ML102371203

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Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3)
ML102371203
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: ML102371203 (41)
v • d • e


Text

ITS NRC Questions Id681NRC Question Number KAB-001 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number CTS Table 3.5-2 JFD Number JFD Bases Number Page Number(s) 7 of 517 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On Page 7 of 517 in Attachment 1, volume 8, Table TS 3.5.2 function 9, "pressurizer high water level" indicates a proposed change to column 5, "permissible bypass conditions".

The change indicates that , "table 3.3.1-1 Note (b)" applies; however Table 3.3.1-1 function 9, "pressurizer water level - high" on page 67 of 517 references note (e), not note (b). Note (b) does not exist on this page.

Please explain the discrepancy, or indicate which reference is correct.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:37 AM Notification NRC/LICENSEE Supervision 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=681 Licensee Response/NRC Response/NRC Question Closure Id291NRC Question Number KAB-001 Select Application Licensee Response Response Date/Time 10/21/2009 2:40 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) agrees that in Attachment 1, Volume 8, Page 7 of 15 the reference for CTS Table 3.5.2 Functional Unit 9, "Pressurizer High Water Level," should be ITS Table 3.3.1-1, Note (e). A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-001 markup.pdf (848KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Gerald Riste Added By Gerald Riste Date Added 10/21/2009 2:37 PM Modified By Ray Schiele Date Modified 10/21/2009 2:44 PM 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=291 TABLE TS 3.5-2 INSTRUMENT OPERATION CONDITIONS FOR REACTOR TRIP Amendment No. 94 Page 2 of 4 11/12/91 ITS 3.3.1 A01 ITS 1 2 3 4 5 6 NO. FUNCTIONAL UNIT NO. OF CHANNELS NO. OF CHANNELS TO TRIP MINIMUM OPERABLE CHANNELS MINIMUM DEGREE OF REDUNDANCY PERMISSIBLE BYPASS CONDITIONS OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET 9 Pressurizer High Water Level 3 2 2 - P-7 Maintain HOT SHUTDOWN 10 Low Flow In One Loop

Low Flow Both Loops 3/loop 3/loop 2/loop (any loop)

2/loop (both loops) 2

2 -

- P-8 P-7 Maintain HOT SHUTDOWN

Maintain HOT SHUTDOWN 11 Deleted 12 Lo-Lo Steam Generator Water Level 3/loop 2/loop 2/loop - Maintain HOT SHUTDOWN 13 Undervoltage 4-kV 2/bus 1/bus (both buses) 1/bus - P-7 Maintain HOT SHUTDOWN 14 Underfrequency 4-kV Bus (4) 2/bus 1/bus (both buses) 1/bus - Maintain HOT SHUTDOWN 15 Deleted 16 Steam Flow/Feedwater Flow Mismatch 2 1 1 - Maintain HOT SHUTDOWN Page 3 of 15 LA01 REQUIRED A03 LA01 9 10 14 12 11.a, 11.b, 13 15 3/loop Table 3.3.1-1

Function M03 Add proposed ACTION E 3/loop M06 3 M03 3 2/SG M06 M03 2 2 M06 Applicability A04 Table 3.3.1-1

Note (b) Table 3.3.1-1

Note (e) Table 3.3.1-1

Note (f) L13 Add proposed ACTIONS L and M A11 Add proposed ACTION K Add proposed Applicability and number of Required Channels A ttachment 1, Volume 8, Rev. 0, Page 7 of 517 A ttachment 1, Volume 8, Rev. 0, Page 7 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 3 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 3 of 41 e

Licensee Response/NRC Response/NRC Question Closure Id581NRC Question Number KAB-001 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:23 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=581 ITS NRC Questions Id691NRC Question Number KAB-002 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number A-4 JFD Number JFD Bases Number Page Number(s) 21 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 21 of Attachment 1, volume 8, the discussion of changes A04 states, "Furthermore, since the Nuclear Flux Intermediate Range are not required until below the P-6 setting-" On the other hand, Table 3.3.1-1 function 4, "intermediate range neutron flux" shows the applicable mode to be modes 1 and 2 with reference to notes (b) and (c). Note (b) states, "below the P-10 (power range neutron flux) interlocks" and note (c) states, "above the P-6 (intermediate range neutron flux) interlocks." This appears to be a discrepancy. Please explain which is correct or provide the reason for the differences Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:38 AM Notification NRC/LICENSEE Supervision 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=691 Licensee Response/NRC Response/NRC Question Closure Id301NRC Question Number KAB-002 Select Application Licensee Response Response Date/Time 10/21/2009 2:35 PM Closure Statement Response Statement After further review, Kewaunee Powe r Station has determined that statement in Attachment 1, Volume 8, Page 21 of 517 in Discussion of Change A04, which states, "Furthermore, since the Nuclear Flux Intermediate Range are not required until below the P-6 setting, then the HOT STANDBY requirement would only be above the P-6 setting" was typed incorrectly. The statement should read " Furth ermore, since the Nuclear Flux Intermediate Range ar e not required until above the P-6 setting, then the HOT ST ANDBY requirement would only be above the P-6 setting." A draft markup re garding 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-002 Markup.pdf (818KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Gerald Riste Added By Gerald Riste Date Added 10/21/2009 2:41 PM Modified By Date Modified 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=301 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 2 of 31 A03 CTS Table TS 3.5-2, Column 3 specifies the "MINIMUM OPERABLE CHANNELS" associated with each RPS Functional Unit and CTS 3.5.2 specifies the actions to take when the number of channels for a particular Functional Unit is less than the Column 3 requirements. Additionally, the Notes for Table

TS 3.5-2 contain a table that pertains to the RPS Permissives and Interlocks.

