to apply the WCAP-10271, as supplemented, and WCAP-15376 or WCAP-14333 TS relaxations to plant specific Functions not evaluated generica lly, licensees must submit plant specific evaluations for NRC review and approval. --------------------------------------------------------------------------------------------------

A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.1-1.

In the event a channel's Trip Setpoint is found non-conservative with

respect to the Allowable Value, or the transmitter, instrument loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition(s) entered for the protection Function(s) affected.

When the number of inoperable channels in a trip Function exceed those specified in one or other related Conditions associated with a trip

Function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 must be immediately entered if applicable in the current MODE of operation.

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

Certain LCO Completion Times are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Completion Times as required by the staff Safety Evaluation Report (SER) for the topical report. --------------------------------------------------------------------------------------------------

A.1 Condition A applies to all RTS protection Functions. Condition A addresses the situation where one or more required channels or trains for one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.1-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and Required Actions.

P 2 7 7 [NTSP] SCP STET or the channel is not functioning as required, RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-54 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.7

SR 3.3.1.7 is the performance of a COT every 184 days.

A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This

clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

Setpoints must be within the Allowable Values specified in Table 3.3.1-1.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The "as found" and "as left" values must also be recorded and reviewed

for consistency with the a ssumptions of Reference 9.

SR 3.3.1.7 is modified by a Note that provides a 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months this Surveillance must be performed prior to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

The Frequency of 184 days is justified in Reference 9.

2 2 2 INSERT 5 2 6 INSERT 5 2 B 3.3.1 Insert Page B 3.3.1-54 INSERT 5 COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.

2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded. The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

B 3.3.1 Insert Page B 3.3.1-55 INSERT 6 COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.

2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded. The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-56 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.9

SR 3.3.1.9 is the performance of a TADOT and is performed every

[92] days, as justified in Reference

9. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.

SR 3.3.1.10

A CHANNEL CALIBRATION is per formed every [18] months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values

where applicable.

2 4 4 2 INSERT 7 5 B 3.3.1 Insert Page B 3.3.1-56 INSERT 7 in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.

2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded. The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-57 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.11

SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every [18] months.

This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL

CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux m ap performed above 15* RTP. The CHANNEL CALIBRATION for the sour ce range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp

discriminator curves, ev aluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for

the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The

[18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the

reactor at power. Operating experience has shown these components usually pass the Surveillance when performed on the [18] month

Frequency.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every [18] months.

This SR is modified by a Note stating that this test shall includ e verification of the RCS resistance temperature detector (RTD) bypass loop flow rate. Whenever a sensing

element is replaced, the next requi red CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

This test will verify the rate lag compensation for flow from the core to the RTDs.

The Frequency is justified by the a ssumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the

setpoint analysis.

INSERT 9 4 2 4 4 4 ¶ INSERT 8 INSERT 8 2 B 3.3.1 Insert Page B 3.3.1-57 INSERT 8 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.

INSERT 9 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel

OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.

2 2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded. The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

Licensee Response/NRC Response/NRC Question Closure Id2191NRC Question Number KAB-065 Select Application NRC Response Response Date/Time 2/16/2010 9:50 AM Closure Statement Response Statement Kewaunee's markup is consistent with TSTF 493 revision 4 and errata, with one exception. Please remove the following phrase, "The specific as-found values to ensure that the channel is OPERABLE and that Safety Limits are not exceeded are specified in the SCP." from the bottom of Attachment 1, Volume 8, Page 80 of 517 to be consistent with TSTF 493 errata. Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 2/16/2010 8:49 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2191 Licensee Response/NRC Response/NRC Question Closure Id2341NRC Question Number KAB-065 Select Application Licensee Response Response Date/Time 2/26/2010 2:45 PM Closure Statement Response Statement KPS has reviewed the errata to TSTF-493, Rev. 4 and determined that the draft markup attached to the previous KPS response to KAB-065 did not include three changes, one of which is identified in the NRC reviewer's follow-up question. A dr aft markup regarding the se changes is attached, and supersedes the previ ous draft markup. Chan ges from the previous markup are identified in gr een (see pages 2, 4, and 7 of the attachment).

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

Question Closure Date Attachment 1 KAB-065 Rev 1 Markup (3).pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Robert Hanley Jerry Jones Bryan Kays Added By David Mielke Date Added 2/26/2010 2:49 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/10/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=2341 RTS Instrumentation B 3.3.1 WOG STS B 3.3.1-1 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 B 3.3 INSTRUMENTATION