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{{#Wiki_filter:ITS NRC Questions Id1221NRC Question Number KAB-040 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number   Page Number(s) 122 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 122 of Attachment 1, volume 8, the reviewer's note states if WCAP-14333 and WCAP-15376 are being adopted then the bracketed sentence in the above paragraph must be replaced with the information in the reviewer's note. Both WCAP-14333 and WCAP-15376 are being incorporated into ITS. Please replace the sentence in the ITS Bases with the information in the reviewer's note or provide an explanation of the discrepancy.
{{#Wiki_filter:Kewaunee ITS Conversion Database                                                                                        Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 1 of 76 ITS NRC Questions Id 1221 NRC Question KAB-040 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 122 (s)
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:49 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.
NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N
p h p?re q uestT ype=areaItemPrint&itemId=1221 Licensee Response/NRC Response/NRC Question Closure Id1181NRC Question Number KAB-040 Select Application Licensee Response Response Date/Time 12/4/2009 11:30 AM Closure Statement Response Statement Kewaunee Power Station (KPS) has incorporated WCAP-14333 and WCAP-15376 into the ITS submittal. However, the Reviewer's Note is in error. While the Note states that the words in the Reviewer's Note should replace the bracketed words above the Review er's Note if the two WCAPs are incorporated, it should have stated that the words are to be replaced if the two WCAPs are not incorporated. WCAP-15376 cha nged the test time for the RTBs from 2 hours to 4 hours.
Requested NRC Question On page 122 of Attachment 1, volume 8, the reviewers note states if WCAP-14333 and WCAP-15376 are being adopted then the bracketed sentence in the above paragraph must be replaced with the information in the reviewers note. Both WCAP-14333 and WCAP-15376 are being incorporated into ITS. Please replace the sentence in the ITS Bases with the information in the reviewers note or provide an explanation of the discrepancy.
WCAP-10271 supports the 2 hour RTB test time. The 4 hour RT B test time allowed by WCAP-15376 was added to the NUREG-1431 (the ISTS) as part of TSTF-411. Furthermore, the ISTS 3.3.1 Bases Actions P.1 and P.2 Reviewer's Note, which provide the description of the action for inoperable RTBs, clearly states that the RTB test time is 4 hours when WCAP-15376 is adopted. Therefore, based on the above, the proposed words referencing a 4 hour RTB test time in ITS 3.3.1 Bases Actions N.1 and N.2 (ISTS 3.3.1 Bases Action O.1 and O.2) are correct. However, it was noted that the JFD referenced for the change should have been 9, not 8.
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:49 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 1 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1221                                       06/08/2010
Thus, JFD 9 has been mo dified to identify the typographical error related to the Reviewer's Note. Furthermore, the first sentence of the ITS 3.3.1 Bases Actions N.1 and N.2 also references that the Action is applicable to the SI Input from ESFAS reactor trip. This is not correct since the SI Input from ESFAS reactor trip Function is not included in the KPS ITS. A dr aft markup regarding the se changes is attached.
These changes will be refl ected in the supplement to this section of the ITS conversion amendment.
Question Closure Date  Attachment 1 KAB-040 Markup.pdf (882KB) Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 12/4/2009 11:30 AM Pa ge 1of 2 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee ITS Conversion Database                                                     Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 2 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1181 NRC Question KAB-040 Number Select Licensee Response Application
p h p?re q uestT ype=areaItemPrint&itemId=1181 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=1181 RTS Instrumentation B 3.3.1   WOG STS B 3.3.1-44 Rev. 3.0, 03/31/04  All changes are unless otherwise noted 1 P BASES  ACTIONS  (continued)


[ The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 12 hours while performing routine surveillance testing of the other channels. The 12 hour time limit is justified in Reference 8. ]
===Response===
12/4/2009 11:30 AM Date/Time Closure Statement Response  Kewaunee Power Station (KPS) has incorporated WCAP-14333 and WCAP-Statement 15376 into the ITS submittal. However, the Reviewer's Note is in error.
While the Note states that the words in the Reviewer's Note should replace the bracketed words above the Reviewer's Note if the two WCAPs are incorporated, it should have stated that the words are to be replaced if the two WCAPs are not incorporated. WCAP-15376 changed the test time for the RTBs from 2 hours to 4 hours. WCAP-10271 supports the 2 hour RTB test time. The 4 hour RTB test time allowed by WCAP-15376 was added to the NUREG-1431 (the ISTS) as part of TSTF-411. Furthermore, the ISTS 3.3.1 Bases Actions P.1 and P.2 Reviewer's Note, which provide the description of the action for inoperable RTBs, clearly states that the RTB test time is 4 hours when WCAP-15376 is adopted. Therefore, based on the above, the proposed words referencing a 4 hour RTB test time in ITS 3.3.1 Bases Actions N.1 and N.2 (ISTS 3.3.1 Bases Action O.1 and O.2) are correct. However, it was noted that the JFD referenced for the change should have been 9, not 8. Thus, JFD 9 has been modified to identify the typographical error related to the Reviewer's Note. Furthermore, the first sentence of the ITS 3.3.1 Bases Actions N.1 and N.2 also references that the Action is applicable to the SI Input from ESFAS reactor trip. This is not correct since the SI Input from ESFAS reactor trip Function is not included in the KPS ITS. A draft markup regarding these changes is attached.
These changes will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment KAB-040 Markup.pdf (882KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/4/2009 11:30 AM Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 2 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1181    06/09/2010


-----------------------------------REVIEWERS NOTE-----------------------------------
Kewaunee ITS Conversion Database                                                Page 2 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 3 of 76 Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 3 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1181 06/09/2010
The below text should be used for plants with installed bypass test capability:
 
The Required Actions are  modified by a Note that allows placing one channel in bypass for up to 12 hours while performing routine surveillance testing. The 12 hour time limit is justified in Reference 8.
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----------------------------------
5
 
O.1 and O.2 Condition O applies to the SI Input from ESFAS reactor trip and the RTS Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these Functions. With one train inoperable, 24 hours are allowed to restore the train to OPERABLE status (Required Action O.1) or the unit must be placed in MODE 3 within the next 6 hours. The Completion Time of 24 hours (Required Action O.1) is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of an event during this interval. The 24 hours allowed to restore the inoperable RTS Automatic Trip Logic train to OPERABLE status is justified in Reference 8. The Completion Time of 6 hours (Required Action O.2) is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging
 
unit systems.  
 
The Required Actions have been modified by a Note that allows bypassing one train up to [4] hours for surveillance testing, provided the other train is OPERABLE. [The [4] hour time limit for testing the RTS


Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 4 of 76 All changes are  1                    RTS Instrumentation unless otherwise noted P          B 3.3.1 BASES ACTIONS (continued)
[ The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 12 hours while performing routine surveillance testing of the other channels. The 12 hour time limit is justified in Reference 8. ]
                  -----------------------------------REVIEWERS NOTE-----------------------------------                5 The below text should be used for plants with installed bypass test capability:
The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours while performing routine surveillance testing. The 12 hour time limit is justified in Reference 8.
                  --------------------------------------------------------------------------------------------------
N O.1 and O.2                                                                                              5 N                                                                            P Condition O applies to the SI Input from ESFAS reactor trip and the RTS                                  5 P Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these Functions. With one train inoperable, N
24 hours are allowed to restore the train to OPERABLE status (Required Action O.1) or the unit must be placed in MODE 3 within the next 6 hours.                          N 5
The Completion Time of 24 hours (Required Action O.1) is reasonable                                    5 considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of P
an event during this interval. The 24 hours allowed to restore the inoperable RTS Automatic Trip Logic train to OPERABLE status is justified in Reference 8. The Completion Time of 6 hours (Required N
Action O.2) is reasonable, based on operating experience, to reach                                        5 MODE 3 from full power in an orderly manner and without challenging unit systems.
The Required Actions have been modified by a Note that allows bypassing one train up to [4] hours for surveillance testing, provided the P  5 other train is OPERABLE. [The [4] hour time limit for testing the RTS 8
Automatic Trip logic train may include testing the RTB also, if both the Logic test and RTB test are conducted within the [4] hour time limit. The
Automatic Trip logic train may include testing the RTB also, if both the Logic test and RTB test are conducted within the [4] hour time limit. The
[4] hour time limit is justified in Reference 8.]  
[4] hour time limit is justified in Reference 8.]                                                             9
 
                  -----------------------------------REVIEWERS NOTE-----------------------------------
-----------------------------------REVIEWERS NOTE----------------------------------- The below text should replace the bracketed information in the previous paragraph if WCAP-14333 and WCAP-15376 are being incorporated:  
The below text should replace the bracketed information in the previous paragraph if WCAP-14333 and WCAP-15376 are being incorporated:                                           8 The [4] hour time limit for the RTS Automatic Trip Logic train testing is greater than the 2 hour time limit for the RTBs, which the logic train WOG STS                                      B 3.3.1-44                                    Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 4 of 76


The [4] hour time limit for the RTS Automatic Trip Logic train testing is greater than the 2 hour time limit for the RTBs, which the logic train P P P 8 8 N 5 N 5 N N N 5 5 5 5 P 9 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1 BASES, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 1 of 2 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 5 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1 BASES, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION
: 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 2. Changes are made to the ISTS Bases that reflect the adoption of proposed Revision 4 of TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions".
: 2. Changes are made to the ISTS Bases that reflect the adoption of proposed Revision 4 of TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions".
Three options are provided for licensees to pursue when adopting TSTF-493.
Three options are provided for licensees to pursue when adopting TSTF-493.
Line 59: Line 59:
: 5. Changes are made to reflect changes made to the Specifications.
: 5. Changes are made to reflect changes made to the Specifications.
: 6. Typographical error corrected.
: 6. Typographical error corrected.
: 7. The Reviewer's Note has been deleted. The information is for the NRC reviewer to be keyed into what is needed to meet thi s requirement. This is not meant to be retained in the final version of the plant specific submittal.
: 7. The Reviewer's Note has been deleted. The information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.
: 8. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. Required Actions for Conditions D, E, and K are modified by a Note that provides two options for bypassing a channel for up to 12 hours for the purpose of performing surveillance testing without requiring entry into  
: 8. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. Required Actions for Conditions D, E, and K are modified by a Note that provides two options for bypassing a channel for up to 12 hours for the purpose of performing surveillance testing without requiring entry into the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for plants that do not have installed bypass testing capabilities. KPS does not have installed bypass testing capabilities.
 
Therefore, the Note for plants that do not have bypass testing capabilities is retained for Condition D, E, and K.
the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for plants that do not have installed bypass testing capabilities. KPS does not have in stalled bypass testing capabilities. Therefore, the Note for plants that do not have bypass testing capabilities is retained for Condition D, E, and K.
: 9. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design. Also, the Reviewer's Note has been deleted. The information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal. Furthermore, the bracketed value and the Reviewer's Note allows options dependent upon if the plant is incorporating WCAP-14333 and WCAP-15376. Since KPS is incorporating both of the WCAPs, the correct section has been selected.         In addition, it should be noted that the Reviewer's Note for ISTS 3.3.1 Actions O.1 and O.2 should have stated that the alternate wording is required if WCAP-14333 and WCAP-15376 are not adopted, not if they are adopted.
: 9. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design. Also, the Reviewer's Note has been deleted. The information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final  
 
version of the plant specific submittal. Furthermore, the bracketed value and the  
 
Reviewer's Note allows options dep endent upon if the plant is incorporating WCAP-14333 and WCAP-15376. Since KPS is incorporating both of the WCAPs, the correct section has been selected.
In addition, it should be noted that the Reviewer's Note for ISTS 3.3.1 Actions O.1 and O.2 should have stated that the alternate wording is required if WCAP-14333 and WCAP-15376 are not adopted, not if they are adopted.
WCAP-15376 justified a 4 hour RTB test time.
WCAP-15376 justified a 4 hour RTB test time.
Licensee Response/NRC Response/NRC Question Closure Id1431NRC Question Number KAB-040 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 3:21 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee Power Station                    Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 5 of 76
p h p?re q uestT ype=areaItemPrint&itemId=1431 ITS NRC Questions Id1231NRC Question Number KAB-041 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number  Page Number(s) 133, 135, 137, 138 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On pages 133, 135, 137 and 138 of Attachment 1, volume 8, inserts 5, 6, 7, 8 and 9 are not consistent with TSTF-493. TSTF-493 adds new paragraphs to STS NUREG-1431. The new paragraphs have not been added to Kewaunee's ITS Bases for 3.3.1.7, 3.3.1.8, 3.3.1.10, 3.3.1.11 and 3.3.1.12. Please add the paragraphs to the ITS Bases or provide an explanation for the change.
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:50 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=1231 Licensee Response/NRC Response/NRC Question Closure Id951NRC Question Number KAB-041 Select Application Licensee Response Response Date/Time 11/30/2009 3:30 PM Closure Statement Response Statement Kewaunee Power Station (KPS) has reviewed proposed TSTF-493 Rev. 4 and concurs with the assessmen t that INSERTS 5, 6, 7, 8, and 9 need to be changed to reflect the current version of TSTF-493 Rev.4.
A draft markup regarding this change is attached.
This change will be reflected in the supplement to this section of the ITS conversion amendment.
Please note that TSTF-493 Rev. 4 was not an approved traveler at the time of the KPS submittal and that the KPS submittal was marked up to the draft version of TSTF-493 sent to the NRC in July of 2009.
Question Closure Date Attachment 1 KAB-041 Markup.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 11/30/2009 3:31 PM Modified By Date Modified  Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee ITS Conversion Database                                                                     Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 6 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1431 NRC Question KAB-040 Number Select Application NRC Question Closure
p h p?re q uestT ype=areaItemPrint&itemId=951 RTS Instrumentation B 3.3.1   WOG STS B 3.3.1-54 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES


SURVEILLANCE REQUIREMENTS  (continued)
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


SR  3.3.1.7
===Response===
Statement Question Closure 1/4/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/4/2010 3:21 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 6 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1431                    06/09/2010


SR 3.3.1.7 is the performance of a COT every 184 days.  
Kewaunee ITS Conversion Database                                                                                              Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 7 of 76 ITS NRC Questions Id 1231 NRC Question KAB-041 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 133, 135, 137, 138 (s)
NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question On pages 133, 135, 137 and 138 of Attachment 1, volume 8, inserts 5, 6, 7, 8 and 9 are not consistent with TSTF-493.
TSTF-493 adds new paragraphs to STS NUREG-1431. The new paragraphs have not been added to Kewaunees ITS Bases for 3.3.1.7, 3.3.1.8, 3.3.1.10, 3.3.1.11 and 3.3.1.12. Please add the paragraphs to the ITS Bases or provide an explanation for the change.
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:50 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 7 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1231                                              06/08/2010


A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 8 of 76 Licensee Response/NRC Response/NRC Question Closure Id 951 NRC Question KAB-041 Number Select Licensee Response Application


clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
===Response===
 
11/30/2009 3:30 PM Date/Time Closure Statement Response  Kewaunee Power Station (KPS) has reviewed proposed TSTF-493 Rev. 4 Statement and concurs with the assessment that INSERTS 5, 6, 7, 8, and 9 need to be changed to reflect the current version of TSTF-493 Rev.4. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Setpoints must be within the Allowable Values specified in Table 3.3.1-1.  
Please note that TSTF-493 Rev. 4 was not an approved traveler at the time of the KPS submittal and that the KPS submittal was marked up to the draft version of TSTF-493 sent to the NRC in July of 2009.
 
Question Closure Date Attachment 1 KAB-041 Markup.pdf (1MB)
The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 11/30/2009 3:31 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 8 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=951    06/09/2010
 
The "as found" and "as left" values must also be recorded and reviewed
 
for consistency with the a ssumptions of Reference 9.  
 
SR 3.3.1.7 is modified by a Note that provides a 4 hours delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without  a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for > 4 hours this Surveillance must be performed prior to 4 hours after entry into MODE 3.  


Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 9 of 76 All changes are  1            RTS Instrumentation unless otherwise noted P        B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.1.7 SR 3.3.1.7 is the performance of a COT every 184 days.
INSERT 5      2 A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
INSERT 5    2 Setpoints must be within the Allowable Values specified in Table 3.3.1-1.        2 The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the    2 setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.
The "as found" and "as left" values must also be recorded and reviewed 2
for consistency with the assumptions of Reference 9.
SR 3.3.1.7 is modified by a Note that provides a 4 hours delay in the            6 requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for > 4 hours this Surveillance must be performed prior to 4 hours after entry into MODE 3.
The Frequency of 184 days is justified in Reference 9.
The Frequency of 184 days is justified in Reference 9.
2 2 2 INSERT 5 2 6 INSERT 5 2 B 3.3.1 Insert Page B 3.3.1-54 INSERT 5   COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.  
WOG STS                                B 3.3.1-54                          Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 9 of 76


2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 10 of 76 B 3.3.1 2
INSERT 5 COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.
The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.
The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
Insert Page B 3.3.1-54 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 10 of 76


The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 11 of 76 B 3.3.1 2
INSERT 6 COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.
The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.
The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
Insert Page B 3.3.1-55 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 11 of 76


consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 12 of 76 All changes are  1          RTS Instrumentation unless otherwise noted P      B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT and is performed every 4
[92] days, as justified in Reference 9. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.
SR 3.3.1.10 A CHANNEL CALIBRATION is performed every [18] months, or                          4 approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.                                            INSERT 7 CHANNEL CALIBRATIONS must be performed consistent with the                        2 assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left"            2 values must be consistent with the drift allowance used in the setpoint methodology.
The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.
SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values        5 where applicable.
WOG STS                                  B 3.3.1-56                        Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 12 of 76


response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 13 of 76 B 3.3.1 2
INSERT 7 in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.
The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.
The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
Insert Page B 3.3.1-56 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 13 of 76


OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 14 of 76 All changes are  1            RTS Instrumentation unless otherwise noted P        B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.1.11 INSERT 8 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every [18] months. This SR is modified by a          4 Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range                          2 INSERT 8 neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The
[18] month Frequency is based on the need to perform this Surveillance              4 under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed on the [18] month                      4 Frequency.
SR 3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as                  ¶ INSERT 9 described in SR 3.3.1.10, every [18] months. This SR is modified by a            4  2 Note stating that this test shall include verification of the RCS resistance temperature detector (RTD) bypass loop flow rate. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.
This test will verify the rate lag compensation for flow from the core to the RTDs.
The Frequency is justified by the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
WOG STS                                    B 3.3.1-57                          Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 14 of 76


channel as-found condition will be entered into the Corrective Action Program for further evaluation.
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 15 of 76 B 3.3.1 2
B 3.3.1 Insert Page B 3.3.1-55 INSERT 6  COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.
INSERT 8 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.
2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.
2 INSERT 9 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.
The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will  
The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.
The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.
Insert Page B 3.3.1-57 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 15 of 76


consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 16 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1491 NRC Question KAB-041 Number Select Application NRC Question Closure


response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the
===Response===
Statement Question Closure 1/5/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/5/2010 8:48 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 16 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1491                    06/09/2010


channel as-found condition will be entered into the Corrective Action Program for further evaluation.
Kewaunee ITS Conversion Database                                                                                              Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 17 of 76 ITS NRC Questions Id 1241 NRC Question KAB-042 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 129 (s)
RTS Instrumentation B 3.3.1   WOG STS B 3.3.1-56 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES
NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 129 of Attachment 1, volume 8, there is a reviewers note that states, A plant specific evaluation based on the guidance in Westinghouse Technical Bulletin ESBU-TB-92-14 is required to determine the power below which power range channel adjustments in a decreasing power direction become a concern. Please provide Kewaunees evaluation based on the technical bulletin (including when the power range channel adjustments become a concern and if additional administrative controls are required for power range neutron flux-high trip setpoint setting changes).
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:52 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 17 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1241                                              06/08/2010


SURVEILLANCE REQUIREMENTS  (continued)  
Kewaunee ITS Conversion Database                                                          Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 18 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1201 NRC Question KAB-042 Number Select Licensee Response Application


SR  3.3.1.9
===Response===
12/7/2009 3:40 PM Date/Time Closure Statement Response  Westinghouse Technical Bulletin ESBU-TB-92-14 was evaluated by KPS under Statement Operating Experience Assessment (OEA) 96-029. A summary of that evaluation is attached.
In regard to low power gain adjustments, if a calorimetric is performed at < 70%
RTP, the power range neutron high flux setpoint is lowered to less than or equal to 85%. A calorimetric must be performed at a higher power level (typically 75%
RTP) before the power range neutron high flux setpoint can be raised to the normal value of 105%.
Guidance is contained in SP-48-002, Nuclear Power Range Channel Gain Adjustment as follows:
Precaution Step 2.6, When Reactor Power is less than 75% power, NI gain adjustments are NOT required, unless more than 18 hours of operation will occur at this power level.
Procedure Step 6.1, IF Reactor Power is less than 70%, THEN REDUCE NI High Flux Trips to less than or equal to 85% power.
Procedure Step 6.10, IF NI High Flux Trips were reduced to less than or equal to 85% AND NI gain adjustment is verified acceptable, THEN RESET NI High Flux Trips to normal power.
Question Closure Date Attachment 1 KAB-042 OEA-96-029-Summary.pdf (135KB)
Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/7/2009 3:40 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 18 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1201          06/09/2010


SR 3.3.1.9 is the performance of a TADOT and is performed every
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 19 of 76 FORM SSEP-Ol-2                                  SSEP-ol January 31, 1994 OPERATING EXPERIENCE ASSESSMENT TECHNICAL BVALUATION                                Page 13 of 18
[92] days, as justified in Reference
                            -,                                                        ~&.--T--
: 9. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
OEANO.: 96-029            ,REPORT: WTB92-14-Rl,OE7771/uJo<:,,,"-OlSiIDATE: OS/22/96 CROSS REFERENCE OEAs:            93-036
The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.