This Note table contains a column titles "Coincident," which describes the coincidence logic needed for each permissive/interlock. ITS LCO 3.3.1 requires the RPS Instrumentation to be OPERABLE, and includes only one column in Table 3.3.1-1 titled "REQUIRED CHANNELS." This changes the CTS by changing the title of the MINIMUM OPERABLE CHANNELS" and "Coincidence" columns to "REQUIRED CHANNELS."

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

A04 CTS Table TS 3.5-2 Column 6 specifies the "OPERATOR ACTION IF CONDITIONS OF COLUMN 3 OR 4 CANNOT BE MET." CTS Table TS 3.5-2 Column 6 requires maintaining HOT SHUTDOWN for Functional Units 1, 2, 3, 4, 5, 6, 8, 9, 10, 12, 13, 14, 16, and 17. Based on the CTS Table TS 3.5-2 requirement to maintain HOT SHUTDOWN, the Mode of Applicability would be considered OPERATING and HOT STANDBY for Functional Units 1(Manual), 2, (Nuclear Flux Power Range (High Setting, Positive Setting, and Negative Setting)), 5 (Overte Pressure), 12 (Lo-Lo Steam Generator Water Level), 16 (Steam Flow/Feedwater Flow Mismatch), and 17 (Reactor Trip Breaker (RTB) and (Independently Test Shunt and Undervoltage Trip Attachments). For Functional Unit 2 (Nuclear Flux Power Range (Low Setting)), the Mode of Applicability is OPERATING below the P-10 interlock and HOT STANDBY for the Nuclear Flux Power Range (Low Setting) because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-10. This means that the Nuclear Flux Power Range (Low Setting) channels are blocked above the P-10 setting. With the P-10 Setting Limit of

< 7.8% RATED POWER, Nuclear Flux Power Range (Low Setting) would be required to be OPERABLE in the OPERATING MODE below the P-10 limit and in HOT STANDBY. For Functional Unit 3 (Nuclear Flux Intermediate Range), the MODE of Applicability is OPERATING below the P-10 interlock and HOT STANDBY because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-10. This means that the Nuclear Flux Intermediate Range channels are blocked above the P-10 setting. With the P-10 Setting Limit of < 7.8% RATED POWER, Nuclear Flux Intermediate Range would be required to be OPERABLE in the OPERATING MODE below the P-10 limit. Furthermore, since the Nuclear Flux Intermediate Range are not required until below the P-6 setting, then the HOT STANDBY requirement would only be above the P-6

setting. Therefore, the MODE of Applicability, for the Nuclear Flux Intermediate Range, would be OPERATING below the P-10 interlock and HOT STANDBY above the P-6 interlock. For Functional Unit 4 (Nuclear Source Range), the A ttachment 1, Volume 8, Rev. 0, Page 21 of 517 A ttachment 1, Volume 8, Rev. 0, Page 21 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 7 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 7 of 41 above Licensee Response/NRC Response/NRC Question Closure Id591NRC Question Number KAB-002 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:27 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=591 ITS NRC Questions Id701NRC Question Number KAB-003 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number A-4 JFD Number JFD Bases Number Page Number(s) 22 NRC Reviewer Supervisor Select Technical Branch POC Add Name Conf Call Requested N NRC Question On page 22 of Attachme nt 1, volume 8, the di scussion of changes A04 indicates that "functional unit 10" applies to "(low flow in one loop) and (low flow in one l oop)-" However, in Table TS 3.5.2, function 10 is "low flow in one loop and low flow both loops".

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

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:39 AM Notification NRC/LICENSEE Supervision 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=701 Licensee Response/NRC Response/NRC Question Closure Id311NRC Question Number KAB-003 Select Application Licensee Response Response Date/Time 10/21/2009 2:40 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the statement on Attachment 1, Volume 8, Page 22 of 517, in Discussion of Change A04 should be (Low Flow in One Loop and Low Flow Both Loops).

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

Functional Unit 10 is Low Flow in One Loop and Low Flow Both Loops. Therefore, the sentence on Attachment 1, Volume 8, Page 22 of 517, in Discussion of Change A04 is proposed to be changed to state "For Functional Unit 10 (Low Flow in One Loop and Low Flow Both Loops), the Mode of Applicability is OPERATING because Column 5 lists the permissible bypass conditions for Low Flow in One Lo op as P-8 and for Low Flow in Two Loops as P-7." A draft markup rega rding this change is attached. This change will be reflected in the suppl ement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-003 Markup.pdf (809KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By Gerald Riste Date Added 10/21/2009 2:43 PM Modified By Date Modified 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=311 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 3 of 31 Mode of Applicability is HOT STANDBY because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-6. This means that the Nuclear Source Range channels are blocked when above the P-6 setting. With the P-6

