ML021220053

Attachment 2 - Table a - Administrative Changes North Anna, Units 1 and 2, Amendments 231 and 212

ML021220053
Person / Time
Site:	North Anna
Issue date:	04/05/2002
From:	NRC/NRR/DLPM
To:
References
TAC MB0799, TAC MB0800
Download: ML021220053 (183)

Text

ATTACHMENT 2 Table A - Administrative Changes

Table A - Administrative Changes ITS Section 1.0 - Use and Application I'1'S Requirement j CTS Requir ement Description of Change ITS ReqUirmcmcnI CTS RCIe Circarot DOC No.

None 1.0 A.lI In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Nonic SVarilous Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG- 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

rnot result in These changes are designated as administrative changes and are acceptable because they do technical changes to the CTS. -1 1.1 definitions ol 1 ne 1.0 A.2 ITS Section 1.1 provides definitions of ACTUATION LOGIC TEST, MASTER REIAY TEST, and I. I definlitions of, ACTUATION INone TEST (TADOT). These terms are used as defined TRIP ACTUATING DEVICE OPERATIONAL LOGIC TEST, terms in the ITS but do not appear in the CTS. MASTEIiR RELAY "'IS'l',

or alter existing This change is acceptable because these changes do not impose any new requirements AND TADOT requirements. Any technical changes due to the addition of these terms and definitions will be addressed in the Discussion of Changes (DOCs) for the sections of the Technical Specilfications in which the terms involve no are used. These changes are designated as administrative as they add defined terms which technical change to the Technical Specifications. -t 1.1 delinition of I 1.0 (lefinition of 4I ITS Section 1. I 1.0 A.3 CTS Section 1.0 provides a definition of SHUTDOWN MARGIN (SDM). The 1 dclinitio of, D. 1.0 dcil)itionMcol" SI)M SI)M definition of SDM contains three diffcrcnces froml the CTS dcl'inition.

to hc The CTS definition is changed to state the highest reactivity worth RCCA does not have means. 'T'his change is assumed if the RCCAs can be verified fully inserted by two independent described in DOC L.5.

Assemblics SThe CTS definition is changed to indicate that the worth of any Rod Control Cluster fully inserted must be accounted [For in the (RCCAs) which are not capable of being determnination of the SDM.

in CTS This change is acceptable because it is consistent with the existing SDM reqtuirCmenls 3.1.1.1 and 3.1.1.2.

,iomi nal SThe CTS defIinition is clarified to include a description of the reacttor Conditions, i.e.

zero power level, at which thc SDM is calculated.

SDM This change is acceptable because including this in formation is not a technical change.

calculations are currently performed for nominal zero power conditions.

change to the These changes are designated as administrative because they do not represent a technical Technical Specifications...

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Table A - Administrative Changes ITS Section 1.0 - Use and Application

. . .. - 1 .1.1,.1 - - -- - I - " - .:- - - --

DOC No. Description of Change ITS RequiremenltICTSRequire-mnt I 1dfniino I .0 (lehnition of for 1.0 def'inition of, 1.0 A.4 The CTS Section 1.0 definition of CHANNEL FUNCTIONAL TEST includes the requirements 1 definition of A. CHANNEL TADOT "performing a CHANNEL FUNCTIONAL TEST on bistable channels. ITS Section I. IImoves these FUNCTIONAl.

requirements to a new defined term, TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT). TlESTI This change is acceptable because the movement of this information does not impose any new requirements or alter existing requirements. Any technical changes associated with the movement of this it is information will be addressed in other DOCs. This change is categorized as administrative because the movement of information within the Technical Specifications. i- i of 1.0 A.5 CTS Section 1.0 provides a definition of CORE ALTERATION. The ITS Section I. I definition 1.1 definition of*

CORE 1.0 definlitionl of, CORE CORE ALTERATION revises the CTS definition to eliminate two redundant phrases. AtITERATION ALTERATION The CTS definition includes, "movement or manipulation" of any component within the reactor vessel. The ITS definition of CORE ALTERATION will only include "movement" of components, not "manipulation."

This change is acceptable because the eliminated phrase adds no value. In the context of this definition, any manipulation of a component will involve its movement, so stating "movement or manipulation" is redundant and potentially confusing.

The CTS definition does not preclude completion of movement of a component to at "safe conservative" position. The ITS definition specifies only a "salfe" position.

This change is acceptable because the eliminated phrase adds no value. The Technical Specifications provide no basis for determining whether a movement is conservative, so it is assumed that the word "conservative" is used in the definition to mean "sal'e."

Therefore, stating "safe conservative" is repetitious andl potentially confusing.

words These changes are designated administrative because they rep,'scnt thle elimination of redundant changing the intent of the definition. I I I and phrases without Pagc 2 of I I A- 1.0 North Anna Power Station

Table A - Administrative Changes ITS Section 1.0- Use and Application DOC No. Description of Change ITS Rcqtlii rcment CTS Requliremen.t 1.0 A.6 CTS Section 1.0 provides a definition of FREQUENCY NOTATION and includes CTS Table 1.2, which None 1.0 definition of lists these notations. TFhe ITS will not contain this information in Section I.1, but will state the FREQUENCY requirements in each Surveillance. NOTATION and Table 1.2 This change is acceptable because each ITS Surveillance Requirement (SR) provides the specific frequency without relying on a notation (e.g., "31 days" versus "M"). Providing the specific fr'equencies in the Surveillance Requirements eliminates the need for the FREQUENCY NOTATION definition and CTS Table 1.2. Any Surveillance Frequencies altered by the elimination of the definition and table will be addressed in a DOC for the affected section. This change is designated as administrative because it does not change any SR frequencies.

1.0 A.7 CTS Section 1.0 provides a definition of FULLY WITHDRAWN, which defines the fully withdrawn None 1.0 definition of position of the RCCAs as between 225 and 229 steps. The ITS will not include FULLY WITHDRAWN FULLY as a defined term. WITHDRAWN This change is acceptable because the term FULLY WITHIDRAWN is not used as a defined termi in the ITS or ITS Bases. This change is designated as administrative because it eliminates a defined tei in that is no longer used 1.0 A.8 CTS Section 1.0 includes the Ihllowing definitions: CONTAINMENT INTEGRITY, GASEOUS None Listed 1.0 RADWASTE TREATMENT SYSTEM, MEMBER(S) OF THE PUBLIC, PURGE - PURGING, definitions REPORTABLE EVENT, SITE BOUNDARY, SOURCE CHECK, UNRESTRIICTED AREA.

VENTILATION EXHAUST TREATMENT SYSTEM, VENTING. The ITS does not use this terminology and ITS Section I. I does not contain these definitions.

These changes are acceptable because the terms are not used as defined terms in) tile ITS. Discussions of any technical changes related to the deletion of these terms are included in the DOCs for the CTS sections in which the terms are used. These changes are designated as administrative because they eliminate defined terms that are no longer used.

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Table A - Administrative Changes ITS Section 1.0 - Use and Application DOC No. Description of Change Descritioniofthrng ITl',. I u e.UqLIII tI I u I- ) 1l...t;,k IItll lll',-t I I

1.1 (lelinition ol I .0 dcfinitions of LAIK GinitionEof

1. 1.(0 definitions of*

1.0 A.9 CTS Section 1.0 provides definitions for CONTROLLED LEAKAGE, IDENTIFIED LEAKAGE, LEAKAGE CONTROLLED Section 1.l1 includes PRESSURE BOUNDARY LEAKAGE, and UNIDENTIFIED LEAKAGE. ITS LEAKAGE, tirce categories: Jentified IDENTIFIED these requirements in one definition called LEAKAGE (which includes LEAKAGE). This changes the CTS by LEAKAGE, LEAKAGE, unidentified LEAKAGE, and pressure boundary definition with no technical changes. The CTS PRESSURE incorporating the definitions into the ITS LEAKAGE the seal water flow supplied to the reactor coolant pump 13BUNDAIRY term CONTROLILEI) LEAKAGE, which is has its own specification titled "Seal Injection Flow" as ITS LEAKAGE, and seals, is no longer considered leakage and CTS no longer considered leakage, it appears as an exccpti(! i in the UNIDENTIFIEID 3.5.5. Since Seal Injection flow is a result, the ITS will not definitions of IDENTIFIED LEAKAGE and UNIDENTIFIED LEAKAGE. As LEAKAGE contain a defined term, "Controlled Leakage."

Specifications. This This change is acceptable because it results in no technical changes to the Technical change in that it rearranges existing definitions, with no change in change is designated an administrative intent.

-t I delinitions ol I I .0 definitions of TIME and 1.1 dclinitions of' 1.0} definlitions o}f 1.0 A. 10 CTS Section 1.0 provides definitions of ENGINEERED SAFETY FEATURE RESPONSE ENGINFHERFI) ENGINEERED Section 1. 1 modifies thie definitions to SAFETY REACTOR PROTECTIVE SYSTEM RESPONSE TIME. ITS time SAFEI'TY tile CTS by stating that the response FEA'I'URE more fully describe how the tests are performed. This changes FEATURE total steps so that the entire RESPONSE TIMEI test may be measured by means of any series of sequential, overlapping, or RESPONSE, response time is measured. TIME and and RFCT'Ol'OR REACT)OR PROTI CTIVE.

current plant practices, as well This change is acceptable because the ITS definitions are consistent with PIOTECT'IV I; SYSTEM 6.3.4, "lResponse Time Veri fication Tests." The as the guidance provided in IEEE 338-1977, Section SYSTEM RE"SPONSE 'TIME This change is designated as administrative as it does results of the test are unaffected by this allowance. RESPONSE not result in a technical change to the response time tests.

TIME

___ I_________________________________

L _____________

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Table A - Administrative Changes ITS Section 1.0 - Use and Application I't'S Requi lenient CTS Requirement D)OC No. Description ol' Change FI'S Requirenlient CTS R*equirementt

.1 del'inition of I.) A.l l CTS Section 1.0 defines CHANNEL FUNCTIONAL TEST as "the injection {of a sinmlatcd signal into 1. 1 def'inition of' CFtANNEIL 1.{0 definition of CHANNEL the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip OPERATIONAL FUNCTIONAL functions." ITS Section I-.I renames the CTS definition to CHANNEL OPERATIONAL TEST (COT) TEST "Il'F'ST and defines it as, "the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channecl required for channel OPERABILITY.

The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip sctpoints so that the setpoints are within the required range and accuracy. The COT'l may be perlormed by means of' any series of sequential, overlapping or total channel steps." The addition of use of an actual signal is discussed in DOC L.I1. This changes the CTS by stating that the COT shall inclIude adjustmcnts, as necessary, of the (devicesin the channel so that the setpoints are within tthe required range and accuracy, changes the example list of (evices contained in the definition, and states that the test may be pcrfornmed by means of any series of sequential, overlapping, or total channel steps.

This change is acceptable because the ITS definition is consistent with currcnt plant practices anid the results of' the test are unaffected by the change.

"TheCTS definition states that the CHANNEL FUNCTIONAl. T'ES shall verify that the channel is operable "including alarm and/or trip initiating action." The ITS states that the COT shall verify OPERABILITY of "all devices in the channel rcquired for channel OPERABILITY." This change is acceptable because the statements are equivalent in that both require that the channel be Verified to be OPERABLE. The CTS and the ITS Use different examples of what is included in a channel, but this does not change the intent ofI the requirement. The IeTS use of the phrase "all devices in the channel required for channel OPERABILITY" reflects the CTS undersianding that the test only incIides t(hose portionis of' the channel needed to perform the safetytrunction.

" The ITS states, "'The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints so that tie setpoints ate within the required lange and accuracy." This change is acceptable because it clarifies that adjustments perlormed during a COT do not invalidate ihe test.

This is consistent with the current implementation of tIhe CHANNEL FUNCTIONAL TEST and does not result in a technical change to the speci fications.

" The ITS states, "The COT may be perlormed by means of any series (If sequential, overlappling, and total channel steps." This change is acceptable because it states current Industry pnactice. This is consistent with the current implementation of the CHANNEL FUNCTIONAL TEST an( (doesnot result in a technical change to tlie specifications.

This change is designated as administrative because it does not resIUlt in a technical change it) tile speci fications.

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Table A - Administrative Changes ITS Section 1.0 - Use and Application I'17S Requirenrent C'FS RCquiremCflt Description of Change [TS RequLiremen~ltI CTS Requirement DOC No. _ __ _ _ _ __ _ _ __ __ __ _ _......._ __..._ _._......1 shall be the 1.1 definition of 1.0 definition of, 1.0 A.12 'The CTS (definesCHANNEL CALIBRATION as, "A CHANNEL CALIBRATION CHANNEL CHANNEL necessary range and adjustment, as necessary, of the channel output such thlat it responds with the CALl BRPATION CALIBRATION CHANNEL accuracy to known values of the parameter which the channel monitors. The alarm and/or trip functions, CALIBRATION shall encompass the entire channel including the scnsor and CALIBRATION may be and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL such that thie entire channel is performed by any series of sequential, overlapping or total channel steps as necessary, of the channel calibrated." ITS defines CHANNEL CALIBRATION as, "the adjustment, The CHANNEL so that it responds within tile required range and accuracy to known input.

OPERABIILITY.

CALIBRATION shall encompass all devices in the channel required for channel detector (RTD) or thermocouple sensors Calibration of instrument channels with resistance temperature behavior and normal calibration of the may consist of an inplace qualitative assessment of sensor CHANNEL CALIBRATION may be performed by remaining adjustable devices in the channel. The calibrations or total channel steps." 'This rcsuIts in a means of any series of sequential, overlapping CALIBRATION shall number o" changes to the CTS. The CTS definition states, "The CHANNEL including the sensor and alarm and/or trip functions" The ITS states, "The encompass tile entire channel required fo1r channel CHANNEL CALIBRATION shall encompass all devices in tihe channel "shall include the CHANNEL OPERABILITY.' The CTS states that the CHANNEL CALIBRATION IS adds the statement, FUNCTrIONAL TEST." The ITS does not include this statement. ThIc detector (R,°.I'l)) or thermocouple sensors "Calibration of instrument channels with resistance temperature behavior and normal calibration of the may consist of an inplace qualitative assessment of sensor remaining adjustable devices in the channel."

-t I 1.1 delinition

- definition

-I.I1 . ... . .

of.. 1I I .t) definition ol' train, component or device of 1.0 definlitionl of OPERABLE 1.0 A.13 The CTS Section 1.0 definition of OPERABLE requires a system, subsystem, OPERABLI support systems to also be OPEIRABILITY to be capable of performing its "specified function(s)" and all necessary OPERAI3 II.ITY of OPERABLE requires the capable of performing their "lunction(s)." The ITS Section I. I definition to be capable of system, subsystem, train, component or device, and all necessary support systems, the requirement to be performing the "specified safety 'unction(s)". This changes the CTS by altemring safcty functions."

able to perform "'functions'"tro a requirement to be able to perlormn The purpose of the CTS and 'I'Sdefinitions of OPERABIALE is to ensure that the sal'ety analysis assumptions regarding equipment and variablcs are valid. '[his change is acceptable because the intent of analysis and both the CTS and ITS definitions is to address the safety function(s) assumed in the accident non-safety functions are not not encompass other non-safety functions a system may also perform. These public hcalth and safety. This assumed in the safety analysis and are not nceded in order to protect tile of the terms OPLRABLE and change is consistent with the cutrrent interpretation and use as it does not change the currcnt use and OPERABILITY. This change is designated as administrative application of tie Technical Specifications. AI l(

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Table A - Administrative Changes ITS Section 1.0 - Use and Application DOC No. J Description of Changec ITS Rcquiremcnt CTS ,CRequiremcint 1.0 A. 14 CTS Section 1.0 and Table I. I, "OPERATIONAL MODES," provide a description of the MOI)ES. ITS . I delinition of, 1.0 delinition of Section I. 1 and Table, I. 1 I, "MODES," changes the CTS MODE dehnitioils in several ways: MODE andTable OPEI3,ATIONAL 1.1-1 MODES aid Table The phrase "the vessel head closure bolts" is replaced with "one or more vessel head closure bolts" in Note **. This change is acccptable because thie revised phrase is consistent with the current interpretation and usage. MODE 6 is currently declared when the first vessel head closure bolt is dctensioned.

iThe Note ** condition, "fuel in tile reactor vessel" is moved fronm ['able I. I to the MODE definition. This change is acceptable because it moves in formation within the Technical Specifications with no change in intent.

The phrase "or with the head removed" is eliminated from Note *.This change is acceptable because it eliminates a redundant phrase. The reactor vessel head cannott be removed unless tile reactor vessel head closure bolts are detensioned. Since "One or more reactor vessel head closure bolts less thtan fully tensioned" is already specified in the Note, including "or with the head removed" is uonnecessary.

ITS Table 1.1-1 contains a new Note, labeled "(b)", which applie.s to MODES 4 and 5. Note (b) states, "All reactor vessel head closure bolts Iully tensioned." This Note is tihe opposite of CTS Note ** and ITS Note (c).This change is acceptable because it avoids a conflict between the definition of MODE 6 and the other MODES should RCS temperature increase above tile CTS MODE 6 temperature limit when a reactor vessel head closure bolt is less than fully tensioned.

This ITS Note is included only for clarity. It is consistent with the current use of MODES 4 and 5 and does not result in any technical change to the application of the MODES.

For consistency with the Notes in ITS Table I. I- I, the ITS definition of MODE incorporates "reactor vessel head closure bolt tensioning" to the list of characteristics that define a MODE.This change is acceptable because the definition of MODIE should be consistent with the MODE table in order to avoid confusion. This change is made only I'*r consistency and results in no technical changes to the Technical Specifications.

These changes are designated as administra!ive because they clarify the application of the MOI)ES and no technical changes to the MODE definitions are made. The clarifications are consistent with the current use and application of the MODES.

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Table A - Administrative Changes ITS Section 1.0 - Use and Application Description of Change r ITS Requirement T L1*s t(equrrernent t CTIS RClilequnl'entn1 I DOC No. ITS Requirenment

.1 definition of I .0 definition of BASIS ILI definfition of' 1.0 definition of, 1.0 A.15 The CTS Section 1.0 definition of STAGGERED TEST BASIS states, "A STAGGERED TEST STIAGGERIE STAGGERED subsystems, trains or other designated components TEST BASIS TFST BASIS shall consist of: a. A test schedule For n systems, testing of one system, obtained by dividing the specified test interval into n equal subintervals, b. The beginning of each subinterval." The ITS Section subsystem, train, or other designated component at the BASIS shall consist of the testing of one of the systems, 1.1 definition states, "A STAGGERED TEST during the interval specified by the Surveillance subsystems, channels, or other designated components channels, or other designated components are tested during n Frequency, so that all systems, subsystems, n is the total number of systems, subsystems, channels, or other Surveillance Frequency intervals, where function." This changes tile CTS to specify tile frequency of a designated components in the associated train, or other designated component in the Frequency column of Surveillance on one system, subsystem, in which all systems, subsystems, trains, or other designated the ITS instead of specifying the frequency components must be tested.

on a STAGGERED TEST BASIS This change is acceptable because the testing frequency of components is not changed. Unlike the CTS definition, the ITS dceinition allows the Surveillance intcerval for one column of the applicable Surveillance Requirements, subsystem to be specified in the Frequency As an example, consider a three channel system tested on a independent of the number of subsystems.

The CTS would specify testing every three months on a STAGGEREDI STAGGERED TEST BASIS.

results in one channel being tested each month (three equal subintervals). Under the TEST BASIS, which TEST BASIS and, ITS definition, tile Surveillance frequency would be monthly on a STAGGERED and ITS definition, all channels are again, one channel would be tested each month. In both the CTS be perfornmed at the heginning of the tested every three months. Each test under the CTS definition would the beginning of the CTS subinterval. Under the ITS definition, each Surveillance Frequency starts ai in the testing interval. This change reprcselnts an definition subintcrval. Thus, there are no net changes changes are editorial preference in tile ITS. This change is designated as administrative as no technical made to the Technical Specifications II Page 8 of I I A 1.0

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Table A - Administrative Changes ITS Section 1.0 - Use and Application Description of* Change ITS Rl.equirement CTS Requiremlent DOC No.

adds 1.2, 1.3, and 1.4 None 1.0 A.]16 ITS Sections 1.2, 1.3, and 1.4 contain information that is not in the CTS. This change to the CTSarc:

explanatory information on the ITS usage that is not applicable to the CTS. The added sections Section 1.2 - Logical Connectors Section 1.2 provides specific examples of the logical connectors "AND" and "OR" and the numbering sequence associated with their use.

Section 1.3 - Completion Times Section 1.3 provides proper use and interpretation of Completion 'limes. The section also provides specific examples that aid in the use and understanding of Completion Times.

Section 1.4 - Frequency Section 1.4 provides proper use and interpretation of thc SurveillancC Frequency. The section also provides specific examples that aid in the use and understanding of Surveillance Frequency.

This change is acceptable because it aids in the understanding and use of* the fIormat and presentation he style of the ITS. The addition of these sections does not add or delete technical requirements, and will of the added sections results in a change.

discussed specifically in those Specifications where application This change is designated as administrative because it does not result in a technical change to the Technical Specifications Page 9 of I I A- 1.0 North Anna Power Station

Table A - Administrative Changes ITS Section 1.0 - Use and Application DOC No. Dcscription of Changc ITS Rcquircmcnt CTS Rcqtiirement 1.0 A. 17 CTS Table 1.1, OPERATIONAL MODES, is reviscd. The corresponding table in ITS Section I. I is Table 1. I- 1 Table 1.1 Table I. I- 1, MODES. The changes to (he CTS are:

SThe minimum average reactor coolant tcmperature f1r MODES I and 2 provided in CTS Tablc I. I is changed to NA (not applicable) in ITS Table I. 1-1I.

This change is acccptable because ITS LCO 3.4.2, RCS Minimum Tcmperature lor Criticality, provides the minimum reactor coolant temperature limits for MODES I and 2. Therelfoe, the 350'F minimum temperature docs not provide any useful infOrmnation in Table I. I- I, and is deleted from the ITS.

• , The CTS Table I. I MODE 6 upper limit on average reactor coolant temperature is removed. In ITS Table 1. I-I, the MODE 6 average reactor coolant temperalure limit is given as "NA" (not applicable).

This change is acceptable because it eliminatcs a conllict in the CTS MODE table. If the avcragc coolant temperature exceeds the upper limit with'the reactor vessel hcad closure bolts less than fully tensioned, the CTS Table could be misinterpreted as no MODE being applicable.

This is not the intent of the CTS or ITS MODE 6 definitions. By removing the temperature reference, this ambiguity is eliminated.

The CTS Table 1.1 RATED THERMAL POWER limits of"01 (Yfor MODES 3, 4, 5. and 6 arc changed in ITS Table I.1-i to "NA" (not applicable).

This change is acceptable because the reactivity and plant cquipmcnt limitations in MODES 3, 4, 5 and 6 do not allow power operation. Therelore, it is not necessary to have these restrictions in the MODE table.

These changes are designated as administrative because they result in nio technical changes to the Technical Specifications North Anna Power Station Page 10 of'I I A-1.0

Table A - Administrative Changes ITS Section 1.0 - Use and Application of Change F II Z

.,... KequIrenleOl

.-. Ij L 1 . 1.cquirciiIeILL Description of Chang.e Descrip~tion IT1 R4eqtli['CIIIelIlI _I1CTS R.q~llllClllCllt DOC No. *I definition of I .0 dehliitiOfl ol slave relay and 1.1 definition of* 1.0 definlition of, FLOA.18 CTS Section 1.0 defines a SLAVE RELAY TEST as "the energization of each SLAVE REL.AY SLAVE RELAY relay. The SLAVE REI AY TEST shall include a continuity 'TEST TI ' S° verification of OPERABILITY of each I defines the SLAVE check, as a minimum, of* associated testable actuation devices." ITS Section 1.

RELAY TEST as, "the energization of all slave relays in the channel required for channel SLAVE RELAY OPERABILITY and verification of OPERABILITY of each required slave relay. The The SLAVE RELAY TEST shall include a continuity check of associated testable actuation devices.

or total channel steps." This TEST may be performed by means of any series of sequential, overlapping, include the slave relays required for changes the CTS by stating that the SLAVE RELAY TEST shall of any series of channel OPERABILITY and by stating that the test may be performed by mcans sequential, overlapping, or total channel steps.

practices and the This change is acceptable because the ITS definition is consistent withl corrent plant results of the test are unaffected by the change.

The ITS The CTS definition states that the SLAVE RELAY TEST shall energize "each slave relay."

the energization of "all slave relays in the states that the SLAVE RELAY TEST shall include statements are channel required for channel OPEiRABILITY." This change is acceptable because the equivalent in that both require that the channel be verified to be OPFERABLE. The ITS use of the required for channel OPERABIIT.l1'Y" rielects the CTS phrase "all slave relays in the channel only includes those portions of the channel needed to perform the safety understanding that the test function.

series ol sequential,

" The ITS states, "The SLAVE RELAY TEST may be performed by means of any steps." This change is acceptable because it s:ates current Industry overlapping, and total channel with the current implementation of the SLAVE* RELAY TEST and does practice. This is consistent not result in a technical change to the specifications.

This change is designated as administrative because it does not result in a technical change to the specifications. I I I

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Table A - Administrative Changes ITS Section 2.0 - Safety Limits Description of Change ITS Requirement CTS Requirement DOC No.

None:

A.I None V ariouls 2.0 In the conversion of the North Anna Current Technical Specifications (CTS) to tile plant specific Improved Technical Specifications (ITS), certain changes (wording prelcrences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 1, "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.

I___________________________________________________________________________________ t None I None II 2.1.1, Figures 2.1 2 2.1.1,2-2Figures 2.

2.0 A.2 CTS 2.1. I references three curves providing limits on THERMAL POWER, pressurizer pressure, and the and 2. 1-3 highest operating loop coolant temperature (Tavg). One curve applies to three loop operation (Figure 2.1-i) and two apply to two-loop operation (Figures 2.1 -2 and 2.1-3). In the CTS, Figures 2.1-2 and 2.1 3 are replaced with a note stating, "This page left blank pending NRC approval of ECCS evaluation of two loops in operation with the third loop isolated" and "This page left blank pending NRC approval of ECCS evaluation of two loops in operation with the third loop not isolated," respectively. ITS 2.1. I does not contain an allowance to operate with less than three reactor coolant loops in operation. This changes the CTS by eliminating references and place holders for curves applying to two-loop operation.

This change is acceptable because the requirements have not changed. Both the ITS and the CTS require all three loops in operation in the applicable MODES (MODES I and 2). This change is designated as administrative because it eliminates an option in the CTS which cannot be used.

None I unil

-t IUI.,;. I ., ; , II I I TUnit II -).Li.

4 I None Un I I 2.0 A.3 Unit I CTS 2. I.1 contains a Note and an additional Figure, Figure 2. I- 1 a, which is to be used for the itu1 2. 1.I a1, period of operation until steam generator replacement. ITS 2. I.1 does not contain a similar Note or additional Figure.

This change is acceptable because the North Anna Unit I steam generators have been replaced and the Note and the Figure are no longer applicable. This change is designated as administrative because it eliminates information from thie CTS that is no longer applicable.

I I I

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Table A- Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change [IFS Requirement CTS Requirement 3.0 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to tile plant specific None Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG- 143 1, Rev. 1, "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.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.2 Unit I CTS 3.0.1 states, "Limiting Conditions for Operation and ACTION requirements shall be LCO 3.0.1 3.0.1 applicable during the OPERATIONAL MODES or other conditions specified for each Specification."

Unit 2 CTS 3.0.1 states, "Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met." ITS LCO 3.0.1 states, "LCOs shall be met during the MODES or other specified conditions in the Applicability, except as noted in LCO 3.0.2 and 3.0.7." This results in several changes to the CTS.

Certain phrases are revised to be consistent with the equivalent phrase used in the ITS.

Specifically, "Limiting Conditions for Operation" is changed to "LCOs", and "OPERATIONAL MODES or other conditions specified" is changed to "MODES and other specified conditions" to be consistent with the ITS definition of MODE and the terminology used in the ITS. These changes are acceptable because they result in no change in the intent or application of the specification, but merely reflect editorial preferences used in the ITS.

The Unit I phrase ". . . ACTION requirements shall be applicable during the OPERATIONAL.

MODES..." and the Unit 2 phrase ". . . except that upon failure to meet the Limliting Conditions for Operation, the associated ACTION requirements shall be met" are moved firom CTS 3.0.1 to ITS LCO 3.0.2 which states that when an LCO is not met, the Required Actions must be met. The change is acceptable because moving this information within the Technical Specifications results in no change in the intent or application of ACTIONS.

The Unit I CTS 3.0.1 phrase "Limiting Conditions for Applicability ... shall be applicable" and the Unit 2 CTS 3.0.1 phrase "Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required" are replaced in ITS LCO 3.0. I with the phrase "LCOs shall be met." This change is made to be consistent with the ITS terminology and to clarify the concept of an LCO being met (e.g., being in compliance with the requirements of the LCO), versus the LCO being applicable or required (e.g., the requirements in the LCO apply.) This change is acceptable because it is an editorial change that does not change the intent of the requirements.

_________ __________________________________________________________________________________________ I _________________ L __________________

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability

[DOC No. Description of Change ITS Requirement [ CTS Requirement LCO 3.0.1 3.0.1 3.0 A.2

• The phrase "except as provided in LCO 3.0.2 and LCO 3.0.7" is added to CTS 3.0.1. ITS LCO 3.0.2 describes the appropriate actions to be taken when ITS LCO 3.0.1 is not met. LCO 3.0.7 (con't) describes Test Exception LCOs, which are exceptions to other LCOs. This change is acceptable because adding the exception for LCO 3.0.2 and LCO 3.0.7 prevents a conflict within the Applicability section. This addition is needed for consistency in the ITS requirements and does not change the intent or application of the Specifications.

These changes are designated administrative because they are editorial and result in no technical changes to the Technical Specifications.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOG No. Description of Change ITS Requirement CTS Requirement

-3.0.2n-Unit I CTS 3.0.2 states, "Adherence to the requirements of the Limiting Condition for Operation and/or IILCO I LCO-- 3.0.2 3.0 A.3 1 .0 .2 Z associated ACTION within the specified time interval shall constitute compliance with the Specification.

In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required." Unit 2 CTS 3.0.2 states the same requirements, but in the negative, as, "Noncompliance with a specification shall exist when the requirements of the Limiting Conditions for Operation and associated ACTION requirements are not met within the specified time intervals. Ifthe Limiting Conditions for Operation is restored prior to expirations of the specified time intervals, completion of ACTION requirements is not required." ITS LCO 3.0.2 states, "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated." This results in several changes to the CTS.

The first sentence in Unit I CTS 3.0.2, states, in part, "Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION ... shall constitute compliance with the Specification." This requirement is divided into portions of ITS LCO 3.0.!1, "LCOs shall be met" and ITS LCO 3.0.2, "Upon discovery of failure to meet an LCO, the Required Actions of the associated Conditions shall be met".

This change is acceptable because the intent of the CTS requirement is preserved, but the aspects of LCO compliance and the performance of ACTIONS when the LCO is not met are separated.

Unit 2 CTS 3.0.2, states, "Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals." This sentence is deleted. This information currently is stated in Unit 2 CTS 3.0.1 and is moved to ITS 3.0.2 as described in Discussion of Change A.2.

ITS 3.0.2 states that the Required Actions are to be taken when the LCO is not met. This rearrangement separates the description of LCOs (in ITS LCO 3.0.1) and the description of Required Actions (in ITS LCO 3.0.2).

This change is acceptable because it makes the Unit I and Unit 2 descriptions of LCOs and Required Actions identical and improves clarity, without changing the intent of the CTS.

_ __I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ I _ _ _ _ _f _ _ _ _

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability Description of Change ITS Requirement I CTS Requirement LCO 3.0.2 3.0.2 3.0 A.3

• The Unit 1 and Unit 2 CTS 3.0.2 are revised to include an exception for LCO 3.0.5 and 3.0.6.

LCO 3.0.5 and LCO 3.0.6 are new allowances which take exception to the ITS LCO 3.0.2 (con't) requirement to take the Required Actions when the associated LCO is not met. This exception is included in LCO 3.0.2 to avoid conflicts between the applicability requirements.

This change is acceptable because it includes references to new items in the ITS and results in no change to the CTS. Changes resulting friom the incorporation of LCO 3.0.5 and LCO 3.0.6 are discussed in Discussions of Change L.2 and L.3.

The second sentence of Unit I CTS LCO 3.0.2 states, "In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required." The second sentence of Unit 2 CTS LCO 3.0.2 states, "if the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required." These sentences state the same requirement. They are replaced in ITS LCO 3.0.2 with, "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated." This change is acceptable because, while worded differently, both the CTS and ITS state that ACTIONS do not have to be completed once the LCO is met or is no longer applicable. ITS LCO 3.0.2 also adds the phrase, "unless otherwise stated." There are some ITS ACTIONS which must be completed, even if the LCO is met or is no longer applicable.

This change is acceptable because it reflects a new feature in the ITS which did not exist in the CTS.

The technical aspects of these changes are discussed in the appropriate ITS sections.

These changes are designated as administrative because they are editorial and do not result in technical changes to the Technical Specifications.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change I ITS Requirement CTS Requirement 3.0 A.4 CTS LCO 3.0.3 is applicable, "when a Limiting Condition for Operation is not met, except as provided LCO 3.0.3 3.0.3 in the associated ACTION requirements." ITS LCO 3.0.3 expands those applicability requirements so that the requirement is applicable, "when an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS." This changes the CTS to add two new applicability conditions.

ITS LCO 3.0.3 is applicable when the LCO is not met and there is no applicable ACTION to be taken.

This change is acceptable because it is consistent with the current understanding and application of CTS 3.0.3.

ITS LCO 3.0.3 is applicable when directed by the associated ACTIONS. The current Technical Specifications do not contain requirements that direct entry into LCO 3.0.3. The ITS does contain such requirements. Any technical changes related to directing LCO 3.0.3 entry in an ACTION will be discussed in the affected specifications.

This change is acceptable because referencing a new feature in the ITS is an editorial change.

These changes are designated as administrative because they do not result in any technical changes to the Technical Specifications.

3.0 A.5 CTS 3.0.3 states the shutdown time limits in sequential order; i.e., each time limit is measured friom the LCO 3.0.3 3.0.3 completion of the previous step. ITS 3.0.3 states the time limits (Completion Times) from the time the condition was entered. In addition, the MODE titles used in CTS 3.0.3 are replaced with the corresponding MODE numbers in ITS LCO 3.0.3.

These changes are acceptable because the ITS times are the sum of the CTS times (e.g., the ITS Completion Time of 37 hours1.542 days <br />0.22 weeks <br />0.0507 months <br /> to enter MODE 5 is the same as tile sum of the CTS allowance of I hour, 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />, 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />, and 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />.) This changes the CTS presentation only, and tile time allowed to enter each MODE is unchanged. Using MODE numbers instead of the corresponding MODE titles is an editorial preference which results in no change the requirements in the Technical Specifications. These changes are designated as administrative as they implement the editorial conventions used in the ITS without resulting in technical changes to the specifications.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change I ITS Requirement CTS Requirement 3.0 A.6 CTS 3.0.3 states, "Where corrective measures are completed that permit operation under the ACTION LCO 3.0.3 3.0.3 requirement, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation." ITS LCO 3.0.3 states this as, "Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required."

This change is acceptable because the changes to CTS 3.0.3 are editorial. Both the CTS and ITS state that LCO 3.0.3 can be exited if the LCO which lead to the entry into LCO 3.0.3 is met, or if one of the ACTIONS of that LCO is applicable. The CTS requirement also specifies that the time to complete the ACTIONS in the LCO is based on the initial failure to meet the LCO. Reentering the LCO after exiting LCO 3.0.3 does not reset the ACTION statement time requirements. This information is not explicitly stated in ITS LCO 3.0.3 but is true under the multiple condition entry concept of the ITS. This change is designated as administrative because there is no change in the intent or application of the CTS 3.0.3 requirements.

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"Fable A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.7 Unit I CTS 3.0.4 states, "Entry into an OPERATIONAL MODE or other specified applicability LCO 3.0.4 3.0.4 condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION statements." The Unit 2 CTS 3.0.4 is identical, except that the phrase, "unless otherwise excepted" is eliminated from the first sentence and a sentence is added stating, "Exceptions to these requirements are stated in individual specifications." ITS 3.0.4 states, "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made a) When the associated ACTIONS to be entered permit continued operation in the MODE or other specific condition in the Applicability for an unlimited period of time, b) After performance of a risk evaluation, consideration of the results, determination of the acceptability of the MODE change, and establishment of risk management actions, if appropriate, or c) When a specific value or parameter allowance has been approved by the NRC. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." The addition of the a) and b) conditions is described in Discussion of Change (DOC) L. 1.

The following changes are made to CTS 3.0.4:

• Unit I CTS 3.0.4 states, "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted." Unit 2 CTS 3.0.4 is the same, except as described above. ITS LCO 3.0.4 does not contain a discussion of exceptions, but LCO 3.0.4.c states that specific value or parameter allowances, as approved by the NRC, may be used. The list of value or parameter allowances is in the Bases and lists LCO 3.4.16, RCS Specific Activity. This change is acceptable because the provisions in ITS LCO 3.0.4 eliminate the need for specific exceptions in individual specifications. The specific exceptions are eliminated from the specifications and discussed in specific DOCs in those specifications. Elimination of reference to these exceptions is acceptable because it does not technically change the specifications.

This change is designated as administrative because the change is needed to reflect technical changes made in other specifications. The technical aspects of those changes are discussed in other DOCs.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.7

• Unit I and Unit 2 CTS 3,0.4 states, "This provision shall not prevent passage through LCO 3.0.4 3.0.4 (con't) OPERATIONAL states in part, "ThisMODES as required Specification shall to notcomply preventwith ACTION changes statements." ITS LCO 3.0.4 in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS." This change is acceptable because these statements are equivalent. Both are stating that LCO 3.0.4 shall not prevent a unit shutdown required by the Technical Specifications. The ITS wording recognizes that there are conditions in the Applicability that are not MODES, such as "During Core Alterations."

This change is designated as administrative as there is no change in the intent of CTS 3.0.4 and no additional flexibility is granted.

3.0 A.8 ITS LCO 3.0.7 is added to the CTS. LCO 3.0.7 states, "Test Exception LCOs [3.1.8] and 3.4.19 allow LCO 3.0.7 None specified Technical Specification requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is riot desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications."

This change is acceptable because the current Technical Specifications contain test exception specifications which allow certain LCOs to not be met for the purpose of special tests and operations.

However, the CTS does not contain the equivalent of LCO 3.0.7. As a result, there could be confusion regarding which LCOs are applicable during special tests and LCO 3.0.7 was crafted to avoid that possible confusion. LCO 3.0.7 is consistent with the use and application of current test exception Specifications and does riot provide any new restriction or allowance. This change is designated as administrative because it does not technically change the specifications.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. I Description of Change ITS Requirement CTS Requirement 3.0 A.9 CTS 4.0.1 states that Surveillance Requirements shall be applicable during the OPERATIONAL SR 3.0.1 4.0.1 MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. The first sentence of CTS 4.0.3 states that failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the operability requirements for a Limiting Condition for Operation. The last sentence of CTS 4.0.3 states that Surveillance Requirements do not have to be performed on inoperable equipment. ITS SR 3.0.1 states that SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits. Surveillances may be performed by means of any series of sequential, overlapping, or total steps. The changes to the CTS are:

The first sentence of CTS 4.0.1 states that Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. ITS SR 3.0.1 states that SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

This change is acceptable because the requirements are identical. Changes friom Limiting Conditions for Operation to LCO, Surveillance Requirement to SR, and OPERATIONAL MODES to MODES are editorial preferences made to be consistent with the ITS format. This change is designated as administrative because the intent of the requirement is unchanged.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.9

• The first sentence ofCTS 4.0.3 states, "Failure to perform a Surveillance Requirement within SR 3.0.1 4.0.1 the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance (con't) with the operability requirements for a Limiting Condition for Operation." This information is moved to ITS SR 3.0.1 which states, "Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO." This changes the CTS by adding the clarification, "whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance."

This change is acceptable because it is consistent with the current use and application of the Technical Specifications and with previous NRC guidance. This change is designated as administrative because it clarifies the Technical Specifications with no change in intent.

CTS 4.0.3 which states in pail, "Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the operability requirements for a Limiting Condition for Operation." This information is moved from CTS 4.0.3 to ITS SR 3.0.1. ITS SR 3.0.1 states, "Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3."

This change is acceptable and is designated as administrative because moves information within the Technical Specifications with no change in intent. The reference to SR 3.0.3 is editorial and any technical changes resulting from SR 3.0.3 are discussed in another DOCs.

0 CTS 4.0.3 states, in part, "Surveillance requirements do not have to be performed on inoperable equipment." ITS SR 3.0.1 states, "Surveillances do not have to be performed on inoperable equipment or variables outside specified limits." This changes the CTS by including "variables within limits" in recognition that not all Surveillances test equipment, but may test variables such as boron concentration, power distribution factors, temperatures, and pressures. This does not change the current use and application of the statement in CTS 4.0.3.

This change is acceptable and is designated as administrative because moves and clarifies information within the Technical Specifications with no change in intent.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.9 [ITS 3.0.1 states, in part, "Surveillances may be performed by means of any series of sequential, SR 3.0.1 4.0.1 overlapping, and total steps. This changes the CTS by explicitly stating an accepted industry (con't) practice. This does not change the current use and application of the statement in CTS 4.0.1.

This change is acceptable and is designated as administrative because it clarifies information within the Technical Specifications with no change in intent.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.10 CTS 4.0.2 states, "Each Surveillance Requirement shall be performed within the specified surveillance SR 3.0.2 4.0.2 interval with a maximum allowable extension not to exceed 25 percent of the surveillance interval." ITS SR 3.0.2 states, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured firom the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as 'once,' the above interval extension does not apply. If a Completion Time requires periodic performance on a 'once per . . .' basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications." This results in several changes to the CTS.

ITS SR 3.0.2 adds to the CTS, "For Frequencies specified as 'once,' the above interval extension does not apply. This is described in DOC M.2.

ITS SR 3.0.2 adds to the CTS, "ifa Completion Time requires periodic performance on a 'once per . . .' basis, the above Frequency extension applies to each performance after the initial performance." This is described in DOC L.5.

ITS SR 3.0.2 is more specific regarding the start of the Frequency by stating, "as measured from the previous performance or as measured from the time a specified condition of the Frequency is met." This direction is consistent with the current use and application of the Technical Specifications.

This change is acceptable because the ITS presentation has the same intent as the CTS requirement.

ITS SR 3.0.2 adds to the CTS, "Exceptions to this Specification are stated in the individual Specifications."

This change is acceptable because it reflects practices used in the ITS that are not used in the.CTS. Any changes to a specification, by inclusion of such an exception, will be addressed in the affected specification.

The changes are designated as administrative because they reflect presentation and usage rules of the ITS without making technical changes to the Technical Specifications.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No.I Description of Change I ITS Requirement CTS Requirement 3.0 A.I 1 CTS 4.0.3 states, in part, that the time limits of the action statement requirements are applicable at the SR 3.0.3 4.0.3 time it is identified that a surveillance requirement has not been performed. The action statement requirements may be delayed for up to 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the action statement requirements are less than 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS 3.0.3 states that if it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. This adds to the CTS that this delay period is permitted to allow performance of the Surveillance and that if the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. Changes to the time allowed to perform the missed Surveillance are described in DOC L.6.

This change is acceptable because this additional information does not change the current intent or application of CTS 4.0.3. It is understood that CTS 4.0.3 requires that the appropriate ACTIONS be taken if the SR is not performed during the time allowed by CTS 4.0.3 or if the SR is performed but fails. This change is designated as administrative because the added detail is consistent with the current intent and application of the Technical Specifications.

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Table A - Administrative Changes ITS Section 3.0 - LCO and SR Applicability DOC No. Description of Change ITS Requirement CTS Requirement 3.0 A.12 CTS 4.0.4 restricts entry into MODES or other conditions specified in the Applicability unless the SR 3.0.4 4.0.4 applicable SRs have been successfully performed. ITS SR 3.0.4 contains tile same restriction, but adds an allowance that, "This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit."

This changes the CTS in two ways:

ITS SR 3.0.4 adds an allowance that failure to perform a Surveillance will not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

This change is acceptable because it is consistent with the current understanding and application of CTS 4.0.4 and is necessary to avoid a conflict between SR 3.0.4 and other Specifications.

ITS SR 3.0.4 adds an allowance that failure to perform a surveillance will not prevent entry into MODES or other specified conditions in the Applicability "that are part of a shutdown of the unit." ITS SR 3.0.4 is also only applicable in MODES 1, 2, 3 and 4. These changes are addressed in DOC L.4.

This change is designated as administrative because there is no change in the intent of CTS 4.0.4 and no additional flexibility granted.

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Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems Description of Change LI'S RcqtliremelnltI ITS Rccuireinent f CTS C'FS Requirenient Requ]Lirenllenlt DOC No.

None Va otis 3.1.1 A.1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plat specific None IVariouIs Improved Technical Speci fications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) arc made to obtain consistency with NUREG- 143 1, Rev. I, "Standard Technical Specifications-Westinghousc Plants" (ISTFS).

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

I ---li t ,-.--.--- .----

(SDM) requirements in MODES I, 2, 3 aid 4. CTS 1.

1.. and 3.1.1.2 3.1.1 A.2 CTS 3.1.1.1 provides SHUTDOWN MARGIN 3.1.1 3.1.1.2 provides SDM requirements in MODE 5. ITS 3.1.1 provides SI)M requirements in MODE 2 with K,,, < 1.0 and MODES 3, 4, and 5. T'his changes the CTS by combining the SDM requirements for MODE 2 with K 1t1 < 1.0 and MODES 3, 4, and 5. The change in Applicability for MODE I and MODE 2 with K~-> 1.0 are described in DOC A.3.

This change is acceptable because thie requirements have not changed. Combining the specifications is an editorial change. Any technical changes resulting from this combination aicdiscussed in other DOCs.

This change is designated as administrative because it does not result in a technical change to the specification.

3.I.I 3.1.1 A.3 CTS 3.1. 1.1 provides SHUTDOWN MARGIN (SDM) requiremCnts in MODES I, 2, 3 and 4. 3.1.1 3.1.1.1,4 .1.1.1.1.1 ,

3.1.3.6 Surveillance 4.1.1. 1. .b states that when in MODES I and 2 with K,,II - 1.0, SDM is verified hy verifying that the control banks are within the insertion requirements of CTI'S 3.1.3.6, Control Rod Insertion Limits.

ITS 3. 1.1 is Applicable in MODE 2 with K-ff < 1.0 and MODES 3, 4, and 5. ITS 3.1.5 contains the control bank insertion requirements. This changes tei CTS by dividing the SI)M requirements and placing those applicable in MODE 2 with K,jf < 1.0 Ak/k and MODES 3, 4, and 5 in ITS 3. 1.1 and placing those applicable in MODE I and MODE 2 with K,, > 1.0 in the control bank specif'ications.

The purpose of CTS 3. I. I.1 is to ensure that the SDM assumed in the accident analyses is availablc.

