ML102371203

Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3)

ML102371203
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: ML102371203 (41)

Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 1 of 41 ITS NRC Questions Id 681 NRC Question KAB-001 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number CTS Table 3.5-2 JFD Number JFD Bases Number Page 7 of 517 Number(s)

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

Requested NRC Question On Page 7 of 517 in Attachment 1, volume 8, Table TS 3.5.2 function 9, pressurizer high water level indicates a proposed change to column 5, permissible bypass conditions. The change indicates that , table 3.3.1-1 Note (b) applies; however Table 3.3.1-1 function 9, pressurizer water level - high on page 67 of 517 references note (e), not note (b).

Note (b) does not exist on this page. Please explain the discrepancy, or indicate which reference is correct.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:37 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 1 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=681 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 2 of 41 Licensee Response/NRC Response/NRC Question Closure Id 291 NRC Question KAB-001 Number Select Licensee Response Application

Response

10/21/2009 2:40 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) agrees that in Attachment 1, Statement Volume 8, Page 7 of 15 the reference for CTS Table 3.5.2 Functional Unit 9, "Pressurizer High Water Level," should be ITS Table 3.3.1-1, Note (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 KAB-001 markup.pdf (848KB)

Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Gerald Riste Added By Gerald Riste Date Added 10/21/2009 2:37 PM Modified By Ray Schiele Date 10/21/2009 2:44 PM Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 2 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=291 06/08/2010

ITS A01 ITS 3.3.1 TABLE TS 3.5-2 A03 Table 3.3.1-1 LA01 INSTRUMENT OPERATION CONDITIONS FOR REACTOR TRIP LA01 Applicability Function REQUIRED 1 2 3 4 5 6 NO. OF MINIMUM MINIMUM PERMISSIBLE OPERATOR ACTION IF NO. OF CHANNELS TO OPERABLE DEGREE OF BYPASS CONDITIONS OF COLUMN 3 NO. FUNCTIONAL UNIT CHANNELS TRIP CHANNELS REDUNDANCY CONDITIONS OR 4 CANNOT BE MET 9

9 Pressurizer High Water 2 3 P-7 Maintain HOT SHUTDOWN 3 2 -

Level 10 10 Low Flow In One Loop 3/loop 2/loop 2 3/loop - P-8 Maintain HOT SHUTDOWN (any loop)

Low Flow Both Loops 3/loop 2/loop 2 3/loop - P-7 Maintain HOT SHUTDOWN (both loops) 11 Deleted 14 12 Lo-Lo Steam Generator 2/loop Maintain HOT SHUTDOWN 3/loop 2/loop 3 -

Water Level 12 13 1/bus 1/bus Maintain HOT SHUTDOWN Undervoltage 4-kV 2/bus 2 - P-7 (both buses) 11.a, 14 Underfrequency 2/bus 1/bus 1/bus - Maintain HOT SHUTDOWN 11.b, 2 13 4-kV Bus(4) (both buses) 15 Deleted 15 16 Steam Flow/Feedwater 2 1 1 2/SG - Maintain HOT SHUTDOWN Flow Mismatch Add proposed ACTION E M03 M03 M06 Table 3.3.1-1 Note (e) A04 Add proposed ACTION K M06 M06 M03 , Volume 8, Rev. 0, Page 7 of 517 Attachment 1, Volume 8, Rev. 0, Page 7 of 517 Table 3.3.1-1 Note (f)

Add proposed ACTIONS L and M L13 Add proposed Applicability and Table 3.3.1-1 number of Required Channels A11 Note (b) e Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 3 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 3 of 41 Amendment No. 94 Page 2 of 4 11/12/91 Page 3 of 15

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 4 of 41 Licensee Response/NRC Response/NRC Question Closure Id 581 NRC Question KAB-001 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:23 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 4 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=581 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 5 of 41 ITS NRC Questions Id 691 NRC Question KAB-002 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC A-4 Number JFD Number JFD Bases Number Page 21 Number(s)

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

Requested NRC On page 21 of Attachment 1, volume 8, the discussion of changes A04 states, Question Furthermore, since the Nuclear Flux Intermediate Range are not required until below the P-6 setting On the other hand, Table 3.3.1-1 function 4, intermediate range neutron flux shows the applicable mode to be modes 1 and 2 with reference to notes (b) and (c). Note (b) states, below the P-10 (power range neutron flux) interlocks and note (c) states, above the P-6 (intermediate range neutron flux) interlocks. This appears to be a discrepancy. Please explain which is correct or provide the reason for the differences Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:38 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 5 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=691 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 6 of 41 Licensee Response/NRC Response/NRC Question Closure Id 301 NRC Question KAB-002 Number Select Licensee Response Application

Response

10/21/2009 2:35 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station has determined that Statement statement in Attachment 1, Volume 8, Page 21 of 517 in Discussion of Change A04, which states, "Furthermore, since the Nuclear Flux Intermediate Range are not required until below the P-6 setting, then the HOT STANDBY requirement would only be above the P-6 setting" was typed incorrectly. The statement should read " 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." 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 KAB-002 Markup.pdf (818KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Gerald Riste Added By Gerald Riste Date Added 10/21/2009 2:41 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 6 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=301 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 21 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 7 of 41 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 the RPS Instrumentation to be OPERABLE, and includes only one column in Table 3.3.1-1 titled "REQUIRED CHANNELS." This changes the CTS by changing the title of the MINIMUM OPERABLE CHANNELS" and "Coincidence" columns to "REQUIRED CHANNELS."

