Text

Attachment 3 - Table M - More Restrictive Changes North Anna, Units 1 and 2, Amendments 231 and 212
	ML021220061
Person / Time
Site:	North Anna
Issue date:	04/05/2002
From:	; Office of Nuclear Reactor Regulation
To:	;
References
	TAC MB0799, TAC MB0800
	Download: ML021220061 (55)
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ATTACHMENT 3 Table M - More Restrictive Changes

"Table M - More Restrictive Changes ITS Section 1.0 - Use and Application ITS Rcquirement CTS Requirement cription of Changes N/A N/A I D...... ,*'1 M -1.0 North Anna Power Station rage i oi i

Table M - More Restrictive Changes ITS Section 2.0 - Safety Limits North Anna Power Station Page IOf I M -2.0

Table M - More Restrictive Changes ITS Section 3.0 - LCO and SR Applicability Fi("

DOC No.

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Description of Changes II 1i1i Q

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N/A cuiuu mi.-

1 1ý N/A

-I.N/A N/A 3.0 M.1 Not used. SR 3.0.2 SR, 3.0.2 4.(0.2 the specified surveillanhc 3.0 M.2 CTS 4.0.2 states, "Each Surveilhnce cRequirement shall be performed within not to exceed 25 percent of the surveillance interval."

interval with a maximum allowable extension Frequency for each SR is met if the Surveillance is performed ITS SR 3.0.2 states, "The specified the previous pe,'formance or within 1.25 times the interval specified in the Frequency, as measured Iromi spccificd as is met. For Frcquencies as measured from the time a specified condition of the Frequency

,once,' the above interval extension does not apply. If a Completion Time requires periodic applies to each performance after performance on a 'once pert...' basis, the above Frequency extension in the individual Specifications."

the initial performance. Exceptions to this Specification are stated as 'once,' the above interval extension This changes the CTS by adding, "For Frequencies specified are discussed in DOC A. 10 and DOC L.5.

does not apply." The remaining changes to CTS 4.0.2

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Table M - More Restrictive Changes ITS Section 3.1 - Reactivity Control Systems T I 'J I? (l'q R nurtn r Description of Changes ITS Romilrelliclit I U I ý) KCCIIIII"ClIlClIt I DOC No. SR 3.1.1.1 4. 1.1..Lie, 3.1.1 M.I to be within its limit every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 4.1.1.2.1 CTS 4. 1.1. 1. Le and CTS 4.1.1 .2.b requires SDM to be determined to be within its limit in when in MODES 3, 4, and 5. ITS SR 3. 1.1. I requires SDM to be dctermined

5. This changes the CI'S by expanding the MODE 2 with Kj1 < 1.0, and MODES 3, 4, and MODE 2 with Kcir < 1.0.

applicability of the Surveillance to include PSR 3.1.2.1 None to be within 1% Ak/k of the 3.1.2 M.I ITS SR 3.1.2.1 requires the corereactivity balance to be determined The CTS does not contain a predicted value once prior to entering MODE 1 after each refueling.

performannc requirement for the similar requirement. This changes the CTS by adding an additional core reactivity balance SR.

N/A 3.1.3None N/A N/A 3.1.4, Action C 3.1.3.1, Action c OPERATION may continue 3.1.4 M.A CTS 3.1.3. 1, Action c, states that with one rod misaligned, POWER are not complete, CTS provided that certain actions are completed within one hour. If those actions into MOI)E 3 within 7 hours, for a total time From 3.0.3 would be entered which requires entry of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS 3.1.4, Action C. stales that if the ,Required condition discovery to entry into MODE 3 of Condition 13, one rod not within alignment limits, are not Actions and associated Completion Times Time in ITS Condition 13 is one met, the unit must be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The shortest Completion to entry into MODE 3 is 7 hour8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . Therefore, under the ITS, the time from discovery of the condition MODE 3 lollowing discovery of hours. This changes the CTS by providing one less hour for entry into it misaligned rod.

k,:f*. > 1.0. ITS 3.1.5 is apHplicable in MODES 3.1.5 Applicability 3.1.3.5 CTS 3.1.3.5 is applicable in MODE I and MODE 2 with Applicability from MOI)E 2 with the reactor critical to 3.1.5 M.I I and 2. This changes tile CTS by expanding tile applicability applicability of'thilreqIretell)ts.

