Text

Attachment 1, Volume 9, Revision 1, Kewaunee Power Station Improved Technical Specifications Conversion, ITS Section 3.4 Reactor Coolant System (RCS)
	ML101890218
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Site:	Kewaunee
Issue date:	07/01/2010
From:	; Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
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	Download: ML101890218 (479)
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Summary of Changes ITS Section 3.4 Page 1 of 1 Change Description Affected Pages The changes described in the KPS response to question RPG-007 have been made. This change adds ISTS 3.4.5 Required Action D.1 into the KPS ITS. Pages 87, 90, and 98 The changes described in the KPS response to question RPG-008 have been made. This change deletes the containment humidity monitor requirements from ITS 3.

4.15. Note that these requirements are not currently in the CTS. Pages 341, 343, 345, 346, 347, 348, 349, 351, 352, 353, 354, 355, 359, 360, 361, 362, 363, 364, and 365 The changes described in the KPS response to question RPG-005 have been made. This change deletes the Notes from ITS SR 3.4.16.1 and 3.4.16.2. Pages 372, 374, 375, 380, 383, 393, 394, and 395

ATTACHMENT 1 VOLUME 9 KEWAUNEE POWER STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.4 REACTOR COOLANT SYSTEM (RCS)

Revision 1

LIST OF ATTACHMENTS

1. ITS 3.4.1

2. ITS 3.4.2

3. ITS 3.4.3

4. ITS 3.4.4

5. ITS 3.4.5

6. ITS 3.4.6

7. ITS 3.4.7

8. ITS 3.4.8

9. ITS 3.4.9

10. ITS 3.4.10

11. ITS 3.4.11

12. ITS 3.4.12

13. ITS 3.4.13

14. ITS 3.4.14

15. ITS 3.4.15

16. ITS 3.4.16

17. ITS 3.4.17

18. Relocated/Deleted Current T echnical Specifications (CTS)

19. ISTS Not Adopted

ATTACHMENT 1 ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS 3.4.1A01ITS g. Inoperable Rod Limitations

1. An inoperable rod is a rod which does not trip or which is declared inoperable under TS 3.10.e or TS 3.10.h.

2. Not more than one inoperable full length rod shall be allowed at any time.

3. If reactor operation is continued with one i noperable full length rod, the potential ejected rod worth and associated transient power distribution peaking factors shall be determined by analysis within 30 days unless the rod is made OPERABLE earlier. The analysis shall include due allowance for nonuniform fuel depletion in the neighborhood of the inoperable rod. If the analysis results in a more limiting hypothetical transient than the cases reported in the safety analysis, the plant power level shall be reduced to an analytically determined part power level which is consistent with the safety analysis.

h. Rod Drop Time

At OPERATING temperature and full flow, the drop time of each full length rod cluster control shall be no greater than 1.8 seconds from loss of stationary gripper coil voltage

to dashpot entry. If drop time is > 1.8 seconds, the rod shall be declared inoperable.

i. Rod Position Deviation Monitor

If the rod position deviation monitor is inoperable, individual rod positions shall be logged at least once per eight hours and after a load change > 10% of rated power or

after > 24 steps of control rod motion. hours and after a load change > 10% of rated power or after > 24 steps of control rod motion.

j. Quadrant Power Tilt Monitor j. Quadrant Power Tilt Monitor If one or both of the quadrant power tilt monitors is inoperable, individual upper and lower excore detector calibrated outputs and the quadrant tilt shall be logged once per shift and after a load change > 10% of rated power or after > 24 steps of control rod motion. The monitors shall be set to alarm at 2% tilt ratio. If one or both of the quadrant power tilt monitors is inoperable, individual upper and lower excore detector calibrated outputs and the quadrant tilt shall be logged once per shift and after a load change > 10% of rated power or after > 24 steps of control rod motion. The monitors shall be set to alarm at 2% tilt ratio. See ITS 3.2.4 See ITS 3.1.4 k. Core Average Temperature k. Core Average Temperature During steady-state power operation, Tavg , shall be maintained within the limits specified in the COLR, except as provided by TS 3.10.n. During steady-state power operation, Tavg , shall be maintained within the limits specified in the COLR, except as provided by TS 3.10.n. LCO 3.4.1.b A pplicabilit y l. Reactor Coolant System Pressure l. Reactor Coolant System Pressure During steady-state power operation, Reactor Coolant System pressure shall be

maintained within the limits specified in t he COLR, except as provided by TS 3.10.n. During steady-state power operation, Reactor Coolant System pressure shall be

maintained within the limits specified in t he COLR, except as provided by TS 3.10.n. Add proposed Applicability Notes a and b L01 LCO 3.4.1.a A pplicabilit y Amendment No. 181 TS 3.10-7 Revised by letter dated 11/03/06 Page 1 of 2 ITS 3.4.1A01ITS m. Reactor Coolant Flow

1. During steady-state power operation, reactor coolant total flow rate shall be 178,000 gallons per minute average and greater than or equal to the limit specified in the COLR.

If reactor coolant flow rate is not within the limits as specified in the COLR, action shall

be taken in accordance with TS 3.10.n.

LCO 3.4.1.c A pplicabilit y 2. Compliance with this flow requirement shall be demonstrated by verifying the reactor coolant flow during initial power escalation following each REFUELING, at or above

90% power with plant parameters as constant as practical.

LA01A02 SR 3.4.1.4 Note SR 3.4.1.4

n. DNBR Parameters If, during power operation any of the conditions of TS 3.10.k, TS 3.10.l, or TS 3.10.m.1 are not met, restore the parameter in two hours or less to within limits or reduce power to < 5% of thermal rated power within an additional six hours. Following analysis, thermal power may be raised not to exceed a power level analyzed to maintain a DNBR

greater than the minimum DNBR limit. M01 A CTION B A CTION A Add proposed SR 3.4.1.1, SR 3.4.1.2, and SR 3.4.1.3 M02 Amendment No. 181 TS 3.10-8 03/24/2005 Page 2 of 2 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.10.m.2 states, in part, that compliance with the reactor coolant total flow rate shall be demonstrated by verifying the reactor coolant flow during initial power escalation following each REFUELING, at or above 90% power "with plant parameters as constant as practical." ITS SR 3.4.1.4 requires measurement of the RCS total flow rate and is modified by a Note which states, "Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 90% RTP." This changes the CTS by explicitly specifying the time required to perform the Surveillance after entering MODE 1 conditions. That is, it defines how long the plant has to get the parameters constant.

This change is acceptable because the Note applies a specific period of time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) to establish stable operating conditions. In CTS, the time period is not specific and can vary from outage to outage. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.10.m states, in part, that if the reactor coolant flow is not restored to within limits to reduce power to < 5% of thermal rated power. It further states that following analysis, thermal power may be raised not to exceed a power level analyzed to maintain a departure from nucleate boiling ratio (DNBR) greater than the minimum DNBR limit. ITS 3.4.1 ACTION B requires that if the RCS DNB parameters are not restored to be in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by not allowing an analysis to be performed to raise THERMAL POWER.

The purpose of CTS 3.10.m is to ensure that the minimum DNBR will be met for each of the analyzed transients. ITS 3.4.1 ACTION B continues to maintain this assurance by exiting the MODE of Applicability when the RCS DNB parameters cannot be restored to within limits, thereby restoring the DNB margin and eliminating the potential for violation of the accident analysis bounds. Therefore, there is no need to perform an analysis as power will not be allowed to be increased until the parameters are within the limits. This change is designated as more restrictive because the ITS will no longer include an allowance for raising power based on an analysis.

M02 ITS SR 3.4.1.1 requires verification that the pressurizer pressure is greater than or equal to the limit specified in the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.1.2 requires verification that the RCS average temperature is less than or equal to the limit specified in the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.1.3 requires Kewaunee Power Station Page 1 of 3 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS verification that the RCS total flow rate is 178,000 gpm and greater than or equal to the limit specified in the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS does not contain these Surveillance Requirements. This changes the CTS by adding Surveillance Requirements to verify that the pressurizer pressure is greater than or equal to the limit specified in the COLR, the RCS average temperature is less than or equal to the limit specified in the COLR, and the RCS total flow rate is 178,000 gpm and greater than or equal to the limit specified in the COLR.

This change is acceptable because the added Surveillance Requirement provide additional assurance that the RCS DNB parameters are within the limits specified in the COLR. This change is designated as more restrictive because new Surveillance Requirements are added.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES

LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)

CTS 3.10.m.2 states, in part, that compliance with the reactor coolant flow rate requirement shall be demonstrated by verifying the reactor coolant flow during initial power escalation following each REFUELING. ITS SR 3.4.1.4 requires verification by precision heat balance that RCS total flow

rate is 178,000 gpm and greater than or equal to the limit specified in the COLR every 18 months. This SR is modified by a Note which states that the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 90% RTP. This changes the CTS by removing the procedural detail of "during initial power escalation" to the Bases.

The removal of this detail for performing the Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform a precision heat balance every 18 months. Also this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for evaluation of changes to ensure the Bases are properly controlled.

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

LESS RESTRICTIVE CHANGES

L01 (Category 2 - Relaxation of Applicability) CTS 3.10.l states, in part, that during steady-state power operations, the Reac tor Coolant System (RCS) pressure shall be maintained within the limits specified in the COLR. ITS 3.4.1.a requires Kewaunee Power Station Page 2 of 3 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS Kewaunee Power Station Page 3 of 3 the RCS DNB parameters for pressurizer pressure to be within limits during MODE 1, but the Applicability is modified by a Note. The Note states that the pressurizer pressure limit does not apply during THERMAL POWER ramp > 5%

RTP per minute or THERMAL POWER step > 10% RTP. This changes the CTS by allowing the pressurizer pressure limit to be outside of its limit during THERMAL POWER ramp > 5% RTP per minute or THERMAL POWER step

> 10% RTP.

The purpose of CTS 3.10.l is to ensure the RCS pressure is consistent with operation within the nominal operational envelope. ITS 3.4.1 continues to ensure the RCS pressure is consistent with this same operational envelope. The addition of the Note is to allow short term perturbations where actions to control the pressure variations could be counterproductive. Furthermore, since these proposed Note allowances represent transients initiated from power levels

< 100 % RTP, an increased DNBR margin exists to offset the temporary pressure variations. This change is designated as less restrictive because an allowance for pressurizer pressure to be outside its limits is allowed in the ITS that is not allowed in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 WOG STS 3.4.1-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB)

Limits LCO 3.4.1 RCS DNB parameters for pressurizer pressure, RCS average temperature, and RCS total flow rate shall be within the limits specified

below: a. Pressurizer pressure is greater than or equal to the limit specified in the COLR, 3.10.l 1 b. RCS average temperature is less than or equal to the limit specified in the COLR, and

3.10.k 1

c. RCS total flow rate [284,000] gpm and greater than or equal to the limit specified in the COLR.

178,000 2 3.10.m.1

3.10.l, 3.10.k, 3.10.m.1 APPLICABILITY: MODE 1.

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

Pressurizer pressure limit does not apply during: DOC L01 1 a. THERMAL POWER ramp > 5% RTP per minute or

b. THERMAL POWER step > 10% RTP. --------------------------------------------------------------------------------------------------

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more RCS DNB parameters not within limits. A.1 Restore RCS DNB parameter(s) to within limit.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B. Required Action and associated Completion Time not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.10.n 3.10.n

RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 WOG STS 3.4.1-2 Rev. 3.0, 03/31/04 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure is greater than or equal to the limit specified in the COLR.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.1.2 Verify RCS average temperature is less than or equal to the limit specified in the COLR.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.1.3 Verify RCS total flow rate is [284,000] gpm and greater than or equal to the limit specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.1.4 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after

[90]% RTP. ---------------------------------------------------------------------

Verify by precision heat balance that RCS total flow rate is [284,000] gpm and greater than or equal to the limit specified in the COLR.

[18] months DOC M02 DOC M02 178,000 2DOC M02 3.10.m.2 2 2178,000 JUSTIFICATION FOR DEVIATIONS ITS 3.1.4, RCS PRESSURE, TEMPERATURE AND FLOW DNB LIMITS

1. The punctuation corrections have been made consistent with the Writer's Guide for the Improved Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. The ITS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 WOG STS B 3.4.1-1 Rev. 3.0, 03/31/04 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits

BASES BACKGROUND These Bases address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses.

The safety analyses (Ref. 1) of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on RCS pressure, temperature, and flow rate ensure that the minimum departure from nucleate boiling ratio (DNBR) will be met for each of the transients

analyzed.

1Condition I and II The RCS pressure limit is consistent with operation within the nominal operational envelope. Pressurizer pressure indications are averaged to come up with a value for comparison to the limit. A lower pressure will cause the reactor core to approach DNB limits.

The RCS coolant average temperature limit is consistent with full power operation within the nominal operational envelope. Indications of

temperature are averaged to determine a value for comparison to the limit. A higher average temperature will cause the core to approach DNB limits. The RCS flow rate normally remains constant during an operational fuel

cycle with all pumps running. The minimum RCS flow limit corresponds to that assumed for DNB analyses. Flow rate indications are averaged to come up with a value for comparison to the limit. A lower RCS flow will cause the core to approach DNB limits.

Operation for significant periods of time outside these DNB limits increases the likelihood of a fuel cladding failure in a DNB limited event.

APPLICABLE The requirements of this LCO represent the initial conditions for DNB SAFETY limited transients analyzed in the plant safety analyses (Ref. 1). The ANALYSES safety analyses have shown that transients initiated from the limits of this LCO will result in meeting the DNBR criterion. This is the acceptance limit for the RCS DNB parameters. Changes to the unit that could impact these parameters must be assessed for their impact on the DNBR criteria. The transients analyzed for include loss of coolant flow events and dropped or stuck rod events. A key assumption for the analysis of these events is that the core power distribution is within the limits of LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)." Condition I and II 1 1partial RCCA misalignment 1

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 WOG STS B 3.4.1-2 Rev. 3.0, 03/31/04 BASES APPLICABLE SAFETY ANALYSES (continued)

The pressurizer pressure limit and RCS average temperature limit specified in the COLR correspond to the analytical limits used in the safety analyses, with allowance for measurement uncertainty.

The RCS DNB parameters satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

limits 3 LCO This LCO specifies limits on the monitored process variables - pressurizer pressure, RCS average temperature, and RCS total flow rate - to ensure the core operates within the limits assumed in the safety analyses. These variables are contained in the COLR to provide operating and analysis flexibility from cycle to cycle. However, the minimum RCS flow, usually based on [maximum analyzed steam generator tube plugging], is retained in the TS LCO. Operating within these limits will result in meeting the DNBR criterion in the event of a DNB limited transient.

2 RCS total flow rate contains a measurement error based on performing a precision heat balance and using the result to calibrate the RCS flow rate indicators. Potential fouling of the feedwater venturi, which might not be detected, could bias the result from the precision heat balance in a nonconservative manner. Therefore, a penalty for undetected fouling of

the feedwater venturi raises the nominal flow measurement allowance for no fouling.

Any fouling that might bias the flow rate measurement greater than the penalty for undetected fouling of the feedwater venturi can be detected by monitoring and trending various plant performance parameters. If detected, either the effect of the fouling shall be quantified and compensated for in the RCS flow rate measurement or the venturi shall be cleaned to eliminate the fouling.

The numerical values for pressure, temperature, and flow rate specified in the COLR are given for the measurement location and have been adjusted for instrument error. pressurizer RCS averageRCS total INSERT 1 1 APPLICABILITY In MODE 1, the limits on pressurizer pressure, RCS coolant average temperature, and RCS flow rate must be maintained during steady state operation in order to ensure DNBR criteria will be met in the event of an unplanned loss of forced coolant flow or other DNB limited transient. In all other MODES, the power level is low enough that DNB is not a concern.

B 3.4.1 4 INSERT 1 RCS flow indication calibration must include appropriate considerations for the accuracy of feedwater flow measurement. KPS can employ ei ther of two methods to measure feedwater flow; an installed Crossflow Ultrasonic Flow Measurement System (Crossflow System), or in-line feedwater flow venturis. Unlike the feedwater venturis, the Crossflow System is not susceptible to fouling during use and possesses a higher accuracy. These attributes make the Crossflow System the preferred method of measuring feedwater flow as an input to the determination of RCS flow.

In the event the Crossflow System is not available, the feedwater venturis are used to calibrate the RCS flow indicators. Because the feedwater venturis are susceptible to fouling during use, a nonconservative bias in RCS flow indicators might develop over time. Therefore, when the feedwater venturis are used to calibrate the RCS flow rate indicators, a penalty for undetected fouling of the feedwater venturis may be applied to raise the nominal flow measurement. The penalty is described in Specification 5.6.3.b. The need for such a bias would be detected by monitoring and trending various plant performance parameters.

Insert Page B 3.4.1-2 RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 WOG STS B 3.4.1-3 Rev. 3.0, 03/31/04 BASES APPLICABILITY (continued)

A Note has been added to indicate the limit on pressurizer pressure is not applicable during short term operational transients such as a THERMAL POWER ramp increase > 5% RTP per minute or a THERMAL POWER step increase > 10% RTP. These conditions represent short term perturbations where actions to control pressure variations might be counterproductive. Also, since they represent transients initiated from power levels < 100% RTP, an increased DNBR margin exists to offset the temporary pressure variations.

The DNBR limit is provided in SL 2.1.1, "Reactor Core SLs." The conditions which define the DNBR limit are less restrictive than the limits of this LCO, but violation of a Safety Limit (SL) merits a stricter, more severe Required Action. Should a violation of this LCO occur, the operator must check whether or not an SL may have been exceeded.

ACTIONS A.1 RCS pressure and RCS average temperature are controllable and measurable parameters. With one or both of these parameters not within LCO limits, action must be taken to restore parameter(s).

RCS total flow rate is not a controllable parameter and is not expected to vary during steady state operation. If the indicated RCS total flow rate is below the LCO limit, power must be reduced, as required by Required Action B.1, to restore DNB margin and eliminate the potential for violation of the accident analysis bounds.

A 3 The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for restoration of the parameters provides sufficient time to adjust plant parameters, to determine the cause for the off normal condition, and to restore the readings within limits, and is based on plant operating experience.

B.1 If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable to reach the required plant conditions in an orderly manner.

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 WOG STS B 3.4.1-4 Rev. 3.0, 03/31/04 BASES SURVEILLANCE SR 3.4.1.1 REQUIREMENTS Since Required Action A.1 allows a Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore parameters that are not within limits, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Surveillance Frequency for pressurizer pressure is sufficient to ensure the pressure can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety analysis assumptions.

SR 3.4.1.2

Since Required Action A.1 allows a Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore parameters that are not within limits, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Surveillance Frequency for RCS average temperature is sufficient to ensure the temperature can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety analysis assumptions.

SR 3.4.1.3 The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Surveillance Frequency for RCS total flow rate is performed using the installed flow instrumentation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess potential degradation and to verify operation within safety analysis assumptions.

SR 3.4.1.4

Measurement of RCS total flow rate by performance of a precision calorimetric heat balance once every [18] months allows the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate.

2 2The Frequency of [18] months reflects the importance of verifying flow after a refueling outage when the core has been altered, which may have caused an alteration of flow resistance.

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 WOG STS B 3.4.1-5 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note that allows entry into MODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be

performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after [90%] RTP. This exception is appropriate since the heat balance requires the plant to be at a minimum of

[90%] RTP to obtain the stated RCS flow accuracies. The Surveillance shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching [90%] RTP.

2 2 REFERENCES 1. FSAR, Section [15].

U 1 2Chapter 14

JUSTIFICATION FOR DEVIATIONS ITS 3.4.1 BASES, RCS PRESSURE, TEMPERATURE AND FLOW DNB LIMITS

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. The ITS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

3. Typographical error corrected.

4. KPS normally uses the Crossflow Ultrasonic Flow Measurement System Crossflow System) in lieu of flow venturis. Therefore, the Bases have been modified accordingly. The Crossflow System was approved for use at KPS by the NRC in License Amendment 168 (ADAMS Accession No. ML031530734).

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.1, RCS PRESSURE, TEMPERATURE AND FLOW DNB LIMITS There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 2 ITS 3.4.2, RCS MINIMUM TE MPERATURE FOR CRITICALITY Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS 3.4.2 Add Proposed ITS 3.4.2 M01 Page 1 of 1 DISCUSSION OF CHANGES ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY ADMINISTRATIVE CHANGES None

MORE RESTRICTIVE CHANGES

M01 The CTS does not have any requirements for RCS minimum temperature for criticality. ITS 3.4.2 requires that each RCS loop average temperature (Tavg) shall be 540ºF in MODE 1 and in MODE 2 with k eff 1.0. This changes the CTS by incorporating the requirements of ISTS 3.4.2. The ITS also provides an Action for when Tavg in one or more RCS loops is not within limits (ACTION A) and a Surveillance Requirement (SR 3.4.2.1).

The primary function of the RCS loop aver age temperature limit is to ensure that the reactor will not be made or maintained critical at a temperature less than that assumed in the safety analysis. This change is acceptable because each RCS loop average temperature is now required to be 540º when in MODE 1 and in MODE 2 with k eff 1.0. All low power safety analyses assume initial RCS loop temperatures the HZP temperature of 547°F. The minimum temperature for criticality limitation provides a small band, 7°F, for critical operation below HZP.

This band allows critical operation below HZP during plant startup and does not adversely affect any safety analyses. In addition, the MTC is explicitly considered in the safety analysis process by verifying key input parameters to transient analyses at conditions which bound the MTC. This change has been designated as more restrictive because it adds a new requirement to the CTS.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES None

LESS RESTRICTIVE CHANGES None Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Minimum Temperature for Criticality 3.4.2 WOG STS 3.4.2-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.2 RCS Minimum Temperature for Criticality

LCO 3.4.2 Each RCS loop average temperature (Tavg) shall be [541]°F.

APPLICABILITY: MODE 1, MODE 2 with k eff 1.0.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. Tavg in one or more RCS loops not within limit.

A.1 Be in MODE 2 with K eff < 1.0.

30 minutes 540 2 1DOC M01 DOC M01 DOC M01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.4.2.1 Verify RCS Tavg in each loop [541]°F.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 540 1DOC M01 JUSTIFICATION FOR DEVIATIONS ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY

1. The ITS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

2. Typographical/grammatical error corrected.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Minimum Temperature for Criticality B 3.4.2 WOG STS B 3.4.2-1 Rev. 3.0, 03/31/04 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.2 RCS Minimum Temperature for Criticality

BASES BACKGROUND This LCO is based upon meeting several major considerations before the reactor can be made critical and while the reactor is critical.

The first consideration is moderator temperature coefficient (MTC),

LCO 3.1.3, "Moderator Temperature Coefficient (MTC)." In the transient and accident analyses, the MTC is assumed to be in a range from slightly positive to negative and the operating temperature is assumed to be within the nominal operating envelope while the reactor is critical. The LCO on minimum temperature for criticality helps ensure the plant is operated consistent with these assumptions.

The second consideration is the protective instrumentation. Because certain protective instrumentation (e.g., excore neutron detectors) can be

affected by moderator temperature, a temperature value within the nominal operating envelope is chosen to ensure proper indication and response while the reactor is critical.

The third consideration is the pressurizer operating characteristics. The transient and accident analyses assume that the pressurizer is within its normal startup and operating range (i.e., saturated conditions and steam bubble present). It is also assumed that the RCS temperature is within its normal expected range for startup and power operation. Since the density of the water, and hence the response of the pressurizer to transients, depends upon the initial temperature of the moderator, a minimum value for moderator temperature within the nominal operating envelope is chosen.

The fourth consideration is that the reactor vessel is above its minimum nil ductility reference temperature when the reactor is critical.

