ML102371210

Enclosure (3 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3)

ML102371210
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: ML102371210 (61)

Text

ITS NRC Questions Id911NRC Question Number KAB-023 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number LA-5 JFD Number JFD Bases Number Page Number(s) 186 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question On page 186 of Attachment 1, volume 8, the discussion of changes LA05 indicates that details are being moved to the Bases. Please explain which part of the Bases has the relocated details.

Attach File 1 Attach File 2 Issue Date 10/26/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/26/2009 7:33 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=911 Licensee Response/NRC Response/NRC Question Closure Id541NRC Question Number KAB-023 Select Application Licensee Response Response Date/Time 11/3/2009 1:10 PM Closure Statement Response Statement Kewaunee Power Station (KPS) has prov ided a yellow highlighted markup of the ITS Bases markup pages (KAB-023 Information.pdf) to identify where the technical information that was relocated by Attachment 1, Volume 8, Page 186 of 517 Discussion of Change (DOC) LA05, is contained. While the words in the ITS Bases markup are not identical to the words being relocated from the KPS CTS, the ITS Bases contai ns the same technical information that is being relocated.

Specifically, the CTS Table TS 4.1-1 Note states that the containment pressure channel associated with the safety injection (SIS) signal is associated with the Isolation Valve (i.e., the containment isolation valv es) Signal. This note ensures the user knows that by testing the containment pressure channel for the SIS the containment pressure channel for th e containment isolation function is also being tested. The ITS Table 3.3.2-1 Function 3.c shows that the SI signal is part of the Co ntainment Isolation function, since it references the SI signal in Function 1. The ITS Bases states that the SI signal initiates the Containment Isolation function. This is shown in the yellow highlighted markup (KAB-023 Information.pdf). ITS SR 3.3.2.4 requires a CHANNEL OPERATIONAL TEST and ITS SR 3.3.2.6 requi res a CHANNEL CALIBRATION of ITS Table 3.3.2-1 Function 1c, Containment Pressure- High. These two SRs ensure the Co ntainment Isolation function is tested as part of the SI signal tests. The actual reposi tioning of the containment isolation valves is tested as required by ITS SR 3.6.3.6. References (not to be included in NRC Response)

E-1635 E-1636 Question Closure Date Attachment 1 KAB-023 Information.pdf (408KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones Bryan Kays Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=541 Added By Robert Hanley Date Added 11/3/2009 1:08 PM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=541 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 WOG STS B 3.3.2-7 Rev. 3.0, 03/31/04 BASES

APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as:

Phase A Isolation, Containment Purge Isolation, Reactor Trip, Turbine Trip, Feedwater Isolation, Start of motor driven auxiliary feedwater (AFW) pumps, Control room ventilation isolation, and

Enabling automatic switchover of Emergency Core Cooling Systems (ECCS) suction to containment sump.

These other functions ensure:

Isolation of nonessential systems through containment penetrations, Trip of the turbine and reactor to limit power generation, Isolation of main feedwater (MFW) to limit secondary side mass losses, Start of AFW to ensure secondary side cooling capability, Isolation of the control room to ensure habitability, and

Enabling ECCS suction from the refueling water storage tank (RWST) switchover on low low RWST level to ensure continued cooling via use of the containment sump.

Containment Ventilation Main ; and . ; contribution to containment pressurization

and ; ; ; ; ; ; . All changes are unless otherwise noted 1 2 2 2 2 2 2 2 2 2 2 2 LOCA and SLB events

Licensee Response/NRC Response/NRC Question Closure Id1041NRC Question Number KAB-023 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 Date 12/2/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 12/2/2009 8:18 AM Modified By Date Modified 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=1041 ITS NRC Questions Id921NRC Question Number KAB-024 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number LA-7 JFD Number JFD Bases Number Page Number(s) 187 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question On page 187 of Attachment 1, volume 8, the discussion of changes LA07 indicates that R15 and R19 will be relocated to the Technical Requirements Manual. Please provide an explanation of this deletion with regards to 10 CFR 50.36(c)(2)(ii) criteria. Attach File 1 Attach File 2 Issue Date 10/26/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/26/2009 7:34 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=921 Licensee Response/NRC Response/NRC Question Closure Id521NRC Question Number KAB-024 Select Application Licensee Response Response Date/Time 11/2/2009 8:00 AM Closure Statement Response Statement In ITS conversions, the convention has been that a comparison to the criteria in 10 CFR 50.36(c)(2)(ii) is only used to relocate an entire LCO requirement. In th e NRC response to the Owners Group Applicat ion of the Commission's Interim Policy Statement Criteria to the Standard Technical Specifications, from Murley to George, dated May 9, 1988, only LCOs were compared to the Interim Policy Statement Criteria. Note that these criteria were later added to the CFR, specifically into the LCO section of 10 CFR 50.36. Thus, only LCOs need to be compared to th e criteria, not individual Surveillance Requirements.

In the Kewaunee Power Station (KPS) IT S conversion, LA DOCs are used to relocate information from the CTS to other controlled documents while R DOCs are used to relocate entire LCOs (which include Surveillances and Actions). The Generic No Significant Hazards Considerations (NSHCs) for these two types of DOCs are written differently, with the R type NSHC written to describe why the relocated LCO does not meet any of the 10 CFR 50.36(c)(2)(ii) criteria and the LA type NSHC written to justify the acceptability of the relocation using other reasons.

In the KPS CTS, instruments R15 a nd R19 have no LCO requirements.

They only have Surveillance Requirements in CTS Ta ble TS 4.1-1. Thus, if the instruments are inopera ble, no actions are current ly required. This is why KPS used an LA DOC to relocate the surveillance requirements to the TRM. However, the two instruments in question R15 and R19, are not assumed to function in any design basis accidents. In other words, if they had an LCO requirement, the specification would not meet any of the 4 criteria. In addition, subsequent to the ITS submittal, KPS iden tified that the Surveillance Requirements being relocated to the TRM for instruments R15 and R19 are already in the ODCM. Therefore, DOC LA07 will be modified to relocate the Surveillance to the ODCM in lieu of the TRM. 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 Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=521 1 KAB-024 Markup.pdf (835KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones Bryan Kays Vic Myers Gerald Riste Ray Schiele Carl Schulten Added By Robert Hanley Date Added 11/2/2009 8:02 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=521 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION LA06 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS Table TS 4.1-1 Channel Description 14 provides Surveillance Requirements for Residual Heat Removal Pump Flow

instrumentation. The ITS does not include requirements for this flow instrumentation. The Technical Specification function of this instrumentation is only to provide indication. This changes the CTS by relocating the requirements for this flow instrumentation to the TRM.

The removal of requirements for indication only instrumentation from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. These instruments are not required to be OPERABLE to support OPERABILITY of the Technical Specification systems or components. Therefore, this instrumentation is more appropriately specified in the TRM. Therefore, this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is incorporated

by reference into the USAR and any changes to the TRM are made under

10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as less restrictive removal of detail change because a Technical Specification Requirement is being removed from the Technical Specifications.

LA07 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS Table TS 4.1-1 Channel Description 19, Radiation Monitoring System, provides Surveillance Requirements for the instrumentation channels. Included in the REMARKS column of Channel Description 19 is footnote (a) that states, in part, that channels R15 and R19 are included.

Specifically, channels R15 and R19 are required to have a performance of a CHANNEL CHECK daily, a CHANNEL CALIBRATION each refueling cycle, and

a CHANNEL TEST quarterly. The ITS does not include these requirements for

these radiation monitor instrumentation channels. This changes the CTS by moving these requirements to the Technical Requirements Manual (TRM).