When the reactor is critical, SDM is verilied by ensuring that the control rods are above the rod insertion limits. The Applicability Bases to ITS 3. 1.1 states that in MODES I and 2, SDM is ensured by complying with LCO 3.1.5, Shutdown Bank Insertion Limits" and LCO 3.1.6, "Control Bank Insertion Limits." This change is acceptable because the SDM requirements have not changed. Even though CTS 3.1. I. I is applicable in MODES I and 2, the CTS Surveillances state that it is veriflied by meeting the rod insertion limits. The ITS also veriflies SDM in MODES I and 2 via the rod insertion limits. Any changes is to the rod insertion limit requirements will be discussed in I)OCs for those specifications. This change because it does not result in a technical change to the speci'ication. I I I dcsignated as administrative North Anna Power Station Page I of 14 A -3.1

Table A - Administrative Changes ITS Section 3. 1 - Reactivity Control Systems DOC No. Description of Change [TS Requir ernent CT'S Requirement

3. 1.1 A.4 Test The Applicability of CTS 3. 1. 1.1 is MODES I, 2, 3, and 4 with a footnote stating, "See SpecialSpecial None 3.I.I.I Exception 3. 10. 1I." ITS 3.1. I Applicability does not contain the loolnote or aitrelerence to the Test Exception.

The purpose of the footnote relcrence is to alert the reader that a Special T'est Exception exists which may niodi fy tile Applicability of the specification. It is an ITS convention t0 not include these types of Footnotes or cross-references. This change is designated as administrative .is it incorporates an ITS convention with no technical change to the Technical-Specifications.

None Various 3.1.2 A. I In tile conversion of tile North Anna Current Technical Specifications (CTS) to the plant specil'ic Improved Technical Specifications (ITS), certain changes (wording prelcrences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with N URF,G- 143 I, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they (10 not result in technical changes to tile CTS.

3.1.2 4. I I.1..2 3.1.2 A.2 CTS Surveillance 4.1.1.1.2 requires the overall core rcactivity balance be compared to predicted values to demonstrate agreement within +/- IIX Ak/k . ITS LCO 3.1.2 rCquil'cs the measuredCore reactivity to be within +/- I% Ak/k of predicted values. This changes the CTS by replacing the Surveillance requirement with an LCO.

This change is acceptable because the requirements have not changed. Converting the requirement IFron a Surveillance in the SHUTDOWN MARGIN specification to an LCO is consistent with tile ITS lormat and content guidance. Any technical changed resulting fi'or this cnange arc discussed in other l)OCs.

This change is designated as administrative because it does not result in a tc'hnical change to the specification.

None Various 3.1.3 A. I In the conversion of the North Anna Current Technical Specifications (CT'S) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with 1,UR,EG-143 1, Rev. 1, "Standard Technical Speci fications-Westinghouse Plants" (ISTS).

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

North Anna Power StationP Page 2 of'l14 A-3.1

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems DOC No. Description of Change ITS Requirement CTS Requirement below 70% RT7 P and 3.1.3 3.1 .1.4 3.1.3 A.2 CTS 3.1.1.4 states that the maximum MTC upper limit shall be < 0.6 x 10-4 Ak/k/°F

< 0.0 x 10' Ak/k/P/F at or above 70% RTP. ITS 3.1.3 states that the maximum MTC upper limit shall be 0 the CTS by

• 50.6 x 10 Ak/k/IF when < 70% RTP, and

• 0.0 Ak/k/ F when > 701k RTlp. This changes 4

0 designating the maximum MTC upper limit at > 70% RTP as 0.0 Ak/k/ F instead of ().0x 10'- Ak/k/l:.

This change is acceptable because tile requirements have not changed. The llaxillt, mlUpper linlit for MTC when 2! 70% RTP is zero. Presenting tile limit as 0.0 instead of'0.0 x 10 "*is less confusing and]

consistent with how similar valves are presented in tile ITS. This change is designated as administrative because it does not result in a technical change to the specification.

Special Test None 3 I. 1.4 3.1.3 A.3 The Applicability or cTS 3.1 . 1.4 is modified by a footnote, designated "#", stating, "See Exception 3.10.3." ITS 3.1.3 Applicability does not contain the footnote or a relb'rence to the Special Test Exception.

may The purpose of the frootnote reference is to alert the reader that a Special Test Exception exists which modify the Applicability of the specification. It is an ITS convention to not include these types Of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the Technical Specifications.

I I iA 3.1.3 3. 1. I1.4 3.1.3 A.4 CTS 3. I. 1.4 refers to the Beginning of Cycle (BOC) MTC limit and the lEnd of Cycle (EOC) MTC limit.

ITS 3.1.3 refers to thesc values as the upper MTC limit and lower MTC Itnii, respecCtIrcly.

This change is acceptable because the requirements have not changed. The BOC MTC value is the most positive, upper limit and the EOC MTC value is the most negative, lower limit. The terminology used in the ITS is an editorial preference selected folr consistency with that used in NUREG-143 1. This change is designated as administrative as it incorporates an ITS convention with no technical change to the Technical Specifications.

I North Anna Power Station Page 3 of'14 A -3.1

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems ITReuem t CTI eurmn DOCSNo. Description of Change ITS Requirerment jTS RZ/cquiiena.cnt

- .- 1 A , ;, - I 3.1.3, Aclion A 3.I,1 .1. , Action a. I 3.1.3 A.5 CTS 3. I. 1.4, Action a. I, states that if the MTC is more positive than tihe BOC (c.g., upper) limit, control ITS rod withdrawal limits mtst be imposed within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or be in HOT STANDBY within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />.

control rod withdrawal 3.1.3, ACTION A, states that with the MTC not within the upper limit, establish limits with 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or be in MODE 2 withiKn < 1.0 within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />. This changes the CTS by requiring the plant to be in MODE 2 with Knff < 1.0 instead of HOTF SHUTDOWN (i.e.; MODE 3).

LCO This change is acceptable because the requirements have not changed. Inl accordance with CTS are only required to be followed while in the mode of applicability. The CTS upper MTC 3.0. 1, Actions have limit is applicable in MODES I and 2 with Kdi Ž 1.0. Therefore, under the CTS, tlhe unit does not MODE 3 because the applicability of the action ends when in MOI)E 2 with Kir < 1.0. As a to enter This change is designated as result, there is no difference between the CTS and ITS requirements. to tile s ecification.

.. ......... ,, ..... . oe h ,i,,fd ,s ,-otre in l latehnical chanire None 3. I. 1.4, Action a. I 3.1.3 A.6 CTS 3.1.1.4, Action a. I, states that when the MTC is more positive than the BOC limit, control rod withdrawal Iimits must be established. It also states, "these withdrawal limits shall he in addition to tile inscrtion limiits of Specification 3.1.3.6." The I'S does not include this seillcltce.

This change is acceptable becausc tile requireCnents have not changed. 'The 'TIS rereifrncc to or mlodifies Spccilficatioin 3. 1.3.6 is an "information only" statement that neither adds, elininates, convention is to not include these types of statelllemlis. This change is designated requiremenils . The ITS to the speciLication.

as adminIni-sta itive because it docs not result in a technical change Vaiiouls 3.1.4 A.I In tie conversion of the North Anna Current Technical Specifications (CTS, to the plant specific None changes, hIproved Technical Specifications (ITS), certain changes (wording picfiereies, editorial I, Rev. 1, reformatting, revised numbering, etc.) are made to obtain consistency with NURE(i- 143 "Standard Technical Specifications-Westinghlouise Plants" (ISTS).

do not result in These changes are designated as administrative changes and are acceptalle, because they technical ch n*slll to[ li k-1.3. 1.3.

None 3.1.3.1 3.1.4 A.2 The Applicability of CTS 3.1.3.1 is modified by a footnote, designated "*", stating, "See Special Test to the Exceptions 3.10.2 and 3.10.3." ITS 3.1.4 Applicability does not contain the.footnole .or a relference Special Test Exception.

exists which may The purpose of the Footnote reference is to alcrt the reader that a Special e'lst Exception to not include these types of modify the Applicability of the specification. It is an ITS convention as administrative because it does not result in footnotes or cross-references. This change is designated technical changes to the specifications.

FPage 4 of 14 A -3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems DOC No. Description of Change ITS Requirement CTS Requirement None 3. 1.3. 1, Action c. I 3.1.4 A.3 CTS 3.1.3. I, Action c. I, states that with a maximum of one rod misaligned from thie group step counter demand position by more than the alignment requirements, POWER OPERATION may continue "provided that within one hour, the rod is restored to OPERABLE status within the above alignment limits, or other compensatory measures described in tile specification are taken. ITS 3.1.4 does not contain a Required Action stating that the rod must be restored to OPERABLE status within tihe alignment limits.

This change is acceptable because the technical requirements have not changed. Restoration of compliance with tile LCO is always an available Required Action and it is the convention ini the ITS to not state such "restore" options explicitly unless it is thie only action or is required for clarity. This change is designated as administrative because it does not result in technical changes 1o the specifications.

None 3.1.3. I, Action 3.1.4 A.4 CTS 3.1.3. I, Action c.2.c, states that with a maximum of one rod misaligned h'om the group step counter c.2.e demand position by more than the alignment requirements, POWER OPERATION may continue provided that the remainder of the rods in tile group are aligned to within +/- !2 steps of the misaligned rod within I hour while maintaining the thermal power, rod sequence, and insertion limits of Specification 3.1.3.6 during subsequent operation. H'S 3.1.4 does not contain a Required Action stating that tihe remainder of the rods in the group must be aligned with the misaligned rod.

This change is acceptable because the technical requiremenls have not changed. Moving the remainder of the rods in a group to within the LCO limit of the misaligned rod while maintaining compliance with all other rod position requirements is simply restoring compliance with the LCO. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in technical changes to tihe stpeci fications.

drop time of any full length rod determined to exceed tile None 3.1.3.4, Action a 3.1.4 A.5 CTS 3. 1.3.4, Action a, states that with the iod rod drop time limit, restore tile rod drop time to within limit prior to proceeding to MOD)E I or 2. CTS 3.1.3.4 is applicable in MODES I and 2. The ITS does not have a similar requirement.

CTS 4.0.4 and ITS SR 3.0.4 require verification that Surveillances are met prior 0oentering the MODE in which they apply. CTS 4.0.4 and ITS SR 3.0.4 also prohibit entering a MOI)E or condition with the Surveillance not met and while relying on Actions. Therefore, the Action prohibiting entry into MODES I and 2 with the rod drop time requirements not met is redundant to CTS 4.0.4 and ITS SR 3.0.4. This change is acceptable because the technical requirements have not changed. This change is designated as administrative because it does not result in technical changes to the speciflicatiog._;.

North Anna Power Station Page 5 of*14 A -3.1

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems I I. Ci'S Requirement Description of Change ITS Rccquirenmcnt CIS l.e.quireXlient DOC No. "1ii ' I q A *A .t;,...1, than three Nonec .-1. 1 .3.4.q, Actionl1 3.1.4 A.6 CTS 3.1.3.4, Action b, contains actions to follow if the rod drop times are measured with less with less than all three reactor coolant loops in service and provide restrictions on power operation reactor coolant loops in service. The ITS does not contain similar restrictions.

than three reactor This change is acceptable because operation in MODES I and 2 is prohibited with less Therefore, the options in this Action cannot be used. This change is coolant loops in operation.

as a provision of tile CTS which cannot be used is eliminated designated as administrative . l.a and T 1.1 delinition ol 1 4.1 1.. I .1 one hour alter 1.1 definition of 4. 1..La and I 3.1.4 A.7 CTS 4. 1.1. I. I .a and 4. I.1.2.a require verification of SHUTDOWN MARGIN within SD~M 4.1I.1.2.a per 12 hours thercal'ter while tile rod(s) is detection of an inoperable control rod(s) and at least once CTS 3.1.3.1, Action c.2 and Action c.2.b and is inoperable. This duplicates the requirements in also state that if the inoperable control rod is immovable or eliminated. CTS 4. I. I. I.1 .a and 4.1.1.2.a shall be increased by the amount at least equal to the withdrawn untrippable, the SHUTDOWN MARGIN MARGIN" worth of the immovable or untrippable control rod(s). The ITS def(inition of"SHUTDOWN of being fully inserted, the reactivity worth oflthe RCCA must be states, "With any RCCA not capable of SDM." This changes the CTS by eliminating duplicated accounted for in the determination requirements and moving information f'rom the Speci fications to the Idel in1ilIons.

duplicated This change is acceptable because tile requirements have not changed. The elimination of of the specifications. Moving inlformation from requirements does not affect the technical requirements affect the technical requirements of the specifications. This thie specifications to the definitions does not it does not result in technical changes to the change is designated as administrative because specifications.

-t None V arious None V ilI'I(LIS 3.1.5 A.I In the conversion of the North Anna Current Technical Speciflications (CTS) to the plant speciflic changes, Improved Technical Specifications (ITS), certain changes (wording preFe'rences, editorial NUREG- 1431, Rev. I, reformatting, revised numbering, etc.) are made to obtain consistency with "Standard Technical Speci fications-Westinghtouse Plants" (ISTS).

(It) nott result in These changes are designated as administrative changes and are acceptable because they technical changes to the CTS.

I Page 6 of I1d A-3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems ITS Requirement CTS Requirement Description of Change ITS Requirement CTS Requirement DOC No. t .j.J None j.

None ,3.1.3.5}

3.1.5 A.2 The Applicability of CTS 3.1.3.5 is modificd by a footnote, designated "'", stating, "See Special Test to the Exceptions 3.10.2 and 3.10.3." ITS 3.1.5 Applicability does not contain tlh footnote or a refcrencc Special Test Exceptions.

which may The purpose of the footnote relference is to alert the reader that Special Test Exceptions exist modify the Applicability ol the specification. This change is acceptable because it is an I]TS convention as to not include these types of footnotes or cross-let'eretces. This change is designated as administrative it incorporates an ITS convention with no technical change to the Specifications.

i I I -- - I i - - -3.1.51,1Condition1 3.1.5, ConditiBn 3} .1.3.5, Actlion D I 3.1.5 A.3 CTS 3.1.3.5, Action b, stales that power operation may continue with a maximum or one shutdown bank B inserted beyond the insertion limit during surveillance testing pursuant to Specification 4.1.3.1.2 and immovable due to malfunctions in the rod control system. ITS 3.1.5, Condition B, states, in part, "One

< 18 steps below the insertion limit and immovable." This changes the CTS by shutdown bank inserted "during surveillance testing pursuant to Specification 4.1.3.1.2" and eliminating the qualification, immovable "due to malfunctions in the rod control system."

rcquirecd This change is acceptable because the requirements have not changed. The shutdown banks are specification is applicable. The only time the to be fully withdrawn in the MODES in which the

'reedom shutdown banks are inserted while in the applicable MODES is during performance ol 'the rod test, CTS Surveillance 4.1.3.1.2. Therefore, stating that the malfunction otXi1Trrcd during that test is ITS LCO 3.1.5 is not applicable during the rod freedom test, ITS SR 3. 1.4.2, under unnecessary. Further, 3.1.5 Applicability Note. Referencing the SR within the specification would be confusing. The the ITS I1 qualification that a bank is immovable "due to malfunctions in the rod control system" is unnecessary.

rod system. If1 a bank is immovable, it is either due to mechanical binding or a malflunctiot of" the control 3.1.4 would apply. T'his the problem is mechanical binding, the bank would not be trippable and LCO that the Condition can only apply during a malfunction of the rod control system. Therefore. specil'ying is not necessary..This change is bank is immovable due to malfunctions in the rod control system designated as administrative because it does not result in a technical change to the specifications I4 Page 7 of If A -3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3. 1 - Reactivity Control Systems

(.21'S Requirement

[I'S Requirement DOC No. Description of Change ITi~S Requirement CTS R l\equirement I I ~~31 -. 1-l'..".. -

beyond the

.5, ConditioqAn 3.1.5, Condition

-i ,

CTS 3.1.3.5, Action b, states, in part, that "With a maximumn of one shutdown hank inserted 3.1I.3.5, lAction 1) 3.1.5 A.4 B LIMITS RFPORT during surveillance testing insertion limit specified in the CORE OPERATING pursuant to Specification 4.1.3.1.2 and immovable due to mallunctions in the rod control system,

3. each POWER OPERATION may continue provided that: .... 2. the alfected hank is trippable, rod is aligned to within +/- 12 steps or its respective group step counter demand shutdown and control B, states, in part, "One shutdown bank inserted < 18 steps below the position.. " ITS 3.1.5, Condition of I CO 3.1.4." ITS insertion limit and immovable AND each control and shutdown bank within the limits LCO 3.1.4 requires that all shutdown and control banks be OPERABLE (which is defined as "trippable,")

position.

and individual indicated rod positions be within 12 steps of their group step counter demand 3.1.4 for the explicit requirements in the CTS This changes the CTS by substituting a reference to LCO action.

requirements have been This change is acceptable because the requirements have not changed. The CTS have not changed.

rearranged. This change is designated as administrative as the technical requirements 1- 1 None IVariouIs 3.1.6 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific editorial changes, improved Technical Specifications (ITS), certain changes (wording preferenices, Rev. I, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG- 143 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

None II None 3.1.3.6*

by a footnote, designated -4". stating, "Scc Special Test 113.1.6 A.2 I The Applicability of CTS 3.1.3.6 is modi fied a reference to tie Exceptions 3.10.2 and 3.10.3." ITS 3.1.6 Applicability does not contain the Ieootninh or Special Test Exceptions.

may The purpose of the lootnote reference is to alert the reader that Special Test Excptions exist which types of modify the Applicability of the specification. It is an rl'S convention to not include these are footnotes or cross-references as they are not required. The referenced items apply whether or not they a technical cross-referenced. This change is designated as administrative because it does not i tsull in change to the specifications.

Page 8 of 14 A-3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems DOC No. Description of Change ITS Requirement CTS Requirement CTS 3.1.3.6, Action a, states, in part, "With tile control banks inserted beyond the insertion limits, except 3.1.6, 3.1.3.6, Actions a 3.1.6 A.3 tbir surveillance testing pursuant to Specification 4.1.3.1.2" and CTS 3.1.3.6, Action b, stales, in part, Applicability and b "With a maximum of one control bank inserted beyond the insertion limits specified in the CORE Note OPERATING LIMITS REPORT during surveillance testing pursuant to Specification 4.1 1. 1.2." ITS 3.1.6, Applicability Note, states, "The LCO is not applicable while performing SR 3.1.4.2." This changes the CTS by moving the qualifications, "during surveillance testing pursuant to Specification 4.1.3.1.2" to an Applicability Note.

This change is acceptable because the requirements have not changed. The only time the control banks are inserted below the insertion limits while in the applicable MODES is during performance of'the rod freedom test, CTS Surveillance 4.1.3.1.2. Therefore, stating that the malfunction occurred during that test is unnecessary. Further, ITS LCO 3.1.6 is not applicable during the rod frecdonm test, ITS SR 3.1.4.2, under the ITS 3.1.6 Applicability Note. Referencing the SR within the specification would be confusing.

This change is designated as administrative because it does not result in a technical clhange to the specifications.

3.1.6, Condition 3.1.3.6, Action b 3.1.6 A.4 CTS 3.1.3.6, Action b, states, in part, "With a maximum of one control bank inserted beyond the insertion limit specified in the CORE OPERATING LIMITS REPORTlT during surveillance testing C pursuant to Specification 4.1.3.1.2 and immovable due to malfunctions in the rod control system, POWER OPERATION may continue ... " ITS 3.1.6, Condition C, states, in part,."Control bank A, B, or C inserted < 18 steps below the insertion limit and immovable." This changes the CI'S by eliminating a qualification, immovable "due to malfunctions ill the rod control system." O iher changes to CTS 3.1.3.6, Action b, are described in DOC A.3.

This change is acceptable because the requirements have not changed. Th'Ile qualification that a bank is immovable "due to malfunctions in the rod control system" is unnecessary. If a bunk Is immovable, it is either due to mechanical binding or a malfunction of the control rod system. If thi problem is mechanical binding, the bank would not be trippable and LCO 3.1.4 would apply. This Condition can only aj@ply during a malfunction of the rod control system. Therefore, specifying that the bank is immovable due to malfunctions in the rod control system is not necessary. This change is (desig) ,wadas administrative because it does not result in a technical change to the specifications.

North Anna Power Station Page 9 of* 14 A - 3.1

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems Description of Change ITS Requirement CTS Requirement DOC No.

3. 1.6 A.5 CTS 3.1.3.6, Action b, states, in part, that With a maximumn or one control bank inserted beyond the 3.1.6, Condition 3.1.3.6, Action 1) insertion limit specified in the CORE OPERATING LIMITS REPORT during surveillance testing C pursuant to Specification 4.1.3.1.2 and immovable due to malfunctions in the rod control system, POWER OPERATION may continue provided that: .... 2. the affected bank is trippable, 3. each shutdown and control rod is aligned to within +/- 12 steps or its respective group step counter demand position..." ITS 3.1.6, Condition C, states, in part, "One control bank inserted < 1 8 steps below the insertion limit and immovable AND each control and shutdown bank within the limits ol LCO 3.1.4."

ITS LCO 3.1.4 requires that all shutdown and control banks be OPERABLE (which is defined as "trippable,") and individual indicated rod positions be within 12 steps or the'ir group step counter (lemand position. This changes the CTS by substituting a reference to LCO 3.1.4 for the explicit requirements in the CTS action.

This change is acceptable because the rcquircments have not changed. The CTI'S requirements have been rearranged. This change is designated as administrative as the technical requirements have not changed.

limits, 3.1.6, Action 1B.2 3. 1.3.6, Action a. I 3.1.6 A.6 CTS 3.1.3.6, Action a. I and a.2 state that with the control banks inscrted beyond the insertion and a.2 within two hours or reduce thc THERMAl restore the control banks to within thie insertion limits POWER within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> to less than or equal to that fraction of RAT'lEI) 'ITHERMAl 1POWE-R which is allowed by the rod group step counter demand position using the insertion limits specified in the CORE OPERATING LIMITS REPORT. ITS 3.1.6, Action B.2, requires the control hank to be testored to within limits within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />. This changes the CTS by eliminating the explicit statement that compliance with the LCO can be restored in order to exit the Action.

This change is acceptable because the rcquirements have not changed. Reducing THERMAL. POWER so that the insertion limits, which are a function of power, are lowered and the contnrol hank inserted below the insertion limits comes within tile limit is the same as the CTS Action a. I option to "restore the control banks to within the insertion limit." This change is considered administrative bcause the technical requirements have not changed.

to tbe plant spccific None Various 3.1.7 A. I In the conversion of the North Anna Current Technical Specifications (CTS)

Improved Technical Specifications (IrS), certain changes (wording prcferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG- 1431, Rcv. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable becau0se they (10 not result in technical changes to the CTS.

Pagc 10 of 14 A -3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3.1 -Reactivity'ControJ Systems DOC No. Description of Change ITS Requirement CTS Requircment None 3.1.3 I, Action a. 1, 3.1.7 A.2 CTS Action a. , a.2, and b.2 require veriFication that the requirements of CTS 3.1.3. I arc satisfied. CTS a.2, and h.2 3.1.3. I is equivalent to ITS LCO 3.1.4. The ITS does not contain a requirement in ITS 3.1.7 to verily that ITS LCO 3.1.5 is satisfied.

This change is acceptable because the requirements have not changed. CTS specification 3.1.3.1 applies and its Actions must be followed whenever the LCO is not met. Cross-'cfcrencing between specifications is inconsistent with the ITS conventions and does not create, modify, or eliminate requirements.

Specifications apply in their Applicabilities, as described in ITS LCO 3.0.1, whether or not a cross reference exists. Therefore, elimination of the cross-referencing does not result in a technical change to the specifications. This change is designated as administrative because the technical requirements have not changed.

for each 3.1.7 Actions None 3.1.7 A.3 ITS 3.1.7 Actions are modiflicd by a Note which states, "Separate Condition entry is allowed inoperable rod position indicator and each demand position indicator." The CTS doe4 not have a similar Note statement.

This change is acceptable because the technical requircments have not changed. The CTS Actions are worded such that separate condition entry can be made. It is the ITS convention to include a Note like the one modifying the ITS 3.1.7 Actions in this condition. This change is designated as administrative because the technical requirements have not changed.

to he Lip to None 3.1.3.2 Note

• 3.1.7 A.4 CTS 3.1.3.2 contains a Note, designated "*", which allows individual rod position indication

+/- 24 steps, vice +/- 12 steps, for up to one hour per 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> when reactor power is .5 50% RTP. It contains the statement, "If either the one hour period or the +/- 24 step limit is exceeded, immediately declare the individual rod position indicator channel inoperable." The ITS does not contain a similar statement.

This change is acceptable because the technical requirements have not changed. I Ihic rod position is outside the +/- 12 step tolerance given in the CTS LCO and ITS SR 3.1.7.1 and the conditions allowing the wider 24 steps tolerance are not met, and the rod position indication is inoperable. It is unnecessary to state that the rod position indicator must be declared inoperable as the normal Use and Applicability rules require the rod position indicator to be declarcd inoperable if the Surveillance is not met. This change is designated as administrative because it does not result in a technical change to the speci fications.

North Anna Power Station Page II of' 14 A -3.1

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems I ITS Requirement I CIS Requironient DOC No. Description of Change ITS Requirement CTS Reqt~lirenient LCO 3.1.4, I.CO

• I . .i Z . a, I OOtflOtC 3.1.7 A.5 CTS 3.1.3.2.a states "Each individual rod position indicator channel, I per rod, accurate to within +/-

12 LCO7CO3.1.4, .1.3.2.a, footnote 3.1.7 steps* of actual rod position." Footnote "*"states, "Below 50% power each individual rod position a maximum of indicator may be more than +/- 12 steps from its group step counter demand position for one hour in every 24. During this hour, each individual rod position indicator may be no more than +/

24 steps from its demand position." ITS 3.1.7 states, "The Rod Position Indication (RPI) system and the ITS LCO 3.1.4 stales, "All shutdown and Demand Position Indication System shall be OPERABLE."

indicated rod positions shall be within 12 steps of control rods shall be OPERABLE AND individual their group step counter demand position." ITS LCO 3.1.4 is modified by a Note which states, "Whenl THERMAL POWER is <50% RTP, the indicated position of each rod as determined by its individual to I rod position indicator may be within 24 steps from its group step counter demand position for up hour per 24 hours. This NOTE is not applicable For control rods known to be imeater than 12 steps from step counter demand position." This changes the CTS by moving the requircment that the the rod group RPI indicate within 12 or 24 steps of the actual position to LCO 3.1.4.

and the This change is acceptable because the techMical requirements have not chaned. Both the CTS within 12 steps. This change is designated as ITS ,'equires the RPI system to indicate the rod position administrative because it does not result in a technical change to the specifications. -4 None 1 V amio us In the conversion of the North Anna Current Technical Specifications (CTS) to the plhnt spccific None Vatl-iouIS 3.1.8 A. 1 Improved Technical Specifications (ITS), certain changes (wording prelefrues, editorial changes, ev. I reformatting, revised numbering, etc.) are made to obtain consistency wilh NURRECG- 1431, 1 "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because I

they do not resuilt in technical changes to the CTS.

Page 12 of' 14 A -3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3.1 - Reactivity Control Systems Description of Change ITS Requirement CTS Requirement DOc No.

secured in the closed LCO 3.1.8 Note, 3.1.1.3.2 3.1.8 A.2 CTS 3.1.1.3.2 states, "The following valves shall be locked, scaled or otherwise planned boron dilution or makeup activities." ITS LCO 3.1.8 states, "Each valvc SR 3.1.8. I position except during water flow paths shall be secured in the closed position." A Note to the used to isolate primary grade grade water Ilow path isolation valves may be opened under administrative control LCO states, "Primary each valve that isolatcs lor planned boron dilution or makeup activities." ITS SR 3.1.8. I states, "Verifly primary grade water flow paths is locked, sealcd, or otherwise secured in the closed position."

ITS, requirements This change is acceptable because the technical requirements have not changed. In the located in ihc Surveillances, not the LCO. Under that valves be locked, scaled, or otherwise secured are to meet the LCO. Thereffore ,Moving the rcquirement SR 3.0. I, the SRs provide requirements necessary from the LCO to the SR has no effect on tile application of the requirements. 'lMe addition of the plhrase "undcr administrative control" to the LCO Note is consistent with the ITS conventions and does not Note. This change is designatcd as administrative because it does not result change the applicationtoofthethespecifications,.

in a technical change states that with the valves not None 3.1.1.3.2 3.1.8 A.3 CTS 3.1.1.3.2 is applicable in MODES 3, 4, 5 and 6. The CTS Action locked, scaled, or otherwisc secured in the closed not contain Action.CORE Al .I'ERA-.iIONS. ITS 3.1.8 suspend position,(his is applicable in MODES 3, 4, ind] 5 and does ITS 3.9.2 This change is acceptable because CORE ALTERATIONS cannot occur in MOI)ES 3, 4, or 5.

watcr flow path in MODE (' and thaIt speci ication will provides similar requirements on primary grade changes in the Actions in MOI)E 6 will he addressed in address Actions in that MODE. Any technical change is designated as administrative because it divides Actions the DOCs for that specification. This according the applicable MODE with no technical change to the specilications.

(CTS) to the plant specific None Various 3.1.9 A. I In the conversion of the North Anna Current Technical Specifications changcs, Improved Technical Specifications (ITS), certain changes (wording peeie~wi's, editorial Rev. I.

reformatting, revised numbering, etc.) are made to obtain consistency with NURIFG-1431, "Standard Technical Specifications-Westinghousc Plants" (IS'T'S).

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

Page 13 ofl14 A -3.1 North Anna Power Station

Table A - Administrative Changes ITS Section 3.1 - Reactivity-Control.Systems is ITS Rcquiierncnt CTS Requirement DOC No. Description of Changc ITS iRequ~il'enlcCnt CTS RcqtLlir'cIIclt LCO 3.1.9 .5.Wi LCO 3.1.9 3.10t.3 3.1.9 A.2 CTS 3.10.3 states that the limitations of Speci fication 3.1.1 .4, 3.1.3. I, 3.1.3.5, and 3.1.3.6 may be suspended during the peforlmance of PHYSICS TESTS providcd the Reactor Trip Setpoints on the OPERABLE Intermediatc and Power Range Channels are set < 35% and < 25% of RATED THERMAL POWER, respectively. Other requirements are also iniposcd. ITS 3.1.9 states that the requirement of no LCO 3.1.3, LCO 3.1.4, LCO 3.1.5, LCO 3.1.6, and LCO 3.4.2 may be suspended, but contains requirements onihe Intermediate and Power Range Channels. The ITS contains the same requirements on the Intermediate and Power Range Channels in ITS LCO 3.3. I. This changes the CTS by eliminating tile rcquircment that the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are set < 35% and < 25% of RATED THERMAL POWER, respectivwly, from the test exception.

This change is acceptable because the Reactor Trip Setpoints on the OPEIRABI.E Intermediate and Power Range Channels are contained in LCO 3.3. I, RTS Instrumentation. Repeating that requircment in designated administrative as it eliminates a the test exception LCO is unnecessary. This change is repeated Icceuirement from the CTS, resulting in no technical change to the lechnical Specifications. I 3.10.3 I 3.1.9 3.10.3 3.1.9 A.3 CTS 3.10.3 is applicable in MODE 2. ITS 3.1.9 is applicable, "During PHYSICS TESTS initiatcd in 3.1.9 Applicability Appl icabi lily MODE 2."

The purpose of the ITS 3.1.9 Applicability is to ensure that the Actions contained in the spccification are POWER followed. The wording of CTS 3.10.3 appcars to bc contradictory because when THERZMAL exceeds 5%, the test exception specification applicability is exited and the Actions no longer apply.

However, it is clear that tile CTS 3.10.3 Action should be applied if THERMAL POWER excecd 5Y.

and

'The ITS Applicability eliminates this apparent contradiction and allows the test exception Conditions Required Actions to be applied when the LCO is not met. This is consistent with the wording of the CTS the Action. This change is designated as administrative because it clarifies the current wording ol specification with no change in intent. I I Page 14 of'14 A -3.1 North Anna Power Station

"Table A - Administrative Changes ITS Section 3.2 - Power Distribution Limits DOC No. Description of Change ITS Requiremcnt CTS Rcquiremcnt In the conversion of' the North Anna Current Technical Spccifications (CTS) to the plant specific None Various 3.2.1 A. 1 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. I, "Standard Technical Specifications-Westinghiouse Plants" (ISTS).

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

leQ(Z) limit for None 3.2.2 3.2.1 A.2 CTS 3.2.2 provides tile limit for FQ(Z). The LCO provides two equations, which give the power > 50% RTP and power 50% RTP. ITS 3.2. 1 does not contain these equations.

This change is acceptable because the technical requirements have not changed. CTS Surveillance 4.2.2.2 states "FQM(Z) shall be evaluated to determining if FQ(Z) is within limit by: ... c. Satisfying the following relationship" and provides two equations. These equations for FQM(Z) are always more limiting than the equations presented in the LCO. Under CTS 4.0.1 and ITS SR 3.0.1, failure to mcet the SR results in failure to meet the LCO. Therefore, the equations presented in the l.CO are never limiting.

In the ITS, the equations presented in the CTS Surveillance 4.2.2.2 are used to establish the LCO limit.

This change is designated as administrative because it eliminates information from1 the CTS that is not used.

3.2. I 3.2.2 3.2. 1 A.3 CTS 3.2.2 provides a limit For FQ(Z). The Actions for CTS 3.2.2 apply when FQ(Z) excecds its limit.

ITS 3.2.1 states, "FQ(Z), as approximated by FQM(Z), shall be within the limit specified in the COLR."

The ITS Condition is, "EQM(Z) not within limit." ITS SR 3.2. 1. I requires verification that FQM(Z) is within its limit. This changes the CTS by stating tile limited value as 1QM(Z) instead of FQ(Z).

This change is acceptable because the requirements have not changed. CTIS SR 4.2.2.2, which is used to determine if FQ(Z) is within its limit, is written in terms of the mcasured FQ(Z), given as FQM(Z). The value used to determine if FQ(Z) is within its limit in CTS SR 4.2.2.2.c is FQM(Z). Therefore, the ITS use of FQM(Z) is consistent with the CTS limits. This change is designated as administrative because it does not result in a technical change to the specifications.

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Table A - Administrative Changes ITS Section 3.2 - Power Distribution Limits

. . .. - 11-11 .1 1 11 31 11 DOC No. Description of Change I '[TSR~equirement Rlequirement 1

<,5CTS

-1 None 1ý , n ,

3.2.1 A.4 CTS 4.2.2.1 states, "The provisions of Specification 4.0.4 are not applicable." The ITS does not include IN o nec 4.2.2.1 this statement.

of applicability The purpose of a Specification 4.0.4 exception is to allow the plant to cntcr the MODE CTS Specification without performing the required Surveillances. This change is acceptable because the 4.0.4 exception is not used. CTS 4.2.2.2 is modified by a Note which states, "During power escalation, and a the power level may be increased until a power level for extended operation has been achieved provides the allowance to enter power distribution map obtained." Therefore, the CTS Surveillance Note This serves the same purpose as the MODE I and increase power without performing the Surveillance.

because ITS Surveillance 3.2. 1.1 Specification 4.0.4 exception. The ITS does not need the exception because it contains the same Note as the CTS Surveillance. This change is designated as administrative eliminates a CTS provision which is not used. -1 t .

each 3.2.2, Action a 3.2.1 A.5 ITS 3.2. I, Action A.2. 1, A.2.2, and A.2.3 state that the Required Actions must be taken "after 3.2. 1, IRcquLir-cC Actions A.2.f1, FQM(Z) determination." CTS 3.2.2, Action a, (doesnot explicitly state this requirement. A.2.2, A.2.3.

CTS

'This change is acccptable because it (foes not result in a technical change to the specifications. Tihe as administrative is understood to apply after each mcasurement of FQM(Z). This change is designates a technical change to the CTS.

because it does not result in -4 Nonc + Va jotis None VariouIs plant spccilic 3.2.2 A.lI In thle conversion of the North Anna Current Technical Spccifications (CTS) to the Specifications (ITS), certain changes (wording preferences, editorial changes, Improved Technical revised numbering, etc.) are made to obtain consistency with NUREG-1431,. Rev. I, reformatting, "Standard Technical Specifications-Westi rghouse Plants" (ISTf'S).

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

North Anna Power Station Page 2 of 6

Table A - Administrative Changes ITS Section 3.2 - Power Distribution Limits DOC No. Description of Change ITS Requircmcnt CT'S Requiremlcnt 3.2.2 A.2 CTS 3.2.3, Action c states that with FNAH exceeding its limit, identify and correct the cause of the out of 3.2.2, Action A, 3.2.3, Action c limit condition prior to increasing THERMAL POWER above the erduced limit; subsequent POWFR SR 3.2.2. I OPERATION may proceed provided that FNA1H is demonstrated through in-core mapping to be within its limit. ITS 3.2.2, Action A, states that SR 3.2.2. I shall be performcd. SR 3.2.2. I requires measurement of FNAH. This changes the CTS by eliminating the statement that tie cause of the out of limit condition must be identified and corrected prior to increasing power and the stalement that FNAH must be demonstrated through incore mapping.

This change is acceptable because the requircmcnts have not changed. Stating that the cause of" the FNAH liimit violation must be identified and corrected prior to increasing power (i.e., exiting the Action which required power reduction) is unnecessary. Restoration of compliancc with thie LCO is always an option alid allows exiting the Action per ITS 3.0.2. Therefore, it does not have to be stated. Stating that FNAH must be measured with the incore mapping system is unnecessary, as FNAH can only be measured with the incore mapping system. Therefore, stating that FNAH must be measuied (by invoking SR 3.2.2. I) means that the incore mapping system must be used. This change is designated as administrative because it does not result in technical changes to the specifications.;.

3.2.2 A.3 CTS 3.2.3, Action c, states that with FNA1- exceeding its limit, FNAI-I Must he measured prior to 3.2.2, Action A.4 3.2.2, Action c exceeding 50% RTP, 75% RTP, and within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> of exceeding 95% RT!-"[ ITS 3.2.2, Action A.4, contains the same requirements. ITS 3.2.2, Action A.4, is modified by a Note which states, "THERMAL POWER does not have to be reduced to comply with this Required Action." This modifies the CCTS by adding a Note stating that THERMAL POWER does not have to be reduced to comply with the Action.

This change is acceptable because the requirements have not changed. The Note is included in tilhe ]ITS tC make clear that THERMAL POWER does not have to be reduced to perform the Action. For example, itf FNAH exceeded its limit and power was reduced to 60% RTP before FNAH is lenionstrated to be within its limit, under the Note THERMAL IPOWER does not have to be reduced]to less than 50% RTP for a FNAH measurement. FNAH must be measured prior to exceeding 75% RTP and within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> of exceeding 95% RTP. The Condition A is needed because the ITS contains a Note on lITS 3.2.3, Condition A, which states, "Rcquired Actions A.3 and A.4 must be completed whenever Condition A is entered." The Condition A Note does not exist in the CTS and could be construed as requiring THERMAL POWER to be reduced to comply with Action A.4. The Condition A Note is described in DOC M. I. As a result, the Action A.4 Note makes the ITS and CTS actions con.sistent. This change is designated as administrative because it does not result in technical changes to the speccifications.

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Table A - Administrative Changes ITS Section 3.2 - Power Distribution Limits Description of Change ITS Requirement CTS Requiremcnt DOC No.

SR 3.2.2.1 4.2.3.1 3.2.2 A.4 CTS 4.2.3.1 states that FNAH shall be determined to be within its limit by using the moveable incore detectors to obtain a power distribution map. ITS SR 3.2.2. I states that FNAH shall le verified to be within the limits specified in the COLR. This changes the CTS by eliminating Ihe statement that FNAH must be determined by using the moveable incore detector system to obtain a power distribution map.

This change is acceptable because the requirements have not changed. Stating that FNAH must be measured by using the incore mapping system to obtain a power distribution map is unnecessary, as FNAH can only be measured with the incore mapping system to create a power distribution map.

Therefore, eliminating a statement of the method that must be used to measure FNAIH does not change the specifications. This change is designated as administrative because it does not result in technical changes to the specifications.

None 4.2.3.1 3.2.2 A.5 CTS 4.2.3. L.c states, "The provisions of Specification 4.0.4 are nol applicable." The ITS does not include this statement.

The purpose of a Specification 4.0.4 exception is to allow the plant to enter the MODE of applicability without performing the required Surveillances. This change is acceptablC because the CTS Specification 4.0.4 exception is not required in the ITS. CTS 4.2.3.1 is required to be pcrformcd prior to operation above 75% RTP after each fuel loading and once per 31I EFPD. Without the SR 4.0.4 exception, MODE I could not be entered without a measurement because tlie "once per 3 I ElFPD" Frequency would he violated under SR 4.0.4 because Surveillances must be met prior to cntcring the MODIl ol'applicability.

However, under the ITS, the Frequency "Once after each refueling prior to THERMvAl. POWER exceeding 75% RTP AND 31 EFPD thereafter," means that the 31I EI-PD Frequency does not apply until after the 75% RTP measurement is performed. Therefore, the appiicability of the SR is changed and MODE I can be entered without the SR being met. This change is designated as administrative because it does not result in technical changes to the specifications.

None Various 3.2.3 A. I in the conversion of the North Anna Current Technical Specifications (C'FS, to the plant specific Improved Technical Specifications (ITS), certain changes (wording prelferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG- 143 1, Rev. 1, "Standard Technical Spcci lications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable bccauSe they (10d 0ot rCsult in technical changes to the CTS.

North Anna Power Station Page 4 of 6 A -3.2

Table A - Administrative Changes ITS Section 3.2 - Power Distribution Limits DOC No. Description ol'Change ITS Requirement CTS Requirement 3.2.3, Condition 3.2. I, Action a 3.2.3 A.2 CTS 3.2. I, Action a, states that with AFD outside its limit, restore the indicated AFD to within its limit within 15 minutes or reduce THERMAL POWER to less than 50% RTP within 30t minutes. ITS 3.2.3, A Condition A, states that with AFD not within limits, reduce THERMAL POWER to less than 50% within 30 minutes. This changes the CTS by eliminating the action to restore AFD within its limit within 15 minutes.

This change is acceptable because the technical rcquirenmnts havc not chang.cd. If AFD is not restored to within its limit within 15 minutes, no CTS Actions apply except to reduce powcr to less than 50% RTP within 30 minutes. Therefore, the action to restore AFD to within its limit wilhin 15 minutes contains no requirement to take action. Both the CTS and the ITS require power to tie reduced to less than 50% R'I'P within 30 minutes if APD is not restored to within its limit. This change is designated as administrative because it does not result in a technical change to the specifications.

CTS 3.2. 1, Action b, states, "THERMAL POWER shall not be increased ahove 5t}5/( ol RATHL None 3.2. 1, Action 1) 3.2.3 A.3 THERMAL POWER unless the indicated AFD is within the limits specified in the CORE OPERATING LIMITS REPORT." ITS 3.2.3 does not contain a similar requirement. This changes the CTS by eliminating a prohibition in the CTS.

This change is acceptable because the rcquircmcnts have not changed. CTS 3.0.4 and ITS LCO 3.0.4 prohibit entering the MODE of applicability of a specification unless t0Ie requir'ements of the LCO are met. CTS 3.2.1 and ITS 3.2.3 are applicable in MODE I with THERMAL POWER 50%. Therefore, the Use and Application rules in the CTS and thc ITS prohibit exceeding 50% ol RATED THERMAL POWER without tile LCO reqtuirements met. CTS 3.2.1, Action b, is duplicativý of C'I'S 3.0.4 and ITS LCO 3.0.4 and its elimination does not make a technical change to the spcci;fications. This change is I4-designated as administrative because it does not result in a technical change to the speci fications. None V I I ( IOS 3.2.4 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to th phint specific None VariouIs Improved Technical Specifications (ITS), certain changes (wording prcfrenccs; editorial changcs, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG- 143 I, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable bcc,,uw;e they do not rest,(t in tcchnical changes to the CTS. I I North Anna Power Station Page 5 o!f(-. A - 3.2

Table A - Administrative Changes ITS Section 3.2 - Power Distribution Limits

-- i l'l'S Re(fuireroent 1 Cl'S Requirement DOC No. Description of Change ITS Requirement CTS Requirement None 3.2.4, footnote

• 3.2.4 A.2 The Applicability of CTS 3.2.4 is modified by a footnote, designated "*", stating, "See Special Test Exception 3.10.2." ITS 3.2.4 Applicability does not contain the footnote or a referenctu to the Special Test Exception.

which may The purpose of the footnote reference is to alert the reader that a Special Test Exception exists It is an ITS convention to not include these types of modify the Applicability of the specification.

is designated as administrative because it does not result in footnotes or cross-references. This change technical changes to the specifications.

i None ~ ' ')L.I ActA o None 3.2.4~,

a. I.(a)Action 3.2.4 A.3 CTS 3.2.4, Action a.1 .a (Unit I) states that with QPTR > 1.02, within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> reduce the QPTR to within and 2.a once per its limit. CTS 3.2.4, Action a. l(a) and 2.a state thit with QPTR > 1.02, calculate QPTR at least (Utnit I) hour until QPTR is within its limit and within 2 houIIrS reduce QPTR to within its limit. ITS 3.2.4 does not contain a Required Action stating QPTR must be calculated at least once per hour and QPT'IR rust be reduced to within its limit.

This change is acceptable because the technical requircmcnts have not changcd. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is r/equired for clarity. Monitoring a parameter that is outside its limit in order to determine if it has been restored to within its limit is a is necessary action which must occur whether or not it is explicitly required by the TS. This change designated as administrative because it does not result in technical changes to the specifications.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. I, "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.

3.3.1 A.2 The Functional Units required to be OPERABLE for the Reactor Trip System (RTS) 3.3.1 ACTIONS Table 3.3-1 instrumentation are shown in CTS Table 3.3-1. The TFable defines each function with specific Note requirements for Channels, Applicable MODES, and Actions. A Note is added to ITS 3.3.1 Actions, which states, "Separate Condition entry is allowed for each Function." This modifies the CTS by providing a specific allowance to enter each Function separately.

This change is acceptable because it clearly states the current requirement. The CTS considers each function to be separate and independent from the other functions. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.1 A.3 The Action for CTS LCO 3.3.1.1 states, "As shown in Table 3.3-I." ITS LCO 3.3.1 Action A 3.3.1 ACTION A 3.3.1.1 Action states, "One or more Functions with one or more channels inoperable, enter the Condition referenced in Table 3.3.1I-I for the channel(s), immediately."

This change is acceptable because it maintains the CTS requirements in the ITS format. The CTS and ITS refers to a Table for the requirements on each function. Any change to the functional requirements will be discussed by a specific discussion of change. This change modifies the format of the specifications but not the technical requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.4 CTS Surveillance Requirement (SR) 4.3..1I.1 states that each Reactor"Trip System 'Fable 3.3. 1--1 4.3.1.1.1 instrumentation channel shall be demonstrated OPERABLE by the performance of specific test requirements. These include a CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST performed for required MODES of operation and tile specified frequencies shown in Table 4.3-I. ITS TFable 3.3. 1-I includes the surveillance requirement column in addition to the applicable MODES or other specified condition column for each Function. ITS SRs for the CHANNEL CHECK, CHANNEL CALIBRATION, TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), and CHANNEL OPERATIONAL TEST (COT) are listed by numbers and Frequency in the surveillance requirements section for the specification.

This change is acceptable because ITS SRs maintain the CTS requirements for testing of each RTS function. The change is one of format only and any technical change to the requirements for a RTS function is specifically addressed in an individual discussion of change. This change is designated as administrative because it does not result in technical changes to the CTS.

North Anna Power Station Page 2 of 30 A -3.3

Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3,1 A.5 CTS Table 3.3-I provides the requirements for each RTS instrumentation function. The table Table 3.3.1 -1 Table 3.3-1, lists "FUNCTIONAL UNIT", "TOTAL NUMBER OF CHANNELS," "CHANNELS TO TRIP," Table 4.3-1 "MINIMUM CHANNELS OPERABLE," "APPLICABLE MODES," and "ACTIONS" columns.