SR  3.3.1.10
==SUBJECT:==
Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70% RTP; Logarithmic Power Nuclear Instrumentation Calibration Problems - Waterford 3 SAFETY OR RELIABIUTY SIGNIFICANCE:
SEE ATTACHMENT RECOM1\mNDED ACTION(S):
DEPARTMENT NO. DEPARTMENT                                        RECOMMENDATION                                HEAD~IALS 1        Operations        Revise SP 48-002 to require the NI High Flux Trips be reduced to 85 %
power if the adjustment is done at less than or equal to 70% power.
BVALUATED BY:                                                                      DATE:      /0 )/'-1/91 REvmWEDBY~~e                                            ~
Plant Operations Assessment Supervisor APPROVED 'BY                            -~/l/)_J1-..:....._ _- _ - - - D A T E :                            --.-._
(SOERs only)                            Plant Manager Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 19 of 76


A CHANNEL CALIBRATION is per formed every [18] months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 20 of 76 FORM SSEP-Ol-3                                        SSEP-Ol January 31. 1994 OPERATING EXPERIENCE ASSESSMENT REVIEW                                    Page 14 of 18 OEANO.; 96-029              IREPORT:      WTB 92-14-Rl, OE 777~      u.'6&~'t' -o;} ~fhATE:        /D /2-~ /~.,   ..,.
CROSS REFERENCE OEAs: 93-036


CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.  
==SUBJECT:==
Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70% RTP; Logarithmic Power Nuclear Instrumentation calibration Problems - Waterford 3 DISTRIBUTION:
o Plant Management                                                o Corporate Management
;ft( Operations                        /'1.1'1 /(w, 1-c~            0  Maintenance o SecurityIFire/Safety                                            o Instrument & Control o Maintenance Training                                            ~ Operations Training                      S1 !5v--o  40CJ ~
o General Employee Development                                    o Licensing & Systems o Project Management                                              o Radiochemistry o Quality Assurance                                                o Warehouse/Info*& Sche4ule o Nuclear Computer Systems                                        o Other o Radiation ProteCtion                                            ~ Plant Quality Program                    6  $ !2~ .. k ;tv""
o Chem/Rad Technologist Tmg.                                      o Tech Staff/Management Tmg.
o Safety System Engineering                                        o Plant Personnel o Nuclear Fuels                                                    D  NSRAC o Nuclear Projects                                                  o Nuclear Engineering Control o NBS Drawing Control                                              o NBS Mechanical Engineering o NBS Electrical Engineering                                        o NBS I&C Engineering o NBS Design/Field Services                                        o Nuclear Health Physicist ISSUED
: 1. 0    The attached evaluation is for your information only and no action is required. If you have comments you wish to include in our file, pl~se attach them to  this cover sheet and return to the Plant Operations Assessment Supervisor.
: 2. 0    When recommended actions have been completed, please complete Item 3 on the original Form SSEP..ol-4 kept in the OEA files and return to the Plant Operations Assessment Supervisor" 3.)2f{  This OBA for the above listed report(s) is closed out.
            ~~:y~
r :Operations Assessment Supervisor                                              Date Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 20 of 76


The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 21 of 76 FO~SSEP~14                                                    SSEP~l January 31, 1994 OPERATING EXPERIENCE ASSESSMENT RECOMMENDATION STATUS Page 15 of 18 OEANO.: 96-029                  IREPORT:        WTB 92-14-Rl, OE TI71,l>>oG          *'7 o"1M
:-tDATB:      ~/~J~?
                                                                                                                        ...
CROSS REFERENCE OEAs: 93-036


SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values
==SUBJECT:==
Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70% RTP; Logarithmic Power Nuclear Insttumentation Calibration Problems - Waterford 3 1.. Recommendation No. __l_ _ of __1~_ Responsible Department _O~pe~r...AoC.ata..LIioIlo.oLLD~S:.....-...                               _
Revise SP 48-002 to require the NI High Flux Trips be reduced to 85 % power if the adjustment is done at less than or equal to 70% power.
                                                                        ~-~- PLANT OPERAnONS ASSESSMENT SUPERVISOR L
: 2. Action to be taken:
A6 pl&#xa3;l1.. -A~~1l' tsI,~,~
Estimated Completion Date tJ~'Se.~l~                      ~              .                  .------:>
d~~~. lot n l9 J DEPARTMENT HEAD/DATE 3.. Recommended Action Implemented SI' o/y"DO<"              {;U-.s  re.tJist!.J    ffM-J '''''55''~.,A    /llzs/'l?            4.5 ;(e.<lJ"S;IJ...      t; S+e..f      tI,1      -A'",c/. tlt l .!    fe~.. c.t.  .rl,.. s~lj?o, .... t-    +0  ~.s""~    .:.t      -JI.. .....
          ,(I,IjLf.s+..... c ..t y ; os d'JJt,.~      (/1+ ?~~    1'~1Mt.,        t#r          Ie.ss.
Qf3 fL{JJJ.M- (or              KH~()              I-I 3    M qq DEPARTMENT HEAD/DATE
: 4. Recommendation Action Complied With                                    ."                                                  /;/s&
                                                                      ~LANT OPERATIONS ASSESSMENT &sect;UPV/DATE
: 5. Completed SOER Recommendation PLANT MANAGER/DATE Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 21 of 76


where applicable.  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 22 of 76 OEA96-o29 A. SAFETY OR RELIABILITY SIGNIFICANCE:
This Westinghouse Technical Bulletin discusses the potential to decalibrate the NIs at low power levels due to errors in the calorimetric. Decalibration of the NIs due to flux shift and low leakage cores was addressed by OBA 93-036 and IR 93-115 (LER 93-014).
Recommendations 1, 2, and 3 of this Tech. Bulletin are already being implemented at Kewaunee. Procedures SP 87-125 and SP 48-002 ensure the NIs are normalized to a calorimetric. Procedures RXT-6 and SPs 48-Q04A,B,C&D ensure the High Power trip is reduced to 80 % following a refueling outage and that the trip setpoint reduction is conservative. Procedure RXT-6 ensures the NIs are renormalized at successively higher power levels (2S, 40, 7S, 90, and 100%)..
KNPP bas chosen to address the concerns covered by Recommendations 4, 5, and 6 differently than descn'bed in the Tech Bulletin.
In Recommendation 4 Westinghouse suggests correcting the NIB by use of a gain adjust anytime they indicate less than the calorimetric. We will typically do this when the difference exceeds 1 % and power is greater than 75%. Jf power is less than 75% due to a backdown or return to power from a plant trip and the plant will remain at that power level less than 18 hours, no adjustment will be made. This is justified because the NlS hAs been previously adjusted for 100%
operation and the plant will be returning to that power level in a relatively short period of time. If an adjustment were to be made, it would likely have to be undone when power is increased.
In Recommendation 5 Westinghouse suggests that when power level is greater than 70% and the NIS indicate higher than the calorimetric, a gain adjust is not necessary. For cases where the plant is in a transient, the plant guidance described in Recommendation 4 is implemented. If the plant is operating at steady state power and the NIS indicates 1 % or greater than the calorimetric~ they will be adjusted. 'This is necessary to account for the changes in leakage due to core bumup.
In Recommendation 6 Westinghouse suggests that when power level is less than 70% power and the NIS indicate higher than the calorimetric, no adjustment should be made. As stated in the previous two recommendations~ if the plant is in a transient state, this guidance is followed. However ~ if the plant will remain at a power level greater than 18 hours, an adjustment must be made to meet Tech Spec requirements.. However, if the plant is maintaining a power level less than 50 % when the adjustment is made, the high power reactor trip setpoint will be reduced to 85%. The setpoint will be changed to its normal value when a more accurate adjustment can be made. Typically at approx. 75% power.. While this change was not made to account for calorimetric error, it does meet the intent of the Westinghouse recommendation.. The difference in power levels (50% for WPS, 70% for Westinghouse) should be addressed.
Kewaunee determines feedwater flow for the calorimetric differently than described in this Tech Bulletin. However, the worst case feedwater flow error possible at 50% power including the 2% NI-calorimetric mismatch driving the adjustment could result in a 13.5% error at 100% power6 An. error of this magnitude would result in KNPP exceeding the Tech Spec value of 109% and the analysis limit of 118%. To ensure analysis limits are met, SP48.. 002 should be revised to require the High Power NI setpoint be reduced if an adjustment is made at a power less than 70%. The maximum feedwater flow error at 70 % coupled with the 2 % NJ.-ca1orimetric error driving the adjustment will only result in a 6% error at 100%. While this may result in the plant exceeding the Tech Spec value of 109%, the analysis setpoint of 118 % will be maintained.
The second document covered by this OEA is a 50,,92 evaluation to change the Tech Spec requirements for NIS adjustment.. Due to the relatively short time KNPP operates at reduced power and the proposed changes to the procedural guidance already in place, a revision to p~t Tech Specs is not justified.
This OBA should be routed to Operations, Reactor Engineering, and I&C Engineering for information.
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 22 of 76


2 4 4 2 INSERT 7 5 B 3.3.1 Insert Page B 3.3.1-56 INSERT 7  in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 23 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1441 NRC Question KAB-042 Number Select Application NRC Question Closure
2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded. 


The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel
===Response===
Statement Question Closure 1/5/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/5/2010 8:23 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 23 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1441                    06/09/2010


response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is
Kewaunee ITS Conversion Database                                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 24 of 76 ITS NRC Questions Id 1251 NRC Question KAB-043 Number Category Editorial ITS Section 3.3 ITS Number 3.3.5 DOC Number JFD Number JFD Bases Number Page Number(s) 392 NRC Reviewer Rob Elliott Supervisor Technical Branch Add Name POC Conf Call Requested N NRC Question On page 392 of Attachment 1, Volume 8, the bases reference SR 3.3.5.3 however SR 3.3.5.3 has been renumbered to SR 3.3.5.2. Please update.
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:53 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 24 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1251                                    06/08/2010


OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 25 of 76 Licensee Response/NRC Response/NRC Question Closure Id 961 NRC Question KAB-043 Number Select Licensee Response Application


channel as-found condition will be entered into the Corrective Action Program for further evaluation.
===Response===
RTS Instrumentation B 3.3.1   WOG STS B 3.3.1-57 Rev. 3.0, 03/31/04 P All changes are unless otherwise noted 1 BASES
11/30/2009 3:35 PM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement the Bases reference on Attachment 1, Volume 8, Page 392 of 517 should be SR 3.3.5.2 instead of SR 3.3.5.3 (as currently shown). 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-043 Markup.pdf (807KB)
Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 11/30/2009 3:33 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 25 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=961    06/09/2010


SURVEILLANCE REQUIREMENTS  (continued)  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 26 of 76 All changes are  1 LOP DG Start Instrumentation O
B 3.3.5 unless otherwise noted BASES BACKGROUND (continued)
The Trip Setpoints used in the relays are based on the analytical limits presented in FSAR, Chapter 15 (Ref. 2). The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account.
Setpoints adjusted consistent with the requirements of the Allowable Value ensure that the consequences of accidents will be acceptable, providing the unit is operated from within the LCOs at the onset of the accident and that the equipment functions as designed.
2              Allowable Values and/or Nominal Trip Setpoints are specified for each Setpoint  Function in SR 3.3.5.3. Nominal Trip Setpoints are also specified in the      4 Control    unit specific setpoint calculations. The trip setpoints are selected to Program ensure that the setpoint measured by the surveillance procedure does not exceed the Allowable Value if the relay is performing as required. If the measured setpoint does not exceed the Allowable Value, the relay is considered OPERABLE. Operation with a trip setpoint less conservative than the nominal Trip Setpoint, but within the Allowable Value, is acceptable provided that operation and testing is consistent with the assumptions of the unit specific setpoint calculation (Ref. 3). methodology APPLICABLE      O The LOP DG start instrumentation is required for the Engineered Safety SAFETY            Features (ESF) Systems to function in any accident with a loss of offsite ANALYSES          power. Its design basis is that of the ESF Actuation System (ESFAS).
Accident analyses credit the loading of the DG based on the loss of offsite power during a loss of coolant accident (LOCA). The actual DG start has historically been associated with the ESFAS actuation. The DG loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power.
The analyses assume a non-mechanistic DG loading, which does not explicitly account for each individual component of loss of power detection and subsequent actions.
O The required channels of LOP DG start instrumentation, in conjunction with the ESF systems powered from the DGs, provide unit protection in the event of any of the analyzed accidents discussed in Reference 2, in which a loss of offsite power is assumed.
The delay times assumed in the safety analysis for the ESF equipment include the 10 second DG start delay, and the appropriate sequencing delay, if applicable. The response times for ESFAS actuated equipment in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," include the appropriate DG loading and sequencing delay.
WOG STS                                      B 3.3.5-2                        Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 26 of 76


SR  3.3.1.11
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 27 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1601 NRC Question KAB-043 Number Select Application NRC Question Closure


SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every [18] months.
===Response===
This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux m ap performed above 15% RTP. The CHANNEL CALIBRATION for the sour ce range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, ev aluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for
===Response===
Statement Question Closure 1/11/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/11/2010 11:27 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 27 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1601                    06/09/2010


the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The
Kewaunee ITS Conversion Database                                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 28 of 76 ITS NRC Questions Id 1251 NRC Question KAB-043 Number Category Editorial ITS Section 3.3 ITS Number 3.3.5 DOC Number JFD Number JFD Bases Number Page Number(s) 392 NRC Reviewer Rob Elliott Supervisor Technical Branch Add Name POC Conf Call Requested N NRC Question On page 392 of Attachment 1, Volume 8, the bases reference SR 3.3.5.3 however SR 3.3.5.3 has been renumbered to SR 3.3.5.2. Please update.
[18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:53 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 28 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1251                                    06/08/2010


reactor at power. Operating experience has shown these components usually pass the Surveillance when performed on the [18] month
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 29 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1461 NRC Question KAB-044 Number Select Licensee Response Application


Frequency.
===Response===
SR  3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every [18] months.
1/5/2010 8:25 AM Date/Time Closure Statement Response  After further review, Kewaunee Power Station has determined that Statement Justification for Deviation (JFD) 12 is not the correct JFD for the change described on Attachment 1, Volume 8, Page 199 of 517. A new JFD (JFD
This SR is modified by a Note stating that this test shall includ e verification of the RCS resistance temperature detector (RTD) bypass loop flow rate. Whenever a sensing
: 16) has been written to justify the change placing the channel in trip instead of bypass. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment KAB-044 Markup.pdf (850KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 1/5/2010 8:29 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 29 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1461      06/09/2010


element is replaced, the next requi red CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 30 of 76 CTS                                                                                ESFAS Instrumentation 3.3.2 ACTIONS (continued)
CONDITION                  REQUIRED ACTION                        COMPLETION TIME D.2.1      Be in MODE 3.                          78 hours AND D.2.2      Be in MODE 4.                          84 hours 3.5.d,  E. One Containment      [ ------------------NOTE-------------------
DOC M04,                                                                                                        1 DOC L08      Pressure channel      One additional channel may be inoperable.          bypassed for up to 12 hours for surveillance testing of other channels.
                                    -----------------------------------------------
                                    ----------REVIEWERS NOTE----------
The below Note should be used for                                            13 plants with installed bypass test capability.
One channel may be bypassed for up to 12 hours for surveillance testing.
                                    ---------------------------------------------- ]
16  12 E.1        Place channel in bypass.              72 hours trip OR E.2.1      Be in MODE 3.                          78 hours AND E.2.2      Be in MODE 4.                          84 hours DOCs M16,  F. One channel or train  F.1        Restore channel or train to            48 hours and L07 inoperable.                      OPERABLE status.
OR F.2.1      Be in MODE 3.                          54 hours AND WOG STS                                  3.3.2-3                                Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 30 of 76


This test will verify the rate lag compensation for flow from the core to the RTDs.  
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 31 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)
INSTRUMENTATION requirement to perform the surveillance test in accordance with the SCP. Hence, the addition of the phrase "in accordance with the Setpoint Control Program" to ITS SR 3.3.2.4, CHANNEL OPERATIONAL TEST (COT) and ITS SR 3.3.2.6, CHANNEL CALIBRATION in the surveillance requirement table.
: 13. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. ISTS Required Actions D, E, and I (ITS Required Actions D, E, and H, respectively) are modified by a Note that provides two options for bypassing a channel for up to 12 hours for the purpose of performing surveillance testing without entry into the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for plants that do not have installed bypass testing capabilities. KPS does not have installed bypass testing capabilities. Therefore, the Note for plants that do not have bypass testing capabilities is retained for Required Actions D, E, and H.
: 14. ISTS Table 3.3.2-1 Function 6.g (Trip of all Main Feedwater Pumps) specifies that ISTS SR 3.3.2.9, a CHANNEL CALIBRATION, is required for the Function. This CHANNEL CALIBRATION requirement is not being included in the KPS ITS for the same Function (ITS Table 3.3.2-1 Function 6.e). The ISTS shows that the Function has an ALLOWABLE VALUE and NOMINAL TRIP SETPOINT based on a pressure. The ISTS Bases describes that the trip is derived from low pressure on the control air/oil line of the turbine driven main feedwater pumps. Thus, it is appropriate to perform a CHANNEL CALIBRATION on the sensors. However, KPS uses motor driven main feedwater pumps, and the signal to start the AFW pumps comes from the breaker position contacts. Thus, there is no CHANNEL CALIBRATION to perform. This is also consistent with the KPS CTS, which does not require a CHANNEL CALIBRATION.
: 15. The RTS RESPONSE TIME requirement, ISTS SR 3.3.2.10, has not been adopted into the KPS ITS, consistent with Kewaunee current licensing basis and current Technical Specifications. The Kewaunee USAR describes the implementation of the principles as related to the proposed IEEE-279 "Standard, Nuclear Power Plant Protection Systems," August 1968. This industry standard provides guidance and requirements for conducting periodic testing of protection systems. IEEE-279-1968 does not address response time testing. Furthermore, generic studies have shown that instrumentation response time changes (increasing times), that could impact safety, do not normally vary such that they would not be detected during other required surveillances (e.g., CHANNEL CALIBRATIONS). Since the addition of these tests would be a major burden (plant design does not readily lend itself to such testing) with little gain in safety, ISTS SR 3.3.2.10 has not been added.
16  Throughout the ISTS, in both the Specifications and the Bases, reference is made to placing a channel in bypass or bypassing an inoperable channel. KPS does not have the ability to place a channel in bypass or perform a bypass of an inoperable channel 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 place a channel in bypass or perform a bypass of an inoperable channel. As a result, when a channel is required to be placed in bypass or a bypass of a channel is required, the channel is placed in the trip condition.
Kewaunee Power Station                    Page 5 of 5 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 31 of 76


The Frequency is justified by the a ssumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the
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setpoint analysis.  
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


INSERT 9 4 2 4 4 4 &#xb6; INSERT 8 INSERT 8 2 B 3.3.1 Insert Page B 3.3.1-57 INSERT 8  CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.  
===Response===
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:43 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 32 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1611                    06/09/2010


INSERT 9 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 33 of 76 ITS NRC Questions Id 1281 NRC Question KAB-045 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number Page Number 204 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question  On page 204 of Attachment 1, volume 8, SR 3.3.2.5 (renumbered to SR 3.3.2.4) references justification for deviations (JFD) 5. However, JFD 5 discusses deletion of the master and slave relay SR and SR 3.3.2.4 is a COT. Please provide an explanation for referencing JFD 5.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:39 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 33 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1281      06/08/2010


OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.
Kewaunee ITS Conversion Database                                                  Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 34 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1261 NRC Question KAB-045 Number Select Licensee Response Application
2 2 The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.