The removal of these Surveillance Requirements from the Technical Specification is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The function of R15, Condenser Air Ejector Gas Monitor, is to monitor the condenser air ejector discharge flow path on a continuous basis. A high radiation condition initiates closure of the steam

generator blowdown sample isolation valves and the steam generator blowdown

isolation valves. The function of R19, Steam Generator Blowdown System Liquid Sample Monitor, is to monitor the liquid phase of the secondary side of the steam generator for radiation. A high radiation condition, indicative of a primary to secondary system leak, closes the isolation valves in the blowdown lines and

sample lines. The functions of Radiation Monitors R15 and R19 are interconnected, such that either monitor isolates the blowdown and reroutes the air ejector exhaust. These instruments and alarms are not required to be OPERABLE to support the Technical Specification systems or components. Therefore, this instrumentation is more appropriately specified in the TRM. Kewaunee Power Station Page 23 of 31 Offsite Dose Calculation Manual (ODCM)

ODCM DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION Therefore, this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is incorporated by reference into the USAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as less restrictive removal of detail change because a Technical Specification Requirement is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports) CTS Table TS 4.1-1 Channel Descriptions 7 (Pressurizer Pressure), 11.a (Steam Generator Low Level), 11.b (Steam Generator High Level), 18.a (Containment Pressure (SIS signal)), 18.b (Containment Pressure (Steamline Isolation)), 18.c (Containment Pressure (Containment Spray Act)), and 23 (Steam Generator Pressure) require a CHANNEL FUNCTIONAL TEST monthly. ITS Table 3.3.2-1 Functions 1.d (Safety Injection - Pressurizer Pressure-Low), 6.b (Auxiliary Feedwater - Steam Generator Water Level-Low Low), 5.b (Feedwater Isolation - Steam Generator Water Level-High High), 1.c (Safety Injection - Containment Pressure-High), 4.c (Steam Line Isolation - Containment Pressure-High), 2.c (Containment Spray - Containment Pressure-High High), and 1.e (Safety Injection - Steam Line Pressure-Low) require performance of a CHANNEL OPERATIONAL TEST (COT) (ITS SR 3.3.2.4) every 184 days. This changes the CTS by changing the Frequency from monthly to 184 days for CTS Table TS 4.4-1 Channel Descriptions 7, 11.a, 11.b, 18.a, 18.b, 18.c, and 23. See Discussion of Change A06 for discussion on changing TEST to COT.

The purpose of the COT is to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. These changes are acceptable and are the result of WCAP-10271, Revision 0 ("Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System"), dated May 1996, and supplements, WCAP-14333, Revision 1 ("Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times"), dated October 1998, or WCAP-15376, Revision 1 ("Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and

Completion Times"), dated March 2003 (or a combination of the WCAPs). Dominion Energy Kewaunee has performed evaluations of the applicable changes associated with the three WCAPs to justify the above changes. The evaluations supporting these changes are provided in Attachment 2 of this submittal. This change is designated as less restrictive because less stringent

Frequencies are being applied in the ITS than were applied in the CTS.

L02 (Category 2 - Relaxation of Applicability)

Column 6 of CTS Table TS 3.5-3 specifies the "OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET." Column 6 requires placing the unit in HOT SHUTDOWN (equivalent to ITS MODE 3) for Functional Units 1.b and 3.b of Table TS 3.5-3.

The HOT SHUTDOWN requirement in Column 6 contains a footnote, footnote (1) for Functional Unit 1.b of Table TS 3.5-3, which states if minimum conditions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (i.e., restoration of at least the minimum number of Kewaunee Power Station Page 24 of 31 ODCM. Changes made to the ODCM are controlled by the ODCM change control process in ITS 5.5.1, which ensure changes are properly evaluated.

Licensee Response/NRC Response/NRC Question Closure Id1081NRC Question Number KAB-024 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 Date 12/2/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 12/2/2009 9:23 AM Modified By Date Modified 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=1081 ITS NRC Questions Id951NRC Question Number KAB-025 Category Editorial ITS Section 3.3 ITS Number 3.3.6 DOC Number M-1 JFD Number JFD Bases Number Page Number(s) 412 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 412 of Attachment 1, volume 8, the discussion of changes M01 indicates that the CTS is being changed to require two manual initiation channels to be operable instead of one channel per bus. Please explain what is meant by per bus. Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:37 PM 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=951 Licensee Response/NRC Response/NRC Question Closure Id711NRC Question Number KAB-025 Select Application Licensee Response Response Date/Time 11/12/2009 2:15 PM Closure Statement Response Statement Kewaunee Power Station (KPS) has de termined that the words "per bus" were used inappropriately in Di scussion of Change (DOC) M01 on , Volume 8, Page 412 of 517. The discussion in the DOC is in reference to CTS Table 3.5-4 Functional Unit 1.a.

As shown on the markup (Attachment 1, Volume 8, Page 406 of 517), the number of REQUIRED OPERABLE CHANNELS for ITS Table 3.3.6.1-1, Func tion 3 is being changed one to two. Furthermore, it was noted that DOC M01 states that "ITS Table 3.3.2-1 Function 3.a requires two channels of the Containment Isolation - Manual Initia tion Function to be OPERAB LE. ITS 3.3.6 ACTION B provides compensatory actions to take with one Manual channel inoperable. ACTION B requires immediately entering the applicable Conditions and Required Actions for the cont ainment purge and vent isolation valves made inoperable by isolation instrumentation." While the change is still a more restrictive change, these statements concerning the appropriate ACTION to enter and take are not correct. As stated on , Volume 8, Page 421 of 517, Table 3.3.6-1 Function 3 references the user to ITS LCO 3.3.2 "ESFAS Instrumentation," (ITS Table 3.3.2-1) Function 3.a for al l initiation functions and requirements. ITS Table 3.3.2-1 Function 3.a (Attac hment 1, Volume 8, Page 208 of 517) references Condition B for an inoperable Contai nment Isolation - Manual Initiation channel. ITS 3.3.2 Condition B (Attachment 1, Volume 8, Page 197 of 517) requires restoration of the inoperable channel 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 be in MO DE 3 within 54 and MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. Therefore, DOC M01 was modified to address the reference to ITS LCO 3.3.2 for inoperable Containment Isolation - Manual Initiation channels. 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-025 Markup.pdf (889KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=711 Ray Schiele Added By Robert Hanley Date Added 11/12/2009 2:22 PM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=711 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION This change is acceptable because the COT is a test similar to the current CHANNEL FUNCTIONAL TEST. The change is one of format only. In addition, the change to the CHANNEL FUNCTIONAL TEST definition is described in the Discussion of Changes in ITS 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

A05 Column 3 of CTS Table TS 3.5-4 specifies the "MINIMUM OPERABLE CHANNELS" associated with each Functional Unit and CTS 3.5.c specifies the actions to take when the number of channels for a particular Functional Unit is less than the Column 3 requirements. ITS LCO 3.3.6 requires the Containment

Purge and Vent Isolation Instrumentation to be OPERABLE, and includes only one column in Table 3.3.6-1 titled "REQUIRED CHANNELS." This changes the CTS by changing the title of the MINIMUM OPERABLE CHANNELS" column to "REQUIRED CHANNELS."

This change is acceptable because the ITS Table 3.3.6-1 "REQUIRED CHANNELS" column reflects required actions to be taken, consistent with the CTS column when actions must be taken. This change is designated as administrative because it does not result in technical changes to the CTS.

A06 Column 6 of CTS Table TS 3.5-4 contains a footnote (2) that states the detectors that provide a high radiation signal for the initiation of a Containment Purge and Vent Isolation are required for Reactor Coolant System leak detection as referenced in CTS 3.1.d.5. ITS 3.3.6 does not contain this footnote, or a

reference to CTS 3.1.d.5. This changes the CTS by deleting the reference

footnote.

The purpose of the footnote reference is to alert the user that additional isolation requirements exist that may affect satisfying the requirements of the

Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is considered administrative because the

technical requirements have not changed.

MORE RESTRICTIVE CHANGES

M01 CTS 3.5.c states, in part, that when the number of channels of a subsystem fall below the limits given in Table TS 3.5-4 Column 3, operation shall be limited according to the requirement shown in Column 6 as soon as practicable. Table TS 3.5-4 Functional Unit 1.b (Containment Isolation - Manual), Column 3 requires one Manual channel to be OPERABLE. Thus, while there are two Manual channels in the KPS design, the CTS allows one of the Manual channels to be inoperable for an indefinite amount of time; no actions are required when one of the two Manual channels is inoperable. ITS Table 3.3.6-1 Functional Unit 3 references ITS LCO 3.3.2 for the number of required channels. ITS Table 3.3.2-1 Function 3.a requires two channels of the Containment Isolation -

Manual Initiation Function to be OPERABLE. ITS 3.3.6 ACTION B provides

compensatory actions to take with one Manual channel inoperable. ACTION B

requires immediately entering the applicable Conditions and Required Actions for the containment purge and vent isolation valves made inoperable by isolation instrumentation. This changes the CTS by requiring two channels of the Manual Kewaunee Power Station Page 2 of 6 and provides the appropriate ACTION and Surveillance Requirements

3.3.2 restoring

the channel 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 be in MODE 3 with 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> and MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION Kewaunee Power Station Page 3 of 6 Initiation Functional Unit to be OPERABLE instead of one channel per bus and by adding a specific ACTION to take when one of the two required channels is inoperable.