all of MODE 2. This has the effect of expanding the in physical insertion as specified illtile CORE LCO 3.1.6, CTS LCO 3.1.3.6 requircs tile control banks to be limited Condition A, SR 3.1.3.6 3.1.6 M.I the control banks to he within the insertion, 3.1.6.3 OPERATING LIMITS REPORT. ITS LCO 3.1.6 requires for not meeting A provides Actions sequence, and overlap limits specified in the COLR. ITS Condition verification of the overlap and the overlap and sequence requirements, and ITS SR 3.1.6.3 requires on the overlap and sequence to sequence every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by adding requirements the Technical Specifications. 3.1.6, Condition 13 3.1.3.6, Action a the insertion limits to be restored within 2 3.1.6 M.2 CTS 3.1.3.6, Action a, requires control banks inserted beyond the same Condition B, contains hours or the plant to be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.1.6, the SDM is within the limits specified in the COLR or requirements and adds the requirement to verify changes the CTS by adding the initiate boration to restore SDM to within the limit within I hou,1r. This Sl)M within one hout, when control banks requirement to verify SDM or boration to restore the required are below the insertion limits. I ___________________________

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Table M - More Restrictive Changes ITS Section 3.1 - Reactivity Control Systems ii I T'T'*-

cqutremeni II I c,'r'C' n ---

"- C) 1s.cquireittettt r"'PQ D -- . ;............ f Description of Changes IT1 IeqUilenient I C. TS Rc.,. eq nle lentI DOC No. 3.1.7, Action Ii 3.1.3.2 3.1.7, Action E 3.1.3,2 3.1.7 M. CTS 3.1.3.2 does not contain an Action to follow if the provided Actions cannot be met. Thercfore, and he in MODE 3 within 7 CTS 3.0.3 would be entered which would allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to plan a shutdown MODE 3 if the Required hours, ITS 3.1.7 contains Action E which states that the plant must be in by elinminating the one Actions and associated Completion Times are not mct. This changes the CTS unit to be in MODE 3.

hour to plan a shutdown and, consequently, allowing one hour less for the 3.1.8 ACTIONS 3.1. 1.3.2 3.1.8 M.I valves are not locked, 3.1.8 ACTIONS 3.1.1.3.2 Unit I CTS 3. I. 1.3.2 states that when the primary grade water flow path isolation position in MODES 3 and 4, the plant must be in COLD scaled, or otherwise secured in the closed If in MOD)E 5 or 6, all operations involving positive reactivity changes SHUTDOWN within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

sealed, or secured in the or CORE ALTERATIONS must be suspended, and the valves must be locked, thie primary grade water flow closed position within 15 minutes. Unit 2 CTS 3.1 .1.3.2 states that when operations "path isolation valves are not locked, scaled, or otherwise secured in the closed position, allisolation be suspended, the involving positive reactivity changes or CORE ALTERA'I'IONS must within 15 miinutcs, and valves must be locked, sealed, or otherwise secured in the closed position 1.77% Ak/k within 60( minuttes. ITS SHUTDOWN MARGIN must be verified greater than or equal to flow paths are not isolated, positive reactivity

3. 1.8 Actions state than when the primary grade water grade water flow paths must be isolated within additions must be suspended immediately, the primary within 4 hours. The Condition is modified by a Note 15 minutes and SR 3.1.1.1 must be performed be done whenever Condition A is entered. This changes the requiring that the SR 3. 1. 1.1 performance to verify the SHUTDOWN MARGIN within 4 hours and by Unit 1 CTS by adding a requirement is entered. The other requiring the SHUTDOWN MARGIN be performed whenever the Condition LA. I.

changes to CTS 3.1.1 .3.2 are discussed in DOCs A.3, L. I, and 1 3.lt).l I None in CTS 3.11. I.1 for the None 3.10.1 3.1.9 M.I CTS 3. 10.1 provides an exception to the SHUTDOWN MARGIN requirements in the N-I con'iguration (all rods inserted inlo tile core purpose of performing rod worth measurement the test exception. This changes the CTS by eliminating a test except I). The ITS does not contain exception.