APPLICABLE Although the RCS minimum temperature for criticality is not itself an initial SAFETY condition assumed in Design Basis Accidents (DBAs), the closely aligned ANALYSES temperature for hot zero power (HZP) is a process variable that is an initial condition of DBAs, such as the rod cluster control assembly (RCCA)

withdrawal, RCCA ejection, and main steam line break accidents performed at zero power that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. uncontrolled RCS Minimum Temperature for Criticality B 3.4.2 WOG STS B 3.4.2-2 Rev. 3.0, 03/31/04 BASES

APPLICABLE SAFETY ANALYSES (continued)

All low power safety analyses assume initial RCS loop temperatures the HZP temperature of 547°F (Ref. 1). The minimum temperature for criticality limitation provides a small band, 6°F, for critical operation below HZP. This band allows critical operation below HZP during plant startup and does not adversely affect any safety analyses since the MTC is not significantly affected by the small temperature difference between HZP and the minimum temperature for criticality.

7 In addition, the MTC is explicitly considered in the safety analysis process by verifying key input parameters to transient analyses at conditions which bound the MTC.

3 3The RCS minimum temperature for criticality satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO Compliance with the LCO ensures that the reactor will not be made or maintained critical (keff 1.0) at a temperature less than a small band below the HZP temperature, which is assumed in the safety analysis.

Failure to meet the requirements of this LCO may produce initial conditions inconsistent with the initial conditions assumed in the safety analysis.

APPLICABILITY In MODE 1 and MODE 2 with k eff 1.0, LCO 3.4.2 is applicable since the reactor can only be critical (k eff 1.0) in these MODES.

The special test exception of LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 2," permits PHYSICS TESTS to be performed at 5% RTP with RCS loop average temperatures slightly lower than normally allowed so that fundamental nuclear characteristics of the core can be verified. In order for nuclear characteristics to be accurately measured, it may be necessary to operate outside the normal restrictions of this LCO. For example, to measure the MTC at beginning of cycle, it is necessary to allow RCS loop average temperatures to fall below T no load, which may cause RCS loop average temperatures to fall below the temperature limit of this LCO.

ACTIONS A.1 If the parameters that are outside the limit cannot be restored, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 2 with K eff < 1.0 within 30 minutes. Rapid reactor shutdown can be readily and practically achieved within a 30 minute period. The allowed time is reasonable, based on operating experience, to reach MODE 2 with K eff < 1.0 in an orderly manner and without challenging plant systems.

1 1 RCS Minimum Temperature for Criticality B 3.4.2 WOG STS B 3.4.2-3 Rev. 3.0, 03/31/04 BASES SURVEILLANCE SR 3.4.2.1 REQUIREMENTS RCS loop average temperature is required to be verified at or above [541]°F every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The SR to verify RCS loop average temperatures every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months takes into account indications and alarms that are continuously available to the operator in the control room and is consistent with other routine Surveillances which are typically performed once per shift. In addition, operators are trained to be sensitive to RCS temperature during approach to criticality and will ensure that the minimum temperature for criticality is met as criticality is approached.

540 2 REFERENCES 1. FSAR, Section [15.0.3].

U 3 2Chapter 14

JUSTIFICATION FOR DEVIATIONS ITS 3.4.2 BASES, RCS MINIMUM TEMPERATURE FOR CRITICALITY

1. Typographical/grammatical error corrected.

2. The ITS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

3. 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.

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 3 ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01 ITS 3.4.3 ITS b. Heatup and Cooldown Limit Curves for Normal Operation

1. The reactor coolant temperature and pressure and system heatup and cooldown rates (with the exception of the pressurizer) shall be limited in accordance with Figures TS 3.1-1 and TS 3.1-2. Figures TS 3.1-1 and TS 3.1-2 are applicable for the

service period of up to 33 (1) effective full-power years.

A. Allowable combinations of pressure and temperature for specific temperature change rates are below and to the right of the limit lines shown. Limit lines for

cooldown rates between those presented may be obtained by interpolation.

B. Figures TS 3.1-1 and TS 3.1-2 define limits to assure prevention of non-ductile failure only. For normal operation other inherent plant characteristics, e.g.,

pump heat addition and pressurizer heater capacity may limit the heatup and cooldown rates that can be achieved over certain pressure-temperature ranges.

LA02M02M01 Add proposed Applicability Figures 3.4.3-1 and

3.4.3-2 LCO 3.4.3 Add proposed ACTIONS, A, B, and CLA01C. The isothermal curve in Figure TS 3.1-2 defines limits to assure prevention of non-ductile failure applicable to low temperature overpressurization events only. Application of this curve is limited to evaluation of LTOP events whenever one or more of the RCS cold leg temperatures are less than or equal to the LTOP enabling temperature of 200 F. 2. The secondary side of the steam generator must not be pressurized > 200 psig if the temperature of the steam generator is < 70 F. 3. The pressurizer cooldown and heatup rates shall not exceed 200 F/hr and 100 F/hr, respectively. The spray shall not be used if the temperature difference between the

pressurizer and the spray fluid is > 320 F. 4. The overpressure protection system for low temperature operation shall be OPERABLE whenever one or more of the RCS cold leg temperatures are 200 F, and the reactor vessel head is installed. The system shall be considered

OPERABLE when at least one of the following conditions is satisfied:

A. The overpressure relief valve on the Residual Heat Removal System (RHR 33-1) shall have a set pressure of 500 psig and shall be aligned to the RCS by maintaining valves RHR 1A, 1B, 2A, and 2B open.

1. With one flow path inoperable, the valves in the parallel flow path shall be verified open with the associated motor breakers for the valves locked in the off position. Restore the inoperable flow path within five days or complete depressurization and venting of the RCS through a 6.4 square inch vent within an additional eight hours.

2. With both flow paths or RHR 33-1 inoperable, complete depressurization and venting of the RCS through at least a 6.4 square inch vent pathway within eight hours.

See CTS 3.1.b.3 See ITS 3.4.12 Add proposed SR 3.4.3.1 M03See ITS 3.4.12 See CTS 3.1.b.2 (1) The curves are limited to 31.1 EFPY due to changes in vessel fluence associated with operation at uprated power.

Figures 3.4.3-1 and

3.4.3-2 Amendment No. 168 TS 3.1-6 07/08/2003 Page 1 of 4 A01 ITS 3.4.3 ITS f. Minimum Conditions for Criticality

1. The reactor shall not be brought to a critical condition until the pressure-temperature state is to the right of the criticality limit line shown in Figure TS 3.1-1.

LCO 3.4.3 A pplicabilit y 2. The reactor shall be maintained subcritical by at least 1% k/k until normal water level is established in the pressurizer.

3. When the reactor is critical the moderator temperature coefficient shall be as specified in the COLR, except during LOW POWER PHYSICS TESTING. The maximum upper moderator temperature coefficient limit shall be 5 pcm/ F for power levels 60% RATED POWER and 0 pcm/ F for power levels 60% RATED POWER. See ITS 3.4.9 See ITS 3.1.3 and 3.1.8 4. If the limits of 3.1.f.3 cannot be met, then power operation may continue provided the following actions are taken:

A. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , develop and maintain administrative control rod withdrawal limits sufficient to restore the moderator temperature coefficient to within the limits specified in TS 3.1.f.3. These withdrawal limits shall be in addition to the

insertion limits specified in TS 3.10.d.

B. If the actions specified in TS 3.1.f.4.A are not satisfied, then be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

See ITS 3.1.3 Amendment No. 165 TS 3.1-10 03/11/2003Page 2 of 4 A01 ITS 3.4.3 ITS FIGURE TS 3.1-1 Amendment No. 168 07/08/2003 KEWAUNEE UNIT NO. 1 HEATUP LIMITATION CURVESAPPLICABLE FOR PERIODS UP TO 33

[1]EFFECTIVE FULL-POWER YEARS 0 250 500 750 1000 1250 1500 1750 2000 2250 2500 50 100 150 200 250 300 350 400Indicated Temperature (°F)

Indicated Pressure (psig)Material Property BasisIntermediate Forging Cu = 0.06 wt% Ni = 0.71 wt%

Initial RTNDT = 60°FCF = 37°FMargin = 34°FAt 33 Effective Full Power Years Adj. RTNDT at 1/4T = 139°F Adj. RTNDT at 3/4T = 131°FClosure Flange Initial RTNDT = 60°FCriticality LimitIn-Service Leak Test Minimum Tem peratureHeatup Rates

u p to 100°F/HrAcceptable OperationUnacceptableOperationLA03 Figure 3.4.3-1 s for Instrumentation Error and Pressure cross RV Core F Instrumentation si Instrumentation s i PMargins for Instrumentation Error and Pressure Drop Across RV Core

+13°F Instrumentation

-58 psi Instrumentation

-70 psi D P NOTE: [1)The curves are limited to 31.1 EFPY due to changes in vessel fluence associated with operation at uprated power.

Page 3 of 4 FIGURE TS 3.1-2 KEWAUNEE UNIT NO. 1 COOLDOWN LIMITATION CURVES APPLICABLE FOR PERIODS UP TO 33

[1] EFFECTIVE FULL-POWER YEARS Amendment No. 168 07/08/2003

[1] The curves are limited to 31.1 EFPY due to changes in vessel fluence associated with operation at uprated power.

0 250 500 750 1000 1250 1500 1750 2000 2250 2500 50 100150 200 250 300 350Indicated Temperature (°F)Indicated Pressure (psig)Material Property BasisWeld Metal Cu = 0.287 wt% Ni = 0.756 wt% Initial RTNDT = -50°F CF = 192.3°F Margin = 219.9°F At 33 Effective Full Power Years Adj. RTNDT at 1/4T = 246°F Adj. RTNDT at 3/4T = 200°F Intermediate Forging Cu = 0.06 wt% Ni = 0.71 wt%

Initial RTNDT = 60°F CF = 37°F Margin = 34°F At 33 Effective Full Power Years Adj. RTNDT at 1/4T = 139°F Adj. RTNDT at 3/4T = 131°FClosure Flange Initial RTNDT = 60°FMargins for Instrumentation Error and Pressure Drop Across RV Core

+13°F Instrumentation -58 psi Instrumentation -70 psi P0°F20°F40°F60°F 100°F0°F20°F40°F 60°F 100°FUnacceptableOperationAcceptable OperationLA03 Figure 3.4.3-2 ITS 3.4.3 ITS A01 Page 4 of 4 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES

M01 CTS 3.1.b.1 does not provide any Applicability requirements for the Heatup and Cooldown Limit Curves. ITS 3.4.3 requires the RCS Pressure, RCS Temperature, and RCS heatup and cooldown rates to be maintained with limits "at all times." This changes the CTS by specifically stating that the RCS Pressure, RCS Temperature, and RCS heatup and cooldown rates to maintained with limits are required "at all times."

The purpose of the heatup and cooldown limit curves is to limit the pressure and temperature changes during RCS heatup and cooldown to within the design assumptions and the stress limits for cyclic operation. This change is acceptable because the RCS pressure and temperature (P/T) limits provide the limits for acceptable operation for the prevention of nonductile failures. Even though the P/T limits were developed to provide guidance for operations during heatup and cooldown, the Applicability of "at all times" is required because of concern for nonductile failure. This change is designated as more restrictive because specific Applicability requirements have been added.

M02 CTS 3.1.b.1 provides limits for reactor coolant temperature and pressure and system heatup and cooldown rates. It does not specify Actions to take when the limitations are not met, therefore, CTS 3.0.c would be entered. CTS 3.0.c requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to be in HOT STANDBY (equivalent to MODE 3) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , HOT SHUTDOWN (equivalent to MODE 4) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and COLD SHUTDOWN (equivalent to MODE 5) within the subsequent 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ITS 3.4.3 adds ACTION A, which states that if the requirements of the LCO are not met in MODE 1, 2, 3, or 4 to restore the parameters to within limits in 30 minutes and to determine if the RCS is acceptable for continued operation within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . It also adds ACTION B, which states that if the Required Action and associated Completion Time of Condition A is not met, then to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in MODE 5 with the RCS pressure less than 500 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Additionally, it adds ACTION C, which states that if the requirements of the LCO are not met when not in MODE 1, 2, 3, or 4 to initiate action to restore the parameters to within limits immediately and to determine the RCS is acceptable for continued operation prior to entering MODE 4. This changes the CTS by adding specific ITS 3.4.3 ACTIONS A, B, and C.

Kewaunee Power Station Page 1 of 4 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS This purpose of ITS 3.4.3 ACTIONS A, B, and C is to provide specific compensatory actions for when RCS pressure and temperature are not maintained within the limits. This change is acceptable because it provides the necessary and specific actions to take when the requirements are not met and provides appropriate times to complete the actions. This change is designated as more restrictive because it adds specific compensatory actions and times that are more restrictive than the current action and times for when P/T limits are not met in all conditions.

M03 CTS 3.1.b.1 provides pressure and temperature (P/T) limits during heatup and cooldown. However, there is no specific Surveillance Requirement for verification that the CTS pressure and temperature are within the P/T limits. ITS SR 3.4.3.1 requires verification that the RCS Pressure, RCS Temperature, and RCS heatup and cooldown rates are within limits every 30 minutes during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing. This changes the CTS by adding a specific Surveillance Requirement to verify the RCS heatup and cooldown rates are met.

The purpose of CTS 3.1.b.1 is to specify the P/T limits during heatup and cooldown. The CTS does not include a Surveillance Requirement for verification of the specified P/T limits. This change adds a specific Surveillance Requirement. This change is acceptable because the proposed Surveillance Requirement (ITS SR 3.4.3.1) will verify that heatup and cooldown limits are met.

This change is designated as more restrictive because it adds a specific Surveillance Requirement not currently required by the CTS.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.1.b.1 states, in part, that reactor coolant temperature and pressure and system heatup and cooldown rates (with the exception of the pressurizer) shall be limited in accordance with Figures TS 3.1-1 and TS 3.1-2. ITS 3.4.3 states that RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained with limits. This changes the CTS by moving the exclusion of the pressurizer from the LCO limit to the Bases.

The removal of these details, which are related to design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the P/T limits on the RCS. Neither the CTS or the ITS P/T limits apply to the pressurizer. It is the ITS convention to state this detail in the ITS Bases. This detail of the LCO is not required to be in the Technical Specifications in order to provide adequate protection of the public health and safety. Also, this change is acceptable because the removed Kewaunee Power Station Page 2 of 4 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS information will be adequately controlled in the ITS Bases. Furthermore, the pressurizer limits are currently covered by CTS 3.1.b.3. As allowed by the NUREG-1431, these limits will be relocated to the TRM as discussed in CTS 3.1.b.3 DOC R01 in this section. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.1.b.1.A states that allowable combinations of pressure and temperature for specific temperature change rates are below and to the right of the limit lines shown. Limit lines for cooldown rates between those presented may be obtained by interpolation. Furthermore, CTS 3.1.b.1.B states that Figures TS 3.1-1 and TS 3.1-2 define limits to assure prevention of non-ductile failure only. For normal operation other inherent plant characteristics, e.g., pump heat addition and pressurizer heater capacity may limit the heatup and cooldown rates that can be achieved over certain pressure-temperature ranges. ITS 3.4.3 does not contain these statements. This changes the CTS by moving this information to the Bases.

The removal of these details, which are related to design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS Figures 3.4.3-1 and 3.4.3-2 clearly state the acceptable regions of the curve. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Figures TS 3.1-1 and TS 3.1-2 describe in text boxes the Margins for Instrumentation Error and Pressure Drop that are used to determine the P/T limits. The ITS Figures 3.4.3-1 and 3.4.3-2 do not include this information. This changes the CTS by moving this information to the Bases.

The removal of these details, which are related to design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the P/T limits on the RCS and the curves include the margins listed in the two text boxes. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

Kewaunee Power Station Page 3 of 4 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS Kewaunee Power Station Page 4 of 4 LESS RESTRICTIVE CHANGES None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS P/T Limits 3.4.3 WOG STS 3.4.3-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.3 RCS Pressure and Temperature (P/T) Limits

LCO 3.4.3 RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within the limits specified in the PTLR. 3.1.b.1; 3.1.f.1 1 Figure 3.4.3-1 and Figure 3.4.3-2 DOC M01 APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------

Required Action A.2 shall be completed whenever this Condition is entered. ---------------------------------

Requirements of LCO not met in MODE 1, 2, 3, or 4.

A.1 Restore parameter(s) to within limits.

AND A.2 Determine RCS is acceptable for continued operation.

30 minutes

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and associated Completion Time of Condition A not met. B.1 Be in MODE 3.

AND B.2 Be in MODE 5 with RCS pressure < [500] psig.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. ------------NOTE------------

Required Action C.2 shall be completed whenever this Condition is entered. ---------------------------------

Requirements of LCO not met any time in

other than MODE 1, 2, 3, or 4. C.1 Initiate action to restore parameter(s) to within limits.

AND C.2 Determine RCS is acceptable for continued operation.

Immediately

Prior to entering MODE 4 DOC M02 DOC M02 2 DOC M02 RCS P/T Limits 3.4.3 WOG STS 3.4.3-2 Rev. 3.0, 03/31/04 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 -------------------------------NOTE------------------------------

Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing. ---------------------------------------------------------------------

Verify RCS pressure, RCS temperature, and RCS heatup and cooldown rates are within the limits specified in the PTLR.

30 minutes DOC M03 1Figure 3.4.3-1 and Figure 3.4.3-2 1INSERTS 1 and 2 3.4.3 1 INSERT 1 Figure 3.4.3-1 KPS Heatup, Criticality, and In-Service Leak Test Limitation Curves Applicable for Periods up to 33 (1) Effective Full Power Years (EFPY)

(1) Curves limited to 31.1 EFPY due to changes in vessel fluence associated with operation at power uprate.

Insert Page 3.4.3-2a 3.4.3 1 INSERT 2 Figure 3.4.3-2 KPS Cooldown and LTOP Event Limitation Curves Applicable for Periods up to 33 (1) EFPY (1) Curves limited to 31.1 EFPY due to changes in vessel fluence associated with operation at power uprate.

Insert Page 3.4.3-2b JUSTIFICATION FOR DEVIATIONS ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS

1. Kewaunee Power Station is not adopting a Pressure Temperature Limits Report (PTLR) and is retaining in the ITS the limits on heatup, cooldown, and inservice leak and hydrostatic testing, and data for maximum rate of change of reactor coolant temperature. Therefore, references to the PTLR have been changed to Figure 3.4.3-1 and Figure 3.4.3-2. Furthermore, Figure 3.4.3-1 and Figure 3.4.3-2 have been added to ITS 3.4.3.

2. The ITS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-1 Rev. 3.0, 03/31/04 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.3 RCS Pressure and Temperature (P/T) Limits

BASES BACKGROUND All components of the RCS are designed to withstand effects of cyclic loads due to system pressure and temperature changes. These loads are introduced by startup (heatup) and shutdown (cooldown) operations, power transients, and reactor trips. This LCO limits the pressure and temperature changes during RCS heatup and cooldown, within the design assumptions and the stress limits for cyclic operation.

The PTLR contains P/T limit curves for heatup, cooldown, inservice leak and hydrostatic (ISLH) testing, and data for the maximum rate of change of reactor coolant temperature (Ref. 1). This LCO 1criticality, Each P/T limit curve defines an acceptable region for normal operation.

The usual use of the curves is operational guidance during heatup or

cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable region.

The LCO establishes operating limits that provide a margin to brittle failure of the reactor vessel and piping of the reactor coolant pressure boundary (RCPB). The vessel is the component most subject to brittle failure, and the LCO limits apply mainly to the vessel. The limits do not apply to the pressurizer, which has different design characteristics and operating functions.

10 CFR 50, Appendix G (Ref. 2), requires the establishment of P/T limits for specific material fracture toughness requirements of the RCPB materials. Reference 2 requires an adequate margin to brittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests. It mandates the use of the American Society of Mechanical Engineers (ASME) Code,Section III, Appendix G (Ref. 3).

The neutron embrittlement effect on the material toughness is reflected by increasing the nil ductility reference temperature (RT NDT) as exposure to neutron fluence increases. and ASME Code,Section XI, Appendix G (Ref.

4) 7 The actual shift in the RT NDT of the vessel material will be established periodically by removing and evaluating the irradiated reactor vessel material specimens, in accordance with ASTM E 185 (Ref. 4) and Appendix H of 10 CFR 50 (Ref. 5). The operating P/T limit curves will be adjusted, as necessary, based on the evaluation findings and the recommendations of Regulatory Guide 1.99 (Ref. 6).

5 7 6 7 RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-2 Rev. 3.0, 03/31/04 BASES BACKGROUND (continued)

The P/T limit curves are composite curves established by superimposing limits derived from stress analyses of those portions of the reactor vessel and head that are the most restrictive. At any specific pressure, temperature, and temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the span of the P/T limit curves, different locations are more restrictive, and, thus, the curves are composites of the most restrictive regions.

The heatup curve represents a different set of restrictions than the cooldown curve because the directions of the thermal gradients through the vessel wall are reversed. The thermal gradient reversal alters the location of the tensile stress between the outer and inner walls.

The criticality limit curve includes the Reference 2 requirement that it be 40°F above the heatup curve or the cooldown curve, and not less than the minimum permissible temperature for ISLH testing. However, the criticality curve is not operationally limiting; a more restrictive limit exists in LCO 3.4.2, "RCS Minimum Temperature for Criticality."

The consequence of violating the LCO limits is that the RCS has been operated under conditions that can result in brittle failure of the RCPB, possibly leading to a nonisolable leak or loss of coolant accident. In the event these limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB components.

The ASME Code,Section XI, Appendix E (Ref. 7), provides a recommended methodology for evaluating an operating event that causes an excursion outside the limits.

8 7 APPLICABLE The P/T limits are not derived from Design Basis Accident (DBA) SAFETY analyses. They are prescribed during normal operation to avoid ANALYSES encountering pressure, temperature, and temperature rate of change conditions that might cause undetected flaws to propagate and cause nonductile failure of the RCPB, an unanalyzed condition. Reference 1 establishes the methodology for determining the P/T limits. Although the P/T limits are not derived from any DBA, the P/T limits are acceptance limits since they preclude operation in an unanalyzed condition.

RCS P/T limits satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-3 Rev. 3.0, 03/31/04 BASES LCO The two elements of this LCO are:

a. The limit curves for heatup, cooldown, and ISLH testing and criticality, 2 3; 2 b. Limits on the rate of change of temperature.

The LCO limits apply to all components of the RCS, except the pressurizer. These limits define allowable operating regions and permit a large number of operating cycles while providing a wide margin to nonductile failure. (maximum of 100ºF/hr for heatup and cooldown)

The limits for the rate of change of temperature control the thermal gradient through the vessel wall and are used as inputs for calculating the heatup, cooldown, and ISLH testing P/T limit curves. Thus, the LCO for the rate of change of temperature restricts stresses caused by thermal gradients and also ensures the validity of the P/T limit curves.

1 Violating the LCO limits places the reactor vessel outside of the bounds of the stress analyses and can increase stresses in other RCPB components. The consequences depend on several factors, as follow: INSERT 1 a. The severity of the departure from the allowable operating P/T regime or the severity of the rate of change of temperature, 3

b. The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced), and

3

c. The existences, sizes, and orientations of flaws in the vessel material.

APPLICABILITY The RCS P/T limits LCO provides a definition of acceptable operation for prevention of nonductile failure in accordance with 10 CFR 50, Appendix G (Ref. 2). Although the P/T limits were developed to provide guidance for operation during heatup or cooldown (MODES 3, 4, and 5) or ISLH testing, their Applicability is at all times in keeping with the concern for nonductile failure. The limits do not apply to the pressurizer.