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 Containment Isolation Manual Initiation channels are inoperable. This change is acceptable because the new channel requirement in ITS LCO 3.3.6 will ensure that all of the installed channels are required OPERABLE and will ensure sufficient channels are required OPERABLE to account for a single failure under all conditions. The proposed ITS ACTION for when one channel is inoperable will ensure that the inoperable channel is not allowed to be inoperable for an indefinite period of time. 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 providing time to repair inoperable features. This change is designated as more restrictive because more stringent LCO requirements and associated Required Actions and Completion Times are being applied in the ITS than were applied in the CTS.

M02 CTS Table TS 3.5

-4 Functional Unit 3 provides requirements for Containment Ventilation Isolation Functions, but does not explicitly provide requirements for the Automatic Actuation Logic and Actuation Relays Function that result in closure of the containment purge supply and vent isolation valves. ITS 3.3.6, "Containment Purge and Vent Isolation Instrumentation," requires the Automatic Actuation Logic and Actuation Relays (Function

1) to be OPERABLE, provides appropriate ACTIONS if the Function is inoperable (ITS

3.3.6 ACTIONS

B and C), and provides a Surveillance Requirement (ITS SR 3.3.6.2) to ensure the proper functioning of the associated actuation logic relays. This changes the CTS by explicitly requiring the Automatic Actuation Logic and Actuation Relays Function for the Containment Purge and Vent System isolation instrumentation to be OPERABLE and providing appropriate ACTIONS and Surveillance Requirements.

This change is acceptable because the Automatic Actuation Logic and Actuation Relays Function is required to support the OPERABILITY of the containment purge and vent isolation valves. As such, explicitly including requirements for the Automatic Actuation Logic and Actuation Relays Functions in the Technical Specifications provides additional assurance that the OPERABILITY of the Containment Purge and Vent System isolation instrumentation will be maintained. The change provides explicit requirements for the Automatic Actuation Logic and Actuation Relays Function (Table 3.3.6

-1, Function

1) to be OPERABLE, and provides appropriate actions if it is inoperable. The addition of SR 3.3.6.2 (ACTUATION LOGIC TEST) is acceptable since the actuation logic testing Frequency is consistent with similar tests in ITS 3.3.1 and 3.3.2.

The requirements for the Containment Purge and Vent System isolation instrumentation continue to require the isolation of the Containment Purge and Vent System upon Containment High Radiation, Safety Injection and Containment Spray signals. This change is designated as more restrictive because it adds explicit OPERABILITY requirements, ACTIONS, and SRs for the Automatic Actuation Logic and Actuation Relays Function to the CTS.

Licensee Response/NRC Response/NRC Question Closure Id1551NRC Question Number KAB-025 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 Date 1/8/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/8/2010 12:35 PM Modified By Date Modified 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 ITS NRC Questions Id961NRC Question Number KAB-026 Category Editorial ITS Section 3.3 ITS Number 3.3.7 DOC Number M-1 JFD Number JFD Bases Number Page Number(s) 449 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 449 of Attachment 1, volume 8, the discussion of changes M01 indicates that Required action D.2 will place the unit outside the new applicability. However, ITS 3.3.7 does not have a D.2 required action but C.2 places the unit in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Please explain which is correct or provide an explanation of the discrepancy.

Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:39 PM 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=961 Licensee Response/NRC Response/NRC Question Closure Id721NRC Question Number KAB-026 Select Application Licensee Response Response Date/Time 11/12/2009 2:20 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that in Discussion of Change M01 on Attachme nt 1, Volume 8, Page 449 of 517, the statement should have referenced Required Action C.2, not Required Action D.2. As shown on Attachment 1, Volume 8, Page 456 of 517, when the Required Action and associated Co mpletion Time for Condition A or B are not met, then Required Action C.1 requires the plant to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Required Action C.2 requires the plant to be in MODE 5 with 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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-026 Markup.pdf (809KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/12/2009 2:24 PM Modified By Date Modified 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=721 DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM POST ACCIDENT RECIRCULATION (CRPAR) SYSTEM ACTUATION INSTRUMENTATION Kewaunee Power Station Page 3 of 7 and Actuation Relays is inoperable in MODE 3 or 4, ITS 3.3.7 ACTION A will require placing the associated CRPAR train in the emergency mode within 7 days; b) When both trains of Automatic Actuation Logic and Actuation Relays or

the Control Room Vent Radiation Monitor is inoperable in MODE 3 or 4, ITS 3.3.7 ACTION B requires either placing one CRPAR train in the emergency mode and declaring the other CRPAR train inoperable (and entering the applicable Conditions and Required Actions of ITS 3.7.10) immediately, or placing both CRPAR trains in the emergency mode immediately; and c) If either ACTION A or B is not met in MODE 3 or 4, or a unit shutdown is required while the unit is in MODE 1 or 2, ITS 3.3.7 Required Action C.2 requires the unit to be in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Furthermore, Required Action C.1 only provides 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in MODE 3. This changes the CTS by requiring the Automatic

Actuation Logic and Actuation Relays and the Control Room Vent Radiation Monitor to be OPERABLE in MODES 3 and 4, providing ACTIONS to take when

the instruments are inoperable in MODES 3 and 4, decreases the time to reach subcritical conditions (i.e., MODE 3) from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and provides a Required Action (Required Action D.2) to place the unit outside the new Applicability. The addition of the MODES 5 and 6 and during movement of irradiated fuel assemblies Applicability is discussed in DOC M02.

The purpose of CTS 3.12.a is to ensure that the CRPAR System is OPERABLE to provide a protected environment from which operators can control the unit following an uncontrolled release of radioactivity. During accident conditions, the CRPAR System isolates the normal outside air intake supply to the control room and both CRPAR fans are started and the flow path through the emergency filtration system is opened. The addition of MODES 3 and 4 and the associated ACTIONS when in MODES 3 and 4 is acceptable since an accident could occur in these MODES that could cause a release of radioactive material to the environment. Furthermore, the time to reach MODE 3 has been reduced and a

new Required Action has been added to place the unit in a MODE outside the new Applicability. This change is acceptable because the Completion Times are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for

repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in MODE 3 and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to be in MODE 5 ensures a unit shutdown is commenced and completed within a reasonable period of time upon failure to restore the instrumentation to OPERABLE status or place the associated CRPAR trains in operation within the allowed Completion Time. The proposed ACTIONS A and B are acceptable since the proper compensatory measures are provided when the instrumentation is inoperable. In both ACTIONS A and B, the final action to place the CRPAR train in the emergency mode performs the function of the instruments. This change is more restrictive because a new Applicability containing MODE 3 and 4 and associated Required Actions to exit the new Applicability has been added

and the time to reach MODE 3 has been reduced.

M02 The CTS does not contain any requirements for the CRPAR System, nor its associated instrumentation (Automatic Actuation Logic and Actuation Relays and

the Control Room Vent Radiation Monitor) in MODES 5 and 6 and during C.2 Licensee Response/NRC Response/NRC Question Closure Id1591NRC Question Number KAB-026 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 Date 1/11/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/11/2010 11:21 AM Modified By Date Modified 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=1591 ITS NRC Questions Id971NRC Question Number KAB-027 Category Technical ITS Section 3.3 ITS Number 3.3.3 DOC Number L-4 JFD Number JFD Bases Number Page Number(s) 317 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 317 of Attachment 1, volume 8, the discussion of changes L04 indicates that the reactor coolan t system (RCS) subcooling monitor CHANNEL FUNCTIONAL TEST will be deleted and the ITS CHANNEL CALIBRATION will be done in its place. Please provide a detailed explanation of how the CTS CHANNEL FUNCTIONAL TEST is currently performed, includin g a description of all the co mponents tested during the test. In addition, please provide a detailed explanation of how the new ITS CHANNEL CALIBRATION will be performed and what components will be tested during the calibration. In your explanation, ple ase demonstrate how the ITS CHANNEL CALIBRATION adequately ensures the operability of the RCS subcooling monitor.

Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:40 PM 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=971 Licensee Response/NRC Response/NRC Question Closure Id731NRC Question Number KAB-027 Select Application Licensee Response Response Date/Time 11/12/2009 2:30 AM Closure Statement Response Statement Currently, Kewaunee Power Station is required to perform a CHANNEL FUNCTIONAL TEST and a CHANNEL CA LIBRATION on the Reactor Coolant System (RCS) subcooling monitor. Both of these tests are performed on the same frequency of each refueling outage. In the CTS, performance of a CHANNEL FUNCTIONAL TEST involves injecting a simulated signal into the channel as close to the primary se nsor as you can and verifying that the channel is OPERABLE, including any alarm and the trip initiating action. Additionally, in the CT S, the definition of a CHANNEL CALIBRATION states that performance of the CHANNEL CALIBRATION encompasses a CHANNEL FUNCTIONAL TEST. Therefore, when the CHANNEL CALIBRATION is currently performed, the CHANNEL FUNCTIONAL TEST is also performed.

In the ITS (Volume 3, Page 31), the CHANNEL CALIBRATION is the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors and encompasses all devices (italics added for emphasis) in the channel required fo r channel OPERABIL ITY. Therefore, due to the term "all devices," the ITS CHANNEL CALIBRATION will continue to require testing the currently tested devices of the channel in the same manner as the CTS CHANNEL FUNCTIONAL TEST, and will also require the adjustment of the channel output as necessary.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/12/2009 2:35 PM Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=731 Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=731 Licensee Response/NRC Response/NRC Question Closure Id1541NRC Question Number KAB-027 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 Date 1/8/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/8/2010 8:24 AM Modified By Date Modified 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=1541 ITS NRC Questions Id981NRC Question Number KAB-028 Category Technical ITS Section 3.3 ITS Number 3.3.4 DOC Number JFD Number 3 JFD Bases Number Page Number(s) 357 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 357 of Attachment 1, volume 8, the justification for deviations for ITS 3.3.4, item number 3 indicates that plant procedures govern the methods to trip the reactor, and that surveillance requirement (SR) 3.3.4.4 has not been added for the reactor trip breakers open/closed indication. 10 CFR 50.36, "Technical Specifications" includes Surveill ance Requirements which assure that the ne cessary quality of syst ems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for ope ration will be met. Please explain if there is open/closed indications on the dedicated shutdown system panel for the reactor trip breakers.

If there is indication on the dedicated shutdown system panel, please provide a safety basis for de leting SR 3.3.4.4. Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:42 PM 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=981 Licensee Response/NRC Response/NRC Question Closure Id751NRC Question Number KAB-028 Select Application Licensee Response Response Date/Time 11/12/2009 3:10 PM Closure Statement Response Statement Kewaunee Power Station (KPS) does not have reactor trip breaker indication on the Dedicated Shutdown Panel. KPS USAR Section 7.7.6.2 provides a list of the indi cations that are provided outside of the control room. The listed indicators are level indication for the steam generators, pressure indication for the steam generators, press urizer level indication pressurizer pressure indicat ion, level indication for the RWST, temperature indication for RCS cold leg (Loop A), and temperat ure indication for RCS hot leg (Loop A). Therefo re, ISTS SR 3.3.4.4 was not included in the ITS submittal for KPS.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/12/2009 3:10 PM Modified By Date Modified 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=751 Licensee Response/NRC Response/NRC Question Closure Id1521NRC Question Number KAB-028 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 Date 1/6/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/6/2010 3:32 PM Modified By Date Modified 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=1521 ITS NRC Questions Id991NRC Question Number KAB-029 Category Technical ITS Section 3.3 ITS Number 3.3.4 DOC Number JFD Number 3 JFD Bases Number Page Number(s) 357 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 357 of Attachment 1, volume 8, the justification for deviations for ITS 3.3.4, item number 3 indicates that plant-specific indications and controls have been adde d, consistent with US AR Section 7.

7.6.2. However, the USAR talks about the letdown orifice isolation valves in Section 7.7.6.2, valve cont rol f. Please provide an explanation of why the letdown orifice isolation valves were not added to ITS Table B 3.3.4-1 Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:43 PM 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=991 Licensee Response/NRC Response/NRC Question Closure Id821NRC Question Number KAB-029 Select Application Licensee Response Response Date/Time 11/17/2009 4:15 PM Closure Statement Response Statement The first note below ITS Table 3.3.4-1 discusse s channels requir ed for inclusion depending upon the units licensing basis as described in the NRC un it specific Safety Evaluation Report (SER) For Kewaunee the applicable SER was transmitted to Kewaunee by letter dated December 22, 1981

[1]. This SER was reviewed and the applicable equipment is includ ed in ITS Table B 3.3.4-1.

In this SER, the NRC's evaluation consisted of that equipment necessary for Kewaunee to achieve and maintain Hot Standby (ITS Mode 2) and Co ld Shutdown. The ITS basis for section 3.3.4, the applicable safety analysis, states that the dedicated shutdown system is required to provide equipment at appropriate location s outside the control room with a capability to promptly shutdown and main tain the unit in a safe shutdown condition in Mode

3. Therefore, only the equipment necessary to achieve and maintain Mode 3 was includ ed in ITS Table 3.3.4-1.

The letdown orifice isolation valves were not includ ed in the equipment listed in ITS table 3.3.3-1 because the SER listed them as equipment needed to reach and ma intain cold shutdown.

[1] Letter from Steven A. Varga (NRC) to Eugene R. Mathews (WPSC), "10 CFR 50.48 and 10 CFR 50 Appendix R Items III.G.3 and III.L Concerning Fire Protection of Safe Shutdown Capability," dated December 22, 1981.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/17/2009 4:17 PM Modified By Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=821 Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=821 Licensee Response/NRC Response/NRC Question Closure Id1571NRC Question Number KAB-029 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 Date 1/11/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/11/2010 7:14 AM Modified By Date Modified 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=1571 ITS NRC Questions Id1001NRC Question Number KAB-030 Category Technical ITS Section 3.3 ITS Number 3.3.5 DOC Number LA-1 JFD Number JFD Bases Number Page Number(s) 379 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 379 of Attachment 1, volume 8, the discussion of changes LA01 indicates that the long-term low voltage operation details are being moved to the bases. Please explain which part of the bases has the relocated details.

Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:45 PM 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=1001 Licensee Response/NRC Response/NRC Question Closure Id761NRC Question Number KAB-030 Select Application Licensee Response Response Date/Time 11/12/2009 3:20 PM Closure Statement Response Statement The CTS statement in Table TS 3.5-1 Footnote (5) clarifies that the degraded voltage Function protect s ESF equipment from long-term low voltage operation. The Background section of the ITS Bases (Page 391, INSERT 2) states that the degraded voltage instrumentation is time-delayed, while the loss of voltage is instantaneous. Since the degraded voltage is specified as time-delayed, KPS believes that this implies the low voltage condition exists for some longer peri od of time than the loss of voltage Function, and that tripping of the degraded voltage after this time delay prevents low voltage operation for an extended time (i.e., longer than the time delay allows). Furthermore, from Background section of the ITS Bases (Page 390, third paragraph), discusses the relationship between the Allowable Value and trip setpoint in preventing acceptable limits from being exceeded so that the consequences of DBAs will be acceptable.

However, while KPS believes that the above identified locations includes the technical context of the words from Footnote (5), KP S has decided to add the Footnote (5) words to the KP S ITS Bases to be tter clarify the purpose of the degraded voltage trip. 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-030 Markup.pdf (826KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/12/2009 3:21 PM Modified By Date Pa ge 1of 2 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=761 Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=761 B 3.3.5 Insert Page B 3.3.5-1 INSERT 1 Each DG is capable of starting automatically on a Safeguard Bus Undervoltage (loss of voltage) or Safeguard Bus Second Level Undervoltage (degraded voltage) signal from its corresponding 4160 V Safeguard Bus (Emergency Bus 1-5 or 1-6). The signal will start the associated DG and trip the offsite power supply breakers to the associated

emergency bus. Each DG has adequate capacity to supply one train of the engineered safety features (ESF) for the Design Basis Accident (DBA).