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

A04 CTS Table TS 3.5-2 Column 6 specifies the "OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET." CTS Table TS 3.5-2 Column 6 requires maintaining HOT SHUTDOWN for Functional Units 1, 2, 3, 4, 5, 6, 8, 9, 10, 12, 13, 14, 16, and 17. Based on the CTS Table TS 3.5-2 requirement to maintain HOT SHUTDOWN, the Mode of Applicability would be considered OPERATING and HOT STANDBY for Functional Units 1(Manual), 2, (Nuclear Flux Power Range (High Setting, Positive Setting, and Negative Setting)), 5 (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, above since the Nuclear Flux Intermediate Range are not required until below 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 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 7 of 41 Attachment 1, Volume 8, Rev. 0, Page 21 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 8 of 41 Licensee Response/NRC Response/NRC Question Closure Id 591 NRC Question KAB-002 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:27 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 8 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=591 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 9 of 41 ITS NRC Questions Id 701 NRC Question KAB-003 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number A-4 JFD Number JFD Bases Number Page Number 22 (s)

NRC Reviewer Select Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 22 of Attachment 1, volume 8, the discussion of changes A04 indicates that functional unit 10 applies to (low flow in one loop) and (low flow in one loop) However, in Table TS 3.5.2, function 10 is low flow in one loop and low flow both loops. Please explain which is correct, or provide an explanation for the discrepancy.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:39 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 9 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=701 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 10 of 41 Licensee Response/NRC Response/NRC Question Closure Id 311 NRC Question KAB-003 Number Select Licensee Response Application

Response

10/21/2009 2:40 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the statement on Attachment 1, Volume 8, Page 22 of 517, in Discussion of Change A04 should be (Low Flow in One Loop and Low Flow Both Loops).

As shown on CTS Table TS 3.5-2 (Attachment 1, Volume 8, Page 7 of 517)

Functional Unit 10 is Low Flow in One Loop and Low Flow Both Loops.

Therefore, the sentence on Attachment 1, Volume 8, Page 22 of 517, in Discussion of Change A04 is proposed to be changed to state "For Functional Unit 10 (Low Flow in One Loop and Low Flow Both Loops), the Mode of Applicability is OPERATING because Column 5 lists the permissible bypass conditions for Low Flow in One Loop as P-8 and for Low Flow in Two Loops as P-7." 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 KAB-003 Markup.pdf (809KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By Gerald Riste Date Added 10/21/2009 2:43 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 10 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=311 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 22 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 11 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Mode of Applicability is HOT STANDBY because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-6. This means that the Nuclear Source Range channels are blocked when above the P-6 setting. With the P-6 Setting Limit of > 10-5% RATED POWER, the Nuclear Source Range would not be required to be OPERABLE above HOT STANDBY. For Functional Unit 7 (Low Pressurizer Pressure), 9 (Pressurizer High Water Level), 13 (Undervoltage 4-kV), and 14 (Underfrequency 4-kV), the Mode of Applicability is OPERATING because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-7. This means that the Low Pressurizer Pressure channel, the Pressurizer High Water Level, the Undervoltage 4-kV, and the Underfrequency 4-kV channels are blocked when below the P-7 setting. With the P-7 Setting Limit of

> 12.2% RATED POWER, the Low Pressurizer Pressure, the Pressurizer High Water Level, the Undervoltage 4-kV, and the Underfrequency 4-kV would not be required to be OPERABLE below the OPERATING MODE. For Functional Unit Both Loops 10 (Low Flow in One Loop) and (Low Flow in One Loop), the Mode of Applicability is OPERATING because Column 5 lists the permissible bypass condition for Low Flow in One Loop as P-8 and for Low Flow in Two Loops as P-

7. For the Low Flow in One Loop, this means that the channels are blocked when below the P-8 setting. With the P-8 Setting Limit of < 10% RATED POWER, Low Flow in One Loop channel would not be required to be OPERABLE below the OPERATING MODE. For the Low Flow in Two Loops, this means that the channels are blocked when below the P-7 setting. With the P-7 Setting Limit of > 12.2% RATED POWER, the channel would not be required to be OPERABLE below the OPERATING MODE. ITS LCO 3.3.1 requires the RPS instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 1, 2.a, 2.b, 3.a, 3.b, 4, 6, 7, 8.b, 14, 15, 17, and 18 state that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1 and 2.

ITS Table 3.3.1-1 Function 2.b (Power Range Neutron Flux - Low) states that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1 below the P-10 (Power Range Neutron Flux) interlock and MODE 2. ITS Table 3.3.1-1 Function 4 states that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1 below the P-10 (Power Range Neutron Flux) and MODE 2 above the P-6 (Intermediate Range Neutron Flux) Interlocks. ITS Table 3.3.1-1 Function 5 (Source Range Neutron Flux) state that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 2 below the P-6 (Intermediate Range Neutron Flux) interlocks. ITS Table 3.3.1-1 Function 8.a, 9, 12, and 13 state that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1 above the P-7 (Low Power Reactor Trip Block) interlock. ITS Table 3.3.1-1 Function 10 states that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1 above the P-8 (Power Range Neutron Flux) interlock. This changes the CTS by explicitly stating the MODES of Applicability for each Functional Unit.