During MODES 1 and 2, other Technical Specifications provide limits for operation that can be more restrictive than or can supplement these P/T limits. LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits," LCO 3.4.2, "RCS Minimum Temperature for Criticality," and Safety Limit 2.1, "Safety Limits," also provide operational restrictions for pressure and temperature and ITS B 3.4.3 1 INSERT 1 Figure 3.4.3-1 and Figure 3.4.3-2 were originally developed for service periods of up to 33 effective full power years (EFPY). However, the curves are limited to 31.1 EFPY due to changes in the vessel fluence associated with operation at uprated power.

Figure 3.4.3-1 and Figure 3.4.3-2 define limits to assure prevention of non-ductile failure only. For normal operation, other inherent plant characteristics, e.g., pump heat addition and pressurizer heater capacity may limit the heatup and cooldown rates that can be achieved over certain pressure-temperature ranges. Allowable combinations of pressure and temperature for specific temperature change rates are below and to the right of the limit lines shown. Limit lines for cooldown rates between those presented may be obtained by interpolation.

Furthermore, the Figures include margins for instrumentation error and pressure drop

(+ 13ºF, -58 psi, and -70 psi P).

Insert Page B 3.4.3-3 RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-4 Rev. 3.0, 03/31/04 BASES APPLICABILITY (continued)

maximum pressure. Furthermore, MODES 1 and 2 are above the temperature range of concern for nonductile failure, and stress analyses have been performed for normal maneuvering profiles, such as power ascension or descent.

ACTIONS A.1 and A.2

Operation outside the P/T limits during MODE 1, 2, 3, or 4 must be corrected so that the RCPB is returned to a condition that has been

verified by stress analyses.

6 The 30 minute Completion Time reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner. is within the limits of the applicable Figures (i.e., Figures 3.4.3-1 and 3.4.3-2

)

Besides restoring operation within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify the RCPB integrity remains acceptable and must be completed before continuing operation. Several methods may be used, including

comparison with pre-analyzed transients in the stress analyses, new analyses, or inspection of the components. within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4

ASME Code,Section XI, Appendix E (Ref. 7), may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline.

8 7 The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable to accomplish the evaluation. The evaluation for a mild violation is possible within this time, but more severe violations may require special, event specific stress analyses or inspections. A favorable evaluation must be completed before continuing

to operate.

4 Condition A is modified by a Note requiring Required Action A.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action A.1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity.

RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-5 Rev. 3.0, 03/31/04 BASES ACTIONS (continued)

B.1 and B.2

If a Required Action and associated Completion Time of Condition A are not met, the plant must be placed in a lower MODE because either the RCS remained in an unacceptable P/T region for an extended period of increased stress or a sufficiently severe event caused entry into an unacceptable region. Either possibility indicates a need for more careful examination of the event, best accomplished with the RCS at reduced pressure and temperature. In reduced pressure and temperature conditions, the possibility of propagation with undetected flaws is decreased.

is any 4for continued operation time resulted in a determination that the RCS is or may be 4

If the required restoration activity cannot be accomplished within 30 minutes, Required Action B.1 and Required Action B.2 must be implemented to reduce pressure and temperature.

If the required evaluation for continued operation cannot be accomplished within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or the results are indeterminate or unfavorable, action must proceed to reduce pressure and temperature as specified in Required Action B.1 and Required Action B.2. A favorable evaluation must be completed and documented before returning to operating pressure and temperature conditions.

Pressure and temperature are reduced by bringing the plant to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 with RCS pressure < [500] psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

5 The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 and C.2

Actions must be initiated immediately to correct operation outside of the P/T limits at times other than when in MODE 1, 2, 3, or 4, so that the RCPB is returned to a condition that has been verified by stress analysis.

6 The immediate Completion Time reflects the urgency of initiating action to restore the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a

controlled manner. is within the limits of the applicable Figures (i.e., Figures 3.4.3-1 and 3.4.3-2)

RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-6 Rev. 3.0, 03/31/04 BASES ACTIONS (continued)

Besides restoring operation within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify that the RCPB integrity remains acceptable and must be completed prior to entry into MODE 4. Several methods may be used, including comparison with pre-analyzed transients in the stress analyses, or inspection of the

components.

ASME Code,Section XI, Appendix E (Ref. 7), may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline.

8 7 Condition C is modified by a Note requiring Required Action C.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action C.1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity.

SURVEILLANCE SR 3.4.3.1 REQUIREMENTS 1Verification that operation is within the PTLR limits is required every 30 minutes when RCS pressure and temperature conditions are undergoing planned changes. This Frequency is considered reasonable in view of the control room indication available to monitor RCS status.

Also, since temperature rate of change limits are specified in hourly increments, 30 minutes permits assessment and correction for minor deviations within a reasonable time.

Surveillance for heatup, cooldown, or ISLH testing may be discontinued when the definition given in the relevant plant procedure for ending the activity is satisfied.

This SR is modified by a Note that only requires this SR to be performed during system heatup, cooldown, and ISLH testing. No SR is given for criticality operations because LCO 3.4.2 contains a more restrictive

requirement.

2REFERENCES 1. WCAP-7924-A, April 1975.

2. 10 CFR 50, Appendix G. 14278, Rev. 1, "Kewaunee Heatup and Cooldown Limit Curves for Normal Operation." 3. ASME, Boiler and Pressure Vessel Code,Section III, Appendix G.

4. AMSE, Boiler and Pressure Vessel Code,Section XI, Appendix G.

2 RCS P/T Limits B 3.4.3 WOG STS B 3.4.3-7 Rev. 3.0, 03/31/04 BASES REFERENCES (continued)

4. ASTM E 185-82, July 1982.

5. 10 CFR 50, Appendix H.

6. Regulatory Guide 1.99, Revision 2, May 1988.

7. ASME, Boiler and Pressure Vessel Code,Section XI, Appendix E.

5 7 6 7 8 ASTM E 185-70 (removal) and (evaluation) 2 JUSTIFICATION FOR DEVIATIONS ITS 3.4.3 BASES, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS

1. Changes are made to reflect those changes made to the Specification.

2. 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.

3. These 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. Changes are made to reflect the ISTS.

5. The ITS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and proper plant specific information/value is provided. This is acceptable since the generic specific information/value is revised to reflect the current plant design.

6. The phrase is changed to be consistent with the actual words in the Required Action. The curves are not generated from stress analy ses; they are generated from fracture mechanics as stated in the Background section.

7. 10 CFR 50 Appendix G also mandates the use of ASME Code,Section XI, Appendix G. Thus, this statement has been modified to include this reference. Due to this addition, subsequent References have been renumbered.

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 4 ITS 3.4.4, RCS LOOPS - MODES 1 AND 2

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.4.4 A013.1 REACTOR COOLANT SYSTEM APPLICABILITY Applies to the OPERATING status of the Reactor Coolant System (RCS).

OBJECTIVE To specify those LIMITING CONDITIONS FOR OPERATION of the Reactor Coolant System which must be met to ensure safe reactor operation.

SPECIFICATIONS

a. Operational Components

1. Reactor Coolant Pumps See ITS .5, 3.4..7, 3.4.9.3 and3.9.4 3.46, 3.48, 3. A. At least one reactor coolant pump or one residual heat removal pump shall be in operation when a reduction is made in the boron concentration of the reactor coolant. B. When the reactor is in the OPERATING mode, except for low power tests, both reactor coolant pumps shall be in operation.

C. A reactor coolant pump shall not be started with one or more of the RCS cold leg temperatures 200F unless the secondary water temperature of each steam generator is < 100 F above each of the RCS cold leg temperatures. M01 2. Decay Heat Removal Capability A. At least two of the following four heat sinks shall be OPERABLE whenever the average reactor coolant temperature is 350 F but > 200 F. 1. Steam Generator 1A

2. Steam Generator 1B

3. Residual Heat Removal Train A

4. Residual Heat Removal Train B If less than the above number of required heat sinks are OPERABLE, then corrective action shall be taken immediately to restore the minimum number to

the OPERABLE status.

Page 1 of 1 See ITS 3.4.6 See ITS 3.4.7 and 3.4.12 A pplicabilit y LCO 3.4.4 M01Add proposed ACTION A OPERABLE andM02A02M03Add proposed SR 3.4.4.1 Amendment No. 165 TS 3.1-1 03/11/2003 DISCUSSION OF CHANGES ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.1.a.1.B states, in part, both reactor coolant pumps shall be in operation. ITS LCO 3.4.4 states two RCS loops shall be OPERABLE and in operation. This changes the CTS by requiring the RCS loops to be OPERABLE.

This change is acceptable because it is consistent with the current use and understanding of the LCO. It is not sufficient for an RCS loop to be in operation if it is not capable of performing its safety function (i.e., OPERABLE). This change is designated as administrative as it clarifies the current understanding of a

requirement.

MORE RESTRICTIVE CHANGES M01 CTS 3.1.a.1.B states, in part, that both reactor coolant pumps shall be in operation when the reactor is in the OPERATING (equivalent to ITS MODE 1) mode. ITS 3.4.4 requires two RCS loops to be OPERABLE and in operation in MODE 1 (equivalent to CTS OPERATING) and MODE 2 (equivalent to CTS HOT STANDBY). Furthermore, in the event there are less than two reactor coolant pumps operating, CTS 3.1.a.1.B does not contain any actions to be taken; CTS 3.0.c would be entered. CTS 3.0.c requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to be in HOT STANDBY (equivalent to ITS MODE 2) in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ITS 3.4.4 adds an ACTION statement to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the requirements of the LCO (i.e., two RCS loops OPERABLE and in operation) are not met. This changes the CTS by requiring the RCS loops be OPERABLE and in operation in MODE 2 and an appropriate ACTION to exit the Applicability if the LCO is not met. The change concerning the word "OPERABLE" is discussed in

DOC A02.

The addition of the MODE 2 Applicabilit y is acceptable since KPS is currently limited to less than 2 percent rated thermal power when only one reactor coolant pump is in operation. Less than two percent of rated thermal power is the CTS Fission Power value for HOT STANDBY (equivalent to ITS MODE 2) mode. If the plant were to operate with only one reactor coolant pump in operation, there would be reverse flow through the inactive reactor coolant loop due to the pressure difference across the reactor vessel and because there are no isolation or check valves in the reactor coolant loops. The change is also acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Times. Allowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be Kewaunee Power Station Page 1 of 2 DISCUSSION OF CHANGES ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 Kewaunee Power Station Page 2 of 2 in MODE 3 ensures a unit shutdown is commenced and completed within a reasonable period of time. This change is more restrictive because a new Applicability (MODE 2) and appropriate ACTION with a shorter completion time

have been added.

M02 CTS 3.1.a.1.B states, in part, both reactor coolant pumps are required to be in operation except for low power tests. ITS 3.4.4 does not include this exception; the reactor coolant pumps are required during PHYSICS TESTS. This changes the CTS by requiring the reactor coolant pumps to be OPERABLE during PHYSICS TESTS.

The purpose of CTS 3.1.a.1.B is to ensure the reactor coolant pumps are OPERABLE under both normal operating and accident conditions. Since Physics Tests do not require the RCPs to be inoperable to perform the tests, there is no reason to maintain this current allowance. Therefore, this change is acceptable and is more restrictive because the reactor coolant pumps are now required to be OPERABLE under more conditions in the ITS than in the CTS.

M03 CTS 3.1.a.1.B does not contain a Surveillance Requirement to verify each RCS loop is in operation. ITS SR 3.4.4.1 requires verification that each RCS loop is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring the operation of each RCS loop be verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The purpose of CTS 3.1.a.1.B is to ensure that the RCS loops are in operation when the plant is in the OPERATING mode. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. This change is more restrictive because a new Surveillance Requirement has been added to ensure the RCS loops are periodically verified to be in operation.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES None

LESS RESTRICTIVE CHANGES

None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Loops - MODES 1 and 2 3.4.4 WOG STS 3.4.4-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.4 RCS Loops - MODES 1 and 2

LCO 3.4.4 [Four] RCS loops shall be OPERABLE and in operation. Two 1 3.1.a.1.B

APPLICABILITY: MODES 1 and 2.

3.1.a.1.B

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of LCO not met.

A.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months DOC M01

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify each RCS loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months DOC M03 JUSTIFICATION FOR DEVIATIONS ITS 3.4.4, RCS LOOPS - MODES 1 AND 2

1. 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.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Loops - MODES 1 and 2 B 3.4.4 WOG STS B 3.4.4-1 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.4 RCS Loops - MODES 1 and 2

BASES BACKGROUND The primary function of the RCS is removal of the heat generated in the fuel due to the fission process, and transfer of this heat, via the steam generators (SGs), to the secondary plant.

The secondary functions of the RCS include:

a. Moderating the neutron energy level to the thermal state, to increase the probability of fission, ;

b. Improving the neutron economy by acting as a reflector,

c. Carrying the soluble neutron poison, boric acid,

d. Providing a second barrier against fission product release to the environment, and

e. Removing the heat generated in the fuel due to fission product decay following a unit shutdown.

The reactor coolant is circulated through [four] loops connected in parallel to the reactor vessel, each containing an SG, a reactor coolant pump (RCP), and appropriate flow and temperature instrumentation for both control and protection. The reactor vessel contains the clad fuel. The SGs provide the heat sink to the isolated secondary coolant. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and prevent fuel damage. This forced circulation of the reactor coolant ensures mixing of the coolant for proper boration and chemistry control. two ; ; 2; APPLICABLE Safety analyses contain various assumptions for the design bases SAFETY accident initial conditions including RCS pressure, RCS temperature, ANALYSES reactor power level, core parameters, and safety system setpoints. The important aspect for this LCO is the reactor coolant forced flow rate, which is represented by the number of RCS loops in service.

Both transient and steady state analyses have been performed to establish the effect of flow on the departure from nucleate boiling (DNB). The transient and accident analyses for the plant have been performed assuming [four] RCS loops are in operation. The majority of the plant two RCS Loops - MODES 1 and 2 B 3.4.4 WOG STS B 3.4.4-2 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES APPLICABLE SAFETY ANALYSES (continued)

safety analyses are based on initial conditions at high core power or zero power. The accident analyses that are most important to RCP operation are the [four] pump coastdown, single pump locked rotor, single pump (broken shaft or coastdown), and rod withdrawal events (Ref. 1). two Steady state DNB analysis has been performed for the [four] RCS loop operation. For [four] RCS loop operation, the steady state DNB analysis, which generates the pressure and temperature Safety Limit (SL) (i.e., the departure from nucleate boiling ratio (DNBR) limit) assumes a maximum power level of 109% RTP. This is the design overpower condition for

[four] RCS loop operation. The value for the accident analysis setpoint of the nuclear overpower (high flux) trip is 107% and is based on an analysis assumption that bounds possible instrumentation errors. The DNBR limit defines a locus of pressure and temperature points that result in a minimum DNBR greater than or equal to the critical heat flux correlation

limit.

The plant is designed to operate with all RCS loops in operation to maintain DNBR above the SL, during all normal operations and anticipated transients. By ensuring heat transfer in the nucleate boiling region, adequate heat transfer is provided between the fuel cladding and the reactor coolant.

RCS Loops - MODES 1 and 2 satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The purpose of this LCO is to require an adequate forced flow rate for core heat removal. Flow is represented by the number of RCPs in operation for removal of heat by the SGs. To meet safety analysis acceptance criteria for DNB, [four] pumps are required at rated power.

An OPERABLE RCS loop consists of an OPERABLE RCP in operation providing forced flow for heat transport and an OPERABLE SG.

APPLICABILITY In MODES 1 and 2, the reactor is critical and thus has the potential to produce maximum THERMAL POWER. Thus, to ensure that the assumptions of the accident analyses remain valid, all RCS loops are required to be OPERABLE and in operation in these MODES to prevent

DNB and core damage.

The decay heat production rate is much lower than the full power heat rate. As such, the forced circulation flow and heat sink requirements are reduced for lower, noncritical MODES as indicated by the LCOs for MODES 3, 4, and 5.

two 3INSERT 1 two 3unacceptable B 3.4.4 3 INSERT 1 These analyses establish allowable reacto r coolant average temperature for the minimum measured flow and power distribution as a function of RCS pressure. These analyses also establish a locus of power, pressure, and temperature conditions for which the departure from nucleate boiling ratio (DNBR) is equal to its Safety Limit value. The area of permissible operation is bounded by the following combination of reactor trips: high neutron flux (fixed setpoint), high pressurizer pressure (fixed setpoint), low pressurizer pressure (fixed setpoint), overpower T (variable setpoint), and overtemperature T (variable setpoint). The difference between the reactor trip values assumed in the safety analyses and the nominal reactor trip setpoints provides an allowance for instrumentation channel error and setpoint error.

Insert Page B 3.4.4-2 RCS Loops - MODES 1 and 2 B 3.4.4 WOG STS B 3.4.4-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES APPLICABILITY (continued)

Operation in other MODES is covered by:

LCO 3.4.5, "RCS Loops - MODE 3," LCO 3.4.6, "RCS Loops - MODE 4," LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -

High Water Level" (MODE 6), and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).

ACTIONS A.1 If the requirements of the LCO are not met, the Required Action is to reduce power and bring the plant to MODE 3. This lowers power level and thus reduces the core heat removal needs and minimizes the

possibility of violating DNB limits.

The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging safety systems.

SURVEILLANCE SR 3.4.4.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that each RCS loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal

while maintaining the margin to DNB. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop performance.

REFERENCES 1. FSAR, Section [ ].

U ;; 2 3 ;4 4 s 314.1.1, 14.1.2, 14.1.8 JUSTIFICATION FOR DEVIATIONS ITS 3.4.4 BASES, RCS LOOPS - MODES 1 AND 2

1. 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.

2. 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.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis or licensing basis description.

4. The correct ITS number has been provided (changed to be consistent with a number change to the actual specification in Section 3.9).

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 5 ITS 3.4.5, RCS LOOPS - MODE 3

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) 3.1 REACTOR COOLANT SYSTEM APPLICABILITY Applies to the OPERATING status of the Reactor Coolant System (RCS).

OBJECTIVE To specify those LIMITING CONDITIONS FOR OPERATION of the Reactor Coolant System which must be met to ensure safe reactor operation.

SPECIFICATIONS

a. Operational Components

1. Reactor Coolant Pumps A. At least one reactor coolant pump or one residual heat removal pump shall be in operation when a reduction is made in the boron concentration of the reactor

coolant. B. When the reactor is in the OPERATING mode, except for low power tests, both reactor coolant pumps shall be in operation.

C. A reactor coolant pump shall not be started with one or more of the RCS cold leg temperatures 200F unless the secondary water temperature of each steam generator is < 100 F above each of the RCS cold leg temperatures.

2. Decay Heat Removal Capability A. At least two of the following four heat sinks shall be OPERABLE whenever the average reactor coolant temperature is 350 F but > 200 F. 1. Steam Generator 1A

2. Steam Generator 1B

3. Residual Heat Removal Train A

4. Residual Heat Removal Train B If less than the above number of required heat sinks are OPERABLE, then corrective action shall be taken immediately to restore the minimum number to

the OPERABLE status.

ITS ITS 3.4.5 Page 1 of 1 See ITS 3.4.6 A01M01See ITS 3.4.6, 3.4.7, 3.4.8, 3.9.3, and 3.9.4 See ITS3.4.4 LCO 3.4.5 A pplicabilit y See ITS 3.4.7 and 3.4.12Add proposed SR 3.4.5.1 Add proposed SR 3.4.5.2, SR 3.4.5.3 and NoteM03Add proposed ACTIONS B and C (for 1st condition) Add proposed ACTION A M02Two RCS loops shall be OPERABLE M01Add proposed ACTION C (for 2nd condition) M04M01 Amendment No. 165 TS 3.1-1 03/11/2003 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 Kewaunee Power Station Page 1 of 3 ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES

M01 CTS 3.1.a.1.A requires one reactor coolant pump (RCP) to be in operation under a certain condition, but it does not provide any requirements that the associated Reactor Coolant System (RCS) loop be OPERABLE. ITS 3.4.5 requires two RCS loops to be OPERABLE. OPERABILITY of an RCS loop is defined in the ITS Bases as an OPERABLE RCP and one OPERABLE steam generator, and an OPERABLE RCP is OPERABLE if it is capable of being powered and able to provide forced flow. Thus, to ensure the RCP loops are OPERABLE, ITS SR 3.4.5.2 requires verification of steam generator secondary side water levels are 5% for required RCS loops every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.5.3 requires verification that each required RCP is OPERABLE every 7 days by verifying correct breaker alignment and indicated power are available to each required pump. A Note further explains that the Surveillance is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. Furthermore, ITS 3.4.5 ACTIONS A and B provide the appropriate compensatory measures if one of the RCS loops is inoperable in that restoration of the inoperable RCS loop is required within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (ITS 3.4.5 ACTION A) and if not restored, to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (ITS 3.4.5 ACTION B). If both RCS loops are inoperable, ITS 3.4.5 ACTION C requires immediate suspension of operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM limit of LCO 3.1.1 and initiation of action to restore one RCS loop to OPERABLE status. This changes the CTS by adding new OPERABILITY requirements for two RCS loops and appropriate ACTIONS

and Surveillance Requirements.

The purpose of the OPERABILITY requirements for two RCS loops is to ensure adequate loops are available for forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. While only one RCS loop is required to meet the above purpose, two RCS loops are required for redundancy. The purpose of the proposed ACTIONS is to provide adequate compensatory measures if one or both of the RCS loops are inoperable. The purpose of ITS SR 3.4.5.2 is to ensure that the secondary side water level of the steam generator is sufficient to provide a heat sink for removal of decay heat. The purpose of ITS SR 3.4.5.3 is to ensure that each required pump is OPERABLE. Verification of proper breaker alignment and power availability ensures that an additional reactor coolant pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Both Surveillances help ensure the RCS loops are OPERABLE.

DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 Kewaunee Power Station Page 2 of 3 These changes are designated as more restrictive because a new LCO requirement and appropriate ACTIONS and Surveillance Requirements have been added.

M02 CTS 3.1.a.1.A, which requires an RCP to be in operation, is applicable in MODE 3 only when a reduction is made in the boron concentration of the reactor coolant. ITS 3.4.5 is applicable at all times when in MODE 3, except for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided a) no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required

to meet the SDM of LCO 3.1.1; and, b) core outlet temperature is maintained at least 10°F below saturation temperature (ITS 3.4.5 LCO Note). This changes the CTS by specifying that the LCO requirement for an RCP to be in operation is applicable in MODE 3 at all times except for those conditions specified in the ITS 3.4.5 LCO Note.

CTS 3.1.a.1 requires at least one reactor coolant pump to be in operation when a reduction is made in the boron concentration of the reactor coolant. The CTS applicability statement applies during only those times when a change in the boron concentration of the reactor coolant is made; it is not for decay heat removal purposes. While a change in boron concentration may occur in

essentially any MODE; this discussion is only applicable during those times when the plant is in HOT SHUTDOWN (equivalent to ITS MODE 3). Other MODES are discussed in other ITS discussions. The ITS 3.4.5 Applicability is MODE 3 at all times, except for the conditions in 3.4.5 LCO Note, and primarily addresses the decay heat removal function, but also covers the boron mixing issue.

Reactor coolant pumps are utilized in MODE 3 to provide for removal of residual heat from the reactor core, via the steam generator to the secondary plant, and to ensure proper boron mixing within the reactor coolant. The MODE 3 decay heat removal requirements are low enough that a single RCS loop with one RCP running is sufficient to remove core decay heat. The purpose of the Note is to permit all RCPs to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period to perform certain infrequent tests which require reactor coolant flow to be stopped.

With the RCPs removed from operation, there is no forced flow of reactor coolant. As a result, the reactor coolant is in natural circulation and there is a risk of boron stratification or the formation of a vapor bubble that may cause a natural circulation flow obstruction should the RCPs be removed from service for longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. This change is acceptable because the time limitation to have the RCPs removed from operation ensures that both boron stratification and inadequate residual heat removal do not occur should multiple one hour periods be required to complete the testing. This change is designated more restrictive because the reactor coolant pump is now required to be in operation in MODE 3 at all times except for those conditions specified in the ITS 3.4.5 LCO Note.