None 3.10.2 and power distribution linits INone 3.10.2 3.1.9 M.2 CTS 3.10.2 provides an exception to the rod group height, rod insertion, pseudo drop and for the purpose of performing the control rod pseudo ejection test, control rod test, and xenon stability measurements. The ITS does not contain the test exception. This misalignment test exception.

changes the CTS by eliminating a -i i 3.1.3.1, 3.1.3.5, and 3.1.3.6 during the performance LCO ACTIONS, 3.1.9, 3.1.9 SR 3.10.3 3.1.9 M.3 CTS 3.10.3 provides an exception to CTS 3.1.1.4, that must be followed when uiliizing thie exception. ITS 3.1.9.4 of PHYSICS TESTS and provides restrictions that tMust he followed 3.1.9 provides an exception to tie equivalent ITS LCOs and to the restrictions must be within the limits providedl in the COLR. A adds a requirement that SHUTDOWN MARGIN MARGIN every 24 hours and ACTIONS to Follow if the I Surveillance to verily the SHUTDOWN Page 2 of 3 M-3.1 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.1 - Reactivity Control Systems I - -- I ----

T Re ie et I- Requirement-------

DOC No. Description of Changes ITS Requ~irementll ICTS R eq ulire et-Cl~

i SHUTDOWN MARGIN limit is not met are also added to the CTS. This changes the CTS by imposing an additional requirement on the application of the test exception LCO.

I, i LCO 3.1.9, 3.1.9 i 3.10.3 an exception to CTS 3.1.1.4, 3.1.3.1, 3.1.3.5, and 3.1.3.6"during the LCO 3.1.9, 3.1.9 3.10.3 3.1.9 M.4 Unit I CTS 3.10.3 provides ACTIONS, SR performance of PHYSICS TESTS and provides restrictions that must be followed when utilizing the 3.1.9.2 exception. ITS 3.1.9 provides an exception to the equivalent ITS LCOs and to the restrictions that must be followed adds a requirement that RCS lowest loop average temperature be > 531 'F. A Surveillance to verify the RCS lowest loop average temperature is > 531 'F and ACTIONS to follow if the RCS lowest loop average temperature is not within limit are also added to the CTS. This changes tile CTS by imposing an additional requirement on the application of the test exception I-CO. The LCO requirement, Action, and Surveillance being added to the Unit I CTS exists in the Unit 2 CTS. -i i 3.1.9.3 3.1.9 M.5 CTS 4.10.3.1 requires THERMAL POWER to be verified to he < 5% once per hour. ITS SR 3.1.9.3 SSR R 3.1.9.3 4.10.3.1 requires the verification be performed every 30 minutes. This changes thLt' :TS by increasing the Frequency of the THERMAL POWER verification.

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Table M - More Restrictive Changes ITS Section 3.2 - Power Distribution Limits

. . '. I T. I

("IN Po UiI~~lit'I..io IDescription of Chaniges I ITS ReNquliremenIt U I *.3 lrC(Ull'..lllk-III DOC No. ....... 2...Action.B or Completion Times are not 3.2. 1, Action B 3.2.2 3.2.1 M.I CTS 3.2.2 does not contain an Action to follow if the provided Actions plant to be in MODE 2 followed. Therefore, CTS 3.0.3 would be entered which would require the and associated Completion within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.2. 1, Action B, states that when the Required Action must be in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by providing 6 Time is not met, the plant hours vice 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to be in MODE 2. i t FQN1 (Z) outside its limit provided 3.2. 1, Action A. I 3.2.2, Action f.2.a 3.2.1 M.2 CTS 3.2.2, Action f.2.a, states that power operation may continue with limit. ITS 3.2.1, Action A.lI the AFD limits are reduced 1% for each percent FQ(Z) exceedcd its its limit within 15 minutes.

requires the AFD limits to be reduced > I% for each 1% FQM(Z) exceeds does not have a Completion This changes the CTS by providing a Completion Time for ain action which Time in the CTS. SR32i14....

condilions aftercexceceding S R 3.2. 1.1 4.2.2.2.d 3.2.1 M.3 CTS 4.2.2.2.d requires FQM(Z) to be measuredl upon achieving cquilibriuim which FQ(Z) was last detcrmincd by 10% or more o R*AI'ED THERMAL the THERMAL POWER at reqniremcnts, but also POWER or at lease once per 31 EFPD. ITS SR 3.2. 1.1 contains the same prior to THERMAL requires FQ (Z) to be verified to be within its limit once after each refueling 51 Frequency.