CTS Table 4.3-1 lists the surveillance requirements for each RTS function including a column labeled "MODES IN WHICH SURVEILLANCE REQUIRED," that specifies the applicability for each function. ITS 'Fable 3.3.1-1 is constructed from the requirements of the CTS Tables with modifications. ITS Table 3.3.1-1 lists the columns as, "FUNCTION," "APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS-," "REQUIRED CHANNELS,"

"CONDITIONS," "SURVEILLANCE REQUIREMENTS," and "ALLOWABLE VALUE." The elimination of "CHANNELS TO TRIP" and "MINIMUM CHANNELS OPERABLE" columns is addressed in DOC LA. 15. This change modifies the CTS Tables by changing the names of columns and deleting the Table 4.3-1 column labeled "MODES IN WHICH SURVEILLANCE REQUIRED."

This change is acceptable because it maintains the technical requirements of the CTS with the conversion to the ITS requirements. The "REQUIRED CHANNELS" column incorporates the channel requirements of the instrumentation function provided by the CTS by the "TOTAL NUMBER OF CHANNELS" column in the ITS. The CTS "ACTIONS" become the ITS "CONDITIONS". The "APPLICABLE MODES" column of CTS is changed to the column labeled, "Applicable MODES or other specified conditions" of the ITS. The column in Table 4.3 I labeled, "MODES IN WHICH SURVEILLANCE REQUIRED," is not required because it is redundant to CTS Table 3.3-I "APPLICABLE MODE" column. A separate DOC addresses any technical change to Tables 3.3-I and 4.3-I requirements if there is a technical difference from the CTS to the ITS. This change is designated as administrative because it does not result in technical changes to the CTS requirements.

3.3.1 A.6 CTS 2.2. I in Table 2.2-I lists various notes for the Allowable Values associated with the None 'Fable 2.2-I operation of the unit until steam generator replacement or 2-loop operation. The steam generators have been replaced and 2-loop operation has never been licensed. Therefore, these notes do not provide any technical requirements and are eliminated.

This change is acceptable because no CTS or ITS RTS function relies upon these notes to ensure proper operation or safety of the plant. With the deletion, no technical requirements of the CTS are changed. This change is designated as administrative because it does not result in technical changes to the CTS.

North Anna Power Station Page 3 of 30 A -3.3

Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.7 CTS Surveillance Requirement 4.3.1.1.2 states, in part, that the RTS Response Time of each trip 3.3.1.16 4.3.1.1.2, function shall be demonstrated to be within its limit at least on per 18 months. The requirement Table 4.3-I specifies that each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-I. A column added to CTS Table 4.3-1 addresses each function, and which the RESPONSE TIME testing requirement is applicable. The RESPONSE TIME requirements reflect the channel requirements contained in the Technical Requirements Manual (TRM) Section 6.2. This does not modify the CTS requirements, but provides clarification. ITS SR 3.3.1.16 requires the verification of RTS RESPONSE TIMES be with limits every 18 months on a STAGGERED TEST BASIS. The ITS definition of STAGGERED TEST BASIS is consistent with the CTS testing Frequency. This changes the CTS by utilizing the ITS definition of STAGGERED TEST BASIS.

This change is acceptable because the requirements for RESPONSE TIMES testing for the RTS channels remain unchanged. ITS definition for STAGGERED TEST BASIS and its application in this requirement do not change the current testing frequency requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.1 A.8 CTS Table 3.3-1 for the RTS Functions does not list Action II to be entered for an inoperable None Table 3.3-I, Action channel. ITS 3.3.1 does not convert the Action to an ITS Condition for any of the required RTS II Functions. This changes the CTS by eliminating Action 11.

This change is acceptable because no CTS or ITS RTS function relies upon the compensatory measures of Action 11 to ensure proper operation or safety of the plant. With the deletion, no technical requirements of the CTS are changed. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.1 A.9 Not used. N/A N/A North Anna Power Station Page 4 of 30 A -3.3

Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.10 CTS Surveillance Requirements (SRs) for the Intermediate Range channels in Table 4.3-1 list a Table 3.3.1-1 Table 4.3-1I, CHANNEL CHECK at a frequency of Q (12) for the MODES 3*, 4*, and 5* applicability. The Table 3.3-1 SRs listed for the Intermediate Range channels with the applicability in MODES I and 2 require the performance of a CHANNEL CHECK at a frequency of each shift (S), a CHANNEL CALIBRATION at a refueling frequency (R (6,13)), and a CHANNEL FUNCTIONAL FEST at the frequency of each startup (S/U (I)) and quarterly (Q (12)). CTS Table 3.3-1 requires the Intermediate Range channels to be OPERABLE in MODES Ifl### and 2. The ### represents "Below the P-10 (Low Setpoint Power Range Neutron Flux Interlock) setpoint" for the applicability. CTS Action 3 must be entered for an inoperable channel. The applicability for Intermediate Range channels is set above the P-6 setpoint in Action 3 Part a. This states, "Below the P-6 setpoint, restore the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above the P-6 setpoint." ITS 3.3.1 Function 4 Intermediate Range Neutron Flux channels lists the applicability as MODES I(b) and 2(c) and Conditions F and G must be entered for inoperable channel(s). Note (b) states, "Below the P-10 (Power Range Neutron Flux) interlocks," and Note (c) requires, "Above the P-6 (Intermediate Range Neutron Flux) interlocks." The surveillance requirements for these channels are SRs 3.3.1.1, 3.3.1.8, and 3.3.1.11. The change of the CTS applicability from MODE 2 to MODE 2(c) in DOC L.27. The change in applicability firom #PH to Note (b) maintains the technical requirement from the CTS to the ITS. This changes the CTS by clarifying the Q (12) CHANNEL FUNCTIONAL TEST for MODES 3*, 4*, and 5*.

The change in applicability is acceptable because the Intermediate Range is only assumed in the safety analyses to be OPERABLE one decade above the overlap with the Source Ranges channels (P-6 setpoint) up to the overlap with the Power Range channels (P-10 setpoint). This is reflected in the CTS Action for the inoperability of a channel when it requires the unit to remain below P-6 until the inoperable channel is returned to OPERABLE status. The performance of the Surveillance Requirements ensure the Intermediate Range channels are maintained OPERABLE for the specified MODES. The deletion of the CHANNEL FUNCTIONAL TEST for MODES 3*, 4*, and 5* is acceptable because the Intermediate Range channels are not required to be OPERABLE in these MODES. ITS SR 3.3.1.8 must be met when the Intermediate Range channels are required to be OPERABLE. The applicability requirement in the CTS is maintained in the ITS by requiring the function's OPERABILITY below the P-10 setpoint. This change is designated as administrative because it corrects CTS Table 4.3-I requirements for performing testing to only include tests during the MODE for which the function is required to be OPERABLE. Therefore, this change is administrative because it does not result in changes to the CTS applicable surveillance requirements.

I _____________________________1_______________. I_____- _________ 1______

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requtirement 3.3.1 A. 11 The CHANNEL FUNCTIONAL TEST (CFT) requirements in CTS Table 4.3-I have been Table 3.3.1 -1 Table 4.3-1 translated in ITS Table 3.3. 1-Ito the CHANNEL OPERATIONAL TEST (COT), TRIP ACTUATION DEVICE OPERATIONAL TEST (TADOT), or ACTUATION LOGIC TEST (ALT). The individual RTS functions will require a COT or TADOT to be performed with the exception of the trip actuation logic, which requires the ALT. Trip actuation devices (bistable or digital) such as manual switches or RCP breakers require a TADOT to be performed. The analog channels such as Pressurizer Pressure require a COT to be performed. Each SR Frequency is replaced with an ITS SR number that corresponds to the required testing at the current frequency.

The technical requirements and frequency of testing for each function will remain unchanged in the ITS requirements, unless noted and addressed by a separate discussion of change.

Tile change is acceptable because tile COT, ALT, and TADOT maintain the technical requirements of the CFT and more accurately describe the required testing for each RTS function. The CTS CFT is divided in two parts, one for the analog channels and the other the bistable channels. The COT requirements provide for the parameter monitoring channels and are consistent with the analog requirements. The COT requires the injection of simulated or actual signal into tile channel as close as practicable to the sensor to verify OPERABILITY of all devices associated with the channel. This includes adjustments, as necessary, of required alarms, interlocks, and trip setpoints within their necessary range and accuracy. The TADOT is defined in a similar manner for the trip actuation device. The TADOT requirements provide for a digital or bistable channel testing requirements of the CTS CFT requirements. The ALT verifies the OPERABILITY of the logic circuits and its required outputs. This type of testing is required in the CTS requirements by the monthly CFT for the Automatic Trip Logic. This change is designated as administrative because it does not result in technical changes to the CTS surveillance requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requiremlent CTS Requirement 3.3.1 A. 12 CTS 3.3.1.1 Actions denoted with a ' in Table 3.3-1 state that the provisions of Specification None Table 3.3-I, Action 3.0.4 are not applicable. The ITS does not contain this exception, but provides the same allowance in the requirements of LCO 3.0.4. This change modifies the CTS by eliminating the specific exception to Specification 3.0.4 and utilizing a generic exception described in LCO 3.0.4.

This change is acceptable because ITS LCO 3.0.4 states when an LCO is not met, entry into the applicable MODE may be made when the associated Actions permit continued operation for an unlimited period of time. The Actions modified by note # allow continued operation for an unlimited period of time. Therefore, eliminating the specific exceptions to CTS 3.0.4 is appropriate because the allowance is addressed in ITS LCO 3.0.4. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.1 A. 13 Not used. N/A N/A 3.3.1 A. 14 CTS surveillance requirement in Table 4.3-1 for the SI input from ESF is stated as M (4). Note Table 3.3.1- I Table 4.3-1 (4) states the following "Manual ESF functional input check every 18 months." The monthly requirement is therefore only required to check the input from ESF on an 18 monthly firequency.

ITS 3.3.1 for function 17, SI input from ESF, requires SR 3.3.1.14 to be performed. This requirement performs a TADOT every 18 months. A Note modifies the requirement that specifies that verification ofsetpoint is not required. This change maintains the technical requirements of the CTS in ITS format.

This change is acceptable because the current requirement is only performed every 18 months to verify the SI input. No setpoint verification is required with the input from ESF and therefore, the Note modifying the SR does not change the technical intent from the CTS requirement. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change I CTS 3.3.1.1 requirements for Functional Unit 6.C, Source Range Neutron Flux Shutdown, are I ITS Requirement I CTS Requirement 3.3.1 A.15 Table 3.3.1 -1 Table 3.3-1 stated in CTS Table 3.3-I. Tile total number of Source Range channels is listed as two, and the minimum channels OPERABLE is listed as one. Note 5 does not require any action unless no channels are OPERABLE. This requirement is applicable in MODES 3, 4, and 5 with the RTBs open. ITS 3.3.1 requirement for the Source Range Neutron Flux, Function 5, is stated in ITS Table 3.3.1-I, and lists the number of required channels as one. The Table lists the applicability or other specified conditions as MODES 3(e), 4(e), and 5(e). Note (e) states, "With the Rod Control System incapable of rod withdrawal. In this condition, source range Function does not provide reactor trip but does provide indication." This change maintains the CTS technical requirements for the number of OPERABLE Source Range channels. The addition of Note (e) is addressed in DOC L.29.

This change is acceptable because the CTS requirements are maintained with the conversion to the ITS format. The ITS number of required Source Range channels is one, which is the same as the CTS requirement. This change is designated as administrative because it does not result in technical changes to the CTS.

I CTS functions for the RTS Interlocks in Table 3.3.-I require Action 17 to be entered for an 3.3.1 A.16 Table 3.3.1 -1 Table 3.3.-I inoperable channel. Action 17 states with less than the Minimum Channels OPERABLE, within one hour verify that the interlocks are in the required state for plant conditions, or apply Specification 3.0.3. ITS function 18, the RTS interlocks list Conditions Q and R to be entered for an inoperable channel. Required Action Q.2 requires the unit to be placed in MODE 3 within 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br />. Required Action R.2 requires the unit to be placed in MODE 2 within 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br />. This changes the CTS from the LCO 3.0.3 statement to specific required actions to be performed.

This change is acceptable because the ITS Required Actions place the unit in a condition within the time allowed by CTS LCO 3.0.3 for each of the functional interlocks. Function P-6 and P-10 are required to be OPERABLE in MODE 2 therefore the required action places the unit into MODE 3 within 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br />. Functions P-7, P-8, and P-13 are required to be OPERABLE in MODE 1, therefore the required action requires the unit to be placed in MODE 2 with 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br />. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.17 CTS Action 7 is required to be performed when the Overtemperature, Overpower, Pressurizer Table 3.3.1-I Table 3.3-1 Action Pressure - High, Steam Generator (SG) Water Level - Low Low, and Steam/Feed Flow 7 Mismatch and Low SG Water Level functions have a required channel become inoperable. Each of the functions is required to be OPERABLE in MODES I and 2. Action 7 states that the inoperable channel must be placed in trip within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />, and if this is not satisfied, the unit must be placed in HOT STANDBY in 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />, HOT SHUTDOWN within the next 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> and COLD SHUTDOWN in the following 30 hours1.25 days <br />0.179 weeks <br />0.0411 months <br />. ITS 3.3.1 for the Overtemperature, Overpower, Pressurizer Pressure - High, Steam Generator (SG) Water Level - Low Low, and SG Water Level Low coincident with Steam Flow /Feed Flow Mismatch requires each function to be OPERABLE in MODES I and 2 and requires Condition E to be entered for an inoperable channel. Condition E states with one inoperable channel, place tile channel in trip within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or be in MODE 3 within 78 hours3.25 days <br />0.464 weeks <br />0.107 months <br />. This changes the CTS by elimination the requirement to place the unit in HOT SHUTDOWN or COLD SHUTDOWN. Tile purpose of this change is appropriately direct the unit to a MODE of operation in which the functions are no longer required by tile safety analysis to perform their safety function.

This change is acceptable because the Condition's Required Actions direct the unit to be placed in an operating mode which the safety functions are no longer assumed by the safety analyses to provide protection. Each function is only required to be OPERABLE in MODES I and 2, therefore, upon entry into HOT STANDBY (MODE 3) each function is no longer required to be OPERABLE. Therefore, eliminating the requirement for the unit to be placed in HOT SHUTDOWN or COLD SHUTDOWN is not required or justified since each function is not required to perform its safety function in MODES 4 or 5. This change is designated as administrative because it does not result in technical changes to tile CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A. 18 CTS 3.3.1.1 Functional Unit 21 B, Reactor Trip Bypass Breakers, states two channels are required 3.3. 1, ACTION P Table 3.3-I Action to be OPERABLE in the applicable MODES, as indicated by a Note *** and Action 13 is I required to be entered, if a channel is inoperable. Note *** states, "With the Reactor Trip Breaker open for surveillance testing in accordance with Specification Table 4.3-1 (item 21 A)."

CTS Action 13 states that with an inoperable bypass breaker, the breaker must be restored to OPERABLE status within one hour, or the testing of the RTB must be terminated and the bypass breaker opened. CTS Action I for the RTB requirements (item 21 A) for an inoperable channel states, "With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirements be in HOT STANDBY within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />." ITS Function 19 states two trains for the Reactor Trip Breakers (h) are required to be OPERABLE in MODES I and 2. Note (h) states, "Includes any reactor trip bypass breakers that are racked in and closed for bypassing an RTB." Condition P is required to be entered for an inoperable RTB train. ITS Required Action P.1I states, "Restore train to OPERABLE status," within one hour. The change to CTS Action I, with the addition of ITS Required Action P.1, is addressed by DOC L. 13.

Required Action P.2 states, "OR Be in MODE 3," within 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br />. This changes the CTS by including the requirement for the bypass breakers into the function for the RTB train and maintains the allowed outage time for an inoperable breaker.

This change is acceptable because including the bypass breaker into the ITS requirement for the RTBs does not change the technical requirements for the bypass breaker. In the CTS and ITS requirements if the bypass breaker becomes inoperable, that breaker must restored to OPERABLE status within one hour if it is relied upon as a substitute for the RTB. If the bypass breaker cannot be returned to OPERABLE the testing or maintenance of the RTB nmust be immediately suspended and the bypass breaker must be placed in the open position. In this condition with the RTB inoperable, the unit is required to be in MODE 3 in the next 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />.

This CTS time allowance is maintained in the ITS. The RTB bypass breaker, in the ITS, is testqd prior to replacing the RTB, therefore, it is unlikely, that the RTB bypass will become inoperable while being substituted for the RTB. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.20 The requirements in CTS Table 3.3-I for the Reactor Trip System low power interlocks list Table 3.3. 1 -I Table 3.3-I function 23.B as P-7, comprised of three channels of P-b10 input or two channels of P- 13 input.

These interlocks are required to be OPERABLE from the surveillance requirement 4.3.1.1.2, associated with CTS 3.3. 1. 1. The P-10 and P-13 interlocks are required to provide a signal at a specific indicated power level, from either the neutron detectors (P- I 0-Power Range Neutron Flux) channels, or power indication of the main turbine (P-13-turbine impulse chamber pressure) channels. The P-10 and P-13 function are required to actuate at a specific setpoint with a tolerance up to the allowable value. The P-7 interlock is derived from P-10 and P-13 functions and is a logic function only. ITS 3.3.1, Table 3.3.1-1, list the Reactor Trip System Interlocks as Function 18, and the P-7 function is Function I8b. Function I18d and I 8e represent the P- 10 and P-13 interlocks. P-10 and P-13 functions are required to actuate and provide its specific interlocks at a specific setpoint with an allowance up to an allowed value. The P-7 Function is not a channel related interlock, but functions on a train related basis; therefore, the channel requirements for P-7 are stated as, "I per train." Because the P-7 interlock is a logic function, there is no setpoint or allowable value limit associated with the function.

This change is acceptable because all technical requirements of the CTS are reflected in the ITS requirements. The requirements of ITS 3.3.1 Function 18 b for P-7 has not modified the CTS requirements, except only in format. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.21 CTS requirements for the Power Range Instrumentation channels are listed in Table 3.3-1. This Table 3.3. 1-1, Table 3.3-1, Table states four total channels are required in MODES I and 2 and Action 211 must be entered for an 3.3.1 ACTION F 2.2-1 inoperable channel. The Limiting Safety System Settings listed in CTS Table 2.2-I specifies for the Power Range Neutron Flux two trip setpoints and allowable values. These are divided into Low and High values. The P-10 interlock in CTS Table 3.3-I describes the requirements for enabling the Power Range Neutron Flux Low setpoint trip below the specified values. The ITS in Table 3.3.1- I states the Power Range Neutron Flux channels, functions 2a and 2b, are to be OPERABLE in two states, High and Low Neutron Flux, with four channels required to be OPERABLE. The functions are applicable in MODES I and 2 for the High and MODES 1(b) and 2 for the Low. For the Power Range Low function Action E is required to be entered.

Action E requires the channel to be placed in trip within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or be in MODE 3 within the next 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />. Note (b) states, "Below the P-10 (Power Range Neutron Flux) setpoint. This change maintains the technical requirements of the CTS as they are translated to the ITS format.

This change is acceptable because all technical requirements of the CTS are maintained by the conversion to the ITS. The ITS presentation of the CTS requirements only modifies the format and does not add or delete any technical requirements. The Power Range functions continue to require four channels to be OPERABLE in MODES I and 2, with the trip setpoints for High and Low Neutron Flux values required above and below the P-10 interlock. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.22 CTS Table 3.3-1 Functions 18.a (Low Auto Stop Oil Pressure) and 18.b (Turbine Stop Valve Table 3.3.lI-1 Note Table 3.3-1 Action Closure) requires the functions to be OPERABLE in MODE I and Action 9 to be entered for anl g,19 inoperable channel. Action 9 requires an inoperable channel be placed in trip within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> o1 ACTION N Note reduce power to less than P-8 setpoint within the next 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />. ITS Table 3.3.1-1 Function 16 Turbine Trip with Low Auto Stop Oil Pressure (16a) and Turbine Stop Valve Closure (16b) lists the applicable MODES as MODE I(g). Note (g) states, "Above the P-8 (Power Range Neutron Flux) interlock." The Table lists Condition N to be entered for an inoperable channel. Condition N states, "One Turbine Trip channel inoperable place the channel in trip," within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />, or "Reduces power < P-8," within 76 hours3.167 days <br />0.452 weeks <br />0.104 months <br />. A Note modifies Condition N that states, " The inoperable channel may be bypassed for up to 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> for surveillance testing of other channels."

The addition of this Note is addressed by DOC L.26. This changes the format of the CTS while maintaining the technical requirements.

This change is acceptable because the technical requirements of the CTS for the required trips from the Turbine Trips are maintained in the ITS. Any technical changes are address in other discussion of changes in this section. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.1 A.23 CTS 3.3.1.1 for Functional Units 19, 21, and 22 lists the test requirements for the Safety Injection SR 3.3.1.4 Table 3.3-1 Note (SI) input to Engineered Safety Features (ESF), Reactor Trip Breakers (RTBs), and Automatic SR 3.3.1.5 (5)

Trip Logic. Each of these functions must be tested monthly. This Frequency is modified by Note (5), which states, "Each train or logic channel shall be tested at least every 62 days on a STAGGERED TEST BASIS (STB)." ITS notation for STB utilizes a definition that states the frequency as 3 1 days on a STB for the RTBs, Function 19, and the Automatic Trip Logic, Function 21. This change maintains the required testing frequency for each required safety function.

This change is acceptable because the testing of the functions will continued to be required at the same frequency. The CTS definition for STB requires all trains or channels to be tested within the allowed time stated by the Frequency. ITS definition for STB states that the Frequency listed is the time for one train or channel to be tested. Under the CTS Frequency for the listed functions, two trains must complete the required testing in 62 days. The ITS Frequency requirement for each of these functions requires a train to be tested every 31 days with both trains completed in 62 days. Therefore, the testing requirements in the CTS and ITS require the same frequency for each function. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.24 Not used. N/A N/A 3.3.1 A.25 CTS Table 4.3-1 Function 18, Turbine Trip, specifies aICHANNEL, FUNCTIONAL TEST with a SR 3.3.1.15 "[able 4.3-I Note frequency of S/U (1). The S/U stands for prior to a reactor startup and Note (1) specifies "If not performed within the previous 31 days." Action 9 must be entered for an inoperable channel.

Action 9 states, "With the number of channels OPERABLE less than the Total Number of Channels OPERABLE requirement, STARTUP and POWER OPERATION may proceed provided the inoperable channel is placed in the tripped condition within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> and the Minimum Channels OPERABLE Requirement is met or reduce power to less than the P-8 setpoint in the next 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />." ITS Table 3.3.1-1 Function 16 Turbine Trip requires SR 3.3.1.15, a TADOT, to be performed. The Frequency for the SR states, "prior to exceeding the P-8 interlock whenever the unit has been in MODE 3, if not performed within the previous 31 days." A Note to the SR states, "Verification of setpoint is not required." This changes the CTS surveillance requirement frequency from startup, if not performed in the previous 3 1 days, to prior to exceeding P-8 setpoint whenever the unit has been in MODE 3, if not performed in the previous 31 days and specifically states that verification of the setpoint is not required.

This change is acceptable because the frequency of the required test continues to be performed in the same time period as required by the CTS. The ITS Frequency is set to be consistent with (he MODE of applicability for the Turbine Trip function. The intent of the CHANNEL FUNCTIONAL TEST in the CTS is to ensure that the turbine trip signal would generate a reactor trip signal. The CTS requirement for a CFT is satisfied by a turbine trip below the setpoint of P

8. This test produces lit annunciators in the main control room that signifies that the turbine trip would occur. This test corresponds to the ITS requirement of a Trip Actuation Device Operational Test (TADOT) without a setpoint verification which verifies that a turbine trip would occur. The ITS TADOT satisfies the technical requirements of the CTS CFT. Therefore, the addition of the ITS Note stating that no verification of setpoint is required is not a change in the requirement, but is provided for clarification. This change is designated as administrative because it does not result in technical changes to the CTS.

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"Fable A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.26 CTS Table 3.3-1 Action I states with the number of channels OPERABLE one less than required 3.3.! ACTION P Table 3.3-1 Action by the Minimum Channels OPERABLE requirement the unit must be shutdown within a given Note 3 1 time. Additionally, Action I states that one channel may be bypassed for up to 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> for concurrent surveillance testing of the RTB and automatic trip logic provided the other channel is OPERABLE. Action I applies to Function 21 Reactor Trip Breakers. ITS Table 3.3.1 I- for function 19 requires Condition P to be entered for an inoperable train. Condition P requires with one RTB train inoperable, it must be restored to OPERABLE status or tile unit must be shutdown. Three Notes modify Condition P. Note 3 states that one RTB train may be bypassed for up to 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> for concurrent surveillance testing of the RTB and automatic trip logic, provided the other channel is OPERABLE. This changes the CTS by placing the allowance of concurrent surveillance testing from ACTION I into a Condition in the ITS format.

This change is acceptable because the allowance of the CTS is maintained in the ITS format.

Four hours of concurrent surveillance testing of the RTB and automatic trip logic are allowed in the CTS requirements. The CTS allowance is justified by WCAP-14333 P-A. This change is designated as administrative because it does not result in a technical change to the CTS.

3.3.1 A.27 CTS Table 3.3-1 Function 20 RCP Breaker Position provides for a reactor trip. The total number 3.3.1 ACTION M Tfable 3.3-1 of channels is one per (RCP) breaker and for an inoperable channel Action 8 must to be entered and requires the inoperable channel to be placed into trip within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or tile unit is required to be placed below P-7 interlock within 78 hours3.25 days <br />0.464 weeks <br />0.107 months <br />. ITS 3.3.1 for RCP Breaker Position specifies the required channels is one per RCP (breaker) and requires Condition M for an inoperable channel. The Condition provides for an inoperable channel that tile channel must be returned to OPERABLE status within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or power must be reduced below P-7 setpoint within 78 hours3.25 days <br />0.464 weeks <br />0.107 months <br />. This changes the CTS by stating the channel requirement for RCP breaker position as one per RCP. The purpose of this change is to provide consistent requirements for the functions as assumed in the safety analyses assumptions.

This change is acceptable because the required Reactor Trip function is specified to be OPERABLE in the applicable MODE with consistent required actions. The Condition is consistent with appropriate Required Action to place tile unit out of the MODE of applicability within Completion Times consistent with other measures that shutdown the unit. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.28 CTS Table 4.3-1 lists the surveillance requirements for the Power Range Neutron Flux SR 3.3.1.3 NOTE I Table 4.3-I Note CHANNEL CALIBRATION as M (3)(6). Note (3) states, "Compare incore to excore axial (3) offset above 15 % RATED THERMAL. POWER (RTP). Adjust channel if absolute difference>

3 percent." The CTS does not specify a CHIANNEL CALIBRATION for the Overtemperature (OT)AT function. ITS Table 3.3.1-1 specifies SR 3.3.1.3 for PRNF and OTAT functions. SR 3.3.1.3 states," Compare results of the incore detector measurements to NIS AFD," every 31 effective full power days (EFPD). Two Notes modify the SR. Note I states, "Adjust NIS channel if absolute difference is > 3 %." Note 2 states, "Not required to be performed until 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> after THERMAL POWER is > 15 % RTP." The addition of Note 2 is addressed by DOC L.9. The change from monthly to every 31 EFPD is addressed by DOC L. 16. This changes the CTS by applying the requirement of a monthly comparison of axial offset of the NIS channel to both the PRNF and OTAT functions. The purpose of CTS monthly CHANNEL CALIBRATION for the PRNF channels is to ensure the indicated Al signal from the Power Range channels for the OTA]'

channels are within 3% of the actual Al.

This change is acceptable because the technical requirements of the CTS are translated into the appropriate ITS requirements. The monthly calibration of the PRNF channels is to ensure the PRNF properly reflect AFD indications and OTAT channels receive appropriate adjustments to change their setpoints for changing plant conditions of Al. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.1 A.29 CTS Table 4.3-1 lists for the Power Range Low Setpoint and Intermediate Range channels a SR 3.3.1.8 Note Table 4.3-I Note quarterly test to be performed (Q (12)). Note (12) states, "Quarterly Surveillance in MODE 3*, (12) 4*, and 5* shall also include verification that Permissives P-6 and P-]0 are in their required state for existing plant conditions by observation of the permissive annunciator window." ITS SR 3.3.1.8 for the Source, Intermediate, and Power Range Neutron Flux Low Setpoint channels require a CHANNEL OPERATIONAL TEST (COT) to be performed every 92 days. A Note modifies the SR that states, "This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions." The movement of the phrase, "by observation of the permissive annunciator window," is addressed by DOC LA.6. The deletion of quarterly surveillance in MODES 3*, 4*, and 5* is addressed by DOC L. 10. This changes the CTS by reformatting the requirement to the ITS SR 3.3.1.8 Note. The purpose of ITS SR 3.3.1.8 Note is to ensure the interlocks P-6 and P-10 are in the proper state for the indicated power level from the appropriate NIS channels.

This change is acceptable because the technical requirements of the CTS are maintained in ITS format. The CTS and ITS require the verification of P-6 and P-I0 interlocks are in the required state for existing plant conditions. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.2 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. I, "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.

3.3.2 A.2 CTS Actions a and b for LCO 3.3.2.1 require the applicable Action requirements of Table 3.3-3 3.3.2 ACTIONS 3.3.2.1 Actions a be entered for an inoperable channel until the required channel is restored to OPERABLE status. NOTE and b ITS LCO 3.3.2 Action A states for an ESFAS function with one or more required channels or trains inoperable, the referenced Condition in Table 3.3.2-1 for the channel(s) or train(s) be entered immediately. The Actions of the ITS are modified by a Note which states, "Separate Condition entry is allowed for each Function."

This change is acceptable because it clearly states the current requirement. The CTS considers each function to be separate and independent from the other functions. This change is designated as administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A.3 CTS Surveillance Requirement 4.3.2.1.1 states that each ESFAS instrumentation channel shall be Table 3.3.2-1 4.3.2.1.1 demonstrated OPERABLE by the performance of specific test requirements. This includes a CHANNEL FUNCTIONAL TEST (CFT) shown in Table 4.3-2. ITS Table 3.3.2-I includes the SRs in a column for each Function. Tile ITS SRs for the TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), ACTUATION LOGIC TEST (ALT), MASTER RELAY TEST (MRT), and CHANNEL OPERATIONAL TEST (COT) are listed by numbers in the Surveillance Requirements section for the specification.

This change is acceptable because the ITS SRs maintain the CTS requirements for testing of each Function. The change is one of format only and any technical change to the requirements for a Function is specifically addressed in an individual discussion of change. The CTS CFT is divided into several parts in the ITS requirements, and becomes the COT for analog devices, i.e.,

pressure or temperature channels, and the TADOT for on/off channels, i.e., manual switches for SI, Containment Spray, and etc. For the logic testing requirements, the ALT and MRT are the appropriate test designations. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 AA4 CTS Functional Units If and 4.d of Table 3.3-3 specifies, "Steam Flow in Two Steam Lines - 3.3.2-I Note (b) Table 3.3-3, Note High Coincident with either Tave - Low Low or Steam Line Pressure - Low," for Safety 811 Injection (SI) and Steam Line Isolation (SLI) are required to be OPERABLE in MODES I, 2, 3##. The notation #9 states, "Trip function may be blocked in this MODE below the P-12 setpoint." ITS Table 3.3.2-I requires the High Steam Flow in Two Steam Lines Coincident with Tave - Low Low function for SI and SLI to be OPERABLE in MODES I, 2 and 3. MODES 2 and 3 are modified by Note (b) that states, "Above the P-12 (Tave-Low Low) interlock." This changes the CTS by providing a clarification for the functional requirements.

This change is acceptable because the ITS requirement states the applicability in the terms of when the function is required to be OPERABLE. CTS stated the requirement in terms of an exception and did not state the specific applicability requirements. The change is designated as administrative change because it does not result in technical changes to the CTS requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A.5 CTS Table 3.3-3 provides the requirements for the ESFAS instrumentation functions. The Table 3.3.2-1 Table 3.3-3 table's columns list the name of the function, total number of channels, channels to trip, minimum number of OPERABLE channels, applicable MODES, and associated Actions. ITS Table 3.3.2-I is constructed from the requirements of CTS Table, but with modifications. The ITS Table requirements list the name of the function, applicable MODES or other specified Conditions, required channels, Conditions, Surveillance Requirements, and Allowable Values.

The "Channels to Trip" and "Minimum Channels OPERABLE" columns are addressed by DOC LA. 12. A separate DOC addresses any technical change to the CTS Table 3.3-3. This changes the CTS Table by requiring different formatted information in the ITS.

This change is acceptable because it maintains the technical requirements of the CTS with the conversion to the ITS. The required channels' column units incorporates the channel requirements of the instrumentation function formerly provided by the CTS column of total number of channels. This requires a function, with the reactor being operated in specific MODES or specific conditions, to have a number of channels OPERABLE. If the number of OPERABLE channels is less than the required, the ITS Condition (formally the CTS Action) must be entered. The addition of specific conditions in the ITS that were in the CTS are made with notes, which specify modifications to Actions or applicability for a function. With these modifications to the table, it is the intent of this change to not modify any technical requirement, but rather to present the information in a more logical manner. Any technical change to a function is addressed by a separate item DOC. Tile change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A.6 CTS Table 3.3-3 for Functional Unit 3, C"ontainment Isolation Phase 'A', states the finction is Table 3.3.2-1 Table 3.3-3 initiated from safety injection automatic actuation logic, in addition to manual initiation. ITS requirement in Table 3.3.2-1 states manual, atutomatic actuation logic and actuation relays, and the safety injection signals provide the Containment Isolation Phase A initiation signal. This rewords the requirement and provides a clarification for the CTS.

This change is acceptable because the CTS requirements are maintained in JTS format. The Containment Phase A Isolation is initiated by the automatic actuation logic and actuation relays and the safety injection signals. The presentation of the requirements in ITS format does not modify the technical requirement of the CTS. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

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"Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTrS Requirement 3.3.2 A.7 CTS requirements for LCO 3.3.2.1 in Table 3.3-3 associated with Functions require various None Table 3.3-3 Actions marked with

• to be entered when a channel becomes inoperable for the functions. The notation

• for the Action states, "The provisions of Specification 3.0.4 are not applicable." This allowance is not needed to be specifically stated for these functions in the ITS format and is eliminated.

This change is acceptable because ITS LCO 3.0.4 states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when tile associated Actions to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Tile Required Actions of ITS LCO 3.3.2 for the ESFAS Functions conform to this requirement, and therefore the allowance is provided in the ITS without requiring a specific exception. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A.8 CTS Table 4.3-2 lists in the last column the MODES in which the associated Surveillance Table 3.3.2-1 Table 4.3-2 Requirements must be performed. CTS Tables 3.3-3 and 4.3-2 are combined to form ITS Table 3.3.2-I. With the combining of these Tables, the 'MODES in which surveillance required' column of 4.3-2 is redundant to the requirements listed for the functions in Table 3.3-3

'Applicable MODES' column and is labeled as, 'Applicable MODES or other specified conditions' in ITS Table 3.3.2-I.

This change is acceptable because the technical requirements for each listed function is maintained with the conversion of the CTS to the ITS requirements. Any changes to the CTS Applicable MODES would apply to the Surveillance Requirements, and would be discussed in a separate discussion of change The change is designated as administrative change because it does not result in technical change to the CTS requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A.9 CTS Surveillance Requirement 4.3.2.1.2 requires the ENGINEERED SAFETY FEATURES SR 3.3.2.9 4.3.2.1.2 RESPONSE TIME test on each ESFAS function be performed at least once per 18 months. The requirement states, "Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that both logic trains are tested at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No. of Channels" Column of Table 3.3-3." ITS SR 3.3.2.9 requires the verification that ESFAS RESPONSE TIMES are within limits every 18 months on a STAGGERED TEST BASIS. The ITS definition of STAGGERED TEST bASIS is consistent with the CTS testing Frequency. This changes the CTS by utilizing the ITS definition of STAGGERED TEST BASIS..

This change is acceptable the requirements for ESFAS RESPONSE TIME testing for the ESFAS channels remain unchanged. ITS definition for STAGGERED TEST BASIS and its application in this requirement do not change the current testing frequency requirements. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A. 10 CTS ESFAS system interlocks P- Il and P-12 are required to be OPERABLE in MODES 1, 2, 3.3.2 ACTION J Table 3.3-3 Action and 3. If a channel becomes inoperable, Action 22 must be entered. The Action requires with 22 less that the Minimum Channels within I hour determine, "that the interlock is in its required state for the existing plant condition or apply Specification 3.0.3." ITS requirements for the ESFAS interlocks P-I I and P-12 require the functions to be OPERABLE in MODES 1, 2, and 3.

If a channel becomes inoperable Action J must be entered. The Action requires a verification of the interlocks are in their required state for plant conditions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in MODE 3 within 7 hours0.292 days <br />0.0417 weeks <br />0.00959 months <br /> and MODE 4 within 13 hours0.542 days <br />0.0774 weeks <br />0.0178 months <br />. This changes the CTS by specifically stating shutdown requirements in specified time requirements in the Action.

This change is acceptable because the Required Actions and Completion Times are the same as the CTS requirements. CTS LCO 3.0.3 allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 6 additional hours to reach HOT STANDBY and 6 more hours to reach HOT SHUTDOWN. This change maintains the technical requirements of the CTS in the ITS format. The change is designated as administrative because the technical requirements remain unchanged.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A.]I 1 CTS Functional Unit Ld of Table 3.3-3 specifies Pressurizer Pressure -- Low-Low shall be Table 3.3.2-I Note Table 3.3-3 Note #

OPERABLE in MODES I, 2, 3#. The notation # states the function may be blocked in MODE 3 (a) below P-I I setpoint. ITS Table 3.3.2-1 requires Pressurizer Pressure- Low Low function to be OPERABLE in MODES 1,2, and 3(a). Note (a) states, "Above the P-I I setpoint." This changes the CTS by providing a clarification for the functional requirements.

This change is acceptable because the ITS requirement states the applicability in the terms of when the function is required to be OPERABLE. CTS stated the requirement in terms of an exception and did not state the specific applicability requirements. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A. 12 CTS Table 4.3-2 notation (1) is associated with the manual initiation switches for Safety SR 3.3.2.7 NOTE Table 4.3-2 Injection, Containment Spray, Containment Isolation (Phase A and B), Steam Line Isolation, and notatin (1) the start of the AFW pumps. The notation requires that each manual actuation switch be tested to actuate the required function at least once per 18 months during shutdown. In ITS Table 3.3.2-1I, for each of the listed functions, SR 3.3.2.7 states that a TADOT must be performed at a frequency of eighteen months. A Note to SR 3.3.2.7 specifies, "Verification of setpoint not required for manual initiation functions." The deletion of the performance of the surveillance requirement during shutdown is addressed by DOC L.4. This changes the CTS by replacing the wording of testing each required switch with the ITS requirement of performing a TADOT for the required functions and adds the Note to not require verification of setpoint.

This change is acceptable because the required testing maintains the CTS requirements in the ITS format. The CHANNEL FUNCTIONAL TESTING of the manual switches to perform their function continues to be required in the ITS TADOT. The addition of the Note to the SR simply states that setpoints for manual activation do not require tile verification ofsetpoints. A manual activation either provides a function or not. Ifthe function is initiated by the manual actuation, the function is satisfied, and therefore, the setpoint verification is not necessary for any manual initiation. The change is designated as anladministrative change because it does not result inl technical change to the CTS requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A. 13 CTS Table 4.3-2 lists the requirements for the ESFAS Interlocks P-I I and P-12. A CHANNEL SR 3.3.2.8 Table 4.3-2 FUNCTIONAL TEST (CFT) and a CHANNEL CALIBRATION must be performed for each interlock on a refueling frequency (R). ITS SRs for the P-I I and P-12 interlocks require SR 3.3.2.8 (CHANNEL CALIBRATION) to be performed every 18 months. This changes the CTS by eliminating the CHANNEL FUNCTIONAL TEST requirements.

This change is acceptable because the ITS requirements maintains the CTS technical requirements. The CHANNEL CALIBRATION requirements contain all the requirements of the CFT and therefore, performing a CHANNEL CALIBRATION will satisfy all of the technical requirements of the CFT. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A. 14 CTS requirements in Table 3.3-3 for ESFAS Function 3.b.l1), Containment Isolation Phase B Table 3.3.2-1 TFable 3.3-3 manual, state that 2 sets, 2 switches/set are the total number of channels required. This function is required to be OPERABLE in MODES I, 2, 3, and 4 with Action 18 to be entered for an inoperable channel. ITS in Table 3.3.2-I Function 3.b.1, Containment Isolation Phase B on Manual Initiation, states, "Refer to Function 2.a (Containment Spray - Manual Initiation) for all functions and requirements." This changes the CTS by deleting the specific requirements for the Containment Isolation Phase B manual requirements and referring the function to the Containment Spray Manual Initiation for the specific requirements.

This change is acceptable because there are no separate switches to initiate the Phase B Containment Isolation function. The Containment Spray manual switches are the only switches that initiate the Phase B Containment Isolation signal. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A.15 CTS requirements in Table 3.3-3 for ESFAS Function 3.b.3, Containment Isolation Phase B Table 3.3.2-1 Table 3.3-3 Containment Pressure High-High state that 4 channels are required. The function is required to be OPERABLE in MODES 1,2,3, and 4 with Action 16* to be entered for an inoperable channel.

CTS requirements in Table 3.3-3 for ESFAS Function 2.c, Containment Spray on Containment Pressure High-High state that 4 channels are required. The function is required to be OPERABLE in MODES 1,2,3, and 4 with Action 16* to be entered for an inoperable channel.

ITS in Table 3.3.2-I Function 3.b.3, Containment Isolation Phase B on Containment Pressure High High, states, "Refer to Function 2.c (Containment Spray - Containment Pressure High High) for all functions and requirements." This changes the CTS by deleting the specific requirements for the Containment Isolation Phase B on Containment Pressure High High requirements and referring the function to the Containment Spray Containment Pressure H igh High for the specific requirements.

This change is acceptable because there are no separate signals fiom Containment Pressure channels to initiate the Phase B Containment Isolation function. The Containment Spray Containment Pressure High High signal is the same signal that initiates the Phase B Containment Isolation signal. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A. 16 CTS Surveillance Requirement 4.3.2.1.2 states that the Engineered Safety Feature Response None 4.3.2.1.2 Time of each ESFAS function shall be demonstrated to be within the limit at least once per 18 months. Under the CTS, it is recognized that a Response Time Test is not required for the manual initiation and automatic actuation logic portions of the ESFAS functions. These portions of the function are tested by other Surveillances. ITS 3.3.2 replaces the general statement in CTS 4.3.2.1.2 with specific testing requirements for each function. For those portions of the ESFAS functions that a Response Time Test is appropriate, ITS SR 3.3.2.9 is required. This changes the CTS by explicitly recognizing those portions of ESFAS functions for which a Response Time Test is not required.

This change is acceptable because it explicitly states the portions of ESFAS functions for which a Response Time Test is required. The ITS and CTS Response Time Testing requirements are the same. The change is designated as administrative because it does not result in technical change to the CTS requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.2 A. 18 CTS Table 3.3-3 allows one channel of certain functional units to be bypassed for up to 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> 3.3.2 Required 'Fable 3.3-3 to perform surveillance testing. A Note for ITS 3.3.2 Required Action C states, "One train may Action C Note be bypassed for up to 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> for surveillance testing provided the other train is OPERABLE."

This rewords the CTS by specifically stating that surveillance testing can only be performed when the remaining train is OPERABLE. The purpose of the ITS Note phrase, "provided the other train is OPERABLE," is to remind the SR performer that there are only two trains of Automatic Actuation Logic and Actuation Relays for SI, Containment Spray, and Containment Isolation. With one train inoperable, testing the other train would disable the safety function.

This change is acceptable because it restates the CTS requirements in more clearly defined terms.

The CTS requirements are maintained in ITS format. Tile change is designated as an administrative change because it does not result in technical change to the CTS requirements.

3.3.2 A. 19 CTS Table 4.3 - 2 Functional Units I.b, 2.b, 3.b. 1, 3.b.2, 4.b, 5.b, and 6.b 1, the Automatic SR 3.3.2.2, Table 4.3 - 2 Note Actuation Logic for SI, Containment Spray, Containment Isolation (Phases A and B), Steam Line SR 3.3.2.3 (2)

Isolation, Turbine Trip and Feedwater Isolation, AFW pump, and the Automatic Actuation Logic and Actuation Relays for Steam Line Isolation require a monthly CHANNEL FUNCTIONAL TEST to be performed. The surveillance firequency is modified by Note (2) that states, "Each train or logic channel shall be functionally tested at least every other 3 1 days .. ." ITS Surveillance Requirements (SR) for the Automatic Actuation Logic and Actuation Relays for SI, Containment Spray, Containment Isolation (Phase A Isolation and Phase B Isolation), Steam Line Isolation, Turbine Trip and Feedwater Isolation, and AFW, require SRs 3.3.2.2 and 3.3.2.3 to be performed. ITS SR 3.3.2.2 requires the performance of an ACTUATION LOGIC TEST (ALT) and ITS SR 3,3.2.3 states that a MASTER RELAY TEST (MRT) must be performed. The Frequency of both ITS SRs is "31 days on a STAGGERED TEST BASIS." This changes the CTS SR Frequency from "every other 31 days" to the ITS requirement of"31 days invoking STAGGERED TEST BASIS" definition, while the CTS testing requirements are expressed in ITS terms of ALT and MRT, The purpose of the phrase "on a STAGGERED TEST BASIS" is to provide standard means of expressing the testing requirement frequency. The testing requirements of ALT and MRT continue to require the appropriate testing requirements for each safety function's Automatic Actuation Logic and Actuation Relays. This change is acceptable because the CTS testing requirements and frequencies are maintained in the ITS format. The change is designated as administrative change because it does not result in technical changes to the CTS requirements.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.3 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

3.3.3 A.2 CTS LCO 3.3.3.6 states the PAM instrumentation channels listed in Table 3.3- 10 shall ',e 3.3.3 ACTIONS 3.3.3.6 OPERABLE. ITS 3.3.3 states the PAM instrumentation for each function shall be OPERABLE. Note Each Function is listed in Table 3.3.3 - 1. A Note to the Actions states, "Separate Condition entry is allowed for each Function." This changes the CTS by adding a Note to the CTS requirements. The purpose for adding the Note to the Actions is to provide a clear understanding that each function is independent. Each function requires a parameter to be available for the operator to monitor during post accident conditions. In addition, this changes the format for initiating Completion Time clocks.

This change is acceptable because tile CTS is constructed to provide for separate entry into the Actions for each PAM function and the addition of the ITS Note clarifies the requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

3.3.3 A.3 CTS SR 4.3.3.6 in Table 4.3-7 requires each PAM instrumentation channel to be demonstrated SR 3.3.3.2 Note 4.3.3.6 OPERABLE by the performance of a CHANNEL CALIBRATION on a refueling frequency.

ITS SR 3.3.3.2 requires a C1HANNEL CALIBRATION be performed on each PAM instrumentation function shown in Table 3.3.3-1, at a Frequency of eighteen months. A Note modifies the SR that excludes neutron detectors from CHANNEL CALIBRATIONS. This changes the CTS by clarifying an existing allowance.