The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will
===Response===
12/15/2009 2:30 PM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment KAB-045 Markup.pdf (828KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:30 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 34 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1261  06/09/2010


consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 35 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)
INSTRUMENTATION Therefore, all master and slave relays in ESF that can be safely checked online and do not pose a significant risk to plant reliability are checked during the performance of the Actuation Logic Test (ALT). The remainder of the Master and Slave Relays are checked by actual equipment operation when the plant conditions are such that it does not significantly affect safety and reliability in the plant. KPS currently tests and meets the requirements of Generic Letter 96-01 and the inclusion of specific Master or Slave Relay Testing would be intrusive and/or affect safety and reliability due to the design of KPS. This was acknowledged in the original plant NRC SER (Ref. 1), a letter from WPSC to the NRC dated April 19, 1996 in regard to Generic Letter 96-01 (Ref. 2), and the acceptance letter from the NRC to WPSC dated January 14, 1999 in regard to Generic Letter 96-01 (Ref.
3). KPS testing of the Master and Slave Relays is limited and plant design does not allow for safely and reliably performing separate Master and Slave Relay Testing surveillances.      Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary.
: 6. ISTS 3.3.2 ACTIONS H, K, and L are applicable to ISTS Table 3.3.2-1 Functions 5.a, 7.b, 7.c, 8.b, and 8.c. These Functions are not applicable to the design of KPS; therefore, the applicable ACTIONS have been deleted. The discussion for the reason each function is not applicable to KPS is found in other Justification For Deviations.
: 7. ISTS SR 3.3.2.3 requires the performance of an ACTUATION LOGIC TEST every 31 days on a STAGGERED TEST BASIS. ISTS SR 3.3.2.3 also contains a NOTE that the continuity check may be excluded. ISTS SR 3.3.2.3 is applicable only to ISTS Table 3.3.2-1 Function 6.b, Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays. This test is currently not required at KPS. Since the design of the KPS ESFAS actuation logic is such that master and slave relays are employed and not a solid state protection system, ISTS SR 3.3.2.2 (ITS SR 3.3.2.2) is used to check the Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays. ISTS SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST every 92 days on a STAGGERED TEST BASIS. ISTS SR 3.3.2.2 does not contain the NOTE that the continuity check may be excluded. This testing Frequency is considered acceptable and is the same Frequency as relay testing for other ESFAS Functions. In addition, the Note is not needed for ITS SR 3.3.2.2. Subsequent Surveillance Requirements have been renumbered, as necessary.
: 8. ISTS Table 3.3.2-1 Functions 1.e.2 (Steam Line Pressure - High Differential Pressure Between Steam Lines), 1.f (High Steam Flow in Two Steam Lines Coincident with T avg - Low Low), 1.g (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 2.c (Containment Pressure High - 3 (High High)), 3.b.(1) (Phase B Isolation - Manual Initiation), 3.b.(2) (Phase B Isolation - Automatic Actuation Logic and Actuation Relays), 3.b.(3) (Containment Pressure High - 3 (High High)), 4.d.(1), (Steam Line Pressure Low), 4.d.(2),
(Negative Rate - High), 4.e, (High Steam Flow in Two Steam Lines Coincident with T avg - Low Low), 4.f, (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 6.a, (Automatic Actuation Logic and Actuation Relays (Solid State Protection System)), 6.e, (Auxiliary Feedwater Loss of Offsite Power), 6.h, (Auxiliary Feedwater Pump Suction transfer on Suction Pressure - Low), all Functions associated with Function 7 (Automatic Switchover to Containment Kewaunee Power Station                    Page 3 of 5 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 35 of 76


response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is
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OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


channel as-found condition will be entered into the Corrective Action Program for further evaluation.
===Response===
Licensee Response/NRC Response/NRC Question Closure Id1491NRC Question Number KAB-041 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 1/5/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/5/2010 8:48 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:47 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 36 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1621                    06/09/2010
p h p?re q uestT ype=areaItemPrint&itemId=1491 ITS NRC Questions Id1241NRC Question Number KAB-042 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number  Page Number(s) 129 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 129 of Attachment 1, volume 8, there is a reviewer's note that states, "A plant specific evaluation based on the guidance in Westinghouse Technical Bulletin ESBU-TB-92-14 is required to determine the power below which power range channel adjustments in a decreasing power direction become a concern."  Please provide Kewaunee's evaluation based on the technical bulletin (including when the power range channel adjustments become a concern and if additional administrative controls are required for power range neutron flux-high trip setpoint setting changes).
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:52 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=1241 Licensee Response/NRC Response/NRC Question Closure Id1201NRC Question Number KAB-042 Select Application Licensee Response Response Date/Time 12/7/2009 3:40 PM Closure Statement Response Statement Westinghouse Technical Bulletin ES BU-TB-92-14 was evaluated by KPS under Operating Experience Assessment (OEA) 96-029. A summary of that evaluation is attached. In regard to low power gain adjustments, if a calorimetric is performed at < 70% RTP, the power range neutron high flux setp oint is lowered to less than or equal to 85%. A calorimetric must be performed at a higher power level (typically 75% RTP) before the power range neutron high flux setpoint can be raised to the


normal value of 105%.
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 37 of 76 ITS NRC Questions Id 1291 NRC Question KAB-046 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5l6 JFD Bases Number Page Number 204 (s)
Guidance is contained in SP-48-002, "N uclear Power Range Channel Gain Adjustment" as follows:
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Precaution Step 2.6, When Reactor Power is less than 75% power, NI gain adjustments are NOT required, unless more than 18 hours of operation will occur at this power level.
Requested NRC Question    On page 204 of Attachment 1, volume 8, SR 3.3.2.7 (renumbered to SR 3.3.2.3) references justification for deviations (JFD) 5 and 6. However, JFD 5 discusses deletion of the master and slave relay SR and SR 3.3.2.3 is a TADOT. JFD 6 does not appear to be applicable to SR 3.3.2.3. Please provide a JFD reference that explains the change.
Procedure Step 6.1, IF Reactor Power is less than 70%, THEN REDUCE NI High Flux Trips to less than or equal to 85% power.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:40 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 37 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1291      06/08/2010
Procedure Step 6.10, IF NI High Flux Trips were reduced to less than or equal to 85% AND NI gain adjustment is verified acceptable, THEN RESET NI High Flux Trips to normal power.
Question Closure Date Attachment 1 KAB-042 OEA-96-029-Summary.pdf (135KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 12/7/2009 3:40 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee ITS Conversion Database                                                   Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 38 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1271 NRC Question KAB-046 Number Select Licensee Response Application
p h p?re q uestT ype=areaItemPrint&itemId=1201 FORM SSEP-Ol-2 SSEP-ol January 31, 1994 OPERATING EXPERIENCE ASSESSMENT TECHNICAL BV ALUATION Page 13 of 18-,
OEANO.: 96-029 ,REPORT: WTB92-14-Rl,OE7771/uJo<:,,,"-OlSiIDATE:
OS/22/96 CROSS REFERENCE OEAs: 93-036


==SUBJECT:==
===Response===
Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70%RTP;Logarithmic Power Nuclear Instrumentation Calibration Problems-Waterford 3 SAFETY OR RELIABIUTY SIGNIFICANCE:
12/15/2009 2:30 PM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
SEE ATTACHMENT RECOM1\mNDED ACTION(S):
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." The draft markup regarding this change is attached as part of the response to KAB-045 (since KAB-045 resulted in the same correction).
NO.1 DEPARTMENT Operations RECOMMENDATION Revise SP 48-002 to require the NI High Flux Trips be reduced to 85%power if the adjustment is done at less than or equal to 70%power.DEPARTMENT BV ALUATED BY: DATE:/0)/'-1/91Plant Operations Assessment Supervisor APPROVED'BY
In addition, KPS has determined that the correct Justification for Deviation (JFD) for the removal of the brackets should be JFD 1, not JFD 6. A draft Markup regarding this change is attached.
__-_---DATE:
These changes will be reflected in the supplement to this section of the ITS conversion amendment.
--.-._(SOERs only)Plant Manager FORM SSEP-Ol-3 OPERATING EXPERIENCE ASSESSMENT REVIEW SSEP-Ol January 31.1994 Page 14 of 18 OEANO.;96-029 I REPORT: WTB 92-14-Rl, OE-o;}
Question Closure Date Attachment KAB-046 Markup.pdf (810KB) 1 Attachment 2
/D..,.CROSS REFERENCE OEAs: 93-036
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:34 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 38 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1271    06/09/2010


==SUBJECT:==
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 39 of 76 CTS All changes are  1                      ESFAS Instrumentation 3.3.2 unless otherwise noted SURVEILLANCE REQUIREMENTS
Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70%RTP;Logarithmic Power Nuclear Instrumentation calibration Problems-Waterford 3 o Corporate Management
                -------------------------------------------------------------NOTE----------------------------------------------------------
/'1.1'1/(w,0 Maintenance DISTRIBUTION:
4.1.a      Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.
o Plant Management
                -------------------------------------------------------------------------------------------------------------------------------
;ft(Operations o Security IFire/Safety o Maintenance Training o General Employee Development o Project Management o Quality Assurance o Nuclear Computer Systems o Radiation ProteCtion o Chem/Rad Technologist Tmg.o Safety System Engineering o Nuclear Fuels o Nuclear Projects o NBS Drawing Control o NBS Electrical Engineering o NBS Design/Field Services o Instrument
Table TS 4.1-1,                                        SURVEILLANCE                                                    FREQUENCY Channel Descriptions 7, 11.a, 11.b, 18.a, 18.b, 18.c  SR 3.3.2.1               Perform CHANNEL CHECK.                                                  12 hours Table TS 4.1-1, Channel        SR 3.3.2.2                Perform ACTUATION LOGIC TEST.                                            92 days on a Description 26,                                                                                                      STAGGERED DOC M18 TEST BASIS SR 3.3.2.3                ------------------------------NOTE-------------------------------
&ControlOperations Training S1!5v--o 40CJo Licensing&Systems o Radiochemistry o Warehouse/Info*&
The continuity check may be excluded.
Sche4ule o OtherPlant Quality Program 6$..k;tv"" o Tech Staff/Management Tmg.o Plant Personnel D NSRAC o Nuclear Engineering Control o NBS Mechanical Engineering o NBS I&C Engineering o Nuclear Health Physicist ISSUED 1.0 The attached evaluation is for your information only and no action is required.If you have comments you wish to include in our file, attach them to this cover sheet and return to the Plant Operations Assessment Supervisor.
                                            ---------------------------------------------------------------------                                  7 Perform ACTUATION LOGIC TEST.                                           31 days on a STAGGERED TEST BASIS
2.0 When recommended actions have been completed, please complete Item 3 on the original Form SSEP..ol-4 kept in the OEA files and return to the Plant Operations Assessment Supervisor" 3.)2f{This OBA for the above listed report(s)is closed out.
                  ----------------------------------REVIEWERS NOTE---------------------------------
r: Operations Assessment Supervisor Date
The Frequency remains at 31 days on a STAGGERED TEST BASIS for plants with a Relay Protection System.
                  -----------------------------------------------------------------------------------------------                                     5 SR 3.3.2.4                Perform MASTER RELAY TEST.                                              92 days on a STAGGERED TEST BASIS Table TS 4.1-1, Channel                                                                                                                                          12 Descriptions 7,                                                          in accordance with the SR 3.3.2.5        4      Perform COT.              Setpoint Control Program                     184 days                    5 11.a, 11.b, 18.a, 18.b, 18.c, and 35 5
SR 3.3.2.6                Perform SLAVE RELAY TEST.                                               [92] days 5
DOC M14          SR 3.3.2.7        3      ------------------------------NOTE-------------------------------
Verification of relay setpoints not required.
                                            ---------------------------------------------------------------------
1  6 Perform TADOT.                                                          [92] days WOG STS                                                      3.3.2-7                                  Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 39 of 76


January 31, 1994 OPERATING EXPERIENCE ASSESSMENT RECOMMENDATION STATUS Page 15 of 18 OEANO.: 96-029 I REPORT: WTB 92-14-Rl, OE TI71,l>>oG*'7 M o"1:-tDATB:
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 40 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1631 NRC Question KAB-046 Number Select Application NRC Question Closure
...CROSS REFERENCE OEAs: 93-036


==SUBJECT:==
===Response===
Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70%RTP;Logarithmic Power Nuclear Insttumentation Calibration Problems-Waterford 3 1..Recommendation No.__l__of__Responsible Department
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
_Revise SP 48-002 to require the NI High Flux Trips be reduced to 85%power if the adjustment is done at less than or equal to 70%power.L PLANT OPERA nONS ASSESSMENT SUPERVISOR 2.Action to be taken: A6 pl&#xa3;l1..
Estimated Completion Date..------:>
lot n l 9 J DEPARTMENT HEAD/DATE 4.Recommendation Action Complied With 3..Recommended Action Implemented SI'o/y"DO<"{;U-.s re.tJist!.J ffM-J
/llzs/'l?4.5;(e.<lJ"S;IJ...
t;S+e..f tI,1-A'",c/.tlt l.!..c.t..rl,.......t-+0
.:.t-JI.......,(I,IjLf.s+
.....c..t y;os
(/1+ t#r Ie.ss.Qf3 fL{JJJ.M-(or I-I 3 M qq DEPARTMENT HEAD/DATE."/;/s&
OPERATIONS ASSESSMENT
&sect;UPV/DATE 5.Completed SOER Recommendation PLANT MANAGER/DATE OEA96-o29 A.SAFETY OR RELIABILITY SIGNIFICANCE:
This Westinghouse Technical Bulletin discusses the potential to decalibrate the NIs at low power levels due to errors in the calorimetric.
Decalibration of the NIs due to flux shift and low leakage cores was addressed by OBA 93-036 and IR 93-115 (LER 93-014).Recommendations 1, 2, and 3 of this Tech.Bulletin are already being implemented at Kewaunee.Procedures SP125 and SP 48-002 ensure the NIs are normalized to a calorimetric.
Procedures RXT-6 and SPs 48-Q04A,B,C&D ensure the High Power trip is reduced to 80%following a refueling outage and that the trip setpoint reduction is conservative.
Procedure RXT-6 ensures the NIs are renormalized at successively higher power levels (2S, 40, 7S, 90, and 100%)..KNPP bas chosen to address the concerns covered by Recommendations 4, 5, and 6 differently than descn'bed in the Tech Bulletin.In Recommendation 4 Westinghouse suggests correcting the NIB by use of a gain adjust anytime they indicate less than the calorimetric.
We will typically do this when the difference exceeds 1%and power is greater than 75%.Jf power is less than 75%due to a backdown or return to power from a plant trip and the plant will remain at that power level less than 18 hours, no adjustment will be made.This is justified because the NlS hAs been previously adjusted for 100%operation and the plant will be returning to that power level in a relatively short period of time.If an adjustment were to be made, it would likely have to be undone when power is increased.
In Recommendation 5 Westinghouse suggests that when power level is greater than 70%and the NIS indicate higher than the calorimetric, a gain adjust is not necessary.
For cases where the plant is in a transient, the plant guidance described in Recommendation 4 is implemented.
If the plant is operating at steady state power and the NIS indicates 1%or greater than the they will be adjusted.'This is necessary to account for the changes in leakage due to core bumup.In Recommendation 6 Westinghouse suggests that when power level is less than 70%power and the NIS indicate higher than the calorimetric, no adjustment should be made.As stated in the previous two if the plant is in a transient state, this guidance is followed.Howeverif the plant will remain at a power level greater than 18 hours, an adjustment must be made to meet Tech Spec requirements..
However, if the plant is maintaining a power level less than 50%when the adjustment is made, the high power reactor trip setpoint will be reduced to 85%.The setpoint will be changed to its normal value when a more accurate adjustment can be made.Typically at approx.75%power..While this change was not made to account for calorimetric error, it does meet the intent of the Westinghouse recommendation..
The difference in power levels (50%for WPS, 70%for Westinghouse) should be addressed.
Kewaunee determines feedwater flow for the calorimetric differently than described in this Tech Bulletin.However, the worst case feedwater flow error possible at 50%power including the 2%NI-calorimetric mismatch driving the adjustment could result in a 13.5%error at 100%power6 An.error of this magnitude would result in KNPP exceeding the Tech Spec value of 109%and the analysis limit of 118%.To ensure analysis limits are met, SP48...002 should be revised to require the High Power NI setpoint be reduced if an adjustment is made at a power less than 70%.The maximum feedwater flow error at 70%coupled with the 2%NJ.-ca1orimetric error driving the adjustment will only result in a 6%error at 100%.While this may result in the plant exceeding the Tech Spec value of 109%, the analysis setpoint of 118%will be maintained.
The second document covered by this OEA is a 50,,92 evaluation to change the Tech Spec requirements for NIS adjustment..
Due to the relatively short time KNPP operates at reduced power and the proposed changes to the procedural guidance already in place, a revision to Tech Specs is not justified.
This OBA should be routed to Operations, Reactor Engineering, and I&C Engineering for information.
Licensee Response/NRC Response/NRC Question Closure Id1441NRC Question Number KAB-042 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 1/5/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/5/2010 8:23 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=1441 ITS NRC Questions Id1251NRC Question Number KAB-043 Category Editorial ITS Section 3.3 ITS Number 3.3.5 DOC Number JFD Number JFD Bases Number Page Number(s) 392 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 392 of Attachment 1, Volume 8, the bases reference SR 3.3.5.3 however SR 3.3.5.3 has been renumbered to SR 3.3.5.2. Please update.
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:53 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=1251 Licensee Response/NRC Response/NRC Question Closure Id961NRC Question Number KAB-043 Select Application Licensee Response Response Date/Time 11/30/2009 3:35 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the Bases reference on Attachment 1, Volume 8, Page 392 of 517 should be SR 3.3.5.2 instead of SR 3.3.5.3 (as currentl y shown). 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-043 Markup.pdf (807KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 11/30/2009 3:33 PM Modified By Date Modified   Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
===Response===
p h p?re q uestT ype=areaItemPrint&itemId=961 LOP DG Start Instrumentation B 3.3.5    WOG STS B 3.3.5-2 Rev. 3.0, 03/31/04 O BASES
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:48 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 40 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1631                    06/09/2010


BACKGROUND (continued)  
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 41 of 76 ITS NRC Questions Id 1301 NRC Question KAB-047 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number Page Number 205 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC On page 205 of Attachment 1, volume 8, Surveillance Requirements Question  3.3.2.8, 3.3.2.9 and 3.3.2.11 (renumbered to SR 3.3.2.5, 3.3.2.6 and 3.3.2.7) reference justification for deviations (JFD) number 5. However, JFD 5 discusses deletion of master and slave relay testing. JFD 5 is not applicable to these SRs. Please provide a JFD reference that explains the changes.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:41 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 41 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1301      06/08/2010


The Trip Setpoints used in the relays are based on the analytical limits presented in FSAR, Chapter 15 (Ref. 2). The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account.
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 42 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1281 NRC Question KAB-047 Number Select Licensee Response Application


Setpoints adjusted consistent with the requirements of the Allowable Value ensure that the consequences of accidents will be acceptable, providing the unit is operated from within the LCOs at the onset of the  
===Response===
12/15/2009 2:35 PM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." The draft markup regarding this change is attached as part of the response to KAB-045 (since KAB-045 resulted in the same correction). This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:37 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 42 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1281    06/09/2010


accident and that the equipment functions as designed.  
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 43 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1661 NRC Question KAB-047 Number Select Application NRC Question Closure


Allowable Values and/or Nominal Trip Setpoints are specified for each Function in SR 3.3.5.3. Nominal Trip Setpoints are also specified in the unit specific setpoint calculations.
===Response===
The trip setpoints are selected to ensure that the setpoint measured by the surveillance procedure does not
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


exceed the Allowable Value if the relay is performing as required. If the
===Response===
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:55 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 43 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1661                    06/09/2010


measured setpoint does not exceed the Allowable Value, the relay is considered OPERABLE. Operation with a trip setpoint less conservative than the nominal Trip Setpoint, but within the Allowable Value, is acceptable provided that operation and testing is consistent with the assumptions of the unit specific setpoint calculation (Ref. 3).  
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 44 of 76 ITS NRC Questions Id 1311 NRC Question KAB-048 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 6 JFD Bases Number Page Number 205 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 205 of Attachment 1, volume 8, Surveillance Requirements 3.3.2.8 and 3.3.2.9 (renumbered to SR 3.3.2.5 and 3.3.2.6) reference justification for deviations (JFD) number 6. JFD 6 is not applicable to these SRs. Please provide a JFD reference that explains the changes.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:43 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 44 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1311      06/08/2010


APPLICABLE The LOP DG start instrumentati on is required for the Engineered Safety SAFETY  Features (ESF) Systems to function in any accident with a loss of offsite ANALYSES power. Its design basis is that of the ESF Actuation System (ESFAS).
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 45 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1291 NRC Question KAB-048 Number Select Licensee Response Application
Accident analyses credit the loading of the DG based on the loss of offsite power during a loss of coolant accident (LOCA). The actual DG start has historically been associated with the ESFAS actuation. The DG loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power.
The analyses assume a non-mechanistic DG loading, which does not


explicitly account for each i ndividual component of loss of power detection and subsequent actions.
===Response===
The required channels of LOP DG start instrumentation, in conjunction
12/15/2009 2:40 PM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement the correct Justification for Deviation (JFD) for the removal of the brackets in ISTS SR 3.3.2.8 and SR 3.3.2.9 (ITS SR 3.3.2.5 and SR 3.3.2.6, respectively) on Attachment 1, Volume 8, Page 205 of 517 should be JFD
: 1. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment KAB-048 Markup.pdf (840KB) 1 Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:39 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 45 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1291      06/09/2010


with the ESF systems powered from the DGs, provide unit protection in
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 46 of 76 CTS                                                                                              ESFAS Instrumentation All changes are    3 3.3.2 unless otherwise noted SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                                  FREQUENCY DOC M09      SR 3.3.2.8  5  ------------------------------NOTE-------------------------------                                  5 Verification of setpoint not required for manual initiation functions.
                                ---------------------------------------------------------------------
Perform TADOT.                                                        [18] months          1      6 Table TS 4.1-1,  SR 3.3.2.9  6  ------------------------------NOTE-------------------------------                                5 Channel Descriptions 7,                  This Surveillance shall include verification that the                                                9 11.a, 11.b,                    time constants are adjusted to the prescribed 18.a, 18.b, and 18.c values.
                                ---------------------------------------------------------------------
Perform CHANNEL CALIBRATION.                                          [18] months            1        6 in accordance with the                                       12 Setpoint Control Program SR 3.3.2.10    ------------------------------NOTE-------------------------------
Not required to be performed for the turbine driven AFW pump until [24] hours after SG pressure is
                                 [1000] psig.
                                ---------------------------------------------------------------------                              15 Verify ESFAS RESPONSE TIMES are within limit.                          [18] months on a STAGGERED TEST BASIS DOC M17                                                                                                                          5 SR 3.3.2.11  7 ------------------------------NOTE-------------------------------
Verification of setpoint not required.
                                ---------------------------------------------------------------------
Perform TADOT.                                                        Once per reactor trip breaker cycle WOG STS                                            3.3.2-8                                Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 46 of 76


the event of any of the analyzed accidents discussed in Reference 2, in
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 47 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1641 NRC Question KAB-048 Number Select Application NRC Question Closure


which a loss of offsite power is assumed.  
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


The delay times assumed in the safety analysis for the ESF equipment include the 10 second DG start delay, and the appropriate sequencing
===Response===
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:50 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 47 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1641                    06/09/2010


delay, if applicable. The res ponse times for ESFAS actuated equipment in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)
Kewaunee ITS Conversion Database                                                        Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 48 of 76 ITS NRC Questions Id 1321 NRC Question KAB-049 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 9 JFD Bases Number Page Number 218 (s)
Instrumentation," include the appropriate DG loading and sequencing delay. O O All changes are unless otherwise noted 1 methodology Setpoint Control Program 2 4 Licensee Response/NRC Response/NRC Question Closure Id1601NRC Question Number KAB-043 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 11:27 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
p h p?re q uestT ype=areaItemPrint&itemId=1601 ITS NRC Questions Id1251NRC Question Number KAB-043 Category Editorial ITS Section 3.3 ITS Number 3.3.5 DOC Number JFD Number JFD Bases Number Page Number(s) 392 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 392 of Attachment 1, Volume 8, the bases reference SR 3.3.5.3 however SR 3.3.5.3 has been renumbered to SR 3.3.5.2. Please update.
Requested NRC Question   On page 218 of Attachment 1, volume 8, justification for deviations (JFD) 9 indicates ITS SR 3.3.2.6 applies to function 6.e. However, SR 3.3.2.6 is not listed in TS Table 3.3.2.1 for function 6.e. Please correct or explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:53 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:44 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 48 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1321        06/08/2010
p h p?re q uestT ype=areaItemPrint&itemId=1251 Licensee Response/NRC Response/NRC Question Closure Id1461NRC Question Number KAB-044 Select Application Licensee Response Response Date/Time 1/5/2010 8:25 AM Closure Statement Response Statement After further review, Kewaunee Powe r Station has determined that Justification for Deviation (JFD) 12 is not the correct JFD for the change described on Attachment 1, Volume 8, Page 199 of 517. A new JFD (JFD 16) has been written to justify the change placing the channel in trip instead of bypass. A draf t markup regarding this ch ange 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-044 Markup.pdf (850KB) Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 1/5/2010 8:29 AM Modified By Date Modified  Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee ITS Conversion Database                                                     Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 49 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1451 NRC Question KAB-049 Number Select Licensee Response Application
p h p?re q uestT ype=areaItemPrint&itemId=1461 ESFAS Instrumentation 3.3.2  WOG STS 3.3.2-3 Rev. 3.0, 03/31/04 ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.2.1 Be in MODE 3.