POWER exceeding 75% RTP. This changes the CTS by adding a new Surveillance 3) 'iCniinA 3..,Ato POWEPR OPERATION may 3.2.2, Condition A 3.2.3, Action c 3.2.2 M.lI CTS 3.2.3, Action c, states that with FNAll exceeding its limit, subsequent Note mapping to be within its limit at a nominal proceed provided that FNall is demonstrated through incore this THERMAL POWER, at a nominal 75%

50% of RATED THERMAL POWER prior to exceeding this THERMAL POWEIR, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of RATED THERMAL POWER prior to exceeding THERMAL POWER. However, under CTS 3.0.2, these after attaining 95% or greater RATED be completed if compliance with the LCO is reestablished. ITS 3.2.2 measurements do not have to must be completed whenever Condition A contains a Note which states, "Required Actions A.3 and A.4 Condition A is entered." ITS Required Actions A.3 and A.4 require performance of a FNAll RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after measurement every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and prior to exceeding 50% RTP, 75% the ENAlI mea,'surements to he changes the CTS by requiring THERMAL POWER >95% RTP. This made even if FNAll is restored to within its limit. -- -- -- - - - - -I I I -N/A

.. ý N/A 3.2.3 None 3.2.4, Action 3.'2.4, Co~ndition A THERMAL POWER to be a. L.h) (Unit I) 3.2.4 M.I CTS 3.2.4, Action a. I.b) (Unit 1) and Action a.2(b) (Unit 2) requires 1.0 and allows a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation and Action a.2(b) reduced at least 3% for every I1%QPTR exceeds the limit. ITS 3.2.4, Condition A, also requires THERMAL (Unit 2) above 50% RTP with QPTR greater than 1% QPTR exceeds 1.0, but the ITS allows indefinite power POWER to be reduced at least 3% for every is dtcrmined within 12 hours, FQ(Z) and E-NAIl are operation above 50% RTP provided that QPTR of achieving equilibrium conditions.after the power reduction verified to be within limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Page I of12 M - 3.2 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.2 - Power Distribution Limits ITS Requirement CTS Requirement DOC No. Description of Changes results are still valid and every 7 days thereafter, and the safety analyses are reevaluated to confirm the to increasing power. If the reevaluation of the for the duration of operation under this condition prior ITS allows the excore detectors to be safety analyses confirms that the results remain valid, the FQ(Z) and FNAll are verified to be within limits normalized to restore QPTR within limit provided that condition at RTP. This changes the CTS by requiring within 24 to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after achieving equilibrium be normalized FQ(Z) and FNAll be verified, the safety analyses be reevaluated, and the excore doeectors the requirement to reduce power to less to restore QPTR to within the limits. The change eliminating than 50% RTP is discussed in DOC L.4.

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Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation Description of Change ITS Requirement CTS Requirement DOC No.

SR 3.3.1.6 Note Unit I None 3.3.1 M. I Unit I CTS Table 4.3-1 Function 16 RCP Undervoltage does not contain a Surveillance Requirement for a CHANNEL FUNCTIONAL TEST to be performed. Unit 2 CTS Table 4.3-I Function 16 requires a CHANNEL FUNCTIONAL TEST to be performed at a Q (Quarterly) Frequency. ITS Table 3.3. 1-I Function 12 RCP undervoltage requires ITS SR 3.3.1.0 to be performed for both units undervoltage functions. A Note that states, "Verification of setpoint is not required," modilies the SR. This changes the Unit I CTS Surveillance Requirements for RCP undervoltage by specifying a TADOT be performed every 92 days and adds a Note to the SR.

3.3. I ACTIONS 3.3. 1.1 Action 2 3.3.1 M.2 CTS 3.3.1. I Action 2 requires an inoperable Power Range channel to he placed in trip within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , for either the neutron flux levels or positive and negative rate trips functions being inoperable. D and E If this cannot be accomplished, the unit is required to enter LCO 3.0.3 and one hour is allowed to initiate action and 6 additional hours for the unit to be placed in HOT STANDBY. CTS LCO 3.0.3 provides the requirements when a LCO is not met and within one hour Action shall be initiated to place the unit in a MODE in which the Specification does not apply. ITS LCO 3.0.3 is required to be entered if more than one Power Range channel becomes inoperable for either of the required functions of flux level or rate trips. ITS 3.3. I Required Actions D for an inoperable Power Range Neutron Flux channel requires the inoperable channel to be placed into trip within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with additional compensatory measures, or place the unit in MODE 3 within tihc next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.3. I Required Action E for an inoperable Power Range channel for positive or negative rate trips, requires the inoperable channel to be placed into trip within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or ri.c unit is required to be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS requirements by decreasing the time allowed to be in MODE 3 from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in the CTS to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the ITS.