This change is acceptable because the requirements are the same. The ITS explicitly states the MODES of Applicability in ITS Table 3.3.1-1. This change is designated as administrative because it does not result in technical changes to the CTS.

A05 CTS Table 3.5-2 includes Channels, Coincidence, and setting limits for P-6, P-7, P-8, P-10, and P-13. However, no specific Applicability requirements are provided. ITS Table 3.3.1-1 specifies the Applicable MODES or other specified Kewaunee Power Station Page 3 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 11 of 41 Attachment 1, Volume 8, Rev. 0, Page 22 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 12 of 41 Licensee Response/NRC Response/NRC Question Closure Id 601 NRC Question KAB-003 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:29 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 12 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=601 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 13 of 41 ITS NRC Questions Id 711 NRC Question KAB-004 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number A-8 JFD Number JFD Bases Number Page 23 Number(s)

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

Requested NRC On page 23 of Attachment 1, volume 8, the discussion of changes A08 Question indicates that the equivalent CHANNEL CHECK requirement for function 4, is only applicable in MODE 1 above the P-10 interlock and in MODE 2 below the P-6 interlock. However, in Table 3.3.1-1 function 4 is applicable in MODE 1 below the P-10 and MODE 2 above the P-6.

Please explain which is correct, or provide an explanation for the discrepancy.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:41 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 13 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=711 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 14 of 41 Licensee Response/NRC Response/NRC Question Closure Id 321 NRC Question KAB-004 Number Select Licensee Response Application

Response

10/21/2009 2:45 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the statement on Attachment 1, Volume 8, Page 23 of 517, in Discussion of Change A08 should be "For ITS Table 3.3.1-1 Function 4, ITS SR 3.3.1.1, the equivalent CHANNEL CHECK requirement, is only applicable in MODE 1 below the P-10 (Power Range Neutron Flux) interlocks and in MODE 2 above the P-6 (Intermediate Range Neutron Flux) interlocks consistent with the Applicability of the LCO. 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 KAB-004 Markup.pdf (810KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Added By Gerald Riste Date Added 10/21/2009 2:46 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 14 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=321 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 23 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 15 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION conditions associated with the P-6, P-7, P-8, P-10, and P-13 interlocks (Functions 16.a, 16.b, 16.c, 16.d, and 16.e). This changes the CTS by adding specific applicable MODES or other specified conditions associated with P-6, P-7, P-8, P-10, and P-13 interlocks.

This change is acceptable because the change provides more explicit conditions for when the interlocks are required to be OPERABLE, and is consistent with the RPS Functions they support (i.e., the RPS instruments described in the Functional Unit column of CTS Table 3.5-2). This change is designated as administrative because it does not result in a technical change to the CTS.

A06 CTS 4.1.a requires calibration, testing, and checking of protective instrumentation channels and testing of logic channels shall be performed as specified in Table TS 4.1-1. Table TS 4.1-1 requires performance of a TEST at the frequencies shown on Table TS 4.1-1. CTS 4.1.b requires, in part, equipment tests shall be conducted as specified in Table TS 4.1-3. Table TS 4.1-3 requires performance of a TEST at the frequencies shown on Table TS 4.1-3. Table TS 4.1-1 requires performance of a TEST at the frequencies shown on Table TS 4.1-1. ITS 3.3.1 requires the performance of either a CHANNEL OPERATIONAL TEST (COT), a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), or, in the case of the Automatic Trip Logic, an ACTUATION LOGIC TEST. This changes the CTS by changing the TEST requirements to a COT, a TADOT, or an ACTUATION LOGIC TEST.

This change is acceptable because the COT, a TADOT, or an ACTUATION LOGIC TEST continue to perform tests similar to the current TEST. This change is one of format only and any technical change to the requirements is specifically addressed in an individual Discussion of Change. This change is designated as administrative because it does not result in technical changes to the CTS.

A07 Note (a) to CTS Table TS 4.1-1, Channel Description 2 and 3 in the Remarks Section states that Channel Check is once per shift when in service. For ITS Table 3.3.1-1 Function 4 and 5, ITS SR 3.3.1.1, the equivalent CHANNEL CHECK requirement, has a frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by deleting this specific Note.

While the purpose of the Note appears to require the Channel Check only when it is in service, CTS 4.0.a, which provides the general requirements of all Surveillance Requirements, specifically states that Surveillances are only required to be met during the operational MODES or other specified conditions in the LCO. ITS SR 3.0.1 provides the same general requirement for Surveillances.

Therefore, it is unnecessary to reiterate that a CHANNEL CHECK is required when the instrument is in service. Therefore, the deletion of this Note is acceptable and considered administrative, since the technical requirements have not been changed.