Setting Limit of > 10

-5% RATED POWER, the Nuclear Source Range would not be required to be OPERABLE above HOT STANDBY. For Functional Unit 7 (Low Pressurizer Pressure), 9 (Pressurizer High Water Level), 13 (Undervoltage 4-kV), and 14 (Underfrequency 4-kV), the Mode of Applicability is OPERATING because Column 5 of Table TS 3.5-2 lists the permissible bypass condition as P-7. This means that the Low Pressurizer Pressure channel, the Pressurizer

High Water Level, the Undervoltage 4-kV, and the Underfrequency 4-kV channels are blocked when below the P-7 setting. With the P-7 Setting Limit of > 12.2% RATED POWER, the Low Pressurizer Pressure, the Pressurizer High Water Level, the Undervoltage 4-kV, and the Underfrequency 4-kV would not be required to be OPERABLE below the OPERATING MODE. For Functional Unit

10 (Low Flow in One Loop) and (Low Flow in One Loop), the Mode of

Applicability is OPERATING because Column 5 lists the permissible bypass condition for Low Flow in One Loop as P-8 and for Low Flow in Two Loops as P-7. For the Low Flow in One Loop, this means that the channels are blocked

when below the P-8 setting. With the P-8 Setting Limit of < 10% RATED POWER, Low Flow in One Loop channel would not be required to be

OPERABLE below the OPERATING MODE. For the Low Flow in Two Loops, this means that the channels are blocked when below the P-7 setting. With the P-7 Setting Limit of > 12.2% RATED POWER, the channel would not be required to be OPERABLE below the OPERATING MODE. ITS LCO 3.3.1 requires the

RPS instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 1, 2.a, 2.b, 3.a, 3.b, 4, 6, 7, 8.b, 14, 15, 17, and 18 state that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1 and 2.

ITS Table 3.3.1-1 Function 2.b (Power Range Neutron Flux - Low) states that the APPLICABLE MODE OR OTHER SPECIFIED CONDITIONS is MODE 1

below the P-10 (Power Range Neutron Flux) interlock and MODE 2. ITS Table 3.3.1-1 Function 4 states that the APPLICABLE MODE OR OTHER SPECIFIED

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

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

the CTS.

A05 CTS Table 3.5-2 includes Channels, Coincidence, and setting limits for P-6, P-7, P-8, P-10, and P-13. However, no specific Applicability requirements are provided. ITS Table 3.3.1-1 specifies the Applicable MODES or other specified A ttachment 1, Volume 8, Rev. 0, Page 22 of 517 A ttachment 1, Volume 8, Rev. 0, Page 22 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 11 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 11 of 41 Both Loops Licensee Response/NRC Response/NRC Question Closure Id601NRC Question Number KAB-003 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:29 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=601 ITS NRC Questions Id711NRC Question Number KAB-004 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number A-8 JFD Number JFD Bases Number Page Number(s) 23 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 23 of Attachme nt 1, volume 8, the di scussion of changes A08 indicates that the equivalent CHANNEL CHECK requirement for function 4, is only applicable in MODE 1 above the P-10 interlock and in MODE 2 below the P-6 interlock. Ho wever, in Table 3.3.

1-1 function 4 is applicable in MODE 1 below the P-10 and MODE 2 a bove the P-6.

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

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:41 AM Notification NRC/LICENSEE Supervision 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=711 Licensee Response/NRC Response/NRC Question Closure Id321NRC Question Number KAB-004 Select Application Licensee Response Response Date/Time 10/21/2009 2:45 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the statement on Attachment 1, Volume 8, Page 23 of 517, in Discussion of Change A08 should be "For ITS Table 3.3.1-1 Function 4, ITS SR 3.3.1.1, the equivalent CHANNEL CHECK requirement, is only applicable in MODE 1 below the P-10 (Power Range Neutron Flux) interlocks and in MODE 2 above the P-6 (Intermediate Range Neutron Flux) interlocks consistent with the Applicability of the LCO. A draf t markup regarding this change is attached. This change will be reflected in the suppl ement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-004 Markup.pdf (810KB) Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Riste Date Added 10/21/2009 2:46 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=321 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 4 of 31 conditions associated with the P-6, P-7, P-8, P-10, and P-13 interlocks (Functions 16.a, 16.b, 16.c, 16.d, and 16.e). This changes the CTS by adding specific applicable MODES or other specified conditions associated with P-6, P-7, P-8, P-10, and P-13 interlocks.

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

A06 CTS 4.1.a requires calibration, testing, and checking of protective instrumentation channels and testing of logic channels shall be performed as specified in Table TS 4.1-1. Table TS 4.1-1 requires performance of a TEST at the frequencies shown on Table TS 4.1-1. CTS 4.1.b requires, in part, equipment tests shall be conducted as specified in Table TS 4.1-3. Table TS 4.1-3 requires performance of a TEST at the frequencies shown on Table TS 4.1-3. Table TS 4.1-1 requires performance of a TEST at the frequencies

shown on Table TS 4.1-1. ITS 3.3.1 requires the performance of either a CHANNEL OPERATIONAL TEST (COT), a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), or, in the case of the Automatic Trip Logic, an ACTUATION LOGIC TEST. This changes the CTS by changing the TEST requirements to a COT, a TADOT, or an ACTUATION LOGIC TEST.