INSERT 2 Four voltage relays provide input to the logic for each 4160 V bus for detecting a Safeguards Bus Undervoltage (loss of voltage) condition and two voltage relays provide input to the logic for each 4160 V bus for detecting a Safeguards Bus Second Level Undervoltage (degraded voltage) condition. The four loss of voltage relays are paired into two Safeguard Bus Undervoltage channels, with each channel consisting of an instantaneous loss of voltage relay in series with a time-delayed loss of voltage relay.

Both relays must trip for the channel to trip and send a start signal to the associated DG and close supply breakers to the associated 4160 V emergency bus. The two time-

delayed degraded voltage relays are paired (in series) in a single Safeguard Bus Second

Level Undervoltage channel. Both relays must trip for the channel to trip and send a start signal to the associated DG and trip in supply breakers to the associated 4160 V emergency bus. The time delays are applied within the two Functions (loss of voltage and degraded voltage) to prevent actuations during normal transients.

1 1 Furthermore, the time-delayed degraded voltage instrumentation protects the ESF equipment from long-term low voltage operation.

Licensee Response/NRC Response/NRC Question Closure Id1531NRC Question Number KAB-030 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 Date 1/8/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/8/2010 8:01 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=1531 ITS NRC Questions Id1011NRC Question Number KAB-031 Category Technical ITS Section 3.3 ITS Number 3.3.6 DOC Number L-1 JFD Number JFD Bases Number Page Number(s) 415 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 415 of Attachment 1, volume 8, the discussion of changes L01 states, "This changes th e CTS by allowing the actions for inoperable containment purge and vent valves to be taken when both Manual initiation channels are inoperable in lieu of shutting down the unit." However, on page 417 of Attachment 1, volume 8, Action B indicates a deletion of the word manual. If the word manual is removed from Action B then ITS 3.3.6 contains no action/s when both Manual initiation ch annels are inoperable.

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

Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:46 PM 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=1011 Licensee Response/NRC Response/NRC Question Closure Id861NRC Question Number KAB-031 Select Application Licensee Response Response Date/Time 11/19/2009 1:20 PM Closure Statement Response Statement Kewaunee Power Station classified the change described in DOC L01 conservatively as a less r estrictive change. Howeve r, after further review, Kewaunee Power Station has determined that Discussion of Change (DOC)

L01 on Attachment 1, Volume 8, Page 415 of 512 should be classified as a more restrictive change since ITS LCO would be entered if both channels of the Manual Containment Isolation Functi on are inoperable.

In CTS, when there are two inoperable Manual Containment Isolat ion channels, the unit must be placed in HOT SHUTDOWN. Since no time is provided in the CTS to attain HOT SHUTDOWN, KPS applies the times from LCO 3.0.c. In the ITS, Table 3.3.6-1 references ITS 3.3.2 as the location of all the requirements for the Containment Isol ation - Manual In itiation Function.

Thus, since ITS

3.3.2 contains

the requirements for the Manual Function, and there are not other Manual Functions covered by ITS 3.3.6, the word "manual" being deleted from ITS 3.3.6 Condition B is acceptable. IT S Table 3.3.2-1 Function 3.a requires two channels to be OPERAB LE. Further, ITS 3.3.2 does not provide any ACTIONS when both channels are inoperable, an ACTION is only provided when one channel is inoperable. Therefore, when there are two inoperable Containment Isolation -

Manual Initiation ch annels, ITS 3.3.2 requires that LCO 3.0.3 is entered immediately. The change to the CTS is in the execution of ITS LCO 3.

0.3 compared

to CTS LCO 3.0.c. In CTS, using the times in LCO 3.0.c to reach CTS HOT SHUTDOWN requ ires taking action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, being in HO T STANDBY (equivalent to ITS MODE 2) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, being in HOT SHUTDOWN (equiva lent to ITS MODE

3) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In ITS, entering LCO 3.0.3 for this Function (which is now applicable in MODES 1, 2, 3, and 4) requires taki ng action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, being in MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, being in MODE 4 wi thin 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and to be in MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Therefore , a new M DOC (M05) is written to justify the changes betwee n the CTS requirement to be in HOT SHUTDOWN and the time in LCO 3.0.c and ITS LCO 3.0.3, and DOC L01 is deleted. 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-031 Markup.pdf (1MB) Pa ge 1of 2 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=861 Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/19/2009 1:24 PM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=861 TABLE TS 3.5-4 INSTRUMENT OPERATING CONDITIONS FOR ISOLATION FUNCTIONS Amendment No. 202 Page 1 of 2 1/12/2009 1 2 3 4 5 6

NO.

FUNCTIONAL UNIT NO. OF CHANNELS NO. OF CHANNELS TO TRIP MINIMUM OPERABLE CHANNELS MINIMUM DEGREE OF REDUNDANCY PERMISSIBLE BYPASS CONDITIONS OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET 1 Containment Isolation a. Safety Injection Refer to Item No. 1 of Table TS 3.5-3 HOT SHUTDOWN (1 ) b. Manual 2 1 1 - HOT SHUTDOWN 2 Steam Line Isolation

a. Hi-Hi Steam Flow with Safety Injection 2/loop 1 1 (3) - HOT SHUTDOWN (1) b. Hi Steam Flow and 2 of 4 Lo-Lo Tavg with Safety Injection 2/loop 1 1 (3) - HOT SHUTDOWN (1) c. Hi-Hi Containment Pressure 3 2 2 (3) - HOT SHUTDOWN (1) d. Manual 1/loop 1/loop 1/loop (3) - HOT SHUTDOWN

(1) If minimum conditions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, steps shall be taken to place the plant in a COLD SHUTDOWN condition.

(3) Steam Line Isolation channels are not required to be operable when both main steam isolation valves are closed and deactivated.

ITS ITS 3.3.6 A01 See ITS 3.3.2 Table 3.3.6-1 Function 3 Add proposed Function 1, including ACTIONS B and C M02 LA03 See ITS 3.3.2 Pa g e 3 of 6 ACTION B LA03 A05 M01 2 L01 REQUIRED A ttachment 1, Volume 8, Rev. 0, Page 406 of 517 A ttachment 1, Volume 8, Rev. 0, Page 406 of 517 M05 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION Kewaunee Power Station Page 4 of 6 M03 CTS Table TS 4.1-1 Channel Description 19 requires a Daily instrument check of the radiation monitoring system. ITS SR 3.3.6.1 requires the performance of a CHANNEL CHECK of the required containment purge and vent isolation radiation monitors every 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 requiring a check of the required containment purge and vent isolation radiation monitors more often

in ITS than in CTS.

The purpose of the instrument check is to demonstrate that the required containment purge and vent isolation radiation monitors are OPERABLE and capable of providing an early indication of any abnormal leakage conditions in the containment. ITS SR 3.3.6.1 provides reasonable confidence that the channel is operating properly. This change is designated more restrictive because less time is allowed between performances of the CHANNEL CHECK than was allowed in the CTS.

M04 CTS 3.5.d states, in part, that in the event of subsystem instrumentation channel failure permitted by CTS 3.5.b, then Tables TS 3.5-2 through TS 3.5-5 need not be observed for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> while the operable channels are tested, as long as the failed channel is blocked to prevent an unnecessary reactor trip. CTS 3.5.b states, in part, that in the event of failure of a subsystem instrumentation channel, plant operation shall be permitted to continue at RATED POWER in accordance with Tables TS 3.5-2 through TS 3.5-5. ITS 3.3.5 does not contain this allowance. This changes the CTS by removing the allowance to block a failed channel.