A08 Note (c) to CTS Table TS 4.1-1, Channel Description 2 and 3 in the Remarks Section states that the Channel Check is required in all plant modes. For ITS Table 3.3.1-1 Function 4, ITS SR 3.3.1.1, the equivalent CHANNEL CHECK below requirement, is only applicable in MODE 1 above the P-10 (Power Range Neutron Flux) interlocks and in MODE 2 below the P-6 (Intermediate Range above Kewaunee Power Station Page 4 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 15 of 41 Attachment 1, Volume 8, Rev. 0, Page 23 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 16 of 41 Licensee Response/NRC Response/NRC Question Closure Id 621 NRC Question KAB-004 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:35 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 16 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=621 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 17 of 41 ITS NRC Questions Id 721 NRC Question KAB-005 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number M-3 JFD Number JFD Bases Number Page Number 28 (s)

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

Requested NRC Question On page 28 of Attachment 1, volume 8, the discussion of changes M03 does not mention the Power Range Neutron Flux Negative Rate function in the description of ITS 3.3.1 Action E. However, in table 3.3.1-1 the Power range neutron flux rate - high negative rate references Action E. Please explain which is correct or provide the reason for the differences.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:42 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 17 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=721 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 18 of 41 Licensee Response/NRC Response/NRC Question Closure Id 331 NRC Question KAB-005 Number Select Licensee Response Application

Response

10/21/2009 2:45 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the statement on Attachment 1, Volume 8, Page 28 of 517, in Discussion of Change M03 should include one power Range Neutron Flux - High Negative Rate channel. Therefore, the sentence will be changed to state "ITS 3.3.1 ACTION E provides compensatory actions to take when one Power Range Neutron Flux - Low channel, one Power Range Neutron Flux

- High Positive Rate channel, one power Range Neutron Flux - High Negative Rate channel, one Overtemperature T channel, one Overpower T channel, Pressurizer Pressure - High channel, one Steam Generator (SG) Water Level - Low Low channel, or one SG Water Level - Low -

Coincident with Steam Flow/Feedwater Flow Mismatch channel is inoperable and requires placing the inoperable channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or to be in MODE 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />." 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 KAB-005 Markup.pdf (817KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Added By Gerald Riste Date Added 10/21/2009 2:48 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 18 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=331 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 28 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 19 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Functional Unit 12 (Lo-Lo Steam Generator Pressure Water Level), Column 3 requires two Lo-Lo Steam Generator Pressure Water Level channels per loop to be OPERABLE. Thus while there are three Lo-Lo Steam Generator Pressure Water Level channels per loop in the KPS design, the CTS allows one of the Lo-Lo Steam Generator Pressure Water Level channels per loop to be inoperable for an indefinite period of time; no actions are required for when one of the three Lo-Lo Steam Generator Pressure Water Level channels per loop is inoperable.

Table TS 3.5-2 Functional Unit 16 (Steam Flow/Feedwater Flow Mismatch),

Column 3 requires one Steam Flow/Feedwater Flow Mismatch channel to be OPERABLE. Thus while there are two Steam Flow/Feedwater Flow Mismatch channels in the KPS design, the CTS allows one Steam Flow/Feedwater Flow Mismatch channel to be inoperable for an indefinite amount of time; no actions are required when one Steam Flow/Feedwater Flow Mismatch channel is inoperable. ITS LCO 3.3.1 requires the RPS Instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 2.b requires four Power Range Neutron Flux - Low channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.a requires four Power Range Neutron Flux - High Positive Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.b requires four Power Range Neutron Flux - High Negative Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 6 requires four Overtemperature T channels to be OPERABLE. ITS Table 3.3.1-1 Function 7 requires four Overpower T channels to be OPERABLE. ITS Table 3.3.1-1 Function 8.a requires three Pressurizer Pressure

- High channels to be OPERABLE. ITS Table 3.3.1-1 Function 14 requires three Steam Generator (SG) Water Level - Low Low channels per steam generator to be OPERABLE. ITS Table 3.3.1-1 Function 15 requires two SG Water Level-Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels per steam generator to be OPERABLE. ITS 3.3.1 ACTION E provides compensatory one Power Range Neutron actions to take when one Power Range Neutron Flux - Low channel, one Power Flux- High Range Neutron Flux - High Positive Rate channel, one Overtemperature T Negative Rate channel, one Overpower T channel, Pressurizer Pressure - High channel, one channel, Steam Generator (SG) Water Level - Low Low channel, or one SG Water Level

- Low - Coincident with Steam Flow/Feedwater Flow Mismatch channel is inoperable and requires placing the inoperable channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or to be in MODE 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />. Additionally, ACTION E contains a Note which allows the inoperable channel to be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Surveillance testing of other channels. This changes the CTS by requiring additional channels for Nuclear Flux Power Range Low setting channel, Nuclear Flux Power Range Positive rate channel, Nuclear Flux Power Range Negative rate channel, Overtemperature T channel, Overpower T channel, High Pressurizer Pressure channel, Lo-Lo Steam Generator Pressure Water Level channels per loop, and Steam Flow/Feedwater Flow Mismatch channel to be OPERABLE.

See DOC L12 for discussion of ACTION Note.

The purpose of the new ITS channel requirement and proposed ACTION is to ensure that appropriate compensatory actions are taken if any of the installed Power Range Neutron Flux - Low, Power Range Neutron Flux - High Positive Rate, Overtemperature T, Overpower T, Pressurizer Pressure - High, Steam Generator (SG) Water Level - Low Low, or SG Water Level - Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels are inoperable. This change is acceptable because the new channel requirement in ITS Table 3.3.1-1 will ensure that all of the installed RPS channels are required OPERABLE.