AND D.2.2 Be in MODE 4.  
===Response===
1/5/2010 8:20 AM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement Justification for Deviation (JFD) 9 does not apply to ITS Table 3.3.2-1 Function 6.e. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1 KAB-049 Markup.pdf (392KB)
Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 1/5/2010 8:23 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 49 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1451      06/09/2010


78 hours
Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 50 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)
INSTRUMENTATION Sump), 8.b, (Pressurizer Pressure, P-11), and 8.c, (T avg - Low Low, P-12) have been deleted since they do not apply to the KPS design. In addition, all applicable footnotes related to those Functions are also being deleted. Subsequent Functions and footnotes have been renumbered as applicable.
: 9. A Note to ISTS SR 3.3.2.9 (ITS SR 3.3.2.6) requires the CHANNEL CALIBRATION to include verification that time constants are adjusted to the prescribed values. In the KPS ITS, this Surveillance (ITS SR 3.3.2.6) applies to ITS Table 3.3.2-1, Functions 1.c, 1.d, 1.e, 2.c, 4.c, 4.d, 4.e, 5.b, 6.b, 6.d, 6.e, and 7.b. Of these Functions, the only one that has a time constant is ITS Table 3.3.2-1 Functions 1.e, and the time constants are included in a Note to the Allowable Value. Thus, the time constant is part of the Allowable Value for this function. The definition of CHANNEL CALIBRATION states that it 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. Thus the CHANNEL CALIBRATION of this Function requires the time constant be set properly. It is not necessary to include a Note that also says that the CHANNEL CALIBRATION Surveillance includes the time constants; it already does. Including this note in this Surveillance would incorrectly imply that a CHANNEL CALIBRATION does not require certain Allowable Values (i.e., time constant type Allowable Values) to be verified during the CHANNEL CALIBRATION. In addition, the Allowable Values for the KPS ITS will be removed from the ITS and retained in a licensee-controlled Setpoint Control Program. Therefore, the Note is not included in the KPS ITS.
: 10. The Nominal Trip Setpoint column has been deleted as allowed by the Reviewer's Note at the end of the ISTS Table 3.3.2-1. This Reviewer's Note allows specific unit implementation to contain only the Allowable Value. The nominal trip setpoints for each of the applicable ITS Table 3.3.2-1 Functions will be controlled in accordance with the Note in the ISTS 3.3.2 Bases Background section.
: 11. ISTS Table 3.3.2-1 (ITS Table 3.3.2-1) Function 8 (Reactor Trip, P-4 Interlock) has been revised by deleting the term "2 trains." This information is Bases type information and has been included in the ITS Bases.
: 12. Changes are made to the ISTS that reflect the adoption of proposed Revision 4 of TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions".
Three options are provided for licensees to pursue when adopting TSTF-493. KPS has elected to implement TSTF-493 via the use of a Setpoint Control Program.
Under this adoption strategy, KPS relocates the Technical Specification Section 3.3, "Instrumentation," Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Values from the Technical Specifications to a licensee-controlled Setpoint Control Program. The requirements for the Setpoint Control Program will be described in Chapter 5, "Administrative Controls," of the Technical Specifications. Hence the deletion of the "ALLOWABLE VALUE" and "NOMINAL TRIP SETPOINT" columns from Table 3.3.2-1 of the ITS. Included in the relocation to the licensee-controlled Setpoint Control Program is all information contained within any associated footnotes that tie to numerical values in the Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Value columns.
In addition, the adoption strategy requires that each instrument surveillance requirement which verifies a LSSS (both SL and non-SL-LSSSs) contain a Kewaunee Power Station                  Page 4 of 5 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 50 of 76


84 hours E. One Containment Pressure channel
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 51 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1651 NRC Question KAB-049 Number Select Application NRC Question Closure


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


[ ------------------NOTE------------------- One additional channel may be
===Response===
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:53 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 51 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1651                    06/09/2010


bypassed for up to 12 hours for surveillance testing of other channels.  
Kewaunee ITS Conversion Database                                                  Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 52 of 76 ITS NRC Questions Id 1331 NRC Question KAB-050 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number JFD Bases Number Page Number 205 (s)
-----------------------------------------------
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 205 of Attachment 1, volume 8, surveillance requirement 3.3.2.8 (renumbered to SR 3.3.2.5) does not show a change that would be consistent with the adoption of TSTF-493. TSTF-493 would add the statement in accordance with the setpoint control program to SR 3.3.2.5.
Please provide a new JFD reference that explains the change.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:45 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 52 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1331  06/08/2010


----------REVIEWERS NOTE----------
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 53 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1311 NRC Question KAB-050 Number Select Licensee Response Application


The below Note should be used for plants with installed bypass test capability.  
===Response===
12/17/2009 11:00 AM Date/Time Closure Statement Response  TSTF-493, Rev. 4, Option B includes the statement concerning the setpoint Statement control program for ISTS SR 3.3.2.8. This SR is a TADOT, and applies to all the manual initiation functions as well as the AFW trip of all main feedwater pumps function. In the ISTS, this function includes setpoints. However, for the KPS design, this trip is actuated by breaker position switches, not a pressure sensor. The Note for ISTS SR 3.3.2.8 (ITS SR 3.3.2.5) specifically states that verification of setpoints are not required for the manual initiation functions. Since there are no setpoints for the KPS design, and the definition of TADOT in Section 1.1 (Volume 3, page 38) states that it includes an adjustment only as necessary, setpoint verification would also not be required. Therefore, the addition of the requirement from TSTF-493, Rev. 4 concerning the setpoint control program is not needed. KPS does not believe that a JFD is necessary to state that a small piece of TSTF-493, which is not approved yet by the NRC, is not being adopted. KPS believes that this response, in addition to the actual KPS design for the function as described in the ITS Bases (page 263), provides proper documentation as to why this part of TSTF-493 is not being adopted.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:04 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 53 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1311      06/09/2010


One channel may be bypassed for
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 54 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1671 NRC Question KAB-050 Number Select Application NRC Question Closure


up to 12 hours for surveillance testing. ---------------------------------------------- ]
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


E.1 Place channel in bypass.  
===Response===
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:59 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 54 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1671                    06/09/2010


OR E.2.1 Be in MODE 3.  
Kewaunee ITS Conversion Database                                                                Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 55 of 76 ITS NRC Questions Id 1341 NRC Question KAB-051 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number Page Number 206-214 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question  On page 206-214 of Attachment 1, volume 8, TS Table 3.3.2-1 functions 1.a, 1.c, 1.d, 1.e.1, 2.a, 2.c, 3.a, 4.a, 4.c, 4.d, 4.e, 5.b, 6.b, 6.d, 6.e, and 8 reference justification for deviations (JFD) number 5. However, JFD 5 discusses deletion of master and slave relay testing. JFD 5 is not applicable to these SRs. Please provide a JFD reference that explains the changes.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:46 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 55 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1341                06/08/2010


AND  E.2.2 Be in MODE 4.  
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 56 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1321 NRC Question KAB-051 Number Select Licensee Response Application


72 hours
===Response===
12/17/2009 11:05 AM Date/Time Closure Statement Response  After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." The draft markup regarding this change is attached as part of the response to KAB-045 (since KAB-045 resulted in the same correction). This change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:06 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 56 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1321    06/09/2010


78 hours
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 57 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1681 NRC Question KAB-051 Number Select Application NRC Question Closure


84 hours  F. One channel or train inoperable.  
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


F.1 Restore channel or train to OPERABLE status.
===Response===
OR F.2.1 Be in MODE 3.
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:01 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 57 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1681                    06/09/2010
AND 48 hours


54 hours
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 58 of 76 ITS NRC Questions Id 1351 NRC Question KAB-052 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5l8 JFD Bases Number Page 215 and 424 Number(s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC  On page 215 and 424 of Attachment 1, volume 8, justifications for Question  deviations 5 and 8 discuss deletion of master and slave relay testing.
Please provide a list stating which functions have master relays and which functions have slave relays. Include in your response the current master and slave relay surveillance testing frequency for each function and which surveillance tests apply i.e., functional check, calibrate or test.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:48 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 58 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1351    06/24/2010


CTS 3.5.d, DOC M04, DOC L08 DOCs M16, and L07 13 12 trip 1 16 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FE ATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Kewaunee Power Station Page 5 of 5 requirement to perform the surveillance test in accordance with the SCP. Hence, the addition of the phrase "in accordance wi th the Setpoint Control Program" to ITS SR 3.3.2.4, CHANNEL OPERATIONAL TEST (COT) and ITS SR 3.3.2.6, CHANNEL CALIBRATION in the surveillance requirement table.
Kewaunee ITS Conversion Database                                                          Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 59 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1391 NRC Question KAB-052 Number Select Licensee Response Application
: 13. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. ISTS Required Actions D, E, and I (ITS Required


Actions D, E, and H, respectively) are modified by a Note that provides two options for bypassing a channel for up to 12 hours for the purpose of performing surveillance testing without entry into the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for
===Response===
12/22/2009 3:10 PM Date/Time Closure Statement


plants that do not have installed bypass testing capabilities. KPS does not have installed bypass testing capabilities. Therefore, the Note for plants that do not have bypass testing capabilities is retained for Required Actions D, E, and H.
===Response===
: 14. ISTS Table 3.3.2-1 Function 6.g (Trip of all Main Feedwater Pumps) specifies that ISTS SR 3.3.2.9, a CHANNEL CALIBRATION, is required for the Function. This CHANNEL CALIBRATION requirement is not being included in the KPS ITS for the same Function (ITS Table 3.3.2-1 Function 6.e). The ISTS shows that the
Statement  Table 3.3.2-1, Functions 5a, 6a, and 7 have master and slave relays but do not require master and slave relay testing in NUREG-1431 for ITS, therefore they are not included below.
The following Functions have Master and/or Slave relays that will be checked by the Actuation Logic Test (ALT) every 92 days on a staggered test basis in ITS (SP-55-155):
Table 3.3.2-1 Function 1.b Table 3.3.2-1 Function 2.b Table 3.3.2-1 Function 3.b Table 3.3.2-1 Function 4.b Table 3.3.6-1 Function 1 Table 3.3.6-1 Function 2.a (ALT is SI logic portion)
Table 3.3.6-1 Function 2.b (ALT is SI logic portion)
There are some Master and/or Slave relays that are blocked during the ALT to prevent them from operating at inopportune times. Most of these blocked relays are tested for continuity during the ALT by passing enough current to light a bulb, but not enough current to actually pick up the relay. The following Functions contain some relays that do not operate during the ALT but are checked by other surveillances:
Table 3.3.2-1 Function 1.b Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.2-1 Function 2.b Slave checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.2-1 Function 3.b Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.2-1 Function 4.b Slaves checked by Valve Timing Test every 18 months (SP-55-167-6A)
Table 3.3.2-1 Function 5.a Masters & Slaves checked by FRV Timing Test every 18 months (SP-05A-202)
Table 3.3.6-1 Function 1 Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.6-1 Function 2.a Slaves (SP-45-49.12) R12 Quarterly Test cycle Master and Slave Table 3.3.6-1 Function 2.b Slaves (SP-45-49-11) R11 Quarterly Test cycle Master Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 59 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1391          06/24/2010


Function has an ALLOWABLE VALUE and NOMINAL TRIP SETPOINT based on a pressure. The ISTS Bases describes that the trip is derived from low pressure on the control air/oil line of the turbine driven main feedwater pumps. Thus, it is appropriate to perform a CHANNEL CALIBRATION on the sensors. However, KPS uses motor driven main feedwater pum ps, and the signal to start the AFW pumps comes from the breaker position contacts. Thus, there is no CHANNEL CALIBRATION to perform. This is also consistent with the KPS CTS, which does not require a CHANNEL CALIBRATION.
Kewaunee ITS Conversion Database                                                Page 2 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 60 of 76 and Slave Question Closure Date Attachment 1
: 15. The RTS RESPONSE TIME requirement, ISTS SR 3.3.2.10, has not been adopted into the KPS ITS, consistent with Kewaunee current licensing basis and current Technical Specifications. The Kewaunee USAR describes the implementation of the principles as related to the proposed IEEE-279 "Standard, Nuclear Power Plant Protection Systems," August 1968. This industry standard provides guidance and
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/22/2009 3:16 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 60 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1391 06/24/2010


requirements for conducting periodic testing of protection systems. IEEE-279-1968 does not address response time testing. Furthermore, generic studies have shown that instrumentation response time changes (increasing times), that could impact
Kewaunee ITS Conversion Database                                                            Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 61 of 76 Licensee Response/NRC Response/NRC Question Closure Id 3231 NRC Question KAB-052 Number Select NRC Response Application


safety, do not normally vary such that they would not be detected during other required surveillances (e.g., CHANNEL CALIBRATIONS). Since the addition of these tests would be a major burden (plant design does not readily lend itself to such testing) with little gain in safety, ISTS SR 3.3.2.10 has not been added.
===Response===
16 Throughout the ISTS, in both the Specifications and the Bases, reference is made to placing a channel in bypass or bypassing an inoperable channel. KPS does not have the
5/26/2010 6:00 PM Date/Time Closure Statement Response  In ITS TS 3.3.2, Table 3.3.2-1, Function 5a, Feedwater Isolation Automatic Statement Actuation Logic and Actuation Relays, Function 6a, Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays, and Function 7.a, Turbine Building Service Water Header Isolation Automatic Actuation Logic and Actuation Relays, require SR 3.3.2.2 (Attachment 1 Volume 8, pages 212 and 213 of 517).
Please clarify the quoted statement, in the response to RAI KAB-052, as to why the master and slave relays of ITS TS 3.3.2 Table 3.3.2-1, Functions 5a, 6a, and 7a do not require testing. If these master and slave relays are not tested by SR 3.3.2.2 or other TS 3.3.2 surveillances, how is operability of the relays determined?
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 5/26/2010 11:18 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 61 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3231            06/24/2010


ability to place a channel in bypass or perform a bypass of an inoperable channel without
Kewaunee ITS Conversion Database                                                      Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 62 of 76 Licensee Response/NRC Response/NRC Question Closure Id 3341 NRC Question KAB-052 Number Select Licensee Response Application


performing a temporary alteration of the circuit. Since the installation of temporary
===Response===
 
5/28/2010 10:15 AM Date/Time Closure Statement Response  KAB-052, Second Response Statement The paragraph being quoted in the KAB-052 NRC response of 5/26/2010 is referencing the first paragraph of the original KPS response to KAB-052.
alterations is intrusive, KPS has determined that this practice is unacceptable. Therefore, KPS does not have the ability to place a channel in bypass or perform a bypass of an
This paragraph, which was inadvertently included in the KPS response, should not have been included as this paragraph was informational and related to the ISTS Table Functions (it was information provided to internal KPS reviewers).
 
KPS ITS Functions 5.a and 6.a do have Master and Slave Relays. Function 5.a was described in the previous response, but for completeness, the information is also provided in this response.
inoperable channel. As a result, when a channel is required to be placed in bypass or a
KPS ITS Function 5a Master and Slave Relays are checked by the Feed Regulating Valve Timing Test every 18 months (procedure SP-05A-202).
 
KPS ITS Function 6a Master and Slave Relays are checked at power (i.e.
bypass of a channel is required, the channel is placed in the trip condition.
online) by Reactor Protection Logic test (procedures SP-47-062A/B) and during shutdown conditions by Reactor Protection Logic test (procedures SP-47-062G/H/I).
Licensee Response/NRC Response/NRC Question Closure Id1611NRC Question Number KAB-044 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:43 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
KPS ITS Function 7a does not have a typical Master/Slave Relay design, therefore a specific Master or Slave Relay test is not required for this Function. However, the design that does exist is a single contact matrix that is tested by SR 3.3.2.2 (as required by the ITS).
p h p?re q uestT ype=areaItemPrint&itemId=1611 ITS NRC Questions Id1281NRC Question Number KAB-045 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number  Page Number(s) 204 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 204 of Attachment 1, volume 8, SR 3.3.2.5 (r enumbered to SR 3.3.2.4) references justif ication for deviations (J FD) 5. However, JFD 5 discusses deletion of the master and slave relay SR and SR 3.3.2.4 is a COT. Please provide an explanation for referencing JFD 5.
Question Closure Date Attachment 1
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:39 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.
Attachment 2
p h p?re q uestT ype=areaItemPrint&itemId=1281 Licensee Response/NRC Response/NRC Question Closure Id1261NRC Question Number KAB-045 Select Application Licensee Response Response Date/Time 12/15/2009 2:30 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that JFD 5 needs an additional sentenc
Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Kristy Bucholtz Added By Charles Smoker Date Added 5/28/2010 10:12 AM Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 62 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3341      06/24/2010
: e. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has b een added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessar y."  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-045 Markup.pdf (828KB) Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays
 
Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:30 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=1261 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FE ATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Kewaunee Power Station Page 3 of 5 Therefore, all master and slave relays in ESF that can be safely checked online and do not pose a significant risk to plant reliability are checked during the performance of the Actuation Logic Test (ALT). The remainder of the Master and  
 
Slave Relays are checked by ac tual equipment operation when the plant conditions are such that it does not significantly affect safety and reliability in the plant. KPS currently tests and meets the requirements of Generic Letter 96-01 and the inclusion of specific Master or Slav e Relay Testing would be intrusive and/or affect safety and reliability due to the design of KPS. This was acknowledged in the original plant NRC SER (Ref. 1), a letter from WPSC to the NRC dated April 19, 1996 in regard to Generic Letter 96-01 (Ref. 2), and the acceptance letter from the NRC to WPSC dated January 14, 1999 in regard to Generic Letter 96-01 (Ref.
3). KPS testing of the Master and Slave Relays is limited and plant design does not allow for safely and reliably performing separate Master and Slave Relay Testing surveillances.
: 6. ISTS 3.3.2 ACTIONS H, K, and L are applicable to ISTS Table 3.3.2-1 Functions 5.a, 7.b, 7.c, 8.b, and 8.c. These Functions are not applicable to the design of KPS; therefore, the applicable ACTIONS have been deleted. The discussion for the reason each function is not applicable to KPS is found in other Justification For
 
Deviations.
: 7. ISTS SR 3.3.2.3 requires the performance of an ACTUATION LOGIC TEST every 31 days on a STAGGERED TEST BASIS. ISTS SR 3.3.2.3 also contains a NOTE that the continuity check may be excluded. ISTS SR 3.3.2.3 is applicable only to ISTS Table 3.3.2-1 Function 6.b, Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays. This test is curr ently not required at KPS. Since the design of the KPS ESFAS actuation logic is such that master and slave relays are employed and not a solid state protect ion system, ISTS SR 3.3.2.2 (ITS SR 3.3.2.2) is used to check the Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays. ISTS SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST every 92 days on a STAGGERED TEST BASIS. ISTS SR 3.3.2.2 does not contain the NOTE that the continuity check may be excluded. This testing Frequency is considered acceptable and is the same Frequency as relay testing for other ESFAS Functions. In addition, the Note is not needed for ITS


SR 3.3.2.2. Subsequent Surveillance Requirements have been renumbered, as
Kewaunee ITS Conversion Database                                                Page 2 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 63 of 76 Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 63 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3341 06/24/2010


necessary.
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 64 of 76 Licensee Response/NRC Response/NRC Question Closure Id 3401 NRC Question KAB-052 Number Select Application NRC Question Closure
: 8. ISTS Table 3.3.2-1 Functions 1.e.2 (Steam Line Pressure - High Differential Pressure Between Steam Lines), 1.f (High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low), 1.g (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 2.c (Containment Pressure High - 3 (High High)), 3.b.(1) (Phase B Isolation - Manual Initiation), 3.b.(2) (Phase B Isolation - Automatic Actuation Logic and Actuation Relays), 3.b.(3) (Containment Pressure High - 3 (High High)), 4.d.(1), (Steam Line Pressure Low),  4.d.(2), (Negative Rate - High), 4.e, (High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low), 4.f, (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 6.a, (Automatic Actuation Logic and Actuation Relays (Solid


State Protection System)), 6.e, (Auxiliary Feedwater Loss of Offsite Power), 6.h, (Auxiliary Feedwater Pump Suction transfer on Suction Pressure - Low), all Functions associated with Function 7 (Automatic Switchover to Containment Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary.
===Response===
Licensee Response/NRC Response/NRC Question Closure Id1621NRC Question Number KAB-045 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:47 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
p h p?re q uestT ype=areaItemPrint&itemId=1621 ITS NRC Questions Id1291NRC Question Number KAB-046 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5l6 JFD Bases Number  Page Number(s) 204 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 204 of Attachment 1, volume 8, SR 3.3.2.7 (r enumbered to SR 3.3.2.3) references justif ication for deviations (J FD) 5 and 6. However, JFD 5 discusses deletion of the master and slave relay SR and SR 3.3.2.3 is a TADOT. JFD 6 does not appear to be applicable to SR 3.3.2.3. Please provide a JFD reference that explains the change.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:40 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=1291 Licensee Response/NRC Response/NRC Question Closure Id1271NRC Question Number KAB-046 Select Application Licensee Response Response Date/Time 12/15/2009 2:30 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as neces sary."  The draft markup regarding this change is attached as part of the response to KAB-04 5 (since KAB-045 resulted in the same correction).
In addition, KPS has determined that the correct Justificat ion for Deviation (JFD) for the removal of the brackets should be JFD 1, not JFD 6. A draft Markup regarding this change is attached.
These changes will be reflect ed in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1 KAB-046 Markup.pdf (810KB) Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:34 PM Modified By Date Modified   Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
===Response===
p h p?re q uestT ype=areaItemPrint&itemId=1271 ESFAS Instrumentation 3.3.2  WOG STS 3.3.2-7 Rev. 3.0, 03/31/04 SURVEILLANCE REQUIREMENTS -------------------------------------------------------------NOTE----------------------------------------------------------
Statement Question Closure 6/7/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 6/7/2010 7:13 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 64 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3401                    06/24/2010
Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function. -------------------------------------------------------------------------------------------------------------------------------
SURVEILLANCE FREQUENCY SR  3.3.2.1 Perform CHANNEL CHECK.