The purpose of the Note is to exclude neutron detectors from the requirement because of the impracticality of this test on this device type. CTS requirement 4.3.1.1.1 states each reactor trip instrumentation channel will have a C14ANNEL CALIBRATION performed in accordance with Table 4.3-1. Note (6) to the table applies to all nuclear instrumentation required for power operation. This states, "Neutron detectors may be excluded from CHANNEL CALIBRATION."

the CTS of Therefore, theofinclusion requirements forthe Note is acceptable because this requirement parallels the calibration of all other nuclear instrumentation channels. This change is designated as administrative because it does not result in a technical change to the CTS.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.3 A.4 CTS 3.3.3.6 Table 3.3-10 lists in two columns the requirements for accident monitoring Table 3.3.3-1 Table 3.3-10 instrumentation. These columns are labeled as, "Total No. of Channels" and "Minimum Channels OPERABLE." The CTS provides Actions stated as part of the LCO. ITS 3.3.3 Table 3.3.3-I states the requirements for PAM Instrumentation in one column labeled "Required Channels." This changes the CTS by only including thee minimum channels OPERABLE column.

The change is acceptable because the technical requirements of the CTS columns and Actions are incorporated in the ITS technical requirements. Any technical changes for the individual functions are addressed by other discussion of changes. This change is designated as administrative because it does not result in a technical change to tile CTS.

3.3.3 A.5 CTS 3.3.3.6 Table 3.3-10 lists the functions of Reactor Vessel Coolant Level Monitor, In Core Table 3.3.3-1 Table 3.3-10 Thermocouples, and Reactor Coolant System Subcooling Margin Monitor as required accident monitoring instruments. ITS 3.3.3 Table 3.3.3-1 groups these instruments under the Inadequate Core Cooling Monitor as subsystems. This changes the CTS by the regrouping PAM functions.

This change is acceptable because the technical requirements remain unchanged. The incorporation of the functions under the system of inadequate core cooling does not change the instrument requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

3.3.4 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to tile plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

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Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.4 A.2 CTS 3.3.3.5 requirements for the auxiliary shutdown panel monitoring instrumentation channels 3.3.4 ACTIONS 3.3.3.5 state that the functions in Table 3.3-9 shall be OPERABLE. ITS LCO 3.3.4 provides a Note to NOTE the Actions that states, "Separate Condition entry is allowed for each Function." This changes the CTS by stating that separate Condition entry for each function is allowed. In addition, this changes the format for initiating Completion Time clocks.

The purpose of the ITS Note is to state that individual functions may enter the conditional requirements separately and that each function has an independent Completion Time from each of the other instrumentation functions. This change is acceptable because it is consistent with the application of the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

3.3.5 A.I1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. I, "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.

3.3.5 A.2 CTS LCO 3.3.2.1, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, states LCO 3.3.5 3.3.2.1 Actiii- b the trip setpoints for the features are required to be set consistent with the values listed in the Trip Setpoint column of Table 3.3-4. CTS Action b states, "With an ESFAS instrumentation channel inoperable, take the ACTION shown in Table 3.3-3." ITS LCO 3.3.5, "Loss of Power (LOP)

Emergency Diesel Generator (EDG) Start Instrumentation," requires specific channels per bus for the undervoltage and degraded voltage functions to be OPERABLE. This change maintains the CTS requirements for the loss of power finction in the ITS format.

This change is acceptable because the technical requirements for the LOP EDG function are maintained with the change in format. The LOP EDG function continue to start the EDG on a loss of voltage or degraded voltage within the assumed time of the safety analyses. This change is designated as administrative because it does not result in a technical change to the CTS.

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"Fable A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.5 A.3 CTS LCO 3.3.2.1 requires the ESFAS instrumentation channels to be OPERABLE in accordance 3.3.5 ACTIONS T[able 3.3-3 with the requirements in Table 3.3-3. If a required channel becomes inoperable, the table NOTE provides the appropriate required Actions to be performed for each required function. ITS LCO 3.3.5 requires three channels per bus for the loss of voltage and degraded voltage functions to be OPERABLE. The ITS Actions provide the appropriate Conditions, Required Actions, and Completion Times for the LOP EDG function. A Note modifies the Actions that states, "Separate Condition entry is allowed for each function." This changes the CTS by specifically stating that each Condition may be entered for each function separately and follow a separate Completion Time resulting in no technical changes to CTS Action requirements.

This change is acceptable because the requirements of the CTS are maintained in the ITS format.

The functional requirements can affect each emergency bus separately, therefore the loss of voltage and degraded voltage function may be treated as independent. This change is designated as administrative because it does not result in a technical change to the CTS.

3.3.5 A.4 SR3.3.5.3 4.3.2.1.2 CTS Surveillance Requirement 4.3.2.1.2 requires the ENGINEERED SAFETY FEATURES RESPONSE TIME test on each ESFAS function at least once per 18 months. The requirement states, "Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that both logic trains are tested at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No. of Channels" Column of Table 3.3-3." ITS SR 3.3.5.3 requires the verification of ESFAS RESPONSE TIMES are within limits every 18 months on a STAGGERED TEST BASIS. The ITS definition of STAGGERED TEST BASIS is consistent with the CTS testing Frequency. This changes the CTS by utilizing the ITS definition of STAGGERED TEST BASIS. This also changes the CTS by removing the references to logic train testing as the LOP EDG start instrumentation does not have logic trains.

This change is acceptable because the requirements for ESFAS RESPONSE TIME testing for the ESFAS channels remain unchanged. ITS definition for STAGGERED TEST BASIS and its application in this requirement do not change the current testing firequency requirements. The ITS separates the LOP EDG start instrumentation, which does not have logic trains, from other ESFAS functions. Therefore, the CTS reference to logic trains is not required in ITS 3.3.5. This change is designated as administrative because it does not result in technical changes to the CTS.

North Anna Power Station Page 29 of 30 A -3.3

Table A - Administrative Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement 3.3.5 A.5 CTS Table 4.3-2 lists for Functional Unit 7, Loss of Power 4.16KV Emergency Bus requirements SR 3.3.5.1 NOTE Table 4.3-2 for a quarterly CHANNEL FUNCTIONAL TEST for the Loss of Voltage and Degraded Voltage functions. The CHANNEL FUNCTIONAL TEST does not require a verification of relay setpoints for the Loss of Voltage and Degraded Voltage functions. ITS SR 3.3.5.1 states that a TADOT must be performed every 92 days. The SR is modified by a Note that states, "Verification of setpoint is not required." This changes the CTS by specifically stating that setpoint verification is not required for the required quarterly testing.

This change is acceptable because the verification of the relay setpoints require elaborate bench calibration and this is performed during the CHANNEL CALIBRATION. The CHANNEL CALIBRATION is performed every 18 months. The verification of relay setpoints has been consistently within the limits of the 18-month requirements. Therefore, the addition of the Note to the SR does not modify the CTS and is provided to clarify the requirement. The change is designated as administrative change because it does not result in technical change to the CTS requirements.

North Anna Power Station Page 30 of 30 A -3.3

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

IFS Requirement UPS Requirement Dcscription of Change ITS RequirementI CTS Rc(]uir'cnmn~t DOC No. Various to the plani specific 3.4.1 A.I In the conversion of the North Anna Current Technical Specifications (CTS) Var1iouIs IVarious editorial Improved Technical Specifications (ITS), certain changes (wording preferences, conistecicy.with NUREG changes, reformatting, revised numbcring, etc.) are made to obtain Technical Specifications-Westinghouse Plants" (ISTS).

1431, Rev. I, "Standard acceptable because they do not These changes are designated as administrative changes and are result in technical changes to the CTS. i- i 2 loop operation with loop Table 3.2-1I 3.4.1 A.2 CTS 3.2.5, Tablc 3.2-I1, contains placcholders for DNB limits during None with isolated loop stop yalves closed. A footnote, stop valves open and during 2 loop operation be dependent on NRC approval of ICCS evaluation for designated **, states that values will not contain a similar place holder. This changes(l theCTS by these conditions. Tie ITS does holders for I)NB limits applying to IwO-loop operation.

eliminating references and place the ITS and the CTS This change is acceptable because the requirements have not changed. Both (MOI)t I 1. This change is require all three loops in operation in the applicable MODES which cannot be used.

designated as administrative because it eliminates an option in the CTS +/- Various t Various (CTS) to tihe plant specific VariouIs VariouIs 3.4.2 A.I In the conversion of the North Anna Current Technical Specificatiolrs preferences, editorial Improved lTechnical Specifications (ITS), certain changes (wording obtain consistency with NUREG changes, reformatting, revised numbering, etc.) arc made to Plants" (ISTS).

1431, Rev. 1, "Standard Technical Specifications-Westinghouse acceptabl, tbecause they do not These changes are designated as administrative changes and are result in technical changes to the CTS. -I 34.2 Action A t 3.1.1.5 loop temperature, Tavg, 3.4.2 A.2 CTS 3.1 . 1.5 Action states, "With a Reactor Coolant System operating 3.4.2 Action A 3.1.1.5 15 minutes or bt' in HOT STANDBY less than 54 1'F, restore Tavg to within its limit within

'avg in one or more RCS loops within the next 15 minutes." ITS 3.4.2, Action A, states that with not within limit, be in MODE 2 with Kcff < 1.0 within 30 minutes. This changes the CTS bry 15 minutes. The change eliminating the requirement to restore Tavg to within its limit within STANDBY is discussed in associated with entering MODE 2 with Kcff < 1.0 instead of HOT DOC A.3.

to the "l'echnical This change is acceptable because it results in no technical change is always an option in an Action, so Specifications. Restoration of compliance with LCO It both the CTS and the ITS, iF eliminating the restoration Action f'rom the C'S has no effect.

in a MODE in which the ILCO does Tavg is not restored with 30 minutes, the unit must be placed as it results in no technical change to the not apply. This change is designated as administrative Technical Specifications. I Page I ol 24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description ol Change ITS Rcquircn1cnt C'TS Requirement 3.4.2 A.3 CTS 3.1.1.5 Action states, "With a Reactor Coolant System operating loop temperaturc, Tavg, 3.4.2 Action A 3. I. 1.5 less than 541 'F, restore Tavg to within its limit within 15 minutes or bc in HOT STANDBY within the next 15 minutes." ITS 3.4.2, Action A, states that with Tavg in one mor'ore RCS loops not within limit, be in MODE 2 with Keff < 1.0 within 30 minutes. This changes the CTS requirement to enter HOT STANDBY to enter MODE 2 with Kcfr< 1.0. Other changes to this Action are discussed in DOC A.2.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3. 1.1.5 is applicable in MODE I and MODE 2 with Kerff> 1.0. CTS 3.0. I states that Actions are applicable during the MODES or other conditions specified for tile Specification. Therefore, the CTS 3.1.1.5 Action to enter MODE 3 cczscs to be applicable once the unit enters MODE 2 with Keff < 1.0, and the Action is exited. As a result, changing the ACTION to "be in MODE 2 with Kcff < 1.0" results in no operational dilTerence from the CTS Action. This change is designated as administrative as it results in no technical change to the Technical Specifications.

3.4.2 A.4 Unit 2 CTS 3. I. 1.5 Applicability is modified by a footnote, designated with an asterisk, which None Unit 2, 3.1.1.5 states, "See Special Test Exception 3.10.3." ITS 3.4.2 does not contain this reference.

This change is acceptable because this footnote is provided for inlormation only, and does not contain any requirements. It is an ITS convention to not include such refecrcnces and it has been removed. This change is designated as administrative as it is an editorial change required to comply with the ITS format and content rules.

3.4.3 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant speciflic Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, rceformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

North Anna Power Station Page 2 of 24. A - 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

Description ol Change ITS Requirement CTS Requirement DOC No.

3.4.3 3.4.9.1 3.4.3 A.2 CTS 3.4.9.1 states that tile RCS temperature and pressure shall be limited "during atheatup, cooldown, and inservice leak and hydrostatic testing." CTS 3.4.9.1 is applicable all times. ITS 3.4.3 states that the RCS pressure, lemperature, and RCS heatup and cooldown rates shall be maintained. ITS 3.4.3 is applicable at all times. This changes the CTS by eliminating the LCO requirement that the limits must be met during heatup, cooldown, and inservice leak and hydrostatic testing.

This change is acceptable because the CTS and ITS limits are applicable at all times, including during heatup, cooldown, and inservice leak and hydrostatic testing. Staling that the lim)its are applicable during heatup, cooldown, and inservice leak and hydrostatic testing in thie LCO times.

presents an apparent conliict with the Applicability which states that the limits apply at all This change is designated as administrative as it is an editorial change to clinlinate an apparent conflict in the CTS.

and/or 3.4.3 Conditions A 3.4.9. I 3.4.3 A.3 CTS 3.4.9.1 Action states that with any of the PIT limits exceeded, restore the temperature and .C pressure to within the limit within 30 minutes; perform an engineering evaluation to determine the effects of the out-of limit condition on the structural integrity of the RCS; determine that the RCS remains acceptable for continued operations. ITS 3.4.3, Conditions A and C state that when the requirements of the LCO are not filt, the paranleters mfust be restored to within limits and it most be determined that the RCS acceptable for continued operation. ITS 3.4.3, Conditions A and C are modified by a Note which requires the determination that the RCS is acceptable lor continued operation to be performed whenever the Condition is enlered. This changes the C I'S by explicitly stating that a determination that the RCS is acceptable for continued operation must be performeld whenever the condition is entered. Other changes to the Actions are dev::ribed in .:ther DOCs.

This change is acceptable because it is the current understanding and application of the CTS Action. The CTS 3.4.9. I Action is currently interpreted as requiring a determination that the RCS is acceptable for continued operation whenever the LCO is not met. This change is designated as editorial as it clarifies the current understanding of the CTS rcquirmcenel..___.

Page 3 of*2d A - 3.4 North Anna Power Station

Table A - Administrativ'e Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requiremcnt CTS Requirement 3.4.3 A.4 CTS 3.4.9.1 Action states that with any or the P/T limits exceeded, restore hlletemperature and/or 3.4.3 Conditions A 3.4.9. I pressure to within the limit within 30 minutes; perform an engineering cvaluat,)"n to) dct,'rinc the and C effects of the out-of linlit condition on tile structural integrity of the RCS, determine that the RCS remains acceptable for continued operations. ITS 3.4.3, Conditions A and C divide the Conditions. ITS 3.4.3 Condition A is applicable when the requirements of thc LCO are not met in MODES I, 2, 3, and 4. Condition C is applicable when the requirements o1" the LCO are not maet any time in other than MODE I, 2, 3, or 4. Any technical changes resuling 'rom IIhis division are discussed in other DOCs.

This change is acceptable because the survcillance is unnecessary and repetitive. Thc unit is rcquircd to remove material irradiation surveillhace specimens and generate P/T curves in accordance with 10 CFR 50, Appendix Fl. Therefore, the surveillance Serves nro purpose and is removed. This change is designed as administrative as it eliminates a requiremient that is duplicative ol a requirement in the CFR.

A.5 CTS 4.4.9.1.2 states that the reactor vessel material irradiation surveillance specimenr's shall be None 4.4.9. 1.2 3.4.3 removed and examiined to determine changes in material properlics at the intervals required by 10 CFR 50, Appendix H. The rcsults of these exariinations shall be used to update th,', P/T limit curves. ITS 3.4.3 does not contain this Surveillance.

This change is acceptable because the sIurveillance is unnecessary and ri'petitivc. The unit is required to remove material irradiation surveillance speciriers arnd generate PI'/'T curves ill accordance with 10 CFR 50, Appendix H. Therefore, the surveillance cserves lit) pthrpOse and is removed. This change is designed as administrative as it eliminates a requirelcirt that is duplicative of a requirement in the CFR.

A. I In the conversion oh the North Anna Current Technical Speci fications (C'iS) t rthe plant specific Various Various 3.4.4 Improved Technical SpeciFications (ITS), certain changes (wording preterences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NURIIG 143 1, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptl rble jiecause they do not result in technical changes to the CTS.

North Anna Power Station Page 4 of '24- A - 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Changc ITS Requirenment C'T'S Requirement 3.4.4 A.2 CTS 3.4.1.1 states that all reactor coolant loops shall be in operation. ITS-3.4.4 states that three 4.41 3.4.

reactor coohlnt loops shall he OPERABLE and in operation. This chan.I:-s the CTS by Icquiring the RCS loops to be OPERABLE.

This change is acceptable because it is consistent with the current use and understanding of the LCO. It not sufficient for a loop to be in operation if it is not capahle of1perl'oming its safety function (i.e., OPERABLE). This change is designated as administrativc as it clarifies the current understanding of a requirement.

A.3 The Applicability of CTS 3.4. 1.1 is MODES I and 2 with a footnote stating, "See Special Test None 3.4.1.1 3.4.4 Exception 3.10.4." ITS 3.4.4 Applicability does not contain the Ifoonote or a reference to the Special Test Exception.

The purpose of the footnote refcrcnce is to alert the ecader that a Special,'Test Exception exists which may modify the Applicability of the spccilicat ion. It is an ITS convention to not incILIde these types of footnotes or cross-references. This change is designated as editorial as it incorporates an ITS convention with no technical change to the 'Technical Speci fications.

3.4.5 A. I In the conversion of the North Anna Current Technical Specifications W(_'TS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording prefcrences, editorial changes, refornmatting, revised numbering, etc.) are made to obtain consistency with N UREG 1431, Rev. I, "Standard Technical Specifications-WestinghotIse PlanltS' (IS'S)*j These changes are designated as administrative changes and are acceptable because they (t1 not result in technical changes to the CTS.

North Anna Power Station Page 5 of 2/1, A - 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

II Description of Change IITS lR'equirement CTS Reqluirement FDOG No. I. N(inc

_____________________________________ t Unit 2 CTS 3.4.1.2 Unit 2 CTS 3.4.1.2 3.4.5 A.2 CTS 3.4.1.2, Unit 2 only, contains a footnote that states that tile requirement to have one coolant None as stipulated in loop in operation is excmpted during thie performance of the boron mixing ,ests does not contaiai this footnote.

License Condition 2.C( 15)(1) and 2.C(20)(b). ITS 3.4.5 Unit 2 License Condition This change is acceptable because this footnote is no longer applicable.

2.C(15) contains actions that must be completed prior to reSuining power operation ll lowing the 2.C( 15)(1) rCq(uirCs VEPCO to submit for Commission 1irst relfueling outage. License Condition to North Anna Power Station, Unit 2, of a study approval the results of the tests applicable added borated water and cooldown under natural circulation conditions.

concerning mixing of 2.C(20) contains requirements contained in Supplement II to the Safety Unit 2 License Condition License Evaluation Report for the North Anna Power Station, Unit 2, dated Au,.ust 1980.

(second paragraph) requires VEPCO to perl-foril a boron mixing and Condition 2.C(20)(b) at least 10 hours0.417 days <br />0.0595 weeks <br />0.0137 months <br /> cooldown test using decay heat within 31 days after burnup sufficicni to produce These L..icense Conditions have of decay heat equivalent to one percent of rated thermal power.

LCO re(iquimen1ls in oider to pIcrHfri been completed and the footnote taking an exception toi the 1)s it eliminates an the tests is no longer needed. This change is designated as administralive exception which is no longer applicable..

r Var io us I Va ous to the plant specific VariouIs In the conversion of the North Anna Current Technical Specifications (CTS)i Various 3.4.6 A.1 preferences, editorial Improved Technical Specifications (ITS), certain changes (wording numbering, etc.) are made to obtain consistency with NUREG changes, reformatting, revised Specifications-Westinghoiuse Plants" (ISTS).

1431, Rev. I, "Standard Technical b,.wausc they do not These changes are designated as administrative changes and arc acceptable result in technical change,, to the CTS. i -t shall be demonstrated None 4A.4.1.3.1I 3.4.6 A.2 CTS Surveillance 4.4.1.3.1 states that the required RHR subsystems 4.7.9.2. ITS 3.4.6 does not contain this .rrv'.'i !:ncc.

OPERABLE per Specification which is equivalent to This change is acceptable because the ITS does not contain a specification in Survcillance 4.7.9.2 will be Surveillance 4.7.9.2. The disposition of the re1(uirements is designated as administrative as it addressed in DOCs for Specification 3.7.9.2. This change in the ITN This change is acceptable eliminates a reference to a specification which does not exist 4.7.9.2. The because the ITS does not contain a specification which is equivalent to Surveillance will be addrcssed in DOCs fIor disposition of the requirements in Surveillance 4.7.9.2 l!mivaes

, a rel'crence to a Specification 3.7.9.2. This change is designated as administrative as il specification which does not exist in the ITS. I I Page 6 of 24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description ol Change ITS RcquiIcIImcIt CTS Requirement 3.4.7 A. 1 In the conversion or the North Anna Current Technical Speci fications (CTS) to he plant spcie V Various improved Technical Specifications (ITS), certain changes (wording prfcrecnces, editorial changes, reforinatting, revised numbering, etc.) are made to obtain consistency wvith NUREG 143 1, Rev. 1, "Standard Technical Specifications-Wcstinghouse PIlanis" (ISTS).

These changes are dcsignated as administrativc changes and are accep able because they do not result in technical changes to the CTS.

A.2 CTS 3.4.1.3 is applicable in MODES 4 and 5. ITS 3.4.6 is applicable in MODE 4, ITS 3.4.7 is 3.4.7 3.4.1.3 3.4.7 applicable in MODE 5 with the RCS loops filled, and ITS 3.4.8 is applicable in MODE 5 with the RCS loops not filled. Editorial changes are made in the division o1" the (-"i'S requirements to the ITS.

This change is designated as editorial because all technical changes resulting Fmm tile division of CTS 3.4.1.3 are discussed in other DOCs.

3.4.7 A.3 statesto that CTS 3.4.1.3action withtileless required loops OPERAB1F', immediately initiate than theloops 3.4.71..3 corrective return required to OPERABI1.E status as soon as possible and be in cold shutdown (MODE 5) within 20 hours. ITS 3.4.7 states that when an RHR loop is inoperable, immediately initiate action to restore a second RHR loop to OlI I:IABI1,.-- status. This changes tile CTS by eliminating the requirement to be in MODE 5 within 20 hours0.833 days <br />0.119 weeks <br />0.0274 months <br />.

This change is acceptable because ITS 3.4.7 is only applicablc in MODEr  ;. Thercfore. a requirement to be in MODE 5 is unneeded. This change is designated as administrative because it is an editorial change required by the division of CTS 3.4.1.3 into( the ITS__

CTS 3.4.1.3 states that two coolant loops shall be OPERABLE, consisthingor ally combination of None 3.4.1.3.

3.4.7 A.4 RCS and RHR loops. A footnote to tile LCO states that the OPERAB LE'. RHR loops may have inoperable offisite or emergency power sources in MOi)E 5. ITS 3.4.7 does not contain an allowance For an OPERABLE RHIR loop to have an ollsite or cilcrgnew-y power sourcc inoperable.

This change is acceptable because the [TS definition of OPERABLE ahows an OPERABLhE componetnt to have either a normal or emergency power source. Thi,: ,hangc to the CTS definition of OPERABLE is discussed in the Section 1.0 Discussion of Change. Given this change to the definition of OPERABLE, a spccific allowance for the RWHIZ loops is not required.

This change is designated as editorial as it replaces a specific exceptionn with an ITS change in tile definition of OPERABLE.

Page 7 of 24' A - 3.4 North Anna Power Station7

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

I

________ ITS Requirement C1'S Requirement Description of Change ITS Requirement CTIS RequLiremenClt DOC No.

I to LCO 3.4.7 Note 3.4.1.3 3.4.7 A.5 CTS 3.4.1.3 is applicable in MODES 4 and 5 and allows any combination o" two coolant loops satisfy the LCO. ITS 3.4.7 is applicable in MODE 5 with the RCS loops fillcd and requires one RHIR loop to be OPERABLE and in operation. ITS 3.4.7 contains a Note which allows all RHR loops to be removed from operation during planned hcatup to MODE 4 when at least one RCS loop is in operation.

This change is acccptable because an RCS loop is capable ol providing the necessary decay heat removal and reactor coolant flow. The ITS convention of dividing the coolant loop specifications between MODES 4 and 5 requires an allowance in the MODE 5 LCO for the starting of an RCP for healup to MODE 4. Such an allowance is not needed in the CTS since an RCS loop can be used to satisfy the LCO. This change is designated its admninistrative because it is anleditorial change required by the division of"CTS_3.4.1.3_into theITS.

CTS Surveillance 4.4.1.3. I states that the required RHR subsystems shall be demonstrated None 4.4.1.3.1 3.4.7 A.6 OPERABLE per Specification 4.7.9.2. ITS 3.4.7 does not contain this Surveillance.

to This change is acceptable because thei[TS does not contain a specification which is equivalent of the requircmentts in Surveillance 4.7.9.2 will be Surveillance 4.7.9.2. The disposition it addressed in DOCs for that specification. This change is designated as jidministrativc as in the ITS.

eliminates a reference to a specification which does not exist -i specific 3.4.8 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant VariouIs VariouIs Technical Specifications (ITS), certain changes (wording preflertences, e'ditor ial Improved changes, reformatting, revised numbering, etc.) are made to obtain consistency with NI RIFG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plats" (ISTS).

do not These changes are designated as administrative changes and are acceptabte because they changes to the CTS.

-Lresult in technical 3.4.8 T 3.4.1.3 3.4.8 A.2 CTS 3.4.1.3 is applicable in MODES 4 and 5 and requires two coolant loops, ýxonsisting of any 3.4.8 3.4.1.3 5 with combination of RCS and RHR loops, to be OPERABLE. ITS 3.4.8 is ipplicatlle in MODE the RCS loops cannot be used for decay heat rtemoval the RCS loops not filled. In this condition, and all references to the RCS loops, steam generators, and Reactor Coola-nt Pumps are removed.

RCS This change is acceptable because it does not change the current trequirements. With the and the steam generators cannot be used For dccay heat removal loops not filled, the RCS loops and cannot be OPERABLE. Therefore, the two RHR loops must be used as the OFPERABiF it loops in MODE 5 with the loops not filled. This change is designated is administrative because editorial change resulting from the division of CTS 3.4.1.3 in thc.!TS. I I is an I

Page 8 of 24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

Description of Change r [IS Requirement ITS Requirement 1 (il S ReqLlircnlent C 1T S R cttt mc n

( li -ll~

11 DOC No. 3.4.1.3 3.4.8 I 3.4.8 I 3.4.8 A.3 CTS 3.4.1.3 is applicable in MODES 4 and 5. ITS 3.4.6 is applicablel ii MODE 4, ITS 3.4.7 is 3.4.1.3 5 with the applicable in MODE 5 with the RCS loops filled, and ITS 3.4.8 is applicable in MODE CTS 3.4.1.3 requirements into three RCS loops not filled. This changes the CTS by dividing the specifications with different applicabilities. Editorial changes are made in the division of the CTS requirements to the ITS.

This change is designated as administrative because all technical changes resulting froin the division of CTS 3.4.1.3 are discussed in other DOCs.

t t 3.4.8 A.4 CTS 3.4.1.3 states that with less than the required loops O1PFRABIlE, immediately initiate 3.4.8 3.4.1.3 required loops to OPERABLE status as soon as possible and be in corrective action to return the cold shutdown (MODE 5) within 20 hours0.833 days <br />0.119 weeks <br />0.0274 months <br />. [TS 3.4.8 states that when an RHR loop is inoperable, the immediately initiate action to restore a second RHR loop to OPERABLE status. This changes CTS by eliminating the requirecntcil to be in MODE 5 within 20 hours.

a This change is acceptable because ITS 3.4.8 is only applicable in MODE 5. Therefore.

because it requirement to be in MODE 5 is unneeded. 'I'his change is designated as ,mdninistrative is an editorial chang*e required by the division of CTS 3.4.1.3 into the I'T'S. 1 i of 3.4.8 A.5 CTS 3.4.1.3 states that two coolant loops shall be OPERABLE, consisting of amiy combination Nonec 3.4.1.3 A footnote to the LCO states that the OPERABLE , HR lioops may have RCS and RHR loops.

an inoperable olfsite or emergency power sources in MOI)E 5. ITS 3.4., rdores io c;*mlain

-ovwer rce so)w'!

allowance for an OPERABLE RHR loop to have an of site or emergcw..

inoperable.

This change is acceptable because the I'S definition of OPEIRABLE allows an OPERABLE component to have either a normal or emergency power source. This ,:haer wothe CI'S this definition of OPERABLE is discussed in the Section 1.0 Discussion of.'hange. Given change to the definition of OPERABLE, a specific allowance For the RHR loops is not required.

generic This change is designated as editorial as it replaces a speciflic exception with aln ITS

-j-I change. __7 S -t t .

3.4.8 A.6 CTS Surveillance 4.4.1.3.1 states that the required RHR subsystcms shall b" dmmonstralcd None 4.4.1.3.1 OPERABLE per Specification 4.7.9.2. ITS 3.4.8 does not contain this Survellance.

This change is acceptable because the ITS does not contain a specifict*ion which is equivalent to he Surveillance 4.7.9.2. The disposition or the requirenments in Surveiliance 4.7.9.) will for that spccification. This change is designated as administrativc as it addressed in DOCs eliminates a reference to a specification which does not exist in thc ITS.

Page 9 ol 24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change . ITS Requirement CTS Requirement 3.4.9 A. I In tile conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording pre.ercces., editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with Nt.IREG 143 I, Rev, I, "Standard Technical Specifications-Wcstinghouse Plants" (ISTS).

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

3.4.9 A.2 CTS 3.4.4 requires that pressurizer water volume be less than or equal to 1240 cubic feet and 3.4.9 and 3.4.4 and 4.4.4.1 Surveillance 4.4.4.1 requires verification of the volume every 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. ITS 3.4.9 will require SR 3.4.9.1 that pressurizer level be . 93% and SR 3.4.9.1 will require verification of the pressurizer level every 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />.

This change is acceptable because the CTS limit and thie ITS limit arc the same. The ITS presents thie pressurizer limit in thie scale displayed in tile Control Room. Pressuirizer volume is displayed as a percent of level on Control Room instrumentation. This change is designated as administrative as the units of the limit are changed but the value of the limit is nit affected.

3.4.9 A.3 CTS 3.4.4, action b, applies when tile pressurizer is inoperable for re.asons 6ther than i noperable 3.4.9 Condition A 3.4.4 Action b group of pressurizer heaters. ITS 3.4.9, Condition A, applies when the pic,:surrer waiter level is not within limit. Changes to CTS 3.4.4, action a, to make it applicable to all aIuses of pressuri.zcr heater inopcrability are discussed in DOC L. I.

The purpose of CTS 3.4.4 is to require the pressurizer to be OPERABI L-,, andLtw, conditions of OPERABILITY are supplied. The conditions are prcssur izrci water lel and prCssuriz i hcletater OPERABILITY. CTS 3.4.4, action b, applies when water level is not wilhinltilmit. This is the same condition for which ITS 3.4.9, Condition A applies. The Actions in CTS 3.4.4, action b, and ITS 3.4.9, Action A are the same, except as described in DOC L. I. IThis change is acceptable because the remaining conditions under which the actions in CTS 3.4.4, actiel I-,,:apply have not changed. This change is designated as administrative as it ici:.ults in no technical change to the specifications.

3.4. 10 A. I In thie conversion of the North Anna Current Technical Specifications (CI'S) to tile plant specific Various VariouS Improved Technical Specifications (ITS), certain changes (wording p-reiirenaces, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NURIi'G 143 I, Rev. I, "Standard Technical Specifications-Westinghouse Plant-' (IS'f S).

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

North Anna Power Station Page 10 of 24t A -- 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

T'rQ PIfi. il-I ITS4.1 I1 Description of Change 0l.llllnlnl DOC No. 4.4.2 and 4.4.3.1 CTS Surveillances 4.4.3.1 -and4.4.2 state that there arc no Surveillance Requirements on the SR 3.4. 10.1 3.4.10 A.2 Spccification 4.0.5. Specification 4.0.5 pressurizer safety valves other than those required by stetes that it musm be verified that describes the Inservice Test requirements. ITS SR 3.4.10.1 with the Inservice Testing Program each pressurizer safety valve is OPERABLE in accordance

+/- 1%.

and, following testing, lift settings shall be within This change is acceptable because the requirements havc not changed. Both the CTS and the ITS with the Inservice Testing Program. LThe state that the safety valves must be tested in accordance

+/- I% is moved from CTS LCO 3.4.3.1 ITS requirement that the as-left lift settings must be within as the technical reqcuirements are not and 3.4.2. This change is designated as administrative changed.

3.4.10 3.4.2 safety valve to be OPERABLE with a lift 3.4.10 A.3 CTS 3.4.2 requires a minimum of one pressurizer code three prcssuriy"r code safety valves to be setting of 2485 psig +/-3% as-found. ITS 3.4.10 requires average with ntvsinglo valve outside of+/-

OPERABLE with a lift setting of 2485 psig, +2% /-3%

in MODE 4 is described in DOC 3%. TFile requirement for three salcty Valves to be OPERABLE M.3.

change to the requirement. In both This change is acceptable because it results in no technical have a lift setting Within +/-- 3% of 2185 psig.

the CTS and the ITS, any single valve is required to CTS LCO 3.4.3.1 amtd only applies under the The limitation on average lift setting is taken from This change is designated as ITS requirement for all three safety valves to be OPERABLE.

for consistency with another change.

administrative as it is a non-technical change required V ariouLsI 5 VariouIs Specifications (CTS) to the plant specieic 3.4.11 A.I In thle conversion of the North Anna Current Technical (wording p

.fe.ences. editorial Improved Technical Specifications (ITS), certain changes to obtain consiste.ncy with NU REG changes, reformatting, revised numbering, etc.) are made

ý1- 1431, Rev. I, "Standard Technical Speci fications-WestingloLuse Phlants (,STS) and are accelnutblc because they do not These changes are designated as administrative changes result in technical changes to the CTS.

A 3.4 Page I I of 24 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

I 15 t(equireiflcnt L I KCUiCi1]CflL DOC No. Description of Change I1 5 l(C-lronienl I CTS Requilreenton I 3.4.11 I 3.4.3 .)

ITS 3.4.11 A.2 CTS 3.4.3.2 describes the Actions to be taken when a PORV or block valve is inoperable. 3.4.11 S3.4.3.2 block valve is inoperable and contains 3.4.11 also describes Actions to be taken when a PORV or a statement that separate condition entry is allowed 1"o each PORV an(d[ ieh block valve.

entercd l'(r each This change is acceptable because the CTS is interpreted as Action A may be rhis valve separately. It does not result in a technical change to the Tcchnical Sfccifications.

as it is a change required by the !TS usagc rules that does change is designated as administrative not result in a technical change to the specifications. i. 4 because of

.4.1I A.3 CTS 3.4.3.2, Action A. I, applies with one or both PORV(s) inoperable solely 3.4.1 Action1 Actions A, C B, Action 3.4.3.2 Action Action A. I, A.2, Action A.2, applies with one or both PORV(s) inoperable excessive seat leakage. CTS 3.4.3.2, Action and Action F A.4 and Action A.5 supply. CTS 3.4.3.2, Action A.4. applies with one because or an inoperable backup nitrogen those addressed in Actions A. I, A.2, or A.3. CTS PORV inoperable due to causes other than A.2, or A.3 3.4.3.2, Action A.5, applies with both PORVs inoperable such that Act ions A. I, divide the conditions of PORV inoperability into above do not apply. ITS 3.4. II ACTIONS o" being manually cycled and those which do, not. !TS those in which tile PORV is capable nitrogen 3.4. I I, Action A applies with one or more PORVs inoperable due to inoperable backup manually cycles. ITS 3.4. I I, Action B, applics with one or more supply and capable of being for reasons other than Condition A and capable or being manually cycled. ITS PORV inoperable of being manually cycled.

3.4. I I, Action C, applies with one PORV inoperable and not capable cycled. This ITS Action F applies with two PORVs inoperable and not capable of b'hing uivinally in which I(he PORV can, and changes tile CTS by dividing the existing conditions into those cannot, be manually cycled.

inoperable due

'T'his change is acceptable because the requirements have not changed.A., POPV leakage can still be manually cycled. A PORV inopelablc duc to an inoperable to excessive seat can still be manually cycled. PORVs inoperable (or ,*o*r" i-easons cannot backup nitrogen supply are appliedr have be manually cycled. Therefore, thie conditions under which the Required Actions not rOS1ult in a technical not changed. This change is designated as administrative because it do10"S

-A change to the specifications.

I Page 12 of 2- A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

I ITS Recluirenient 1' Cl'S Requirement DOC No. Description of Change ITS Requirement CTS Requll'irleent I ________________________________________________________ I 3..1 cioI

+/- 3.4.3.2 Action B. I A.4 tile 3.4.3.2, CTSblock Action valves B. I, states that to OPERABLE withorone block valve inoperable, within I hour cither restore status 3.4.11 Action D 3.4.3.2 Action B.2I 3.4.11 place the PORVs in manual control, restore the block and Action G and Action B.2 valve to OIPERABLE status within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or be in at least HOT STANDBY within the next 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> and in HOT SHUTDOWN within the following 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />. CTS 3.4.3.2, Action B.2, states that with both block valves inoperable, within I hour either restore the block valves to OPERABLE status or place the PORVs in manual control; restore at least one block valve to OPERABLE status within the next hour, and restore thie remaining inoperable block valve to OPERABLE status within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or be in at least HOT STANDBY within the next 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> and in HOT SHUTDOWN within the following 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />. [TS I 3.4. I I, Action D, states that with one block valve inoperable, place the associated PORV in manual control and restore the block valve to OPERABLE status within 72 hours. ITS 3.4.1 I , Action G, states that with two block valves inoperable, restore one block valve to OPERABLE status within 2 hoUIrSs. This changes the CTS by eliminating the actions for one block valve inoperable in the Condition for two block valves inoperable.

ITS, This change is acceptable because ihe rcquirements have not changed. Under the rules of tile all applicable Conditions are entered. Thcrefore, with two block valves inopcrable, the Conditions and Required Actions for one block valve inoperable must a!lso hIe followed. As a result, it is not necessary to repeat those Required Actions in tile Condition f{or two block valves inoperable. This change is designated as administrative as it is a change required by the ITS usage rules that does not result in a technical change to the specifications. -t -i - .

In the conversion of the North Anna Current Technical Speci Iications ("IS) to, the plant specific Vario}us Various 3.4.12 A.I Improved Technical Specifications (IIS), certain changes (wording preferenccs, editorial changes, reformatting, revised numbering, etc.) are made to obtain consislencv with NUREG 1431, Rev. I, "Standard Technical Speci fications-Westinghouse Plants .I.S' .IST.

These changes are designated as administrative changes and are acceptable because they do( no1t to the CTS.

I4 Iresult in technical changes -l r 3.4.12 A.2 CTS 4.4.9.3.d states that each PORV shall be demonstrated OPERABLE by testing pursuant to None 4.4.9.3.d Specification 4.0.5. ITS 3,4.12 does not contain a similar requirement This change is acceptable because Specification 4.0.5 applies whether or not it is specifically invoked in a particular specification. A requirement to follow Specificatio'4 0.5 in CTS 4.4.9.3.d is repetitious and adds no requirements. Thcrefore, it is deleii:_;. C.ha*,oes to 4.0.3 are discussed in the ITS Section 3.0 DOCs.

I Specification I I Page 13 oft'A24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description ol'Change ITS RequnircmCnlt CTS Reqi remlent 3.4.13 A. I the conversion of the North Anna CurrCnt Technical Specifications '(C"I'S) to the plant specific n1li Various Vairious Improved Technical Specifications (ITS), certain changes (wording preleences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUIRBG 1431, Rev. I, "Standard Technical Specifications-Westinghouse Plants" ISTS).

These changes are designated as administirative changes and aire acceptable because they do0not result in technical changes to the CTS.

A.2 CTS LCO 3.4.6.2.c states that the RCS leakage shlall be limited to I GPM total prilmary-to- None 3.4.6.2.c 3.4.13 secondary leakage through all steam generators not isolated rl-om tie Reactor Coolant System and 500 gallons per day through any one steam generator not isolated fiom tthe Reactor Coolant System. ITS 3.4.13 contains the same limits olprinmary-to-secondary leakage, but does rot contain( tie qualification that tile steam generators must riot be isolated i roll tile RCS.

This change is acceptable because under the ITS tile steam gencratoirs cannot be isolatedl from the RCS in thle MODES in which ITS 3.4.13 applies and, therefore, the qualiification is unnecessary.

ITS 3.4.17 requires that the loop isolation valves be open in MODES ! -4, wllict' is also the Applicability of ITS 3.4.13. This change is designated as administralive'as it eliminates a requirenient which has been superceded by another change to the Specilications.

A.3 CTS LCO 3.4.13.c contains an asterisk reference to a foolnote which oates that CTS None 3.4.13.c footnote 3.4.13 Specification 3.4.6.3 applies when in MODE I above 50% power. ITS Specification 3.4.13 does riot contain this footnote.

This change is acceptable because tie ITS formaat eliminates infornmIalii l clfIciices to othel Specifications. Suchl references do riot impose or change requirenments and alc, therefore, unnecessary. This change is designated as administrative as it climinalcs a ireferelnce which contains no requirements.

Page 14 of 2-'A A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.4.13 A.4 CTS 4.4.5.0 states, "Each steam generator shall be demonstrated OPERABLE by perlormance of SR 3.4.13.2 4.4.5.0 the following augmented inservice inspection program and the required Specification 4.0.5." ITS SR 3.4.13.2 states that the RCS operational leakage must be verified tc he within limits in accordance with the Steam Generator Tubc SurveilhaMce Program. This chaniges the (CTSby changing the reference to the rcqtuired testing from the testing in CTS 3.4.5 and Specification 4.0.5 to the. Steam Generator Tube Inspection Program in the ITS Administrative Controls.

The purpose of SR 3.4.13.2 is to provide a link to the Steam Generator Tube Surveilfance Program in the Administrative Controls. The ITS moves the Steam Generator tube inspection fr-om CTS 3.4.5 to a program in the Administrative Controls section. This change is acceptable because it creates an administrative reference to the Steam Generator ',Fubc Surveillance Program and does not, of itself, impose any new requirements. Differences between CTS 3.4.5 and the Steam Generator Tube Surveillance Program are discussed in ITS Section 5.0. In both the CTS and the ITS, discovery while irn MOI)BS I - 4 that the steam generators have not been inspected in accordance with the stated requirements results in entry into LCO 3.0.3. "l'herelore, adding this Surveillance imposes no new requirements. T'his change is dcsignaled as ,dminislrative because it does not result in a technical change to the Specifications.

In the conversion of the North Anna Current Technical Specifications (TCS) to Ihe plant specific Various Various 3.4.14 A. I Improved Technical Specifications (ITS), certain changes (wording profe,'Aice;, editorial changes, relormatting, revised nu,mbering, etc.) are made to obtain cmnisis;leuy with NURIiG 143 1, Rev. I, "Standard Technical Specifications-Wcstinghouse Plant,'" (ISTS)

These changes are designated as administrative changes andl are acceprabil, bv.',use they do[ not result in technical changes to the CTS.

3.4.14 A.2 ITS 3.4.14 contains ACTION Note 2 which states, "nter applicable CotInditions and Reqtuired 3.4.14 Action None Actions for systems made inoperable by an inoperable PIV." CT'S 3 4.6... dýes :'not spe-cifically Note 2 state a similar requirement. "

This change is acceptable because it does not change lie intent or application of the Specification.

The CTS definition of OFPERABLE requires ildeclaring equipment in-opi.rabl:. if it its incapable o(f performing its safety function. This Note makes clear that ITS LCO 3.:.'6 canntl be invoked in this case and systems rendered inoperable due to a leaking PIV or a Hlow path. closed to isolate a leaking PIV must be declared inoperable and the applicable Conditions 'And Required Actions mut, st be taken. This change is designated as administrative because it d,11 no0 c.ha,1ngC tliC intent of the specification. ....... _............ ____

North Anna Power Stationa Page 15 oif R4 A - 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS RCquiremlent CTS Requirement 3.4.14 A.3 CTS Surveillances 4.4.6.2.2.b and Unit I CTS Surveillance 4.4.6.2.2.a-require testing 6f RCS SR 3.4.14.1 Note 4.4.6.2.2.a and PIVs prior to entering MODE 2. Unit 2 CTS Surveillance 4.4.6.2.2..) r.quires testing every 18 4.4.6.2.2.b months. However, Surveillance 4.4.6.2.2.b can be used to meet this Surveillance, so the exception to enter MODES 3 and 4 prior to performing the testing applies. ITS SR 3.4.14.1 contains a Note which states that RCS PIV testing is not required to be performed in MODES 3 and 4.

This change is acceptable because it applies a general Note to the Surveillance instead of exceptions on each Frequency of the Surveillance. This change is designated as administrative because it does not result in a technical change to the Specifications.

A.4 Unit I CTS Surveillance 4.4.6.2.2.a requires testing ol RCS PIVs prior to entering MODE 2 after SP, 3.4.14.1 Unit I 4.4.6.2.1a 3.4.14 and Unit 2 each refueling. Unit 2 CTS 4.4.6.2.2 requires testing of RCS PlVs in accordance with 4.0.5 (the 4.4.6.2.2 Testing Program) and cvery 18 months. ITS SR 3.4.14.1 requires testing or RCS PIVs Inservice in accordance with tile Inservice Testing (IST) Program and every 18 nmonths.:

This change is acceptable hecause it does not change the testing F requency of the RCS PtVs. 'The Unit I and Unit 2 RCS PIVs are tested under the IST program. Stating that the valves must be tested oil a Frequency specified in the IST program does not impose any new mequircment. The North Anna refueling interval is 18 months. Requiring testing every 18 months and requiring testing after each refueling does not change the test Frecquency. This chInge is designatcd as administrative because it does not result in a technical change to the specifiation:-;.

A.l In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.4.15 Improved Technical Specifications (ITS), certain changes (wording pro fetchmes, editorial changes, reformatting, revised numbering, etc.) are made to obtain conlsisIincy with NURFG 143 1, Rev. I, "Standard Technical Spccifications-Westinughouse Plant. (1STh).

These changes are designated as administrative changes and are accep!:thle becatise thcv do not result in technical changes to the CTS. These changes are designated as ad'*niistrative changes and are acceptable because they do not result in technical changes to he CTS.

Page 16 of 2..!. A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CI'TS Requirement 3.4.15 A.2 CTS 3.4.6.1 does not include an explicit requirement to enter LCO 3.0.3 when all required 3.4.15 Action D. I None "

monitors are inoperable. ITS 3.4.15 Required Action D. I requires entering LCO 3.0.3 when all rcquircd monitors are inoperable. This changes CTS by adding a Required Action explicitly requiring entry into LCO 3.0.3, while the CTS would also require entry into L.CO 3.0.3 based on not meeting thie LCO and not having an explicit Condition to enter.

This change is acceptable because entry into LCO 3.0.3 would be required with or without the Required Action. This change is designated as administrative because it does not result in technical changes to the CTS.

3.4.15 A.3 CTS 3A4.6. I .b states, "The following Reactor Coolant System leakage detection systems shall bh e O 3.4. I.a 3.4.6. lb OPERABLE: ....b. The containment sump level and discharge now measulrement systemn.'ITS 3.4.15.a states, "The following RCS leakage detection instrunletation shall be: OPERABLEi: a.

One containncnit sump (level or discharge flow) monitor;..."'This changes C'FS by more explicitly stating that any one of the components in the system is capable of monitoring tile containment sump for Reactor Coolant System leakage.

The purpose of CTS 3.4.6. I.b is to provide assurance llhat the containnwnt sumip level and discharge flow measurement system can providel an indication o R'cactor Coolant Systelm leakage. The system described in CTS 3.4.6. L.b consists of two contain ment sump level monitors and a containment sun1p discharge flow totalizcr. Any one of these colpolcnIfit, call perforlll tile function of the system. ITS 3.4.15.a explicitly states that either the COIII.Cl!Iilteli (Sunp or discharge flow) monitors can perlorm tile function. This change is acccptable.because he existing requirement is retained but clarified. This change is designated as administrative because it does not result in technical changes to tile CTS.

3.4.16 A. I In the conversion of the North Anna Current Technical Specifications IC'IS to thl plant specific Various Various Ihproved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain con,:isten-cy with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghousc Plants" (ISTS).