Kewaunee Power Station Page 9 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 19 of 41 Attachment 1, Volume 8, Rev. 0, Page 28 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 20 of 41 Licensee Response/NRC Response/NRC Question Closure Id 471 NRC Question KAB-005 Number Select NRC Response Application

Response

10/30/2009 10:50 AM Date/Time Closure Statement Response Please determine if the Power Range Neutron Flux- High Negative Rate function should also be Statement added to the following sentence under M03 on page 28, Attachment 1 volume 8, "The purpose of the new ITS channel requirement and proposed ACTION is to ensure that appropriate compensatory actions are taken if any of the installed Power Range Neutron Flux - Low, Power Range Neutron Flux - High Positive Rate, Overtemperature T, Overpower T, Pressurizer Pressure - High, Steam Generator (SG) Water Level - Low Low, or SG Water Level

- Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels are inoperable.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 10/30/2009 9:50 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 20 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=471 06/10/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 21 of 41 Licensee Response/NRC Response/NRC Question Closure Id 501 NRC Question KAB-005 Number Select Licensee Response Application

Response

10/30/2009 3:45 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the statement on Attachment 1, Volume 8, Page 28 of 517, in Discussion of Change M03, second paragraph, should include the Power Range Neutron Flux - High Negative Rate channel. Therefore, the sentence will be changed to include this Function. A draft markup regarding this change is attached. This draft markup supersedes the previous draft markup in the first licensee response (dated 10/21/2009). This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment KAB-005 Markup2.pdf (818KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones David Mielke Vic Myers Gerald Riste Ray Schiele Added By Robert Hanley Date Added 10/30/2009 2:47 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 21 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=501 06/10/2010

Attachment 1, Volume 8, Rev. 0, Page 28 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 22 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Functional Unit 12 (Lo-Lo Steam Generator Pressure Water Level), Column 3 requires two Lo-Lo Steam Generator Pressure Water Level channels per loop to be OPERABLE. Thus while there are three Lo-Lo Steam Generator Pressure Water Level channels per loop in the KPS design, the CTS allows one of the Lo-Lo Steam Generator Pressure Water Level channels per loop to be inoperable for an indefinite period of time; no actions are required for when one of the three Lo-Lo Steam Generator Pressure Water Level channels per loop is inoperable.

Table TS 3.5-2 Functional Unit 16 (Steam Flow/Feedwater Flow Mismatch),

Column 3 requires one Steam Flow/Feedwater Flow Mismatch channel to be OPERABLE. Thus while there are two Steam Flow/Feedwater Flow Mismatch channels in the KPS design, the CTS allows one Steam Flow/Feedwater Flow Mismatch channel to be inoperable for an indefinite amount of time; no actions are required when one Steam Flow/Feedwater Flow Mismatch channel is inoperable. ITS LCO 3.3.1 requires the RPS Instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 2.b requires four Power Range Neutron Flux - Low channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.a requires four Power Range Neutron Flux - High Positive Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.b requires four Power Range Neutron Flux - High Negative Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 6 requires four Overtemperature T channels to be OPERABLE. ITS Table 3.3.1-1 Function 7 requires four Overpower T channels to be OPERABLE. ITS Table 3.3.1-1 Function 8.a requires three Pressurizer Pressure

- High channels to be OPERABLE. ITS Table 3.3.1-1 Function 14 requires three Steam Generator (SG) Water Level - Low Low channels per steam generator to be OPERABLE. ITS Table 3.3.1-1 Function 15 requires two SG Water Level-Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels per steam generator to be OPERABLE. ITS 3.3.1 ACTION E provides compensatory one Power Range Neutron actions to take when one Power Range Neutron Flux - Low channel, one Power Flux- High Range Neutron Flux - High Positive Rate channel, one Overtemperature T Negative Rate channel, one Overpower T channel, Pressurizer Pressure - High channel, one channel, Steam Generator (SG) Water Level - Low Low channel, or one SG Water Level

- Low - Coincident with Steam Flow/Feedwater Flow Mismatch channel is inoperable and requires placing the inoperable channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or to be in MODE 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />. Additionally, ACTION E contains a Note which allows the inoperable channel to be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Surveillance testing of other channels. This changes the CTS by requiring additional channels for Nuclear Flux Power Range Low setting channel, Nuclear Flux Power Range Positive rate channel, Nuclear Flux Power Range Negative rate channel, Overtemperature T channel, Overpower T channel, High Pressurizer Pressure channel, Lo-Lo Steam Generator Pressure Water Level channels per loop, and Steam Flow/Feedwater Flow Mismatch channel to be OPERABLE.

See DOC L12 for discussion of ACTION Note.

The purpose of the new ITS channel requirement and proposed ACTION is to Power Range ensure that appropriate compensatory actions are taken if any of the installed Neutron Flux- Power Range Neutron Flux - Low, Power Range Neutron Flux - High Positive High Negative Rate, Overtemperature T, Overpower T, Pressurizer Pressure - High, Steam Rate, Generator (SG) Water Level - Low Low, or SG Water Level - Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels are inoperable. This change is acceptable because the new channel requirement in ITS Table 3.3.1-1 will ensure that all of the installed RPS channels are required OPERABLE.

Kewaunee Power Station Page 9 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 22 of 41 Attachment 1, Volume 8, Rev. 0, Page 28 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 23 of 41 Licensee Response/NRC Response/NRC Question Closure Id 631 NRC Question KAB-005 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:37 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 23 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=631 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 24 of 41 ITS NRC Questions Id 731 NRC Question KAB-006 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number M-9 JFD Number JFD Bases Number Page Number 33 (s)

NRC Reviewer Select Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 33 of Attachment 1, volume 8, the discussion of changes M09 indicates that function 1 is the Reactor Trip Breakers (RTBs).