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

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

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

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

A08 Note (c) to CTS Table TS 4.1-1, Channel Description 2 and 3 in the Remarks Section states that the Channel Check is required in all plant modes. For ITS Table 3.3.1-1 Function 4, ITS SR 3.3.1.1, the equivalent CHANNEL CHECK requirement, is only applicable in MODE 1 above the P-10 (Power Range Neutron Flux) interlocks and in MODE 2 below the P-6 (Intermediate Range A ttachment 1, Volume 8, Rev. 0, Page 23 of 517 A ttachment 1, Volume 8, Rev. 0, Page 23 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 15 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 15 of 41 below above Licensee Response/NRC Response/NRC Question Closure Id621NRC Question Number KAB-004 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:35 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=621 ITS NRC Questions Id721NRC Question Number KAB-005 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number M-3 JFD Number JFD Bases Number Page Number(s) 28 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 28 of Attachme nt 1, volume 8, the discussion of changes M03 does not mention the Power Range Neutron Flux Nega tive Rate function in the description of ITS 3.3.1 Action E. However, in table 3.3.1-1 the Power range neutron flux rate - high negative rate references Action E. Please explain which is correct or provide the reason for the differences.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:42 AM Notification NRC/LICENSEE Supervision Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=721 Licensee Response/NRC Response/NRC Question Closure Id331NRC Question Number KAB-005 Select Application Licensee Response Response Date/Time 10/21/2009 2:45 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the statement on Attachment 1, Volume 8, Page 28 of 517, in Discussion of Change M03 should incl ude one power Range Neutron Flux - High Negative Rate channel. Therefore, the sentence will be changed to state "ITS 3.3.1 ACTION E provides compensatory acti ons to take when one Power Range Neutron Flux - Low cha nnel, one Power Ra nge Neutron Flux

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

Coincident with Steam Flow/Feedwater Flow Mismatch channel is inoperable and requires placing the inope rable channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or to be in MODE 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />." A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-005 Markup.pdf (817KB) Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Riste Date Added 10/21/2009 2:48 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=331 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 9 of 31 Functional Unit 12 (Lo-Lo Steam Generator Pressure Water Level), Column 3 requires two Lo-Lo Steam Generator Pressure Water Level channels per loop to be OPERABLE. Thus while there are three Lo-Lo Steam Generator Pressure

Water Level channels per loop in the KPS design, the CTS allows one of the Lo-Lo Steam Generator Pressure Water Level channels per loop to be inoperable

for an indefinite period of time; no actions are required for when one of the three Lo-Lo Steam Generator Pressure Water Level channels per loop is inoperable. Table TS 3.5-2 Functional Unit 16 (Steam Flow/Feedwater Flow Mismatch),

Column 3 requires one Steam Flow/Feedwater Flow Mismatch channel to be OPERABLE. Thus while there are two Steam Flow/Feedwater Flow Mismatch channels in the KPS design, the CTS allows one Steam Flow/Feedwater Flow Mismatch channel to be inoperable for an indefinite amount of time; no actions are required when one Steam Flow/Feedwater Flow Mismatch channel is inoperable. ITS LCO 3.3.1 requires the RPS Instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 2.b requires four Power Range Neutron Flux - Low channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.a requires four Power Range Neutron Flux - High Positive Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.b requires four Power Range Neutron Flux - High Negative Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 6 requires four Overte OPERABLE. ITS Table 3.3.1-1 Function 7 requires four OverpoOPERABLE. ITS Table 3.3.1-1 Function 8.a requires three Pressurizer Pressure - High channels to be OPERABLE. ITS Table 3.3.1-1 Function 14 requires three Steam Generator (SG) Water Level - Low Low channels per steam generator to be OPERABLE. ITS Table 3.3.1-1 Function 15 requires two SG Water Level-Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels per steam generator to be OPERABLE. ITS 3.3.1 ACTION E provides compensatory actions to take when one Power Range Neutron Flux - Low channel, one Power Range Neutron Flux - High Positive channel, one Overpower Pressure - High channel, one Steam Generator (SG) Water Level - Low Low channel, or one SG Water Level

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

See DOC L12 for discussion of ACTION Note.

The purpose of the new ITS channel requirement and proposed ACTION is to ensure that appropriate compensatory actions are taken if any of the installed Power Range Neutron Flux - Low, Power Range Neutron Flux - High Positive Rate, Overt Generator (SG) Water Level - Low Low, or SG Water Level - Low - Coincident

with Steam Flow/Feedwater Flow Mismatch channels are inoperable. This change is acceptable because the new channel requirement in ITS Table 3.3.1-1 will ensure that all of the installed RPS channels are required OPERABLE.

A ttachment 1, Volume 8, Rev. 0, Page 28 of 517 A ttachment 1, Volume 8, Rev. 0, Page 28 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 19 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 19 of 41 one Power Range Neutron Flux- High Negative Rate

channel, Licensee Response/NRC Response/NRC Question Closure Id471NRC Question Number KAB-005 Select Application NRC Response Response Date/Time 10/30/2009 10:50 AM Closure Statement Response Statement Please determine if the Power Range Neutron Flux- High Negative Rate function should also be added to the following sentence under M03 on page 28, Attachment 1 volume 8, "The purpose of the new ITS channel requirement and proposed ACTION is to ensure that appropriate compensatory actions are taken if any of the installed Power Range Neutron Flux - Low, Power Range Neutron Flux - High Positive Rate, Overtemperature T, Overpower T, Pressurizer Pressure - High, Steam Generator (SG) Water Level - Low Low, or SG Water Level - Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels are inoperable.