M03 CTS 3.1.a.1 does not contain any ACTIONS to take should there be less than the required number of reactor coolant pumps in operation when required. As a result, CTS 3.0.c would be entered, which requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in HOT STANDBY (equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , to be in HOT SHUTDOWN (equivalent to ITS MODE 3) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and to be in COLD SHUTDOWN (equivalent to ITS MODE 5) within the subsequent 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . However, since the RCP only has to be in DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 Kewaunee Power Station Page 3 of 3 operation when a reduction in boron concentration is being made, the CTS 3.0.c requirement does not provide any relevant compensatory measures (i.e., it does not require boron concentration reductions to be suspended). ITS 3.4.5 ACTION C specifies the Required Actions for a required RCS loop not in operation as immediately placing the Rod Control System in a condition incapable of rod withdrawal, immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and initiation of action to restore one RCS loop to operation. This changes the CTS by adding a new ACTION.

The purpose of CTS LCO 3.0.c is to place the unit outside of the Applicability of the Specification. ITS 3.4.5 ACTION C effectively places the unit outside of the Applicability for a loop not in operation by requiring the plant to immediately place the Rod Control System in a condition incapable of rod withdrawal, suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and to initiate action to restore one RCS loop to operation. These proposed Required Actions reflect the importance of maintaining operation for heat removal and boron mixing. This change is designated as more restrictive because a new proposed ACTION has been added.

M04 CTS 3.1.a.1.A requires one RCP to be in operation under certain conditions, but does not provide a Surveillance Requirement to periodically verify the RCP is in operation. This changes the CTS by adding a new Surveillance Requirement.

The purpose of ITS SR 3.4.5.1 is to ensure that the RCS loops are in operation providing forced flow of the reactor coolant for heat removal. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. This will ensure the LCO requirement is periodically verified to be met. This change is designated as more restrictive because a new Surveillance Requirement has been added.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES None

LESS RESTRICTIVE CHANGES

None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Loops - MODE 3 3.4.5 WOG STS 3.4.5-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.5 RCS Loops - MODE 3

LCO 3.4.5 [Two] RCS loops shall be OPERABLE and either:

a. [Two] RCS loops shall be in operation when the Rod Control System is capable of rod withdrawal or

b. One RCS loop shall be in operation when the Rod Control System is not capable of rod withdrawal.

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

All reactor coolant pumps may be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature.

2 ,, "SHUTDOWN MARGIN" 6 1 DOC M01, 3.1.a.1.A --------------------------------------------------------------------------------------------------

DOC M02 APPLICABILITY: MODE 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One required RCS loop inoperable.

A.1 Restore required RCS loop to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 4.

12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 3 DOC M01 s DOC M01 4 RCS Loops - MODE 3 3.4.5 WOG STS 3.4.5-2 Rev. 3.0, 03/31/04 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. [ One required RCS loop not in operation with Rod

Control System capable of rod withdrawal.

C.1 Restore required RCS loop to operation.

OR C.2 Place the Rod Control System in a condition incapable of rod withdrawal.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ] D. [Two] [required] RCS loops inoperable.

OR Required RCS loop(s) not in operation.

D.1 Place the Rod Control System in a condition incapable of rod withdrawal.

AND D.2 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

AND D.3 Initiate action to restore one RCS loop to OPERABLE status and operation.

Immediately

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.4.5.1 Verify required RCS loops are in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C.3 C.2 C is one DOC M01, DOC M03 CTS DOC M04 2 5 5 5 2 2 1 2C.1 RCS Loops - MODE 3 3.4.5 WOG STS 3.4.5-3 Rev. 3.0, 03/31/04 CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.5.2 Verify steam generator secondary side water levels are [17]% for required RCS loops.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.5.3 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ---------------------------------------------------------------------

Verify correct breaker alignment and indicated power are available to each required pump.

7 days DOC M01 DOC M01 1 3 3 3 5 both JUSTIFICATION FOR DEVIATIONS ITS 3.4.5, RCS LOOPS - MODE 3

1. 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.

2. The ISTS contains requirements and actions on the Rod Control System based on the assumption that the accident analysis for an uncontrolled Rod Control Cluster Assembly (RCCA) bank withdrawal requires two Reactor Coolant System (RCS) loops to be in operation. The KPS accident analysis for an uncontrolled RCCA bank withdrawal from a subcritical condition assumes only one RCS loop is in operation. As a result, the ITS LCO does not contain requirements on the reactor trip breakers or the Rod Control System, and requires only one RCS loop to be in operation. This is acceptable since the basis for the change is consistent with the accident analysis assumptions.

3. The ISTS is generically written for Westinghouse plants that have four RCS loops. For those plants that have three or more RCS loops, there are typically a minimum number of "required" loops (out of the total number of RCS loops) that need to be available to satisfy design and accident considerations. Since KPS is a two loop RCS plant, the use of "required" is not needed since there are a total of two loops, both of which are required to be OPERABLE.

4. Typographical error/omission corrected.

5. Changes are made to reflect those changes made to the ISTS. Subsequent requirements are renumbered or revised, where applicable, to reflect the changes.

6. The title of the LCO has been provided since this is the first reference to the LCO.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Loops - MODE 3 B 3.4.5 WOG STS B 3.4.5-1 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 RCS Loops - MODE 3

BASES BACKGROUND In MODE 3, the primary function of the reactor coolant is removal of decay heat and transfer of this heat, via the steam generator (SG), to the secondary plant fluid. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.

two The reactor coolant is circulated through [four] RCS loops, connected in parallel to the reactor vessel, each containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The reactor vessel contains the clad fuel. The SGs provide the heat sink. The RCPs circulate the water through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and prevent fuel damage.

In MODE 3, RCPs are used to provide forced circulation for heat removal during heatup and cooldown. The MODE 3 decay heat removal requirements are low enough that a single RCS loop with one RCP running is sufficient to remove core decay heat. However, [two] RCS loops are required to be OPERABLE to ensure redundant capability for decay heat removal.

APPLICABLE Whenever the reactor trip breakers (RTBs) are in the closed position and SAFETY the control rod drive mechanisms (CRDMs) are energized, an ANALYSES inadvertent rod withdrawal from subcritical, resulting in a power excursion, is possible. Such a transient could be caused by a malfunction of the rod control system. In addition, the possibility of a power excursion due to the ejection of an inserted control rod is possible with the breakers closed or open. Such a transient could be caused by the mechanical failure of a CRDM.

Therefore, in MODE 3 with the Rod Control System capable of rod withdrawal, accidental control rod withdrawal from subcritical is postulated and requires at least [two] RCS loops to be OPERABLE and in operation to ensure that the accident analyses limits are met. For those conditions when the Rod Control System is not capable of rod withdrawal, two RCS loops are required to be OPERABLE, but only one RCS loop is required to be in operation to be consistent with MODE 3 accident analyses.

3 11 2one RCS loop shall be 9 4analysis RCS Loops - MODE 3 B 3.4.5 WOG STS B 3.4.5-2 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES APPLICABLE SAFETY ANALYSES (continued)

Failure to provide decay heat removal may result in challenges to a fission product barrier. The RCS loops are part of the primary success path that functions or actuates to prevent or mitigate a Design Basis Accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier.

RCS Loops - MODE 3 satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The purpose of this LCO is to require that at least [two] RCS loops be OPERABLE. In MODE 3 with the Rod Control System capable of rod withdrawal, [two] RCS loops must be in operation. [Two] RCS loops are required to be in operation in MODE 3 with the Rod Control System capable of rod withdrawal due to the postulation of a power excursion because of an inadvertent control rod withdrawal. The required number of RCS loops in operation ensures that the Safety Limit criteria will be met for all of the postulated accidents.

When the Rod Control System is not capable of rod withdrawal, only one RCS loop in operation is necessary to ensure removal of decay heat from the core and homogenous boron concentration throughout the RCS. An additional RCS loop is required to be OPERABLE to ensure that safety

analyses limits are met.

The Note permits all RCPs to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to perform tests that are designed to validate various accident analyses values. One of these tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident. This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again. Another test performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow.

The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits the stopping of the pumps in order to perform this test and validate the assumed analysis values. As with the validation of the pump coastdown curve, this test should be performed only once unless the flow characteristics of the RCS are changed. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period specified is adequate to perform the desired tests, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow. accident analysis 3 4and one RCS loop in operation redundant capability for heat removal 4 3 9 5 RCS Loops - MODE 3 B 3.4.5 WOG STS B 3.4.5-3 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES LCO (continued)

Utilization of the Note is permitted provided the following conditions are met, along with any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation and

b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

An OPERABLE RCS loop consists of one OPERABLE RCP and one OPERABLE SG, which has the minimum water level specified in SR 3.4.5.2. An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required.

APPLICABILITY In MODE 3, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing.

The most stringent condition of the LCO, that is, two RCS loops OPERABLE and two RCS loops in operation, applies to MODE 3 with the Rod Control System capable of rod withdrawal. The least stringent condition, that is, two RCS loops OPERABLE and one RCS loop in operation, applies to MODE 3 with the Rod Control System not capable of rod withdrawal.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops - MODES 1 and 2," LCO 3.4.6, "RCS Loops - MODE 4," LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -

High Water Level" (MODE 6), and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).

6 6 4"SHUTDOWN MARGIN", 7 5 3 8 4 RCS Loops - MODE 3 B 3.4.5 WOG STS B 3.4.5-4 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES ACTIONS A.1 If one [required] RCS loop is inoperable, redundancy for heat removal is lost. The Required Action is restoration of the required RCS loop to OPERABLE status within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This time allowance is a justified period to be without the redundant, nonoperating loop because a single loop in operation has a heat transfer capability greater than that needed to remove the decay heat produced in the reactor core and because of the low probability of a failure in the remaining loop occurring during this period.

B.1 If restoration for Required Action A.1 is not possible within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the unit must be brought to MODE 4. In MODE 4, the unit may be placed on the Residual Heat Removal System. The additional Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is compatible with required operations to achieve cooldown and depressurization from the existing plant conditions in an orderly manner and without challenging plant systems.

[ C.1 and C.2 If one required RCS loop is not in operation, and the Rod Control System is capable of rod withdrawal, the Required Action is either to restore the required RCS loop to operation or to place the Rod Control System in a condition incapable of rod withdrawal (e.g., de-energize all CRDMs by opening the RTBs or de-energizing the motor generator (MG) sets).

When the Rod Control System is capable of rod withdrawal, it is postulated that a power excursion could occur in the event of an inadvertent control rod withdrawal. This mandates having the heat transfer capacity of two RCS loops in operation. If only one loop is in operation, the Rod Control System must be rendered incapable of rod withdrawal. The Completion Times of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to restore the required RCS loop to operation or defeat the Rod Control System is adequate to perform these operations in an orderly manner without exposing the unit to risk for an undue time period. ]

4 5 RCS Loops - MODE 3 B 3.4.5 WOG STS B 3.4.5-5 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES

ACTIONS (continued)

D.1, D.2, and D.3

If [two] [required] RCS loops are inoperable or a required RCS loop is not in operation, except as during conditions permitted by the Note in the LCO section, the Rod Control System must be placed in a condition incapable of rod withdrawal (e.g., all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets). All operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertent rod withdrawal. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loops are in operation. Verification includes flow rate, temperature, and pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop

performance.

SR 3.4.5.2 SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is

[17]% for required RCS loops. If the SG secondary side narrow range water level is < [17]%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink for removal of the decay heat. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to a loss of SG level.

5C.1 , C.2 , and C.3 the 4 one is 4the 5 5 5 or 10 RCS Loops - MODE 3 B 3.4.5 WOG STS B 3.4.5-6 Rev. 3.1, 12/01/05 All changes are unless otherwise noted 1BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.5.3 5Verification that each required RCP is OPERABLE ensures that safety analyses limits are met. The requirement also ensures that an additional RCP can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power availability to each required RCP. Alternatively, verification that a pump is in operation also verifies

proper breaker alignment and power availability.

5 This SR is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

5 REFERENCES None.

JUSTIFICATION FOR DEVIATIONS ITS 3.4.5 BASES, RCS LOOPS - MODE 3

1. The ISTS Bases 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.

2. The ISTS Bases Applicable Safety Analyses section addresses the possibility of a power excursion due to the ejection of an inserted control rod as a result of a control rod drive mechanism (CRDM) mechanical failure. The rod ejection analysis for Kewaunee Power Station (KPS) is performed in MODES 1 and 2, not MODE 3. Therefore, the discussion on rod ejection is not applicable and has been deleted.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis or licensing basis description.

4. The ISTS Bases contains a discussion for those conditions when the Rod Control System is not capable of rod withdrawal based on the assumption that the accident analysis for an uncontrolled Rod Control Cluster Assembly (RCCA) bank withdrawal requires two Reactor Coolant System (RCS) loops to be in operation. The KPS accident analysis for an uncontrolled RCCA withdrawal from a subcritical condition assumes only one RCS loop is in operation. As a result, the ITS LCO does not contain requirements on the reactor trip breakers or the Rod Control System, and requires only one RCS loop to be in operation. Therefore, the discussion of rod ejection is not applicable and has been deleted.

5. Changes are made to reflect those changes made to the ISTS. Subsequent requirements are renumbered or revised, where applicable, to reflect the changes.

6. 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.

7. The title of the LCO has been provided since this is the first reference to the LCO.

8. The correct ITS number has been provided (changed to be consistent with a number change to the actual specification in Section 3.9).

9. Since KPS only has two RCS loops, the words "at least" are not necessary.

10. Typographical error corrected. Verification that the loop is in operation can be performed by monitoring any of the thr ee parameters (flow rate, temperature, and pump status). As written, it implies all three must be observed. Also, use of "or" is consistent with similar SRs in the ITS 3.4.4, 3.4.6, 3.4.7, and 3.4.8 Bases.

11. Typographical error corrected. The title of a system is capitalized, as shown in the next paragraph.

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.5, RCS LOOPS - MODE 3 There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 6 ITS 3.4.6, RCS LOOPS - MODE 4

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.4.6 A013.1 REACTOR COOLANT SYSTEM APPLICABILITY Applies to the OPERATING status of the Reactor Coolant System (RCS).

OBJECTIVE To specify those LIMITING CONDITIONS FOR OPERATION of the Reactor Coolant System which must be met to ensure safe reactor operation.

SPECIFICATIONS

a. Operational Components

1. Reactor Coolant Pumps A. At least one reactor coolant pump or one residual heat removal pump shall be in operation when a reduction is made in the boron concentration of the reactor

coolant. B. When the reactor is in the OPERATING mode, except for low power tests, both reactor coolant pumps shall be in operation.

C. A reactor coolant pump shall not be started with one or more of the RCS cold leg temperatures 200F unless the secondary water temperature of each steam generator is < 100 F above each of the RCS cold leg temperatures.

2. Decay Heat Removal Capability A. At least two of the following four heat sinks shall be OPERABLE whenever the average reactor coolant temperature is 350 F but > 200 F. 1. Steam Generator 1A

2. Steam Generator 1B

3. Residual Heat Removal Train A

4. Residual Heat Removal Train B If less than the above number of required heat sinks are OPERABLE, then corrective action shall be taken immediately to restore the minimum number to

the OPERABLE status.

See ITS 3.4.4 Page 1 of 1 LA01 LCO 3.4.6 Applicability ACTIONS A and B M03Add proposed ACTION B (for 2nd Condition)M02Add proposed Required Actions A.2 and B.1M05Add proposed SR 3.4.6.2 and SR 3.4.6.3M04Add proposed SR 3.4.6.1 LCO 3.4.6 M01Applicability See ITS 3.4.7 and 3.4.12 Amendment No. 165 TS 3.1-1 03/11/2003 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.1.a.1.A, which requires a reactor coolant pump (RCP) or residual heat removal (RHR) pump to be in operation, is applicable in MODE 4 only when a reduction is made in the boron concentration of the reactor coolant. ITS 3.4.6 is applicable at all times when in MODE 4, except for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided a) no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and b) core outlet temperature is maintained at least 10ºF below saturation temperature (ITS 3.4.6 LCO Note). This changes the CTS by specifying that the LCO requirement for an RCP or RHR pump to be in operation is applicable in MODE 4 at all times except for those conditions specified in ITS

3.4.6 LCO Note.

CTS 3.1.a.1.A requires at least one RCP or one RHR pump to be in operation when a reduction is made in the boron concentration of the reactor coolant. The CTS applicability statement applies during only those times when a change in the boron concentration of the reactor coolant is made; it is not for decay heat removal purposes. While a change in boron concentration may occur in

essentially any MODE; this discussion is only applicable during those times when the plant is in MODE 4 (i.e., > 200°F and 350°F). Other MODES are discussed in other ITS discussions. The ITS 3.4.6 Applicability is MODE 4 at all times, except for the conditions in ITS 3.4.6 LCO Note, and primarily addresses the decay heat removal function, but also covers the boron mixing issue. RCPs or RHR pumps are utilized in MODE 4 to provide for removal of decay heat from the

reactor core, via the steam generator to the secondary plant or through the RHR heat exchangers, and to ensure proper boron mixing within the reactor coolant. The MODE 4 decay heat removal requirements are low enough that a single RCS loop with one RCP running or a single RHR pump is sufficient to remove core decay heat. The purpose of the Note is to permit all RCPs and RHR pumps

to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period to perform certain infrequent tests which require reactor coolant flow to be stopped. With the RCPs and RHR pumps removed from operation, there is no forced flow of reactor coolant. As a result, the reactor coolant is in natural circulation and there is a risk of boron stratification or the formation of a vapor bubble that may cause a natural

circulation flow obstruction should the RCPs and RHR pumps be removed from service for longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. This change is acceptable because the time limitation to have the RCPs and RHR pumps removed from operation ensures that adequate boron mixing and residual heat removal are Kewaunee Power Station Page 1 of 4 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 maintained should multiple one hour periods be required to complete the testing. This change is designated more restrictive because one RCP or RHR pump is required to be in operation in MODE 4 at all times except for those conditions specified in the ITS 3.4.6 LCO Note.

M02 CTS 3.1.a.2.A requires that if less than the required number of heat sinks are OPERABLE (i.e., one or both of the required heat sinks are inoperable), then corrective action shall be taken immediately to restore the minimum number to OPERABLE status. ITS 3.4.6 ACTION A provides the actions when one required heat sink is inoperable and ITS 3.4.6 ACTION B provides the actions when both required heat sinks are inoperable. Both ACTIONS require immediate action to be taken to restore the inoperable loops to OPERABLE status. In addition, ITS 3.4.6 Required Action A.2 requires that the unit be placed in MODE 5 in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the inoperable loop is an RHR loop. A Note for Required Action A.2 states that this action is only required if an RHR loop is OPERABLE. Furthermore, ITS 3.4.6 Required Action B.1 requires immediate suspension of operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1. This changes the CTS by adding new Required Actions when one or both required loops are inoperable.

The purpose of the CTS 3.1.a.2.A action is to provide compensatory measures for when one or both required heat sinks are inoperable. ITS 3.4.6 ACTION A places the unit outside of the Applicability of the Specification by requiring the plant to be in MODE 5 in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months should the inoperable loop not be restored to OPERABLE. The change is acceptable because allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to be in MODE 5 is reasonable, based on operating experience, to achieve MODE 5 from MODE 4 in an orderly manner and without challenging plant systems. In addition, bringing the unit to MODE 5 is a conservative action, with regard to residual heat removal, and with only one RHR loop OPERABLE, redundancy for residual heat removal is lost. In the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 rather than MODE 4. If both required loops are inoperable, ITS 3.4.6 Required Action B.1 ensures that a boron reduction cannot occur since there are no pumps running to mix the coolant. This change is designated as more restrictive because the time to exit the Applicability of the LCO has been reduced from 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

M03 CTS 3.1.a.1.A does not contain any ACTIONS to take should there be less than the required number of RHR pumps in operation while in MODE 4. As a result, CTS 3.0.c would be entered, which requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in HOT STANDBY (equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , to be in HOT SHUTDOWN (equivalent to ITS MODE 3) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and to be in COLD SHUTDOWN (equivalent to ITS MODE 5) within the subsequent 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . However, since the RCP or RHR pump only has to be in operation when a reduction in boron concentration is being made, the CTS 3.0.c requirement does not really provide any relevant compensatory measures; i.e., it does not require boron concentration reductions to be suspended. ITS 3.4.6 ACTION B specifies the Required Actions for a required RCS or RHR loop not in operation, and requires immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and initiation of action to restore one RCS or RHR loop to operation. This changes the CTS by adding a new ACTION.

Kewaunee Power Station Page 2 of 4 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 The purpose of CTS LCO 3.0.c is to place the unit outside of the Applicability of the Specification. ITS 3.4.6 ACTION B effectively places the unit outside of the Applicability for a loop not in operation by requiring the plant to immediately suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and to initiate action to restore one RCS or RHR loop to operation. The proposed Required Actions reflect the importance of maintaining operation for decay heat removal and boron mixing. This change is designated as more restrictive because a new proposed ACTION has been added.

M04 CTS 3.1.a.1.A requires one RCP or RHR pump to be in operation under certain conditions, but does not provide a Surveillance Requirement to periodically verify the required pump is in operation. ITS SR 3.4.6.1 requires verification that the required RHR or RCS loop is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS

by adding a new Surveillance Requirement.

The purpose of ITS SR 3.4.6.1 is to ensure that one RCS or RHR loop is in operation providing forced flow of the reactor coolant for heat removal. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. This will ensure the LCO requirement is periodically verified to be met. This change is designated as more restrictive because a new Surveillance Requirement has been added.

M05 CTS 3.1.a.2.A requires two heat sinks to be OPERABLE, but does not provide any Surveillance Requirements to periodically verify the required loops are OPERABLE. ITS SR 3.4.6.2 requires verification of steam generator secondary

side water levels are 5% for required RCS loops every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.6.3 requires verification that each required pump is OPERABLE every 7 days by verifying correct breaker alignment and indicated power are available to each required pump. A Note further explains that the Surveillance is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. This changes the CTS by adding new Surveillance Requirements to periodically verify the RCS or RHR loops are OPERABLE.

The purpose of ITS SR 3.4.6.2 is to ensure that the secondary side water level of the steam generator is sufficient to provide a heat sink for removal of decay heat.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. The purpose of ITS SR 3.4.6.3 is to ensure that each required pump is OPERABLE. Verification of proper breaker alignment and power availability ensures that an additional reactor coolant pump can be placed in operation, if needed, to maintain residual heat removal and reactor coolant circulation. These changes are acceptable because the surveillance requirements ensure the availability of the system to remove reactor residual heat and to provide proper boron mixing via the forced circulation of the reactor coolant. This change is designated as more restrictive because new Surveillance Requirements have been added to ensure that the RCS or RHR loops are periodically verified to be OPERABLE.

Kewaunee Power Station Page 3 of 4 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 Kewaunee Power Station Page 4 of 4 RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES

LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.1.a.2.A contains a listing of four heat sinks that are utilized for decay heat removal. The heat sinks are Steam Generator 1A, Steam Generator 1B, Residual Heat Removal Train A, and Residual Heat Removal Train B. ITS LCO 3.4.6, in part, requires two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops to be OPERABLE. The ITS does not define the components that comprise an OPERABLE loop. This changes the CTS by moving the description of the RCS and RHR loops to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS retains all necessary requirements in the LCO to ensure OPERABILITY of the required RCS and RHR loops in MODE 4. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Loops - MODE 4 3.4.6 WOG STS 3.4.6-1 Rev. 3.0, 03/31/04 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.6 RCS Loops - MODE 4

LCO 3.4.6 Two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops shall be OPERABLE, and one loop shall be in operation.