However, in table 3.3.1-1 function 17 is reactor trip breakers (RTBs) and function 1 is manual reactor trip. Please explain which is correct, or provide an explanation for the discrepancy.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:44 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 24 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=731 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 25 of 41 Licensee Response/NRC Response/NRC Question Closure Id 341 NRC Question KAB-006 Number Select Licensee Response Application

Response

10/21/2009 2:50 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station has determined that the Statement reference in Attachment 1, Volume 8, Page 33 of 517 in Discussion of Change M09, to ITS Table 3.3.1-1 Function 1 should be Function 17. 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 KAB-006 Markup.pdf (798KB)

Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Added By Gerald Riste Date Added 10/21/2009 2:50 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 25 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=341 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 33 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 26 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION according to the requirement shown in Column 6 as soon as practicable. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip) Column 6 requires maintaining HOT SHUTDOWN. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip)

Column 6 requires, in part, maintaining HOT SHUTDOWN. Thus, the applicability for these Functional Units is determined to be HOT STANDBY and OPERATING. ITS LCO 3.3.1 requires the RPS instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Manual Reactor Trip as MODES 1 and 2 (equivalent to CTS OPERATING and HOT STANDBY, respectively); and MODES 3, 4, and 5 (equivalent to CTS HOT SHUTDOWN, INTERMEDIATE SHUTDOWN and COLD SHUTDOWN, respectively) when the Rod Control System is capable of rod withdrawal or when 17 one or more rods are not fully inserted. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Reactor Trip Breakers (RTBs) trains to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted, in addition to MODES 1 and 2. ITS Table 3.3.1-1 Function 18 requires the Applicability of the Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted, in addition to MODES 1 and 2. Commensurate with the addition of the new MODES of Applicability, ACTION C was added to address when there is one channel or train inoperable in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ACTION C requires that with one channel or train inoperable, to either restore the channel or train to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or to initiate action to fully insert all rods within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and to place the Rod Control System in a condition incapable of rod withdrawal within 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />. Additionally, commensurate with the addition of the new MODES of Applicability, new Surveillance Requirements are being adding. ITS SR 3.3.1.14 has been added for Function 1 to perform a TADOT every 18 months, but is modified by a Note that states that the verification of the setpoint is not required. ITS SR 3.3.1.4 has been added for Function 17 and 18 to perform a TADOT every 31 days, but is modified by a Note, which states that the Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. This changes the CTS by requiring the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains to be OPERABLE in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. Furthermore, this change adds an ACTION to take when the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains are inoperable in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. It also adds additional Surveillance Requirements for the new MODE of Applicability.

This change is acceptable because in MODE 3, 4, or 5 if one or more shutdown rods or control rods are withdrawn or the Rod Control System is capable of withdrawing the shutdown rods or the control rods, there is a possibility of an inadvertent control rod withdrawal. Therefore, action must be taken to restore the channel or train or to place the unit in a condition where there are no withdrawn rods and the ability to withdraw rods is precluded. This change is also acceptable because the new Required Actions and Completion Times are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while Kewaunee Power Station Page 14 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 26 of 41 Attachment 1, Volume 8, Rev. 0, Page 33 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 27 of 41 Licensee Response/NRC Response/NRC Question Closure Id 641 NRC Question KAB-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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:39 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 27 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=641 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 28 of 41 ITS NRC Questions Id 741 NRC Question KAB-007 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number L-5 JFD Number JFD Bases Number Page 43 Number(s)

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

Requested NRC On page 43 of Attachment 1, volume 8, the discussion of changes L05 Question indicates that 3.a and 3.b are the Power Range Neutron Flux Rate -

High Positive Rate function. However, in table 3.3.1-1 function 3.a is Power Range Neutron Flux Rate - High Positive Rate and 3.b is Power Range Neutron Flux Rate - High Negative Rate. Please explain which is correct, or provide an explanation for the discrepancy.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:46 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 28 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=741 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 29 of 41 Licensee Response/NRC Response/NRC Question Closure Id 351 NRC Question KAB-007 Number Select Licensee Response Application

Response

10/21/2009 2:50 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the statement on Attachment 1, Volume 8, Page 43 of 517, in Discussion of Change L05 for ITS 3.3.1-1 Function 3.b should be Power Range Neutron Flux Rate - High Negative Rate. Therefore, the sentence will be changed to state "ITS Table 3.3.1-1 Functions 2.a (Power Range Neutron Flux - High),

3.a (Power Range Neutron Flux Rate - High Positive Rate), 3.b (Power Range Neutron Flux Rate - High Negative Rate), 6 (Overtemperature T), 7 (Overpower T), 8.a (Pressurizer Pressure - Low), 8.b (Pressurizer Pressure - High), 9 (Pressurizer Water Level - High), 10 (Reactor Coolant Flow - Low), 14 (Steam Generator (SG) Water Level - Low Low), and 15 (SG Water Level - Low and SG Water Level - Low - Coincident with Steam Flow/Feedwater Flow Mismatch) requires performance of a COT (ITS SR 3.3.1.7) every 184 days." 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 KAB-007 Markup.pdf (835KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By Gerald Riste Date Added 10/21/2009 2:53 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 29 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=351 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 43 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 30 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION channels, or Turbine Impulse Pressure, P-13 channels are inoperable and requires verification that the interlock is in the required state for existing unit conditions within 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or to be in MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. This changes the CTS by allowing continued operation as long as the interlock is placed in the correct state for existing unit operation and providing actions if the inoperable interlock is not placed in the correct state.