Question Closure Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 10/30/2009 9:50 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/10/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=471 Licensee Response/NRC Response/NRC Question Closure Id501NRC Question Number KAB-005 Select Application Licensee Response Response Date/Time 10/30/2009 3:45 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the statement on Attachment 1, Volume 8, Page 28 of 517, in Discussion of Change M03, second paragraph, should include the Power Range Neutron Flux - High Negati ve Rate channel. Therefore, the sentence will be changed to include this Function. A dr aft markup regarding this change is attached. This draft markup supersedes the previ ous draft markup in the first licensee response (dated 10/21/2009). This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-005 Markup2.pdf (818KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones David Mielke Vic Myers Gerald Riste

Ray Schiele Added By Robert Hanley Date Added 10/30/2009 2:47 PM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/10/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=501 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 9 of 31 Functional Unit 12 (Lo-Lo Steam Generator Pressure Water Level), Column 3 requires two Lo-Lo Steam Generator Pressure Water Level channels per loop to be OPERABLE. Thus while there are three Lo-Lo Steam Generator Pressure

Water Level channels per loop in the KPS design, the CTS allows one of the Lo-Lo Steam Generator Pressure Water Level channels per loop to be inoperable

for an indefinite period of time; no actions are required for when one of the three Lo-Lo Steam Generator Pressure Water Level channels per loop is inoperable. Table TS 3.5-2 Functional Unit 16 (Steam Flow/Feedwater Flow Mismatch),

Column 3 requires one Steam Flow/Feedwater Flow Mismatch channel to be OPERABLE. Thus while there are two Steam Flow/Feedwater Flow Mismatch channels in the KPS design, the CTS allows one Steam Flow/Feedwater Flow Mismatch channel to be inoperable for an indefinite amount of time; no actions are required when one Steam Flow/Feedwater Flow Mismatch channel is inoperable. ITS LCO 3.3.1 requires the RPS Instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 2.b requires four Power Range Neutron Flux - Low channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.a requires four Power Range Neutron Flux - High Positive Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 3.b requires four Power Range Neutron Flux - High Negative Rate channels to be OPERABLE. ITS Table 3.3.1-1 Function 6 requires four Overte OPERABLE. ITS Table 3.3.1-1 Function 7 requires four OverpoOPERABLE. ITS Table 3.3.1-1 Function 8.a requires three Pressurizer Pressure - High channels to be OPERABLE. ITS Table 3.3.1-1 Function 14 requires three Steam Generator (SG) Water Level - Low Low channels per steam generator to be OPERABLE. ITS Table 3.3.1-1 Function 15 requires two SG Water Level-Low - Coincident with Steam Flow/Feedwater Flow Mismatch channels per steam generator to be OPERABLE. ITS 3.3.1 ACTION E provides compensatory actions to take when one Power Range Neutron Flux - Low channel, one Power Range Neutron Flux - High Positive channel, one Overpower Pressure - High channel, one Steam Generator (SG) Water Level - Low Low channel, or one SG Water Level

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

See DOC L12 for discussion of ACTION Note.

The purpose of the new ITS channel requirement and proposed ACTION is to ensure that appropriate compensatory actions are taken if any of the installed Power Range Neutron Flux - Low, Power Range Neutron Flux - High Positive Rate, Overt Generator (SG) Water Level - Low Low, or SG Water Level - Low - Coincident

with Steam Flow/Feedwater Flow Mismatch channels are inoperable. This change is acceptable because the new channel requirement in ITS Table 3.3.1-1 will ensure that all of the installed RPS channels are required OPERABLE.

A ttachment 1, Volume 8, Rev. 0, Page 28 of 517 A ttachment 1, Volume 8, Rev. 0, Page 28 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 22 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 22 of 41 one Power Range Neutron Flux- High Negative Rate channel, Power Range Neutron Flux-High Negative

Rate, Licensee Response/NRC Response/NRC Question Closure Id631NRC Question Number KAB-005 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:37 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=631 ITS NRC Questions Id731NRC Question Number KAB-006 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number M-9 JFD Number JFD Bases Number Page Number(s) 33 NRC Reviewer Supervisor Select Technical Branch POC Add Name Conf Call Requested N NRC Question On page 33 of Attachme nt 1, volume 8, the di scussion of changes M09 indicates that function 1 is the Reactor Trip Breakers (RTBs).

