ML101890236
| ML101890236 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 06/07/2010 |
| From: | Dominion Energy Kewaunee |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML101890236 (7) | |
Text
ITS NRC Questions Id1941NRC Question Number RPG-006 Category Technical ITS Section 3.1 ITS Number 3.1.8 DOC Number JFD Number JFD Bases Number Page Number(s) 190 NRC Reviewer Supervisor Carl Schulten Technical Branch POC Add Name Conf Call Requested N NRC Question Attachment 1, Volume 6, Rev. 0, Page 190 of 213 proposed ITS LCO 3.1.8, "PHYSICS TESTS Exceptions
- MODE 2" Proposed ITS LCO 3.1.8 change (second paragraph) states, "Functions 2, 3, 6 and 16e may be reduced to 3 required channels." Please also refer to marked-up change on page 181 for ITS LCO 3.1.8. However, per Attachment 1, Volume 8, Rev. 0, Page 9 of 517 , CTS Table 3.3.1-1, lists function 16e as 16d for Permissive/Interlock P-10, Power Range Nuclear Instrument." Please correct /explain the change. Attach File 1 Attach File 2 Issue Date 4/19/2010 Added By Ravinder Grover Date Modified Modified By Date Added 4/19/2010 3:13 PM Notification NRC/LICENSEE Supervision Ravinder Grover Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=1941 Licensee Response/NRC Response/NRC Question Closure Id2801NRC Question Number RPG-006 Select Application Licensee Response Response Date/Time 4/21/2010 7:05 AM Closure Statement Response Statement After further review, Kewaunee Power Station (KPS) has determined that this is a typographical error. The referenced IT S Table 3.3.1-1 Function should be 16.d, not 16.e or 18.e. A draft markup regarding this change is attached. This change wi ll be reflected in the supplement to this section of the ITS conversion amendment.
Question Closure Date Attachment 1 RPG-006 Markup.pdf (1MB) Attachment 2 Notification NRC/LICENSEE Supervision Ravinder Grover Jerry Jones Bryan Kays
Ray Schiele Added By Robert Hanley Date Added 4/21/2010 7:09 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
p h p?re q uestT ype=areaItemPrint&itemId=2801 A01 ITS 3.1.8 ITS f. Minimum Conditions for Criticality Add proposed suspension of LCO 3.4.2 requirement L01 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. See ITS 3.4.9 See ITS 3.4.3 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/ºF 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. See ITS 3.1.3 A03 initiated in MODE 2 LCO 3.1.8 and A pplicabilit y Add proposed LCO 3.1.8.a L01Add proposed LCO 3.1.8.b and LCO 3.1.8.c M01During performance of PHYSIC TESTS, the number of required channels for LCO 3.3.1, Functions 2, 3, 6, and 18.e may be reduced to 3. A02M01Add proposed ACTIONS A and B Add proposed ACTIONS C and D L01 L01Add proposed SR 3.1.8.1 M01Add proposed SR 3.1.8.2 and SR 3.1.8.3 Amendment No. 165 TS 3.1-10 03/11/2003 Page 1 of 5 DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS Exceptions - MODE 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.f.3, CTS 3.10.d.3, and CTS 3.10.e state that the limitations of certain specifications may be suspended during the performance of PHYSICS TESTS. CTS Table TS 3.5-2, Functional Units 2, Nuclear Flux Power Range, states the minimum OPERABLE channel requirement is 3, except as modified by Note (1). ITS LCO 3.1.8 includes an allowance to reduce the required number of channels for ITS LCO 3.3.1, "RPS Instrumentation," Functions 2 (Power Range Neutron Flux), 3 (Power Range Neutron Flux Rate), 6 (Overtemperature T), and 16.e (Power Range Neutron Flux, P-10) from "4" to "3" during PHYSICS TESTS. This changes the CTS by stating the specific number of RPS channels from that have to be OPERABLE during PHYSICS TESTS.
The purpose of CTS 3.1.f.3, CTS 3.10.d.3, and CTS 3.10.e is to allow some flexibility during the performance of PHYSIC TESTS. This change is acceptable because the minimum number of channels required for OPERABILITY for the Reactor Trip Functions in CTS Table TS 3.5-2 is currently "3." This allowance is needed since the Required Channels in ITS 3.3.1, Reactor Trip System Instrumentation, is "4." This change from the CTS is discussed in the Discussion of Changes for ITS 3.3.1. Furthermore, the exception identified in CTS Table TS 3.5-2 Note (1) is discussed in DOC M02. This change is designated as administrative because it does not result in technical changes to the CTS.