The purpose of the interlocks is to ensure the associated RPS instrumentation is automatically enabled or disabled when required. This change is acceptable since the proposed ACTIONS ensure that the interlock is either manually placed in the correct state for the existing unit conditions or that the unit is placed in a MODE or specified Condition outside the Applicability of the associated interlock.

ITS 3.3.1 Required Action P.1 and Q.1 require the interlock to be placed in the same state as it would be normally placed in if it were automatically functioning (i.e., this performs the intended function of the interlock). If the Required Action is not accomplished within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, then Required Action P.2 and Q.2 require the unit to be placed in a MODE that is outside of the Applicability of the associated interlock. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L05 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports) CTS Table TS 4.1-1 Channel Description 1 requires a CHANNEL FUNCTIONAL TEST of the Nuclear Power Range channels (High Setting, Positive Setting, and Negative Setting) to be performed monthly as stated in Remarks (b). CTS Table TS 4.1-1 Channel Description 4 requires a CHANNEL FUNCTIONAL TEST of the Overtemperature

T and the Overpower T channels to be performed monthly. CTS Table TS 4.1-1 Channel Description 5 requires a CHANNEL FUNCTIONAL TEST of the Reactor Coolant Flow channels to be performed monthly. CTS Table TS 4.1-1 Channel Description 6 requires a CHANNEL FUNCTIONAL TEST of the Pressurizer Water Level channels to be performed monthly. CTS Table TS 4.1-1 Channel Description 7 requires a CHANNEL FUNCTIONAL TEST of the Pressurizer Pressure channels to be performed monthly. CTS Table TS 4.1-1 Channel Description 11.a requires a CHANNEL FUNCTIONAL TEST of the Steam Generator Low Level channels to be performed monthly. CTS Table TS 4.1-1 Channel Description 12 requires a CHANNEL FUNCTIONAL TEST of the Steam Generator Flow Mismatch channels to be performed monthly. ITS Table 3.3.1-1 Functions 2.a (Power Range Neutron Flux - High), 3.a (Power Negative Range Neutron Flux Rate - High Positive Rate), 3.b (Power Range Neutron Flux Rate - High Positive Rate), 6 (Overtemperature T), 7 (Overpower T), 8.a (Pressurizer Pressure - Low), 8.b (Pressurizer Pressure - High), 9 (Pressurizer Water Level - High), 10 (Reactor Coolant Flow - Low), 14 (Steam Generator (SG) Water Level - Low Low), and 15 (SG Water Level - Low and SG Water Level - Low - Coincident with Steam Flow/Feedwater Flow Mismatch) requires performance of a COT (ITS SR 3.3.1.7) every 184 days. Additionally, this Surveillance Requirement is modified by a Note, which states that the SR is not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after entry into MODE 3. This changes the CTS by changing the frequency of the Surveillances from monthly and quarterly to 184 days and allowing performance of the source range instrumentation COT Kewaunee Power Station Page 24 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 30 of 41 Attachment 1, Volume 8, Rev. 0, Page 43 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 31 of 41 Licensee Response/NRC Response/NRC Question Closure Id 681 NRC Question KAB-007 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 9:09 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 31 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=681 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 32 of 41 ITS NRC Questions Id 751 NRC Question KAB-008 Number Category Technical ITS Section 3.3 ITS 3.3.1 Number DOC A-4 Number JFD Number JFD Bases Number Page 22 Number(s)

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

Requested NRC On page 22 of Attachment 1, volume 8, the discussion of changes A04 Question states that For Functional Unit 7 (Low Pressurizer Pressure), 9 (Pressurizer High Water Level), 13 (Undervoltage 4-kV), and 14 (Underfrequency 4-kV), the Mode of Applicability is OPERATING because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-7.

However, the Kewaunee UFSAR section 7.2.2.4.14 item 3 states that An underfrequency signal from both 4160V buses (Buses 1-1 and 1-2) results in the trip of both reactor coolant pump breakers. There are two underfrequency relays per bus. In addition, the Kewaunee current Technical Specifications Table TS 3.5-2 functional unit 14 does not list the P-7 interlock under column 5, permissible bypass conditions. The UFSAR section 7.2.2.4.14 item 3 does not mention the P-7 interlock.

However UFSAR Table 7.2-1 does state that the RCP bus underfrequency is blocked below P-7. Please explain how the P-7 relay affects the RCP bus underfrequency logic circuitry, including a description of the logic path from the RCP underfrequency relay to the reactor trip.

Attach File 1

Attach File 2

Issue Date 10/19/2009 Added By Kristy Bucholtz Date Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 32 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=751 06/08/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 33 of 41 Modified Modified By Date Added 10/19/2009 10:47 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 33 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=751 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 34 of 41 Licensee Response/NRC Response/NRC Question Closure Id 411 NRC Question KAB-008 Number Select Licensee Response Application

Response

10/28/2009 9:30 AM Date/Time Closure Statement Response The NRC reviewer is correct in that CTS Table TS 3.5-2 Functional Unit 14 Statement does not list the P-7 interlock in Column 5. However, Function Unit 14 is modified by footnote 4, which states that Underfrequency on the 4-kV buses trips the Reactor Coolant Pump breakers, which in turn trips the reactor when power is above P-7. Thus, for Functional Unit 14, the reactor trip is only required above P-7, and the proposed Applicability in the ITS is correct.