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

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:44 AM Notification NRC/LICENSEE Supervision 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=731 Licensee Response/NRC Response/NRC Question Closure Id341NRC Question Number KAB-006 Select Application Licensee Response Response Date/Time 10/21/2009 2:50 PM Closure Statement Response Statement After further review, Kewaunee Power Station has determ ined that the reference in Attachment 1, Volume 8, Page 33 of 517 in Discussion of Change M09, to ITS Table 3.3.1-1 F unction 1 should be Function 17. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-006 Markup.pdf (798KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Added By Gerald Riste Date Added 10/21/2009 2:50 PM Modified By Date Modified 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=341 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 14 of 31 according to the requirement shown in Column 6 as soon as practicable. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip) Column 6 requires maintaining HOT SHUTDOWN. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip)

Column 6 requires, in part, maintaining HOT SHUTDOWN. Thus, the applicability for these Functional Units is determined to be HOT STANDBY and OPERATING. ITS LCO 3.3.1 requires the RPS instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Manual Reactor Trip as MODES 1 and 2 (equivalent to CTS OPERATING and

HOT STANDBY, respectively); and MODES 3, 4, and 5 (equivalent to CTS HOT SHUTDOWN, INTERMEDIATE SHUTDOWN and COLD SHUTDOWN, respectively) when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Reactor Trip Breakers (RTBs) trains to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or

more rods are not fully inserted, in addition to MODES 1 and 2. ITS Table 3.3.1-1 Function 18 requires the Applicability of the Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted, in addition to MODES 1 and 2. Commensurate with the addition of the new MODES of Applicability, ACTION C was added to address when there is one channel or train inoperable in MODES 3, 4, and 5 when the

Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ACTION C requires that with one channel or train inoperable, to either restore the channel or train to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or to initiate action to fully insert all rods within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and to place the Rod Control System in a condition incapable of rod withdrawal within 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />. Additionally, commensurate with the addition of the new MODES of Applicability, new Surveillance Requirements are being adding. ITS SR 3.3.1.14 has been added for Function 1 to perform a TADOT every 18 months, but is modified by a Note that states that the verification of the setpoint is not required. ITS SR 3.3.1.4 has been added for Function 17 and 18 to perform a TADOT every 31 days, but is modified by a Note, which states that the Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. This changes the CTS by requiring the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains to be OPERABLE in MODES 3, 4, and 5 when the

Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. Furthermore, this change adds an ACTION to take when the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains are inoperable in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. It also adds additional Surveillance Requirements for the new MODE of Applicability.

This change is acceptable because in MODE 3, 4, or 5 if one or more shutdown rods or control rods are withdrawn or the Rod Control System is capable of withdrawing the shutdown rods or the control rods, there is a possibility of an inadvertent control rod withdrawal. Therefore, action must be taken to restore the channel or train or to place the unit in a condition where there are no withdrawn rods and the ability to withdraw rods is precluded. This change is also acceptable because the new Required Actions and Completion Times are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while A ttachment 1, Volume 8, Rev. 0, Page 33 of 517 A ttachment 1, Volume 8, Rev. 0, Page 33 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 26 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 26 of 41 17 Licensee Response/NRC Response/NRC Question Closure Id641NRC Question Number KAB-006 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:39 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=641 ITS NRC Questions Id741NRC Question Number KAB-007 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number L-5 JFD Number JFD Bases Number Page Number(s) 43 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 43 of Attachme nt 1, volume 8, the di scussion of changes L05 indicates that 3.a and 3.b are the Power Range Neutro n Flux Rate -

High Positive Rate functi on. However, in table 3.3.1-1 function 3.a is Power Range Neutron Flux Rate - Hi gh Positive Rate and 3.b is Power Range Neutron Flux Rate - High Nega tive Rate. Please explain which is correct, or provide an ex planation for the discrepancy.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:46 AM Notification NRC/LICENSEE Supervision 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=741 Licensee Response/NRC Response/NRC Question Closure Id351NRC Question Number KAB-007 Select Application Licensee Response Response Date/Time 10/21/2009 2:50 PM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that the statement on Attachment 1, Volume 8, Page 43 of 517, in Discussion of Change L05 for ITS 3.3.1-1 Function 3.b should be Power Range Neutron

Flux Rate - High Negative Rate. Therefore, the sentence will be changed to state "ITS Table 3.3.1-1 Functions 2.a (Power Rang e Neutron Flux - High), 3.a (Power Range Neutron Flux Rate

- High Positive Rate), 3.b (Power Range Neutron Flux Rate - High Ne gative Rate), 6 (O vertemperature T), 7 (Overpower T), 8.a (Pressurizer Pressure - Low), 8.b (Pressurizer Pressure - High), 9 (Pressu rizer Water Level - Hi gh), 10 (Reactor Coolant Flow - Low), 14 (Steam Generator (SG) Water Level

- Low Low), and 15 (SG Water Level - Low and SG Water Level - Low -

Coincident with Steam Flow/Feedwater Flow Mismatch) requir es performance of a COT (ITS SR 3.3.1.7) every 184 da ys." 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-007 Markup.pdf (835KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By Gerald Riste Date Added 10/21/2009 2:53 PM Modified By Date Modified 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=351 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 24 of 31 channels, or Turbine Impulse Pressure, P-13 channels are inoperable and requires verification that the interlock is in the required state for existing unit conditions within 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or to be in MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. This changes the CTS by allowing continued operation as long as the interlock is placed in the correct state for existing unit operation and providing actions if the inoperable interlock is not placed in the correct state.