A03 CTS 3.1.f.3 states that the Moderator Temperature Coefficient requirement specified in the COLR may be suspended during the performance of LOW POWER PHYSICS TESTING. CTS 3.10.d.3 states that the Rod Insertion Limits do not apply during the performance of PHYSICS TESTS. CTS 3.10.e states that the Rod Misalignment Limitations do not apply during the performance of PHYSICS TESTS. ITS 3.1.8 is applicable "During PHYSICS TESTS initiated in MODE 2." This changes the CTS such that the Specification is applicable in MODE 2 only when a PHYSICS TEST is initiated.
The purpose of ITS 3.1.8 Applicability is to ensure that the Actions contained in the Specification are followed. The CTS applicability does not specifically state what MODE the PHYSICS TEST is performed in. The ITS Applicability states emphatically the MODE that the PHYSICS TEST will be performed. This change is designated as administrative because it clarifies the current wording in the Specification with no change in intent.
Kewaunee Power Station Page 1 of 3 PHYSICS TESTS Exceptions - MODE 2 3.1.8 WOG STS 3.1.8-1 Rev. 3.0, 03/31/04 CTS 3.1 REACTIVITY CONTROL SYSTEMS
3.1.8 PHYSICS TESTS Exceptions - MODE 2
LCO 3.1.8 During the performance of PHYSICS TESTS, the requirements of:
LCO 3.1.3, "Moderator Temperature Coefficient," 1 2 1 4 LCO 3.1.4, "Rod Group Alignment Limits,"
LCO 3.1.5, "Shutdown Bank Insertion Limits," LCO 3.1.6, "Control Bank Insertion Limits," and LCO 3.4.2, "RCS Minimum Temperature for Criticality"
may be suspended and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, 6 and 18.e, may be reduced to 3 required channels, provided:
- a. RCS lowest loop average temperature is [531]°F, b. SDM is within the limits specified in the COLR, and
- c. THERMAL POWER is < 5% RTP.
APPLICABILITY: During PHYSICS TESTS initiated in MODE 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A. SDM not within limit.
A.1 Initiate boration to restore SDM to within limit.
AND A.2 Suspend PHYSICS TESTS exceptions.
15 minutes
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B. THERMAL POWER not within limit.
B.1 Open reactor trip breakers.
Immediately
C. RCS lowest loop average temperature not within limit.
C.1 Restore RCS lowest loop average temperature to within limit.
15 minutes 530 16 RPS ;; ; DOC L01 DOC M01 DOC M01 3.1.f, 3.10.e, 3.10.d, DOC L01 DOC A02 DOC M01 DOC M01 DOC L01 DOC L01 3.10.d 3.10.d 3.10.e 3.1.f PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 WOG STS B 3.1.8-5 Rev. 3.0, 03/31/04 BASES APPLICABLE SAFETY ANALYSES (continued)
The PHYSICS TESTS include measurement of core nuclear parameters or the exercise of control components that affect process variables. Among the process variables involved are AFD and QPTR, which represent initial conditions of the unit safety analyses. Also involved are the movable control components (control and shutdown rods), which are required to shut down the reactor. The limits for these variables are specified for each fuel cycle in the COLR.
As described in LCO 3.0.7, compliance with Test Exception LCOs is optional, and therefore no criteria of 10 CFR 50.36(c)(2)(ii) apply. Test Exception LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
Reference 6 allows special test exceptions (STEs) to be included as part of the LCO that they affect. It was decided, however, to retain this STE as a separate LCO because it was less cumbersome and provided additional clarity.
LCO This LCO allows the reactor parameters of MTC and minimum temperature for criticality to be outside their specified limits. In addition, it allows selected control and shutdown rods to be positioned outside of their specified alignment and insert ion limits. One power range neutron flux channel may be bypassed, reducing the number of required channels from 4 to 3. Operation beyond specified limits is permitted for the purpose of performing PHYSICS TESTS and poses no threat to fuel
integrity, provided the SRs are met.
The requirements of LCO 3.1.3, LCO 3.1.4, LCO 3.1.5, LCO 3.1.6, and LCO 3.4.2 may be suspended and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, 6 and 18.e may be reduced to 3 required channels during the performance of PHYSICS
TESTS provided:
16 4 RPS a. RCS lowest loop average temperature is [531]°F, b. SDM is within the limits provided in the COLR, and 530 ; ; 3 1 1 c. THERMAL POWER is 5% RTP.
Licensee Response/NRC Response/NRC Question Closure Id2811NRC Question Number RPG-006 Select Application NRC Question Closure Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Response Statement Question Closure Date 4/21/2010 Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Victor Cusumano Added By Ravinder Grover Date Added 4/21/2010 7:24 AM Modified By Date Modified Pa ge 1of 1 Kewaunee ITS Conversion Database 06/07/2010 htt p://www.excelservices.com/rai/index.
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