12 hours SR  3.3.2.2 Perform ACTUATION LOGIC TEST.  
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 65 of 76 ITS NRC Questions Id 1361 NRC Question KAB-053 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 206 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 206 of Attachment 1, volume 8, the title steam line pressure for function 1.e references justifications for deviations (JFD) 8 in TS Table 3.3.2-1. However, JFD 8 discusses deleting functions not applicable to Kewaunee. Steam line pressure is applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:49 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 65 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1361      06/08/2010


92 days on a
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 66 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1331 NRC Question KAB-053 Number Select Licensee Response Application


STAGGERED TEST BASIS SR  3.3.2.3 ------------------------------NOTE-------------------------------  The continuity check may be excluded.  
===Response===
---------------------------------------------------------------------
12/17/2009 11:05 AM Date/Time Closure Statement Response  ITS Table 3.3.2-1 Function 1.e is applicable to KPS. However, the ISTS Statement includes two parts for this Function 1.e.(1) and 1.e.(2). The KPS ITS does not include Function 1.e.(2), High Differential Pressure Between Steam Lines Function. This ISTS Function has been deleted using JFD 8, as annotated on the same page. Since there are only 2 parts to Function 1.e, there was no reason to number the remaining part as 1.e.(1), and the remaining function, Steam Line Pressure - Low, has been numbered as just 1.e. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." While it is recognized that 1.e.(1) is not necessarily "subsequent" to the deleted 1.e.(2), JFD 8 was used to justify the renumbering of the (1) portion since they were both part of Function 1.e.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:08 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 66 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1331      06/09/2010


Perform ACTUATION LOGIC TEST.  
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 67 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1691 NRC Question KAB-053 Number Select Application NRC Question Closure


31 days on a
===Response===
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.


STAGGERED TEST BASIS
===Response===
  ----------------------------------REVIEWERS NOTE---------------------------------
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:07 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 67 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1691                    06/09/2010
The Frequency remains at 31 days on a STAGGERED TEST BASIS for plants with a Relay Protection System. -----------------------------------------------------------------------------------------------
SR  3.3.2.4 Perform MASTER RELAY TEST.  


92 days on a  
Kewaunee ITS Conversion Database                                                        Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 68 of 76 ITS NRC Questions Id 1371 NRC Question KAB-054 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 207-214 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 207 - 214 of Attachment 1, volume 8, functions 2.c, 3.a, 3.b, 3.c, 4.d, 4.e, 6.a, 6.b, 6.c, 6.d, 6.e, and 8 in TS Table 3.3.2-1 reference justification for deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. These functions are applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:50 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 68 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1371        06/08/2010


STAGGERED TEST BASIS SR  3.3.2.5 Perform COT.
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 69 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1341 NRC Question KAB-054 Number Select Licensee Response Application
184 days  SR  3.3.2.6 Perform SLAVE RELAY TEST.
[92] days SR  3.3.2.7 ------------------------------NOTE-------------------------------
Verification of relay setpoints not required.
---------------------------------------------------------------------  


Perform TADOT.  
===Response===
12/17/2009 11:10 AM Date/Time Closure Statement Response  JFD 8 describes the deletion of certain Functions from the ISTS Table Statement 3.3.2-1. These deletions resulted in the renumbering of the remaining Functions, including the ones listed in the question. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." Thus, JFD 8 was used to justify the renumbering of the Functions that are being maintained in the KPS ITS.
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:10 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 69 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1341    06/09/2010


[92] days CTS 4 3 Table TS 4.1-1, Channel Descriptions 7, 11.a, 11.b, 18.a, 18.b, 18.c Table TS 4.1-1, Channel Description 26, DOC M18 Table TS 4.1-1, Channel Descriptions 7, 11.a, 11.b, 18.a, 18.b, 18.c, and 35 DOC M14 4.1.a 7 5 5 5 5 All changes are unless otherwise noted 1 in accordance with the Setpoint Control Program 12 6 1 Licensee Response/NRC Response/NRC Question Closure Id1631NRC Question Number KAB-046 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:48 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee ITS Conversion Database                                                                     Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 70 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1701 NRC Question KAB-054 Number Select Application NRC Question Closure
p h p?re q uestT ype=areaItemPrint&itemId=1631 ITS NRC Questions Id1301NRC Question Number KAB-047 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number  Page Number(s) 205 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 205 of Attachment 1, volume 8, Surveillance Requirements 3.3.2.8, 3.3.2.9 and 3.3.2.11 (renumbered to SR 3.3.2.5, 3.3.2.6 and 3.3.2.7) reference justification fo r deviations (JFD) number 5. However, JFD 5 discusses deletion of master and slave relay testing. JFD 5 is not applicable to these SRs.
Please provide a JFD reference that explains the changes. Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:41 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=1301 Licensee Response/NRC Response/NRC Question Closure Id1281NRC Question Number KAB-047 Select Application Licensee Response Response Date/Time 12/15/2009 2:35 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as neces sary."  The draft markup regarding this change is attached as part of the response to KAB-04 5 (since KAB-045 resulted in the same correction). Thi s change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date  Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:37 PM Modified By Date Modified  Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
===Response===
p h p?re q uestT ype=areaItemPrint&itemId=1281 Licensee Response/NRC Response/NRC Question Closure Id1661NRC Question Number KAB-047 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:55 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
p h p?re q uestT ype=areaItemPrint&itemId=1661 ITS NRC Questions Id1311NRC Question Number KAB-048 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 6 JFD Bases Number  Page Number(s) 205 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 205 of Attachment 1, volume 8, Surveillance Requirements 3.3.2.8 and 3.3.2.9 (renumbered to SR 3.3.2.5 and 3.3.2.6) reference justification for deviations (JFD) number 6. JFD 6 is not applicable to these SRs. Please provide a JFD reference that explains the changes.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:43 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=1311 Licensee Response/NRC Response/NRC Question Closure Id1291NRC Question Number KAB-048 Select Application Licensee Response Response Date/Time 12/15/2009 2:40 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the correct Justification for Deviation (JFD) for the removal of the brackets in ISTS SR 3.3.2.8 and SR 3.3.2.9 (ITS SR 3.3.2.5 and SR 3.3.2.6, respectively) on At tachment 1, Volume 8, Page 205 of 517 should be JFD
: 1. A draft markup regardi ng 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-048 Markup.pdf (840KB) Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:39 PM Modified By Date Modified   Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
===Response===
p h p?re q uestT ype=areaItemPrint&itemId=1291 ESFAS Instrumentation 3.3.2  WOG STS 3.3.2-8 Rev. 3.0, 03/31/04 SURVEILLANCE REQUIREMENTS  (continued)
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:10 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 70 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1701                    06/09/2010
SURVEILLANCE FREQUENCY SR  3.3.2.8 ------------------------------NOTE-------------------------------
Verification of setpoint not required for manual initiation functions.  ---------------------------------------------------------------------


Perform TADOT.  
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 71 of 76 ITS NRC Questions Id 1381 NRC Question KAB-055 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 209-211 (s)
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 209, 210 and 211 of Attachment 1, volume 8, note b in TS Table 3.3.2-1 references justification for deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. These notes are not functions and the notes are applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:51 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 71 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1381    06/08/2010


[18] months
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 72 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1351 NRC Question KAB-055 Number Select Licensee Response Application


SR  3.3.2.9 ------------------------------NOTE-------------------------------
===Response===
This Surveillance shall include verification that the time constants are adjusted to the prescribed
12/17/2009 11:10 AM Date/Time Closure Statement Response  JFD 8 describes the deletion of certain Functions from the ISTS Table 3.3.2-Statement
: 1. These Functions include ISTS Table 3.3.2-1 Functions 4.d.(1), Steam Line Isolation, Steam Line Pressure - Low, and 4.f, Steam Line Isolation, High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure
              - Low. The Allowable Values and Nominal Trip Setpoints are part of the Functions, just like the Applicability, Required Channels, Conditions, and SRs. The Allowable Values and Nominal Trip Setpoint are modified by ISTS Table 3.3.2-1 footnote (b), which provides the lead/lag time constants for the Functions. JFD 8, in part, justifies deleting these two Functions, which would include the Allowable Values and Nominal Trip Setpoint, and the ISTS footnote (b) modification. Note that these two Functions are on pages 209 and 210, no ISTS footnote (b) was found on Page 211. However, ISTS Table 3.3.2-1 footnote (h), which is on page 211, has been renumbered to ITS Table 3.3.2-1 footnote (b) and the change is justified using JFD 8. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." Thus, JFD 8 was used to justify the renumbering of the footnote from (h) to (b).
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:12 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 72 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1351    06/09/2010


values. ---------------------------------------------------------------------  
Kewaunee ITS Conversion Database                                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 73 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1711 NRC Question KAB-055 Number Select Application NRC Question Closure


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


[18] months
===Response===
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:14 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 73 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1711                    06/09/2010


SR  3.3.2.10 ------------------------------NOTE-------------------------------  Not required to be performed for the turbine driven AFW pump until [24] hours after SG pressure is ---------------------------------------------------------------------
Kewaunee ITS Conversion Database                                                    Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 74 of 76 ITS NRC Questions Id 1391 NRC Question KAB-056 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 211 (s)
Verify ESFAS RESPONSE TIMES are within limit.  
NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N
Requested NRC Question    On page 211 of Attachment 1, volume 8, note d in TS Table 3.3.2-1 references justification for deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. This note is not a function and the note is applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:53 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 74 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1391    06/08/2010


[18] months on a STAGGERED TEST BASIS SR  3.3.2.11 ------------------------------NOTE-------------------------------
Kewaunee ITS Conversion Database                                                      Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 75 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1361 NRC Question KAB-056 Number Select Licensee Response Application
Verification of setpoint not required.  ---------------------------------------------------------------------  


Perform TADOT.  
===Response===
12/17/2009 11:10 AM Date/Time Closure Statement Response  JFD 8 describes the deletion of certain Functions from the ISTS Table Statement 3.3.2-1. These deletions resulted in the renumbering of the remaining Functions, as well as any footnotes deleted because they were a part of the Function. Thus, ITS Table 3.3.2-1 footnote (d) is actually ISTS Table 3.3.2-1 footnote (i). The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." Thus, JFD 8 was used to justify the renumbering of the footnote from (i) to (d).
Question Closure Date Attachment 1
Attachment 2
Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:13 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 75 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1361    06/09/2010


Once per reactor trip breaker cycle CTS 5 6 7 DOC M09 Table TS 4.1-1, Channel Descriptions 7, 11.a, 11.b, 18.a, 18.b, and 18.c DOC M17 5 5 5 All changes are unless otherwise noted 3 9 12 in accordance with the Setpoint Control Program 15 6 6 1 1 Licensee Response/NRC Response/NRC Question Closure Id1641NRC Question Number KAB-048 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:50 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
Kewaunee ITS Conversion Database                                                                     Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 76 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1721 NRC Question KAB-056 Number Select Application NRC Question Closure
p h p?re q uestT ype=areaItemPrint&itemId=1641 ITS NRC Questions Id1321NRC Question Number KAB-049 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 9 JFD Bases Number  Page Number(s) 218 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 218 of Attachment 1, volume 8, justification for deviations (JFD) 9 indicates ITS SR 3.3.2.6 applies to function 6.e. However, SR 3.3.2.6 is not listed in TS Table 3.
3.2.1 for function 6.e. Please correct or explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:44 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=1321 Licensee Response/NRC Response/NRC Question Closure Id1451NRC Question Number KAB-049 Select Application Licensee Response Response Date/Time 1/5/2010 8:20 AM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that Justification for Deviat ion (JFD) 9 does not appl y to ITS Table 3.3.2-1 Function 6.e. A draft markup regardi ng 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-049 Markup.pdf (392KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays


Ray Schiele Added By Robert Hanley Date Added 1/5/2010 8:23 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/09/2010 htt p://www.excelservices.com/rai/index.
===Response===
p h p?re q uestT ype=areaItemPrint&itemId=1451 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION  Kewaunee Power Station Page 4 of 5 Sump), 8.b, (Pressurizer Pressure, P
Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
-11), and 8.c, (Tavg  - Low Low, P
-12) have been deleted since they do not apply to the KPS design
. In addition, all applicable footnotes related to those Functions are also being deleted.
Subsequent Functions and footnotes have been renumbered as applicable.
: 9. A Note to ISTS SR 3.3.2.9 (ITS SR 3.3.2.
: 6) requires the CHANNEL CALIBRATION to include verification that time constants are adjusted to the prescribed values. In the KPS ITS, this Surveillance (ITS SR 3.3.2.
: 6) applies to ITS Table 3.3.2
-1, Functions 1.c, 1.d, 1.e, 2.c, 4.c, 4.d, 4.e, 5.b, 6.b, 6.d, 6.e, and 7.b.
Of these Functions, the only one that has a time constant is ITS Table 3.3.2
-1 Functions 1.e, and the time constants are included in a Note to the Allowable Value. Thus, the time constant is part of the Allowable Value for this function. The definition of CHANNEL CALIBRATION states that it 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. Thus the CHANNEL CALIBRATION of this Function requires the time constant be set properly. It is not necessary to include a Note that also says that the CHANNEL CALIBRATION Surveillance includes the time constants; it already does. Including this note in this Surveillance would incorrectly imply that a CHANNEL CALIBRATION does not require certain Allowable Values (i.e., time constant type Allowable Values) to be verified during the CHANNEL CALIBRATION. In addition, the Allowable Values for the KPS ITS will be removed from the ITS and retained in a licensee-controlled Setpoint Control Program. Therefore, the Note is not included in the KPS ITS.
: 10. The Nominal Trip Setpoint column has been deleted as allowed by the Reviewer's Note at the end of the ISTS Table 3.3.2
-1. This Reviewer's Note allows specific unit implementation to contain only the Allowable Value. The nominal trip setpoints for each of the applicable ITS Table 3.3.2
-1 Functions will be controlled in accordance with the Note in the ISTS 3.3.2 Bases Background section.
: 11. ISTS Table 3.3.2
-1 (ITS Table 3.3.2
-1) Function 8 (Reactor Trip, P
-4 Interlock) has been revised by deleting the term "2 trains."  This information is Bases type information and has been included in the ITS Bases.
: 12. Changes are made to the ISTS that reflect the adoption of proposed Revision 4 of TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions".
Three options are provided for licensees to pursue when adopting TSTF
-493. KPS has elected to implement TSTF
-493 via the use of a Setpoint Control Program. Under this adoption strategy, KPS relocates the Technical Specification Section 3.3, "Instrumentation," Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Values from the Technical Specifications to a licensee
-controlled Setpoint Control Program. The requirements for the Setpoint Control Program will be described in Chapter 5, "Administrative Controls," of the Technical Specifications. Hence the deletion of the "ALLOWABLE VALUE" and "NOMINAL TRIP SETPOINT" columns from Table 3.3.2
-1 of the ITS. Included in the relocation to the licensee-controlled Setpoint Control Program is all information contained within any associated footnotes that tie to numerical values in the Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Value columns. In addition, the adoption strategy requires that each instrument surveillance requirement which verifies a LSSS (both SL and non-SL-LSSSs) contain a Licensee Response/NRC Response/NRC Question Closure Id1651NRC Question Number KAB-049 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:53 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=1651 ITS NRC Questions Id1331NRC Question Number KAB-050 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number JFD Bases Number  Page Number(s) 205 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 205 of Attachment 1, volume 8, surveillance requirement 3.3.2.8 (renumbered to SR 3.3.2.5) does not show a change that would be consistent with the adoption of TSTF-493. TSTF-493 would add the statement in accordance with the setpoint control pr ogram to SR 3.3.2.5.
Please provide a new JFD referenc e that explains the change.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:45 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=1331 Licensee Response/NRC Response/NRC Question Closure Id1311NRC Question Number KAB-050 Select Application Licensee Response Response Date/Time 12/17/2009 11:00 AM Closure Statement Response Statement TSTF-493, Rev. 4, Option B includes the statement concer ning the setpoint control program for ISTS SR 3.3.2.8. This SR is a TADOT, and applies to all the manual initiation functions as well as the AFW trip of all main feedwater pumps function. In the IS TS, this function includes setpoints. However, for the KPS design, this trip is actuated by breaker position switches, not a pressure sensor. The Note for ISTS SR 3.3.2.8 (ITS SR 3.3.2.5) specifically states that verification of setpoints ar e not required for the manual initiation functions. Since there are no setpoints for th e KPS design, and the definition of TADOT in Se ction 1.1 (Volume 3, pa ge 38) states that it includes an adjustment only as necessa ry, setpoint verification would also not be required. Therefore, the addition of the requirement from TSTF-493, Rev. 4 concerning the setpoint control program is not needed. KPS does not believe that a JFD is ne cessary to state that a small piece of TSTF-493, which is not approved yet by the NRC, is not be ing adopted. KPS believes that this response, in addition to th e actual KPS design fo r the function as described in the ITS Bases (page 263), provides proper documentation as to why this part of TSTF-493 is not being adopted.
Question Closure Date  Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:04 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=1311 Licensee Response/NRC Response/NRC Question Closure Id1671NRC Question Number KAB-050 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:59 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=1671 ITS NRC Questions Id1341NRC Question Number KAB-051 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number  Page Number(s) 206-214 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 206-214 of  , volume 8, TS Table 3.3.
2-1 functions 1.a, 1.c, 1.d, 1.e.1, 2.a, 2.
c, 3.a, 4.a, 4.c, 4.d, 4.e, 5.b, 6.b, 6.d, 6.e, and 8 reference justification for deviations (JFD) numb er 5. However, JFD 5 discusses deletion of master and slave relay testing. JFD 5 is not applicable to these SRs.
Please provide a JFD reference that explains the changes. Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:46 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=1341 Licensee Response/NRC Response/NRC Question Closure Id1321NRC Question Number KAB-051 Select Application Licensee Response Response Date/Time 12/17/2009 11:05 AM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.
Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as neces sary."  The draft markup regarding this change is attached as part of the response to KAB-04 5 (since KAB-045 resulted in the same correction). Thi s change will be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date  Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:06 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=1321 Licensee Response/NRC Response/NRC Question Closure Id1681NRC Question Number KAB-051 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:01 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=1681 ITS NRC Questions Id1351NRC Question Number KAB-052 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5l8 JFD Bases Number  Page Number(s) 215 and 424 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 215 and 424 of Attachment 1, volume 8, justifications for deviations 5 and 8 discuss deletion of master and slave relay testing.
Please provide a list stating which functions have master relays and which functions have slave rela ys. Include in your response the current master and slave relay surveillance testing frequency for each function and which surveillance tests apply i.e., f unctional check, calibrate or test.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified  Modified By Date Added 12/14/2009 2:48 PM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=1351 Licensee Response/NRC Response/NRC Question Closure Id1391NRC Question Number KAB-052 Select Application Licensee Response Response Date/Time 12/22/2009 3:10 PM Closure Statement Response Statement Table 3.3.2-1, Functions 5a, 6a, and 7 have master and slave relays but do not require master and slave rel ay testing in NUREG-1431 for ITS, therefore they are not included below.
The following Functions have Master and/or Slave relays that will be checked by the Actuation Logic Test (ALT) every 92 days on a staggered test basis in ITS (SP-55-155):  Table 3.3.2-1 Function 1.b Table 3.3.2-1 Function 2.b Table 3.3.2-1 Function 3.b Table 3.3.2-1 Function 4.b Table 3.3.6-1 Function 1 Table 3.3.6-1 Function 2.a (ALT is SI logic portion)
Table 3.3.6-1 Function 2.b (ALT is SI logic portion)
There are some Master and/or Slave relays that are "blo cked" during the ALT to prevent them from operating at inopportun e times. Most of these blocked relays are tested for continuity during the ALT by passing enough current to light a bulb, but not enough current to actually pick up the relay. The following Functions contain some relays that do not operate during the ALT but are checked by other surveillances:
Table 3.3.2-1 Function 1.b Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.2-1 Function 2.b Slave checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.2-1 Function 3.b Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.2-1 Function 4.b Slaves checked by Valve Timing Test every 18 months (SP-55-167-6A)
Table 3.3.2-1 Function 5.a Masters & Slaves checked by FRV Timing Test every 18 months (SP-05A-202)
Table 3.3.6-1 Function 1 Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)
Table 3.3.6-1 Function 2.a Slaves (SP-45-49.12)
R12 Quarterly Test cycle Master and Slave Table 3.3.6-1 Function 2.b Slaves (SP-45-49-11) R11 Quart erly Test cycle Master Pa ge 1of 2 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=1391 and Slave Question Closure Date Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/22/2009 3:16 PM Modified By Date Modified  Pa ge 2of 2 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=1391 Licensee Response/NRC Response/NRC Question Closure Id3231NRC Question Number KAB-052 Select Application NRC Response Response Date/Time 5/26/2010 6:00 PM Closure Statement Response Statement In ITS TS 3.3.2, Table 3.3.2-1, Function 5a, "Feedw ater Isolation Automatic Actuation Logic and Actuation Relays," Function 6a, "Auxiliary Feedwater Automatic Actuation Logic and Actu ation Relays," and Function 7.a, "Turbine Building Service Water Header Isolation Automatic Actuation Logic and Actuation Relays," require SR 3.3.2.2 (Attachment 1 Volume 8, pages 212 and 213 of 517).
Please clarify the quoted statement, in the response to RAI KAB-052, as to why the master and slave relays of ITS TS 3.3.2 Table 3.3.2-1, Functions 5a, 6a, and 7a do not require testing. If these master and slave relays are not tested by SR 3.3.2.2 or other TS 3.3.2 surveillances, how is operability of the relays determined?
Question Closure Date Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 5/26/2010 11:18 AM Modified By Date Modified  Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=3231 Licensee Response/NRC Response/NRC Question Closure Id3341NRC Question Number KAB-052 Select Application Licensee Response Response Date/Time 5/28/2010 10:15 AM Closure Statement Response Statement KAB-052, Second Response The paragraph being quoted in the KAB-052 NRC response of 5/26/2010 is referencing the first paragraph of the original KPS response to KAB-052.
This paragraph, which was inadvertently included in the KPS response, should not have been incl uded as this paragraph was informational and related to the ISTS Table Functions (it was informati on provided to internal KPS reviewers).
KPS ITS Functions 5.a and 6.a do have Master and Slave Relays. Function 5.a was described in the previous response, but for completeness, the information is also provided in this response.
KPS ITS Function 5a Master and Slave Relays are checked by the Feed Regulating Valve Timing Test every 18 months (procedure SP-05A-202).
KPS ITS Function 6a Master and Slave Relays are checked at power (i.e. online) by Reactor Protection Logic test (procedures SP-47-062A/B) and