The purpose of the interlocks is to ensure the associated RPS instrumentation is automatically enabled or disabled when required. This change is acceptable since the proposed ACTIONS ensure that the interlock is either manually placed in the correct state for the existing unit conditions or that the unit is placed in a MODE or specified Condition outside the Applicability of the associated interlock. ITS 3.3.1 Required Action P.1 and Q.1 require the interlock to be placed in the same state as it would be normally placed in if it were automatically functioning (i.e., this performs the intended function of the interlock). If the Required Action is not accomplished within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, then Required Action P.2 and Q.2 require the unit to be placed in a MODE that is outside of the Applicability of the associated interlock. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

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

performed monthly as stated in Remarks (b). CTS Table TS 4.1-1 Channel Description 4 requires a CHANNEL FUNCTIONAL TEST of the Overtemperature

y. CTS Table TS 4.1-1 Channel Description 5 requires a CHANNEL FUNCTIONAL TEST of the Reactor Coolant Flow channels to be performed monthly. CTS Table

TS 4.1-1 Channel Description 6 requires a CHANNEL FUNCTIONAL TEST of the Pressurizer Water Level channels to be performed monthly. CTS Table

TS 4.1-1 Channel Description 7 requires a CHANNEL FUNCTIONAL TEST of the Pressurizer Pressure channels to be performed monthly. CTS Table TS 4.1-1 Channel Description 11.a requires a CHANNEL FUNCTIONAL TEST of the Steam Generator Low Level channels to be performed monthly. CTS Table

TS 4.1-1 Channel Description 12 requires a CHANNEL FUNCTIONAL TEST of the Steam Generator Flow Mismatch channels to be performed monthly. ITS Table 3.3.1-1 Functions 2.a (Power Range Neutron Flux - High), 3.a (Power Range Neutron Flux Rate - High Positive Rate), 3.b (Power Range Neutron Flux Rate - High Positive Rate), 6 (Overt (Pressurizer Pressure - Low), 8.b (Pressurizer Pressure - High), 9 (Pressurizer

Water Level - High), 10 (Reactor Coolant Flow - Low), 14 (Steam Generator (SG) Water Level - Low Low), and 15 (SG Water Level - Low and SG Water

Level - Low - Coincident with Steam Flow/Feedwater Flow Mismatch) requires performance of a COT (ITS SR 3.3.1.7) every 184 days. Additionally, this Surveillance Requirement is modified by a Note, which states that the SR is not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after entry into MODE 3. This changes the CTS by changing the frequency of the Surveillances from monthly and quarterly to 184 days and allowing performance of the source range instrumentation COT A ttachment 1, Volume 8, Rev. 0, Page 43 of 517 A ttachment 1, Volume 8, Rev. 0, Page 43 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 30 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 30 of 41 Negative Licensee Response/NRC Response/NRC Question Closure Id681NRC Question Number KAB-007 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 9:09 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=681 ITS NRC Questions Id751NRC Question Number KAB-008 Category Technical ITS Section 3.3 ITS Number 3.3.1 DOC Number A-4 JFD Number JFD Bases Number Page Number(s) 22 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 22 of Attachme nt 1, volume 8, the discussion of changes A04 states that "For Functional Unit 7 (Low Pressurizer Pressure), 9 (Pressurizer High Water Level), 13 (Undervoltage 4-kV), and 14 (Underfrequency 4-kV), the Mode of Applicability is OPERATING because Column 5 of Table TS 3.5-2 lists the permissible bypass conditi on as P-7." However, the Kewaunee UFSAR section 7.

2.2.4.14 item 3 st ates that "An underfrequency signal from both 4160V buses (Buses 1-1 and 1-2) results in the trip of both reactor cool ant pump breakers. There are two underfrequency relays per bus." In addition, the Kewaunee current Technical Specifications Table TS 3.5-2 functional unit 14 does not list the P-7 interlock under column 5, "permissible bypass cond itions." The UFSAR section 7.2.2.4.14 it em 3 does not mention the P-7 interlock. However UFSAR Table 7.2-1 does state that the RCP bus underfrequency is blocked below P-7. Please explain how the P-7 re lay affects the RCP bus underfrequency logic circuitry, including a description of the logic path from the RCP underfrequency relay to the reactor trip.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=751 Modified Modified By Date Added 10/19/2009 10:47 AM Notification NRC/LICENSEE Supervision Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=751 Licensee Response/NRC Response/NRC Question Closure Id411NRC Question Number KAB-008 Select Application Licensee Response Response Date/Time 10/28/2009 9:30 AM Closure Statement Response Statement The NRC reviewer is correct in that CTS Table TS 3.5-2 Functional Unit 14 does not list the P-7 interlock in Column

5. However, Function Unit 14 is modified by footnote 4, which stat es that Underfre quency on the 4-kV buses trips the Reactor Coolant Pump breakers, which in turn trips the reactor when power is ab ove P-7. Thus, for Functiona l Unit 14, the reactor trip is only required above P-7, and the proposed Appl icability in the ITS is correct. Attached is a simplifi ed diagram of Kewaunee' s underfreque ncy reactor trip logic. Kewaunee h as a trip logic starting with four underfrequency relays two on each of the reactor coolant pump electric supply buses.