The purpose of CTS 3.5.d is to allow time to perform testing of the operable subsystem channels without entering into the requirements specified in Tables TS 3.5-2 through TS 3.5-5. In order to perform this task, the inoperable channel must be placed in bypass. Currently, KPS does not have the ability to perform a bypass of an inoperable channel for the purpose of testing without performing a temporary alteration of the circuit. Since the installation of temporary alterations is intrusive, KPS has determined that this practice is unacceptable. Therefore KPS does not have the ability to perform testing with a channel in bypass and the allowance is not incorporated in the ITS. This change is designated as more

restrictive because an allowance that wa s allowed in the CTS is not allowed in the ITS.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES

LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table TS 4.1-1 Channel Description 19, Remarks Section Note (a) states that the CHECK, CALIBRATE, and TEST Frequencies for the Radiation Monitoring System are applic able only to channels R11 thru R15, R19, R21, and R23. For the Containment Purge and Vent Isolation Instrumentation Specification, only instruments R11, R12, and R21 apply. ITS 3.3.6 does not A ttachment 1, Volume 8, Rev. 0, Page 413 of 517 A ttachment 1, Volume 8, Rev. 0, Page 413 of 517 INSERT 1 INSERT 1M05 CTS Table TS 3.5-4 Functional Unit 1.b requires that when both Containment Isolation Manual channels are inoperable, to place the unit in HOT SHUTDOWN (ITS MODE 3). Since there is no time limit to attain HOT SHUTDOWN, KPS uses the time limit from CTS 3.0.c. CTS LCO 3.0.c requires that within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in at least HOT STANDBY (equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN (equivalent to ITS MODE 3) within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.3.6 references ITS 3.3.2 for the appropriate requirements for the Containment Isolation - Manual Initiation Function. ITS 3.3.2, which requires two Containment Isolation -

Manual Initiation channels to be OPERABLE in MODES 1, 2, 3, and 4, does not provide any ACTIONS to take when both Containment Isolation - Manual Initiation channels are inoperable. Therefore, ITS LCO 3.0.3 would be entered, which requires actions to be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to be in MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, to be in MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and to be in MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. This changes the CTS by allowing less time to reach HOT SHUTDOWN (ITS MODE 3) in the ITS than in the CTS (7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> in the ITS versus 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> in the CTS) and by requiring the unit to go to MODE 5 in lieu of MODE

3. The purpose of requiring the unit to be shutdown is to place the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation. This change is acceptable since it provides the appropriate actions to take under certain conditions. These conditions are for when both channels of the Function are inoperable. This Specification also delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Upon entering

LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a

change in unit operation. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner. The time limits of LCO 3.0.3 allow 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to be in MODE 3 (compared to 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> in the CTS), 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to be in MODE 4 (no action in the CTS), and 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 (no action in the CTS). Additionally, the CTS requirement to be in MODE 2 is not maintained since the ITS requires the unit to be in MODE 3 (a lower MODE) within the same time limit (i.e., 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />). This change is designated as more restrictive because less time is allowed to reach MODE 3 than was allowed in the CTS and a new time to reach MODE 4 (13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />) and MODE 5 (37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />) has been added.

DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION Kewaunee Power Station Page 6 of 6 The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains the requirement for the Containment Purge and Vent Isolation Instrumentation be OPERABLE and specifies the number of required channels. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Contr ol Program in ITS Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail

change because information relating system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action)

When both Containment Isolation Manual channels are inoperable, CTS Table TS 3.5-4 Column 6 requires the unit to be placed in HOT SHUTDOWN (ITS MODE 3). Under similar conditions, ITS 3.3.6 Required Action B.1 requires immediately entering the applicable

Conditions and Required Actions for the containment purge and vent isolation valves made inoperable by isolation instrumentation. This changes the CTS by allowing the actions for inoperable containment purge and vent valves to be taken when both Manual initiation channels are inoperable in lieu of shutting down the unit.

The purpose of the CTS Table TS 3.5-4 Column 6 action is to provide compensatory actions when both Manual Initiation channels are inoperable.

However, the CTS action is overly conserv ative in that it requires more restrictive actions than are allowed if the valves themselves were inoperable. The purpose

of the instrumentation is to isolate the associated valves. Thus, this change is acceptable since the proposed ITS Required Ac tion would accomplish this action (since ITS 3.6.3 would require isolat ion of the associated penetration flow path). This change is designated as less restri ctive since the proposed Required Action will allow operation to continue with the associated flow path isolated in lieu of

shutting down the unit.

A ttachment 1, Volume 8, Rev. 0, Page 415 of 517 A ttachment 1, Volume 8, Rev. 0, Page 415 of 517 None Licensee Response/NRC Response/NRC Question Closure Id1581NRC Question Number KAB-031 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 Date 1/11/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/11/2010 10:18 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=1581 ITS NRC Questions Id1021NRC Question Number KAB-032 Category Technical ITS Section 3.3 ITS Number 3.3.6 DOC Number JFD Number 6 JFD Bases Number Page Number(s) 424 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 424 of Attachment 1, volume 8, the justifications for deviations for ITS 3.3.6, item number 6 indicates that containment isolation or containment spray initiation cause th e isolation of the containment purge and vent system. However, containment spray manual initiation has not been referenced in Table 3.3.6-1 si milar to containmen t isolation manual initiation for ITS functi on 3. Please indicate if the containment Spray manual initiation was inadvertently left off Table 3.3.6-1 with reference to ITS 3.3.2, or provide an explanation of the discrepancy. Attach File 1 Attach File 2 Issue Date 11/6/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/6/2009 3:54 PM 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=1021 Licensee Response/NRC Response/NRC Question Closure Id781NRC Question Number KAB-032 Select Application Licensee Response Response Date/Time 11/16/2009 4:10 PM Closure Statement Response Statement The Containment Spray -

Manual Initiation Function is include d in the KPS ITS submittal for ITS 3.3.6. ITS Table 3.3.6-1 F unction 4, provides the requirements for the Cont ainment Spray - Manual Initiation Function (See Pages 421 and 422, INSERT 1) and identifies that LCO 3.3.2, Function 2.a should be referred to for all initiation functi ons and requi rements.

Therefore, no changes to the ITS submittal appear necessary.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/16/2009 4:09 PM 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=781 Licensee Response/NRC Response/NRC Question Closure Id1561NRC Question Number KAB-032 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 Date 1/8/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/8/2010 2:03 PM 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=1561 ITS NRC Questions Id1081NRC Question Number KAB-033 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number LA-2 JFD Number JFD Bases Number Page Number(s) 38 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 38 of Attachment 1, volume 8, the discussion of changes LA02 indicates that the removal of limiting safety system settings (CTS 2.3) is acceptable because they are not necessary to be included in TS to provide adequate protection of public health and safety. This is not consistent with 10 CFR 50.36(c)(1). 10 CFR 50.36(c)(1) states that TS will include safety limits, limiting safety system settings and limiting control settings. Please provide clarification that explains how Kewaunee will continue to meet 10 CFR 50.36(c)(1).

Attach File 1 Attach File 2 Issue Date 11/16/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/16/2009 1:45 PM 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=1081 Licensee Response/NRC Response/NRC Question Closure Id811NRC Question Number KAB-033 Select Application Licensee Response Response Date/Time 11/17/2009 2:25 PM Closure Statement Response Statement After further review, Kewaunee Powe r Station (KPS) has rewritten the second paragraph of ITS 3.3.1 DOC LA02 to address the NRC reviewer's concerns. In addition, three similar DOCs (i.e., the DOCs justify removal of setpoints from the TS and placing th em under the Setpoint Control Program requirements) in other Specifications have also been reviewed and modified. These are ITS 3.3.2 DOC LA01, ITS 3.3.5 DOC LA02, and ITS 3.3.6 DOC LA02. A draft markup regarding this cha nge 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-033 Markup.pdf (3MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/17/2009 2:26 PM 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=811 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 19 of 31 this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program

provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail

change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS Table TS 3.5-2 Notes contains Setting Limits for Permissive/Interlocks P-6, P-7, P-8, and P-10. CTS 2.3.a.1 specifies the reactor trip settings for Nuclear Flux instrumentation. CTS 2.3.a.2 specifies the reactor trip settings for the pressurizer. CTS 2.3.a.3.A specifies Reactor Coolant Temperature - Overtemperature settings. CTS 2.3.a.3.B specifies Reactor Coolant Temperature Overpower settings. CTS 2.3.a.4 specifies the Reactor Coolant Flow settings. CTS 2.3.a.5 specifies the Steam Generator settings. CTS 2.3.a.6 specifies the Reactor Trip Interlock settings. CTS 2.3.a.7 specifies other Trips which include Undervoltage trip, turbine trip, manual trip, and safety injection trip. ITS 3.3.1 does not contain Setting Limits for the RPS instrumentation. This changes the CTS by moving the Setting Limits and the reactor trip settings for Nuclear Flux instrumentation, pressurizer, Reactor Coolant Temperature, Steam Generator, Undervoltage trip, turbine trip, manual trip, and safety injection trip to the Setpoint Control Program.