during shutdown conditions by Reac tor Protection Logic test (procedures SP-47-062G/H/I).
===Response===
KPS ITS Function 7a does not have a typical Master/Slave Relay design, therefore a specific Master or Slave Relay test is not required for this Function. However, the design that do es exist is a singl e contact matrix that is tested by SR 3.3.2.2 (as required by the ITS).
Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:15 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 76 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1721                    06/09/2010}}
Question Closure Date Attachment 1  Attachment 2  Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Kristy Bucholtz Added By Charles Smoker Date Added 5/28/2010 10:12 AM Pa ge 1of 2 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=3341 Modified By Date Modified  Pa ge 2of 2 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=3341 Licensee Response/NRC Response/NRC Question Closure Id3401NRC Question Number KAB-052 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 6/7/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 6/7/2010 7:13 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/24/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=3401 ITS NRC Questions Id1361NRC Question Number KAB-053 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number  Page Number(s) 206 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 206 of Attachment 1, volume 8, the title "steam line pressure" for function 1.e referen ces justifications for deviations (JFD) 8 in TS Table 3.3.2-1. However, JFD 8 discusses deleting functions not applicable to Kewaunee. Steam line pressure is applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:49 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=1361 Licensee Response/NRC Response/NRC Question Closure Id1331NRC Question Number KAB-053 Select Application Licensee Response Response Date/Time 12/17/2009 11:05 AM Closure Statement Response Statement ITS Table 3.3.2-1 Function 1.e is applicable to KPS. However, the ISTS includes two parts for this Function 1.e.(1) and 1.e.(2). The KPS ITS does not include Function 1.e.(2), High Differential Pressure Between Steam Lines Function. This ISTS Function has been de leted using JFD 8, as annotated on the same page. Since there are only 2 parts to Fun ction 1.e, there was no reason to number the rema ining part as 1.e.(1), and the remaining function, Steam Line Pressure - Low, ha s been numbered as just 1.e. The last sentence of JFD 8 states "Subsequen t Functions and footnotes have been renumbered as applicable."  While it is recognized that 1.e.(1) is not necessarily "subsequent" to the de leted 1.e.(2), JFD 8 was used to justify the renumbe ring of the (1) portion since they were both part of Function 1.e.
Question Closure Date  Attachment 1   Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:08 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=1331 Licensee Response/NRC Response/NRC Question Closure Id1691NRC Question Number KAB-053 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:07 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=1691 ITS NRC Questions Id1371NRC Question Number KAB-054 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number  Page Number(s) 207-214 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 207 - 214 of Attachment 1, volume 8, f unctions 2.c, 3.a, 3.b, 3.c, 4.d, 4.e, 6.a, 6.b, 6.c, 6.d, 6.e, and 8 in TS Table 3.3.2-1 reference justification for deviations (JFD) number 8. However , JFD 8 discusses deleting functions not applicable to Kewaunee. These functions are applicable to Kewaunee. Pl ease explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:50 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=1371 Licensee Response/NRC Response/NRC Question Closure Id1341NRC Question Number KAB-054 Select Application Licensee Response Response Date/Time 12/17/2009 11:10 AM Closure Statement Response Statement JFD 8 describes the deletion of certa in Functions from the ISTS Table 3.3.2-1. These deletions resulted in the renumbering of the remaining Functions, including the ones listed in the question. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable."  Thus, JFD 8 was used to justify the renumbering of the Functions that are being ma intained in the KPS ITS.
Question Closure Date Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:10 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=1341 Licensee Response/NRC Response/NRC Question Closure Id1701NRC Question Number KAB-054 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:10 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=1701 ITS NRC Questions Id1381NRC Question Number KAB-055 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number  Page Number(s) 209-211 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 209, 210 and 211 of Attachment 1, vo lume 8, note b in TS Table 3.3.2-1 references justification for de viations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. These notes are not functions and the notes are applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:51 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=1381 Licensee Response/NRC Response/NRC Question Closure Id1351NRC Question Number KAB-055 Select Application Licensee Response Response Date/Time 12/17/2009 11:10 AM Closure Statement Response Statement JFD 8 describes the deletion of certain Functions from th e ISTS Table 3.3.2-
: 1. These Functions incl ude ISTS Table 3.3.2-1 F unctions 4.d.(1), Steam Line Isolation, Steam Li ne Pressure - Low, and 4.f, Steam Line Isolation, High Steam Flow in Two St eam Lines Coincident with Steam Line Pressure - Low. The Allowable Valu es and Nominal Trip Set points are part of the Functions, just like the Applicability, Required Channels , Conditions, and SRs. The Allowable Values and Nominal Trip Setpoint are modified by ISTS Table 3.3.2-1 footnote (b), which provides the lead/l ag time constants for the Functions. JFD 8, in part, justifies deleting these two Functions, which would include the Allowable Values a nd Nominal Trip Se tpoint, and the ISTS footnote (b) modifi cation. Note that the se two Functions are on pages 209 and 210, no ISTS footnote (b) was found on Page 211. However, ISTS Table 3.3.2-1 footnote (h), which is on page 211, has been renumbered to ITS Table 3.3.2-1 footnote (b) and the change is just ified using JFD 8. The last sentence of JFD 8 states "Subse quent Functions an d footnotes have been renumbered as applicable."  Thus, JFD 8 was used to justify the renumbering of the footnote from (h) to (b).
Question Closure Date  Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:12 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=1351 Licensee Response/NRC Response/NRC Question Closure Id1711NRC Question Number KAB-055 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:14 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=1711 ITS NRC Questions Id1391NRC Question Number KAB-056 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number  Page Number(s) 211 NRC Reviewer Supervisor Gerald Waig Technical Branch POC Add Name Conf Call Requested N NRC Question On page 211 of Attachment 1, volume 8, note d in TS Table 3.3.2-1 references justification fo r deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee.
This note is not a function and the note is applicable to Kewaunee. Please explain this discrepancy.
Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:53 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=1391 Licensee Response/NRC Response/NRC Question Closure Id1361NRC Question Number KAB-056 Select Application Licensee Response Response Date/Time 12/17/2009 11:10 AM Closure Statement Response Statement JFD 8 describes the deletion of certa in Functions from the ISTS Table 3.3.2-1. These deletions resulted in the renumbering of the remaining Functions, as well as any footnotes de leted because they were a part of the Function. Thus, ITS Table 3.3.2-1 footnote (d) is actually ISTS Table 3.3.2-1 footnote (i). The last sentence of JFD 8 states "Subsequent Functions and footnotes ha ve been renumbered as applicable."  Thus, JFD 8 was used to justify the renumbering of the footnote from (i) to (d).
Question Closure Date Attachment 1  Attachment 2  Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:13 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=1361 Licensee Response/NRC Response/NRC Question Closure Id1721NRC Question Number KAB-056 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 1/12/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:15 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=1721}}

Revision as of 15:06, 13 November 2019

Enclosure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3)
ML102371260
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 08/18/2010
From:
Dominion Energy Kewaunee
To:
Office of Nuclear Reactor Regulation
References
10-457, TAC ME2139
Download: ML102371260 (76)
v • d • e


Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 1 of 76 ITS NRC Questions Id 1221 NRC Question KAB-040 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 122 (s)

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

Requested NRC Question On page 122 of Attachment 1, volume 8, the reviewers note states if WCAP-14333 and WCAP-15376 are being adopted then the bracketed sentence in the above paragraph must be replaced with the information in the reviewers note. Both WCAP-14333 and WCAP-15376 are being incorporated into ITS. Please replace the sentence in the ITS Bases with the information in the reviewers note or provide an explanation of the discrepancy.

Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:49 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 1 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1221 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 2 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1181 NRC Question KAB-040 Number Select Licensee Response Application

Response

12/4/2009 11:30 AM Date/Time Closure Statement Response Kewaunee Power Station (KPS) has incorporated WCAP-14333 and WCAP-Statement 15376 into the ITS submittal. However, the Reviewer's Note is in error.

While the Note states that the words in the Reviewer's Note should replace the bracketed words above the Reviewer's Note if the two WCAPs are incorporated, it should have stated that the words are to be replaced if the two WCAPs are not incorporated. WCAP-15376 changed the test time for the RTBs from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. WCAP-10271 supports the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> RTB test time. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> RTB test time allowed by WCAP-15376 was added to the NUREG-1431 (the ISTS) as part of TSTF-411. Furthermore, the ISTS 3.3.1 Bases Actions P.1 and P.2 Reviewer's Note, which provide the description of the action for inoperable RTBs, clearly states that the RTB test time is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when WCAP-15376 is adopted. Therefore, based on the above, the proposed words referencing a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> RTB test time in ITS 3.3.1 Bases Actions N.1 and N.2 (ISTS 3.3.1 Bases Action O.1 and O.2) are correct. However, it was noted that the JFD referenced for the change should have been 9, not 8. Thus, JFD 9 has been modified to identify the typographical error related to the Reviewer's Note. Furthermore, the first sentence of the ITS 3.3.1 Bases Actions N.1 and N.2 also references that the Action is applicable to the SI Input from ESFAS reactor trip. This is not correct since the SI Input from ESFAS reactor trip Function is not included in the KPS ITS. A draft markup regarding these changes is attached.

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

Question Closure Date Attachment KAB-040 Markup.pdf (882KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/4/2009 11:30 AM Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 2 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1181 06/09/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 3 of 76 Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 3 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1181 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 4 of 76 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES ACTIONS (continued)

[ The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing of the other channels. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 8. ]

REVIEWERS NOTE----------------------------------- 5 The below text should be used for plants with installed bypass test capability:

The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 8.

N O.1 and O.2 5 N P Condition O applies to the SI Input from ESFAS reactor trip and the RTS 5 P Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these Functions. With one train inoperable, N

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status (Required Action O.1) or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. N 5

The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Required Action O.1) is reasonable 5 considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of P

an event during this interval. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed to restore the inoperable RTS Automatic Trip Logic train to OPERABLE status is justified in Reference 8. The Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (Required N

Action O.2) is reasonable, based on operating experience, to reach 5 MODE 3 from full power in an orderly manner and without challenging unit systems.

The Required Actions have been modified by a Note that allows bypassing one train up to [4] hours for surveillance testing, provided the P 5 other train is OPERABLE. [The [4] hour time limit for testing the RTS 8

Automatic Trip logic train may include testing the RTB also, if both the Logic test and RTB test are conducted within the [4] hour time limit. The

[4] hour time limit is justified in Reference 8.] 9

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

The below text should replace the bracketed information in the previous paragraph if WCAP-14333 and WCAP-15376 are being incorporated: 8 The [4] hour time limit for the RTS Automatic Trip Logic train testing is greater than the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time limit for the RTBs, which the logic train WOG STS B 3.3.1-44 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 4 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 5 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1 BASES, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. Changes are made to the ISTS Bases that reflect the adoption of proposed Revision 4 of TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions".

Three options are provided for licensees to pursue when adopting TSTF-493.

Kewaunee Power Station (KPS) has elected to implement TSTF-493 via the use of a Setpoint Control Program. Under this adoption strategy, KPS relocates the Technical Specification Section 3.3, "Instrumentation," Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Values from the Technical Specifications to a licensee-controlled Setpoint Control Program. The requirements for the Setpoint Control Program will be described in Chapter 5, "Administrative Controls," of the Technical Specifications.

3. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.
4. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.
5. Changes are made to reflect changes made to the Specifications.
6. Typographical error corrected.
7. The Reviewer's Note has been deleted. The information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.
8. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. Required Actions for Conditions D, E, and K are modified by a Note that provides two options for bypassing a channel for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of performing surveillance testing without requiring entry into the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for plants that do not have installed bypass testing capabilities. KPS does not have installed bypass testing capabilities.

Therefore, the Note for plants that do not have bypass testing capabilities is retained for Condition D, E, and K.

9. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design. Also, the Reviewer's Note has been deleted. The information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal. Furthermore, the bracketed value and the Reviewer's Note allows options dependent upon if the plant is incorporating WCAP-14333 and WCAP-15376. Since KPS is incorporating both of the WCAPs, the correct section has been selected. In addition, it should be noted that the Reviewer's Note for ISTS 3.3.1 Actions O.1 and O.2 should have stated that the alternate wording is required if WCAP-14333 and WCAP-15376 are not adopted, not if they are adopted.

WCAP-15376 justified a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> RTB test time.

Kewaunee Power Station Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 5 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 6 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1431 NRC Question KAB-040 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/4/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/4/2010 3:21 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 6 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1431 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 7 of 76 ITS NRC Questions Id 1231 NRC Question KAB-041 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 133, 135, 137, 138 (s)

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

Requested NRC Question On pages 133, 135, 137 and 138 of Attachment 1, volume 8, inserts 5, 6, 7, 8 and 9 are not consistent with TSTF-493.

TSTF-493 adds new paragraphs to STS NUREG-1431. The new paragraphs have not been added to Kewaunees ITS Bases for 3.3.1.7, 3.3.1.8, 3.3.1.10, 3.3.1.11 and 3.3.1.12. Please add the paragraphs to the ITS Bases or provide an explanation for the change.

Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:50 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 7 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1231 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 8 of 76 Licensee Response/NRC Response/NRC Question Closure Id 951 NRC Question KAB-041 Number Select Licensee Response Application

Response

11/30/2009 3:30 PM Date/Time Closure Statement Response Kewaunee Power Station (KPS) has reviewed proposed TSTF-493 Rev. 4 Statement and concurs with the assessment that INSERTS 5, 6, 7, 8, and 9 need to be changed to reflect the current version of TSTF-493 Rev.4. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Please note that TSTF-493 Rev. 4 was not an approved traveler at the time of the KPS submittal and that the KPS submittal was marked up to the draft version of TSTF-493 sent to the NRC in July of 2009.

Question Closure Date Attachment 1 KAB-041 Markup.pdf (1MB)

Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 11/30/2009 3:31 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 8 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=951 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 9 of 76 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

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

INSERT 5 2 A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

INSERT 5 2 Setpoints must be within the Allowable Values specified in Table 3.3.1-1. 2 The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the 2 setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The "as found" and "as left" values must also be recorded and reviewed 2

for consistency with the assumptions of Reference 9.

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

The Frequency of 184 days is justified in Reference 9.

WOG STS B 3.3.1-54 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 9 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 10 of 76 B 3.3.1 2

INSERT 5 COT must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the COT.

The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.

The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

Insert Page B 3.3.1-54 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 10 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 11 of 76 B 3.3.1 2

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

The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.

The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

Insert Page B 3.3.1-55 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 11 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 12 of 76 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT and is performed every 4

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

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

SR 3.3.1.10 A CHANNEL CALIBRATION is performed every [18] months, or 4 approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. INSERT 7 CHANNEL CALIBRATIONS must be performed consistent with the 2 assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" 2 values must be consistent with the drift allowance used in the setpoint methodology.

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

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values 5 where applicable.

WOG STS B 3.3.1-56 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 12 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 13 of 76 B 3.3.1 2

INSERT 7 in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.

The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.

The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

Insert Page B 3.3.1-56 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 13 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 14 of 76 All changes are 1 RTS Instrumentation unless otherwise noted P B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.11 INSERT 8 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10, every [18] months. This SR is modified by a 4 Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range 2 INSERT 8 neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The

[18] month Frequency is based on the need to perform this Surveillance 4 under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed on the [18] month 4 Frequency.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as ¶ INSERT 9 described in SR 3.3.1.10, every [18] months. This SR is modified by a 4 2 Note stating that this test shall include verification of the RCS resistance temperature detector (RTD) bypass loop flow rate. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

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

The Frequency is justified by the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.

WOG STS B 3.3.1-57 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 14 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 15 of 76 B 3.3.1 2

INSERT 8 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.

2 INSERT 9 CHANNEL CALIBRATIONS must be performed in accordance with the assumptions of the unit specific setpoint methodology specified in the SCP to ensure instrument channel OPERABILITY between periodic testing required by the CHANNEL CALIBRATION.

The test is performed in accordance with the SCP. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE but degraded.

The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the NTSP (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

Insert Page B 3.3.1-57 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 15 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 16 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1491 NRC Question KAB-041 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/5/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/5/2010 8:48 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 16 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1491 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 17 of 76 ITS NRC Questions Id 1241 NRC Question KAB-042 Number Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number 129 (s)

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

Requested NRC Question On page 129 of Attachment 1, volume 8, there is a reviewers note that states, A plant specific evaluation based on the guidance in Westinghouse Technical Bulletin ESBU-TB-92-14 is required to determine the power below which power range channel adjustments in a decreasing power direction become a concern. Please provide Kewaunees evaluation based on the technical bulletin (including when the power range channel adjustments become a concern and if additional administrative controls are required for power range neutron flux-high trip setpoint setting changes).

Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:52 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 17 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1241 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 18 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1201 NRC Question KAB-042 Number Select Licensee Response Application

Response

12/7/2009 3:40 PM Date/Time Closure Statement Response Westinghouse Technical Bulletin ESBU-TB-92-14 was evaluated by KPS under Statement Operating Experience Assessment (OEA)96-029. A summary of that evaluation is attached.

In regard to low power gain adjustments, if a calorimetric is performed at < 70%

RTP, the power range neutron high flux setpoint is lowered to less than or equal to 85%. A calorimetric must be performed at a higher power level (typically 75%

RTP) before the power range neutron high flux setpoint can be raised to the normal value of 105%.

Guidance is contained in SP-48-002, Nuclear Power Range Channel Gain Adjustment as follows:

Precaution Step 2.6, When Reactor Power is less than 75% power, NI gain adjustments are NOT required, unless more than 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of operation will occur at this power level.

Procedure Step 6.1, IF Reactor Power is less than 70%, THEN REDUCE NI High Flux Trips to less than or equal to 85% power.

Procedure Step 6.10, IF NI High Flux Trips were reduced to less than or equal to 85% AND NI gain adjustment is verified acceptable, THEN RESET NI High Flux Trips to normal power.

Question Closure Date Attachment 1 KAB-042 OEA-96-029-Summary.pdf (135KB)

Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/7/2009 3:40 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 18 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1201 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 19 of 76 FORM SSEP-Ol-2 SSEP-ol January 31, 1994 OPERATING EXPERIENCE ASSESSMENT TECHNICAL BVALUATION Page 13 of 18

-, ~&.--T--

OEANO.: 96-029 ,REPORT: WTB92-14-Rl,OE7771/uJo<:,,,"-OlSiIDATE: OS/22/96 CROSS REFERENCE OEAs: 93-036

SUBJECT:

Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70% RTP; Logarithmic Power Nuclear Instrumentation Calibration Problems - Waterford 3 SAFETY OR RELIABIUTY SIGNIFICANCE:

SEE ATTACHMENT RECOM1\mNDED ACTION(S):

DEPARTMENT NO. DEPARTMENT RECOMMENDATION HEAD~IALS 1 Operations Revise SP 48-002 to require the NI High Flux Trips be reduced to 85 %

power if the adjustment is done at less than or equal to 70% power.