These changes are designated as administrative changes and are accept:-die because they do not result in technical changes to the CTS.

North Anna Power Station Page 17 of 2.4. A - 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

..-- 1 11110 T1 .-.... - - I CII01 111 -11,11 DOC No. Description of' Change I 1ITSlRequirement t CTSl l'( L11.-tlll'Cltln I ________________________________________________________ Various V ati 005 3.4.17 A.I In the conversion of thc North Anna Current Technical Specifications (CTS) !)o the plant specific Various Various editorial ilmprovcd Technical Specifications (ITS), certain changes (wording preferences, with NUREG changes, reformatting, revised numbering, etc.) are made to obtain consistency 1431, Rev. I, "Standard Tcchnical Spccifications-WcstinghouseIPlants" (ISTS).

because they do not These changes are designated as administrative changes and are acceptable result in technical changes to the CTS. i i3.4. I fromt 3.4.17 A.2 CTS 3.4. I.1states that all reactor coolant loops shall be in operation wiih power removed 3.4.17 3.4.1.1 reactor coolant loops shall be OPERABLE the loop stop valve operators. ITS 3.4.4 states that all isolation valves shall be and in operation. ITS 3.4.17 states that all RCS hot and cold leg loop valve operator. This changes the CTS by dividing open with power removed from each isolation the existing LCO requirements into two LCOs.

in no technical change to the This change is designated as administrative as it is editorial resulting Technical Specifications........

entry is allowed for i . . - i.

3.4.17 A.3 ITS 3.4.17 Actions are modified by a Note that states that separate condition 3.4.17 Actions None not contain tis allowance. Note each RCS loop isolation valve. CTS does

. frtaining to the loop This change is acceptable because the CTS does not provide any Actior-I ecribed in ,L.I and M.2.

isolation valves. The Note modifies the Actions added to the CTS as rel-atcd () the addition of The addition of the Note itself results in no changes to the CTS excepti as change related to the ITS Actions. This change is designated as administrative its it is an xditori.d other described changes -r Various 'Various r' to the plano specific Various In the conversion of the North Anna Current Technical Specilficatioils I(, IS Variouls 3.4.18 A.I preferenccs. editorial Improved Technical Specifications (ITS), certain changes (wording revised numbering, etc.) are made to obtain consistency wilh NtiJREG changes, reformatting, (ISTS).

1431, Rev. 1, "Standard Technical Specifications-Westinghoutse Plant.,'

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

Page 18 ol124 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

Il'S Requirentent 1 tZYl'S Rcqui enient 1

Description of Changc

-11 DOC No. ITS Requirement C TIS RequLiremenltlt 1

---

4 3.4.18 3.4.1.4 and 3.4.1.5 3.4.18 A.2 CTS 3.4.1.4 provides requirements on tile boron concentration of an isolated loop in MODES 3, 4 3.4.18 3.4.1.4 and 3.4.1.5 and 5. CTS 3.4.1.5 provides requirements on opening a cold leg stop valve in all MODES. ITS 3.4.18 provides requirements on the startup of an isolated loop and is applicable in MODES 5 and

6. ITS 3.4.18 also refers to the minimum boron concentration requirements in MODE 6 imposed by LCO 3.9. I.

This change is acceptable because the condition the Specifications control is only allowed in MODES 5 and 6. ITS 3.4.17 requires the RCS loop isolation valves to be open with power removed to the valve operator in MODES I, 2, 3, and 4. Thcreolre, reqtuirements on the startup of an inactive loop are not applicable in those MODES. Rcfcrencing the boron concentration requirements in LCO 3.9.1 is necessary because the CTS LCO 3. 1.1 and 3.1.2 do not apply in MODE 6. LCO 3.9. I provides an equivalent requirement in MODE 6. T'his change has been designated as administrative as it is editorial resulting from changesjiusiflied in other specifications.

I 3.4.18 A.3 CTS 3.4.1.5 states, in part, that a reactor coolant loop cold leg stop Valve shall rema'.(in closed until None 3.4.1.5 the reactor is subcritical by at least 1.77% Ak/k. ITS 3.4. 18 does not contain this. I-equirCmCnt.

This change is acceptable because the shutdown margin requirement in.C(I'S 3,4.1,5 is redundant.

ITS 3.4.18 is applicable in MODES 5 and 6 with RCS loop(s) isolated. 'CTS 3*.1..2 and ITS

3. . I requirc tile shutdown margin to be > 1.77% Ak/k when in MODE 5. CTS 3.9. I and ITS 3.9.1 require the reactor to be shutdown by greater than 1.77% Ak/k when in MODE 6.

Therefore, the CTS 3.4.1.5 shutdown margin requirement is redundanti to these other, more broadly applicable, specifications and is not needed. Changes to CTSS .1.1.2 or CTS 3.9.1 will be addressed in the DOCs for those Specifications. This change is designated as administrative as it eliminates a redundant requirement from the CTS. I I I

Page 19 of 2-1 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

..- I iV m*.Q

1) culeuL . 1 Description of Change I 1 AIcetloneltion C.I IU.4.I NKCtlll.Cl5u*.

DOC No.

3.4.1.5 loop cold leg stop valve shall remain closed until certain 3.4.18 Action C. I 3.4.18 A.4 CTS 3.4.1..5 states requirements that '[lie are met. CTS coolant a reactor 3.4.1.5 Action states that with the requirements of the ITS 3.4. 18, Action C. 1, states that speeification not satisfied, suspend startup of the isolated loop.

with ILCO rcquirements not fiet, close with the isolated loop hot or cold leg isolation valve open the cold leg isolation valve immediately.

notl met have not changed.

This change is acceptable because the actions taken if the LCO is For the CTS 3.4.1.5 1..CO, whit.I states, Actions are only entered if the LCO is not met. In order "a reactor coolant loop cold leg stop valve shall remain closed until ... " to not be met, the cold leg in the LCO. The action taken under stop valve must he opened without meeting the requirements close the cold leg isolation the CTS to "suspend startup of the isolated loop" is to immediately in this condition. This change is designated valve, which is the same action required by the ITS technical change to the specifications.

as administrative as it does not result in a None 3.4. 1.5 Note leg stop valve is c-losed for maintenance 3.4.18 A.5 'ile LCO Note to CTS LCO 3.4.1.5 states that if a col or testing and not reopened with 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />, A.C. power is to be removed. Fron the- valve and the that A.C.: nwv,er he removed fronm the breaker locked open. This changes the CTS by not requiring open is discussed in DOC1 -.3.

valve. The change regarding locking the breaker to remove A..C. power frmn the valve This change is acceptable because the CTS requirement ITS ICO requires each isolated loop to remain isolated operator is located in, the ITS LCO. The LCO Note requires the loop to bc with power removed from the valve operators. The ITS the loop to, be isolaled and power to isolated. Therefore, the ITS LCO Note and the I.CO require as admin;strativc because it does be removed from the valve operators. This change is designated not result in a technical chang~e to the specifications. 3.4. 18 , Action C 3.4.1.6 be at least , ,05,.,ib~c feet prior to 3.4.18 A.6 CTS LCO 3.4.1.6 requires that the pressurizer water volume and SR 3.4.18.6 filling a drained, isolated loop from the active volume of the RCS. CI'S Action b addresses this volume. ITS LCO 3.4.19 requires limit not being met and Surveillance 4.4.1.6.2 verifies this of this pre:isurizer level not pressurizer level to be : 32%. Action C addresses the condition changes the CTS by suhstittling an being met and SR 3.4.18.6 verifies this level is met. This contained in l the S.1"*'.

equivalent pressurizer level for the pressurizer volume of pressuri/er water volumil in the This change is acceptable because there is no direct indication from the pressurizecr level. Under the Control Room. Pressurizer water volume is calculated should be in the units measured in tei Control Room, conventions of the ITS, values such as this change is designated as :AciVC adminhli.llt;ive tse they do including applicable uncertainties. This specifications.ls not result in technical changes to tle I _________________________________________

Page 20 of 2. A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

I: CTS Requirement DOc No. Description of Change I ITS Rcqulircnent CTS Requ~irementll tiI1 3.4. I .6 Action b CTS 3.4.1.6, Action b, states that if pressuriier water volume is not maintained above the limit, 3.4. 188A 3..I Action D1 3.4.1.6 Action b 3.4.18 A.7 the loop stop valves must be closed. Action b also rcqtuires that A.C. pomwer be removed friom the loop stop valves and the breakers he locked open. ITS 3.4.18, Action ID apprlies in the same circumstance and requires that the isolation valves be closed. This changes the CTS by not requiring that A.C. power be removed from the valve. The change regarding locking the breaker open is discussed in DOC L.3.

This change is acceptable because the CTS requirement to remove A.C. power from the valve operator is located in thie ITS LCO. The ITS LCO requires each isolated loop to remain isolated with power removed from the valve operators. '['he ITS Action requires the loop to be isolated.

"Therefore, the ITS Action and thei CO require the loop to be isolated and power to bh relovewd from the valve operators. This change is designated as administrative lbecausC it (toes not result in a technical change to the specif'icationls.

-I None t 3.4. I .6.a.3 3.4.18 A.8 CT'S 3.4.0.6.a.3 requires a sourlce range neulron flux monitor to be OPFERAIBIL. in MODFS 5 and None 3.4. 1.6.a.3 6 during thie filling of an isolated and draitned portion of(tlie RCS Iroiml the aclivc RCS wlunime.

The ITS does not contain this requirement.

This change is acceptable hecause a source range neutron flux moonilor is required to be OPERABLE in MODES 5 and 6 by other Speciflications in the ITS. ITS 1.3.!, *Table 3.3.1 -1, Item 5, requires a source range neutron IIlux monitor be OPIE:RABIL* m MODE 5 (both with and without the reactor trip breakers open) and ITS 3.9.3 reqt, ires two sourI.e rarire neutron flux monitors to be OPERABLE in MODE 6. Therefore, thie CTS rcquirci, t i:., 'upI licative and unnecessary. This change is designated as administrative because it dots not rc'.ult ill a technical change to the specifications. -f 3.4.18 Action II I 3.4.1 .6 Actions c met, the loopp shall he isohat'l-d am1d 3.4.1 8 Action I.,, 3.4.1.6 Actions c 3.4.18 A.9 CTS 3.4.1.6, Action c and e state if the requirement is not drained or apply Specification 3.4.1.4 and 3.4.1.5. ITS 3.4.18, Action E. applies in the sarrme anld c conditions anid states the valves are to he closed immediately. This change.s thIe CTS by eliminating the requirement that the loop be drained or Specificatioms .4.1.4 and 3.4.1.5 he applied.

This change is acceptable because the requirements have not bcen chaogecd. Under the CTS, once a loop is isolated the requirements of Specification 3.4.1.4, 3.4.1.5, or .1.4.1.6 apply. Under the ITS, once a loop is isolated, the requirements of 3.4.18 apply. CTS 3A. 1.4i 3.4. 1.5, and 3.4.1.6 describe the controls on starting a loop, as does ITS 3.4. 18. T'hereflore, iihe fcuiflClnts have not changed except as described in other DOCS for ITS 3.4.18. This chang' is dcleioiiatcd as administrative because it does not result in a technical chang e to the spc i icat..ions. I-I Page 21 o f 2 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

ITS Requirement f DOC No. Description of Change ITS Requirement CCTS Requirement

____________________________________________-. 1 Various U V an otis A.I In tile conversion of the North Anna Current Technical Specifications (CTS) (() the plant specific IVariouls SVarious 3.4.19 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtainPlanits" (ISTS).with NUREG consistency Technical Specifications-Westinghouse 143 1, Rev. I, "Standard not These changes are designated as administrative changes and are acceptahile because they do result in technical changes to the CTS. -i is 3.4.19 A.2 CTS 3.10.4 is applicable during operation below.the P-7 Interlock Selpoint.I .CO 3.4.19 3.4.19 3.10.4 applicable in MODES I and 2 during startup and PHYSICS TESTS.

while at The pui'pose of CTS 3.10.4 is to allow all Reactor Coolant Pumps (RCPs) to be stopped purpose. This low reactor power to allow natural circulation testing. ICO 3.4.19 serves the same the fuel design limits testing is performed with reactor power less than 10% RTP to ensure that are not exceed. Should power exceed the P-7 Interlock Setpoint (10% RoTP), a low flow reactor trip signal (which is bypassed below the P-7 setpoint) would open the reactor trip circuit breakers of CTS and the reactor would be shutdown. This change is acceptable becau,;e ihe Applicability 3.10.4 and ITS LCO 3.4.19 serve the same purpose. Both allow Ihe testing to be l)erlormed.

Action.

However, the CTS 3.10.4 Applicability could be interpreted to be in coif] ict with the Specifically, should reactor power exceed the P-7 Interlock Setpoint,. thcCTS/lApplicability is exited, and tile Condition ol the Action, power greater than P-7, is nevcr ent'red. The ITS Applicability, MODE I and 2 during startup and PHYSICS TESTS, allows the appropriate Action Action to be entered should power exceed the 1P-7 Interlock Setpoint. this is how the CTS This change is designated as administrative as it is a is currently interpreted and implemented.

clarification oflthe current understanding of a requiremenlt. i i 3.4.19 A.3 CTS 4.10.4.2 requires that a CHANNEL FUNCTIONAL TESTIbe petrforme1d on each SRZ 3.4.1 9.2 4.10.4.2 channel and P-7 Interlock. ITS SR 3.4.19.2 rcquires that a Intcrmediate and Power Range CHANNEL OPERATIONAL TEST be performed on that equipment.

TEST This change is acceptable because, for this equipment, a CTS CHANNELF.IUNCTIONAL and an ITS CHANNEL OPERATIONAL TEST are the same. The ITS renamed tile CHANNEL the FUNCTIONAL TEST to CHANNEL OPERATIONAL TEST and separvted some of definitions. That scparation does not affect this change. "i'ere fore,.this change functions to other The change is designated as administrative as it changes Ilwent0roe1f a test with no is editorial.

change in intent.

I Page 22 ol 24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

- . t ITS Requirement CTS Requirement DOC No. Description of Change iTS Requirement CTS Requirement I -

CTS 3.10.4 states that the limitations of Specification 3.4.1.I may be suspended during the None 3.10.4 3.4.19 A.4 performance of startup and PHYSICS TESTS provided the THERM Al. POWER does not exceed the P-7 Interlock Setpoint and the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are set ; 35% and

• 25% of RATED THERMAl, POWER, respectively.

ITS 3.4.19 states that the requirement of LCO 3.4.4, "RCS Loops - MODES I and 2," may be suspended with THERMAL POWER < P-7. This changes the CTS by eliminating the requirement that the Reactor Trip Setpoints onihe OPERABLE hIntermediate and Power Range Channels are set 35% and < 25% of RATED THERMAL POWER, respectively.

This change is acceptable because the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are contained in LCO 3.3. I, RTS Instrumenitation. Repeating that requirement in this LCO is unnecessary. This change is designated administrative as it eliminates a repeated requirement from the CTS, resulting in no technical change to the Technical Specifications. -ti CTS 3.7.9.2 In the conversion of the North Anna Current Technical Speci fications (CTS) to tile plant specific Various A.I Improved Technical Specifications (ITS), certain changes (wording pirfcrences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 I, Rev. I, "Standard Technical Slpccifications-Westinghousc Plants" (ISTS).

These changes are designated as administralive changes and are acceptaiblh because they do not I

Iresult in technical changes to the CTS. I North Anna Power Station Page 23 of 24 A - 3.4

Table A - Administrative Changes ITS Section 3.4 - Reactor Coolant System (RCS)

VPQ DCqU cne Description ol Change IT1 5 l<.qileClllenlt CTS_

I e urm n 11 11',eCl~l~l~l DOC No. None 3.7.9.2 None 3.7.9.2-CTS 3.7.9.2 CTS 3.7.9.2 Action states that when an RHR subsystem is inoperable, it must he immediately by alternate A.2 restored to OPERABLE status or RCS temperature must be maintained below .i50'F also states that the provisions olfSpecificaliions ".0.3, 3.0.4, and 4.0.4 heat removal methods. It 3.4.6 Actions do not contain exceptions to these specifications. Other are not applicable. ITS changes to the CTS 3.7.9.2 Action are describcd in L.5.

ions. Under the This change is acceptable as it results in no technical changes to the Specifical RCS tempera lure is not kept below CTS, if an RI-R subsystem is not restored immediately or lower node is not required.

350'F, no 3.0.3 entry is required and, as a result, a shutdown to a actions must be initiated to restore a Under the ITS, if a required RHR subsystem is inoperable, to a lower modIe is required.

second coolant loop to OPERABLE status but no shutdown Therefore, eliminating the explicit 3.0.3 exception does not result in l technical change to the Technical Specifications. Under the CTS, if an RHR subsystem is inopcirablc, Specifications 3.0.4 and 4.0.4 are not applicable and, therefore, MODE changes arem not prohibited. However, 0 are the entry conditions the CTS Action requires RCS temperature to be kept below 35 'F, which for the next higher MODE. Therefore, under the CTS, MODE chanj-es to a higher MODE are 3.0.4 or 4.0. With a required RHR loop inoperable, prohibited without reliance on Specifications ITS 3.0.4 also prohibits transition to a higher mode. This change is dcsýignated a:, administrative as it eliminates allowances that tire provided by other nicans in the ITS. I I

Pagc 24 of 24 A - 3.4 North Anna Power Station

Table A - Administrative Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.5.1 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

3.5.1 A.2 CTS LCO 3.5.1 states each reactor coolant system accumulator shall be OPERABLE and states 3.5.1 3.5.1 accumulator requirements that must be met for each accumulator to be OPERABLE. ITS LCO 3.5.1 states three accumulators shall be OPERABLE. This changes CTS by moving the specific accumulator requirements to Surveillances.

This change is acceptable because ITS SR 3.0.1 states that failure to meet a Surveillance is failure to meet the LCO. The movement of this information firom the LCO to the Surveillances results in no change to the OPERABILITY requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

3.5.1 A.3 CTS 3.5.1 does not contain a specific ACTION for two or more aCcumulators inoperable. With 3.5.1 Action D 3.0.3 two or more accumulators inoperable, CTS 3.0.3 would be entered. ITS 3.5.1 ACTION D directs entry into LCO 3.0.3 when two or more accumulators are inoperable.

This change is acceptable because the actions taken when two or more accumulators are inoperable are unchanged. Adding this ACTION is consistent with the ITS convention of directing entry into LCO 3.0.3 when a condition represents a loss of safety function. This change is designated as administrative because it does not result in technical changes to the CTS.

3.5.1 A.4 CTS Surveillance 4.5.l.b requires the accumulator boron concentration to be verified after each SR 3.5.1.4 Note 4.5.I.b solution volume increase ofŽ> 5% of accumulator tank volume. ITS SR 3.5.1.4 Frequency includes a Note clarifying that this boron concentration verification need only be performed on the affected accumulator.

This change is acceptable because it is consistent with the current use and understanding of the Surveillance. Testing is unnecessary on accumulators not affected by a solution volume increase.

This change is designated as administrative because it does not result in technical changes to the CTS.

North Anna Power Station Page I of 6 A -3.5

Table A -- Administrative Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.5.1 A.5 CTS 3.5.1 Applicability is modified by a Note restricting the MODE 3 applicability to when 3.5.1 3.5.1 Note pressurizer pressure above 1000 psig. ITS 3.5.1 Applicability restricts MODE 3 applicability to when RCS pressure is above 1000 psig.

This change is acceptable because the difference between pressurizer pressure and RCS pressure is not significant, though pressurizer pressure and RCS pressure do differ somewhat due to the elevation head of the pressurizer. Specifying RCS pressure instead of pressurizer pressure provides consistency with the instrumentation actually used to meet the LCO. This change is designated as administrative because it does not result in technical changes to the CTS.

Page 2 of 6 A-3.5 North Anna Power Station

Table A - Administrative Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.5.1 A.6 CTS 3.5.1, Action a states that if an inoperable accumulator is not restored to OPERABLE status 3.5.1 3.5.1 within one hour, the unit must be placed in IIOT SHUTDOWN within the next 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. CTS 3.5.1, Action b states that with one accumulator inoperable due to the isolation valve being closed, if the valve is not immediately opened, the unit be in HOT STANDBY within one hour, and HOT SHUTDOWN within the next 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. CTS 3.0.1 states that the LCO and Action requirements are applicable during the Operational Modes or other conditions specified for each Specification. RCS pressure is not part of the definition of I-OT STANDBY or HOT SHUTDOWN in the CTS or MODE 3 or MODE 4 in the I'TS. The Applicability of CTS 3.5.1 is MODES 1,2, and MODE 3 with pressurizer pressure > 1000 psig, so the LCO and Actions become not applicable in MODE 3 with pressurizer pressure < 1000 psig, and entry into HOT SHUTDOWN (MODE 4) is not required.

ITS 3.5.1, ACTION B.lI requires that with one accumulator inoperable for reasons other than boron concentration not within limits, that the accumulator be restored to OPERABLE status within one hour. If the accumulator is not restored to OPERABLE status within one hour, ITS 3.5.1 Action C. I requires entry into MODE 3 within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />, and Action C.2 requires RCS pressure be _<1000 psig within 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. This changes the CTS by replacing the requirement to be in HOT SHUTDOWN within 13 hours0.542 days <br />0.0774 weeks <br />0.0178 months <br /> of the inoperability with a requirement to reduce RCS pressure to < 1000 psig while in MODE 3 within 13 hours0.542 days <br />0.0774 weeks <br />0.0178 months <br />. Reducing pressurizer pressure to _<

1000 psig while in MODE 3 in the CTS would remove the unit from the MODE of Applicability, and placing the unit in MODE 4 would not be required, making the Required Actions of the CTS and ITS the same, though described differently. The addition of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time limit to be in MODE 3 is described in Discussion of Change M. 1, This change is acceptable because the time to reduce RCS pressure to _<1000 psig while in MODE 3 is still 13 hours0.542 days <br />0.0774 weeks <br />0.0178 months <br /> from the time of the inoperability. This change clarifies an existing requirement. This change is designated as administrative because it does not result in technical changes to the CTS.

Page 3 of 6 A -3.5 North Anna Power Station

Table A - Administrative Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.5.1 A.7 CTS 4.5.1.1 .b requires each accumulator be demonstrated OPERABLE, "At least once per 31 SR 3.5.1.4 4.5.1. 1.b days and within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> after each solution volume increase of greater than or equal to 5% of tank volume by verifying the boron concentration of the accumulator solution." ITS SR 3.5.1.4 requires verifying boron concentration every 3 1 days and once within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> after each solution volume increase ofŽ> 50% of indicated level that is not the result of addition from the refueling water storage tank. This changes CTS by changing the parameter value of solution volume increase of greater than or equal to 5% of tank volume to solution volume increase of>_ 50% of indicated level. Changes associated with adding the criteria that the verification is not required when the volume increase is tile result of addition from the refueling water storage tank is addressed by DOC L.4.

This change is acceptable because a solution volume increase of> 5% of tank volume correlates to a solution volume increase of>- 50% of indicated level. This change is consistent with NUREG- 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS). This change is designated as administrative because it does not result in technical changes to the CTS.

3.5.2 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

3.5.3 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. I, "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.

North Anna Power Station Page 4 of 6 A -3.5

Table A - Administrative Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.5.3 A.2 CTS Surveillance 4.5.3.1 states that the ECCS subsystem shall be demonstrated OPERABLE per SR 3.5.3.1 4.5.3.1 the applicable Surveillance Requirements of 4.5.2. ITS SR 3.5.3.1 states the specific Surveillances in Specification 3.5.2 which must be performed.

This change is acceptable because the change is editorial. The Surveillances listed in ITS SR 3.5.3.1 are those that are considered "applicable" under the CTS. All Specification 3.5.2 Surveillances are included in SR 3.5.3.1 except those that are not applicable in MODE 4. SR 3.5.2.2 verifies that ECCS valves are in their proper position to respond to an accident. It is excluded because valves are allowed to be positioned manually to align the flow paths due to reduced RCS pressure. This reduced pressure allows more time for the ECCS to deliver water to the core in the event ofan accident in MODE 4. SR 3.5.2.5 and 3.5.2.6 verify actuation of components on an actuation signal. They are excluded because the ECCS actuation system is not required to be OPERABLE in MODE 4. This change is designated as administrative because it does not result in technical changes to the CTS.

In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.5.4 A.I Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

3.5.4 A.2 CTS LCO 3.5.5 contains a list of requirements that must be met for the Refueling Water Storage SR 4.5.5 3.5.5 Tank (RWST) to be OPERABLE. ITS LCO 3.5.4 still requires the RWST to be OPERABLE, but the requirements for OPERABILITY are moved to the Surveillances.

This change is acceptable because, in accordance with SR 3.0.1, failure to meet a Surveillance is failure to meet tile LCO. Therefore, the movement of the requirements from the LCO to the Surveillances results in no changes to the OPERABILITY requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.5.5 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. I, "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.

Page 5 of 6 A-3.5 North Anna Power Station

Table A - Administrative Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

Ii I.equIreL1IeILL Description of Change I FFSlRequiremntt u i1 J,\eqLLIl- [l;lltL DOC No. 3.46.2Acton rate, CTS 3.4.6.2 Action b states that with any RCS leakage greater than the controlled leakage 3.5.5 Action A 3.4.6.2 Action b 3.5.5 A.2 seal with reduce the leakage rate to within limits within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />. ITS 3.5.5 Action A states within injection flow not within limit, adjust manual seal injection throttle valves to give a flow valve full limit with RCS pressure Ž-2215 psig and < 2255 psig and the seal injection modulating open within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />. This changes CTS by providing more detail for the Action.

is ITS 3.5.5 Action A provides detail of how CTS 3.4.6.2 Action B is carried out. This change CTS.

designated as administrative because it does not result in technical changes to the -+

Various t Various Current Technical Specifications (CTS) to the plant specific Various Various 3.5.6 A.I In the conversion of the North Anna (ITS), certain changes (wording preferences, editorial Improved Technical Specifications NUREG changes, reformatting, revised numbering, etc.) are made to obtain consistency with 143 1, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

they do not These changes are designated as administrative changes and are acceptable because result in technical changes to the CTS. -i Injection Tank 3.5.6 A.2 CTS LCO 3.5.4.1 contains a list of requirements that must be met for the Boron SRs 3.5.6.1, 3.5.6.2 aild 3.5.6.31 13.5.4.1I and 4.5.4.1t LCO 3.5.6 requires tile BIT to be OPERABLE, but tile (BIT) to be OPERABLE. ITS requirements for OPERABILITY are moved to Surveillances.

Surveillance is This change is acceptable because, in accordance with SR 3.0.1, failure to meet a LCO to the failure to meet the LCO. Therefore, the movement of these requirements from the change is Surveillances results in no changes to the OPERABILITY requirements. This it does not result in technical changes to the CTS.

designated as administrative because I

Page 6 of 6 A-3.5 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems DOc No.

- DOC o.

Description of Change escipton o'Cl,,VarcIou

[ITS Requirement VaIr.ious-CTS Requirement A.I In the conversion of the North Anna Current Technical Speci fications (CTS) to the plant specific VariouIs Var1iouIs 3.6.1 Improved Tcchnical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are madc to obtain consistency with NUREG 143 1, Rev. I, "Standard Technical Specihications-Westiughouse Plants" (ISTS).

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

I --di - ..

3.6.1 A.2 CTS 4.6.1.I.b states, "Primary CONTAINMENT INTEGRITY shall he demonstrated...By None 4.6.1I.1I.1b is OPERABLE pcr Spccification 3.6. 1.3." ITS does not verifying that each containment air lock by not include tile refecrence to CTS 3.6.1.3, which is changed to ITS 3.6.2. This changes the CTS including a reference to another LCO that is rcquircd in the same Modes of Applicability each regardless of the refcrence. Tile pu,rpose of the CTS 4.6. I. I .b is to provide assurance that containment air lock is performing its f'unction in support of CONTAINMENT INTEGRITY.

are This change is acceptable becausec ITS 3.6.2 provides assurance that containment air locks because OPERABI.E without the irefcrence in 3.6. I. This change is designated as administrative it does not result in technical changes to the CTS. I.LCO 3.6.1 Action I I.C'O 3.6.1.2, specific 10 3.6.1 A.3 CTS L.CO 3.6.1.2, 3.6.1.2 Action, and Surveillance Rcquirement 4.6.1.6.1 reference ILCO A.l, SR3.6.3.6.1.1, 1, Action ICO 3.6.1.23,6.1.2, Action, 4.6.1.2 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria. CTS 5.5.16 Surveillance I requires also states, "The provisions of Speciflication 4.0.2 are not applicable." ITS I.,CC 3.6. 4.6.1.6.1, 4.6.1.2 statLS, that containment be Operable, Action A. I requires the containment lie restored to Operable examinations and leakage and Surveillance Requirement 3.6.1. I requires plerormance of visual Leakage rate testing excelit for containment air lock testing, in accordance with the Containment of SR 3.0.2 Jo not apply to the test Rate Testing Program. ITS 5.5.16 states, "The provisions

'esting Program.. This changcs CrI'S by frequencies spcciflicd in the Containment Leakage Rate J, Option B requirements, staling that SR 3.0.2 referencing the appropriate 10 CFR 50, Appendix the (vice CTS 4.0.2) is not applicable, and placing other specific leakage rate (.ritvria in Containment Leakage Rate Testing Program requirements in ITS 5.5.16.

will be The purpose of ITS 3.6. I is to ensure that the structur al integrity of the contai nit facility. This-change is maintained comparable to the original design standards for thl lifec of the Option B rcquirei-ncns, and other acceptable because the appropriate 10 CFR 50, Appendix J, the specific leakage rate criteria are retained inl tile Technical Specilfications as part of ITS 5.5.16, Containment Leakage Rate Testing Program. This change is designated as administrative biecatse it does not result in technical changes to the CTS.

I Page I of 15 A - .3.0 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems

. . I- - I Fil e D I'll..;.,.".",- i Iellic, DOC No. Description of*Chanlge ITS,' Requirl'llement CTS.1 lRCCtlll-CIll)lM I Ir3.6.1.1, 3.6.1.2, CTS 3.6.1.2 3.6.1I ~ ~ - _. - -

3.6.1 A.4 CTS 3.6. 1.1 states, "Primary CONTAINMENT INTEGRITY shall be maintained." 3.6.1.1,3.6.1.2, 3.6.1.6 requires that the requires containment leakage rates be within specified paraneters. CTS 3.6.1.6 CTS 1.6 states, structural integrity ol the containment be maintained within specified parameters.

"Conltainmlent shall be "CONTAINMENT INTEGRITY shall exist when..." ITS 3.6.1 states, containmelnt requirements of CTS OPERABLE. " This changes the CTS by combining the The purpose of CTS 3.6.1. I, CTS 3.6.1.2, 3.6. 1. 1, CTS 3.6.1.2, and CTS 3.6.1.6 into one LCO.

pertaining for containment OPERABILITY.

and CTS 3.6.1.6 is to provide requirements LCO, ITS 3.6. I, centralizes This change is acceptable because moving these requirements to one the requirementts. This change is designated as administrative because it does not rcsult in technical chan 'es to the CTS. i i limits are not met 3.6.1 A.5 C-TS 3.6.1I.2 Action does not state what action to take ir specific leakage rate 3.6.o Required A None and includes a requirement that the limits be met prior to Action A. I while in the MODES of Applicability, CTS 3.6.1.2 is not met entering the MODES of Applicability. Entry into CTS 3.0.3 is required if to pr-epare and req uirtes the Unit to while in the MODES of applicability. CTS 3.0.3 allows I hour ITS 3.6.1 REQUIRED ACTION be in MODE 3 within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> and MODE 5 within 36 hours1.5 days <br />0.214 weeks <br />0.0493 months <br />.

it must be restored to OPIRAB3LE status within A. I requires that if the containment is inoperable, that il the Required Action and associated 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. ITS 3.6. I Required Action A. I requires MODE 5 within 36 Completion Time are not met, the unit be in MODE 3 within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />, and stating the Rcquircd Actions rather than del'(Irri,-" to CTS 3.0.3.

hours. This changes CTS by within a The purpose of CTS 3.0.3 is to place the unit outside the MODE of Applicability on these actions, reasonable amount of time in a controlled manner. CTS 3.6.1.2 is silent 3.0.3 for the actions to accomplish this. This change is acceptable because the d(eferring to CTS lhe unit outside Required Actions speciflied in ITS 3.6.1 adopt standard ITS structure for placing to enter MODE 3 and MODIE 5.

the MODE of Applicability without changing the time spccified in technical changes to the This change is designated as administrative because it does not resull CTS. i* t to the plant specific 3.6.2 A.I In the conversion of the North Anna Current Technical SpeciIIications (CTS) Var1iouIs VariouIs prelfcrences. editorial Improved Technical Specifications (ITS), certain changes (wording with NURFG changes, reformatting, revised numbering, etc.) are made to obtain consistency 143 1, Rev. I, "Standard Technical Speci f'ications-Westinghouse Plants" (ISTS) do not result in technical These changes are designated as administrative changes because they changes to the CTS. I I Page 2 of 15 A -3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems I. IIS Rcq nit etnent t L 15 t(cquiretuent

________ of Changc Description of'Chiange I- CT1 R¢eqtllrellienl DOC No. Description I IT S Re qtUrlellICI t None 3.6. I.3, Action a. I

..vnd either restore the 3.6.2 A.2 CTS 3.6. 1.3 Action a. I includes an Action requirement that states, ".- None 3.6.1.3, Action a. I inoperable air lock to OPERABLE status..." ITS 3.6.2 Condition A doiws not include such an that . orrecting the cause of Action Requirement. This changes CTS by not explicilly stating Condition entry allows the Condition to be exiled.

that one option For The purpose ol tie statement in CTS 3.6.1.3 Action a. I is to make it clear LCO. This change is acceptable because the concept is stated in exiting a Condition is to meet the as administrative because it does not resulti . dtechnical pIS 3.0.2. This change is designated changes to the CTFS. plcbC CTS 3.0).4 3.0).4 are not Notie I 3.6. 1.3 .a.4 CTS 3.6.1.3.a.4 states, "The provisions of'Specif'ication condition shall not None 3.6.1.3.a.4 or other specified applicability 3.6.2 A.3 states, "Entry into in OPERATIONAIL MODE_ reliance Oil Condition for1Operation aVCeTMetWithout be made unless the conditions of the Limliting ITS 3.6.2 does not unless otherwise excepted."

provision contained in the ACTION statements entry into a contain the exception to ITS 3.0.4. ITS 3.0.4 states that when an LCO is riot met, the Applicability may he made when the associated MODE or other specified condition in specified condition in ACTIONS to be entered permit continucd operIation in the MODE or ot hcr unlimited period of' titne. Tbhis changes CTS by de :Iting a refekrence to a the Appplicability for an longer required. The requirement which is changed in ITS in such a way that the reference is nil 3.0 4.

purpose of CTS 3.6.1.3.a.4 is to provide an exception to the CTS slrihb tha( these exceptions This change is considered acceptable because ITS 3.0.4 is structured period of time, are not required. ITS 3.6.2 Actions allow continued operation for an unlimited as the CTS Actions. This which together with ITS 3.0.4 result in the same technical requi rements in technical changes to the CTS.

change is designated as administrative because it does not result None 3.6.1.3, Action a.2 may then continue CTS 3.6.1.3 Action a.2 includes an Action requirement that states, "Optiratiom test prv'led ;hat.. " b.ut does not until performance of the next required overall air lock leakage to entering the C(odition. ITS 3.6.2 does include a requirement to perform such a test in response deleting an exclusion1 lt ;itnAction that is riot not include such a statement. This changes CTS by required.

next required owve.ra!l air This change is acceptable because operating until perl'ormance oftlie without the deleted reference, if the speciflied Actions are taken. This lock leakage test is allowed changes to the CTS.

change is designated as administrative because it does not result in technical Page 3 ol 15 A - 3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS Requirement CTS1S Requirement 3.6.2 A.5 CTS 3.6.1.3 states, "Each containment air lock shall be OPERABLE." CTS 3.6.1.3 Action a 3.6.2 Action Note 3.6.1.3, Actions a states, "With one containment air lock door inoperable:" an([ specifies Actions to he taken. CTS 2, Condition A and and b 3.6.1.3 Action b states, "With a containment air lock inoperable, except as a result of an Condition 13 inoperable air lock door," and specifies Actions to be taken. ITS Actions NOTE' 2 states, "Separate Condition entry is allowed for each air lock." ITS Condition A states. "One or more containment air locks with one containment air lock door inoperable," and ITS Condition C states, "One or more containment air locks inoperable lor reasons other than Condition A or B."

This changes CTS by clarilying the current intent of applying the Actions to each air lock separately.

The purpose of CTS 3.6.1.3 is to ensure containment air locks mcec their requirements for containment OPERABILITY. One OPERABLE air lock door in each containment air lock provides a pressure boundary, and applying the Actions for one inoperable air lock door to each of the air locks separately is appropriate. ITS 3.6.2 Actions NOTE 2 clearly states this. The Required Actions for each Condition provide appropriate compcnsato ry action for each inoperable air lock. This change is acceptable because it clarilies existing requitrements and better describes how the requirements are currently used. This change is designated as administrative because it does not result in technical changes to the CTS.

3.6.2 A.6 CTS 3.6.1.3 does not include a relfrence to entering applicable Conditions and Required Actions 3.6.2, Actions Note 3.6.1.3 of the Containment OPERABILITY LCO (CTS 3.6. 1. 1). ITS 3.6.2 Actions NOTE 3 states, 3 "Enter applicable Conditions and Rcquircd Actions of LCO 3.6. 1, "Cdntaininctnl,' whten air lock leakage results in exceeding the overall containment leakage rate." This ohingcs CTS by explicitly requiring the Containment Conditions be entered when the C'mtainment ICO is not met as a result of air lock lcakage exceeding limits.

This change is acceptable because it reinforces the requirement in ITSS 6. I o' nMeet ovetrall containment leakage limits. This change is designated as administrative because it does not r:esult in technical changes to the CTS.

North Anna Power Station Page 4 of'!15 A -3.6

Table A - Administrative Changes ITS Section 3.6 - Containment Systems

- -I ýo nI f C1 11 DOC No. Description of Change ITS RClil.cqtmeltcn CTS

! .. l i..c

[l'e1ll [~it1 i 3.6.2, Required I 3.6.1.3, Actions a anid CrS Action b 3.6.1.3, Acions i 3.6.2 A.7 CTS 3.6.1.3 Action a addresses one inoperable containment air lock door, 3.6.2, Required Action A, Note I and 1) air lock for reasons other than an inoperable air lock door, addresses an inoperable containment doors in one air lock being inoperable. Eilher Action a or b would which includes both air lock C when both be taken. ITS 3,6.2 NOTE I of Rcquircd Action A directs entry into Condition to clarify that doors in the same air lock are inoperable. This changes CTS by adding a NOTE are inoperable, consistent entry into Condition C is required when both doors in the same air lock with tile CTS requirement.

Action for one inoperable This change is acceptable because the CTS requircmcnt to enter one is retained in ITS door in an air lock, and another Action for two inopcrablc doors in an air lock, because it does not result in using ITS usage rules. This change is dcsignatcd as administrative technical changes to the CTS. I. LCO 3.6.2, SR I 3.6.1.3, 4.6.1.3 CFPR 50, Appendix CTS LCO 3.6.1.3 and Surveillance Requirement 4.6.1.3 rcference specific 10 LCO 3.6.2, 55. 3.6.1.3, 4.6.1.3 3.6.2 A.8 ITS LCO 3.6.2 requhires that 3.6.2.1, 5.5.15 J, Option B requirenents, and other specific leakage rate criteria.

requires performance of containmdnt air locks be Operable and Surveillance Requirement 3.6.2.1 Containment Leakage Rate containnient air lock leakage rate testing, in accordance with the appropriate 10 CFR 5(1, Appendix J, Testing Program. This changes CTS by referencing the rate criteria in the Citainmeit Leakage Rate Option B rcquirements, and other specific leakage Testing Program requirements in ITS 5.5.15.

c ntainment air locks will The purpose of CTS 3.6.2 is to ensure that tile structural integrity of Ihe be maintained comparable to the original design standards for the life of the facility. This change 10 CFR 50, Appendix J, Option Cý requirements. and other is acceptable because the appropriate part of ITS 5.5.15, the specific leakage rate criteria are retained in the Technical Specifications as as administrative because Containment Leakage Rate Testing Program. This change is dcsignatc' it does not result in technical changes to the CTS. -I _________________________________

i Page 5 of I5 A-3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems I - f II'S Requirement U I S Rcquiremcnt I Description of Change I ITS Req ulire mlCM(515 TS equirement DOC No. Notc I I 4.6.1.3

-T- SR 3.6.2.1, J, Option B requirements. and other SR 3.6.2. 1, Note 1I 4.6.1.3, 3.6.2 A.9 CTS 4.6.1.3 references spccific 10 CFR 50, Appendix lock specific leakage rate criteria. ITS SR 3.6.2. I requires perfiormance of containment air Leakage Rate 'Festing Program. ITS SR leakage rate testing, in accordance with the Containment 3.6.2.1 Note I states, "An inoperable air lock door does not invalidate the previous successful I as a performance of the overall air lock leakage test." This changes CS by Adding Note of providing a fission product barrier in the event of a "reminder that either air lock door is capable with how the leakage rate criteria are addiicssed .irc addressed by DBA. ITS Changes associated DOC A.8.

will The purpose of CTS 3.6.2 is to ensure that the structural integrity of the containment air locks the o,'iginal design standards for the liif o01 the facility. This change be maintained comparable to is acceptable because it provides additional assurance that the containment air lock rcmains rcquirements considered OPERABLE with one inoperable air lock door, consistent with current and practices. One inoperable door does not invalidate the test for the o\,cral air lock leakage test This change is because the second door is still capable of performing the safety function.

desig nated as administrative because it does not result in technical changes to the CTS.

and other 3.6.2 A. 10 CTS 4.6.1.3 rcferenccs specific 10 CFR 50, Appendix J, Option B requirements, SR 3.6.2.1, Note 2 4.6.1.3 specific leakage rate criteria. ITS SR 3.6.2. I requires perforilianice of'containnicni air lock Leakage Rate 'l' t ng Program. ITS SR leakage rate testing, in accordance with the Containment 3.6.2. I Note 2 states, "Results shall be evaluated against acceptance critcria applicable to SR must be 3.6.1. I "' This changes CTS by adding Note 2 as a reminder that the aiil. ock leakage accounted for in determining the combined Type B alld C containment leakage rate. ITS Changes associated with how the leakage rate criteria are addressed are addressed by DOC AX.

locks Thep urpose of CTS 3.6.1.3 is to ensure that the structural integrity of thc containment air

'f of the facility. This will be maintained comparable to tie original design standards for thle.

lock change is acceptable because it provides additional assurance that the ,:ontainmenl air the combincd Type B and C containnment leakage is properly accounted for in determining as leakage rate, consistent with current requirements and practices. This change ts designated administrative because it does not result in technical changes to (lie C'I S.,

-i i plant speci lic fIn the conversion of the North Anna Current Technical Specifications (C'S) to the Vari-ous VariouIs 3.6.3 A. I (wording preclrenlccs, editorial Improved Techlnical Specifications (ITS), certain changes changes, reformatting, revised numbering, etc.) are made to obtain consistency with NURI-G 1431 , Rev. I, "Standard Technical Spcci fications-Wcstinghouse Plants' (IS I'S).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS. I I Page 6 oI 15 A - 3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems I I ("I'S tRociliffellielit 11 Description of Change ITTqI Ponitin-moni 1NKe~ull-eLIIIIl~ 4-. 13 lwk.*llll 'll-c li,.lit-]

DOC No. 3.6.3, Action Note None CTS 3.6.3.1I and CTlS 3.6.5.1 do not specifically require Conditions be Lmntcrcd for systems i 3.6.3, Action Note Nonle 3.6.3 A.2 3 supported systcms is addressed supported by containment isolation valves. OPERABILITY of for each system, and appropriate LCO Actions are through the definition of OPERABILITY applicable Conditions and Required Actions For taken. ITS 3.6.3 Action Note 3 states, 'Finter isolation valves." ITS 3.0.6 provides an exception to systems made inoperable by containment solely due to) a support system LCO 3.0.2, stating, "When a supported system LCO is not tmct with hllis supported system LCO not being met, the Conditions and Required Actions associated the Safcty Function are not required to be entered." LCO 3.0.6 goes on to describe how This changes Determination Program is used to evaluate support-supported system relationships.

Conditions and Required CTS by requiring a specific statement to r'cquirC supported system NOT(E..

Actions be entered, whereas in CTS this would be done without the C'T'S requirement to take This change is acceptable because the addition of the NOTE rellects the required because ol the addition of LCO applicablc Actions for inoperable systems. The NOTE is systems inoperablec is being retained.

3.0.6, and because the requirement to declare supported it does noto rcsull in technical changes to the

'his change is designated as administrative because CTS. 3.6.3, Action Note Notic appl)licablc Conditions and 3.6.3 A.3 CTS 3.6.3. I and CTS 3.6.5.1 do not include a reference to entering 4 LCO (CTS 3.6.1, I). [ITS 3.6.3 Action Required Actions of the Containment OPERABILITY and Recquircd Actions ol I .CO 3.6. I, "Containment,"

NOTE 4 states, "Enter applicable Conditions containment leakage when leakage for a penetration Ilow path results inexceeding the overall an existing requirement ihlat the containment rate.'" This changes CTS by explicitly stating LCO is not met as a result of a1i: lock Itakage exceeding Actions be taken when the containment limits.

to mect overall This change is acceptable because it rcinlorces the existing CTS reclum-ment because it does not result containment leakage limits. This change is designated as administrativw in technical changes to the CTS.

Page 7 of 15 A - 3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems

[VS Requirenient -i CTS Requirement CTS IRquircilcnt 1 I Description of Change ITS Requirement DOC No. -41 LCO 3.0.2 I 3.6.3.l with I LCO 3.0.2 3.6.3 A.4 CTS 3.6.3.L .a requires restoring the inoperable valvc(s) to OPERABI.E status within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> 3.6.3.1 actions. ITS one or more of the isolation valves inoperable, or take one of the other specified status, 3.6.3 does not state the requirement to restorc an inoperable isolation valve to OPERABLE met or no but includes other Actions to take within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />. ITS L.CO 3.0.2 states, 'ft the LCO is of the longer applicable prior to the expiration of the specified Completion time(s), completion Required Actions(s) is not required unless otherwise stated."

explicitly stating This changes CTS by including the requirement as par( ol LCO 3.0.2, rather than an existing allowance in ITS format the allowance. This change is acceptable because it retains because it does not result in with ITS usage rules. This change is designated as administrative technical changes to the CTS.. I- 3.6.3, Conditions B I None one or mlore 3.6.3 A.5 CTIS 3.6.3. I and CTS 3.6.5. I do not include any Condition and Required Actions,I'or 3.6.3, Conditions 1 None inoperable. CTS 3.0.3 wou ld be and El penetration (low paths with two containment isolation valves "One or more penetration flow paths entered for this Condition. rIS 3.6.3 Condition B states, ITS Required Action B. I states, "Isolate tile with two containment isolation valves inopcrable."

one closed and de-activated automatic valve, affected penetration flow path by use of at least E requires the unit be closed manual valve, or blind fhange," within I hour. FTS 3.6.3 Conditi.on and MODE 5 in 36 hours if the Rcquired Actiorn and associated placed in MODE 3 in 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />, not met. Tibs changes CTS by stating the Actions to be taken for two Completion Time is isolation valves inoperable, rather than relying on CTS 3.0.3, which contains the containment same Completion Times for placing the unit outside its MODE ol Applicability.