NOTES-------------------------------------------

1. All reactor coolant pumps (RCPs) and RHR pumps may be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature.

2. No RCP shall be started with any RCS cold leg temperature [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR] unless the secondary side water temperature of each steam generator (SG) is [50]°F above each of the RCS cold leg temperatures. --------------------------------------------------------------------------------------------------

APPLICABILITY: MODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required loop inoperable.

A.1 Initiate action to restore a second loop to OPERABLE status. AND Immediately CTS 3.1.a.2.A 2 3.1.a.2.A DOC M01, 3.1.a.2.A All changes are 1 unless otherwise noted 2, "SHUTDOWN MARGIN" 3 CTS RCS Loops - MODE 4 3.4.6 WOG STS 3.4.6-2 Rev. 3.0, 03/31/04 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 --------------NOTE-------------- Only required if RHR loop is OPERABLE. -------------------------------------

Be in MODE 5.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Two required loops inoperable.

OR Required loop not in operation.

B.1 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM

of LCO 3.1.1.

AND B.2 Initiate action to restore one loop to OPERABLE status and operation.

Immediately

Immediately 3.1.a.2.A 3.1.a.2.A, DOC M03

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.6.2 Verify SG secondary side water levels are [17]% for required RCS loops.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.6.3 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ---------------------------------------------------------------------

Verify correct breaker alignment and indicated power are available to each required pump.

7 days DOC M04 1 DOC M05 5 DOC M05 JUSTIFICATION FOR DEVIATIONS ITS 3.4.6, RCS LOOPS - MODE 4

1. 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.

2. ISTS 3.4.6 LCO Note 2 provides a temperature restriction for starting a reactor coolant pump (RCP). The temperature value is the Low Temperature Overpressure Protection (LTOP) arming temperature, and for the ISTS is

< 275ºF. However, the value for Kewaunee Power Station is

< 200ºF, as shown in CTS 3.1.a.1.C. Since the minimum temperature for MODE 4 is defined as > 200ºF, the restriction is not needed in this Specification (i.e., the plant cannot be in MODE 4 and violate the RCP minimum temperature restriction for startup). Therefore, this Note has not been included in the Kewaunee ITS. Furthermore, since there is only one Note for the LCO, the term "NOTES" has been changed to "NOTE" and numbering of the first Note is not required.

3. The title of the LCO has been provided since this is the first reference to the LCO.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Loops - MODE 4 B 3.4.6 WOG STS B 3.4.6-1 Rev. 3.1, 12/01/05 All changes are 1 unless otherwise notedB 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Loops - MODE 4

BASES BACKGROUND In MODE 4, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat to either the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. The reactor coolant is circulated through [four] RCS loops connected in parallel to the reactor vessel, each loop containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and to prevent boric acid stratification. two In MODE 4, either RCPs or RHR loops can be used to provide forced circulation. The intent of this LCO is to provide forced flow from at least one RCP or one RHR loop for decay heat removal and transport. The flow provided by one RCP loop or RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that two paths be available to provide redundancy for decay heat removal. OPERABLE 2 APPLICABLE In MODE 4, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event. The RCS ANALYSES and RHR loops provide this circulation.

anwould affect 3INSERT 1 RCS Loops - MODE 4 satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide

redundancy for heat removal.

Note 1 permits all RCPs or RHR pumps to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests that are designed to validate various accident analyses values. One of the tests performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow. The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be The 5 B 3.4.6 3 INSERT 1 The current licensing basis of Kewaunee Power Station (KPS) does not consider boron dilution events during MODE 4 conditions. Therefore, no safety analyses related to the loss of RCS loops are performed for MODE 4.

Insert Page B 3.4.6-1 o -

RCS Loops - MODE 4 B 3.4.6 WOG STS B 3.4.6-2 Rev. 3.1, 12/01/05 BASES LCO (continued)

stopped for a short period of time. The Note permits the stopping of the pumps in order to perform this test and validate the assumed analysis values. If changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values must be revalidated by conducting the test again. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met along with any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant with boron concentrations less than required to meet SDM of LCO 3.1.1, therefore maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation and

b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 requires that the secondary side water temperature of each SG be

[50]°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR]. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

4 5the 6 thereby"SHUTDOWN MARGIN", 5An OPERABLE RCS loop comprises an OPERABLE RCP and an OPERABLE SG, which has the minimum water level specified in

SR 3.4.6.2.

Similarly for the RHR System, an OPERABLE RHR loop comprises an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are

OPERABLE if they are capable of be ing powered and are able to provide forced flow if required.

RCS Loops - MODE 4 B 3.4.6 WOG STS B 3.4.6-3 Rev. 3.1, 12/01/05 BASES APPLICABILITY In MODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing.

One loop of either RCS or RHR provides sufficient circ ulation for these purposes. However, two loops consisting of any combination of RCS and RHR loops are required to be OPERABLE to meet single failure considerations. provide redundant capability for heat removal 3 Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops - MODES 1 and 2," LCO 3.4.5, "RCS Loops - MODE 3," LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -

High Water Level" (MODE 6), and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).

4 7; 3 ;4 ACTIONS A.1 If one required loop is inoperable, redundancy for heat removal is lost.

Action must be initiated to restore a second RCS or RHR loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

A.2 If restoration is not accomplished and an RHR loop is OPERABLE, the unit must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the unit to MODE 5 is a conservative action with regard to decay heat removal. With only one RHR loop OPERABLE, redundancy for decay heat removal is

lost and, in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 rather than MODE 4. The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

This Required Action is modified by a Note which indicates that the unit must be placed in MODE 5 only if a RHR loop is OPERABLE. With no RHR loop OPERABLE, the unit is in a condition with only limited cooldown capabilities. Therefore, the actions are to be concentrated on the restoration of a RHR loop, rather than a cooldown of extended duration.

RCS Loops - MODE 4 B 3.4.6 WOG STS B 3.4.6-4 Rev. 3.1, 12/01/05 BASES

ACTIONS (continued)

B.1 and B.2

If two required loops are inoperable or a required loop is not in operation, except during conditions permitted by Note 1 in the LCO section, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. The required margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required RCS or RHR loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

SR 3.4.6.2

SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is [17]%. If the SG secondary side narrow range water level is < [17]%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of

SG level.

All changes are 1 unless otherwise noted 5the 5 5 RCS Loops - MODE 4 B 3.4.6 WOG STS B 3.4.6-5 Rev. 3.1, 12/01/05 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.6.3

Verification that each required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to each required pump. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

REFERENCES None.

JUSTIFICATION FOR DEVIATIONS ITS 3.4.6 BASES, RCS LOOPS - MODE 4

1. The ISTS Bases 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.

2. The ISTS Bases Background section states the other intent of the LCO is to require that two paths be available to provide redundancy for decay heat removal. This statement has been changed to state the other intent of the LCO is to require the two paths to be OPERABLE to provide redundancy for decay heat removal. This change to the Background statement places it in agreement with the Bases LCO and Specification LCO statements to ensure it is understood that the intent is for the two paths to be OPERABLE.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis or licensing basis description.

4. 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.

5. Changes are made to be consistent with changes made to the Specification.

6. The title of the LCO has been provided since this is the first reference to the LCO within the LCO 3.4.6 Bases.

7. The correct ITS number has been provided (changed to be consistent with a number change to the actual specification in Section 3.9).

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.6, RCS LOOPS - MODE 4 There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 7 ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01ITS ITS 3.4.7 3.1 REACTOR COOLANT SYSTEM APPLICABILITY Applies to the OPERATING status of the Reactor Coolant System (RCS).

OBJECTIVE To specify those LIMITING CONDITIONS FOR OPERATION of the Reactor Coolant System which must be met to ensure safe reactor operation.

SPECIFICATIONS

a. Operational Components

1. Reactor Coolant Pumps A. At least one reactor coolant pump or one residual heat removal pump shall be in operation when a reduction is made in the boron concentration of the reactor

coolant. Applicability See ITS 3.4.5 and 3.4.6 Add proposed LCO 3.4.7 Notes 1 and 4 M01 LCO 3.4.7 B. When the reactor is in the OPERATING mode, except for low power tests, both reactor coolant pumps shall be in operation. See ITS 3.4.4 C. A reactor coolant pump shall not be started with one or more of the RCS cold leg temperatures 200°F unless the secondary water temperature of each steam generator is < 100

°F above each of the RCS cold leg temperatures. A02 LCO 3.4.7 Note 3 2. Decay Heat Removal Capability A. At least two of the following four heat sinks shall be OPERABLE whenever the average reactor coolant temperature is 350°F but > 200

°F. 1. Steam Generator 1A

2. Steam Generator 1B

3. Residual Heat Removal Train A

4. Residual Heat Removal Train B If less than the above number of required heat sinks are OPERABLE, then corrective action shall be taken immediately to restore the minimum number to

the OPERABLE status. See ITS 3.4.6 Amendment No. 165 TS 3.1-1 03/11/2003 Page 1 of 2 ITS ITS 3.4.7 B. Two residual heat removal trains shall be OPERABLE whenever the average reactor coolant temperature is 200°F and irradiated fuel is in the reactor, except when in the REFUELING MODE with the minimum water level above the top of the vessel flange 23 feet, one train may be inoperable for maintenance.

1. Each residual heat removal train shall be comprised of:

a) One OPERABLE residual heat removal pump b) One OPERABLE residual heat removal heat exchanger c) An OPERABLE flow path consisting of all valves and piping associated with the above train of components and required to remove decay heat from the core during normal shutdown situations. This flow path shall be capable of taking suction from the appropriate Reactor Coolant System

hot leg and returning to the Reactor Coolant System.

2. If one residual heat removal train is inoperable, then corrective action shall be taken immediately to return it to the OPERABLE status.

LCO 3.4.7 Applicability ACTION A See ITS 3.9.3 LA01 Page 2 of 2 L01Add proposed LCO 3.4.7 Note 2 Add proposed SR 3.4.7.1 and SR 3.4.7.3 M02Add proposed ACTION C for loop not in operationM04A01M03Add proposed ACTION C for two inoperable RHR loops A03 L02Add proposed Required Action A.2 L02Add proposed ACTION B L02Add proposed SR 3.4.7.2 Amendment No. 165 TS 3.1-2 03/11/2003 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.1.a.1.C restricts starting a reactor coolant pump with one or more of the RCS cold leg temperatures < 200°F unless the secondary water temperature of each steam generator is < 100°F above each of the RCS cold leg temperatures.

This restriction is included in ITS 3.4.7 as LCO Note 3; however, the statement "with one or more of the RCS cold leg temperatures < 200°F" is not included in the Note. However, the ITS 3.4.7 Applicability is MODE 5 (which is essentially equivalent to the CTS wording) with RCS loops filled. This changes the CTS by not including the redundant words that are already covered by the MODE 5 Applicability in the Note restriction.

ITS MODE 5 is the equivalent MODE covering the condition of less than or equal to 200°F. This is shown in ITS Table 1.1-1, which defines that MODE 5 has a minimum average reactor coolant temperature of 200°F. Since the Applicability of LCO 3.4.7 is MODE 5, the words are redundant and are not necessary to be included in ITS LCO Note 3. This change is designated as administrative and is acceptable because it does not result in any technical change to the CTS.

A03 CTS 3.1.a.2.B, which requires two RHR trains to be OPERABLE, is applicable whenever the average reactor coolant temperature is 200ºF and irradiated fuel is in the reactor. ITS 3.4.7, which also includes similar RHR train OPERABILITY requirements (as modified by DOC L02), is applicable in MODE 5 with the RCS loops filled. RHR requirements in MODE 5 with the RCS loops not filled are provided in LCO 3.4.8 and the MODE 6 RHR requirements are provided in LCO 3.9.5 and LCO 3.9.6. This changes the CTS by splitting these RHR

requirements into four separate LCOs.

This change is acceptable since all facets of MODES 5 and 6 operation are covered in the four ITS Specifications. This change is designated as administrative because it does not result in any technical changes.

MORE RESTRICTIVE CHANGES M01 CTS 3.1.a.1.A, which (in MODE 5) requires a residual heat removal (RHR) pump to be in operation, is applicable in MODE 5 only when a reduction is made in the boron concentration of the reactor coolant. ITS 3.4.7, in part, requires an RHR loop to be in operation and is applicable at all times when in MODE 5 with the RCS loops filled, except as allowed in LCO Notes 1 and 4. Note 1 allows the required RHR pump to not be in operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided a) no operations are permitted that would cause introduction of coolant into the Kewaunee Power Station Page 1 of 6 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and b) core outlet temperature is maintained at least 10ºF below saturation temperature. Note 4 allows the required RHR pump to not be in operation during planned heatup to MODE 4 when at least one RCS loop is in operation. This changes the CTS by specifying that the LCO requirement for an RHR pump to be in operation is applicable in MODE 5 with the RCS loops filled at all times except for those conditions specified in ITS 3.4.7 LCO Notes 1 and 4.

In MODE 5, CTS 3.1.a.1.A requires at least one RHR pump to be in operation when a reduction is made in the boron concentration of the reactor coolant. The CTS applicability statement applies during only those times when a change in the boron concentration of the reactor coolant is made; it is not for decay heat removal purposes. While a change in boron concentration may occur in

essentially any MODE; this discussion is only applicable during those times when the plant is in COLD SHUTDOWN (equivalent to ITS MODE 5) with the RCS loops filled. Other MODES are discussed in other ITS discussions. The ITS 3.4.7 Applicability is MODE 5 at all times with the RCS loops filled, except for the conditions in ITS 3.4.7 LCO Notes 1 and 4, and primarily addresses the decay heat removal function, but also covers the boron mixing issue. RHR pumps are utilized in MODE 5 to provide for removal of residual heat from the reactor core to the RHR heat exchangers, and to ensure proper boron mixing within the reactor coolant. The MODE 5 decay heat removal requirements are low enough that a single RHR pump is sufficient to remove core decay heat. The purpose of Note 1 is to permit all RHR pumps to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period to perform certain infrequent tests which require reactor coolant flow to be stopped. With the RHR pumps removed from operation, there is no forced flow of reactor coolant. As a result, the reactor coolant is in natural circulation and there is a risk of boron stratification or the formation of a vapor bubble that may cause a natural circulation flow obstruction should the RHR pumps be removed from service for longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. This change is acceptable because the time limitation to have the RHR pumps removed from operation ensures that both boron stratification and inadequate residual heat removal do not occur should multiple one hour periods be required to complete the testing. The purpose of Note 4 is to allow plant heatup to MODE 4. This Note requires though, that an RCS loop be in operation during this time period. This will ensure adequate boron mixing of the reactor coolant during the heatup. This change is designated more restrictive because one RHR pump is required to be in operation in MODE 5 at all times with the RCS loops filled, except for those conditions specified in ITS 3.4.7 LCO Notes 1 and 4.

M02 CTS 3.1.a.1.A does not contain any ACTIONS to take should there be less than the required number of RHR pumps in operation while in MODE 5. As a result, CTS 3.0.c would be normally entered. However, LCO 3.0.c states that it is not applicable in COLD SHUTDOWN or REFUELING. Since the RHR pump only has to be in operation when a reduction in boron concentration is being made, and for this Specification, the unit is already in MODE 5, the CTS does not provide any compensatory measures. Therefore, 10 CFR 50.36(c)(2)(i) would apply, which states to shutdown the unit. However, no times are provided to complete the shutdown and no further actions (i.e., suspend boron concentration reduction) are required. ITS 3.4.7 ACTION C specifies the Required Actions for a required RHR loop not in operation, and requires immediate suspension of Kewaunee Power Station Page 2 of 6 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and initiation of action to restore one RHR loop to operation. This changes the CTS by adding a

new ACTION when the required RHR pump is not in operation.

The purpose of CTS LCO 3.0.c is to place the unit outside of the Applicability of the Specification. The change is acceptable since ITS 3.4.7 ACTION C effectively places the unit outside of the Applicability for a loop not in operation by requiring the plant to immediately suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and to initiate action to restore one RHR loop to operation. The proposed Required Actions reflect the importance of maintaining operation for decay heat removal and boron mixing. This change is designated as more restrictive because a new proposed ACTIONS has been added

M03 CTS 3.1.a.2.B does not contain any ACTIONS to take if both required RHR loops are inoperable. As a result, CTS 3.0.c would be normally entered. However, LCO 3.0.c states that it is not applicable in COLD SHUTDOWN or REFUELING.

Since the RHR pump only has to be in operation when a reduction in boron concentration is being made, and for this Specification, the unit is already in MODE 5, the CTS does not provide any compensatory measures. Therefore, 10 CFR 50.36(c)(2)(i) would apply, which states to shutdown the unit. However, no times are provided to complete the shutdown and no further actions (i.e., suspend boron concentration reductions) are required. ITS 3.4.7 ACTION C (ISTS 3.4.7 ACTION C) provides the Required Actions when no required loops are OPERABLE. The Required Actions are to immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1 and to immediately initiate action to restore one RHR loop to OPERABLE status. This changes the CTS by adding a new ACTION when both required RHR loops are inoperable.

The change is acceptable because the Completion Times are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Times. The immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and immediately initiating action to restore one loop to OPERABLE status reflects the importance of maintaining decay heat removal and boron mixing capability. Also, coolant added to the RCS without forced circulation could introduce unmixed coolant into the core, which could reduce the required margin to criticality. This change is designated as more restrictive because a new ACTION is being added to the ITS that was not

required by the CTS.

M04 CTS 3.1.a.1.A requires one RHR pump to be in operation under certain conditions, but does not provide a Surveillance Requirement to periodically verify the required pump is in operation. ITS SR 3.4.7.1 requires verification that the required RHR loop is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS 3.1.a.2.B requires two RHR trains to be OPERABLE, but does not provide a Surveillance Requirement to periodically verify the required loops are OPERABLE. ITS SR 3.4.7.3 requires Kewaunee Power Station Page 3 of 6 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED verification that each required RHR pump is OPERABLE every 7 days by verifying correct breaker alignment and indicated power are available to each required pump. A Note further explains that the Surveillance is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. This changes the CTS by adding new Surveillance Requirements to periodically verify the required pump is in operation and the required pumps are OPERABLE.

The purpose of ITS SR 3.4.7.1 is to ensure that one RHR loop is in operation providing forced flow of the reactor coolant for heat removal. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. The purpose of ITS SR 3.4.7.3 is to ensure that each required RHR pump is OPERABLE. Verification of proper breaker alignment and power availability ensures that an RHR pump can be placed in operation, if needed, to maintain residual heat removal and reactor coolant circulation. These changes are acceptable because the Surveillance Requirements ensure the availability of the system to remove reactor residual heat and to provide proper boron mixing via the forced circulation of the reactor coolant. This change is designated as more restrictive because new SRs have been added to periodically verify the requirements of the LCO are met.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES

LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.1.a.2.B requires two residual heat removal (RHR) trains be OPERABLE with each train consisting of the following: 1) one OPERABLE residual heat removal pump; 2) one OPERABLE residual heat removal heat exchanger; and, 3) an OPERABLE flow path consisting of all valves and piping associated with the above train of components and required to remove decay heat from the core during normal shutdown situations. This flow path shall be capable of taking suction from the appropriate Reactor Coolant System hot leg

and returning to the Reactor Coolant System. ITS LCO 3.4.7 requires two RHR loops to be OPERABLE, but does not define the components and the associated flow path that comprise an OPERABLE RHR train. This changes the CTS by moving the description of the RHR trains to the Bases.

The removal of these details which are related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains all necessary requirements in the LCO to ensure OPERABILITY of the RHR loops in MODE 5. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated Kewaunee Power Station Page 4 of 6 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) ITS 3.4.7 LCO Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Surveillance testing, provided that the other RHR loop is OPERABLE and in operation. The CTS does not contain this allowance; CTS 3.1.a.2.B requires both RHR trains to be OPERABLE at all times when in MODE 5 with the RCS loops filled. This changes the CTS by providing an allowance for one of the RHR loops to be inoperable for a limited period of time to perform required Surveillance testing.

Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Surveillance testing, provided that the other RHR loop is OPERABLE and in operation. The purpose of the Note is to permit periodic Surveillance tests to be performed on the inoperable loop during a time when such testing is safe and

possible. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance is acceptable since the remaining RHR loop is OPERABLE and in operation. Thus the decay heat removal and boron mixing functions are still being met. This change is less restrictive because conditions that allow removal of one RHR loop from service have been added to the ITS that were not in the CTS.

L02 (Category 1 - Relaxation of LCO Requirements) CTS 3.1.a.2.B requires two RHR trains to be OPERABLE whenever the average reactor coolant temperature

is < 200ºF and irradiated fuel is in the reactor (i.e., ITS MODE 5). ITS LCO 3.4.7 provides an allowance that a steam generator with secondary side water level

> 5% can replace one of the two RHR trains. Furthermore, due to this allowance, the ITS provides alternate actions (ITS 3.4.7 Required Action A.2 and ACTION B) when only one RHR train is OPERABLE. In addition, ITS SR 3.4.7.2 requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the secondary side water level of the required

steam generator is

> 5%. This changes the CTS by only requiring one RHR train to be OPERABLE, provided the secondary side water level of a steam generator

is > 5%, and provides compensatory actions when this allowance is being used and is not met, as well as a Surveillance Requirement to periodically verify the limit is being met.

The purpose of CTS 3.1.a.2.B is to provide two methods to ensure decay heat can be removed from the reactor coolant. This ensures that if one method fails, a second method is still available. ITS LCO 3.4.7 continues to ensure two methods are required. The first method must be an RHR train. This ensures the primary method can remove the decay heat using forced circulation. The second heat removal method can be either another RHR train, or a steam generator via natural circulation. Even though steam generators cannot produce steam in this MODE, they are capable of being a heat sink due to their large containment volume of secondary water. As long as the secondary side water level is at a lower temperature than the reactor coolant, heat transfer will occur. This is stated in the NRC Information Notice 95-35, and in the ITS 3.4.7 Bases. Therefore, this change is considered acceptable since a second method is still being required and an RHR loop OPERABLE and in operation is still the primary Kewaunee Power Station Page 5 of 6 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED Kewaunee Power Station Page 6 of 6 method required by LCO 3.4.7. Appropriate Actions have been added (ITS 3.4.7 Required Action A.2 and ACTION B) to immediately initiate action to restore the inoperable RHR loop or to restore the secondary side water level of the steam generator to within limit, when the second heat removal method (either a second RHR loop or a steam generator) is inoperable. Furthermore, a new Surveillance has been added to ensure secondary side water level of the required steam generator is periodically verified to be within the limit (> 5%) when the steam generator is being used as the second heat removal method. This change is designated as less restrictive because the LCO requirements in the ITS are less restrictive than the LCO requirements in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Loops - MODE 5, Loops Filled 3.4.7 WOG STS 3.4.7-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.7 RCS Loops - MODE 5, Loops Filled

LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either:

3.1.a.1.A, 3.1.a.2.B 4 a. One additional RHR loop shall be OPERABLE or

5 b. The secondary side water level of at least [two] steam generators (SGs) shall be [17]%. one

NOTES-------------------------------------------

5 1. The RHR pump of the loop in operation may be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided: DOC M01

a. No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature. , "SHUTDOWN MARGIN (SDM)" 2 DOC L01 2. One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

1 S 3.1.a.1.C 3. No reactor coolant pump shall be started with one or more RCS cold leg temperatures [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR] unless the secondary side water temperature of each SG is [50]°F above each of the RCS cold leg temperatures.

3< 100

4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation. DOC M01 --------------------------------------------------------------------------------------------------

3.1.a.1.A, 3.1.a.2.B APPLICABILITY: MODE 5 with RCS Loops Filled.