BVALUATED BY: DATE: /0 )/'-1/91 REvmWEDBY~~e ~

Plant Operations Assessment Supervisor APPROVED 'BY -~/l/)_J1-..:....._ _- _ - - - D A T E : --.-._

(SOERs only) Plant Manager Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 19 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 20 of 76 FORM SSEP-Ol-3 SSEP-Ol January 31. 1994 OPERATING EXPERIENCE ASSESSMENT REVIEW Page 14 of 18 OEANO.;96-029 IREPORT: WTB 92-14-Rl, OE 777~ u.'6&~'t' -o;} ~fhATE: /D /2-~ /~., ..,.

CROSS REFERENCE OEAs: 93-036

SUBJECT:

Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70% RTP; Logarithmic Power Nuclear Instrumentation calibration Problems - Waterford 3 DISTRIBUTION:

o Plant Management o Corporate Management

ft( Operations /'1.1'1 /(w, 1-c~ 0 Maintenance o SecurityIFire/Safety o Instrument & Control o Maintenance Training ~ Operations Training S1 !5v--o 40CJ ~

o General Employee Development o Licensing & Systems o Project Management o Radiochemistry o Quality Assurance o Warehouse/Info*& Sche4ule o Nuclear Computer Systems o Other o Radiation ProteCtion ~ Plant Quality Program 6 $ !2~ .. k ;tv""

o Chem/Rad Technologist Tmg. o Tech Staff/Management Tmg.

o Safety System Engineering o Plant Personnel o Nuclear Fuels D NSRAC o Nuclear Projects o Nuclear Engineering Control o NBS Drawing Control o NBS Mechanical Engineering o NBS Electrical Engineering o NBS I&C Engineering o NBS Design/Field Services o Nuclear Health Physicist ISSUED

1. 0 The attached evaluation is for your information only and no action is required. If you have comments you wish to include in our file, pl~se attach them to this cover sheet and return to the Plant Operations Assessment Supervisor.
2. 0 When recommended actions have been completed, please complete Item 3 on the original Form SSEP..ol-4 kept in the OEA files and return to the Plant Operations Assessment Supervisor" 3.)2f{ This OBA for the above listed report(s) is closed out.

~~:y~

r :Operations Assessment Supervisor Date Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 20 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 21 of 76 FO~SSEP~14 SSEP~l January 31, 1994 OPERATING EXPERIENCE ASSESSMENT RECOMMENDATION STATUS Page 15 of 18 OEANO.: 96-029 IREPORT: WTB 92-14-Rl, OE TI71,l>>oG *'7 o"1M

-tDATB: ~/~J~?

...

CROSS REFERENCE OEAs: 93-036

SUBJECT:

Decalibration Effects of Calorimetric Power Measurements on the Nuclear Instrumentation Systems High Power Reactor Trip at Power Levels Less Than 70% RTP; Logarithmic Power Nuclear Insttumentation Calibration Problems - Waterford 3 1.. Recommendation No. __l_ _ of __1~_ Responsible Department _O~pe~r...AoC.ata..LIioIlo.oLLD~S:.....-... _

Revise SP 48-002 to require the NI High Flux Trips be reduced to 85 % power if the adjustment is done at less than or equal to 70% power.

~-~- PLANT OPERAnONS ASSESSMENT SUPERVISOR L

2. Action to be taken:

A6 pl£l1.. -A~~1l' tsI,~,~

Estimated Completion Date tJ~'Se.~l~ ~ . .------:>

d~~~. lot n l9 J DEPARTMENT HEAD/DATE 3.. Recommended Action Implemented SI' o/y"DO<" {;U-.s re.tJist!.J ffM-J 55~.,A /llzs/'l? 4.5 ;(e.<lJ"S;IJ... t; S+e..f tI,1 -A'",c/. tlt l .! fe~.. c.t. .rl,.. s~lj?o, .... t- +0 ~.s""~ .:.t -JI.. .....

,(I,IjLf.s+..... c ..t y ; os d'JJt,.~ (/1+ ?~~ 1'~1Mt., t#r Ie.ss.

Qf3 fL{JJJ.M- (or KH~() I-I 3 M qq DEPARTMENT HEAD/DATE

4. Recommendation Action Complied With ." /;/s&

~LANT OPERATIONS ASSESSMENT §UPV/DATE

5. Completed SOER Recommendation PLANT MANAGER/DATE Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 21 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 22 of 76 OEA96-o29 A. SAFETY OR RELIABILITY SIGNIFICANCE:

This Westinghouse Technical Bulletin discusses the potential to decalibrate the NIs at low power levels due to errors in the calorimetric. Decalibration of the NIs due to flux shift and low leakage cores was addressed by OBA 93-036 and IR 93-115 (LER 93-014).

Recommendations 1, 2, and 3 of this Tech. Bulletin are already being implemented at Kewaunee. Procedures SP 87-125 and SP 48-002 ensure the NIs are normalized to a calorimetric. Procedures RXT-6 and SPs 48-Q04A,B,C&D ensure the High Power trip is reduced to 80 % following a refueling outage and that the trip setpoint reduction is conservative. Procedure RXT-6 ensures the NIs are renormalized at successively higher power levels (2S, 40, 7S, 90, and 100%)..

KNPP bas chosen to address the concerns covered by Recommendations 4, 5, and 6 differently than descn'bed in the Tech Bulletin.

In Recommendation 4 Westinghouse suggests correcting the NIB by use of a gain adjust anytime they indicate less than the calorimetric. We will typically do this when the difference exceeds 1 % and power is greater than 75%. Jf power is less than 75% due to a backdown or return to power from a plant trip and the plant will remain at that power level less than 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, no adjustment will be made. This is justified because the NlS hAs been previously adjusted for 100%

operation and the plant will be returning to that power level in a relatively short period of time. If an adjustment were to be made, it would likely have to be undone when power is increased.

In Recommendation 5 Westinghouse suggests that when power level is greater than 70% and the NIS indicate higher than the calorimetric, a gain adjust is not necessary. For cases where the plant is in a transient, the plant guidance described in Recommendation 4 is implemented. If the plant is operating at steady state power and the NIS indicates 1 % or greater than the calorimetric~ they will be adjusted. 'This is necessary to account for the changes in leakage due to core bumup.

In Recommendation 6 Westinghouse suggests that when power level is less than 70% power and the NIS indicate higher than the calorimetric, no adjustment should be made. As stated in the previous two recommendations~ if the plant is in a transient state, this guidance is followed. However ~ if the plant will remain at a power level greater than 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, an adjustment must be made to meet Tech Spec requirements.. However, if the plant is maintaining a power level less than 50 % when the adjustment is made, the high power reactor trip setpoint will be reduced to 85%. The setpoint will be changed to its normal value when a more accurate adjustment can be made. Typically at approx. 75% power.. While this change was not made to account for calorimetric error, it does meet the intent of the Westinghouse recommendation.. The difference in power levels (50% for WPS, 70% for Westinghouse) should be addressed.

Kewaunee determines feedwater flow for the calorimetric differently than described in this Tech Bulletin. However, the worst case feedwater flow error possible at 50% power including the 2% NI-calorimetric mismatch driving the adjustment could result in a 13.5% error at 100% power6 An. error of this magnitude would result in KNPP exceeding the Tech Spec value of 109% and the analysis limit of 118%. To ensure analysis limits are met, SP48.. 002 should be revised to require the High Power NI setpoint be reduced if an adjustment is made at a power less than 70%. The maximum feedwater flow error at 70 % coupled with the 2 % NJ.-ca1orimetric error driving the adjustment will only result in a 6% error at 100%. While this may result in the plant exceeding the Tech Spec value of 109%, the analysis setpoint of 118 % will be maintained.

The second document covered by this OEA is a 50,,92 evaluation to change the Tech Spec requirements for NIS adjustment.. Due to the relatively short time KNPP operates at reduced power and the proposed changes to the procedural guidance already in place, a revision to p~t Tech Specs is not justified.

This OBA should be routed to Operations, Reactor Engineering, and I&C Engineering for information.

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 22 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 23 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1441 NRC Question KAB-042 Number Select Application NRC Question Closure

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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 1/5/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/5/2010 8:23 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 23 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1441 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 24 of 76 ITS NRC Questions Id 1251 NRC Question KAB-043 Number Category Editorial ITS Section 3.3 ITS Number 3.3.5 DOC Number JFD Number JFD Bases Number Page Number(s) 392 NRC Reviewer Rob Elliott Supervisor Technical Branch Add Name POC Conf Call Requested N NRC Question On page 392 of Attachment 1, Volume 8, the bases reference SR 3.3.5.3 however SR 3.3.5.3 has been renumbered to SR 3.3.5.2. Please update.

Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:53 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 24 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1251 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 25 of 76 Licensee Response/NRC Response/NRC Question Closure Id 961 NRC Question KAB-043 Number Select Licensee Response Application

Response

11/30/2009 3:35 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the Bases reference on Attachment 1, Volume 8, Page 392 of 517 should be SR 3.3.5.2 instead of SR 3.3.5.3 (as currently shown). 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-043 Markup.pdf (807KB)

Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 11/30/2009 3:33 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 25 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=961 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 26 of 76 All changes are 1 LOP DG Start Instrumentation O

B 3.3.5 unless otherwise noted BASES BACKGROUND (continued)

The Trip Setpoints used in the relays are based on the analytical limits presented in FSAR, Chapter 15 (Ref. 2). The selection of these trip setpoints is such that adequate protection is provided when all sensor and processing time delays are taken into account.

Setpoints adjusted consistent with the requirements of the Allowable Value ensure that the consequences of accidents will be acceptable, providing the unit is operated from within the LCOs at the onset of the accident and that the equipment functions as designed.

2 Allowable Values and/or Nominal Trip Setpoints are specified for each Setpoint Function in SR 3.3.5.3. Nominal Trip Setpoints are also specified in the 4 Control unit specific setpoint calculations. The trip setpoints are selected to Program ensure that the setpoint measured by the surveillance procedure does not exceed the Allowable Value if the relay is performing as required. If the measured setpoint does not exceed the Allowable Value, the relay is considered OPERABLE. Operation with a trip setpoint less conservative than the nominal Trip Setpoint, but within the Allowable Value, is acceptable provided that operation and testing is consistent with the assumptions of the unit specific setpoint calculation (Ref. 3). methodology APPLICABLE O The LOP DG start instrumentation is required for the Engineered Safety SAFETY Features (ESF) Systems to function in any accident with a loss of offsite ANALYSES power. Its design basis is that of the ESF Actuation System (ESFAS).

Accident analyses credit the loading of the DG based on the loss of offsite power during a loss of coolant accident (LOCA). The actual DG start has historically been associated with the ESFAS actuation. The DG loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power.

The analyses assume a non-mechanistic DG loading, which does not explicitly account for each individual component of loss of power detection and subsequent actions.

O The required channels of LOP DG start instrumentation, in conjunction with the ESF systems powered from the DGs, provide unit protection in the event of any of the analyzed accidents discussed in Reference 2, in which a loss of offsite power is assumed.

The delay times assumed in the safety analysis for the ESF equipment include the 10 second DG start delay, and the appropriate sequencing delay, if applicable. The response times for ESFAS actuated equipment in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation," include the appropriate DG loading and sequencing delay.

WOG STS B 3.3.5-2 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 26 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 27 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1601 NRC Question KAB-043 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/11/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/11/2010 11:27 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 27 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1601 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 28 of 76 ITS NRC Questions Id 1251 NRC Question KAB-043 Number Category Editorial ITS Section 3.3 ITS Number 3.3.5 DOC Number JFD Number JFD Bases Number Page Number(s) 392 NRC Reviewer Rob Elliott Supervisor Technical Branch Add Name POC Conf Call Requested N NRC Question On page 392 of Attachment 1, Volume 8, the bases reference SR 3.3.5.3 however SR 3.3.5.3 has been renumbered to SR 3.3.5.2. Please update.

Attach File 1 Attach File 2 Issue Date 11/24/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 11/24/2009 8:53 AM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 28 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1251 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 29 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1461 NRC Question KAB-044 Number Select Licensee Response Application

Response

1/5/2010 8:25 AM Date/Time Closure Statement Response After further review, Kewaunee Power Station has determined that Statement Justification for Deviation (JFD) 12 is not the correct JFD for the change described on Attachment 1, Volume 8, Page 199 of 517. A new JFD (JFD

16) has been written to justify the change placing the channel in trip instead of bypass. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment KAB-044 Markup.pdf (850KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 1/5/2010 8:29 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 29 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1461 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 30 of 76 CTS ESFAS Instrumentation 3.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.2.1 Be in MODE 3. 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> AND D.2.2 Be in MODE 4. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> 3.5.d, E. One Containment [ ------------------NOTE-------------------

DOC M04, 1 DOC L08 Pressure channel One additional channel may be inoperable. 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.

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

The below Note should be used for 13 plants with installed bypass test capability.

One 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.

]

16 12 E.1 Place channel in bypass. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> trip OR E.2.1 Be in MODE 3. 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> AND E.2.2 Be in MODE 4. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> DOCs M16, F. One channel or train F.1 Restore channel or train to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and L07 inoperable. OPERABLE status.

OR F.2.1 Be in MODE 3. 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> AND WOG STS 3.3.2-3 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 30 of 76

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 31 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION requirement to perform the surveillance test in accordance with the SCP. Hence, the addition of the phrase "in accordance with the Setpoint Control Program" to ITS SR 3.3.2.4, CHANNEL OPERATIONAL TEST (COT) and ITS SR 3.3.2.6, CHANNEL CALIBRATION in the surveillance requirement table.

13. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. ISTS Required Actions D, E, and I (ITS Required Actions D, E, and H, respectively) are modified by a Note that provides two options for bypassing a channel for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of performing surveillance testing without entry into the applicable Required Actions. One option is for plants that have installed bypass testing capabilities. The other option is for plants that do not have installed bypass testing capabilities. KPS does not have installed bypass testing capabilities. Therefore, the Note for plants that do not have bypass testing capabilities is retained for Required Actions D, E, and H.
14. ISTS Table 3.3.2-1 Function 6.g (Trip of all Main Feedwater Pumps) specifies that ISTS SR 3.3.2.9, a CHANNEL CALIBRATION, is required for the Function. This CHANNEL CALIBRATION requirement is not being included in the KPS ITS for the same Function (ITS Table 3.3.2-1 Function 6.e). The ISTS shows that the Function has an ALLOWABLE VALUE and NOMINAL TRIP SETPOINT based on a pressure. The ISTS Bases describes that the trip is derived from low pressure on the control air/oil line of the turbine driven main feedwater pumps. Thus, it is appropriate to perform a CHANNEL CALIBRATION on the sensors. However, KPS uses motor driven main feedwater pumps, and the signal to start the AFW pumps comes from the breaker position contacts. Thus, there is no CHANNEL CALIBRATION to perform. This is also consistent with the KPS CTS, which does not require a CHANNEL CALIBRATION.
15. The RTS RESPONSE TIME requirement, ISTS SR 3.3.2.10, has not been adopted into the KPS ITS, consistent with Kewaunee current licensing basis and current Technical Specifications. The Kewaunee USAR describes the implementation of the principles as related to the proposed IEEE-279 "Standard, Nuclear Power Plant Protection Systems," August 1968. This industry standard provides guidance and requirements for conducting periodic testing of protection systems. IEEE-279-1968 does not address response time testing. Furthermore, generic studies have shown that instrumentation response time changes (increasing times), that could impact safety, do not normally vary such that they would not be detected during other required surveillances (e.g., CHANNEL CALIBRATIONS). Since the addition of these tests would be a major burden (plant design does not readily lend itself to such testing) with little gain in safety, ISTS SR 3.3.2.10 has not been added.

16 Throughout the ISTS, in both the Specifications and the Bases, reference is made to placing a channel in bypass or bypassing an inoperable channel. KPS does not have the ability to place a channel in bypass or perform a bypass of an inoperable channel 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 place a channel in bypass or perform a bypass of an inoperable channel. As a result, when a channel is required to be placed in bypass or a bypass of a channel is required, the channel is placed in the trip condition.

Kewaunee Power Station Page 5 of 5 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 31 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 32 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1611 NRC Question KAB-044 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:43 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 32 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1611 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 33 of 76 ITS NRC Questions Id 1281 NRC Question KAB-045 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number Page Number 204 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 204 of Attachment 1, volume 8, SR 3.3.2.5 (renumbered to SR 3.3.2.4) references justification for deviations (JFD) 5. However, JFD 5 discusses deletion of the master and slave relay SR and SR 3.3.2.4 is a COT. Please provide an explanation for referencing JFD 5.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:39 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 33 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1281 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 34 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1261 NRC Question KAB-045 Number Select Licensee Response Application

Response

12/15/2009 2:30 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.

Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment KAB-045 Markup.pdf (828KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:30 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 34 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1261 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 35 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION Therefore, all master and slave relays in ESF that can be safely checked online and do not pose a significant risk to plant reliability are checked during the performance of the Actuation Logic Test (ALT). The remainder of the Master and Slave Relays are checked by actual equipment operation when the plant conditions are such that it does not significantly affect safety and reliability in the plant. KPS currently tests and meets the requirements of Generic Letter 96-01 and the inclusion of specific Master or Slave Relay Testing would be intrusive and/or affect safety and reliability due to the design of KPS. This was acknowledged in the original plant NRC SER (Ref. 1), a letter from WPSC to the NRC dated April 19, 1996 in regard to Generic Letter 96-01 (Ref. 2), and the acceptance letter from the NRC to WPSC dated January 14, 1999 in regard to Generic Letter 96-01 (Ref.

3). KPS testing of the Master and Slave Relays is limited and plant design does not allow for safely and reliably performing separate Master and Slave Relay Testing surveillances. Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary.

6. ISTS 3.3.2 ACTIONS H, K, and L are applicable to ISTS Table 3.3.2-1 Functions 5.a, 7.b, 7.c, 8.b, and 8.c. These Functions are not applicable to the design of KPS; therefore, the applicable ACTIONS have been deleted. The discussion for the reason each function is not applicable to KPS is found in other Justification For Deviations.
7. ISTS SR 3.3.2.3 requires the performance of an ACTUATION LOGIC TEST every 31 days on a STAGGERED TEST BASIS. ISTS SR 3.3.2.3 also contains a NOTE that the continuity check may be excluded. ISTS SR 3.3.2.3 is applicable only to ISTS Table 3.3.2-1 Function 6.b, Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays. This test is currently not required at KPS. Since the design of the KPS ESFAS actuation logic is such that master and slave relays are employed and not a solid state protection system, ISTS SR 3.3.2.2 (ITS SR 3.3.2.2) is used to check the Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays. ISTS SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST every 92 days on a STAGGERED TEST BASIS. ISTS SR 3.3.2.2 does not contain the NOTE that the continuity check may be excluded. This testing Frequency is considered acceptable and is the same Frequency as relay testing for other ESFAS Functions. In addition, the Note is not needed for ITS SR 3.3.2.2. Subsequent Surveillance Requirements have been renumbered, as necessary.
8. ISTS Table 3.3.2-1 Functions 1.e.2 (Steam Line Pressure - High Differential Pressure Between Steam Lines), 1.f (High Steam Flow in Two Steam Lines Coincident with T avg - Low Low), 1.g (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 2.c (Containment Pressure High - 3 (High High)), 3.b.(1) (Phase B Isolation - Manual Initiation), 3.b.(2) (Phase B Isolation - Automatic Actuation Logic and Actuation Relays), 3.b.(3) (Containment Pressure High - 3 (High High)), 4.d.(1), (Steam Line Pressure Low), 4.d.(2),

(Negative Rate - High), 4.e, (High Steam Flow in Two Steam Lines Coincident with T avg - Low Low), 4.f, (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 6.a, (Automatic Actuation Logic and Actuation Relays (Solid State Protection System)), 6.e, (Auxiliary Feedwater Loss of Offsite Power), 6.h, (Auxiliary Feedwater Pump Suction transfer on Suction Pressure - Low), all Functions associated with Function 7 (Automatic Switchover to Containment Kewaunee Power Station Page 3 of 5 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 35 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 36 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1621 NRC Question KAB-045 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:47 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 36 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1621 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 37 of 76 ITS NRC Questions Id 1291 NRC Question KAB-046 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5l6 JFD Bases Number Page Number 204 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 204 of Attachment 1, volume 8, SR 3.3.2.7 (renumbered to SR 3.3.2.3) references justification for deviations (JFD) 5 and 6. However, JFD 5 discusses deletion of the master and slave relay SR and SR 3.3.2.3 is a TADOT. JFD 6 does not appear to be applicable to SR 3.3.2.3. Please provide a JFD reference that explains the change.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:40 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 37 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1291 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 38 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1271 NRC Question KAB-046 Number Select Licensee Response Application

Response

12/15/2009 2:30 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.

Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." The draft markup regarding this change is attached as part of the response to KAB-045 (since KAB-045 resulted in the same correction).

In addition, KPS has determined that the correct Justification for Deviation (JFD) for the removal of the brackets should be JFD 1, not JFD 6. A draft Markup regarding this change is attached.

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

Question Closure Date Attachment KAB-046 Markup.pdf (810KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:34 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 38 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1271 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 39 of 76 CTS All changes are 1 ESFAS Instrumentation 3.3.2 unless otherwise noted SURVEILLANCE REQUIREMENTS

NOTE----------------------------------------------------------

4.1.a Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

Table TS 4.1-1, SURVEILLANCE FREQUENCY Channel Descriptions 7, 11.a, 11.b, 18.a, 18.b, 18.c SR 3.3.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Table TS 4.1-1, Channel SR 3.3.2.2 Perform ACTUATION LOGIC TEST. 92 days on a Description 26, STAGGERED DOC M18 TEST BASIS SR 3.3.2.3 ------------------------------NOTE-------------------------------

The continuity check may be excluded.

7 Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED TEST BASIS

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

The Frequency remains at 31 days on a STAGGERED TEST BASIS for plants with a Relay Protection System.