This change is This change is acceptable because it places CTS 3.0.3 rcquiremcnts in ITS format.

not result in technical changes to tile CTS.

1 -1 designated as administrative because it does P'age 8 oI' 15 A- 3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems I

F P )Ie~UiC

.,I...ý i~

T- l'I'S Requirenient I I I Ic"FIZ

.".3.1*) A Ici I Description ol Change ITS lcq3uire.ent DOC No. [°I',S LCO 3.0.4 r3.6-.3. I Action, 3.0.4 "The provisions ol Specification 3.0.4 (do nol apply." CTS 3.6.3 A.6 states, CTS 3.6.3.1 into anstates, "EntryAction OPERATIONAL MODE or other specirlied applki-ability condition shall not for Operation are met without reliance on be made unless the conditions of the Limiting Condition otherwise excepted.' ITS 3.6.2 does not provision contained in the ACTION statements unless that when an LCO i,; not met, entry into a contain the exception to ITS 3.0.4. ITS 3.0.4 states may bc made when the associaled MODE or other specified condition in tie Applicability operation in the MODE or other speciflied condition in ACTIONS to be entered permit continued changes CTS t): incorporating an the Applicability for an unlimited period of time. This allowance into ITS LCO 3.0.4.

3.0.4 is changed in ITS such that the NOTEL is This change is considered acceptable because LCO 3.6.2 Actions allow continued operation Iom not required to retain the same CTS requirement. ITS 3.0.4 result in the same technical an unlimited period of time, which together with ITS This change is designated as administrative because it does not result in requirements as theto CTS.

the CTIS.

technical changes SR 3.6.3.3 4.6.3.1.3 the isolation time of each power operated or automatic containment

.6.3 A.7 CTS 4.6.3.1.3 requires tested pursU.toi l eSp", il'ication 4.0.5.

isolation valve be determined to be within its limit when ofreach automatic power operated ITS SR 3.6.3.3 requires verilying the isolation time a Frcquency in accorwtincc with the Inservice containment isolation valve is within limits, with by stating that the Frequency is in ai.,..-ordance with the

'resting Program. This changes the CTS is to vcrify the isolation time of each Inservice Testing Program. The purpose ol CTS 4.6.3.1.3 valve is tested in tii -)rcdai)cc with the" power operated or automatic containment isolation Inservice Testing Program.

regarding the power ope rated oi This change is acceptable because the test requirements The ITS SR,3 6.3.3 Frequency remains automlatic containment isolation valves remain the same.

4.0.5 have been rcil(,,atecd to' the Inservice unchanged. The inservice testing requirements of CTS ITS. This change is dcsi onated as administrative

'resting Program contained in Section 5.5 oflthe to the CTS.

because it does not result in technical changes A --3.6 Page 9 o1 15 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems ITS Requiriment CTS RCequiremenl Description of Change 3.6.3. I Action, DOC No. 3.6.3 Actions Note valves inopoerable, maintain at least 3.6.5.1 Action 3.6.3 A.8 CTS 3.6.3. I Action states, "With one or more of the isolation 2 that is opein...CTS 3.6.5.1 Action one isolation valve OPERABLE in each affectcd penetration in the steam jet air ejector suctionlIine not states, "With the inside or outside isolation valve 3.6.3 Actions NOTE 2 states, "Separate closed, restore the valve to the closed position..." ITS This changs CTS by stating an Condition entry is allowed f"or each penetration flow path."

existing allowance in ITS Format.

on how to address isolation valve The purpose of CTS 3.6.3.1 Action is to provide guidance I addresses a ;peilic penetration. ITS inoperabilities for individual penetrations. CTS 3.6.5.

in ITS format, using ITS usage rules. This 3.6.3 Actions NOTE 2 provides similar guidance does not result in technical changes to the CTS. 4.6.5.1.1 change is designated as administrative because it INone line outside isolation valve shall be 3.6.3 A.9 CTS 4.6.5. I. I states, "The steam jet air ejector suction prior to increasing the Reactor determined to be in the closed position by visual observation 0 3.6.3. I d6cs not include a reference to Coolant System temperature above 20 F and..." ITS SR temperature above 200°F. ITS SR verification prior to increasing the Reactor Coolant System or other specil'iedi conditions in the 3.0.1 states, " SRs shall be met during the MODES Applicability For individual LCOs..." This changes CTS by not including ia statement for a Section.

requirement that is already addressed in the ITS 3.0 requircment into the gencral riles forI use This change is acceptable because it incorporates a CTS is designated as administrative because it does not of the ITS in the 3.0 section. '[his change result in technical changes to the CTS. None 4.6.3.I.l.a isolation valve that is a weight or spring 3.6.3 A.lI0 CTS 4.6.3. I. I.a ,requires testing of each containnielt every 92 days. The IPS does noi contain this loaded check valve testable during unit operation this Surveillance.

I Surveillance. This changes the CTS by eliminating I 1 11 not changed. North Anna (toes This change is acceptable because the technical requirements have or spring loaded check valves which not contain any containment isolation valves that are weight is never performed. This change is are testable during unit operation. Therefore, this surveillance result in technical changes to tihe CTS.

designated as administrative because it does not A- 3.6 o I... ,n,, 1 S North Anna Power Station rag I~t.u m111kI .,

Table A - Administrative Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS Requirement I CTS Requirenlcnt 3.6.3 A.lIl CTS 3.6.3.1 Action states, "With one or more of the isolation valves inoperable, maintain at least 3.6.3 Condition A, 3.6.3.1 Action one isolation valve OPERABLE in each affected penetration that is open..." ITS Conditions A B, and C Notes, and B Notes state, "Only applicable to penetration flow paths with two containment isolation Required Action valves." ITS Condition C Note states, "Only applicable to penetration flow paths with only one A.l, 1.I, C.l, and containment isolation valve and a closed system." ITS Condition ITS 3.6.3 Required Actions A. I Condition E and C. I require the associated flow path be isolated by one of the means speciflied with one or more penetration flow paiths with one containment isolation valve inoperable. ITS 3.6.3 Required Actions A. I and C. I both assume the other isolation valve or closed system are OPERABLE for the isolation lfuncti on. If, two valves in a penetration flow path with two containment isolation valves are inoperable, Rcquircd Action B. I requires thie penetration be isolated within one hour, or Condition E is entered, requiring the unit be placcd in MODE 3 within 6 blooms, and MOI)E 5 within 36 hours1.5 days <br />0.214 weeks <br />0.0493 months <br />. In a penetrationf low path with one containment isolation valve and a closed system, where the containment isolation valve and the closed system were not capable of performing the isolation function, ]TS LCO 3.0.3 would be cntcred. This changes CTS by incorporating the concept of assuring that the second means of containment isolation f-r a penetration flow path is OPERABLE into the Conditions and Required Actions .-ssociated with ITS 3.6.3.

This change is acceptable because when one nicans of isolating a containment flow path is inoperable, tih other must be OPERABLE, or the ITS requires Required Actioins be taken For two inoperable means of isolating a containment flow path, rather than allowing the Completion Times associated with one inoperable means of isolating a containment Ilow path. This retains the CTS 3.6.3. I concept of maintaining at least one isolation valve OPERABI E in each aflected penetration that is open when one or more isolation valves are inoperable. 'Ilis change is designated as administrative because it does not result in technical chmlgeilo[lthe CTS.

3.6.3 A. 12 CTS 4.6.1 . IA states, "Each time containment integrity is established alWcIvacuum has been SR 3.6.3.4 4.6. I. I.d broken by pressure testing tile butterfly isolation valves in the containment purge lines and tlfe containment vacuum ejector line." The Applicability is MODES I, 2, 3, and 4. The Frequency for ITS SR 3.6.3.4 states, "Prior to entering MODE 4 from MODE 5 al icr contai.nent vacuum has been broken. This changes tile CTS by adopting the ISTS Frequency format fI)! such a Surveillance Requirement, clarifying that it is required to be perlormed prior to entering die MODE of Applicability each time the containment vacuum has been broken.

This change is acceptable because it clarifies the existing requirelent, hiiISTS format, to test tile relevant valves prior to entering the MODE ol Applicability each time the containment vacutm has been broken. This change is designated as administrative because it does not result in technical changes to the CTS.

L-North Anna Power Station Page I I Of* A -3.6

Table A - Administrative Changes ITS Section 3.6 - Containment Systems-IT Iqiemn Description olfChange CTS Requirement DOC No.

I1- ITS Requirement tISR 4.6. I. Ld A.13 CTS 4.6.1.1Ed states, "Each time containment integrity is established after vacuum has been IISR 3.6.3.4 3.6.3.4 4.6.1.1A~

3.6.3 broken by pressure testing the butterfly isolation valves in tile containlmimt purge lines and the for containment vacuum cjector line." ITS SR 3.6.3.4 states, "Perform leakage rate testing containment purge valves with rcsilicnt seals." This changes CTS by clarifying that the valves are those with "resilient seals." The changes being tested as part of the Surveillance Requirement moving some of the system description to the Bases is addressed by DOC LA.4.

This change is acceptable because it clarifies that the valves addrcssed by the Surveillance arc those with resilient seals, which are the valves described by the phrase, "...butterfly isolation is valves in the containment purge lines and the containment vacuum ejector line." This change designated as administrative because it does not result in technical changes to the CTS.

-I V an otis V an ous 3.6.4 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific VaiiouIs VaiiouIs Improved Technical Speci fications (ITS), certain changcs (wording preferences, editorial changes, reformatting, revised numbering, etc.) arc made to obtain consistency with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

do0not These changes are designated as administrative changes and are acceptable eI)cause they result in technical changes to the CTS.

-t i 3.6.5 A~l In tile conversion of the North Anna Current Technical Specifications (C'!'S) t1 the plant specihic Var-iouJs Var1iouIs Improved Technical Speci fications (ITS), certain changes (wording prelcl'.l:'ccrt, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NURFIG 143 I, Rev. 1, "Standard "Fcchnical Speci fications-Westinghouse Plants' WISIN).

thCey do not These changes are designated as administrative changes and are accepflibk because result in technical changes to the CTS. Va iu' 3.6.6 A.l In the conversion of the North Anna Current Technical Specifications CTS) to tde plant specific VaiiouIs VriiouIs tmproved Technical Specifications (ITS), certain changes (wording pr,.-fcenceS, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with N UREG 143 I, Rev. I, "Standard Tcchnical Speci fications-Wcstinghouse Plan's'" (ISTS).

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

I North Anna Power Station Page 12of1' 5A A - 3.6.

Table A - Administrative Changes ITS Section 3.6 - Containment Systems I . .. - -1 D escriptio nof C hiange 1 'I'Desc,.ipt..on..of.CIhInge IF Re I*,quiIr IIenIt i- t ,- k,.;keqUllrninl t 11 11 DOC No. 4.6.2.1 .a.2 water storage tank SR 3.5.4.1, SR CTS 4.6.2. .a.2 states that the temperature of the borated water in the relfueling SR 3.5.4. 1 , SR 4.6.2. 1I-a.2

.- ,-.....1 3.6.6 A.2 3! days. Figure 3,6-I states 3.6.4.1 1must be verified to be within the limits shown on Figure 3.6-I every must be <

550F. CTS LCO 3.6.1.4 and CTS 4.6.1.4 require that the that the RWST containment temperature internal air partial pressure be in compliance with Figure 3.6- i every 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. CTS and 50' every 3.5.5.c and 4.5.5.b require verification hat tlhe RWST temperature is between 40' verification or RWST temperature every 24 hours. This changes 7 days. ITS SR 3.5.4.1 requires of RWST tcmperatur cevery 7 days from the qucnch spray the CTS by eliminating the verification requirements.

changed. The This change is acceptable because the technical requirements have not ITS SR 3.6.4. 1, and ITS i-equircmcnts to verify RWST temperature in CTS 3.6.1.4, CTS 3.5.5, in CTIS 4.6.2.  ! .a.2. Thereflore, thc SR 3.5.4. I are performed more frcquently than the requirement plant operation. [his chainge is dcsignatcd as elimination of this Surveillance has no e fecet on result in technical changzes to the CTS.

administrativee because it does not i 1-to the plant specific In the conversion of the North Anna Current Technical Specifications (CTS' Various VaiiouIs 3.6.7 A.lI editorial Improved Technical Specifications (ITS), certain changcs (wording prclclcnccs, nu nlbcring, ctc.) arc made to obtain col Sistcic with y' N I P, :'G changes, reformatting, reviscd (f.IS'S).

143 I, Rev. I, "Standard Technical Spcoi licatioris-WestinghouSc Plants" These changes changes are designated as administrative changes because they dot not result in technical to the CTS.

-i i OPERABLE. ITS 3.6.7 3,6.2.2 3.6.7 A.2 CTS 3.6.2.2 states two trains of containment recirculation spray shall hc ILCO 3.6.7 This cmangss the CTS by states four Recirculation Spray (RS) subsystems shall be OPERABI.F..

t The pt-sc specifying that the four subsystems that make up the two RS trains be OPE'RARIE.

rains t beý OIl RABLI-I.

of CTS 3.6.2.2 is to have the required equipment available for two RS so requiring the This change is acceptable because a train of RS is made up ol" two subsystems, to requiring two RS trains to be OPERABLE.

four RS subsystems to be OPERABLE is equal does not result in technical changes to tihe This change is dcsignated as administrative because it CTS. I-I

-- l Page 13of'15 A -3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems 11 -I ,'-c ', - . . . . f ( - V1'C min)l t' Description of Change I ITS

. Ke,.quiIUellUIlt IL

" I,) l3.6. 2-.llvl-l DOC No. LCO 3.6.7 that must be met fo'r the ILCO 3.6.2.2.1) 3.6.7 A.3 CTS LCO 3.6.2.2.b states the casing cooling tank solution requirements SLCO 3.6.7 ca-ing cooling tank to be casing cooling tank to be OPERABLE. ITS LCO 3.6.7 requires the Requnrcmcnts OPERABLE, but the spccilic solution requirements are moved to the Surveillance OPERABILITY from the LCO tomoving parameter Icquircnienls tthat must be met for (SRs). This changes the CTS by the SRs.specific The purpose ol CTS 3.6.2.2.b is to have the casing tile required limits.

cooling tank OPERABLE with the solution parameters within meet a SR is failut, to meet This change is acceptable because ITS SR 3.0. I states that faiure to the SR r.-sults in no change to the the LCO. The movement o Ithis information from the LCO to as administrative because it does not OPERABILITY requirements. This change is designated result in technical changes to the CTS. 3.6.7, Condition G None and one outside RS 3.6.7 A.4 CTS 3.6.2.2 does not contain an ACTION for one inside RS subsystem RS subsystkms inoperable, or for subsystem inoperable not in the same train, or for two outside CTS 3.0.3 would be entered. ITS three or more RS subsystems inoperable. In these conditions to enter ITS 3.0.3 for these conditions.

3.6.7 CONDITION G includes a REQUIRED ACTION for one inside RS subsystem and one outside CTS 3.6.2.2 inipl icitly requires entry into CTS 3.0.3 or for two outside RS siubsystcnms inoperable, or RS subsystem inoperable not in the same train, by omitting ACTIONS for these conditions.

for three or more RS subsystems inoperable, instead of This change is acceptable because it provides explicit direction to enter ICO 3.0.3 as relying on the Section 3.0 usage rules to imply LCO 3.0.3 entry. This lhamc is de;ignateld administrative because it does not result in technical changes to theC -I_'s.____

0,'I-TS) to (he plant specific IVariouIs VarliouIs 3.6.8 A. I In the conversion of the North Anna Current Technical Specifications (ITS), certain changes (wording prefereces, editorial Improved Technical Specifications numbering, etc.) are made to obtain consistency with NUP REG changes, reformatting, revised Plants' (ISTS).

1431, Rev. 1, "Standard Technical Specifications-Westinghouse These changes are designated as administrative changes and are acceptible because they do not result in technical changes ICthe CTFS._......__ ILCO 3.6.8 .6.2.3 for the Chemical Addition 3.6.8 A.2 CTS LCO 3.6.2.3 contains a list of requirements that must be met the Chemical /\dtition Syst6m Io be System to be OPERABLE. ITS LCO 3.6.8 still requires are moved to Surveillances.

OPERABLE, but the requirements for OPERABILITY is failuWe This change is acceptable because ITS SR 3.0. I states that failure to med a Surveillance in Ile movement of this inlormation from the i.CO to tho wSmr,.il lanccs results to meet the LCO. Ihe no change to the OPERABILITY requircmints. This change is dcsigmil cd as admrinistrative because it does not result in technical changes to the C'S. I I Page 14o1f15 A -3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.6 - Containment Systems Description ol Change ITS Rcquircement CTS Requirement DOC No.

plant specitic Var'iois Vaious 3.6.9 A. I In the conversion of the North Anna Current Technical Specil'ications (CTS) to the improved Technical Spccilications (ITS), certain changes (wording prcfercnces, editorial changes, reformatting, revised numbcring, etc.) are made to obtain conskiency with NURIG 1431, Rev. I, "Standard Technical Specil'ications-Westinghousc Plants" (IlS).

These changes arc designated as administrative changes and are acceptable because they do not result in technical changes to the CTS._II Page 15 of I'I. A - 3.6 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.1 A.lI In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

3.7.1 A.2 CTS Table 3.7-1 states the maximum allowable Power Range Neutron Flux - High setpoint as a TFable 3.7. 1- I Table 3.7-I function ofthe number of inoperable main steam safety valves. ITS Table 3.7.1I-1 states the maximum allowable Power Range Neutron Flux - High setpoint as a finction of the number of OPERABLE main steam safety valves. This changes the CTS by stating the maximum allowable Power Range Neutron Flux - High setpoint as a function of the number of OPERABLE, vice inoperable, main steam safety valves.

This change is acceptable because the maximum allowable Power Range Neutron Flux - Iligh setpoint for a condition of the main steam safety valves has not changed. This change is designated as administrative because it does not result in a technical change to the specifications.

3.7.1 A.3 CTS 3.7.1.1 states, "All main steam line code safety valves associated with each steam generators 3.7.1 3.7.1.1 of an unisolated reactor coolant loop shall be OPERABLE with lift settings as specified in Table 3.7-2." ITS 3.7.1 states, "Five MSSVs per steam generator shall be OPERABLE." This changes the CTS by stating the number of MSSVs required to be OPERABLE per steam generator, eliminating a reference to unisolated loops, and eliminating a reference to Table 3.7-2.

This change is acceptable because the technical requirements have not changed. Each steam generator has five MSSVs. Therefore, "All" MSSVs per steam generator and "Five" MSSVs per steam generator is equivalent. In the MODES of applicability of this specification (MODES 1,2, and 3), all RCS loops are required to be unisolated in accordance with ITS 3.4.17. Therefore, this reference to unisolated loops is unnecessary. In the ITS, the Table equivalent to CTS Table 3.7-2 is referenced in Surveillance 3.7.1.1. SR 3.0.1 states that failure to meet a Surveillance is failure to meet the LCO. Therefore, moving the Table reference from the LCO to a Surveillance has no effect. These changes are designated as administrative because they do not result in technical changes to the specifications.

North Anna Power Station Page I of 13 A -3.7

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.2 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. I, "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.

3.7.2 A.2 CTS Surveillance 4.7.1.5 states that the MSTV shall be demonstrated OPERABLE by full 3.7.2.1 4.7.1.5 closure within 5 seconds when tested pursuant to Specification 4.0.5. Specification 4.0.5 refers to the Inservice Test Program requirements. ITS SR 3.7.2.1 states each MSTV is verified OPERABLE with a closure time of< 5 seconds in accordance with the Inservice Testing Program. This changes the CTS by replacing a reference to CTS 4.0.5 to a reference to the Inservice Testing Program.

This change is acceptable because the requirements have not changed. Both the CTS and the ITS state that the MSTVs must be tested in accordance with the Inservice Testing Program. This change is designated as administrative as the technical requirements are not changed.

3.7.3 None N/A N/A N/A 3.7.4 None N/A N/A N/A 3.7.5 A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

North Anna Power Station Page 2 of 13 A -3.7

Table A - Administrative Changes ITS Section 3.7 - Plant Systems

. . - - I Tequ I i-eni I DOC No. Description of Change I1Sequirement IT CTS R¢equiremnent

- .2.a. I I SR 3.7.5.1 I

4.7.1 3.7.5 A.2 CTS 4.7.1.2.a. I requires verification that each AFW valve in the flow path not locked, sealed, or SR 3.7.5.1 4.7.1.2. a.1I otherwise secured in position is in its correct position. ITS SR 3.7.5.1 requires verification that each AFW valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump not locked, sealed, or otherwise secured in position is in its correct position.

This changes CTS 4.7.1.2.a. I by expanding the description of the applicable flow path to specifically include the steam supply valves (MS-TV-I I1A and MS-TV- I I I B for Unit I and MS-TV-21IA and MS-TV-21I B for Unit 2) to the turbine driven AFW pump. These valves are required to be verified by CTS 4.7.1.2.a.

This change is acceptable because CTS 4.7.1.2.a. I is currently considered to be applicable to all valves in both water and steam flow paths. Therefore, the methodology for the surveillance requirement remains technically the same. This change is designated as administrative because it I not modify the CTS requirement.

AI does i- - -l, ,

3.7.5 A.3 CTS LCO 3.7.1.2 states the requirements for the AFW system in terms of"puinps and associated 3.7.5 3.7.1.2 flow paths." CTS 3.7.1.2 Actions a, b, and c refer to the requirements in terms of "pump" or "pumps" when addressing the AFW system. ITS LCO 3.7.5 and the associated ACTIONS state the requirements in terms of "trains required to be OPERABLE". A train consists of a pump and the associated flow path from the Emergency Condensate Storage Tank (ECST) to the associated steam generator (SG). This changes the CTS by adding the term "train" to the CTS to clarify the requirements for the AFW system.

The change is acceptable because it maintains the current technical requirements interpretations of the CTS that pumps, referred to in the ACTIONS, are considered the pumps and associated flow paths as trains. This change is designated as administrative because CTS 3.7.1.2 and ITS

'1 '7 .,.-.,.-.

Cqnr hn1nmt rean,,rrnentsc plant specific Various Various 3.7.6 A.I1 In the conversion of the North Anna Current Technical Specifications (CTS) to the editorial Improved Technical Specifications (ITS), certain changes (wording preferences, changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

Page 3 of 13 A-3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement CTS 3.7.1.3 ACTIONS require if the condensate storage tank (CST) becomes inoperable, within 3.7.6 Action A 3.7.1.3 Actions and 3.7.6 A.2 four hours restore the Emergency Condensate Storage Tank (ECST) is restored to OPERABLE 4.7.1.3.2 status or be in HOT SHUTDOWN within the next twelve hours. The OPERABILITY of the CST to act as a backup water supply to the AFW pumps must be demonstrated if the ECST is not returned to OPERABLE status within four hours. The ECST must be restored to OPERABLE status within seven days or the plant must be placed in HOT SHUTDOWN within the next twelve hours. In addition to these requirements, CTS surveillance 4.7.1.3.2 states the CST shall be demonstrated OPERABLE at least once per twelve hours. This requirement is accomplished by verifying the water level in the CST is sufficient to replenish the ECST to 110,000 gallons whenever the CST is the supply source for the AFW pumps. ITS 3.7.6 ACTION A requires, if the ECST is inoperable, a verification by administrative means of the OPERABILITY of the CST within four hours and once per twelve hours thereafter. Additionally, the ECST is required to be returned to OPERABLE within the next seven days. This change maintains the CTS requirements in the ITS format.

The change is acceptable because the ITS maintains the technical requirements of the CTS ACTIONS and Surveillance. ITS ACTION A. I and CTS ACTION b. and CTS Surveillance 4.7.1.3.2 require the verification of the CST to act as a backup to the ECST. The verification will be performed within four hours of the inoperability of the ECST and every twelve hours thereafter. ITS ACTION A.2 and CTS ACTION b. require the restoration of the ECST to OPERABLE status within seven days. The change is designated as administrative because all technical requirements of the CTS are maintained within the ITS requirements.

3.7.6 and SR 3.7.1.3 3.7.6 A.3 CTS 3.7.1.3 states "The emergency condensate storage tank, (ECST) shall be OPERABLE with a 3.7.6.1 minimum contained volume of 110,000 gallons of water." ITS LCO 3.7.6 states, "The ECST shall be OPERABLE" and SR 3.7.6.1 states, "Verify the ECST contains 11 110,000 gal." This changes the CTS by moving the required volume of water in the ECST from the LCO to the Surveillance.

This change is acceptable because the requirements have not changed. ITS SR 3.0.1 states that failure to meet an SR is failure to meet the LCO. Therefore, moving the required volume from the LCO to the SR has no effect. This change is designated administrative because it does not result in a technical change to the specifications.

Page 4 of 13 A-3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.7.7 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. I, "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.

A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.7.8 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

CTS 3.7.4.1 states, "Two service water loops (shared with Unit 2) shall be OPERABLE..." CTS 3.7.8 3.7.4.1 3.7.8 A.2 3.7.4.1 Applicability states, "Either Unit in MODES 1, 2, 3 or 4." CTS 3.7.4.1 Actions b, c, and e contain requirements to place both units in HOT STANDBY. ITS 3.7.8 does not contain references to both units. This changes CTS by deleting references to both units, and writing the requirements to apply to an individual unit in the Technical Specification. The purpose ofCTS 3.7.4.1 regarding references to both units is to make it clear that OPERABILITY of the SW System affects both units.

This change is acceptable because both units are required to follow the Technical Specifications for their respective unit, and the SW System is a shared system. If a SW component is inoperable, both units enter the CONDITIONS applicable to their respective status. Therefore, eliminating the cross-unit references is an editorial change. This change is designated Page 5 of 13 A-3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement A.3 CTS 3.7.4.1 Action a states, The provisions of Specification 3.0.4 are not applicable once 3.7.8 3.7.4.1 Action a 3.7.8 component cooling heat exchanger flows are throttled." ITS 3.7.8 does not contain this exemption. This changes CTS by deleting a specific exemption to CTS 3.0.4. The purpose of the CTS 3.0.4 exemption is to provide an allowance to change MODES once the SW flow to the component cooling water (CC) heat exchangers has been throttled.

This change is acceptable because ITS 3.0.4 allows MODE changes while in CONDITIONS that permit continued operation for an unlimited period of time. CTS 3.7.4.1 ACTION a requires throttling of the SW flow to the CC heat exchanger within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> and then permits continued operation for an unlimited period of time. ITS 3.7.8 ACTION retains this REQUIRED ACTION and COMPLETION TIME. This change is designated as administrative because it does not result in technical changes to the CTS.

CTS 3.7.4.1 includes a footnote, designated "*", which allowed a temporary exemption from the N/A 3.7.4.1 footnote 3.7.8 A.4 SW System LCO to allow system upgrades to be completed. ITS 3.7.8 does not contain the temporary exemption. This changes CTS by deleting a temporary exemption from CTS requirements. The purpose of the temporary exemption was to allow system upgrades to be completed.

This change is acceptable because the temporary exemption will no longer be valid at the time of ITS implementation. This change is designated as administrative because it does not result in technical changes to the CTS.

SR 3.7.8.1 None 3.7.8 A.5 CTS 3.7.4.1 does not contain an explicit reference to isolating SW flow to individualflow to components. ITS Surveillance 3.7.8.1 contains a Note that states, "Isolation of SW individual components does not render the SW System inoperable." This changes CTS by adding an allowance is not explicitly stated in the CTS.

The purpose of the SW Technical Specification is to provide assurance that service water is available to the appropriate plant components. This change is acceptable because by current use and application of the CTS, isolation of a component supplied with service water does not result in the SW System being considered inoperable, but the respective component may be declared inoperable for its system. This change clarifies this application. This change is designated as administrative because it does not result in technical changes to the CTS.

Page 6 of 13 A-3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement A.6 CTS 4.7.4. I.c.I requires verification that each automatic valve servicing safety related equipment SR 3.7.8.2 4.7.4.1 .c. I 3.7.8 actuates to its correct position on an actual or simulated safety injection signal. ITS SR 3.7.8.2 requires verification that each SW System automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. This changes the CTS by adding the description that the valves must be in the flow path. Other changes are described in L.1, LA.5, LA.6, LA.8, and A.7.

The purpose of CTS 4.7.4. l.c.lI is to provide assurance that required SW valves are in their correct position. This change is acceptable because it clarifies that this requirement applies to valves in the SW flow path. This change is designated as administrative because it does not result in technical changes to the CTS.

CTS 4.7.4. I.c.I requires verification that each automatic valve servicing safety related equipment SR 3.7.8.2 4.7.4. .c. I and 3.7.8 A.7 4.7.4.1.c.2 actuates to its correct position on an actual or simulated safety injection signal. CTS 4.7.4.I.c.2 requires verification that each automatic service water valve actuates to its correct position on an actual or simulated containment high-high signal. ITS SR 3.7.8.2 states, "Verify each SW System automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal." This changes the CTS by combining the requirements for testing the two separate signals into one SR.

The purpose of the CTS 4.7.4. I.c. I and CTS 4.7.4.1 .c.2 is to provide assurance that the required SW automatic valves actuate to their correct position on their respective actuation signals. ITS SR 3.7.8.2 retains this requirement. This change is designated as administrative because it does not result in technical changes to the CTS.

3.7.8 A.8 Not Used.

3.7.8 A.9 Not Used Page 7 of 13 A-3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.8 A.10 CTS 3.7.4.1 Action a states that when one service water pump is inoperable, the SW flow to the 3.7.8 3.7.4.1 Action a CC heat exchangers must be throttled in accordance with approved operating procedures to ensure the remaining service water pumps are capable of providing adequate flow to the RS heat exchangers. ITS 3.7.8 The purpose of CTS 3.7.4.1 Action a is to provide assurance that component cooling heat exchanger flow is throttled within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> of a SW pump inoperability so that the SW System is available when needed.

This change is acceptable because the requirement to perform the action in accordance with approved procedures is redundant to other Specifications. ITS Section 5.4.1 requires that written procedures be established, implemented, and maintained covering activities which include the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1,33 Appendix A states that among the typical safety-related activities that should be covered by written procedures, list number 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems, instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for systems which include item "in", "Service Water System". CTS 3/4.7.4. I Action a, throttling component cooling water heat exchanger flow, would be considered changing the mode of operation of the system. Therefore, deleting this statement from CTS 3.7.4.1 has no effect on plant operation. This change is designated as administrative because it does not result in technical changes to the CTS. Actions A. I and B. I require throttling of the SW flow to the CC heat exchangers to obtain the required RS heat exchanger flow. This changes the CTS by deleting the requirement that the throttling be performed using approved operating procedures.

3.7.9 A.lI In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. I, "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.

Page 8 of 13 A-3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.9 A.2 CTS LCO 3.7.5.1 states that the ultimate heat sinks shall be OPERABLE and describes the SR 3.7.9.1 and 3.7.5.1 Service Water Reservoir parameters that must be met. ITS LCO 3.7.9 states the UHS shall be 3.7.9.2 OPERABLE, and ITS SR 3.7.9.1 and SR 3.7.9.2 contain the parameter values for the Service Water Reservoir that must be met. This changes the CTS by moving the Service Water Reservoir parameter requirements to the SRs.

The purpose of CTS 3.7.5.1 is to provide assurance that the water in the UI4S can provide required cooling in case of an event. This change is acceptable because the parameter requirements for the UHS are retained, but are moved from the LCO to the SRs. These changes are designated as administrative because they do not result in technical changes to the CTS.

3.7.10 A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

3.7.10 A.2 ITS SR 3.7.10.2 requires performing required MCR/ESGR EVS filter testing in accordance with 5.5.10 3.7.10.2 the Ventilation Filter Testing Program (VFTP). CTS 4.7.7.1 does not include a VFTP, but the requirements that make up the VFTP are being moved to ITS 5.0. This changes CTS by requiring testing in accordance with the VFTP, whose requirements are being moved to ITS 5.0.

This change is acceptable because filter testing requirements are being moved to the VFTP as part of ITS 5.0, and ITS SR 3.7.10.2 references the VFTP for performing these tests. This change is designated as administrative because it does not result in technical changes to the CTS.

3.7.11 A.]I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

North Anna Power Station Page 9 of 13 A -3.7

Table A - Administrative Changes ITS Section 3.7 - Plant Systems

. .I l*Q r (' Q P 11 DOC No. Description of Change S lequirenent--

RI I . I. eqtircm ent S.

Various Various I--

. .. r 3.7.12 A.1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific VariouIs IVariouIs Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

II-result t "- . ,

ITS SR 3.7.12.3 requires performing required ECCS PREACS filter testing in accordance with 3.7.12 A.2 5.5.10 4.7.8. 1 but the tile Ventilation Filter Testing Program (VFTP). CTS 4.7.8. I does not include a VFTP, ITS 5.0. This changes CTS by requiring requirements that makeup the VFTP are being moved to testing in accordance with the VFTP, whose requirements are being moved to ITS 5.0' This change is acceptable because filter testing requirements are being moved to the VFTP as part of ITS 5.0, and ITS SR 3.7.12.2 references the VFTP for performing these tests. This CTS.

change is designated as administrative because it does not result in technical changes to the -1 Var ous t Various to the plant specific 3.7.13 A., In the conversion of the North Anna Current Technical Specifications (CTS) Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

N/A N/A 3.7.14 None -l Various t Various specific 3.7.15 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial with NUREG changes, reformatting, revised numbering, etc.) are made to obtain consistency 1431, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

do not These changes are designated as administrative changes and are acceptable because they result in technical changes to the CTS. I I Page 10 of 13 A -3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.15 A.2 The ITS LCO 3.7.15 Note states, "The fuel building boundary may be opened intermittently 3.7.15 LCO Note None under administrative control." This allowance is not explicitly stated in CTS 3.9.12, but plant practice allows opening of the boundary under administrative controls for specific purposes such as fuel building access.

This change is acceptable because it reflects an existing plant practice necessary for the safe operation of the unit. This change is designated as administrative because it does not result in technical changes to the CTS.

3.7.15 A.3 CTS 3.9.12 refers to irradiated fuel movement within the "spent fuel pit." ITS 3.7.15 refers to 3.7.15 3.9.12 recently irradiated fuel movement within the fuel building. This changes the CTS by changing the reference to the location of the fuel movement.

This change is acceptable because all the fuel movement within the fuel building occurs within the spent fuel pit, and requirements associated with the fuel movements remain the same. This change is designated as administrative because it does not result in technical changes to the CTS.

3.7.15 A.4 CTS 3.9.12 Action c. states, "The provisions of Specification 3.0.3, 3.0.4 and 4.0.4 are not 3.7.15 Actions 3.9.12 Action c applicable." ITS 3.7.15 ACTION Note states, "LCO 3.0.3 is not applicable." ITS LCO 3.0.4, the Note, LCO 3.0.4 equivalent of CTS 3.0.4, states, "LCO 3.0.4 is only applicable for entry into a MODE or other and SR 3.0.4 specified condition in the Applicability in MODES I, 2, 3, and 4." ITS SR 3.0.4, the equivalent of CTS 4.0.4, states, "SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES I, 2, 3, and 4." This changes CTS by deleting reference to an allowance already provided in a different portion of the ITS.

This change is acceptable because ITS LCO 3.0.4 and ITS SR 3.0.4 requirements are consistent with those stated in the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

3.7.16 A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

North Anna Power Station PagellIofl13 A- 3.7

Table A - Administrative Changes ITS Section 3.7 - Plant Systems Description ot Lhange DOC No. Description of Change I plant specific Various 3.7.17 A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the Various (wording preferences, editorial Improved Technical Specifications (ITS), certain changes with NUREG changes, reformatting, revised numbering, etc.) are made to obtain consistency 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

because they do not These changes are designated as administrative changes and are acceptable result in technical changes to the CTS. i i to the plant specific Various 3.7.18 A.I In the conversion of the North Anna Current Technical Specifications (CTS) Various preferences, editorial Improved Technical Specifications (ITS), certain changes (wording consistency with NUREG changes, reformatting, revised numbering, etc.) are made to obtain 143 1, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

Vaiou Vio-s the plant specific In the conversion of the North Anna Current Technical Specifications (CTS) to Various VariouIs 3.7.19 A.] editorial Improved Technical Specifications (ITS), certain changes (wording preferences, with NUREG changes, reformatting, revised numbering, etc.) are made to obtain consistency 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

LCO 3.7.19 t 3.7.3.1, Actions a, applies when 3.7.3. 1, Actions a, CTS 3.7.3.1 states that the CC loops are shared by the units. The Applicability LCO 3.7.19 3.7.19 A.2 on both units. b, and c either unit is in MODES 1, 2, 3, or 4. Actions a, b, and c contain requirements in DOC LA.1I.

ITS 3.7.19 is written to apply to a single unit. The change to the LCO is described to be The change to the Applicability and the Actions are administrative changes necessary presentation is also consistent with the presentation consistent with the change to the LCO. This used in ITS LCO 3.7.8, Service Water System, which is a similar shared system.

Specifications This change is acceptable because both units are required to follow the Technical CC subsystem is inoperable, both units are affected.

and CC is a shared system. If a required is in the Applicability, so if either unit is in MODE I, 2, 3, or 4, The CC applies to each unit that If one or more CC subsystems are inoperable, the CC System is required to be OPERABLE.

Therefore, ACTIONS must be entered on both units if both are in the Applicable MODES.

is an administrative change. This change is designated as eliminating the cross-unit references administrative because it does not result in technical changes to the CTS.

Page 12 of 13 A -3.7 North Anna Power Station

Table A - Administrative Changes ITS Section 3.7 - Plant Systems Description of Change ITS Requirement CTS Requirement DOC No.

None 3.7.3. 1, footnote 3.7.19 A.3 CTS 3.7.3.1 includes footnote "'*" which allows a temporary exception to the CC LCO for service water system upgrades. ITS 3.7.19 does not contain that temporary exception.

This change is acceptable because the temporary exception was only allowed to be used two times (once per SW loop). The temporary exception has been used and is no longer valid. This change is designated as administrative because it does not result in technical changes to the CTS.

ACTIONS A, B, C, 3.7.3.1, Actions a, 3.7.19 A.4 CTS 3.7.3.1 Actions refer to CTS MODE names, "Hot Standby," "Hot Shutdown," and "Cold b, and c Shutdown." ITS 3.7.19 uses the corresponding ITS MODE numbers, "MODE 3," "MODE 4," and D and "MODE 5." This changes the CTS by utilizing MODE numbers instead of MODE names.

Any technical changes associated with the differences in CTS MODES and ITS MODES are discussed in Chapter 1.0.

This change is acceptable because the ITS uses MODE numbers instead of MODE names. Any technical changes associated with the differences in CTS MODES and ITS MODES are discussed in Chapter 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

North Anna Power Station Page 13 of 13 A -3.7

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.1 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

North Anna Power Station Page I of 25 A -3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems I *I *I Y IpnhIIrPmenI I I.. I J RUUiIVIIJIIL Description of Change I I NTSRealllrement UbI r .i .,lUllrlle.t11 11 DOC No. 3.8.1, Required CTS LCO 3.7.4.1 service water loops (shared A.2 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two Action J IF3.8.1 of two OPERABLE service with the other unit) shall be OPERABLE with each loop consisting associated normal and water pumps (excluding auxiliary service water pumps) with their Each unit's service water system emergency power supplies, and an OPERABLE flow path." 1, 2, 3, or 4.

operating in MODES requirements consist of the above requirements for either unit requires three component CTS LCO 3.7.3.1, Component Cooling Water System - Operating, OPERABLE. This requirement cooling water subsystems (shared with the other unit) shall be LCO 3.7.10 specifies the must be met with either unit is in MODES I, 2, 3, or 4. ITS Switchgear Room (ESGR) requirements for the Main Control Room (MCR) / Emergency fans on both units to be Habitability System. This system requires the MCR and ESGR recently irradiated fuel OPERABLE in MODES 1,2, 3, and 4 and during the movement of Building central exhaust assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary System (ECCS) Pump Room system to be OPERABLE to support the Emergency Core Cooling the other unit to be Exhaust Air Cleanup System. This could require a fan powered from MCR/ESGR and Auxiliary required for this unit. The SW and CC pumps and the fans from the required by either or both Building exhaust ventilation systems are components that may be electrical components," for the units. Therefore, these pumps and fans are classified as "shared LCO 3.8.1.c EDGs power requirements. ITS LCO 3.8.1 Action J states, "Two required This changes the CTS by inoperable, declare shared components inoperable immediately."

specifically stating the requirement in the ITS Action J.

electrical requirements for the The purpose of the proposed change is to structure the existing requirements in ITS section 3.8. This change shared components in the ITS by placing electrical for the SW, CC, MCR/ESGR Emergency is acceptable because the AC sources requirements Room Exhaust Cleanup System functions are contained in Habitability System, and ECCS Pump The additional the electrical requirement section of the unit's Technical Specifications.

ventilation specifications are addressed by more restrictive requirements of the fans in the requirements. The additional electrical requirements are discussion of changes to the CTS both units electrical power from classified as administrative because of the systems may require is designated as administrative in order to satisfy the individual safety function. This change because it does not result in a technical change to the CTS.

A-3.8 Page 2 of 25 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No.

3.8.1 A.

[ Description of Change [

i ITS Requirement i CTS Requirement 3.8.1 A.3 CTS 3.8.1.1 Actions b. I and b.2 provide an allowance to have an EDG inoperable for up to 14 3.8.1, ACTION B 3.8.1.1, Actions days. These Actions require the OPERABILITY of the alternate AC (AAC) diesel generator and C b.I and b.2 (DG) and the opposite unit's EDGs at the time of the initial inoperability of the EDG and throughout the 14 day allowed outage time. If either the AAC DG or either of the opposite unit's EDGs become inoperable when relied on for this action, a seventy two-hour limit is imposed for the EDG. If the AAC DG and both of the opposite unit's EDGs are returned to an OPERABLE status within the 72-hour limit, the EDG may continue in the 14 day allowed outage. ITS Action B provides the necessary Required Actions for returning the inoperable EDG to OPERABLE status within 14 days. ITS Action C requires with an EDG inoperable and one or more of the opposite unit's EDGs or the AAC DG inoperable, both of the opposite unit's EDGs and the AAC DG must be restored to OPERABLE status within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or restore the ITS 3.8.1 .b EDG to OPERABLE status. A Note to ITS Condition C states that the condition is only applicable if either the AAC DG or the opposite unit EDG(s) is inoperable.

This change is acceptable because no technical requirements are added to or deleted from the current requirements. The change in format of the CTS, with the conversion to the ITS, maintains all technical requirements. This change is designated as administrative because it does I ýnot result in a technical change to the CTS. I I CTS 3.8.1.1 Action c applies, "With one offsite circuit and one EDG inoperable." In this 3.8.1 Action 1 3.8.1. 1, Action c, 3.8.1 A.4 condition an emergency bus may be de-energized. CTS LCO 3.8.2.1 provides an Action for an Note LCO 3.8.2.1 emergency bus that is de-energized. A Note to ITS 3.8.1 Action IH in the Required Actions column states, "Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution System - Operating," when Condition H is entered with no AC power source to any train." TFile addition of the Note does not alter the technical requirements of the CTS and acts as only a reminder to enter appropriate Actions.

This change is acceptable because no changes are made to CTS requirements. The change in format from the CTS to the ITS maintains all technical requirements. The addition of the Note only acts as a reminder to enter all appropriate Actions if any emergency bus becomes de energized. This change is designated as administrative because it does not result in a technical change to the CTS.

I North Anna Power Station Page 3 of 25 A -3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems

- . - -Ii  :;ý, qu1reZen 11 Description of Change IT Rlequirement .8.T equiremeon A

DOC No. . I I-I I 3.8.1, Action I.......................I

-3.8.1I, F-_. I - - II I 3.8. 1. 1, Action c

.5 CTS 3.8.1.1 Action c for an inoperable offsite circuit and EDG requires the restoration of one of -- Action Hl 3.8.1 A.

the sources within 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br /> and states "demonstrate the OPERABILITY of the remaining offsite at A.C. power sources by performing Surveillance Requirement 4.8.1.1.1 .a within one hour and is declared inoperable and Action b is least once per 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br /> thereafter." That is, when the EDG Action a. and Action c.

entered and either earlier or later an offsite circuit is declared inoperable, Action c is to be in Action a are also required to be entered. The only mechanism for entering EDG and Action b concurrently. ITS 3.8.1 Action H states that when one offsite circuit and one within twelve hours. The only are inoperable, one source must be returned to OPERABLE status mechanism to enter this Condition is to have entered ITS 3.8.1 Actions A and B concurrently.

also ITS Required Action B.1 states that SR 3.8.1.1 will be performed for offsite circuit(s). It requires in Required Action B.3, an evaluation of the OPERABLE EDG is made. With the of requirements of the CTS stated in this manner, CTS 3.8.1.1 Action c repeated the requirements and the evaluation of the Action b, for the performance of CTS requirement 4.8.1. 1.La OPERABLE EDG. This requirement is redundant and therefore is eliminated.

This change is acceptable because the technical requirements remain the same. If an offsite circuit and an EDG become inoperable at the same time, the requirement to perform a breaker the and power availability check on the OPERABLE offsite circuit and an evaluation or start on OPERABLE EDG, continue to be required. This change is designated as administrative because it does not result in a technical change to the CTS. I I

Page 4 of 25 A -3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement DOC No.

3.8.1 A.6 CTS 3.8.1.1, Action d, applies when two offsite circuits are inoperable and requires one offsite 3.8.1, ACrIONS A 3.8.1. 1, Actions a circuit be restored to OPERABLE status within twenty-four hours, or be in at least HOT and G and d STANDBY within the next 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />. The requirement also states, "Following restoration of one offsite source, follow Action Statement a with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable offsite A.C. circuit." CTS Action a states, "Restore the offsite circuit to OPERABLE status within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> or be in at least HOT STANDBY within the next six hours and COLD SHUTDOWN within the following 30 hours1.25 days <br />0.179 weeks <br />0.0411 months <br />."

If both inoperable offsite circuits are not restored when the unit reaches HOT STANDBY, the required actions do not specify any further actions. With the unit in HOT STANDBY and no offsite circuits, LCO 3.0.3 must be entered. This requires the unit to be placed in HOT SHUTDOWN in 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> and COLD SHUTDOWN within the next 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS Actions A and G are constructed to track the inoperability of one and two offsite circuits. ITS Action A requires an inoperable offsite circuit be restored to OPERABLE status within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />. ITS Action G must be entered when two circuits are concurrently inoperable and allows 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> to restore one offsite circuit to OPERABLE status. If ITS Actions A or G are not met within either allowed Completion Times, ITS Action K must be entered and requires the unit to be place in MODE 3 within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> and MODE 5 within 36 hours1.5 days <br />0.214 weeks <br />0.0493 months <br />. This changes maintains the technical requirements of the CTS requirements in the ITS format.

This change is acceptable because the technical requirements remain the same. The ITS requires multiple condition entry. Therefore, ITS Actions A and G would both be entered if two offsite circuits were inoperable and Action A would be followed until both offsite circuits were restored to OPERABLE status. This has the same effect as the CTS requirements. Therefore, the deletion of the wording in CTS 3.8.1.1 Action d does not modify the technical requirements of the CTS and the unit would be required to be in MODE 5 (COLD SHUTDOWN) within 30 hours1.25 days <br />0.179 weeks <br />0.0411 months <br /> after reducing to MODE 3 (HOT STANDBY). This change is designated as administrative because it does not result in a technical change to the CTS.