RCS Loops - MODE 5, Loops Filled 3.4.7 WOG STS 3.4.7-2 Rev. 3.0, 03/31/04 All changes are 1 unless otherwise notedCTS ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR loop inoperable.

AND One RHR loop OPERABLE.

A.1 Initiate action to restore a second RHR loop to OPERABLE status.

OR A.2 Initiate action to restore required SGs secondary

side water level to within

limit.

Immediately

B. One or more required SGs with secondary side water level not within limit.

AND One RHR loop OPERABLE.

B.1 Initiate action to restore a second RHR loop to OPERABLE status.

OR B.2 Initiate action to restore required SGs secondary

side water level to within

limit.

Immediately

C. No required RHR loops OPERABLE.

OR Required RHR loop not in operation.

C.1 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM

of LCO 3.1.1.

AND C.2 Initiate action to restore one RHR loop to OPERABLE status and operation.

Immediately

Immediately 3.1.a.2.B.2 2 4 4 DOC L02 4 DOCS M02 and M03 RCS Loops - MODE 5, Loops Filled 3.4.7 WOG STS 3.4.7-3 Rev. 3.0, 03/31/04 All changes are unless otherwise noted 1SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.7.2 Verify SG secondary side water level is [17]% in required SGs.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.7.3 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ---------------------------------------------------------------------

Verify correct breaker alignment and indicated power are available to each required RHR pump.

7 days DOC M04 DOC L02 5 4 5 DOC M04 JUSTIFICATION FOR DEVIATIONS ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED

1. Typographical error corrected.

2. The title of the LCO has been provided since this is the first reference to the LCO.

3. The ISTS LCO 3.4.7 Note 3 provides a bracketed allowance to either specify the minimum RCS cold leg temperature a reactor coolant pump can be started ( 275ºF in the ISTS) or to specify that the RCS cold leg temperature limit is the Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR. Kewaunee Power Station (KPS) has decided not to incorporate a PTLR allowance into the ITS, therefore the Note should reference the actual LTOP arming temperature. However, the current LTOP enabling temperature is 200°F, which is the exact temperature value at which MODE 5 starts. Thus, the words "with one or more RCS cold legs temperatures " and the KPS enabling temperature of 200°F are redundant and have not been included (i.e., the words describing the restriction is needed). In addition, the ISTS LCO 3.4.7 Note 3 provides a bracketed value for the SG secondary side water temperature limit ( 50ºF in the ISTS). The bracketed value in the ISTS has been replaced with the KPS CTS value for this limit (< 100ºF).

4. Changes made to be consistent with changes made to the LCO.

5. 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 revi sed to reflect the current plant design.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Loops - MODE 5, Loops Filled B 3.4.7 WOG STS B 3.4.7-1 Rev. 3.1, 12/01/05 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 RCS Loops - MODE 5, Loops Filled

BASES BACKGROUND In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and transfer this heat either to the steam generator (SG) secondary side coolant via natural circulation (Ref. 1) or the component cooling water via the residual heat removal (RHR) heat exchangers. While the principal means for decay heat removal is via the RHR System, the SGs via natural circulation (Ref. 1) are specified as a backup means for redundancy. Even though the SGs cannot produce steam in this MODE, they are capable of being a heat sink due to their large contained volume of secondary water. As long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.

2 of In MODE 5 with RCS loops filled, the reactor coolant is circulated by means of two RHR loops connected to the RCS, each loop containing an RHR heat exchanger, an RHR pump, and appropriate flow and temperature instrumentation for control, protection, and indication. One RHR pump circulates the water through the RCS at a sufficient rate to prevent boric acid stratification.

The number of loops in operation can vary to suit the operational needs.

The intent of this LCO is to provide forced flow from at least one RHR loop for decay heat removal and transport. The flow provided by one RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that a second path be available to provide redundancy for heat removal. OPERABLE 4 The LCO provides for redundant paths of decay heat removal capability.

The first path can be an RHR loop that must be OPERABLE and in operation. The second path can be another OPERABLE RHR loop or maintaining two SGs with secondary side water levels [17]% to provide an alternate method for decay heat removal via natural circulation (Ref. 1).

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event. The RHR 3would affectnarrow range 5 5 5 is one INSERT 1 ANALYSES loops provide this circulation.

an RCS Loops - MODE 5 (Loops Filled) satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

B 3.4.7 5 INSERT 1 The current licensing basis of Kewaunee Power Station (KPS) does not consider boron dilution events during MODE 5 conditions. Therefore, no safety analyses related to the loss of RCS loops are performed for MODE 5.

Insert Page B 3.4.7-1 o -

RCS Loops - MODE 5, Loops Filled B 3.4.7 WOG STS B 3.4.7-2 Rev. 3.1, 12/01/05 BASES

LCO The purpose of this LCO is to require that at least one of the RHR loops be OPERABLE and in operation with an additional RHR loop OPERABLE or two SGs with secondary side water level [17]%. One RHR loop provides sufficient forced circulation to perform the safety functions of the

reactor coolant under these conditions. An additional RHR loop is required to be OPERABLE to meet single failure considerations.

However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is two SGs with their secondary side water levels [17]%. Should the operating RHR loop fail, the SGs could be used to remove the decay heat via natural circulation. narrow range 5 one 1 3provide redundant capability for heat removal 3 3narrow range its 1 one 5 Note 1 permits all RHR pumps to be removed from operation 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests designed to validate various accident analyses values. One of the tests performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow. The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits stopping of the pumps in order to perform this test and validate the assumed analysis values. If changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values must be revalidated by conducting the test again. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not likely during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant with boron concentrations less than required to meet SDM of LCO 3.1.1, therefore maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation and by 8"SHUTDOWN MARGIN (SDM)," 6 b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.

7 a RCS Loops - MODE 5, Loops Filled B 3.4.7 WOG STS B 3.4.7-3 Rev. 3.1, 12/01/05 All changes are 1 unless otherwise notedBASES LCO (continued)

Note 3 requires that the secondary side water temperature of each SG be [50]°F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with an RCS cold leg temperature [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR].

This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. A SG can perform as a heat sink via natural circulation when it has an adequate water level and is OPERABLE.

APPLICABILITY In MODE 5 with RCS loops fille d, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient circulation for these purposes. However, one additional RHR loop is required to be OPERABLE, or the secondary side water level of at least [two] SGs is required to be [17]%. 100 < 7 3narrow range one 1 Operation in other MODES is covered by:

5 LCO 3.4.4, "RCS Loops - MODES 1 and 2;" LCO 3.4.5, "RCS Loops - MODE 3;" LCO 3.4.6, "RCS Loops - MODE 4;" LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled;" LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -

High Water Level" (MODE 6)," and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation -

Low Water Level" (MODE 6)."

6 9;3 4 RCS Loops - MODE 5, Loops Filled B 3.4.7 WOG STS B 3.4.7-4 Rev. 3.1, 12/01/05 BASES ACTIONS A.1, A.2, B.1 and B.2 has 1 3If one RHR loop is OPERABLE and either the required SGs have secondary side water levels < [17]%, or one required RHR loop is inoperable, redundancy for heat removal is lost. Action must be initiated

immediately to restore a second RHR loop to OPERABLE status or to restore the required SG secondary side water levels. Either Required Action will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

5 narrow range 3

C.1 and C.2

If a required RHR loop is not in operation, except during conditions permitted by Note 1, or if no required loop is OPERABLE, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Times reflect the importance of maintaining operation for heat removal.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and

alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.7.2

Verifying that at least two SGs are OPERABLE by ensuring their secondary side narrow range water levels are [17]% ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.

its one is 1 3 5 is RCS Loops - MODE 5, Loops Filled B 3.4.7 WOG STS B 3.4.7-5 Rev. 3.1, 12/01/05 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.7.3

Verification that each required RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to each required RHR pump. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. If secondary side water level is [17]% in at least two SGs, this Surveillance is not needed. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

REFERENCES 1. NRC Information Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation." 1 3 5 onenarrow range JUSTIFICATION FOR DEVIATIONS ITS 3.4.7 BASES, RCS LOOPS - MODE 5, LOOPS FILLED

1. The ISTS Bases 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.

2. Typographical error/omission corrected.

3. Changes made to be consistent with changes made to the ITS.

4. The ISTS Bases Background section states the other intent of the LCO is to require that two paths be available to provide redundancy for decay heat removal. This statement has been changed to state the other intent of the LCO is to require

the two paths to be OPERABLE to provide redundancy for decay heat removal.

This change to the Background statement places it in agreement with the Bases LCO and Specification LCO statements to ensure it is understood that the intent is for the two paths to be OPERABLE.

5. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis or licensing basis description.

6. 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.

7. Words have been changed to allow for there being other conditions wherein the test might be run safely.

8. The title of the LCO has been provided since this is the first reference to the LCO.

9. The correct ITS number has been provided (changed to be consistent with a number change to the actual specification in Section 3.9).

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 8 ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.4.8 A013.1 REACTOR COOLANT SYSTEM APPLICABILITY Applies to the OPERATING status of the Reactor Coolant System (RCS).

OBJECTIVE To specify those LIMITING CONDITIONS FOR OPERATION of the Reactor Coolant System which must be met to ensure safe reactor operation.

SPECIFICATIONS

a. Operational Components See ITS 3.4.5 and 3.4.6 1. Reactor Coolant Pumps A. At least one reactor coolant pump or one residual heat removal pump shall be in operation when a reduction is made in the boron concentration of the reactor

coolant. B. When the reactor is in the OPERATING mode, except for low power tests, both reactor coolant pumps shall be in operation.

C. A reactor coolant pump shall not be started with one or more of the RCS cold leg temperatures 200°F unless the secondary water temperature of each steam generator is < 100

°F above each of the RCS cold leg temperatures.

2. Decay Heat Removal Capability A. At least two of the following four heat sinks shall be OPERABLE whenever the average reactor coolant temperature is 350°F but > 200

°F. 1. Steam Generator 1A

2. Steam Generator 1B

3. Residual Heat Removal Train A

4. Residual Heat Removal Train B If less than the above number of required heat sinks are OPERABLE, then corrective action shall be taken immediately to restore the minimum number to

the OPERABLE status. See ITS 3.4.4 See ITS 3.4.6 Page 1 of 2 Applicability LCO 3.4.8 See ITS 3.4.7 and 3.4.12M01Add proposed LCO 3.4.8 Note 1 Amendment No. 165 TS 3.1-1 03/11/2003 A01 ITS ITS 3.4.8 B. Two residual heat removal trains shall be OPERABLE whenever the average reactor coolant temperature is 200°F and irradiated fuel is in the reactor, except when in the REFUELING MODE with the minimum water level above the top of the vessel flange 23 feet, one train may be inoperable for maintenance. A02 LCO 3.4.8 Applicability See ITS 3.9.3 1. Each residual heat removal train shall be comprised of:

a) One OPERABLE residual heat removal pump b) One OPERABLE residual heat removal heat exchanger c) An OPERABLE flow path consisting of all valves and piping associated with the above train of components and required to remove decay heat from the core during normal shutdown situations. This flow path shall be capable of taking suction from the appropriate Reactor Coolant System

hot leg and returning to the Reactor Coolant System. LA01Add proposed LCO 3.4.8 Note 2 L01 2. If one residual heat removal train is inoperable, then corrective action shall be taken immediately to return it to the OPERABLE status.

ACTION A Add proposed ACTION B for two inoperable RHR loops M03M04Add proposed ACTION B for loop not in operationM02Add proposed SR 3.4.8.1 and SR 3.4.8.2 Amendment No. 165 TS 3.1-2 03/11/2003 Page 2 of 2 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.1.a.2.B, which requires two RHR trains to be OPERABLE, is applicable whenever the average reactor coolant temperature is 200°F and irradiated fuel is in the reactor. ITS 3.4.8, which also includes similar RHR train OPERABILITY requirements, is applicable in MODE 5 with the RCS loops not filled. RHR requirements in MODE 5 with the RCS loops filled are provided in LCO 3.4.7 and the MODE 6 RHR requirements are provided in LCO 3.9.5 and LCO 3.9.6. This changes the CTS by splitting these RHR requirements into four separate LCOs.

This change is acceptable since all facets of MODES 5 and 6 operation are covered in the four ITS Specifications. This change is designated as administrative because it does not result in any technical changes.

MORE RESTRICTIVE CHANGES

M01 CTS 3.1.a.1.A, which (in MODE 5) requires a residual heat removal (RHR) pump to be in operation, is applicable in MODE 5 only when a reduction is made in the boron concentration of the reactor coolant. ITS 3.4.8, in part, requires an RHR loop to be in operation and is applicable at all times when in MODE 5 with the RCS loops not filled, except as allowed in LCO 3.4.8 Note. Note 1 allows the required RHR pump to not be in operation for 15 minutes when switching from one loop to the other provided a) core outlet temperature is maintained > 10°F below saturation temperature; b) no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and c) no draining operations to further reduce the RCS water volume are permitted. This changes the CTS by specifying that the LCO requirement for an RHR pump to be in operation is applicable in MODE 5 with the RCS loops not filled at all times except for those conditions specified in ITS LCO 3.4.8 Note 1.

In MODE 5, CTS 3.1.a.1.A requires at least one RHR pump to be in operation when a reduction is made in the boron concentration of the reactor coolant. The CTS applicability statement applies during only those times when a reduction in the boron concentration of the reactor coolant is made; it is not for decay heat removal purposes. While a change in boron concentration may occur in

essentially any MODE; this discussion is only applicable during those times when the plant is in COLD SHUTDOWN (equivalent to ITS MODE 5) with the RCS loops not filled. Other MODES are discussed in other ITS discussions. The ITS 3.4.8 Applicability is MODE 5 at all times with the RCS loops not filled, except for the conditions in ITS 3.4.8 LCO Note 1, and primarily addresses the decay heat Kewaunee Power Station Page 1 of 5 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED removal function, but also covers the boron mixing issue. RHR pumps are utilized in MODE 5 to provide for removal of residual heat from the reactor core to the RHR heat exchangers, and to ensure proper boron mixing within the reactor coolant. The MODE 5 decay heat removal requirements are low enough that a single RHR pump is sufficient to remove core decay heat. The purpose of Note 1 is to permit all RHR pumps to be removed from operation for 15 minutes to allow switching from one loop to the other. With the RHR pumps removed from operation, there is no forced flow of reactor coolant. As a result, the reactor coolant is in natural circulation and there is a risk of boron stratification or the formation of a vapor bubble that may cause a natural circulation flow obstruction should the RHR pumps be removed from service for longer than the 15 minute period. This change is acceptable because the short time limitation to have the RHR pumps removed from operation ensures that both boron stratification and inadequate residual heat removal do not occur. This change is designated more restrictive because one RHR pump is required to be in operation in MODE 5 at all times with the RCS loops not filled, except for the condition specified in ITS 3.4.8 LCO Note 1.

M02 CTS 3.1.a.1.A does not contain any ACTIONS to take should there be less than the required number of RHR pumps in operation. As a result, CTS 3.0.c would normally be entered. However, LCO 3.0.c states that it is not applicable in COLD SHUTDOWN or REFUELING. Since the RHR pump only has to be in operation when a reduction in boron concentration is being made, and, for this Specification, the unit is already in MODE 5, the CTS does not provide any compensatory measures. Therefore, 10 CFR 50.36(c)(2)(i) would apply, which states to shutdown the unit. However, no times are provided to complete the shutdown and no further actions (i.e., suspend boron concentration reductions are required. Note that while no ACTIONS are required, KPS in all likelihood would suspend dilution if this occurred. ITS 3.4.8 ACTION B specifies the Required Actions for a required RHR loop not in operation, and requires immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and initiation of action to restore one RHR loop to operation. This changes the CTS by adding a new ACTION when the required RHR pump is not in operation.

The purpose of the ACTIONS should be to place the unit outside of the Applicability of the Specification. ITS 3.4.8 ACTION B effectively places the unit in an equivalent condition by requiring the plant to immediately suspend operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and to initiate action to restore one RHR loop to operation. The proposed Required Actions reflect the importance of maintaining operation for decay heat removal and boron mixing. This change is designated as more restrictive because a new proposed ACTION has been added.

M03 CTS 3.1.a.2.B does not contain any ACTIONS to take if both required RHR loops are inoperable in MODE 5. As a result, CTS 3.0.c would be entered, which requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in HOT STANDBY (equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , to be in HOT SHUTDOWN (equivalent to ITS MODE 3) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and to be in COLD SHUTDOWN Kewaunee Power Station Page 2 of 5 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED (equivalent to ITS MODE 5) within the subsequent 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . However, since the unit is already in MODE 5, the CTS 3.0.c requirement does not really provide any relevant compensatory measures. ITS 3.4.8 ACTION B provides the Required Actions when no required RHR loops are OPERABLE. The Required Actions are to immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1 and to immediately initiate action to restore one RHR loop to OPERABLE status. This changes the CTS by adding a new ACTION when both required

RHR loops are inoperable.

The change is acceptable because the Completion Times are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Times. The immediate suspension of operations that would cause introduction of coolant into the RCS with a boron concentration less than required to meet the SDM of LCO 3.1.1 and immediately initiating action to restore one loop to OPERABLE status reflects the importance of maintaining operation for decay heat removal and boron mixing capability. Also, coolant added to the RCS without forced circulation could introduce unmixed coolant into the core, which could reduce the required margin to criticality. This change is designated as more restrictive because a new ACTION is being added to the ITS that was not required by the CTS.

M04 CTS 3.1.a.1.A requires one RHR pump to be in operation under certain conditions, but does not provide a Surveillance Requirement to periodically verify the required pump is in operation. ITS SR 3.4.8.1 requires verification that the required RHR loop is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS 3.1.a.2.B requires two RHR trains to be OPERABLE, but does not provide a Surveillance Requirement to periodically verify the required loops are OPERABLE. ITS SR 3.4.8.2 requires verification that each required RHR pump is OPERABLE every 7 days by verifying correct breaker alignment and indicated power are available to each required pump. A Note further explains that the Surveillance is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. This changes the CTS by adding new Surveillance Requirements to periodically verify the required pump is in operation and the required pumps are OPERABLE.

The purpose of ITS SR 3.4.8.1 is to ensure that one RHR loop is in operation providing forced flow of the reactor coolant for heat removal. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency for the proposed Surveillance is selected based on operating experience and the need for operator awareness. The purpose of ITS SR 3.4.8.2 is to ensure that each required RHR pump is OPERABLE. Verification of proper

breaker alignment and power availability ensures that an RHR pump can be placed in operation, if needed, to maintain residual heat removal and reactor coolant circulation. These changes are acceptable because the Surveillance Requirements ensure the availability of the system to remove reactor residual heat and to provide proper boron mixing via the forced circulation of the reactor coolant. This change is designated as more restrictive because new SRs have been added to periodically verify the requirements of the LCO are met.

Kewaunee Power Station Page 3 of 5 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES

LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.1.a.2.B requires two residual heat removal (RHR) trains be OPERABLE with each train consisting of the following: 1) one OPERABLE residual heat removal pump; 2) one OPERABLE residual heat removal heat exchanger; and, 3) an OPERABLE flow path consisting of all valves and piping associated with the above train of components and required to remove decay heat from the core during normal shutdown situations. This flow path shall be capable of taking suction from the appropriate Reactor Coolant System hot leg

and returning to the Reactor Coolant System. ITS LCO 3.4.8 requires two RHR loops to be OPERABLE, but does not define the components and the associated flow path that comprise an OPERABLE RHR train. This changes the CTS by moving the description of the RHR trains to the Bases.

The removal of these details which are related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains all necessary requirements in the LCO to ensure OPERABILITY of the RHR loops in MODE 5. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

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

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) ITS 3.4.8 Note 2 allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Surveillance testing provided that the other RHR loop is OPERABLE and in operation. The CTS does not contain these allowances; CTS 3.1.a.2.B requires both RHR trains to be OPERABLE at all times when in MODE 5 with the RCS loops not filled. This changes the CTS by providing an allowance for one of the RHR loops to be inoperable for a limited period of time to perform required Surveillance testing.

Note 2 allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Surveillance testing, provided that the other RHR loop is OPERABLE and in operation. The purpose of the Note is to permit periodic Surveillance tests to be performed on the inoperable loop during a time when such testing is safe and

possible. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance is acceptable since the remaining RHR loop is OPERABLE and in operation. Thus the decay heat removal and boron mixing functions are still being met. This change is less restrictive because conditions Kewaunee Power Station Page 4 of 5 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED Kewaunee Power Station Page 5 of 5 that allow removal of one RHR loop have been added to the ITS that were not in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

RCS Loops - MODE 5, Loops Not Filled 3.4.8 WOG STS 3.4.8-1 Rev. 3.0, 03/31/04 CTS 3.1.a.1.A, 3.1.a.2.B 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.8 RCS Loops - MODE 5, Loops Not Filled

LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

NOTES-------------------------------------------

1. All RHR pumps may be removed from operation for 15 minutes when switching from one loop to another provided:

[ a. The core outlet temperature is maintained > 10°F below saturation temperature, ]

b. No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

c. No draining operations to further reduce the RCS water volume are permitted.

2. One RHR loop may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation. --------------------------------------------------------------------------------------------------

APPLICABILITY: MODE 5 with RCS loops not filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR loop inoperable.

A.1 Initiate action to restore RHR loop to OPERABLE status. Immediately DOC M01 DOC L01 3.1.a.1.A, 3.1.a.2.B 3.1.a.2.B.2

3 2at least All changes are 1 unless otherwise noted, "SHUTDOWN MARGIN (SDM)" 4 S 5 RCS Loops - MODE 5, Loops Not Filled 3.4.8 WOG STS 3.4.8-2 Rev. 3.0, 03/31/04 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No required RHR loop OPERABLE.

OR Required RHR loop not in operation.

B.1 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM

of LCO 3.1.1.

AND B.2 Initiate action to restore one RHR loop to OPERABLE status and operation.

Immediately

Immediately DOCS M02 and M03

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2 -------------------------------NOTE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ---------------------------------------------------------------------

Verify correct breaker alignment and indicated power are available to each required RHR pump.

7 days DOC M04 DOC M04 JUSTIFICATION FOR DEVIATIONS ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED

1. 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.

2. ISTS 3.4.8 Note 1.a states that the core outlet temperature is maintained > 10°F below saturation temperature. This same Note appears in ISTS 3.4.6 and ISTS 3.4.7 and states that the core outlet temperature is maintained at least 10°F below saturation temperature. The ">" 10°F term has been revised to read "at least" 10°F to be consistent with the conditions provided in the Notes for ISTS 3.4.6 and ISTS 3.4.7.

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 title of the LCO has been provided since this is the first reference to the LCO.

5. Typographical error corrected.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 WOG STS B 3.4.8-1 Rev. 3.0, 03/31/04 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.8 RCS Loops - MODE 5, Loops Not Filled

BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat generated in the fuel, and the transfer of this heat to the component cooling water via the residual heat removal (RHR) heat exchangers. The steam generators (SGs) are not available as a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid.

In MODE 5 with loops not filled, only RHR pumps can be used for coolant circulation. The number of pumps in operation can vary to suit the operational needs. The intent of this LCO is to provide forced flow from at least one RHR pump for decay heat removal and transport and to require that two paths be available to provide redundancy for heat removal.

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event. The RHR ANALYSES loops provide this circulation. The flow provided by one RHR loop is adequate for heat removal and for boron mixing.

RCS loops in MODE 5 (loops not filled) satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The purpose of this LCO is to require that at least two RHR loops be OPERABLE and one of these loops be in operation. An OPERABLE loop is one that has the capability of transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the RHR System unless forced flow is used. A minimum of one running RHR pump meets the LCO requirement for one loop in operation. An additional RHR loop is required to be OPERABLE to meet single failure considerations.