5 SR 3.3.2.4 Perform MASTER RELAY TEST. 92 days on a STAGGERED TEST BASIS Table TS 4.1-1, Channel 12 Descriptions 7, in accordance with the SR 3.3.2.5 4 Perform COT. Setpoint Control Program 184 days 5 11.a, 11.b, 18.a, 18.b, 18.c, and 35 5

SR 3.3.2.6 Perform SLAVE RELAY TEST. [92] days 5

DOC M14 SR 3.3.2.7 3 ------------------------------NOTE-------------------------------

Verification of relay setpoints not required.

1 6 Perform TADOT. [92] days WOG STS 3.3.2-7 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 39 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 40 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1631 NRC Question KAB-046 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:48 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 40 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1631 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 41 of 76 ITS NRC Questions Id 1301 NRC Question KAB-047 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number Page Number 205 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC On page 205 of Attachment 1, volume 8, Surveillance Requirements Question 3.3.2.8, 3.3.2.9 and 3.3.2.11 (renumbered to SR 3.3.2.5, 3.3.2.6 and 3.3.2.7) reference justification for deviations (JFD) number 5. However, JFD 5 discusses deletion of master and slave relay testing. JFD 5 is not applicable to these SRs. Please provide a JFD reference that explains the changes.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:41 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 41 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1301 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 42 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1281 NRC Question KAB-047 Number Select Licensee Response Application

Response

12/15/2009 2:35 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.

Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." The draft markup regarding this change is attached as part of the response to KAB-045 (since KAB-045 resulted in the same correction). This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:37 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 42 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1281 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 43 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1661 NRC Question KAB-047 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:55 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 43 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1661 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 44 of 76 ITS NRC Questions Id 1311 NRC Question KAB-048 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 6 JFD Bases Number Page Number 205 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 205 of Attachment 1, volume 8, Surveillance Requirements 3.3.2.8 and 3.3.2.9 (renumbered to SR 3.3.2.5 and 3.3.2.6) reference justification for deviations (JFD) number 6. JFD 6 is not applicable to these SRs. Please provide a JFD reference that explains the changes.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:43 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 44 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1311 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 45 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1291 NRC Question KAB-048 Number Select Licensee Response Application

Response

12/15/2009 2:40 PM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement the correct Justification for Deviation (JFD) for the removal of the brackets in ISTS SR 3.3.2.8 and SR 3.3.2.9 (ITS SR 3.3.2.5 and SR 3.3.2.6, respectively) on Attachment 1, Volume 8, Page 205 of 517 should be JFD

1. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment KAB-048 Markup.pdf (840KB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 12/15/2009 2:39 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 45 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1291 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 46 of 76 CTS ESFAS Instrumentation All changes are 3 3.3.2 unless otherwise noted SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M09 SR 3.3.2.8 5 ------------------------------NOTE------------------------------- 5 Verification of setpoint not required for manual initiation functions.

Perform TADOT. [18] months 1 6 Table TS 4.1-1, SR 3.3.2.9 6 ------------------------------NOTE------------------------------- 5 Channel Descriptions 7, This Surveillance shall include verification that the 9 11.a, 11.b, time constants are adjusted to the prescribed 18.a, 18.b, and 18.c values.

Perform CHANNEL CALIBRATION. [18] months 1 6 in accordance with the 12 Setpoint Control Program SR 3.3.2.10 ------------------------------NOTE-------------------------------

Not required to be performed for the turbine driven AFW pump until [24] hours after SG pressure is

 [1000] psig.

15 Verify ESFAS RESPONSE TIMES are within limit. [18] months on a STAGGERED TEST BASIS DOC M17 5 SR 3.3.2.11 7 ------------------------------NOTE-------------------------------

Verification of setpoint not required.

Perform TADOT. Once per reactor trip breaker cycle WOG STS 3.3.2-8 Rev. 3.0, 03/31/04 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 46 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 47 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1641 NRC Question KAB-048 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:50 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 47 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1641 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 48 of 76 ITS NRC Questions Id 1321 NRC Question KAB-049 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 9 JFD Bases Number Page Number 218 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 218 of Attachment 1, volume 8, justification for deviations (JFD) 9 indicates ITS SR 3.3.2.6 applies to function 6.e. However, SR 3.3.2.6 is not listed in TS Table 3.3.2.1 for function 6.e. Please correct or explain this discrepancy.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:44 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 48 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1321 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 49 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1451 NRC Question KAB-049 Number Select Licensee Response Application

Response

1/5/2010 8:20 AM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement Justification for Deviation (JFD) 9 does not apply to ITS Table 3.3.2-1 Function 6.e. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-049 Markup.pdf (392KB)

Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Ray Schiele Added By Robert Hanley Date Added 1/5/2010 8:23 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 49 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1451 06/09/2010

Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 50 of 76 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION Sump), 8.b, (Pressurizer Pressure, P-11), and 8.c, (T avg - Low Low, P-12) have been deleted since they do not apply to the KPS design. In addition, all applicable footnotes related to those Functions are also being deleted. Subsequent Functions and footnotes have been renumbered as applicable.

9. A Note to ISTS SR 3.3.2.9 (ITS SR 3.3.2.6) requires the CHANNEL CALIBRATION to include verification that time constants are adjusted to the prescribed values. In the KPS ITS, this Surveillance (ITS SR 3.3.2.6) applies to ITS Table 3.3.2-1, Functions 1.c, 1.d, 1.e, 2.c, 4.c, 4.d, 4.e, 5.b, 6.b, 6.d, 6.e, and 7.b. Of these Functions, the only one that has a time constant is ITS Table 3.3.2-1 Functions 1.e, and the time constants are included in a Note to the Allowable Value. Thus, the time constant is part of the Allowable Value for this function. The definition of CHANNEL CALIBRATION states that it 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. Thus the CHANNEL CALIBRATION of this Function requires the time constant be set properly. It is not necessary to include a Note that also says that the CHANNEL CALIBRATION Surveillance includes the time constants; it already does. Including this note in this Surveillance would incorrectly imply that a CHANNEL CALIBRATION does not require certain Allowable Values (i.e., time constant type Allowable Values) to be verified during the CHANNEL CALIBRATION. In addition, the Allowable Values for the KPS ITS will be removed from the ITS and retained in a licensee-controlled Setpoint Control Program. Therefore, the Note is not included in the KPS ITS.
10. The Nominal Trip Setpoint column has been deleted as allowed by the Reviewer's Note at the end of the ISTS Table 3.3.2-1. This Reviewer's Note allows specific unit implementation to contain only the Allowable Value. The nominal trip setpoints for each of the applicable ITS Table 3.3.2-1 Functions will be controlled in accordance with the Note in the ISTS 3.3.2 Bases Background section.
11. ISTS Table 3.3.2-1 (ITS Table 3.3.2-1) Function 8 (Reactor Trip, P-4 Interlock) has been revised by deleting the term "2 trains." This information is Bases type information and has been included in the ITS Bases.
12. Changes are made to the ISTS that reflect the adoption of proposed Revision 4 of TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions".

Three options are provided for licensees to pursue when adopting TSTF-493. KPS has elected to implement TSTF-493 via the use of a Setpoint Control Program.

Under this adoption strategy, KPS relocates the Technical Specification Section 3.3, "Instrumentation," Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Values from the Technical Specifications to a licensee-controlled Setpoint Control Program. The requirements for the Setpoint Control Program will be described in Chapter 5, "Administrative Controls," of the Technical Specifications. Hence the deletion of the "ALLOWABLE VALUE" and "NOMINAL TRIP SETPOINT" columns from Table 3.3.2-1 of the ITS. Included in the relocation to the licensee-controlled Setpoint Control Program is all information contained within any associated footnotes that tie to numerical values in the Limiting Trip Setpoints, Nominal Trip Setpoints, and/or Allowable Value columns.

In addition, the adoption strategy requires that each instrument surveillance requirement which verifies a LSSS (both SL and non-SL-LSSSs) contain a Kewaunee Power Station Page 4 of 5 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 50 of 76

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 51 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1651 NRC Question KAB-049 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:53 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 51 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1651 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 52 of 76 ITS NRC Questions Id 1331 NRC Question KAB-050 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number JFD Bases Number Page Number 205 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 205 of Attachment 1, volume 8, surveillance requirement 3.3.2.8 (renumbered to SR 3.3.2.5) does not show a change that would be consistent with the adoption of TSTF-493. TSTF-493 would add the statement in accordance with the setpoint control program to SR 3.3.2.5.

Please provide a new JFD reference that explains the change.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:45 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 52 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1331 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 53 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1311 NRC Question KAB-050 Number Select Licensee Response Application

Response

12/17/2009 11:00 AM Date/Time Closure Statement Response TSTF-493, Rev. 4, Option B includes the statement concerning the setpoint Statement control program for ISTS SR 3.3.2.8. This SR is a TADOT, and applies to all the manual initiation functions as well as the AFW trip of all main feedwater pumps function. In the ISTS, this function includes setpoints. However, for the KPS design, this trip is actuated by breaker position switches, not a pressure sensor. The Note for ISTS SR 3.3.2.8 (ITS SR 3.3.2.5) specifically states that verification of setpoints are not required for the manual initiation functions. Since there are no setpoints for the KPS design, and the definition of TADOT in Section 1.1 (Volume 3, page 38) states that it includes an adjustment only as necessary, setpoint verification would also not be required. Therefore, the addition of the requirement from TSTF-493, Rev. 4 concerning the setpoint control program is not needed. KPS does not believe that a JFD is necessary to state that a small piece of TSTF-493, which is not approved yet by the NRC, is not being adopted. KPS believes that this response, in addition to the actual KPS design for the function as described in the ITS Bases (page 263), provides proper documentation as to why this part of TSTF-493 is not being adopted.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:04 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 53 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1311 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 54 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1671 NRC Question KAB-050 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 2:59 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 54 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1671 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 55 of 76 ITS NRC Questions Id 1341 NRC Question KAB-051 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5 JFD Bases Number Page Number 206-214 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 206-214 of Attachment 1, volume 8, TS Table 3.3.2-1 functions 1.a, 1.c, 1.d, 1.e.1, 2.a, 2.c, 3.a, 4.a, 4.c, 4.d, 4.e, 5.b, 6.b, 6.d, 6.e, and 8 reference justification for deviations (JFD) number 5. However, JFD 5 discusses deletion of master and slave relay testing. JFD 5 is not applicable to these SRs. Please provide a JFD reference that explains the changes.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:46 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 55 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1341 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 56 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1321 NRC Question KAB-051 Number Select Licensee Response Application

Response

12/17/2009 11:05 AM Date/Time Closure Statement Response After further review, Kewaunee Power Station (KPS) has determined that Statement JFD 5 needs an additional sentence. Since JFD 5 deletes two Surveillances, the remaining Surveillances must be renumbered.

Therefore, an additional sentence has been added that states "Due to these deletions, the subsequent Surveillance Requirements have been renumbered and reordered, as necessary." The draft markup regarding this change is attached as part of the response to KAB-045 (since KAB-045 resulted in the same correction). This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:06 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 56 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1321 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 57 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1681 NRC Question KAB-051 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:01 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 57 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1681 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 58 of 76 ITS NRC Questions Id 1351 NRC Question KAB-052 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 5l8 JFD Bases Number Page 215 and 424 Number(s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC On page 215 and 424 of Attachment 1, volume 8, justifications for Question deviations 5 and 8 discuss deletion of master and slave relay testing.

Please provide a list stating which functions have master relays and which functions have slave relays. Include in your response the current master and slave relay surveillance testing frequency for each function and which surveillance tests apply i.e., functional check, calibrate or test.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:48 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 58 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1351 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 59 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1391 NRC Question KAB-052 Number Select Licensee Response Application

Response

12/22/2009 3:10 PM Date/Time Closure Statement

Response

Statement Table 3.3.2-1, Functions 5a, 6a, and 7 have master and slave relays but do not require master and slave relay testing in NUREG-1431 for ITS, therefore they are not included below.

The following Functions have Master and/or Slave relays that will be checked by the Actuation Logic Test (ALT) every 92 days on a staggered test basis in ITS (SP-55-155):

Table 3.3.2-1 Function 1.b Table 3.3.2-1 Function 2.b Table 3.3.2-1 Function 3.b Table 3.3.2-1 Function 4.b Table 3.3.6-1 Function 1 Table 3.3.6-1 Function 2.a (ALT is SI logic portion)

Table 3.3.6-1 Function 2.b (ALT is SI logic portion)

There are some Master and/or Slave relays that are blocked during the ALT to prevent them from operating at inopportune times. Most of these blocked relays are tested for continuity during the ALT by passing enough current to light a bulb, but not enough current to actually pick up the relay. The following Functions contain some relays that do not operate during the ALT but are checked by other surveillances:

Table 3.3.2-1 Function 1.b Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)

Table 3.3.2-1 Function 2.b Slave checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)

Table 3.3.2-1 Function 3.b Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)

Table 3.3.2-1 Function 4.b Slaves checked by Valve Timing Test every 18 months (SP-55-167-6A)

Table 3.3.2-1 Function 5.a Masters & Slaves checked by FRV Timing Test every 18 months (SP-05A-202)

Table 3.3.6-1 Function 1 Slaves checked by Diesel Test every 18 months (OP-KW-OSP-SI-001)

Table 3.3.6-1 Function 2.a Slaves (SP-45-49.12) R12 Quarterly Test cycle Master and Slave Table 3.3.6-1 Function 2.b Slaves (SP-45-49-11) R11 Quarterly Test cycle Master Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 59 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1391 06/24/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 60 of 76 and Slave Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/22/2009 3:16 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 60 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1391 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 61 of 76 Licensee Response/NRC Response/NRC Question Closure Id 3231 NRC Question KAB-052 Number Select NRC Response Application

Response

5/26/2010 6:00 PM Date/Time Closure Statement Response In ITS TS 3.3.2, Table 3.3.2-1, Function 5a, Feedwater Isolation Automatic Statement Actuation Logic and Actuation Relays, Function 6a, Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays, and Function 7.a, Turbine Building Service Water Header Isolation Automatic Actuation Logic and Actuation Relays, require SR 3.3.2.2 (Attachment 1 Volume 8, pages 212 and 213 of 517).

Please clarify the quoted statement, in the response to RAI KAB-052, as to why the master and slave relays of ITS TS 3.3.2 Table 3.3.2-1, Functions 5a, 6a, and 7a do not require testing. If these master and slave relays are not tested by SR 3.3.2.2 or other TS 3.3.2 surveillances, how is operability of the relays determined?

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 5/26/2010 11:18 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 61 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3231 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 62 of 76 Licensee Response/NRC Response/NRC Question Closure Id 3341 NRC Question KAB-052 Number Select Licensee Response Application

Response

5/28/2010 10:15 AM Date/Time Closure Statement Response KAB-052, Second Response Statement The paragraph being quoted in the KAB-052 NRC response of 5/26/2010 is referencing the first paragraph of the original KPS response to KAB-052.

This paragraph, which was inadvertently included in the KPS response, should not have been included as this paragraph was informational and related to the ISTS Table Functions (it was information provided to internal KPS reviewers).

KPS ITS Functions 5.a and 6.a do have Master and Slave Relays. Function 5.a was described in the previous response, but for completeness, the information is also provided in this response.

KPS ITS Function 5a Master and Slave Relays are checked by the Feed Regulating Valve Timing Test every 18 months (procedure SP-05A-202).

KPS ITS Function 6a Master and Slave Relays are checked at power (i.e.

online) by Reactor Protection Logic test (procedures SP-47-062A/B) and during shutdown conditions by Reactor Protection Logic test (procedures SP-47-062G/H/I).

KPS ITS Function 7a does not have a typical Master/Slave Relay design, therefore a specific Master or Slave Relay test is not required for this Function. However, the design that does exist is a single contact matrix that is tested by SR 3.3.2.2 (as required by the ITS).

Question Closure Date Attachment 1

Attachment 2

Notification Kewaunee ITS Conversion Database Members NRC/LICENSEE Supervision Kristy Bucholtz Added By Charles Smoker Date Added 5/28/2010 10:12 AM Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 62 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3341 06/24/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 63 of 76 Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 63 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3341 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 64 of 76 Licensee Response/NRC Response/NRC Question Closure Id 3401 NRC Question KAB-052 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 6/7/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 6/7/2010 7:13 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 64 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=3401 06/24/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 65 of 76 ITS NRC Questions Id 1361 NRC Question KAB-053 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 206 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 206 of Attachment 1, volume 8, the title steam line pressure for function 1.e references justifications for deviations (JFD) 8 in TS Table 3.3.2-1. However, JFD 8 discusses deleting functions not applicable to Kewaunee. Steam line pressure is applicable to Kewaunee. Please explain this discrepancy.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:49 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 65 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1361 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 66 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1331 NRC Question KAB-053 Number Select Licensee Response Application

Response

12/17/2009 11:05 AM Date/Time Closure Statement Response ITS Table 3.3.2-1 Function 1.e is applicable to KPS. However, the ISTS Statement includes two parts for this Function 1.e.(1) and 1.e.(2). The KPS ITS does not include Function 1.e.(2), High Differential Pressure Between Steam Lines Function. This ISTS Function has been deleted using JFD 8, as annotated on the same page. Since there are only 2 parts to Function 1.e, there was no reason to number the remaining part as 1.e.(1), and the remaining function, Steam Line Pressure - Low, has been numbered as just 1.e. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." While it is recognized that 1.e.(1) is not necessarily "subsequent" to the deleted 1.e.(2), JFD 8 was used to justify the renumbering of the (1) portion since they were both part of Function 1.e.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:08 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 66 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1331 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 67 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1691 NRC Question KAB-053 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:07 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 67 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1691 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 68 of 76 ITS NRC Questions Id 1371 NRC Question KAB-054 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 207-214 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 207 - 214 of Attachment 1, volume 8, functions 2.c, 3.a, 3.b, 3.c, 4.d, 4.e, 6.a, 6.b, 6.c, 6.d, 6.e, and 8 in TS Table 3.3.2-1 reference justification for deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. These functions are applicable to Kewaunee. Please explain this discrepancy.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:50 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 68 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1371 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 69 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1341 NRC Question KAB-054 Number Select Licensee Response Application

Response

12/17/2009 11:10 AM Date/Time Closure Statement Response JFD 8 describes the deletion of certain Functions from the ISTS Table Statement 3.3.2-1. These deletions resulted in the renumbering of the remaining Functions, including the ones listed in the question. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." Thus, JFD 8 was used to justify the renumbering of the Functions that are being maintained in the KPS ITS.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:10 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 69 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1341 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 70 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1701 NRC Question KAB-054 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:10 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 70 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1701 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 71 of 76 ITS NRC Questions Id 1381 NRC Question KAB-055 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 209-211 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 209, 210 and 211 of Attachment 1, volume 8, note b in TS Table 3.3.2-1 references justification for deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. These notes are not functions and the notes are applicable to Kewaunee. Please explain this discrepancy.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:51 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 71 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1381 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 72 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1351 NRC Question KAB-055 Number Select Licensee Response Application

Response

12/17/2009 11:10 AM Date/Time Closure Statement Response JFD 8 describes the deletion of certain Functions from the ISTS Table 3.3.2-Statement

1. These Functions include ISTS Table 3.3.2-1 Functions 4.d.(1), Steam Line Isolation, Steam Line Pressure - Low, and 4.f, Steam Line Isolation, High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure

- Low. The Allowable Values and Nominal Trip Setpoints are part of the Functions, just like the Applicability, Required Channels, Conditions, and SRs. The Allowable Values and Nominal Trip Setpoint are modified by ISTS Table 3.3.2-1 footnote (b), which provides the lead/lag time constants for the Functions. JFD 8, in part, justifies deleting these two Functions, which would include the Allowable Values and Nominal Trip Setpoint, and the ISTS footnote (b) modification. Note that these two Functions are on pages 209 and 210, no ISTS footnote (b) was found on Page 211. However, ISTS Table 3.3.2-1 footnote (h), which is on page 211, has been renumbered to ITS Table 3.3.2-1 footnote (b) and the change is justified using JFD 8. The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." Thus, JFD 8 was used to justify the renumbering of the footnote from (h) to (b).

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:12 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 72 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1351 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 73 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1711 NRC Question KAB-055 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:14 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 73 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1711 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 74 of 76 ITS NRC Questions Id 1391 NRC Question KAB-056 Number Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number JFD Number 8 JFD Bases Number Page Number 211 (s)

NRC Reviewer Gerald Waig Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question On page 211 of Attachment 1, volume 8, note d in TS Table 3.3.2-1 references justification for deviations (JFD) number 8. However, JFD 8 discusses deleting functions not applicable to Kewaunee. This note is not a function and the note is applicable to Kewaunee. Please explain this discrepancy.

Attach File 1 Attach File 2 Issue Date 12/14/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 12/14/2009 2:53 PM Notification NRC/LICENSEE Supervision Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 74 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1391 06/08/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 75 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1361 NRC Question KAB-056 Number Select Licensee Response Application

Response

12/17/2009 11:10 AM Date/Time Closure Statement Response JFD 8 describes the deletion of certain Functions from the ISTS Table Statement 3.3.2-1. These deletions resulted in the renumbering of the remaining Functions, as well as any footnotes deleted because they were a part of the Function. Thus, ITS Table 3.3.2-1 footnote (d) is actually ISTS Table 3.3.2-1 footnote (i). The last sentence of JFD 8 states "Subsequent Functions and footnotes have been renumbered as applicable." Thus, JFD 8 was used to justify the renumbering of the footnote from (i) to (d).

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By David Mielke Date Added 12/17/2009 11:13 AM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 75 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1361 06/09/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 76 of 76 Licensee Response/NRC Response/NRC Question Closure Id 1721 NRC Question KAB-056 Number Select Application NRC Question Closure

Response

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

Response

Statement Question Closure 1/12/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 1/12/2010 3:15 PM Modified By Date Modified Enclsoure (5 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) 76 of 76 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1721 06/09/2010

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