The removal of these Setting Limits is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still maintains the requirement for the number of required channels and the appropriate

Condition to enter if a required channel is inoperable. In addition, this change is acceptable because the removed information will be adequately controlled in the Setpoint Control Program. Changes to the Setpoint Control Program are made under 10 CFR 50.59, which ensures that changes are properly evaluated. This change is designated as a less restrictive removal of detail change because Allowable Value/Setpoint Information is being removed from the Technical

Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits)

Note (a) to CTS Table TS 4.1-1 Channel Description 1 (Nuclear Power Range) in the Remarks Section states that the weekly Channel Check contains a heat balance. Note (b) to CTS Table TS 4.1-1 Channel Description 1 in the Remarks Section states that the monthly CHANNEL FUNCTIONAL TEST contains the and bistable action (permissive, rod stop, and trips).

Note (c) to CTS Table TS 4.1-1 Channel Description 1 in the Remarks Section states that the Effective Full Power quarterly CHANNEL CALIBRATION contains upper and lower chambers for axial off-set using incore detectors. ITS 3.3.1 does not contain these requirements. This changes the CTS by moving these details to the Bases.

The removal of these details, which relate to system design, from the Technical Specifications is acceptable because this type of information is not necessary to A ttachment 1, Volume 8, Rev. 0, Page 38 of 517 A ttachment 1, Volume 8, Rev. 0, Page 38 of 517 INSERT 1 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to be in MODE 4 ensures a unit shutdown is commenced and completed within a reasonable period of time upon failure to restore the applicable ESFAS instrumentation to OPERABLE status within the allowed Completion Time. This

change is designated as more restrictive because less time is allowed for the unit

to reach MODE 4 in the ITS than is allowed to reach MODE 5 in the CTS.

M18 CTS does not include an ACTUATION LOGIC TEST for the Turbine Building Service Water Header Isolation Logic. ITS Table 3.3.2-1 Function 7.a, Automatic Actuation Logic and Actuation Relays, requires performance of ITS SR 3.3.2.2, which is an ACTUATION LOGIC TEST every 92 days on a STAGGERED TEST BASIS. This changes the CTS by specifying a new Surveillance Requirement.

The purpose of ITS SR 3.3.2.2 is to periodically verify the actuation logic is OPERABLE, with respect to the Turbine Building Service Water Header Isolation logic. This change is acceptable since it will help ensure that the turbine building header is isolated following an accident if the header pressure falls below a predetermined setpoint. This changes is designated as more restrictive because a new Surveillance Requirement is being added to the CTS.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES

LA01 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, USAR, ODCM, NFQAPD, CLRT Program, IST Program, ISI Program, or Setpoint Control Program) CTS 3.5.a states that Setting Limits for instrumentation which initiate operation of the engineered safety features shall be as stated in Table TS 3.5-1. CTS Table TS 3.5-1 contains Setting Limits for Engineered Safety Features initiation instruments. ITS 3.3.2 does not contain Setting Limits for ESFAS initiation instruments. This changes the CTS by moving the Setting Limits for the ESFAS instrumentation to the Setpoint Control Program.

The removal of these Setting Limits is acceptable because this type of information is not necessary to be included in the Technical Specifications to

provide adequate protection of public health and safety. The ITS still maintains the requirement for the number of required channels and the appropriate Condition to enter if a required channel is inoperable. In addition, this change is acceptable because the removed information will be adequately controlled in Setpoint Control Program. Changes to the Setpoint Control Program are made under 10 CFR 50.59, which ensures that changes are properly evaluated. This change is designated as a less restrictive removal of detail change because Kewaunee Power Station Page 20 of 31 A ttachment 1, Volume 8, Rev. 0, Page 184 of 517 A ttachment 1, Volume 8, Rev. 0, Page 184 of 517 INSERT 1 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION Allowable Value/Setpoint Information is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table TS 3.5-1 Functional Unit 1 (High Containment Pressure (Hi)), Functional Unit 3 (Pressurizer Low Pressure), and Functional Unit 4 (Low Steam Line Pressure) reference footnote (1) which states that Safety Injection "initiates containment isolation, feedwater line isolation, shield building ventilation, auxiliary building special vent, and starting of all containment fans. In addition, the signal overrides any bypass on the accumulator valves." CTS Table TS 3.5-3 Functional Unit 4.b (Motor-Driven Auxiliary Feedwater Pumps, Loss of Main Feedwater) references footnote (4), which states "Tripping of both main feedwater pump breakers starts both motor-driven auxiliary feedwater pumps."

ITS 3.3.2 does not contain these footnotes. This changes the CTS by moving

these details to the Bases.

The removal of these details, which relate to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still maintains the requirement to perform a CHANNEL CHECK, TADOT/COT, and CHANNEL CALIBRATION of the ESFAS instrumentation. In addition, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in

Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirement or Reporting Requirements)

CTS Table TS 3.5-1 Functional Unit 5 (High Steam Flow in a Steam Line Coincident with Safety Injection and "Lo-Lo" Tavg) and Functional Unit 6 (High-High Steam Flow in a Steam Line Coincident with Safety Injection) reference footnote (2) which requires confirmation of main steam line isolation valve closure within 5 seconds when tested. ITS 3.3.2 does not contain this footnote. This changes the CTS by moving this procedural detail to the TRM. The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still maintains the requirement for the number of required channels and the appropriate Condition to enter if a required channel is inoperable. Also, this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is incorporated by reference into the USAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of requirement change because a requirement is being removed from the CTS.

Kewaunee Power Station Page 21 of 31 A ttachment 1, Volume 8, Rev. 0, Page 185 of 517 A ttachment 1, Volume 8, Rev. 0, Page 185 of 517 DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF OFFSITE POWER (LOOP) DIESEL GENERATOR (DG) START INSTRUMENTATION Kewaunee Power Station Page 4 of 6 changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.5.a states setting limits for instrumentation which initiate operation of the engineered safety features shall be as stated in Table TS 3.5-1.

CTS Table TS 3.5-1 Functional Unit 9, Safeguards Bus Undervoltage, specifies a setting limit of 85.0% +/- 2% nominal busthe associated channels. CTS Table TS 3.5-1 Functional Unit 10, Safeguards Bus Second Level Undervoltage, specifies a setting limit of 93.6% +/- 0.9% of ITS 3.3.5 does not contain this information. This changes the CTS by removing the setting limit information for the Safeguards Bus Undervoltage (loss of voltage) and Safeguards Bus Second Level Undervoltage (degraded voltage) channels and placing it in the KPS Setpoint Control Program (SCP) document.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains the requirement for the LOOP DG Start Instrumentation to be OPERABLE and for the specific setpoints to be consistent with the Setpoint Control Program (ITS 5.5.16). Changes to the Limiting Trip Setpoint, Nominal Trip Setpoint, Allowable Values, As-found tolerance band, and

As-left setting tolerance are controlled by the Technical Specification Setpoint Control Program in Chapter 5. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits)

CTS Table TS 3.5-5 for Safeguards Bus Power Supply Functions has four columns stating various requirements for the Safeguards Bus Undervoltage Function and the Safeguards Bus Second Level Undervoltage Function. These columns are labeled "NO. OF CHANNELS" and "NO. OF CHANNELS TO TRIP." ITS 3.3.5 does not contain these columns. This changes the CTS by moving the information provided in these columns to the Bases. Note that Discussion of Change M01 addresses the changes to the number of channels required by the LCO.