Note 1 permits all RHR pumps to be removed from operation for 15 minutes when switching from one loop to another. The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short [and core outlet temperature is maintained > 10°F below saturation temperature]. The Note prohibits boron dilution with coolant at boron concentrations less than required to assure SDM of LCO 3.1.1 is maintained or draining operations when RHR forced flow is stopped.

2at least 3"SHUTDOWN MARGIN (SDM)," 5All changes are 1 unless otherwise noted anINSERT 1 would affect B 3.4.8 2 INSERT 1 The current licensing basis of Kewaunee Power Station (KPS) does not consider boron dilution events during MODE 5 conditions. Therefore, no safety analyses related to the loss of RCS loops are performed for MODE 5.

Insert Page B 3.4.8-1 o -

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 WOG STS B 3.4.8-2 Rev. 3.0, 03/31/04 BASES LCO (continued)

Note 2 allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible.

7An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

a APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops - MODES 1 and 2," LCO 3.4.5, "RCS Loops - MODE 3," LCO 3.4.6, "RCS Loops - MODE 4," LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -

High Water Level" (MODE 6)," and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6)".

ACTIONS A.1 If one required RHR loop is inoperable, redundancy for RHR is lost.

Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2

If no required loop is OPERABLE or the required loop is not in operation, except during conditions permitted by Note 1, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation. The required margin to

4 3 4 6 RCS Loops - MODE 5, Loops Not Filled B 3.4.8 WOG STS B 3.4.8-3 Rev. 3.0, 03/31/04 BASES ACTIONS (continued)

criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.8.2

Verification that each required pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to each required pump. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

REFERENCES None.

JUSTIFICATION FOR DEVIATIONS ITS 3.4.8 BASES, RCS LOOPS - MODE 5, LOOPS NOT FILLED

1. The ISTS Bases 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.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis or licensing basis description.

3. Changes are made to reflect those changes made to the ISTS. In this case, the ">" 10°F term has been revised to read "at least" 10°F to be consistent with the conditions provided in the Notes to ISTS 3.4.6 and ISTS 3.4.7.

4. 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.

5. The title of the LCO has been provided since this is the first reference to the LCO.

6. The correct ITS number has been provided (changed to be consistent with a number change to the actual specification in Section 3.9).

7. Words have been changed to allow for there being other conditions wherein the test might be run safely.

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 9 ITS 3.4.9, PRESSURIZER

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

4. With one block valve inoperable, within one hour restore the block valve to OPERABLE status or place its associated PORV in manual control. Restore the block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise action shall

be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

5. With both block valves inoperable, within one hour restore the block valves to OPERABLE status or place their associated PORVs in manual control.

Restore at least one block valve to OPERABLE status within the next hour;

otherwise, action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

6. Pressurizer Heaters A. At least one group of pressurizer heaters shall have an emergency power supply available when the average RCS temperature is > 350 F. 7. Reactor Coolant Vent System A. A reactor coolant vent path from both the reactor vessel head and pressurizer steam space shall be OPERABLE and closed prior to the average RCS temperature being heated > 200F except as specified in TS 3.1.a.7.B and TS 3.1.a.7.C below.

B. When the average RCS temperature is > 200F, any one of the following conditions of inoperability may exist:

1. Both of the parallel vent valves in the reactor vessel vent path are inoperable.

2. Both of the parallel vent valves in the pressurizer vent path are inoperable.

If OPERABILITY is not restored within 30 days, then within one hour action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve COLD SHUTDOWN within an additional 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. If no Reactor Coolant System vent paths are OPERABLE, then restore at least one vent path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If OPERABILITY is not

restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then within one hour action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve COLD SHUTDOWN within an additional 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Amendment No. 165 TS 3.1-5 03/11/2003 LCO 3.4.9.b A01ITS ITS 3.4.9 Page 1 of 4See CTS 3.1.a.7 A pplicabilit y L01Add proposed ACTIONS B and C See ITS 3.4.11 A01 ITS 3.4.9 ITS f. Minimum Conditions for Criticality

1. The reactor shall not be brought to a critical condition until the pressure-temperature state is to the right of the criticality limit line shown in Figure TS 3.1-1.

2. The reactor shall be maintained subcritical by at least 1% k/k until normal water level is established in the pressurizer.

3. When the reactor is critical the moderator temperature coefficient shall be as specified in the COLR, except during LOW POWER PHYSICS TESTING. The maximum upper moderator temperature coefficient limit shall be 5 pcm/ F for power levels 60% RATED POWER and 0 pcm/ F for power levels 60% RATED POWER. 4. If the limits of 3.1.f.3 cannot be met, then power operation may continue provided the following actions are taken:

A. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , develop and maintain administrative control rod withdrawal limits sufficient to restore the moderator temperature coefficient to within the limits specified in TS 3.1.f.3. These withdrawal limits shall be in addition to the

insertion limits specified in TS 3.10.d.

B. If the actions specified in TS 3.1.f.4.A are not satisfied, then be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

See ITS 3.1.3 See ITS 3.1.3 and 3.1.8 See ITS 3.4.3 A pplicabilit y M01M01Add proposed ACTION AM02M03Add proposed MODE 3 Applicability LC0 3.4.9 Amendment No. 165 TS 3.1-10 03/11/2003 Page 2 of 4 A01 ITS 3.4.9 ITS 4.1 OPERATIONAL SAFETY REVIEW APPLICABILITY Applies to items directly related to safety limits and LIMITING CONDITIONS FOR OPERATION.

OBJECTIVE To assure that instrumentation shall be checked, tested, and calibrated, and that equipment and sampling tests shall be conducted at sufficiently frequent intervals to

ensure safe operation.

SPECIFICATION

a. Calibration, testing, and checking of protective instrumentation channels and testing of logic channels shall be performed as specified in Table TS 4.1-1.

b. Equipment and sampling tests shall be conducted as specified in Table TS 4.1-2 and TS 4.1-3.

c. Deleted

d. Deleted

e. Deleted See otherITS SR 3.4.9.2, SR 3.4.9.3 Amendment No. 119 TS 4.1-1 04/18/95 Page 3 of 4 TABLE TS 4.1-3 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS Amendment No. 125 Page 1 of 1 08/07/96 A01 ITS 3.4.9 ITS EQUIPMENT TESTS (1) TEST FREQUENCY L021. Control Rods Rod drop times of all full length rods Partial movement of all

rods not fully inserted in the

core Each REFUELING outage

Quarterly when at or above HOT

STANDBY 1a. Reactor Trip Breakers Independent test (2) shunt and undervoltage trip

attachments Monthly 1b. Reactor Coolant Pump Breakers-Open-Reactor Trip OPERABILITY Each REFUELING outage 1c. Manual Reactor Trip Open trip reactor (3) trip and bypass breaker Each REFUELING outage

2. Deleted

3. Deleted

4. Containment Isolation Trip OPERABILITY Each REFUELING outage 5. Refueling System Interlocks OPERABILITY Prior to fuel movement each REFUELING outage

6. Deleted

7. Deleted

8. RCS Leak Detection OPERABILITY Weekly (4) 9. Diesel Fuel Supply Fuel Inventory (5) Weekly 10. Deleted

11. Fuel Assemblies Visual Inspection Each REFUELING outage

12. Guard Pipes Visual Inspection Each REFUELING outage 13. Pressurizer PORVs OPERABILITY Each REFUELING cycle 14. Pressurizer PORV Block Valves OPERABILITY Quarterly (6) 15. Pressurizer Heaters OPERABILITY (7) Each REFUELING cycle 16. Containment Purge and Vent Isolation Valves OPERABILITY (8) Each REFUELING cycle

(1) Following maintenance on equipment that could affect the operation of the equipment, tests should be performed to verify OPERABILITY. (2) Verify OPERABILITY of the bypass breaker undervoltage trip attachment prior to placing breaker into service. (3) Using the Control Room push-buttons, independently test the reactor trip breakers shunt trip and undervoltage trip attachments. The test shall also verify the undervoltage trip attachment

on the reactor trip bypass breakers.

(4) When reactor is at power or in HOT SHUTDOWN condition.

(5) Inventory of fuel required in all plant modes.

(6) Not required when valve is administratively closed.

(7) Test will verify OPERABILITY of heaters and availability of an emergency power supply.

(8) This test shall demonstrate that the valve(s) close in 5 seconds.

M02 Add proposed SR 3.4.9.1 See ITS 3.8.1 and 3.8.3 See ITS 3.6.3 See ITS 3.4.11 See ITS 3.4.15 See ITS 3.3.1 SR 3.4.9.2, SR 3.4.9.3 SR 3.4.9.2, SR 3.4.9.3 L02 See ITS 3.6.3 See ITS 3.4.11 See ITS 3.6.3 See CTS 3.8.a.11 See ITS 3.4.15 See ITS 4.0 See ITS 3.6.1 See ITS 3.8.1 and 3.8.3 See ITS 3.3.1 See ITS 3.1.4 Page 4 of 4 DISCUSSION OF CHANGES ITS 3.4.9, PRESSURIZER ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES

M01 CTS 3.1.f requires that the reactor remain subcritical by at least 1% k/k (ITS MODES 1 and 2) until normal water level is established in the pressurizer. ITS 3.4.9 requires, in part, that the pressurizer water level is 90% not only in MODES 1 and 2, but also in MODE 3. Due to this new Applicability, when the pressurizer water level is not within the limit, ITS 3.4.9 Required Action A.4 will also require the unit to be taken to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , which is outside the new MODE of Applicability. This changes the CTS by adding a new MODE of Applicability (MODE 3) and a commensurate Required Action. The change in the water level requirement is discussed in DOC M02.

This change is acceptable because the analyses performed from a critical reactor condition assumes the existence of a steam bubble and saturated conditions in the pressurizer. Furthermore, the purpose of the MODE 3 Applicability is to prevent water solid reactor coolant system operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup. This change is designated as more restrictive because the requirement that the water level of the pressurizer is 90% is now required in MODE 3.

M02 CTS 3.1.f requires the pressurizer water level to be within the "normal water level." In addition, the CTS does not provide any Surveillance Requirement to periodically verify the pressurizer water level. The CTS Bases states that the requirement that the pressurizer is partly voided ensures that the RCS will not be solid when criticality is achieved. ITS LCO 3.4.9.a requires the pressurizer level to be 90%. Furthermore, ITS SR 3.4.9.1 requires verification that the pressurizer water level is 90% every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by specifically stating the value for the normal water level ( 90%) and providing a periodic verification that the level is within the limit.

The purpose of the water level limit is to ensure the accident analysis is met and to prevent a water solid condition from existing during heatup and cooldown conditions. The proposed value is the value at which the pressurizer level provides a Reactor Protection System trip. The trip ensures a water solid condition does not occur with the reactor critical. Furthermore, the proposed Surveillance Requirement will ensure the water level is periodically monitored to ensure the limit is not exceeded. This change is designated as more restrictive Kewaunee Power Station Page 1 of 3 DISCUSSION OF CHANGES ITS 3.4.9, PRESSURIZER since the specific water level limit is being added to the CTS and a specific Surveillance Requirement to verify the limit is met is being added to the CTS.

M03 CTS 3.1.f does not provide any ACTIONS to be taken when the required pressurizer water level is not met when the reactor is not subcritical by at least

1% k/k. As a result, LCO 3.0.c would be entered, which requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in HOT STANDBY (equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to be in HOT SHUTDOWN (equivalent to ITS MODE

3) with the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Under similar conditions, ITS 3.4.9 ACTION A requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action A.1), to fully insert all rods in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action A.2), and to place the Rod Control System in a condition incapable of rod withdrawal in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action A.3). This changes the CTS by providing specific Required Actions to take when the pressurizer water level is not within limits.

The purpose of CTS LCO 3.0.c is to place the unit outside of the Applicability of the Specification. ITS 3.4.9 ACTION A continues to require the unit to be placed outside the MODE of Applicability, but adds two additional requirements intended to minimize the core reactivity and any pressure transient which may result from an inadvertent withdrawal of control rods. This change is acceptable because it provides additional assurance that certain events will not occur during the transition out of the MODE of Applicability of the Specification. This change is designated as more restrictive because additional Required Actions are now required.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES None

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

CTS 3.1.a.6 does not provide any ACTIONS to take when the required group of pressurizer heaters are inoperable when the average RCS temperature is > 350°F (ITS MODES 1, 2, and 3). As a result, LCO 3.0.c would be entered, which requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to be in HOT STANDBY (equivalent to ITS MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , to be in HOT SHUTDOWN (equivalent to ITS MODE 3) with the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and to be in COLD SHUTDOWN (equivalent to ITS MODE 5) within the subsequent 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (although only CTS INTERMEDIATE SHUTDOWN is required to be entered since CTS 3.1.a.6 is required only when above 350ºF).

ITS 3.4.9 ACTION B allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable pressurizer heater group to OPERABLE status, and if not restored, ITS 3.4.9 ACTION C requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This Kewaunee Power Station Page 2 of 3 DISCUSSION OF CHANGES ITS 3.4.9, PRESSURIZER Kewaunee Power Station Page 3 of 3 changes the CTS by providing specific ACTIONS when the pressurizer heaters are inoperable.

The purpose of CTS 3.1.a.6 is to maintain pressurizer pressure. This is accomplished by having one pressurizer heater bank operable and capable of being powered from an emergency power supply. This change is acceptable because the Required Action is used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Under the ITS, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months are allowed to restore the inoperable pressurizer heater group before requiring a unit shutdown. This change is designated as less restrictive because less stringent Required Actions are being applied.

L02 (Category 5 - Deletion of Surveillance Requirement)

Note 1 to CTS Table 4.1-3 requires, in part, that the pressurizer heaters be tested to verify OPERABILITY following maintenance on equipment that could affect the operation. ITS 3.4.9 does not include this requirement. This changes the CTS by eliminating a post-maintenance Surveillance Requirement.

This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and frequency necessary to give confidence that the equipment can perform its assumed safety function.

Whenever, the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post maintenance testing is required to

demonstrate the OPERABILITY of a system or component. This is described in the Bases for ITS SR 3.0.1 and required under SR 3.0.1. In addition, the requirement of 10 CFR 50, Appendix B, Section XI (Test Control), provides adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be performed in the ITS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Pressurizer 3.4.9 WOG STS 3.4.9-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.9 Pressurizer

LCO 3.4.9 The pressurizer shall be OPERABLE with:

a. Pressurizer water level [92]% and

b. [Two groups of] pressurizer heaters OPERABLE with the capacity [of each group] [125] kW [and capable of being powered from an emergency power supply].

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water level not within limit.

A.1 Be in MODE 3.

AND A.2 Fully insert all rods.

AND A.3 Place Rod Control System in a condition incapable of

rod withdrawal.

AND A.4 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B. One [required] group of pressurizer heaters inoperable.

B.1 Restore [required] group of pressurizer heaters to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C. Required Action and associated Completion

Time of Condition B not met. C.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 1DOC L01 DOC L01 DOCs M01 and M03 3.1.a.6, 3.1.f 3.1.f 3.1.a.6 90 4 Onethe ;2 1 158.4 Pressurizer 3.4.9 WOG STS 3.4.9-2 Rev. 3.0, 03/31/04 CTS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level is [92]%.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ----------------------------------REVIEWER'S NOTE---------------------------------

The frequency for performing Pressurizer heater capacity testing shall be either 18 months or 92 days, depending on whether or not the plant has dedicated safety-related heaters. For dedicated safety-related heaters, which do not normally operate, 92 days is applied. For non-dedicated safety-related heaters, which normally operate, 18 months is applied.

SR 3.4.9.2 Verify capacity of each required group of pressurizer heaters is [125] kW.

[18] months

SR 3.4.9.3 [

Verify required pressurizer heaters are capable of being powered from an emergency power supply.

[18] months ]

90DOC M02 1 3 Table 4.1-3 Equipment Test 15, including Note 7 3 1 158.4 Table 4.1-3 Equipment Test 15, including Note 7 1 JUSTIFICATION FOR DEVIATIONS ITS 3.4.9, PRESSURIZER

1. 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.

2. ISTS 3.4.9 ACTION B contains bracketed information and/or values that are generic to all Westinghouse vintage plants. Since Kewaunee Power Station (KPS) has two groups of pressurizer heaters that are powered from an emergency power supply and only one group is required to be OPERABLE, the word "required" has been maintained in ITS 3.4.9 ACTION B. Furthermore, since only one group is required, the word "one" is not necessary and has been deleted.

3. ISTS SR 3.4.9.2 contains a Reviewers Note that is used by the NRC reviewer to determine the Frequency for ISTS SR 3.4.9.2. As stated in the Reviewer's Note, the frequency for performing Pressurizer heater capacity testing is based on whether or not the plant has dedicated safety-related heaters. If the plant has safety-related heaters, which do not normally operate, 92 days is applied. For non-dedicated safety-related heaters, which normally operate, 18 months is applied. At KPS, the Pressurizer heaters are non-dedicated heaters which normally operate. Therefore, the Frequency for performing SR 3.4.9.2, at KPS, is 18 months, which is also consistent with the current Technical Specification requirement.

4. 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.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Pressurizer B 3.4.9 WOG STS B 3.4.9-1 Rev. 3.0, 03/31/04 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.9 Pressurizer

BASES BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes to prevent bulk boiling in the remainder of the RCS. Key functions include maintaining required primary system pressure during steady state operation, and limiting the pressure changes caused by reactor coolant thermal expansion and contraction during normal load transients.

The pressure control components addressed by this LCO include the pressurizer water level, the required heaters, and their controls and emergency power supplies. Pressurizer safety valves and pressurizer

power operated relief valves are addressed by LCO 3.4.10, "Pressurizer Safety Valves," and LCO 3.4.11, "Pressurizer Power Operated Relief

Valves (PORVs)," respectively.

The intent of the LCO is to ensure that a steam bubble exists in the pressurizer prior to power operation to minimize the consequences of potential overpressure transients. The presence of a steam bubble is consistent with analytical assumptions. Relatively small amounts of noncondensible gases can inhibit the condensation heat transfer between the pressurizer spray and the steam, and diminish the spray effectiveness for pressure control.

Electrical immersion heaters, located in the lower section of the pressurizer vessel, keep the water in the pressurizer at saturation temperature and maintain a constant operating pressure. A minimum required available capacity of pressurizer heaters ensures that the RCS pressure can be maintained. The capability to maintain and control system pressure is important for maintaining subcooled conditions in the RCS and ensuring the capability to remove core decay heat by either forced or natural circulation of reactor coolant. Unless adequate heater capacity is available, the hot, high pressure condition cannot be maintained indefinitely and still provide the required subcooling margin in the primary system. Inability to control the system pressure and maintain subcooling under conditions of natural circulation flow in the primary system could lead to a loss of single phase natural circulation and decreased capability to remove core decay heat.

Pressurizer B 3.4.9 WOG STS B 3.4.9-2 Rev. 3.0, 03/31/04 BASES APPLICABLE In MODES 1, 2, and 3, the LCO requirement for a steam bubble is SAFETY reflected implicitly in the accident analyses. Safety analyses performed ANALYSES for lower MODES are not limiting. All analyses performed from a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect the small fraction of noncondensible gases normally present.

Safety analyses presented in the FSAR (Ref. 1) do not take credit for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure.

The maximum pressurizer water level limit, which ensures that a steam bubble exists in the pressurizer, satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). Although the heaters are not specifically used in accident analysis, the need to maintain subcooling in the long term during loss of offsite power, as indicated in NUREG-0737 (Ref. 2), is the reason for providing an LCO.

LCO -----------------------------------REVIEWER'S NOTE----------------------------------- Plants licensed prior to the issuance of NUREG-0737 may not have a requirement on the number of pressurizer groups.

The LCO requirement for the pressurizer to be OPERABLE with a water volume [1240] cubic feet, which is equivalent to [92]%, ensures that a steam bubble exists. Limiting the LCO maximum operating water level preserves the steam space for pressure control. The LCO has been established to ensure the capability to establish and maintain pressure control for steady state operation and to minimize the consequences of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions.

The LCO requires [two groups of] OPERABLE pressurizer heaters, [each]

with a capacity [125] kW, [capable of being powered from either the offsite power source or the emergency power supply]. The minimum heater capacity required is sufficient to maintain the RCS near normal operating pressure when accounting for heat losses through the pressurizer insulation. By maintaining the pressure near the operating conditions, a wide margin to subcooling can be obtained in the loops.

The exact design value of [125 kW is derived from the use of seven heaters rated at 17.9 kW each]. The amount needed to maintain pressure is dependent on the heat losses.

2 U 1 one 158.4 158.4 90 the emergency buses 3 3 3which is equivalent to approximately 900 cubic feet 4level 1data obtained during in-plant testing. The value is met by 13 OPERABLE heaters, since each heater has a rated capacity of 12.82 kW.

Pressurizer B 3.4.9 WOG STS B 3.4.9-3 Rev. 3.0, 03/31/04 BASES APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, applicability has been designated for MODES 1 and 2. The applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup.

In MODES 1, 2, and 3, there is need to maintain the availability of pressurizer heaters, capable of being powered from an emergency power supply. In the event of a loss of offsite power, the initial conditions of these MODES give the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODE 4, 5, or 6, it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer when the Residual Heat Removal (RHR) System is in service, and therefore, the LCO is not applicable.

ACTIONS A.1, A.2, A.3, and A.4 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the nominal upper limit, even with the plant at steady state conditions. Normally the plant will trip in this event since the upper limit of this LCO is the same as the Pressurizer Water Level - High Trip.

If the pressurizer water level is not within the limit, action must be taken to bring the plant to a MODE in which the LCO does not apply. To achieve this status, within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the unit must be brought to MODE 3 with all rods fully inserted and incapable of withdrawal. Additionally, the unit must be brought to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This takes the unit out of the applicable MODES.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

B.1 If one [required] group of pressurizer heaters is inoperable, restoration is required within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is reasonable considering the anticipation that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using normal station powered heaters. the 4 Pressurizer B 3.4.9 WOG STS B 3.4.9-4 Rev. 3.0, 03/31/04 BASES ACTIONS (continued)

C.1 and C.2 4

If one group of pressurizer heaters are inoperable and cannot be restored in the allowed Completion Time of Required Action B.1, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. the required SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This SR requires that during steady state operation, pressurizer level is

maintained below the nominal upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months corresponds to verifying the parameter each shift. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess level for any deviation and verify that operation is within safety analyses assumption of ensuring that a steam bubble exists in the pressurizer. Alarms are also available for early detection of abnormal level indications.

SR 3.4.9.2

REVIEWER'S NOTE-----------------------------------

The frequency for performing Pressurizer heater capacity testing shall be either 18 months or 92 days, depending on whether or not the plant has dedicated safety-related heaters. For dedicated safety-related heaters, which do not normally operate, 92 days is applied. For non-dedicated safety-related heaters, which normally operate, 18 months is applied.

2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating. This may be done by testing the power supply output and by performing an electrical check on heater element continuity and resistance. The Frequency of [18] months is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.

3 Pressurizer B 3.4.9 WOG STS B 3.4.9-5 Rev. 3.0, 03/31/04 BASES SURVEILLANCE REQUIREMENTS (continued) 3[ SR 3.4.9.3

This SR is not applicable if the heaters are permanently powered by Class 1E power supplies.

3 This Surveillance demonstrates that the heaters can be manually transferred from the normal to the emergency power supply and energized. The Frequency of 18 months is based on a typical fuel cycle and is consistent with similar verifications of emergency power supplies. ] required verifies are capable of being powered by an 5 REFERENCES 1. FSAR, Section [ ].

2. NUREG-0737, November 1980.

14.1 U The Surveillance can be met by verifying the required heaters are energized by its emergency power supply (if the heaters are normally aligned to and energized by an emergency power supply) or by verifying that the required heater power supply can be transferred to an emergency power supply (if the heaters are not aligned to and energized by an emergency power supply).