Page 5 of 25 A-3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.1 A.7 CTS 3.8.1.1 Action e applies when two EDGs are inoperable and requires one EDG to be 3.8.1, ACTIONS B 3.8.1 .1,-Action s b restored to OPERABLE status within two hours. This requirement also states, "demonstrate the and I and e OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1. L.a within one hour and at least once per 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br /> thereafter." In addition the CTS requires, "Following restoration of one EDG, follow Action Statement b. with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable EDG." ITS Actions B and I are constructed to track the inoperability of one and two EDGs. ITS Action B requires that each inoperable EDG be tracked and ITS Action I applies when both EDGs are inoperable. Therefore, ITS Action B must be entered if one or two EDGs are inoperable and requires the performance of SR 3.8. I.1 within one hour and every eight hours thereafter. This maintains the CTS requirement to demonstrate the OPERABILITY of two offsite AC circuits within an hour and every 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br /> thereafter when one or two EDGs are inoperable.

This change is acceptable because the technical requirements remain the same. The ITS requires multiple condition entry. Therefore, ITS Actions B and I would both be entered if two EDGs were inoperable and Action B would be followed until both EDGs were restored to OPERABLE status. This has the same effect as the CTS requirements. Therefore, the deletion of the wording in CTS 3.8.1.1 Action e does not modify the technical requirements of the CTS and the unit would be required to be in MODE 5 (COLD SHUTDOWN) within 30 hours1.25 days <br />0.179 weeks <br />0.0411 months <br /> after reducing to MODE 3 (HOT STANDBY). This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.1 A.8 CTS LCO 3.8.l1.1 does not contain an Action for more than two sources ofeither offsite circuits 3.8. 1, ACTION M LCO 3.8.1.1 or EDGs inoperable. Having more than two sources inoperable requires entering CTS LCO 3.0.3. ITS 3.8.1, Action M, requires entering LCO 3.0.3 immediately if three or more AC sources are inoperable.

The change is acceptable because the CTS Actions for more than two sources inoperable are the same as the ITS Actions. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station Page 6 of 25 A-3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems

.. -- II Vp eqirene I Lt-T euierQn DOC No. Description of Change ITS R5bequirem ent I T S. Requirement I1

- I LCO 3.7.10, VLCO 3.7.4.1 3.8.1 A.9 CTS LCO 3.7.4. 1, Service Water System - Operating, states, "Two service water loops (shared LCO 3.7.10, I ,CO 3.7.4.1 with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service LCO 3.7.12, water pumps (excluding auxiliary service water pumps) with their associated normal and LCO 3.7.19 LCO 3.8.1 .c emergency power supplies, and an OPERABLE flow path." Each unit's service water system specification applies when either unit is operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.*1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for tile Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support tile Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8. I, "AC Sources," part c states, "One qualified circuit between the offsite transmission network and the onsite Class 1IE AC Electrical Power Distribution System and one EDG capable of supplying the onsite Class I E AC power distribution subsystem on the other unit for each required shared component; and." This change maintains the CTS requirements for AC sources in the ITS format.

The purpose of the proposed change is to structure the existing electrical requirements for the shared components in the ITS by placing electrical requirements in ITS Section 3.8. This change is acceptable because the AC sources requirements for the SW, CC, MCR/ESGR Emergency Habitability System, and ECCS Pump Room Exhaust Cleanup System functions are moved to the electrical requirement section of the unit's Technical Specifications. The additional requirements of the fans in the ventilation specifications are addressed by more restrictive discussion of changes to the CTS requirements. The movement of tile electrical requirements is classified as administrative because of the systems may require electrical power from both units in order to satisfy the individual safety function. This change is designated as administrative because it does not result in a technical change to the CTS. I I Page 7 of 25 A -3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.1 A. 10 CTS SR 4.8.1.1 .2.a.4 states "Verifying the EDG can start ** and voltage and frequency at 4160 +/- SR 3.8.1.2 4.8. 1.1.2.a.4 420 volts and 60 +/- 0.5 Hz." The note ** states, "This test shall be conducted in accordance with the manufacturer's recommendations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations." ITS SR 3.8.1.2 states, "Verify each EDG starts from standby conditions and achieves steady state voltage of> 3740 V to _<4580 V, and the frequency from >Ž59.5 Hz to <*60.5 Hz." Two Notes modify SR 3.8.1.2. Note I states, "All EDG starts may be preceded by an engine prelube period and followed by a warm up period prior to loading." Note 2 states, "A modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer, When a modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met." This changes the CTS by specifically stating the requirements and allowances in the ITS format.

This change is acceptable because the requirements of the CTS are maintained in the ITS requirements. ITS Note I maintains the allowances provided by the CTS note for a prelube and warmup period prior to loading. ITS Note 2 establishes that ITS SR 3.8.1.2 may involve idling and gradual acceleration to synchronous speed and SR 3.8.1.2 may be credited when performing SR 3.8.1.7. This is acceptable because the CTS note allows loading in accordance with loading recommendations and SR 3.8.1.7 meets or exceeds the technical requirements of SR 3.8.1.2. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.1 A. 11 the CTS SR 4.8.1.1 .2.a.4 states after a successful start of the EDG, "Subsequently, verifying operates SR 3.8.1.3 4.8.1.1.2.a.4 generator is synchronized, gradually loaded ** to an indicated 2500 - 2600 kW *** and for at least 60 minutes." CTS notes ** and *** allow the test to be conducted in accordance with manufacturer's recommendations regarding engine warmup and loading. These notes also allow momentary variations in loads, due to changing in bus loads, to not invalidate the test. ITS SR 3.8.1.3 states, "Verify each EDG is synchronized and loaded and operates for > 60 minutes at a load > 2500 kW and

• 2600 kW." Four Notes modify the SR. Notes I and 2 allow EDG loading as recommended by the manufacturer and momentary transients outside the load range to not invalidate the test. Notes 3 and 4 are addressed by DOC M.6.

This change is acceptable because Notes I and 2 in ITS SR maintain the allowances provided by the CTS notes. The changes to the notes are editorial and conform to the format of the ISTS.

This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.1 A.]12 Not used. N/A N/A North Anna Power Station Page 8 of 25 A-3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement DOC No.

A. 13 CTS requirement 4.8.1.1.2.c states that the EDG shall be started at least once per 184 days and SR 3.8.1.7, 4.8.1.1.2.c 3.8.1 SR 3.8.1.3 Note manually synchronized to its appropriate emergency bus, gradually loaded** to an indicated 2500 to 2600 kW***, and operated for at least 60 minutes. ITS SR 3.8.1.7 requires the start of the EDG every 184 days. ITS SRs 3.8.1.3 requires the synchronization and loading of the EDG from 2500 to 2600 kW for a period of60 minutes. SR 3.8.1.3 contains a Note, which states that the requirement shall be preceded by and immediately follows without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7. This changes the CTS by eliminating the duplicated requirements of 4.8.1.1.2.c (ITS SR 3.8.1.7), which are now contained in ITS SR 3.8.1.3 (CTS SR 4.8.1.1.2.a.4).

This change is acceptable because the division of the current requirement 4.8.1.1.2.c into r]'S SR 3.8.1.2 or SR 3.8.1.7 and 3.8.1.3 maintains the requirements of starting, synchronizing with the emergency bus, and fully loading the EDG for 60 minutes. Additional changes to requirement 4.8.1.1.2.c are discussed in other discussion of changes. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.1 A. 14 3

CTS requirements 4.8.1.1.2.d.2, d. , d.5, and d.8 require the testing ofthe EDGs, at least once SR 3.8. 1.10, 4.8.1.1.2.d.2, d.3, per 18 months "during shutdown." ITS SRs 3.8.1.10, 3.8.1.15, 3.8.1.16 and 3.8.1.17 incorporate SR 3.8.1.15, d.5, and d.8 this requirement and state it as a Note. The Note states, "This Surveillance shall not be SR 3.8.1.16 and performed in MODES 1, 2, 3, or 4." This changes the CTS by specifically stating the applicable SR3.8.l.17 MODES of operation that the SRs may be performed.

This change is acceptable because the CTS requirements for testing the AC sources do not specifically state the MODES in which the tests must be performed, but simply state "during shutdown." The ITS SRs' Note provides specific MODES in which test is not to be performed.

With the unit in MODE 5, 6, or defueled (no MODE), the performance of these required tests can be conducted with minimum effects on the electrical system for the EDG that is not required to be OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station Page 9 of 25 A -3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.1 A. 15 CTS SR 4.8.1.1 .2.a.6 states, in part, that the EDG shall be operated to an indicated load of 2500 - SR 3.8.1.13 Note I 4.8.1.1.2.a.6 2600 kW and is modified by a footnote labeled ***. CTS note *** allows momentary variations in loads, due to changing in bus loads, to not invalidate the test. ITS SR 3.8.1.13 states in Note 1, "Momentary transients outside the load range to not invalidate the test." The portion of the Note that addresses the power factor limitation is discussed later in these discussions of changes.

This change is acceptable because this portion of Note I in ITS SR maintains the allowance provided by the CTS note. The changes to the note are editorial and conform to the format of the ISTS. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.1 A. 16 CTS SR 4.8.l.1.2.a.10 states, in part, that the EDG shall be operated to an indicated load of 2500 SR 3.8.1.14, Note I 4.8.1.1.2.a. 10,

- 2600 kW *** for 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />, or until operating temperatures have stabilized, then the EDG must footnote ***

be shutdown. Within 5 minutes of shutting down, verify the EDG can start and achieve the required voltage and frequency within 10 seconds. The CTS footnote *** allows momentary variations in loads, due to changes in bus loads to not invalidate the test. ITS SR 3.8.1.14 states in Note 1, "This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated > 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> loaded Ž_2500 kW and < 2600 kW or after operating temperatures have stabilized." The Note I also allows, "Momentary transients outside the load range to not invalidate the test."

This change is acceptable because Note I of the ITS SR maintains the requirement provided in the CTS. The changes to the requirements and note are editorial and conform to the format of the ISTS. This change is designated as administrative because it does not result in a technical change to the CTS 3.8.1 A. 17 Unit I CTS Surveillance Requirement 4.8.1.1.1 .b states that the independent circuits between the SR 3.8.1.8, Note Unit I 4.8.I. 1.L.b offsite transmission network and the onsite Class I E distribution system shall be demonstrated OPERABLE at least once per 18 months during shutdown by manually transferring the onsite Class IlE power supply from the normal circuit to the alternate circuit. This SR for unit 2 has been eliminated by DOC L.7. ITS SR 3.8.1.8 states, "Verify manual transfer of AC power sources from the normal offsite circuit to the alternate required offsite circuit. The SR is modified by a Note that states, "This Surveillance is only applicable to Unit I." This changes the CTS by specifically stating that the SR is only to Unit I.

This change is acceptable because SR 4.8..1l.1.b has been deleted for Unit 2. The purpose of the note is to limit the SR to be required for Unit I. This change is designated as administrative because the addition of the Note does not result in a technical change to the Unit I CTS.

North Anna Power Station Page 10 of 25 A -3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement DOC No.

trips, except CTS Surveillance Requirement 4.8.1.1 .2.d.5.c requires the verification that all EDGbypassed SR 3.8.1.12 4.8.1.1 .2.d.5.c 3.8.1 A. 18 on engine overspeed, generator differential and breaker overcurrent are automatically an emergency start. The output breaker overcurrent for the EDG is not a trip for the diesel and should not be included in the exception. ITS SR 3.8.1.12 requires the verification of each EDG's automatic trips are bypassed on an actual or simulated automatic start signal except for engine overspeed and generator differential current. This changes the CTS by eliminating the EDG output breaker overcurrent from the list of EDG trips.

This change is acceptable because the output breaker overcurrent does not provide a trip of the EDG. With the deletion of the output breaker overcurrent, no technical requirement is added or deleted with the conversion of the CTS requirements to the ITS requirements. The output breaker overcurrent should not have been included in the CTS requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

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Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement DOC No.

LCO 3.7.10, LCO 3.7.4.1 3.8.1 A. 19 CTS LCO 3.7.4. 1, Service Water System - Operating, states, "Two service water loops (shared with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service LCO 3.7.12 water pumps (excluding auxiliary service water pumps) with their associated normal and LCO 3.7.19 emergency power supplies, and an OPERABLE flow path." Each unit's service water system 3.8.1, Action F specification applies when either unit is operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS 3.8. lAction F states if the required offsite circuit and EDG on the other unit that support a required shared components become inoperable, the supported shared components will be declared inoperable immediately. The differences between the requirements for the shared systems of the CTS and the ITS are addressed in ITS LCOs 3.7.8, 3.7.10, 3.7.12, and 3.7.19. This change maintains the CTS requirements in the ITS format.

This change is acceptable because the technical requirements of the CTS are maintained in the ITS. Ifra shared components is required to be OPERABLE for this unit and the pump or fan is powered from the other unit's electrical system, the loss of the normal and emergency AC source would required the pump or fan to be declared inoperable and appropriate Action for the affected system to be entered. This change is designated as administrative because it does not result in a technical change to the CTS.

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Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement CTS SR 4.8.1.i.2.d.5.c states that all non-critical EDG trips will be bypassed on a loss of voltage SR 3.8.1.12 4.8.1.1.2.d.5.c 3.8.1 A,20 on the emergency bus and/or a safety injection actuation signal. The non-critical trips do not include engine overspeed, generator differential, and EDG output breaker overcurrent. The output breaker overcurrent is addressed in DOC A,.18. ITS 3.8.1.12 states, "Verify each EDG's automatic trip are bypassed on actual or simulated automatic start signal except engine overspeed and generator differential current. This changes the CTS specifically stating that the non-critical EDG trips are bypassed on any automatic start signal. The specific automatic start signal is moved to the ITS Bases by DOC LA.].

This change is acceptable because the technical requirements remain unchanged. The EDGs will continue to have their non-critical trips verified to be bypassed on a start from a signal from either an ESF or loss of voltage signal. This change is designated as administrative because it does not result in a technical change to the CTS.

Not used. N/A N/A 3.8.1 A.21 states two EDGs LCO 3.8.1 LCO 3.8.1.1 3.8.1 A.22 CTS LCO 3.8. 1.1 requires two EDGs to be OPERABLE. ITS LCO 3.8.1 shall be OPERABLE.

capable of supplying the onsite Class 1E power distribution subsystem(s)

This changes the CTS by stating the requirement that the EDG must be capable of supplying the onsite Class IE power distribution subsystem.

This change is acceptable because the EDGs may-only be connected to the onsite Class I E subsystems. The change in wording does not modify the technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

plant specific Various Various 3.8.2 A.]I In the conversion of the North Anna Current Technical Specifications (CTS) to the Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

Page 13 of 25 A -3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems I....-. -  :.-. - I r ro1 pniipn i o

+/-r t-' i ý,

Description of Change I V ls

• lkquirl[elltit twquirernem I 11 DOC No. 3.8.2, ACTION B 3.8.1.2, Action a suspend CTS LCO 3.8.1.2 Action a. states with required AC sources inoperable immediately 3.8.2, ACoION B 3.8.1.2, Action a 3.8.2 A.2 movement of Note operations involving CORE ALTERATIONS, positive reactivity additions, until the irradiated fuel assemblies, and movement of loads over irradiated fuel assemblies B adds a Note to these required AC sources are restored to OPERABLE status. ITS 3.8.2 Action of LCO 3.8.10, with requirements that states, "Enter applicable Conditions and Required Actions to CTS ACTION are one required train de-energized as a result of Condition B." Other changes The purpose of the Note is to addressed in by additional discussion of changes in this section.

the offsite circuit remind the user that if an emergency bus becomes de-energized with the loss of for specific Required Actions.

and the required EDG, ITS LCO 3.8.10 would be entered an evaluation of The change is acceptable because the requirements of the CTS would require The change is designated as potential Actions for inoperable buses and equipment.

to enter all necessary specifications for a administrative because the Note only acts as a reminder requirements of the CTS.

specific condition and does not change the technical _ _ _ _ _ _ _

to the plant specific Various 3.8.3 A.I In the conversion of the North Anna Current Technical Specifications (CTS) Various preferences, editorial Improved Technical Specifications (ITS), certain changes (wording obtain consistency with NUREG changes, reformatting, revised numbering, etc.) are made to Plants" (ISTS).

1431, Rev. 1, "Standard Technical Specifications-Westinghouse they do not These changes are designated as administrative changes and are acceptable because result in technical changes to the CTS. -l LCO 3.8.3, +/- LCO 3.8.1.1, sources - operating LCO 3.8.1.1, 3.8.3 A.2 CTS LCOs 3.8.1.1 and 3.8.1.2 state the requirements for the electrical power LCO 3.8.3, 3.8.3 Applicability LCO 3.8.1.2 for tile diesel and shutdown. These requirements are used to form the LCO and Applicability Air," states "The fuel oil and starting air systems. ITS LCO 3.8.3, "Diesel Fuel Oil and Starting each required stored diesel fuel oil and starting air subsystems shall be within limits for are, "When emergency diesel generator (EDG)." The Applicability for these requirements requirements is associated EDG is required to be OPERABLE. The addition of the starting air addressed in DOC M. 1. This changes the CTS by stating the LCO and Applicability requirements for the diesel fuel oil in the ITS format.

form with no This change is acceptable because the current requirements are translated into ITS required to maintain the technical changes. The fuel oil is a support system for each EDG that is EDGs and the EDG's OPERABILITY. The CTS and ITS maintain this relationship between the as fuel oil system without any changes in the technical requirements. This change is designated administrative because it does not result in a technical change to the CTS.

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Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement DOC No.

3.8.3 ACTIONS LCO 3.8.1. 1, 3.8.3 A.3 CTS LCO 3.8.1.1 states the requirements for the diesel fuel oil in the LCO, Action, and Surveillance Requirements for the EDGs when the unit is operating. CTS LCO 3.8.1.2 lists the Note LCO 3.8.1.2 requirements for diesel fuel oil in the LCO, Action, and Surveillance Requirements when the unit is in a shutdown condition. Both CTS 3.8.1.1 and 3.8.1.2 provide tile requirements on the fuel oil system needed to support the OPERABILITY of the associated EDG. ITS 3.8.3 Actions are provided with a Note that states, "Separate Condition entry is allowed for each EDG." The addition of the Note provides clarity to the CTS by specifically stating that a separate entry is allowed for each EDG.

This change is acceptable because each EDG is provided with an independent source for starting air. Each EDG requires an independent fuel oil supply by separate transfer lead and backup pumps and day tank. The requirements of the CTS deal only the fuel oil requirements and separate condition entry is allowed by the current requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

fuel oil is 3.8.3, Condition F 3.8.1.1 Actions 3.8.3 A.4 CTS 3.8.1.1 Actions do not specifically state Required Actions for an EDG if sufficient not available. ITS Condition F states, "Required Action and associated Completion Time not met, or one or more EDGs diesel fuel oil or starting air systems not within limits for reasons other than Condition A, B, C, D, or E, declare associated EDG inoperable immediately." Starting air requirements are addressed in DOC M. I. This changes the CTS by specifically stating that if Actions are not met, the associated EDG would be declared inoperable.

This change is acceptable because the CTS requirements are structured as a support system for EDGs OPERABILITY. Specifically stating the requirement to declare the EDG(s) inoperable does not change the technical intent of the current requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

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Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.3 A.5 CTS Surveillance 4.8.1.1.2 specifies that each EDG shall be tested in accordance with CTS Table SR 3.8.3.1 4.8.1.1.2, 4.8.2. This requirement is modified in ITS Section 3.8.1 and specifies the frequency of testing an 4.8.1.1.2.a.2 EDG as 31 days. CTS requirement 4.8.1.1.2.a.2 requires the verification of fuel oil tank level to support the OPERABILITY of the EDG. ITS SR 3.8.3.1 requires verification of fuel oil volume every 3 1 days. This changes the CTS by specifically stating the frequency for verification of fuel oil tank level as 31 days.

This change is acceptable because the requirements in LCO 3.8.1 specify the testing frequency of the EDG. The fuel oil level is verified to ensure OPERABILITY of the EDG. Therefore, the frequency of the testing is dependent on the testing requirements of the EDG. This change reflects the requirements of the CTS in the ITS format. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.3 A.6 CTS LCO 3.8.1.I.b.2 states that the fuel storage system consists of two under ground storage 3.8.3 Condition B 3.8.1.1.b.2 tanks each containing a minimum of 45,000 gallons of fuel and this is a shared system between units. ITS Condition B states, "One or more EDGs with fuel oil inventory < 90,000 gallons .... "

and SR 3.8.3.1 requires the verification of "fuel oil inventory of > 90,000 gal of fuel." This changes the CTS by stating the total inventory requirement of fuel oil instead of the individual fuel oil tank requirement.

The purpose ofCTS 3.8.1I.lb.2 is to require sufficient fuel oil inventory for two EDGs to operate at full load for 7 days as required to support the accident analysis. This change is acceptable because the total inventory requirement for the EDG fuel oil system of 90,000 gallons remain the same. This change is designated as administrative because it does not result in technical changes to the CTS.

A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.8.4 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

North Anna Power Station Page 16 of 25 A-3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems I.... I,-,-..:..meq1mireumeiit Description Change of Change Description of I I

II S equirement IT 1 equlre IentT. R equrement DOC No.

-L SR-- 3.8.4..31 4.8.2.3.2.c.- I 3.8.4 A.2 CTS Surveillance Requirements 4.8.2.3.2 c. I for the station batteries and 4.8. I.1.3 c. I for the SR 3.8.4.3 4.8.2.3.2.c.1 4.8.1.1.3.c. I EDG batteries require, at least once per 18 months, the verification that battery cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration. ITS SR 3.8.4.3 requires the verification of station and EDG battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance. This changes the CTS requirements by adding the clarification, "that could degrade battery performance."

This change is acceptable because the intent of the CTS is maintained in the ITS requirements.

The ITS adds a clarifying statement that expresses the CTS requirements with no modifications result to technical requirements. This change is designated as administrative because it does not a technical change to the CTS.

I in and e 4 SR 3.8.4.9 I -- - - I- I 4.8 .2.3 3.8.4 A.3 CTS 4,8.2.3.2 e and f Surveillance Requirements for the station batteries, and 4.8.1.1.3 d SR 3.8.4.9 4.8.2.3.2.c, 4.8.2.3.2.f, every for the EDG batteries, both require a test to verify battery capacity. Each battery is tested 4.8.1.1.3.d, 60 months to ensure capacity is at least 80% of the manufacturer's rating during a performance 4.8.1.1.3.e discharge test. A discharge test is required every 18 months if the battery shows signs of the degradation, or has reached 85% of its service life. ITS SR 3.8.4.9 requires the verification of subjected to a station and EDG battery capacity > 80% of the manufacturer's rating when performance discharge test or a modified performance discharge test. The allowance of the modified performance discharge test is addressed in a less restrictive change L. I. The Frequency requirements for the SR are 60 and 18 months when the battery shows degradation or has reached 85% of expected life. This change retains the CTS requirements for the batteries by expressing the testing requirements in a conditional Frequency.

the This change is acceptable because the technical requirements of the CTS are maintained in format does not add or delete any ITS requirements. The re-arrangement of the SR in the ITS result required testing of the CTS. This change is designated as administrative because it does not in a technical change to the CTS. I I I

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Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.4 A.4 CTS Surveillance Requirement 4.8.1 .1.3 provides the testing requirements and acceptance LCO 3.8.4 4.8.1.1.3 criteria for determining EDG DC system OPERABILITY. These requirements relate to the OPERABILITY of the associated EDG in LCO 3.8.1.1. ITS LCO 3.8.4 is constructed to include the LCO, Condition, and SRs for the EDG's DC system. This change retains the CTS requirements for the EDG's DC system and ensures the EDG's OPERABILITY requirements are maintained.

This change is acceptable because the CTS requirements for the EDG's DC requirements are maintained in the ITS format without any technical requirements being modified. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.4 A.5 CTS LCO 3.8.2.3 is modified with the requirement that the DC electrical power subsystem on the LCO 3.8.4 LCO 3.8.2.3, other unit that supplies the DC electrical power for each required Service Water (SW) pump must LCO 3.7.4.1 be OPERABLE for this unit. This requirement is derived from the CTS LCO 3.7.4.1, Service Water System - Operating. ITS LCO 3.8.4 states that the following DC electrical power subsystems shall be OPERABLE, including, "One DC electrical power subsystem on the other unit for each required shared component." This maintains the CTS requirements for the shared components, powered from the other unit that are required by this unit.

This change is acceptable because the electrical requirement contained in CTS LCO 3.7.4.1 is moved into the appropriate LCO of the ITS without technical change. The required DC subsystems of the other unit must be required to be OPERABLE for this unit in order to maintain the required shared components OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station Page 18 of 25 A -3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement DOC No, LCO 3.8.4, LCO 3.8.2.3 3.8.4 A.6 CTS LCO 3.8.2.3 Actions are modified with the requirement that the DC electrical power subsystem on the other unit that supplies the DC electrical power for each required shared Condition D components that must be OPERABLE for this unit. This requirement is derived from the CTS LCO 3.7.4.1, Service Water System - Operating. ITS LCO 3.8.4 Condition D states, "one or more required LCO 3.8.4.c DC electrical power subsystem(s) inoperable, declare associated shared component(s) inoperable, immediately." A Note that states "Separate Condition entry is allowed for each DC subsystem" modifies condition D. This maintains the CTS requirements for the shared components, powered from the other unit that are required by this unit.

This change is acceptable because the electrical requirement contained in CTS LCO 3.7.4.1 are moved into the appropriate Condition of the ITS without technical change. If the required DC subsystems of the other unit become inoperable for the required shared components, then the shared components will be declared inoperable immediately. This change is designated as administrative because it does not result in a technical change to the CTS.

plant specific Various Various 3.8.5 A.1 In the conversion of the North Anna Current Technical Specifications (CTS) to the Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

LCO 3.8.5, Action 4.8.1.2, 3.8.5 A.2 CTS 4.8.1.2 requires the performance of Surveillance Requirement 4.8.1.1.3 for a required EDG. B 4.8.1.1.3 ITS LCO 3.8.5, "DC Sources - Shutdown," states, "EDG DC system shall be OPERABLE for the EDG required by LCO 3.8.2, 'AC Sources - Shutdown."' ITS Action B states that with the required EDG DC system inoperable, enter the applicable Conditions and Required Actions for the associated EDG immediately. This changes the CTS requirements by specifying the EDG DC subsystems shall be OPERABLE and providing Required Actions for an inoperable EDG DC subsystem.

This change is acceptable because the CTS requirements for the EDGs' DC systems are maintained in the conversion to the ITS requirements. The DC system is required when the supported EDG is required to be OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

Page 19 of 25 A-3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.8.6 A.lI Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

CTS testing requirements for station and EDG batteries are contained in Surveillance LCO 3.8.6, 4.8.2.3.2, 3.8.6 A.2 4.8.1.1.3 Requirements 4.8.2.3.2 and 4.8.1.1.3. ITS LCO 3.8.6 is structured to implement the CTS SRs in 3.8.6 Applicability, a standard format for the battery cell parameters. The LCO states, "Battery cell parameters for ACTIONS Note station Train H and Train J, and EDG batteries shall be within limits." Tile Applicability for the LCO is stated as, "When associated DC electrical power subsysterns or EDG DC systems are required to be OPERABLE." A Note is added for the proposed Actions that states, "Separate Condition entry is allowed for each battery." This changes the CTS by specifying an LCO, Applicability, and Note for the Actions that do not currently exist.

The change is acceptable because these requirements continue to ensure the OPERABILITY for the station and EDG batteries. The specific addition of the ITS LCO, Applicability, and Note does not change any technical requirement of the CTS requirements, but provides a clarifying statement for the current requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

Page 20 of 25 A-3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement A.3 CTS 4.8.2.3.2 and 4.8.1.1.3 Surveillance Requirements provide testing requirements for the 3.8.6, ACTION B 4.8.2.3.2, 3.8.6 4.8.1.1 .3, station and EDG batteries. The requirements include the Category A and B limits of Table 4.8-3 for the station and EDG batteries, and electrolyte temperature for station batteries. CTS Table Table 4.8-3 4.8-3 lists the allowable value limit for battery cell parameters under Category B limits. ITS LCO 3.8.6 Action B lists three Conditions for the associated batteries. TFile first Condition is Required Action and associated Completion Time of Condition A not met. Condition A specifies, for station and EDG batteries cell parameters not within Category A or B limits, specific Required Actions to be performed to ensure OPERABILITY of the battery. The second Condition of Action B states one or more station batteries with average electrolyte temperature for the representative cells < 60 'F. The third Condition states one or more station or EDG batteries with one or more battery cell parameters not within Table 3.8.6-1 Category C values.

The associated battery is declared inoperable immediately if any part of the Condition B is met.

This changes the CTS by specifying specific Conditions for ITS Action B.

The change is acceptable because these requirements ensure the station and EDG batteries are verified within specified parameters or the battery is declared inoperable. This is the intent of the CTS requirements on the battery cell parameters listed in a Note to Table 4.8-3. Other changes to the battery cell parameters are addressed in more and less restrictive changes in these discussion of changes. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.6 A.4 CTS LCO 3.7.4.1 requires the normal and emergency power supplies to be OPERABLE for the LCO 3.8.6 LCO 3.7.4.1 required Service Water pumps. Requirements for Main Control Room and Emergency Switchgear Room fans and Auxiliary Building central exhaust fans may require electrical power from the other unit. ITS LCO 3.8.6 is modified to include the Station and EDG batteries on the other unit that are required to support shared components that are powered for the other unit.

This change maintains the CTS requirements in the ITS format.

The change is acceptable because these requirements ensure the station and EDG batteries that are needed to support shared components on the other unit, needed for this unit, are maintained OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station Page 21 of 25 A-3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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 7CO73.8.7 .LC-O--3.8.2.I1I-CTS 3.8.2.1 for the Onsite Power Distribution Systems lists A.C. Distribution - uperating LCO 3.8.7 LCO 3.8.2.1 requirements. CTS LCO 3.8.2.1 states, "The following A. C. electrical busses shall be OPERABLE." The requirement specifies 4 120-volt AC electrical buses are energized from their associated inverter. The inverter receives its power from the associated DC bus. ITS LCO 3.8.7, "Inverters - Operating" requires the H and J Train inverters to be OPERABLE. This changes the CTS by dividing the onsite AC power system into sources and distribution systems.

This change is acceptable because the ITS divides the requirements for the electrical sources from the electrical power distribution systems but does not change the technical requirements.

The inverters provide the regulated 120-volt AC electrical source(s) for the 120 VAC distribution systems. The 120 VAC distribution systems are addressed by ITS LCO 3.8.9, "Distribution Systems - Operating." This change retains the technical requirements for the inverters. This s

i.... isjAicnated a sdministrative because it does not result in a technical change to the CTS.

CTS 3.8.2.1 Action c states that with one AC vital bus not energized from its associated inverter 3.8.7, ACTION A 3.8.2. 1, Action c 3.8.7 A.3 re-energize the inverter within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS LCO 3.8.7 Action A states that with one inverter inoperable, restore the inverter to OPERABLE status in 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. This changes the CTS by specifying the 120 VAC inverter as the electrical power source for the 120-volt AC bus.

This change is acceptable because the ITS divides the requirements for the electrical sources from the electrical power distribution systems. The inverters provide the regulated 120-volt AC electrical source(s) for the 120 VAC distribution systems. As a result the ITS states the requirement in terms of the inverter, while the CTS states the requirement in terms of the bus.

However, the technical requirements remain unchanged. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station Page 22 of 25 A-3.8

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.7 A.4 CTS 3.8.2.1 Action c. states that with the AC Vital bus not energized from its associated inverter, 3.8.7, ACTION A 3.8.2. 1, Action c re-energize the AC Vital bus from its associated inverter within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS LCO 3.8.7, Action Note A, states that with one inverter inoperable, restore the inverter to OPERABLE status within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. The Action is modified by a Note that states, "Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any vital bus de-energized."

This changes the CTS by providing a reminder to take action for the AC vital bus system that may be affected by the inoperability of an inverter.

This change is acceptable because the ITS separates the requirements of the electrical sources from the distribution systems without changing the technical requirements. The inoperability of the source may lead to the de-energized bus. Therefore, the user is reminded to enter the appropriate Conditions that may occur from the inoperable electrical source. This change is designated as administrative because it does not result in a technical change to the CTS.

A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.8.8 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

3.8.8 A.2 CTS LCO 3.8.2.2 states that as a minimum either the H or J train AC and DC buses shall be LCO 3.8.8 LCO 3.8.2.2 OPERABLE. The 1-I train specifies the two 120 VAC buses (I-I and 1-2 or 2-1 and 2) are energized from their associated inverter. The J train similarly states that the two 120 VAC buses (1-3 and 1-4 or 2-3 and 2-4) are energized from their associated inverter. ITS LCO 3.8.8 states, "Inverters shall be OPERABLE to support the onsite Class I E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, 'Distribution System - Shutdown."' This changes the CTS by dividing the inverter and distribution requirements into two specifications This change is acceptable because the requirement for inverters to provide electrical power for the AC buses remains unchanged. The inverters provide the associated AC bus with the necessary power to energize the bus. This change is designated as administrative because it does not result in a technical change to the CTS..

Page 23 of 25 A-3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOG No. Description of Change ITS Requirement CTS Requirement A.lI In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.8.9 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 143 1, Rev. 1, "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.

3.8.9 A.2 Not used. N/A N/A ITS Action G states that with two trains of inoperable distribution subsystems that result in a loss 3.8.9 ACTION G None 3.8.9 A.3 of safety function, enter LCO 3.0.3 immediately. The CTS does not include this specific requirement. This changes the CTS by specifically requiring entry into LCO 3.0.3 when a loss of function occurs.

This change is acceptable because CTS LCO 3.0.3 would be entered when a LCO is not met and there are no Conditions or Required Actions stated. The loss of more than one bus continues to require the entry into LCO 3.0.3 in the CTS and ITS. This change is designated as administrative because it does not result in a technical change to the CTI'S.

A.4 CTS LCO 3.8.2.1 states that the following AC electrical busses shall be OPERABLE and LCO 3.8.9 LCO 3.8.2.1, 3.8.9 LCO 3.8.2.3 energized with the tie breakers open between redundant busses. These buses include H and J trains of AC 4160 and 480 volts subsystems. This requirement also includes that each of the four 120-volt AC vital buses is energized from its associated inverter that is powered from an associated 125-volt DC bus. CTS LCO 3.8.2.3 requires the following DC bus trains to be energized and OPERABLE with tie breakers between bus trains open. The trains consists of two 125-volt DC buses, two batteries, and a charger. The makeup of (he 4160, 480, and 120 volt AC buses and the DC buses is addressed by DOC LA.2. The requirement that all buses are energized is addressed by DOC LA.I. ITS LCO 3.8.9 requires that the I-I and J Trains ofAC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. This changes the CTS by combining the requirements for AC and DC distribution systems into one specification.

This change is acceptable because the technical requirements of the CTS are maintained in the ITS requirements. The CTS and the ITS require the various AC and DC subsystems to be OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

Page 24 of 25 A-3.8 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.9 A.5 CTS LCO 3.7.4.1 requires the normal and emergency power supplies to be OPERABLE for the LCO 3.8.9 LCO 3.7.4.1 required Service Water pumps. The Control Room ventilation fails, the Auxiliary Building central exhaust fans, and the Component Cooling Water (CC) pumps may require electrical power from the other unit for the pumps and fans to be considered OPERABLE. ITS LCO 3.8.9, Actions, and Surveillance Requirements are modified to include the electrical distribution systems on the other unit that are required to support shared components that are powered for the other unit. This change maintains the CTS requirements in the ITS format.

The change is acceptable because these requirements ensure the electrical distribution systems that are needed to support shared components on the other unit, needed for this unit, are maintained OPERABLE. This is the intent of the CTS requirements in LCO 3.7.4.1 for the required shared components are to ensure all electrical system necessary to power these components. This change is designated as administrative because it does not result in a technical change to the CTS.

A.I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various 3.8.10 Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "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.

3.8.10 A.2 ITS 3.8.10 Required Action A.2.5 states, "Declare associated required residual heat removal 3.8.10, Required None subsystem(s) inoperable and not in operation." This is required with a Completion Time of Action A.2.5 "Immediately." CTS 3.8.2.2 does not specifically state this requirement. This changes the CTS by specifically requiring the RHR subsystem(s) to be declared inoperable with a loss of the associated electrical bus.

This change is acceptable because the RHR subsystem(s) would be declared inoperable under the CTS requirements. This addition does not change the technical requirements of the CTS but acts as a reminder to enter the Action for the RI-IR subsystem(s). This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station Page 25 of 25 A -3.8

Table A - Administrative Changes ITS Section 3.9 - Refueling Operations ITS Rcquirement CTS Rcquiremcnt DOC No. Description of Change Norlth Anna Current Technical Specifications (CTS) to the plat spccific None V\aiOuS 3.9.1 A In tile conversion of the hnproved Tecinical Spfcilications (ITS), certain changes (wording prcferences, editorial changes, NUREG-.143 1, Rev. I, reformatting, revised numbering, etc.) arc made to obtain consistency with "Standard Technical Sl)ccifications-Westinigtiouse Plants" (IS'I'S).

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

None ILCO 3.9.1 or removed, the boron concentrti Zionl 3.9.1 A.2 CTS LCO 3.9. I states that with the reactor vessel head unlblollcd Applicability is modified by a I'ootnolethat must be within the limit provided in the LCO. The CTS 3.9.1 ves.e l head is unbolted or states, "The reactor shall be maintained in MODE 6 when thc reactor had Lunbo0lted or reniiovedl" or1 removed." ITS 3.9.1 does not include the phrase "with thie reclor ,,;Vessel.

the Applicability footnote.

tile ITS and C'T'S Th'liis change is acceptable because the technical requircmcnts have not changed. Both 6 as, "'oncmor lJre e i'actor vessel Specifications arc applicable in MOI)E 6. The ITS defined MODI)'

I is cqivalc mt to the ITS head closure bolls less than fully tensioned.' 'l'hereOre, tihe C'T'S CO slateiClnit have not changtdd. The ITS MODE 6 Applicability and the conlditionsi uidelr which thc I.CO applies iunh*lted orleno v"c d, so lie. A opplic;Ibility f'o tnote is Applicability is defined as tie reactor vessel hecad as administrative becausc the techniCal (ileqiiiic men ts of the not required.l. This change is(Ics ignated specil'ications have not chan'cd.

I.CO 3.9. I 3.9. I of,Filled pitorions otf thic Reactor Coolant 3.9. 1 A.3 CTS 3.9.1 provides requirements onil the boron concentration onl the horon :mcentratiic itof the System and the refueling canal. '[he ITS provides rCquirementCls civ ity.

Reactor Coolant System, the irefeiling canal, andI the ricfueling iai ed. Th anitcI 'ticie reicliing cavity is This change is acceptable because the technical requoieincits have mhave ti e rIe uel cli. , ,;::vity iV; typically connected to considered to be governed by the CTS requireienlts because as administrative because tihe technical the RCS, the rcfueling canal, or both. This changc is dcsiglatcd have not changed.

retquiremcnts of the specifications 3.9. I of Specification 3.0.3 aleilo applicable.- ITS None 3.9.1 A.4 CTS 3.9. I Action contains the statement, "The provisions 3.9. I does not contain an equivalent statement.

ITS L'CO 3.0.3 is not This change is acceptable because the technical retulL ireinents hIavc 11t cliaed.

This change is designated as applicable in MODE 6. Therefore, the LCO 3.0.3 exccptioin is not needed.

hm' ,-no't chnan getlcd.

admiin istrative because the technical ircquirements of the specilicalions I* .... I ""A-3.9 North Anna Power Station rage I m 1,

Table A - Administrative Changes ITS Section 3.9 - Refueling Operations I)OC No. Description of Change ITS Reqt,iemnt Requirement C(l'S None Various 3.9.2 A. I In tile conversion ol the North Anna Current Technical Speci fications (CTS) to the plant speltific changes, Improved Technical Speci fications (ITS), certain changes (wording prelere'nccs, editorial to obtain consistency wilh N URI X]-143 1,, '.I, reformatting, revised numbering, etc.) are made "Standard Technical Speci I'ications-Westinglouse Plants" ('STS).

These changes aretodesignated as administrative changes and are acceptable because they do not resulIt in technical chlanl~es the CTS.

SR 3.9.2. I 3. 1.1.3.2 3.9.2 A.2 CTS 3.1. I1.3.2 states, "The following valves shall makeup be locked, scaled or otherwise secured in ti. closed '

position except during phlaned boron dilotion or activities. ITS I£CO 3.9.2 states, "tI ach valve A Note to the used to isolate primary grade water flow patihs shall be secured in the closed position."

LCO states, "Primary grade water flow path isolation valves may be opened under adnlinmislratiCe con triol states, Verily each valve that isolates for planned boron dilution or make(up activities."' IS SR 3.9.2.1 I nILoSitioi."

flow pat his is locked, sealecd., or o0the1twise secuIired in the ci oscd primary grade water This change is acceptable because the lechinical req uieIcmenlts have not cI0ihangIed. lInt lIe II'TS, reqti,ircinclits secured are located in the Surveillances, not the I CO. U uder that valves be locked, sealed, or otlherwise lth requirtitcenl SR 3.0. I, the SRs provide requirements nCcessary to meet the [eCO. ThCrel orc, moving The addition of the phrase "tnder ad iniistralive control" to the join the LCO to the SR has no effcct.

Note as, LCO Note is consistent with ihe ITS conventions and does not change the appli cation of the to the operation ol the according to UFSAR Section 15.2.4, strict administrative controls are appl('d is desi gna ted as administrative because it Primary grade water flow path isolation valves. This change does not result in a technical chang'e to the specifications.

None VattiOus 3.9.3 A. I In the conversion or" the North Anna(ITS), Current Technical Specifications (CISI to tile planht spcciflic Improved Technical Specifications certain changes (wording pre'crei es, editorial changes, reforniatting, revised nu,mbering, etc.) are made to obtain consistency with NURIO- 1431, Rev. I, "Standard Technical Specil'ications-Westirighiouse Plants" (lSTS).

not result in These changes are designated its administrative changes and1 are acceptable be'/;use they do technical changes to the CTS.

"7 A - 3.9 I.....1......o,,

North Anna Power Slatton 1 ¢t1*:5*.-,a. x*l i

Table A - Administrative Changes ITS Section 3.9 - Refueling Operations l)escription of Change ITS Requirement CTS Requiremlent DOC No.

of Specification 3.0.3 None LCO 3.9.2 I 3.9.3 A.2 CTS 3.9.2 LCO is applicable in MODE 6, but in the Action states, "T'hc provisions are not applicable." CTS LCO 3.0.3 states that the requirement is, "appflicak'. in MODES I, 2, 3, and 4."

'Therefore, LCO 3.0.3 is not applicable in MODE 6. ITS 3.9.3 does not contain this requiremlnent. This changes the CTS by deleting the rekercnce to LCO 3.0.3.

This change is acceptable because the statement is not required to be stated in) the CTS ot ITS requirements. Therclbre, deleting the statement does not modify any technical requirements contained in the CTS. This change is designated as administrative because it (foes not resull in a technical chanige to thle CTS.

In the conversion of the North Anna Current Technical Specifications (CTS) to Ole plant specific None Various 113.9.4 A.fI Improved Technical Spccifications (ITS), certain changes (wording precrenccs, editorial ci: iges, reformatting, revised numbering, etc.) are made to obtain consistcncy withi NUR, lI-G1431, IRev. I, "Standard Technical Spccifications-Westinghouse Plants" (ISTS).

These changes are designated as ad ministrative changes and are acceptable because hcy do not result in technical changes to the CTS.

is only applicable None 3.9.4 3.9.4 A.2 CTS 3.9.4 states, "The provisions of Sp)ccification 3.0.3 are not applicablc." CTS 3.9.4 duiing specified conditions of MODE 6. ITS 3.9.4 does not include this sliotement. ITS ICO 3.0.3 states, "LCO 3.0.3 is only applicable in MODES I, 2, 3, and 4." This ch::nmcs CT'S by delci ing an allowance already provided in a (Ii Iffre nt portion of tile ITS.

This change is acceptable because ITS LCO 3.0.3 requiremleni s afeconsiS'-tl*! t wilh those stated in the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

pienetrations shall be S 3.9.4. I4.9.4 3.9.4 A.3 CTS 4.9.4 states, in part, "Each of the above required containment building deterfmined to be either in its closed/isolated condition o)r capable of 'eing closed by an OPFIRAB I.E automatic Containment Purge and Exhaust isolationI valv ... by verifying t1hC pclnetrations. a:e in their closed/isolated condition." ITS SR 3.9.4. I states, "Verily each required cotl.ainninnt penetration is in the required status." This changes the C'T'S by eliminating the discussion oCf th required status of)"the cointainment penetrations from the Surveillance.

This change is acceptable because the C'T'S requiremlenls have not changedt. :llhc rCquitfCd stlatUS of the penetrations in C'T'S 4.9.4 is the same as the (description in CTS LCO 3.9.A. The ITS climinates this duplication by rel'errii g to the '"'requ ired status" of tibe penetrations and relying oin the LCO dcscriptioCn.

The changes to the CTS LCO requirements are described in other DOCS. This's change is designated as administrative because it does notCt result in technical changes tIo the CTS.

North Anna Power Station Page 3 of' 7 A - 3.9

Table A - Administrative Changes ITS Section 3.9 - Refuelintg Operations I' 1' CIS Requirenient I

Description of Cliange ITS R~cCIlCuciremt T CTS Requirementi 1 DOC No.

SR 3.9.4.1 CTS 4.9.4.a is modified by a Footnote ** which states "If both doors of tile containment personnel airlock S R 3.9.4. 1 4l.9.4:, Ifoolllote "

3.9.4 A.4 of being closed are open pursuant to Specification 3.9.4.1 above, one door shall be eriflied to be capable each r'equirCd containlment at thie above surveillance frequency." ITS SR 3.9.4. I states, "Verily of thie penetration is in the required status." This changes the C'I'S by eliminating ' he explicit discussion containment persoincl airlock surveillance testing.

ITS This change is acceptable because tile CTS requirements have not changed. Bohlithie CTS and tile require yerification that one containment airlock door is capable of hcing clsw every 7 days. This chang e is designated as administrative because it does not result in technical changes to the CTS.

1 None 1-3.9.4. I Otitti(itC CTS 3.9.4, Footnote *, states that both doolrs of the containment personnel airlock may be open provided, None 3.9.4, IFootnlote

• r39.4 A.5 in part, that there is at least 23 feet of water above t(ie top of the reactor pIessure vessel fIange during movelllment O fufe assemblies within tile containnient. ITS 3.9.4 does notl coltain these restrictions.

This chlanoge is acceptable becaui(se thie feqtiIlirenlcni ts ill Ihle Footnote arle d uplicativye of tilie rieqiretlllenits of ITS LCO 3.9.7, which requires 23 feet of'water above the top of the rcattor vessel flalneo durinlg is titovetiient of recently irradiated fuel assemblies within containiment. Addition of the word 'recently" as administrative because it does not addressed in the DOCs of ITS 3.9.7. This change is designated result in technical changes to the CTS. -i T specific In the cionversion of the North Anna Current Technical Speciflications (CTS )tothe pl;lt Non~e Varifouls 3.9.5 A.lI cha.iges, Ilmproved Technical Splecifications (ITS), certaini changes (wording pireferenies. editorial are made to obtain consistency with Nt. *,RI(1- 143 I, Rev. 1, reformatting, revised numbering, etc.)

"Standard Technical Speci ficatiotis-Westinglhouise Plants" (ISTS).

These changes are designated as administrative clhan ges andif ale accepthabl e ittuSc theI(cy do.

iot rIsitl in technical changes to the CTS.

-i- +

power source 3.9.8.1I tootnote

• r39.5 A.2 CTS 3.9.8. I LCO is modified by a footnote, *, which states that tile normal Cilemergency None loop. ITS 3.9.5 does not iticlude this stait*,Cent. The ITS hel'niitioln of may be inoperable for each RtIR a component is OPERABL.E if either the normal or emergency power source is "OPERABLE" states that portion of the OPERABLE. This changes CTS by deleting an allowance alheady provided in a di fferent ITS.