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

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

Question Closure Date Attachment 1 KAB-008-Attachment.pdf (97KB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Victor Cusumano Robert Hanley Jerry Jones Bryan Kays Vic Myers Gerald Riste Pa ge 1of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=411 Ray Schiele Added By Robert Hanley Date Added 10/28/2009 9:30 AM Modified By Date Modified Pa ge 2of 2 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=411 SimplifiedReactorCoolantPumpBusUnderfrequencyTripLogic Licensee Response/NRC Response/NRC Question Closure Id611NRC Question Number KAB-008 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:33 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=611 ITS NRC Questions Id761NRC Question Number KAB-009 Category Editorial ITS Section 3.3 ITS Number 3.3.1 DOC Number M-9 JFD Number JFD Bases Number Page Number(s) 33 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question On page 33 of Attachme nt 1, volume 8, the discussion of changes M09 has two sentences that indicate Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip) Column 6 requires ma intaining HOT SHUTDOWN. Please provide an explanation.

Attach File 1 Attach File 2 Issue Date 10/19/2009 Added By Kristy Bucholtz Date Modified Modified By Date Added 10/19/2009 10:49 AM Notification NRC/LICENSEE Supervision 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=761 Licensee Response/NRC Response/NRC Question Closure Id361NRC Question Number KAB-009 Select Application Licensee Response Response Date/Time 10/21/2009 2:55 PM Closure Statement Response Statement After further review, Kewaunee Power St ation has determin ed that one of the two sentences in Attach ment 1, Volume 8, Page 33 of 517 in Discussion of Change M09, related to Table TS 3.5-2 Functional Unit 1 incorrectly references CTS Table TS 3.5-2 Functional Unit 1. The second sentence should reference CTS Table TS 3.5-2 Functional Unit 17. A draft markup regarding this change is attached.

This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment 1 KAB-009 Markup.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Kristy Bucholtz Jerry Jones Bryan Kays Added By Gerald Riste Date Added 10/21/2009 2:56 PM Modified By Date Modified 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=361 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION Kewaunee Power Station Page 14 of 31 according to the requirement shown in Column 6 as soon as practicable. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip) Column 6 requires maintaining HOT SHUTDOWN. Table TS 3.5-2 Functional Unit 1 (Manual Reactor Trip)

Column 6 requires, in part, maintaining HOT SHUTDOWN. Thus, the applicability for these Functional Units is determined to be HOT STANDBY and OPERATING. ITS LCO 3.3.1 requires the RPS instrumentation in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Manual Reactor Trip as MODES 1 and 2 (equivalent to CTS OPERATING and

HOT STANDBY, respectively); and MODES 3, 4, and 5 (equivalent to CTS HOT SHUTDOWN, INTERMEDIATE SHUTDOWN and COLD SHUTDOWN, respectively) when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ITS Table 3.3.1-1 Function 1 specifies the Applicability of the Reactor Trip Breakers (RTBs) trains to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or

more rods are not fully inserted, in addition to MODES 1 and 2. ITS Table 3.3.1-1 Function 18 requires the Applicability of the Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms to be MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted, in addition to MODES 1 and 2. Commensurate with the addition of the new MODES of Applicability, ACTION C was added to address when there is one channel or train inoperable in MODES 3, 4, and 5 when the

Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. ACTION C requires that with one channel or train inoperable, to either restore the channel or train to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or to initiate action to fully insert all rods within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and to place the Rod Control System in a condition incapable of rod withdrawal within 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />. Additionally, commensurate with the addition of the new MODES of Applicability, new Surveillance Requirements are being adding. ITS SR 3.3.1.14 has been added for Function 1 to perform a TADOT every 18 months, but is modified by a Note that states that the verification of the setpoint is not required. ITS SR 3.3.1.4 has been added for Function 17 and 18 to perform a TADOT every 31 days, but is modified by a Note, which states that the Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service. This changes the CTS by requiring the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains to be OPERABLE in MODES 3, 4, and 5 when the

Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. Furthermore, this change adds an ACTION to take when the Manual Reactor Trip channels and the Reactor Trip Breakers (RTBs) trains are inoperable in MODES 3, 4, and 5 when the Rod Control System is capable of rod withdrawal or when one or more rods are not fully inserted. It also adds additional Surveillance Requirements for the new MODE of Applicability.

This change is acceptable because in MODE 3, 4, or 5 if one or more shutdown rods or control rods are withdrawn or the Rod Control System is capable of withdrawing the shutdown rods or the control rods, there is a possibility of an inadvertent control rod withdrawal. Therefore, action must be taken to restore the channel or train or to place the unit in a condition where there are no withdrawn rods and the ability to withdraw rods is precluded. This change is also acceptable because the new Required Actions and Completion Times are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while A ttachment 1, Volume 8, Rev. 0, Page 33 of 517 A ttachment 1, Volume 8, Rev. 0, Page 33 of 517 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 40 of 41 Enclosure (1 of 8), Q&A to Attachment 1, Volume 8 (Section 3.3) Page 40 of 41 17 (Reactor Trip Breakers and Independently Test Shunt and Undervoltage Trip Attachments)

Licensee Response/NRC Response/NRC Question Closure Id651NRC Question Number KAB-009 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 11/9/2009 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Kristy Bucholtz Date Added 11/9/2009 8:40 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/08/2010 htt p://www.excelservices.com/rai/index.

p h p?re q uestT ype=areaItemPrint&itemId=651

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