3 3 1 5 JUSTIFICATION FOR DEVIATIONS ITS 3.4.9 BASES, PRESSURIZER

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. The Reviewer's Note has been deleted. This 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.

3. 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 acceptable since the generic specific information/value is revised to reflect the current plant design.

4. Change made to be consistent with the Specification.

5. The KPS design for the pressurizer heaters includes one train that is only powered from an emergency power supply and one train that can be powered from either an emergency power supply or non-emergency power supply. Therefore, the Bases for SR 3.4.9.3 has been reworded to match the KPS design.

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.9, PRESSURIZER There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 10 ITS 3.4.10, PRESSURIZ ER SAFETY VALVES

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) 3.1.a.3 Pressurizer Safety Valves

LCO 3.1.a.3 Two pressurizer safety valves shall be OPERABLE

APPLICABILITY: Reactor Coolant System Tem perature Greater than the Low Temperature Overpressure Protection (LTOP) Enabling Temperature (200 F)

ACTIONS - NOTE - During a hydro test of the RCS, the pressurizer safety valves may be blanked provided the power-operated relief valves and the safety valve on the discharge pump are set for the test

pressure plus 35 psi to protect the system.

CONDITION REQUIRED ACTION COMPLETION TIME

A. One pressurizer safety valve inoperable

A.1 Restore to OPERABLE status 15 Minutes OR A.2 Be in HOT SHUTDOWN 12 Hours B. Both pressurizer safety valves are inoperable

B.1 Restore one pressurizer safety valve to an

OPERABLE status

15 Minutes OR B.2 Be in a condition with the LTOP system

OPERABLE or reactor

vessel head removed 48 Hours LCO 3.4.10 A01 ITS 3.4.10ITS LCO 3.4.10 Note Add proposed Applicability Note M01LA01 A CTION A A CTION B Add proposed SR 3.4.10.1 36 6M01 A pplicabilit y Required Action B.1 Add proposed lift settings M01 Page 1 of 1M02M03Add proposed Required Action B.1A02 inoperable LA01Add proposed Required Action B.2A02Be in MODE 5 Amendment No. 164 TS 3.1-3 11/07/2002 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES ADMINISTRATIVE CHANGES A01 In the conversion of the Kewaunee Power Station (KPS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 3.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 The Applicability for CTS 3.1.a.3 is when the Reactor Coolant System temperature is greater than the LTOP enabling temperature (200°F). Furthermore, when LCO 3.1.a.3 is not being met, CTS 3.1.a.3 Required Action B.2 requires the unit to be in a condition with the LTOP system OPERABLE or reactor vessel head removed. The ITS 3.4.10 Applicability is MODES 1, 2, 3, and 4, and under similar conditions, ITS 3.4.10 Required Action B.2 requires the unit to be in MODE 5. This changes the CTS by clearly stating the MODES in which the pressurizer safety valves are required to be OPERABLE and the MODE the unit has to be placed in when a unit shutdown is

required.

ITS MODES 1, 2, 3, and 4 are the equivalent MODES covering the condition of greater than the LTOP enabling temperature of 200°F. This is shown in ITS Table 1.1-1, which defines that MODE 4 has a minimum average reactor coolant temperature of > 200°F. Thus, changing the Applicability to be MODES 1, 2, 3, and 4 is the same as the current requirement. In addition, since the 200°F requirement is part of the ITS Table 1.1-1 requirements for MODE 4, there is no reason to include the value in the ITS 3.4.10 Applicability. ITS Table 1.1-1 also

defines MODE 5 as having a maximum reactor coolant temperature of 200°F.

Furthermore, the Applicability of ITS 3.4.12, "LTOP," is also MODE 5. Therefore, requiring the unit to be in MODE 5 is the same as when the LTOP system is required to be OPERABLE. The current requirement to remove the reactor head is equivalent to the condition the unit will be in when in ITS MODE 6. Since the ITS 3.4.10 Required Action B.2 states to be in MODE 5, per the ITS convention, this does not preclude the unit from going all the way to MODE 6. Therefore, the change in the Required Action is also acceptable. These changes are designated as administrative changes because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES

M01 CTS 3.1.a.3 requires two pressurizer safety valves to be OPERABLE, but does not specify their lift settings. ITS 3.4.10 requires two pressurizer safety valves to

be OPERABLE with lift settings 2410.45 psig and 2559.55 psig. Commensurate with the addition of the lift settings, a Note has been added to the Applicability. The Note states that the lift settings are not required to be within the LCO limits during MODE 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. Additionally, the Note states that this exception is allowed for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months following entry into MODE 3 provided a Kewaunee Power Station Page 1 of 3 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES preliminary cold setting was made prior to heatup. Furthermore, a Surveillance Requirement (SR 3.4.10.1) has been added to verify that each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program and that following testing the lift settings are within +/- 1%. This changes the CTS by requiring the pressurizer safety valves to be OPERABLE within specific lift settings, except as allowed in the Applicability Note, and by adding a Surveillance Requirement to ensure the lift settings requirements are met.

This change is acceptable because the addition of the pressurizer safety valves' lift settings ensures that the pressurizer safety valves will be capable of protecting the reactor coolant pressure boundary (RCPB) Safety Limit. Furthermore, the addition of the Surveillance Requirement provides assurance that the pressurizer safety valves will be capable of limiting the RCS pressure to 110% of design pressure. Additionally, the applicability Note permits testing and examination of the pressurizer safety valves to be performed at high pressure and temperatures near their normal operating range. This change is designated as more restrictive because the pressurizer safety valves are required to be OPERABLE within specific lift settings.

M02 CTS 3.1.a.3 ACTION A states that with one pressurizer safety valve inoperable to restore the inoperable valve to OPERABLE status within 15 minutes or be in HOT SHUTDOWN (equivalent to ITS MODE 3) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.4.10 ACTION B, which provides the ACTION when one pressurizer safety valve is inoperable and has not been restored to OPERABLE status within 15 minutes, requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 with any RCS cold

leg temperatures the LTOP arming temperature specified in the PTLR within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes CTS by requiring the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instead of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and by further requiring the unit to be in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The purpose of the shutdown requirement is to reduce the vulnerability of the plant during the time one pressurizer safety valve is inoperable. However, it does not currently require the unit to exit the Applicability of the LCO. This change is acceptable because the requirement to place the unit in MODE 3 ensures an intermediate shutdown condition is reached in a shorter period of time. Furthermore, the requirement to place the unit in MODE 5 is acceptable because it places the unit in a MODE outside the Applicability of the LCO. The Completion Times are based on operating experience and the need to reach the required conditions from full power in an orderly manner and without challenging unit systems. This change is designated as more restrictive because it imposes a more restrictive time requirement for when the unit must be in MODE 3 and adds a new requirement for the unit to be in MODE 5.

M03 CTS 3.1.a.3 ACTION B states that with two pressurizer safety valve inoperable to restore one inoperable valve to OPERABLE status within 15 minutes or be in a condition with the LTOP system OPERABLE or reactor head removed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.4.10 ACTION B, which provides the ACTION when two pressurizer safety valves are inoperable, requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes CTS by not providing a short restoration time for one of the pressurizer safety valves since it is redundant to the time provided in ITS 3.4.10 ACTION A and by requiring the unit to be in Kewaunee Power Station Page 2 of 3 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES Kewaunee Power Station Page 3 of 3 MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The change from requiring the unit to be in a condition with the LTOP system OPERABLE or reactor head removal is discussed in DOC A02.

The purpose of requiring a shutdown when both pressurizer safety valves are inoperable is to exit the Applicability of the LCO since the plant is not meeting the overpressure protection analysis assumptions. This change is acceptable because the requirement to place the unit in MODE 3 ensures an intermediate shutdown condition is reached in a shorter period of time. Furthermore, the requirement to place the unit in MODE 5 is acceptable because it places the unit in a MODE outside the Applicability of the LCO. The Completion Times are based on operating experience and the need to reach the required conditions from full power in an orderly manner and without challenging unit systems. This change has been designated as more restrictive because it deletes a 15 minute restoration time for one of the inoperable valves, adds a requirement to be in MODE 3, and reduces the Completion Time to be in MODE 5 (i.e., in a condition the LTOP is OPERABLE) from 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES

LA01 (Type 2 - Removing Descriptions of System Operation)

CTS 3.1.a.3 ACTIONS Note states, in part, that during a hydro test of the RCS, the pressurizer safety valves may be blanked provided that the relief valves and safety valves of the discharge pump are set to protect the system. The Note for ITS LCO 3.4.10 does not include the statements may be "blanked" or "to protect the system."

The LCO 3.4.10 Note uses the term "inoperable". This changes the CTS by moving the statements may be "blanked" and "to protect the system" to the Bases.

The removal of these details which are related to system operation from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS retains all necessary requirements in LCO to ensure OPERABILITY of the pressurizer safety valves. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

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

LESS RESTRICTIVE CHANGES

None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Pressurizer Safety Valves 3.4.10 WOG STS 3.4.10-1 Rev. 3.0, 03/31/04 CTS 3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.10 Pressurizer Safety Valves

LCO 3.4.10 [Three] pressurizer safety valves shall be OPERABLE with lift settings [2460] psig and [2510] psig. Two LCO 3.1.a.3, DOC M01 1 2559.55 2410.45 APPLICABILITY: MODES 1, 2, and 3, MODE 4 with all RCS cold leg temperatures > [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the

PTLR]. ---------------------------------------------NOTE--------------------------------------------

The lift settings are not required to be within the LCO limits during MODES 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for [54] hours following entry into MODE 3 provided a preliminary cold setting was made prior to heatup. --------------------------------------------------------------------------------------------------

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One pressurizer safety valve inoperable.

A.1 Restore valve to OPERABLE status.

15 minutes

B. Required Action and associated Completion Time not met.

OR Two or more pressurizer safety valves inoperable.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4 with any RCS cold leg temperatures [275 F] [LTOP arming temperature specified in the PTLR].

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[24] hours

36 ACTION A ACTION A. ACTION B 36 4 3 5 3 2 INSERT 1and 4 3.1.a.3 DOC M01 5 1 3.4.10 CTS 2 INSERT 1 --------------------------------------------------NOTE------------------------------------------------- The pressurizer safety valves may be inoperable during a hydro test of the RCS provided the pressurizer power operated relief valves and the safety valves on the discharge pump are set at > the test pressure +35 psi.

A CTIONS Note ------------------------------------------------------------------------------------------------------------

Insert Page 3.4.10-1 Pressurizer Safety Valves 3.4.10 WOG STS 3.4.10-2 Rev. 3.0, 03/31/04 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program.

Following testing, lift settings shall be within +/- 1%.

In accordance with the Inservice Testing Program DOC M01 JUSTIFICATION FOR DEVIATIONS ITS 3.4.10, PRESSURIZER SAFETY VALVES

1. 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. Kewaunee Power Station (KPS) has two pressurizer safety valves, and their setpoints are allowed to be +3% of the nomimal set pressure (i.e., 2410.45 psig to 2559.55 psig). The +3% tolerance band is consistent with the allowance in the ISTS SR 3.4.10.1 Bases, which states that the pressurizer safety valve setpoint is +3% for OPERABILITY. Furthermore, the words "or more" in the second Condition of ISTS 3.4.10 Condition B have been deleted since there are only two safety valves in the KPS design.

2. A Note has been added to LCO 3.4.10 that allows the pressurizer safety valves to be inoperable during a hydro test of the RCS provided that the pressurizer power operated relief valves and the safety valves on the discharge pump (of the hydrostatic test rig) are set for the test pressure plus 35 psi (i.e., > the test pressure

+35 psi). This change is consistent with the current Technical Specifications (CTS 3.1.a.3) and was approved in License Amendment 164, dated 11/07/02 (ADAMS Accession No. ML023120408).

3. ISTS 3.4.10 Applicability for MODE 4 allows a choice of either specifying the actual Low Temperature Overpressure Protection (LTOP) arming temperature value (e.g.,

275ºF in the ISTS) or stating that the value is specified in the PTLR (i.e., > LTOP arming temperature specified in the PTLR). Kewaunee Power Station (KPS) has decided not to incorporate a PTLR allowance into the ITS, therefore the Applicability should reference the actual LTOP arming temperature. However, the current LTOP enabling temperature is 200°F, which is the exact temperature value at which MODE 4 starts. Thus, the words "with all RCS cold legs temperatures >" and the KPS enabling temperature of 200°F are redundant and have not been included (i.e., only MODE 4 is needed). Furthermore, ISTS 3.4.10 Required Action B.2 uses similar words as in the Applicability. These words have been changed to "Be in MODE 5" for the same reason (i.e., MODE 5 is 200°F).

4. The Note for the ISTS 3.4.10 Applicability allows the lift settings to not be met for 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months . This time is bracketed, and the ISTS Bases states that the 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months is based on an 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months outage time for each of the three pressurizer safety valves. The KPS design only includes two pressurizer safety valves, thus the time allowed in the Applicability Note has been decreased to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

5. The Completion Time provided in ISTS 3.4.10 Required Action B.2 is a bracketed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . For KPS, the LTOP arming temperature is 200°F. Therefore, since this is the MODE 5 entry temperature, the Completion Time has been changed to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months consistent with the time normally provided in the ISTS to reach MODE 5.

Kewaunee Power Station Page 1 of 1 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Pressurizer Safety Valves B 3.4.10 WOG STS B 3.4.10-1 Rev. 3.1, 12/01/05 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.10 Pressurizer Safety Valves

BASES BACKGROUND The pressurizer safety valves provide, in conjunction with the Reactor Protection System, overpressure protection for the RCS. The pressurizer safety valves are totally enclosed pop type, spring loaded, self actuated valves with backpressure compensation. The safety valves are designed to prevent the system pressure from exceeding the system Safety Limit (SL), [2735] psig, which is 110% of the design pressure.

2 1 Because the safety valves are totally enclosed and self actuating, they are considered independent components. The relief capacity for each valve, [380,000] lb/hr, is based on postulated overpressure transient conditions resulting from a complete loss of steam flow to the turbine.

This event results in the maximum surge rate into the pressurizer, which specifies the minimum relief capacity for the safety valves. The discharge flow from the pressurizer safety valves is directed to the pressurizer relief tank. This discharge flow is indicated by an increase in temperature downstream of the pressurizer safety valves or increase in the pressurizer relief tank temperature or level. approximately345,000 1 Overpressure protection is required in MODES 1, 2, 3, 4, and 5; however, in MODE 4, with one or more RCS cold leg temperatures [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR], and MODE 5 and MODE 6 with the reactor vessel head on, overpressure protection is provided by operating procedures and by meeting the requirements of LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP) System." 5 3 4The upper and lower pressure limits are based on the +/- 1% tolerance requirement (Ref. 1) for lifting pressures above 1000 psig. The lift setting is for the ambient conditions associated with MODES 1, 2, and 3. This requires either that the valves be set hot or that a correlation between hot and cold settings be established.

The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the American Society of Mechanical Engineers (ASME) pressure limit (Ref. 1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation.

Pressurizer Safety Valves B 3.4.10 WOG STS B 3.4.10-2 Rev. 3.1, 12/01/05 BASES APPLICABLE All accident and safety analyses in the FSAR (Ref. 2) that require safety SAFETY valve actuation assume operation of three pressurizer safety valves to two U 1 2ANALYSES limit increases in RCS pressure. The overpressure protection analysis (Ref. 3) is also based on operation of [three] safety valves. Accidents that could result in overpressurization if not properly terminated include: two 1 3 2 a. Uncontrolled rod withdrawal from full power, RCCA ; 3 b. Loss of reactor coolant flow,

c. Loss of external electrical load, ;3

d. Loss of normal feedwater,

e. Loss of all AC power to station auxiliaries, and

3 3

f. Locked rotor.

Detailed analyses of the above transients are contained in Reference 2. Safety valve actuation is required in events c, d, and e (above) to limit the during pressure increase. Compliance with this LCO is consistent with the design bases and accident analyses assumptions.

2 Pressurizer safety valves satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The [three] pressurizer safety valves are set to open at the RCS design pressure (2500 psia), and within the ASME specified tolerance, to avoid exceeding the maximum design pressure SL, to maintain accident analyses assumptions, and to comply with ASME requirements. The upper and lower pressure tolerance limits are based on the +/- 1% tolerance requirements (Ref. 1) for lifting pressures above 1000 psig. The limit protected by this Specification is the reactor coolant pressure boundary (RCPB) SL of 110% of design pressure. Inoperability of one or more valves could result in exceeding the SL if a transient were to occur.

The consequences of exceeding the ASME pressure limit could include damage to one or more RCS components, increased leakage, or additional stress analysis being required prior to resumption of reactor operation. two 1 4 3 4 INSERT 1 APPLICABILITY In MODES 1, 2, and 3, and portions of MODE 4 above the LTOP arming temperature, OPERABILITY of [three] valves is required because the combined capacity is required to keep reactor coolant pressure below 110% of its design value during certain accidents. MODE 3 and portions of MODE 4 are conservatively included, although the listed accidents may not require the safety valves for protection.

4 3two 4 B 3.4.10 4 INSERT 1 The LCO is modified by a Note which allows the pressurizer safety valves to be inoperable during a hydro test of the RCS. During the hydro test of the RCS, the pressurizer safety valves may be blanked provided the pressurizer power operated relief valves and the safety valve on the discharge pump are set at the test pressure +35 psi to protect the system during this test.

Insert Page B 3.4.10-2 Pressurizer Safety Valves B 3.4.10 WOG STS B 3.4.10-3 Rev. 3.1, 12/01/05 BASES APPLICABILITY (continued)

The LCO is not applicable in MODE 4 when any RCS cold leg temperatures are [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR] or in MODE 5 because LTOP is provided. Overpressure protection is not required in MODE 6 with reactor vessel head detensioned.

The Note allows entry into MODES 3 and 4 with the lift settings outside the LCO limits. This permits testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. The cold setting gives assurance that the valves are OPERABLE near their design condition. Only one valve at a time will be removed from service for testing. The [54] hour exception is based on 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months outage time for each of the [three] valves. The 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months period is derived from operating experience that hot testing can be performed in this timeframe.

ACTIONS A.1

With one pressurizer safety valve inoperable, restoration must take place within 15 minutes. The Completion Time of 15 minutes reflects the importance of maintaining the RCS Overpressure Protection System. An inoperable safety valve coincident with an RCS overpressure event could challenge the integrity of the pressure boundary.

B.1 and B.2

If the Required Action of A.1 cannot be met within the required Completion Time or if two or more pressurizer safety valves are inoperable, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 with any RCS cold leg temperatures [275°F] [Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR] within

[24] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. With any RCS cold leg temperatures at or below [275°F] [Low Temperature Overpressure (LTOP) arming temperature specified in the PTLR], overpressure protection is provided by the LTOP System. The change from MODE 1, 2, or 3 to MODE 4 reduces the RCS energy (core power and pressure), lowers the potential for large pressurizer insurges, and thereby removes the need for overpressure protection by [three]

pressurizer safety valves.

36 two 36 two 5 1 4 5 4 4In MODE 5 1 5 4 4, or 4 Pressurizer Safety Valves B 3.4.10 WOG STS B 3.4.10-4 Rev. 3.1, 12/01/05 BASES SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the Inservice Testing Program. Pressurizer safety valves are to be tested in accordance with the requirements of the ASME Code (Ref. 4), which provides the activities and Frequencies necessary to satisfy the SRs. No additional requirements are specified.

1The pressurizer safety valve setpoint is +/- [3]% for OPERABILITY; however, the valves are reset to +/- 1% during the Surveillance to allow for drift. REFERENCES 1. ASME, Boiler and Pressure Vessel Code,Section III.

2. FSAR, Chapter [15].

14 2 1 U 2 3. WCAP-7769, Rev. 1, June 1972. October 1971

4. ASME Code for Operation and Maintenance of Nuclear Power Plants.

JUSTIFICATION FOR DEVIATIONS ITS 3.4.10 BASES, PRESSURIZER SAFETY VALVES

1. 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.

2. 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.

3. These 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. Changes are made to be consistent with the Specification.

5. The Applicability of ITS 3.4.12 does not include MODE 4. Therefore, the MODE 4 Applicability reference has been deleted.

Kewaunee Power Station Page 1 of 1 Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.10, PRESSURIZER SAFETY VALVES There are no specific NSHC discussions for this Specification.

Kewaunee Power Station Page 1 of 1 ATTACHMENT 11 ITS 3.4.11, PRESSURIZER POWE R OPERATED RELIEF VALVES (PORVS)

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01ITS ITS 3.4.114. Pressure Isolation Valves A. All pressure isolation valves listed in Table TS 3.1-2 shall be functional as a pressure isolation device during OPERATING and HOT STANDBY MODES, except as specified in 3.1.a.4.B. Valve leakage shall not exceed the amounts

indicated.

B. In the event that integrity of any pressure isolation valve as specified in Table TS 3.1-2 cannot be demonstrated, reactor operation may continue, provided that at least two valves in each high pressure line having a non-functional valve are in, and remain in, the mode corresponding to the isolated condition.

(1) C. If TS 3.1.a.4.A and TS 3.1.a.4.B cannot be met, then an orderly shutdown shall be initiated and the reactor shall be in the HOT SHUTDOWN condition within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the INTERMEDIATE SHUTDOWN condition in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

and the COLD SHUTDOWN condition within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

5. Pressurizer Power-Operated Relief Valves (PORV) and PORV Block Valves A. Two PORVs and their associated block valves shall be OPERABLE during HOT STANDBY and OPERATING modes.

1. With one or both PORVs inoperable because of excessive seat leakage, within one hour either restore the PORV(s) to OPERABLE status or close the associated block valve(s) with power maintained to the block valve(s);

otherwise, action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

2. With one PORV inoperable due to causes other than excessive seat leakage, within one hour either restore the PORV to OPERABLE status or close its associated block valve and remove power from the block valve.

Restore the PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or

action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

3. With both PORVs inoperable due to causes other than excessive seat leakage, within one hour either restore at least one PORV to OPERABLE status or close its associated block valve and remove power from the block

valve and

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

(1) Manual valves shall be locked in the closed position. Motor operated valves shall be placed in the closed position with their power breakers locked out. M02See ITS 3.4.14 Add proposed Required Action E.4M01 A CTION E A04and not capable of being manually cycledA03M02Add proposed Required Action D.2M01 A CTION D A04and not ca pable of bein g manuall y c y cledA03M02Add proposed Required Action D.2M01A04 A CTION B A CTION D A CTION A LCO 3.4.11 A02Add proposed ACTIONS Note and capable of being manually cycled Add proposed MODE 3 M01 A pplicabilit y A03See ITS 3.4.14 Amendment No. 165 TS 3.1-4 03/11/2003 Page 1 of 4 A01 ITS 3.4.11ITS 4. With one block valve inoperable, within one hour restore the block valve to OPERABLE status or place its associated PORV in manual control. Restore the block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise action shall

be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

5. With both block valves inoperable, within one hour restore the block valves to OPERABLE status or place their associated PORVs in manual control. Restore at least one block valve to OPERABLE status within the next hour; otherwise, action shall be initiated to:

- Achieve HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

- Achieve HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A05Add proposed ACTION C Note Add proposed Required Action G.2 M01M02Add proposed ACTION F Note M02Add proposed Required Action D.2M01A05A04 A CTION D A CTION G A CTION F A04 A CTION C 6. Pressurizer Heaters A. At least one group of pressurizer heaters shall have an emergency power supply available when the average RCS temperature is > 350 F. 7. Reactor Coolant Vent System A. A reactor coolant vent path from both the reactor vessel head and pressurizer steam space shall be OPERABLE and closed prior to the average RCS temperature being heated > 200F except as specified in TS 3.1.a.7.B and TS 3.1.a.7.C below.