This change is acceptable because the ITS definition of OPERAB I .t contains l the necessary requiremeits admhinistrative

Is because it Ifor a component to peCrfoIrml its salety funtc tion. This change is designated does not result in technical chang es to thie CTS. I Page 4 oti7 A - 3.9 North Anna Power Station

Table A - Administrative Changes ITS Section 3.9 - Refueling Operations I ITS Requirement I:CTS lequircment Description of Change DOC No.

I I , " o ,I, Action Ii LL CTS 3.9.8. I, Action b, states, in part, that with less than one RIHR loop in operation, suspend all I 3.9.5 Actions ý -, -ý -- I-3.9.8. 1, Action 1) 3.9.5 A.3 operations involving an increase ill the reactor decay heat load or a reduction in lorol lConcentration of the Reactor Coolant System. ITS 3.9.5 states that with the RHIR loop requirements not met, suspend operations involving a reduction ii reactolr coolatn t borion C 1cenlration and suspend loading irradiated foelI assemblies in the core. This changes tile CTS by requiring Ihat tile loading of' iriadiated FeIel assembles be suspended instead of requirinrig that allI opIerations involving ail increase in the reactor decay hleat load be suspended.

This change is acceptable be ause lie requiriClieeits have not Celanged. The creactor decay heat load is in MODE 6 generated by irradiated f'ucl. The only method of iincreasinghe diedecay heat load oF a rcactor is to load additional irradiated fuel assemblies into the core. Theelfore, th ("I'S and ITS Pe11riI Ieqiremerits are equivalent. This change is designated as adtninistrative because it does nrit result. in technical chan,,cs to the CTS.

I i 1- 1 ý11 .. -

3.9.5 A.4 CTS 3.9.8.1 Action d. states, "The provisions of Specification 3.0.3 are not applicable.' ITS 3.9.5 does None 3.9.S. 1 Action (I 11ot inlclude this statement. ITS ICO 3.0.3 states, "[.CO 3.0.3 is only applicable ini MODIIS I, 2, 3, and 4." This changes CTS by deleting,i an allowance alricady provided ill a difTcrent portion oif the ITS.

This change is acceptable because ITS LCO 3.0.3 requirements are consistent with those statedl in the CTS. This change is designated as administrative because it does nolt result in technical changes to the I CTS. -i -- 1*-.

Various 3.9.(i A. 1 In the conversion o1" the North Anna Current Technical Specifications (CT Si thoth plant specHic N one1 Improved Technical Specifications (ITS), certain changes (wording prelcieaccs, ed iorial changes, reformatting, revised numbering, etc.) are madc to obtain consistency with NI.JRFG - 431, Rev. I, "Standard Technical Specifications-Westinghotlse Phlts" (IS'T'S).

These changes are designated as adiniistrative changes and ai1reacceptable ecausc hey hdonot result in technical changes to the CTS.

i ~i .11 11--- .

3.9.6 A.2 CTS 3.9.8.2 LCO is modillied by a lootnote, *, which states that the nornal or enirergency powcr source Nonme 3.9.8.2- ot~tiolne **

may be inoperable for each I-IR loop. ITS 3.9.6 does not include this statement. The ITS delrinilion of' "OPERABLE" states that a component is OPERABLE if either the nornmal or eergency power source is OPERABLE. This changes CTS by deleting an allowance already provided in al diflrent portion of the ITlS.

This change is acceptable because the ITS delinition of rOPERAB-LI contairs rihe necessary requirements for a componeit to perlorm its salety lunetin. Th'nis clmgp is designated asad inkismtive becaose it I does not result in technical changes to the CTS.

Page 5 o1'7 A -3.9 North Anna Power Station

Table A - Administrative Changes ITS Section 3.9 - Refueling Operations If I c, Iie

.........t Description of Change 1 1'S l ccq u nr llc icll .T. cteoenta Requ, DOC No.

immediately I .9.6, Cond it I ý 11 Cl ý 5 .9.8;.2, Action a 3.9.6 A.3 CTS 3.9.8.2, Action a, states, that with less than the required RHR loops OPERABI_.I, 3.9.6, Condition rCquired RHR loops to OPERABLE status as soon as possible. ITS A initiate corrective action to return the loops OPERABLE, 3.9.6, Condition A, states that with less than the required nuimber of RHR to restore required RHR loops to OPERAILEB status or inledialcly initiate immediately initiate action by action to establish 23 feet of water above the top of reactor vessel flange. This changes the CTS providing the option to exit the Applicability of the LCO.

tie Applicabiility of'LCO This change is acceptable because tihe rcquirements have not changed. Exiting not change the is always an option to exit a Condition. Therefore, stating this option explicitly does it does not result require menits of the specification. This change is designated as adin in istrativye because in technical changes to the CTS. -t None 0V'I A .

does 3.9.6 A.4 C--S 3.9.8.2 Action c. states, "The provisions of Speciflication 3.0.3 ar enot applicable." ITS 3.9.6 3.9.8J.2., /Action c only applicable in MODIES I, 2, 3, and not include this statement. H'TS LCO 3.0.3 states, "I.CO 3.0.3 is ofilhe ITS.

4.' This changes CTS by deleting an allowance already priovided in a diflerclit portion with those stated in the This change is acceptable because ITS LCO 3.0.3 requirements arC consisteat as ad inin strative because it does not result in lcchnliiical changes to the C'TS . This cIIlanlge is designated C'FS. 3.9.6 Actions -I- A.9..2,

- Act (iii ii suispend all 3.9.8.2, Ac~llii 1) 3.9.6 A.5 CTS 3.9.8.2, Action b, states, in part, that with less than one RHR loop in ojperatioll, 3.9.6 Actions I..*:thoi conceitlatiloil o1 i*:

operations involving an increase in the reactor decay heal load or a redtucLi oplcrationl, su spend operations the Reactor Coolant System. ITS 3.9.6 states that With nlioRFIIR 10oo1p in the CTFS by eliminating the involving a reduction in reactor coolant boron concentration. This changes requirement to suspend operations involving an increase in reactor decay h":.' load This change is acceptable becaise the requireients have not clanged!. 'e reactor cciy liheat load is of increasing tlie decay liead load of a reactor in MODl 6 generated by irradiated fuel. The only method into the core. However, ITS I.C0 3.9.7 iprohibits loading is to load additional irradiated fuel assemblies the water level is less than 23 fect. ['llore. when LCO 3.9.6 of fuel assemblies into the reactor when available to increase the reactor decay hema load and the requirement can is applicable, there is no method because it does be deleted with no effect on plant operations. This change is designated as !';,,iitiflve the CTS.

not result in technical chanýes to I I Page 6 of 7 A -3.9 North Anna Power Station

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Table A - Administrative Changes ITS Section 4.0 - Desi.m Features DOC No. Description of Change ITS Requirement CTS RC(,liicqtfieflt Various Various 4.0 A. I In the conversion of the North Anna Current Technical SpcciFicalions (CTS) to the plant spceific Improved Technical Speci fications (ITS), certain changes (wording pirefcrenccs, editorial changes, relorniatting, revised numbering, etc.) are made to obtain consistency with NURFC-(143 1, Rev. I, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and aic acccptable, bccause they do not result in technical changes to the CTS.

storage None 5.6.1.3 4.0 A.2 CTS 5,6.1.3 contains requirements on storing new Luel For the first core dry in the Spent luef pool racks. The ITSS does not contain this inForrmation.

This change is acceptable beca use the requirements are no longer relevant. "'t'h North Anntia reactors have loaded their first cores and the spentIluel pool is filled with water. These requnrements will not he usedl again. This change is designated as administrative because it eliminateoneC-ti me requirements which no longer apply.

4. I None 4.0 A.3 ITS 4.1 contains a description of the site location. The C'T'S does not contain this information.

This change is acceptable because it does riot add, (lcfcle, or modily any req.h' ii'its. "I'Iiiei ch c is designated administrative becaCus it does not result in a teelIICnical clhange to the sp-ccilicati m s Page I of[ A -4.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls DOC No. Description olfChange ITS Requirement C'FS Pequ irement 5.0 A. I In the conversion of the North Anna Current T'1echnical Spe cifcations (CTS) to the plant specific Various Vaiollus Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NU RUG.-143 I, Rev. I.

"Standard Technical Speci fications-Westinghouse PhMlts" (ISTS).

These changes are designated as administrative changes and arc acccpt*ble biecause they do1 not result in i technical changes to tihc CTS. _

I R I None 5.0 A.2 CTS 'Fable 6.2-I states Shift Supervisor (SS), Senior Reactor Operator (SRO) and Reactor Operator (RO) Table 6.2-1 This changes the CTS by manning requirements. The ITS does not itIchLide these manning requiremenls.

not including manning requirements already required by 10 CFR 50.54(m)(2 t(i).

The purpose of CTS Table 6.2-I is to specily the minilrluIfl shilt crew composition consistent with 10 CFR (m)(2)(i). This change is acceptable because 10 CFR 50.54 (in)(2)(iI) already states this required Composition. This change is designated administrative hecausc it docs n(t result in) technical changes to the CTS.

T 1 5.0 A.3 CTS 6.8. I.b requiiires written procedu'res be established, implemented and maintained covering refueling 5.4. I.a 6.8. 1.1) and 6.8. I.c operations. CTS 6.8. I.c requires written procedures be established, implemented and maintained covering surveillance and test activities of safety related equipment. ITS 5.4. La requircs written procedutcs shall be established, implemented and maintained to cover the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. This changes the CT'S by deleting the specific wording of 6.8. Lb and 6.8.1 .c, which is already addressed by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978 and is committed to in CTS 6.8. La andllITS 5.4. I.a. CTS 6.8. I.h requires written procedures he established, implemented and maintained covering refutelit,g operations. CTS 6.8. I.c requires written procedures be established, implemented and maintained covering stXeLII 'Cilancc and test activities o1 safety related equipment. ITS 5.4. L.a requires written procedures shall be established implemented and maintained to cover the applicable procedures recommended in Regulatory Guide  ! 33, Revision 2, Appendix A, February 1978. This changes the CTS by deleting the specific wording of 6.8. 1.b and 6.8.1I.c, which is already addressed by Regulatory Guide 1.33, Revision 2, Appendix A, FAbruary 1978 and is committed to in CTS 6.8. l.a and ITS 5.4. ].a.

This change is acceptable because tile iecotmmendations of Regulatory Guide. 1.33, Revision '. ,"`ppendix A, February 1978 already require procedures for refueling operatioins and f15surveillhance tests tIor safety riclated to the activities. This change is designated administrative because it does not rc:;utt in t.echnical changes CTS.

I North Anna Power Station Pa ge I ofI'I1 A - 5.0

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls cU Ic D.elIC~in ITS15 li.eqtClelenll ICTSI l 11 DOC No. Description or Change n(. l'el.8. lltII I II None I 6.8.1d and 6.8.1.e 5.0 A.4 CTS 6.8.1 .d and CTS 6.8. L.e require written procedures be established, implemented, and maintained to INone 6.9.1d does not contain these address implemenlation ol the Security Plan and the Emergency Plan. The ITS I Sccurity Plan and t:.e requirements. This changes the CTS by deleting the specific reference to the Emergency Plan because they arc already required by 10 CFR t50.54(p) and 10 (CFR50.54(q), respectively.

Security and I"lli errgcncy Plans This change is acceptable because thie reqtiiicments for imnip!clcenltation o1"ithe deSjin!_iCed administrative becaulse are contained in 10 C[-R 50.5 (p) and 10 CFR 50.54(q). This chllange is 4

it does not result in technical changes to the C'ITS. I 5.5.10 I 4.7.7.1 and 4.7.8.1 shall be established to 5.5.10 4.7.7.1I and 4.7.8.1I 5.0 A.5 ITS 5.5. 10, Ventilation Filter Testing Program (VFTIP), states, "A prograni required testing of Engineered Safety Feature (LSF) filter ventilation systems at implemifelit tile following y Positions C.5.a, C.5.c, Frequencies in general conformance with, and in accordance with Regulatot

- CTS 4.7.7. I (Control C.5.d, and C.6.b of, Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 System) include Room Emergency Ventilation System) and 4.7.8. I (Safeguards Area Ventilation Positions C.5.a, ('.5.c, C.5.d, and requirements for ventilation filter testing in accordance with Regulatory changes the C"!'S by consolidating C.6.b of Regulatory Guide 1.52, Revision 2, and ANSI N510- 1975. This existing ventilation requ,irements in a single program.

for the ventilation filter The purpose of C'TS 4.7.7.1 and 4.7.8.1 is to specil'y the Surveillance Requirements testing in accordance with Regulatory Positions C.5.a, C.5.c, C.5.d, and C 6.' of" RegulIatory Guidc 1.52, it retains cxistinu Ventilation testing Revision 2, and ANSI N510-1975. This clianige is acceptable because admiistiraliVe hbecausIe it does riot requirements in a single program in the ITS. This change is designated result inltechnical changes to tile CTS. 5.1.2

________________ 4 'lahlc 6.2 I tile Cont rol Room hilelic tle 5.1.2 Table 0.2-1 5.0 A.6 CTFS Table 6.2-I states, "During any absence of the Shift Supervisor friom with a Valid RO license...shall be d(s;nae:ilcd to assume the unit is in MODE 5 or 6, and individual luinction.' ITS 5. 1.2 adds the option For a personi with an active SRO license to Control Room command cIarnfylag that an Only also SR()

assume tile Control Room command fuiictioi. This changes the CTS by assume the Control Room conimandId Function.

allowed to assume the Coitrol This change is acceptable because a person with an SRO license is always to use lRO al is an c,.xc,.:ption ito thiat requirement.

Roomn command Function. The CTS and ITIS allowance it does not resul in tieclhi'al c.hanges to the CTS This change is designated administrative because I Page 2 of 14 A - 5.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls ITS Req1,., t meilcn CTS Reqictir cel DOC No. Description o1" Change 50 A7 ITS provisions "The3.4.5 5.5.8 states,CTS or SR 3.0.2 arc apjplicable to the SG TU'be Surveillance P:rogramlTest 5.5.8 3.4.5 Frequencies." does not include such it rCerence because CITS 4.0.2 already applies to CTS providcd 3.4.5. This changes the CTS by adding an eXp)liciti rcerencc to the VFI'S o0 an .llowal:Ct without the reference in the CTS.

and is only required This change is acceptable becausc the added phrase retains ai cxisting allowance, bec ausC it because of the change in format from CICTS to ITS. This chlnge is dCsignated administrative does not result in technical changes to the Cl'S.

None 6. I 5.0 A.8 CTS 6.11, Radiation Protection Program, states, ,,Procedures for pcisonilcl radiatioln protection shall be maintailincd, and adhered prepared consistent with the requirements of 10 CFR Piatl'20 and shall be approved, raddiation exposure." The ITS does not inchlde a*rcqtrl.I elit For it to for all operations involving pcrsonnel the CTS by removing re ferences to rCquirCmcnts alCready Radiation Protection P)rogram. This changes required by 10 CFR Part 20.

10 Cl:R Part 20 are alreCdy required Io he net.(.iThis This change is acceptable bccause the requirements of't tot ("S.

change is designated administrative because it does not result in technical changes Ihlc supervise.l by either a None 6.2.2.d 5.0 A.9 CTS 6.2.2.d states, "ALL CORE ALTERATIONS shall be observed and dirocfly amdling who has no other licensed Senior Reactor Operator or Senior Reactor Operator Limited to( IFelIn I(10Cl1R ConCUrrent responsi hbilities douring this operation." ITS 5.2.2 foes tnot conta in t iis requirctilelint.

6 altleration ollf the cCn0 of a nucleai pIowver 50.54(m)(2)(iv) states, "Each licensee shall have prcscnt, during it seii or operator licclise olr it senior operator un it (including fucl loading or trtansl'er), a person holding see shall not license limited to ruel handling to directly supervise the activity arId, during this ti, limetithi c'ci the CTS 6.2.2.d by delcting this illn1Irnlation eCcausc if is assign other duties to this person'." This changes already a requirement in laccordance with 10 CFR 50.54 (m)(2)(iv).

SCd SRO limited1 lot: fuel The pLrpose of CTS 6.2.2.d is to ensure the presence of a licensed SRO0or licC:

conct,'renl responsibilities during this operation. This ciiinge is acceptable handling who has no othcr ort 10 CFR 50.54 (m)(2)(iv), arid the reqUirecmrt is relaincd, but not in theleITS.

because it is a duplication in technical changes tco thwinCTS.

This change is designated administrative becaulse it does not result Page 3 of 14 A - 5.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls 1, 1- . 1 1 DOC No. Description of' Change ITS Re itu el tI CTs1Rcqture-n 5.5.15 4.6.1.1, 4.6.1.2, requiremcnCs for 5.0 A.10 CTS 4.6.l1.l1, CTS 4.6.1.2, CTS 3.6.1.3, and CTS 4.6.1.3 specify the leakage rate 5.5.15 4.6.1.1I , 4.6.1.2, 3.6.1.3 and ,4.6.1.3 Rate Testing Containment Integrity and thc Con(ainnienit Air Locks. ITS 5.5.15, Containment Leakage Ai Irocks within (the Program, specifies the leakage rate requirercinl s fo rt[le Containment and Containment leakage rate acceptance Containment Leakage Rate Testing Program. T'lhis changes the CTS by moving the "Containmcnt criteria For Containment Integrity and Coilntainimenat Alr IrLocks in the C'T'S to ITS 5.5.15, Leakage Rate 'resting Program."

hut as This change is acceptable because the samc containment leakage rate requirements are being applied, I 'This chanige is a program in ITS 5.5.15 instead of individual I.COs and Surveillance Rcquircmnlts.

designated administrative because it does not result in technical changes to tie CTS. 5.. (il reviews perlforIed 5.0 A.-1 CTS 6.15 states, "Changes to the ODCM: a. Sliall be documented and records of 5.5.1 6.15 initiated changes to shall be retained as required by Specification 6.10.2.r." ITS 5.5. I states, "licensee shall Ihe retained." T'his clihaages the ODCM: a. Shall be d cLaMcitcd and records of reviews perItormed the CTS by not including a reference to how the records arce to be rclained.

freom the CTS by This change is acceptable becauseCe ferenced feqtirenment CCTS 6.10.2.r was removed is desigccaced admi cistrative because it North Anna amendment 208 (Unit 1) / 189 (Unit 2). This change does not result in technical chances to tile CTS.

asappropriatce 5.0 CTS Table 6.2-1 lists acronym definitions for shiflt manning. These acron ycmis arecdeflicied TLablc 6.2- I 115.0 A.12 I in parts of ITS 5.0, atid the ITS does not include a consolidated list. This cci thI C'IS by deleticig the consolidated acronym list acid deicning them as needed ili ITS 5.0.

urpinate in ITS 5.0, acid This change is acceptable because the actrOclynIs arC adequately de'iced wit:,'

because it does it is not ncecessary to have a consolidated list. T[iis change is designated adciniistrative not result ill technical chlanges to the CTS.

i- 1 CTS 4.0.5.b does not specify a biennial or every 2 years frequency of "at Icas! ,c p ,er 731( days." ITS 5.5.7 4,0}.5.1) per 7 1 days. This changes the 5.5.7 incluCdes a biennial or every 2 years frequency of "at least once the ASMF Boiler and Pressure Vessel Code biecnia! or every 2 years CTS 4.0.5 by incorporatingg f'requency of "at least once per 731 (days."

g iniservice testincg The purpose of CTS 4.0.5.b is to specify the required frequencies lor perlr irciic activities associated with ASME Boiler and P'ressurc Vessel Code. This cln~tcmgc is acceptable b1ecauscit and Pressure Vessel Code biennial or every 2 years frIcquecncy of "biennially or adds the ASME Boiler dcministrcaivc because it every 2 years" without adding any new requiremecnts. This change is desiinait2',t I does not result in technical changes to the CTS.

Page 4 of 14 A - 5.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls

-- I4- 0 IXI.A1 t111S...IIr'..II' I I ....C"]'C.'I)....

U I )

Description of Change I No1 Rommcment ITS I 6.9. . and j6 ,

DOC No.

C ntrol i',sk with copics to the None 6.9.1.6 and 5.0 A.14 CTS 6.9.1.7.d requires the COLR to be provided to the, "NRC DIocument 6.9.1.7.dI thc Monthly )pcrarllng Repoirt be Regional Administrator and Resident Inspector." C'FS 6.9.1.6 requircs U.S. Nuclear Regulatory Commission, submitted to, "the Director of Management and Program Analysis, of Inspection aid E'nlolcemntlcl ' ITS Washington, D. C. 20555, with a copy to the Regional Oflicc requires the Monthly Opcrating Report be 5.6.5.d requires the COLR ebprovided to the NRC. ITS 5.6.4 regarding distribuLion or thc reporls to the submitted. This changes the CTS by removing the specifics NRC, which is addressed by 10 CFR 50.4.

icC4iions to the NRC is governed by This change is acceptable because the distribution of wr itten comnIun unnecessary.i'This change is designated 10 C+R 5(0.4, and administrative duplication because in the Technical Specilicatioris it does lnot result illtchnIIiCIIcal tois the CTS.

Jchags

-4 -

Sample Inspection, Additional SG is C-3, 5.6.7.c "T'able 4.4-2 5.0 A. 15 Unit I CTS Table 4.4-2, Steam Generator 'l'ubeInspection, 2'"

4.19-2. Stcam GeneratoI 'Tluhe Action Required includes, "Report to NRC..." Unit 2 CS 'Table Additional SG is C-3, Action Inspection, I" Sample Inspection, C-3 result, and 21d Sample Inspection, include it statinicni requiring prompt Required includes, "Special Report.' ITS TahIc 5.5.8-2 does not lubC inspOt'tionS that tall into CIItegory NRC notification. ITS 5.6.7.c states, "Results o1 slcain genCralor 511.72 to 10 CFR Part 50. A C-3 require prompt notilication of tihe Commission psulant to Section 50.73 to 101 CIR Part 50 and shall p*ovidC Licensee Event Report shall be submitted ptu'suant to Section of' the ItubC dCgradalion and corrective a description of investigations conducted to determine cause CTS by removing a Iepolrting reference that is measures taken to preventt rccurrencce. 'This changes the required by other sctions of the T'0 echnical SpecificatoliOs.

Olew 'I; .ddre'-scd by other sh Tiffs change is acceptable because a duplicate rcporting requirement is d I bccaust, iti d not', result in technical Technical Specifications. This change is designated admninistrative "changes to ihe CI'S.

Plagc 5 of lJ A -5.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Adminisralaive Controls DOC No. Descripion of Change ITS Rcqiirc et CTS Rcquiiircnmct i iui4.i 1 ..

5.0 A.16 CTS 4.6.1.2 and CTS 4.6.1.3 regarding the containment and containmlent I..netrations, and each None 4.6.1t.2 anld 4.6,1.3 containment air lock, respectively, state they shaihll,--be tested by performing le,'Ikage rawetestloig as required by 10 CFR 50, Appendix J, Option B, as inodi fled by approved exemplions, and in accordance with the guidelines conlained illnRegulatory Guide 1. 163, dated Septemher 905. The provisions of Specilication 4.0.2 are not applicable." ITS 5.5.15, Containment 1.cakage Rate Testing Proggram, does nol include the statementht i tile provisions of Speci lie.at ion 4.0.2 are not ;applicable, hot statcs, "Nothing ill these Technical Specifications sliall be construed to modi ly the testing Frequencies reqnuired by 10 CFR 50, Appendix J." This changes the CTS by removing a statement (hat part of Section 3.0 does not apply to this testing requirelilent which is being moved to Section 5.0 because Section 3.0 is understood to not apply to Section 5.0.

The purposC ofl the CTS 4.6.1.2 and CTS 4.6.1.3 statements that the provisions of Specification 4.0.2 are not applicable is to require tle tes tillng frequnLICIiCes f oil contailinnlent andl contahll iC Ofpenetrations to reminl as requilred by 10 C1FR 50, Appendix J, Option B, as, (modified by apprioved exeCmption.s, and ill accordatnce with the guidelines contained ill Regulatory Guide I. 163, dated Septeitiber 1995. The NRC and industry position is that Section 3.0 does not apply to Section 5.0. The stalement,."Nothing in these Technical Specifticationis shall be construed to modily the testinrig ['reqCuericS requiired by 10( CFR 50, Appendix J," was added to avoid any possible conilusion. Therefore, the requlircliments of ('TS4.0.2 continue to not be applicable to tlhe containmlent and conlaihnint penetration leaktage testing requiremen tsl,but the f1orniat is changed to aceonmmodate nmoving ttie lestinig requiihImols to Section 5.0.

This chanige is designated adniniistrative because it d(oes not result ill technical canges: to tileC CTS.

-t i-5.0 A. 17 ITS 5.7.2.a.2 states, irn refrerice to ciiilryways to high r adiationoh areas with doIseC ate greater than 1.0 5.7.2.a.2 Nonle (isoUlce or r1rolla riy SIIl ace fbnet rathlie renIl/fi)LI-r at 30 cenlilieters froll(tclie raildiation RaCd iat ioCI, "Doors anrd gates shall ICml ain lockedC except CliirIing peroios of' pef'r0 sonliel o' uirllllC!lt 2Cf!.:. eCiiry Or Cexit."

The CTS does riot inliude suehi a statement. This changes ile CTS by adding aitclatiortha ittli it door and gate barriers may be openedi for ientry and exit.

Thiis Clialnge is acceptable because it clhlies thiat eiltry and exit tIhroughIiht ,hi';h' baCrieSisa 11(\vwed CiidCl specified controls, as is the case i ltile C'T'S. This change is designatedi adnlilraititi\,e because it does inot result inltechnical changes to the CTS North Anna Power Staliono Page 6 of' H' A -- 5.0

Table A - Administratik'e Changes ITS Section 5.0 - Administrative Controls

'1 II'S Requli cment -i CiS Recjiiireinent Description of Change ITS IZR L~lcluire lt CTS IRcqtuirenimnlt DOC No. _ __ __ __ _ __ __ __ _ _ _ _ _ _-------_ __---_ _-__------

I 5.5.11 I - . . . I- . . -

5.0 A.18 ITS 5.5. II states, "The provisions of SR 3.0.2 and SR 3.0.3 are applicable t,) the Explosive Gas and 3.11I.1 and 3.11.2 Storage Tank Radioactivity Monitoring Program surveillance Frcqtencie:.;" ['S 3. I 1.1 and CTS 3.1 1.2 which are equal to ITS SR 3.0.2 and SR did not include such requirements because CTS 4.0.2 and 4.0.3, 3.0.3, already apply to CTS 3. I I.1 and CTS 3. I1.2. This changes the CTS by adding a rcference for an allowance applies for testing iin Section 5.0.

allowance because it must be stated that the existing is only requircd This change is acceptable because the added phrase retains existing allowancs, and CT'S to the ITS. This change is designated administrative because of the change in format from the because it does not result in technical changes to the CTS.

I None t 6.6.1 A. The 5.0 A.19 CTS 6.6.1 states, "The following actions shall be taken for REIPOR'I'ABLE VFVINTS: None 6.6.1 notiflied and a report submitted pursuant to tih crquircmlents ol Section 50.73 to 10 Commission shall be the CTS by deleting CFR Part 50, and..." ITS 5.0 does not 7include these rcquircmlenls. This changes requiremelits already required by 10 CI R 50.73.

still rejuired without a This change is acceptable because the reporting requLirenients of I0 CI0R 50.73 ale it does not resstlt in technical reference in the ITS. This change is designated administrative because changes to the CTS. i i to other CTS 5.0 A.20 CTS I. 17, 4.0.5.c, 4.4.5.1, 4.4.5.2, 4.4.5.3, 4.4.5.4, 6.9.1.5.b, and 6.12.2 include references Vari'ous 1. 17, 4.0 .5.c, appropriate req,"I.rmnts. This C,'hanges the 4.4.5.1, 4.4.5.2, requirements. The ITS modifies these to ITS references or 4.4.5.3, 4.11.5,4, CT'S by making appropriate references in thie ITS. 6.9. 1.5..b, and 6.12.2

'o1r ti-c '['S. ['his change is This change is acceptable because it makes appropriate reference changes because it does not result in technical changes Io the Cf!S.

designated administrative -t r ol ASME Code Class I, 2, and 3 ctmnponent:; and inservice None 4.0.5 5.0 A.21 CTS 4.0.5.a states, "Inservice inspection 3 pumps and valves shall be performied in accordance with Section testing of ASME Code Class I, 2, and by 10 CFR 50, XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda :iu.required specific written relief has been granted by the Commission pursulatit to Section 50.55a(g), except where CTS 4.0.5 and CTS 4.0.5.c reference inservice inspection 10 CFR 50, Section 50.55a(g)(6)(i).

statement ill requirements for ASME Code Class 1, 2, and 3 components. ITS 5.5.7 doeCS not ieldthe CTS by not CTS 4.0.5.a and does not include references to inservice inspection. This changes the Class I, 2, and 3 including a reference to 10 CFR 50.55a requirements or references to ASM I` Code without thie ieference.

inservice inspection. The 10 CFR 50.55a requirements are still applicable This change is acceptable because the 10 CFR Part 50 requirements are still appl icable and relfcrencing it does 1o1 restUlt in them separately is unnecessary. This change is designated administrativye be,---use tcchnical changes to the CTS. I I

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Table A - Administrative Changes ITS Section 5.0 - Administrative Controls l't'S Requirenient CFS Requirement DOC No. Description of Change ITS ReCt, ircinit CTS Requni-CcnLn None I None I 4.4.10.1

. ý -- .

Ihe Racor Coolant puiimp 4.4.10.1 5.0 A.22 CTS 4.4.10.1. I states, "In addition to the requirements of Specification 4 0.5.

I flywheels shall be inspected..." ITS 5.5.6 does not include tile ref'erence to Specifidation 4.0.5, which is C'TS 4.0.5 requirements ITS 5.5.7, Inservice Testing Program. This changes tile CTS by not referencing which are required regardless ol the refcrence.

has il's own Criteria flo This change is acceptable because it deletes a relference to a requirement that because it does not application, regardless of the rel'erence. This change is designated administrative result in technical changes to the CTS.

i t to the VVITPlest frequencies.' 5.5.10 4.7.7. and 4.7.8 5.0 A.23 ITS 5.5.10 states, "The provisions of SR 3.0.2 and SR 3.0.3 are applicable these allowances, but they apply as CTS 4.0.2 and CTS CTS 4.7.7 and CTS 4.7.8 do not explicitly state allowances applyit tall ilhe CTS LCO 4.0.3, which are equal to ITS SR 3.0.2 and SR 3.0.3, because these the allowances orl'TS SR 3.0.2 Surveillance Requirements. This changes the CTS by explicitly invoking and an explicit allowance is and ITS SR 3.0.3 because tihe requirements have been moived to Section 5.0.

needed to retain the existing allowances.

lhcmi into ITS formal.

This change is acceptable because it retains existing allowances by tr;alnslcrrlellp in teeilICihn,.al ciallw.s to hile CT[IS.

This change is designated admiiinist rativye because it does not ieslt i ~1 T'itlc 10, ('ode of l*ederal 6.9.1 5.0 A.24 CTS 6.9.1 states, "In addition to tile applicable reporting requireCents of None reports shall be submitted to the Director of the lRegional (OHliceof Inspection Regulations, the following cportIs -.hall he subhitncd in and Enforcement unless otherwise noted." ITS 5.6 states, "The following 10 Cl:R 50.4 as tihe refcrence for accordance with 10 CFR 50.4." This changes tile CTS by referncing already addressi-d in It) CFR 50.4.

how to submit reports and excludinrg hle remaining detail, which is e:sltilishtw'lin 10 CFR5 0(.4, and This change is acceptable because thle repo rting req u iremenIts are already change is designated admiiistri:t ivobecause it does riot result do not need to be repeated in the ITS. This in technical changes to the CTS. --I- None t 6.9. I .4 be sub r ii .oriortoNMarchIIoft(lie None 6.9.1.4 5.0 A.25 CTS 6.9.1.4 regarding annual reports states, "The initial reportt shra,.

include such a statcmcn;. Thr:, changes the CI'S by year following initial criticality." The ITS does not and willi not be replcated.

deleting a requirement l'or report submissions that have already occurred alheadv bee n rleltidriao longer This change is acceptable because thie one time report requirement has d(ICes tnottrcstuIt ili technical nceds to be specified. 'T'his change is designated admin istrativ e becaurse il changes to the CT S. -4 N/A I N/A -

IN/A N/A 1 r ,( A -).A Not used.

1___________________________

-).0 A.ZO t 11 Page 8 of 1.; A - 5.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Change ]TS Requirement CTS Requirement 5.0 A.27 CTS 6.9.1.7.c.2f, References for the Core Operating limits Report, states, "WCAP- 12610, 5.6.5.1.7 6.9.1.7.e.21' "VANTAGE+FUEL ASSEMBLY REPeORT," June 1990 (W Proprietary)." ITS 5.6.5.h.7 states,

"-VANTAGE+FUEL ASSEMBLY-REFERENCE CORE RETlORT."'lThis changes the CTS by correcting thie reference to thie title of WCAP- 12610. Regarding deletion ofl, "June 1990 (WYProprietary)," se" DOC LA.9.

This change is acceptable because it corrects the title of a i elrence used, WithoUt chan,ging tile reference.

This change is designated administrative because it does not result in technical changes to file CTS 5.0 A.28 CTS 6.2.4. I states, "Tile Shil't Technical Advisor shall serve in an advisory capacity to Shilf Supervisor 5.2.2.1 and 5.3.1 6.2.4. I and 6.3.1.2 on matters..." CTS 6.3.1.2 states, "Incumbents in the positions of Shift Supe-rvisor, Assistant Shil't Supervisor (SRO), Control Room Operator"- Nuclear (RO), and Shi[It Technical Advisor, shall mcet or 9

exceed the requtirements of 10 CI R 55.59(c) and 55.31(a)(4)." ITS 5.2.2.1 .;t':tes, "An idhvidual shall provide advisory technical support to the unit operations shiIt crew..."'ITS 5.3. 1 states "'The SS, Assistant SS, Control Room Operator - Nuclear, arnd individual piroviding advisory technical sIrppoirt to the unit operations shift crew, shall meet or exceed the requiremcents of'(1 ('PR 55.50(c) and 55.3 I(a)(4)." This changes the CTS by removing the Shifl 'lechnical Advi.-:ir title, and replacing the term S hi ft Surpervisor with unit operations sl/ift crew, though the reqIiiln'Clire iii t"1tile per sonr with tile specifed responsibility remains the same.

This change is acceptable because the individual assigned to thie responsib;lIities described still carries out the same tasks. The support provided is for the henefit of the unit operation,; shi ft crew, its well as thie Shift Supervisor. This change clarifies that the assigned individual may prvic re We support directly to the Shift Supervisor or other members of thie unit opelrations shift crcw, hul rfhe resnlt will be stulXii t for tile crew as a whole in either case. This change is designated admninistralive ecal..c x i" does not result ill technical changes to the CTS.

North Anna Power Station Page 9 of' 14 A - 5.0

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls ITS1*Req uII C mirct CIS RequLIC ireC et DOC No. Description ol Change 5.3.2 None 5.0 A.29 CTS 6.2.4.1 states, "The Shift Technical Advisor shall serve in an advisory Capacity to Shift Supervisor on niatters..." CTS 6.3.1.2 states, "Incumbents in the positions of Shilt Supeirvisor, Assistan! Shilt shalli mce( o Supervisor (SRO), Control Room Operator - Nuclear (Re), and Shi ft Technical Advisor, exceed the requirements of 10 CFR 55.59(c) and 55.31 (a)(4)." ITS 5.2.2.1" stlates, "An ilndividual shall crew..."rl'S 53..1 Slates, "The SS, provide advisory technical support to ihe unit operat i oils shif to Assistant SS, Control Room Operator- Nuclear, and individual providing advisory technical sup0port the unit operations shiflt crew, shall meet or exCeCd the requirements of )10 Ci;R 55.59(c) and 55.3 I1(a)(4)." This changes the CTS by removing the Shiuit Technical Advisor title, and repla.. ng the term Shift Supervisor with unit operationis shiftcrew, though the requireilelint fIm0 t cpersoWn with t lespecificd responsibility remains the same.

This change is acceptable because the ilidividLial assigniCd to(Ite ICSlIee Isibi~liieCS LdesCrihed still CarriCs out the same tasks. The support provided is For the bentefit of the unit operations shliiIt crew, as well as the Shift Supervisor. This change clarifies that the assigned individual May rOw ItheICle Sul*pport direCCtly to tle S hi ft Supervisor oroither members of' the uinit operations shiiIt CreCW, b tlt Ih CCSi1l will bc s upp fir torl tile crew as a whole in either case. This change is designated adminiistratic beicausC i leesCnlot result ill technical chanl'es to( the CTS.

ofn 5.5.4.1 6.8.4.e.2 5.0 A.30 CTS 6.8.4.e.2 states that the program provided coilIFoirming wilhi 10 CFR 50.36a iiChdes, "11nilitations the conicentrationis of radioactive material releasedl il liuidL eLIieiits 1 tto UNIRIhSTR(TlI) ARFI AS coinlformirniig (toten times 10 CFR Part 20 Appendix B, Table 2, Column 2." 'S  ! 5.5.4.b ireferences 10 thiat CFR 20.1001-20.2402. This changes the CTS by referencinig the specilic portion o" 10( CFR Pait 20 includes the referencel requirement.

This change is acceptable because it clarifies which regulatory requtirelnt let'sCeferenced is I[or-ilCeting the This ctiallC is d.,signlatCd Technical Specification reqiliretnenlt, buLildoes not change (ie requ,irement.

administrative because it does not result in technical changes to the CTS.

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Table A - Administrative Changes ITS Section 5.0 - Administrative Controls II'S i(equireinent L I KC(lttirenletlt Description of Change ITS Rc(Iuir-cII)Cnt I i TS15Requiremecnt I DOC No. 5.7.1 and 5.7.2 the ntnsity of' radiation is S6.12.1 and 6.12.2 5.0 A.3 I CTS 6.12.1 applies for con"trol ol entry into high radiation areas in which 5.7.1I and 5.7.2 CTS 6.12.2 applie- i',,r controI o1 entry intoI high greater than 100 nircm/hr but less than 1000 mrenl/hr.

of' radiation is greater than 1000 mrem l llrh1ut ess than 500 1rads/hr radiation areas in which the intensity or any surface through which radiation pcnetr')tcs. ITS 5.7.1 applies at one ntcr from a radiation sour-CC rcm/hIour !it 30 centimeters fjrom the to controls for high radiation areas with (lose rates not exceeding 1.0 by the Radiation. ITS 5.7.2 applies to controls for high radiation source or fromi any Surface Penetrated 1.0 rein/hour at 30 centimneters ofiln tIe radiatio sorl0iCCe or radiation areas with dose rates greater than rads/Iir at i; c icwr tioml a radiation l'ro m any Surface Penetrated by the Radiation, but less lhan 500 Ohw "I'S by deleting tile rel'erence source or any surface through which radiation penetrates. This changes "at and ;ad(!:; the cCriteria o",

to a high radiation area having radiation intensity in excess of' 1001 re ii/hr.

by the Radlatio " to the 30 centimeters tron the radiation source ori roll any Surface Penetrated parameter 1000 noreno/hr.

These changes are acceptable because the It)[i)lile/hri/lr hiniliot t for a hi gil rad iation area is alecady ierm/hrl is iat.ilfied inl terms ol addressed by 10 CFR 20. 1003, and the method of mleasu rilg the 10(0(0 si des-;in, amte.'ald i inisiralive being measured from a point soLItIce aCiid I'toM1 a surlace. This changei chaln1es to the CTS.

because it does not result ill technical I _ _ __ _ __ _ _i aCtis slýl bc to None 41.0.5.dl 5.0 A.32 CTS 4.0.5.d states, "Performance of the above inservice inspectioni ain( tesitg The IS (does notC inlde an Ilequivalnct addition to other specified Surveillance Requiremcnts."

requireienet. This changes the CTS by not explicitly statingI thatte inscrvi:lsm.etltol and testing other speci ified Surveillance RequircnIenI,;.

activities shall be in additioll to aric stil required by 10 "Thischange is acceptable because the inservice inspection and testing activi, icN, Tl'esting Program. A spcci lie reFcrncc to this CFR 50.55a, as appropriate, and ITS 5.5.7, the Inservice administrative' because it (oC.- eCsult in tcchlical fact is unnecessary. This change is designated intIt changes to the CTS. -+ i and tesltt1in, acuvitics shall be in None 6.9.2 5.0 A.33 CTS 4.0.5.d states, "Perliorniance of the above inservice inspection does not cl.udc ant equi valeiit addition to other specified Surveillance Requirements." The ITS inservice,' itspectioll anid tcstiIgl requirement. This changes the CTS by not explicitly stating that tile Requirements.

activities shall be in addition to olher specified Surveillance activitlu.,ti. c stilllcreuired by 10 This change is accepabhle because thC inscrvice inspection and testing lesting Programii. A spe'clie cnce to lthis

fc, CFR 50.55a, as appropriate, and ITS 5.5.7, the Inservice because iLtd .t110 inill teelliiii cal fact is unnecessary. This change is designated administrative ies:

changes to the CTS.

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Table A - Administrative Changes ITS Section 5.0 - Administrative Controls

- I r"ie 1) l)escription of Change ITSl.2.l2.tl'C 11Cll( t £}bl tk 'Cltt llL DOC No. 0.2.2.1) fuel is in None Operator shall be in the coMtrol !'(mm when 5.0 A.34 CTS 6.2.2.b states, "At least one licensed Reactor or 4, at least w one iccise'.l Senior Reactor tile reactor. In addition, while the Unit is in MODES I, 2, 3 Control Room." The ITS does not include this phrase. This clhliilges the CTS by Operator shall be in the 50.54.

deleting two requhienents, both of which are addressed by 10 CFR in all operat ion 11anlode other than cold 10 CiR 50.54 (m)(2)(iii) states, "When a niIuclear power unit is spec il'ications, each lhcensee shall have a person shutdown or relueling, as defined by a unit's technical power unit in the control iooill at all tilies." 10 CFR holding a scnior operator license Ior tie nuclear licensed pursuati to part 55 of this chapter shall be 50.54(k) states, "An operator or senior operator (ofthe facility." '[his change is acceptable because present at the controls at all timnes during operiation tie requirements deleted from the Technical Specifications are already required by 10 CFR 50.54. This result in technical clian,*s to the CITS.

chang e is desiinated administrative because it does not 9 - i mX~~(V chemistry nioniloling tori l l shiall iniiShludC, "Prlocedures 5.5.9.c 6.9.4.c(v) 5.0 A.35 CTS 6.8.4.c(v) states that thie secondary water ITS 5 5.9.e states that tile defining corrective actions for all control point cheemistiy conditions."

iacIlude, "Priocedu re, ('lic inia c rricclive actions [or secondary water c heo iistIfy 111(l1niiotlrin0 g prograill shall t Ihe terli1 WoId ofl' I all off control point chlie ustry conditions."' Tbhis chaliges tile C'T'S by addi*i, tile control point.

is to provide procedures For what to (do This change is acceptable because the intenrt (ofCTS (.8.4(v) which1 is liore accutatcly stated using whenit ie control point chemistry conditions are not within limiits, urequieiIclelll. 'lh1s ,CI 1.geis odCsignallted tile teriil "off control point." This change clarifies til existingig changes to the CTS.

administrative because it does not result in technical Rate Testing 5.5.1 5.c 3.0.3 are applicable to the Conlainment Ieakage 5.0 A.36 ITS 5.5.15.e stales, "The pfovisions of SR 'Ihis changes tile ClTS Iv 4a hthlalt SR, 3.10.3 Program." The CTS do not contain such a statenItelit.

in CTS 4.0.2, which is tile salni tsTS is SR 3.0.3, allready applies because in the CTS the allowance applies.

in CTS 4.0.2, whichi must he explicitly stated This change is acceptable because it retains the allowance change is dlesignoc'  ; Vc because it 1e1 iaidf-¢iiali for it to apply to a requirement in ITS Section 5.0. This does not result in technical changes to tile CTS.

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Table A - Administrative Changes ITS Section 5.0 - Adminuist"ative Controls Description of Change FFS ,C. I . 9. 1 *3,F.7 DOC No.

and docume nte in the Core 5.6.5. a 6.9.1.7. a 5.0 A.37 CTS 6.9.1.7.a contains a list of. the core operating limits established includes additional core opcrating limits establishcd and Operating Limits Report (COLR). ITS 5.6.5.a Limits, Shutdown Margin, Reactor 'rip Systlem documented in the COLR. These are: Safety Instrumentationi- OTAT and OPAT Trip Paranictcrs, RCS Prcssure, 'l'enpefrarurc, and Flow D)NB Limits, had prcviously been addressed in olher parts ol the CTS, but arc and Boron Concentration. These limits of this arc listed in ITS 5.6.5.a. lhT change also deletes being moved to the COLR, and because limits listed with other sections in the CTS. This changes CTS references associating the coNe operating the COt.R because they are being moved by adding core operating limits established and documented in the changes arc addressed by there as part of changes to othcr parts of the CTS. Technical aspects of Discussions of Change for the respective individual specifications.

changes In.adlc to other parts of' the CTS This change is acceptable because it administratively docurnilts it does I,) result in technical changes and the COLR. This change is designated administrative because to tie CTS. N in and documented in the Core None 5.0 A.38 CTS 6.9.1.7.a contains a list of the core operating limits established 5.6.5.a includes additional core opce:rting iinits established and Operating Limits Report (COl.R). ITS Mar gin, Re t or ti p Systcm documented in the COLR. iThese are: Safety Imits, Shutdown Instrulientation - OTAT and OPAT Trip Paranmters, RCS Pressure. l'ciipl)C'alul e, ridd Flow DNB13Limits, in other par111 of the (CTS,but are and Boron Concentration. These limits had p)reviOusly been adldrcssed T'lIe(hagc :lso deletes being moved to the COLR, and because of this arc listed in ITS 5.6.5.a.

il hUCAVl'S. Th,is changes ClCTS references associating tile core operating limits listed with other sections R hccMIoc IhCe arc being l1roved by adding core operating limits established and documented in tile COI of llangcs, arc addi-cssed hy tire there as part of changes to other parts of the CTS. Technical aspects Discussions of Change for the respective individual specifIications.

Thliis chbangITe is acceptable because it administratively doctumcnts changes tndc to odlcr parts of the CTS u l !i1 technical chalnges "and the COLR. This change is designii ated ad utinii strativye hecause it does in , ns to( ihe CTS.

1)age 13 of 1-' A -- 5.0 North Anna Power Station

Table A - Administrative Changes ITS Section 5.0 - Administrative Controls DOC No. Description ol' Change ITS Requirement CTS Requirement "ASME Code for Operation and Maintenance of' Nuclear Powcr" Plants' Code." ITS 5.5.7 refers to the 5.5.7 4.0.5.b 5.0 A.39 CTS 4.0.5.b refers to Section XI and ASME, Boiler and Pressure Vessel and dloes XI. This changes the CTS by revising the title of the applicable not reference Section Program to match the ASME Codc" lor the fnscrvice Testing currently approved version.

Maintenance of Nuclear This change is acceptablePower Plants, NorththeAnna 1995 has 50.55a(b)(3). This version because of the Code does not Edition and the adopted the ASMI- Code fo~r as 1996 Addenda, Oper'ation required and "called the "ASME Code for use Section Xl for the by 10 CtR Operation and Maintenance Inservice Testing Program Boiler and Pressure Vessel of Nuclear Power Ptants' and is Code." This change is instead of the "ASME, designated administrative because it does not result in technical changes to the CTS.

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