The removal of these details, which relate to system design, from the Technical Specifications is acceptable because thi s type of information is not necessary to be included in the Technical Specific ations to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the

Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive A ttachment 1, Volume 8, Rev. 0, Page 380 of 517 A ttachment 1, Volume 8, Rev. 0, Page 380 of 517 INSERT 1 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE AND VENT ISOLATION INSTRUMENTATION Kewaunee Power Station Page 5 of 6 contain this note. This changes the CTS by removing the description of the applicable channels to the Bases.

The removal of these details (instruments R11, R12, and R21), which are related to system design from the Technical Spec ifications, is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains the requirement to perform the CHANNEL CHECK, CHANNEL CALIBRATION , and the CHANNEL

OPERABILITY TEST (COT) for the Radi ation Monitoring System. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. The removal of the other Instruments, R13, R14, R15, R19, and R23, will be discussed in other Discussion of Changes (i.e., in other Specifications).

This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.5.a states setting limits for instrumentation which initiate operation of the engineered safety features shall be as stated in Table TS 3.5-1. CTS Table TS 3.5-1 No. 8 states a setting limit f radiation levels in exhaust duct as defined in Footnote (3)" for the Containment Purge and Vent System Radiation Particulate Detector and Radioactive Gas Detector Functional Unit channel. Footnote 3 states the setting limits for maximum radiation levels are derived from ODCM Specification 3.4.1 and Table 2.2, and USAR Section 6.5. ITS 3.3.6 does not contain this setting limit information. This changes the CTS by removing the setting limit information of the Containment Purge and Vent System Radiation Particulate Detector and Radioactive Gas Detector functional unit and placing it in the KPS Setpoint Control Program document.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains the requirement for the Containment Purge and Vent

Isolation Instrumentation to be OPERABLE for the specific setpoints to be consistent with the Setpoint Control Program (ITS 5.5.16). Changes to the Limiting Trip Setpoint, Nominal Trip Setpoint, Allowable Values, As-found tolerance band, and As-left setting tolerance are controlled by the Technical Specification Setpoint Control Program in ITS Chapter 5. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table TS 3.5-4 Functional Unit 3 for Containment Ventilation Isolation has five columns stating various requirements for the Containment Ventilation Isolation Functions. These columns are labeled "NO. OF

CHANNELS" and "NO. OF CHANNELS TO TRIP." ITS 3.3.6 does not retain these columns. This changes the CTS by removing the information of these columns to the Bases.

A ttachment 1, Volume 8, Rev. 0, Page 414 of 517 A ttachment 1, Volume 8, Rev. 0, Page 414 of 517 INSERT 1 INSERT 1The removal of these Setting Limit values from the Technical Specifications and the subsequent addition of the methodology that controls changes to the Setting Limit values to ITS 5.5.16 will provide adequate protection of public health and safety. This change is acceptable because the removed information (i.e., the actual setting limits for the RPS Instrumentation) will be located in the Kewaunee Setpoint Control Program. The Kewaunee setpoint methodology provides a means for processing changes to instrumentation setpoints, which is controlled by the Setpoint Control Program contained in ITS 5.5.16. The ITS 5.5.16 Setpoint Control Program identifies the NRC approved setpoint methodology and requires that the Allowable Values, Nominal Trip Setpoints, and As-Found and As-Left Tolerances be calculated using this NRC approved setpoint methodology. Changes to the Kewaunee setpoint methodology are made under 10 CFR 50.59, which ensures that changes are properly evaluated. This change is designated as a less restrictive removal of detail change because Allowable Value/Setpoint Information is being removed from the Technical Specifications and relocated to the Kewaunee Setpoint Control Program.

Licensee Response/NRC Response/NRC Question Closure Id1891NRC Question Number KAB-033 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 Date 1/22/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/22/2010 8:18 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=1891 ITS NRC Questions Id1091NRC Question Number KAB-034 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number L-12 JFD Number JFD Bases Number Page Number(s) 48 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question On page 48 of Attachment 1, volume 8, the discussion of changes L12 indicates ITS 3.3.1 Action K provides actions when one channel of pressurizer pressure is inoperable. This statement does not indicate if the discussion is including high pressurizer pressure or low pressurizer pressure. However, the table in ITS 3.3.1-1 condition K is listed for function 8.a pressurizer pressure low. Please explain the discrepancy, or indicate which reference is correct.

Attach File 1 Attach File 2 Issue Date 11/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/19/2009 9:12 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=1091 Licensee Response/NRC Response/NRC Question Closure Id881NRC Question Number KAB-034 Select Application Licensee Response Response Date/Time 11/20/2009 9:20 AM Closure Statement Response Statement After further review, the statement in Discussi on of Change L12 on Attachment 1, Volume 8, Page 48 of 517 needs to be revised to indicate that ITS 3.3.1 ACTION K provides actio ns when one channe l of Pressurizer Pressure - Low is inoperable. A draf t markup regarding this change is attached. This change wi ll be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-034 Markup.pdf (392KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Jerry Jones Bryan Kays

Ray Schiele Added By Robert Hanley Date Added 11/20/2009 9:20 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=881 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 29 of 31 with Steam Flow/Feedwater Flow Mismatch Function is inoperable, includes a Note that states the inoperable channel may 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. ITS 3.3.1 ACTION K, which provides the actions when one channel of the Pressurizer Pressure, Pressurizer Water Level

- High, Reactor Coolant Flow - Low, Undervoltage RCPs, or Underfrequency RCPs Function is inoperable, includes a Note that states the inoperable channel may 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 allowing an inoperable channel to be bypassed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform surveillance testing of other channels instead of the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

allowed in the CTS.

The purpose of CTS 3.5.d is to allow time to perform testing of the operable subsystem channels without entering into the requirements specified in Table TS 3.5-2. These changes are acceptable and are the result of WCAP-10271, Revision 0 ("Evaluation of Surveillance Frequencies and Out of Service Times for

the Reactor Protection Instrumentation System"), dated May 1996, and supplements, WCAP-14333, Revision 1 ("Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times"), dated October 1998, or WCAP-15376, Revision 1 ("Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion

Times"), dated March 2003 (or a combination of the WCAPs). Dominion Energy Kewaunee has performed evaluations of the applicable changes associated with the three WCAPs to justify the above changes. The evaluations supporting these changes are provided in Attachment 2 of this submittal. This change is designated as less restrictive because more time is allowed in the ITS for the testing of channels than was allowed in the CTS.

L13 (Category 4 - Relaxation of Required Actions) CTS Table TS 3.5-2 Note (4) requires the Reactor Coolant Pump Breakers to be OPERABLE, since they provide the direct reactor trip signal when the Underfrequency 4-kV Bus channels trip. However, CTS 3.5.2 does not provide any explicit Actions to take when the Reactor Coolant Pump Breakers are inoperable in either single loop or two loop operation. Since these channels support the Underfrequency 4-kV Bus channels, KPS would take the Column 6 actions for inoperable Underfrequency 4-kV Bus channels. This action requires the plant to be maintained in HOT SHUTDOWN. Since there is no time limit to attain HOT SHUTDOWN, KPS uses the times from CTS 3.0.c. CTS 3.0.c requires action to be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and to be in HOT STANDBY (equivalent to ITS MODE 2) in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to be in HOT SHUTDOWN (equivalent to ITS MODE 3) in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS Table 3.3.1-1 Function 11.a requires one Reactor Coolant Pump (RCP)

Breaker Position channel per RCP to be OPERABLE in single loop operation.

ITS 3.3.1 ACTION L provides compensatory actions to take when one Reactor

Coolant Pump Breaker Position channel is inoperable in single loop operation, and requires the restoration of the channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or the reduction of THERMAL POWER to below P-8 within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. Additionally, ACTION L contains a Note which allows the inoperable channel to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels. ITS Table 3.3.1-1 Function 11.b requires one RCP Breaker Position channel per RCP to be OPERABLE in two loop operation. ITS 3.3.1 ACTION M provides compensatory actions to take when one Reactor Coolant Pump Breaker Position channel is inoperable in two loop operation and requires placing the inoperable A ttachment 1, Volume 8, Rev. 0, Page 48 of 517 A ttachment 1, Volume 8, Rev. 0, Page 48 of 517-Low Licensee Response/NRC Response/NRC Question Closure Id1401NRC Question Number KAB-034 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 Date 1/4/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/4/2010 2:17 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.

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