Attached is a simplified diagram of Kewaunees underfrequency reactor trip logic. Kewaunee has a trip logic starting with four underfrequency relays two on each of the reactor coolant pump electric supply buses.

From the simplified logic diagram the logic matrix for tripping the reactor coolant pump breakers is 1/2 underfrequency relays on 2/2 buses (Bus 1 and Bus 2) which then trip both reactor coolant pump breakers. The reactor coolant pump breakers feed a P-8 permissive logic device and a P-7 permissive logic device. The P-8 permissive device is for a single-loop loss of flow condition whereas the P-7 logic device is for a loss of flow in both loops condition. Because the underfrequency logic matrix trips both reactor coolant pump breakers the only permissive device of concern for the underfrequency trip is the P-7 permissive.

Thus when the plant is below the P-7 permissive setting an underfrequency condition on Bus 1 and Bus 2 will cause the reactor coolant pumps to trip but a subsequent reactor trip will not occur.

Question Closure Date Attachment KAB-008-Attachment.pdf (97KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones Bryan Kays Vic Myers Gerald Riste Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 34 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=411 06/08/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 35 of 41 Ray Schiele Added By Robert Hanley Date Added 10/28/2009 9:30 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 35 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=411 06/08/2010

Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 36 of 41 Simplified Reactor Coolant Pump Bus Underfrequency Trip Logic Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 36 of 41

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 37 of 41 Licensee Response/NRC Response/NRC Question Closure Id 611 NRC Question KAB-008 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:33 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 37 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=611 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 38 of 41 ITS NRC Questions Id 761 NRC Question KAB-009 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number M-9 JFD Number JFD Bases Number Page Number 33 (s)

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

Requested NRC Question On page 33 of Attachment 1, volume 8, the discussion of changes M09 has two sentences that indicate Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip) Column 6 requires maintaining HOT SHUTDOWN. Please provide an explanation.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:49 AM Notification NRC/LICENSEE Supervision Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 38 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=761 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 39 of 41 Licensee Response/NRC Response/NRC Question Closure Id 361 NRC Question KAB-009 Number Select Licensee Response Application

Response

10/21/2009 2:55 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station has determined that one of Statement the two sentences in Attachment 1, Volume 8, Page 33 of 517 in Discussion of Change M09, related to Table TS 3.5-2 Functional Unit 1 incorrectly references CTS Table TS 3.5-2 Functional Unit 1. The second sentence should reference CTS Table TS 3.5-2 Functional Unit 17. 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 KAB-009 Markup.pdf (1MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By Gerald Riste Date Added 10/21/2009 2:56 PM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 39 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=361 06/08/2010

Attachment 1, Volume 8, Rev. 0, Page 33 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 40 of 41 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION 17 (Reactor Trip Breakers and Independently according to the requirement shown in Column 6 as soon as practicable. Table Test Shunt and TS 3.5-2 Functional Unit 1 (Manual Reactor Trip) Column 6 requires maintaining Undervoltage Trip Attachments)

HOT SHUTDOWN. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip)

Column 6 requires, in part, maintaining HOT SHUTDOWN. Thus, the applicability for these Functional Units is determined to be HOT STANDBY and OPERATING. ITS LCO 3.3.1 requires the RPS instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Manual Reactor Trip as MODES 1 and 2 (equivalent to CTS OPERATING and HOT STANDBY, respectively); and MODES 3, 4, and 5 (equivalent to CTS HOT SHUTDOWN, INTERMEDIATE SHUTDOWN and COLD SHUTDOWN, respectively) when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Reactor Trip Breakers (RTBs) trains to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted, in addition to MODES 1 and 2. ITS Table 3.3.1-1 Function 18 requires the Applicability of the Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted, in addition to MODES 1 and 2. Commensurate with the addition of the new MODES of Applicability, ACTION C was added to address when there is one channel or train inoperable in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ACTION C requires that with one channel or train inoperable, to either restore the channel or train to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or to initiate action to fully insert all rods within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and to place the Rod Control System in a condition incapable of rod withdrawal within 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />. Additionally, commensurate with the addition of the new MODES of Applicability, new Surveillance Requirements are being adding. ITS SR 3.3.1.14 has been added for Function 1 to perform a TADOT every 18 months, but is modified by a Note that states that the verification of the setpoint is not required. ITS SR 3.3.1.4 has been added for Function 17 and 18 to perform a TADOT every 31 days, but is modified by a Note, which states that the Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. This changes the CTS by requiring the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains to be OPERABLE in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. Furthermore, this change adds an ACTION to take when the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains are inoperable in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. It also adds additional Surveillance Requirements for the new MODE of Applicability.

This change is acceptable because in MODE 3, 4, or 5 if one or more shutdown rods or control rods are withdrawn or the Rod Control System is capable of withdrawing the shutdown rods or the control rods, there is a possibility of an inadvertent control rod withdrawal. Therefore, action must be taken to restore the channel or train or to place the unit in a condition where there are no withdrawn rods and the ability to withdraw rods is precluded. This change is also acceptable because the new Required Actions and Completion Times are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while Kewaunee Power Station Page 14 of 31 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 40 of 41 Attachment 1, Volume 8, Rev. 0, Page 33 of 517

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 41 of 41 Licensee Response/NRC Response/NRC Question Closure Id 651 NRC Question KAB-009 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 11/9/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:40 AM Modified By Date Modified Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 41 of 41 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=651 06/08/2010