ITS Required 3.3. 1.1 Action 3.b 3.3.1 M.3 CTS 3.3. 1.1 Action 3.b requires for an inoperable Intermediate Range Jhannel, when power is below P- I0 and above the Intermediate Range interlock P-6, that the channel be restored to OPERABLE Actions F'. I and status prior to increasing power above the P-10 limit. ITS Required Actions F. 1i a*nd.2 only allow F.2 operation between P-6 and P-10 power levels for a maximum time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . After thai, power level is required to either be increased above P- 10 or decreased below P-6. The allowance for increasing power above P- 10 is addressed by DOC L.4.. Limiting the time with an inoperable Intermediate Range channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months changes the CTS requirements, which -,urrently allows operation for an indefinite period of time.

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Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Descriptlion of Cha-,nge fqq I IL 3 21 1\Q 6I1ii.jiSIlll I;.Reqiremenll~lt I I TS co ir len

ý t- i,ý. i-,eqmrenmý I 3.3. I ACi'ION I-I 'Fable 3.3-I Action I 4(to be entered if 3.3.1 ACTION H 4ablc 3.3-1 Action 3.3.1 M.4 CTS 3.3.1.1 Functional Unit 6 for the Source Range Neutron Flux requires Action Note 41 number when THERMAL the number of channels OPERABLE is one less than the minimum POWER is below P-6 in MODE 2 operation. This Action limits the THERMAL POWER to the P-6 ITS Function 5 Source setpoint value until the inoperable channel is restored to OPERABLE status.

for an inoperable channel. Required Action Range Neutron Flux requires Condition H to be entered involving reactivity changes must be immediately H states with one inoperable channel all operation by a Note that states, "Limited plant cooldown or boron suspended. The requirement is modified is accounted for in the calculated SDM." This changes the dilution is allowed provided the change Source Range channel by limiting-operationt involving positive CTS requirements for an inoperable reactivity changes. 4 3.3.1 Action I -I.Tablc 3.3-I Unit 6, in TFable 3.3- 1 3.3.1 Action I Table 3.3-1 3.3.1 M.5 CTS requirements for the Source Range instrumentation channels, Functional 5* that Actions 15 and 4, .respectively, arerequired to state for MODE 2## and MODES 3*, 4*, and CTS requirements (10 not "iddress the possibility of two be entered for one channel inoperable. The channels did become inoperable in either applicable channels inoperable. If two Source Range before commencing a condition, LCO 3.0.3 must be entered. This would allow at least one hour Source Range Neutron Flux, provides an additional Action 1.

MODE change. ITS 3.3.1 Function 5, become inoperable, the RFBs will be opened This requires that if two Source Range channels requiring the RTBs to be opened immediately if both Source immediately. This changes the CTS by during start up or with the Rod Control System cappble of Range channels become inoperable withdrawing the shutdown and control rod banks. 4 +

Table Table 3.3-1IAction 373.31 M.6 CTS Table 3.3-I Function 6 Source Range Neutron Flux requires two channels to be OPERABLE in NOTE'3.3. (e),1 -1I 5 Control System capable of rod ACTION K Note MODES 3, 4, and 5 and, with the R'TBs closed and the Rod CTS Action 5 must be entered.

withdrawal. If the required Source Range channel is inoperable, than tie number required, SDM Action 5 states, with the number of channels OPERABLE one less 12 hours thercaftcr. ITS 3.3.1 Function 5 Source shall be verified within I hour and at least once per Pc), "), and "i) ar'd Condition K applies when Range states that I channel is required for MODES 3 4 5

(') states, "With the Rod Control System incapable of rod the channel is inoperable. The notation range Function does not provide reactor trip but does provide withdrawal. In this condition, source with the required Source Range Neutron Flux channel indication." Condition K requires that, reactivity must be immcdiately suspended and SR inoperable, all operations involving positive be performed within an hour and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. A Note

3. 1. 1.1 (SDM calculation) must dilution is-allowcd provided modifies Condition K and it states, "Limitcd plant cooldown or boron for in the calculated SDM." This changes the CFTS by'placing an additional the change is accounted restriction on operations when the Source Range channel is inoperable. I I 1

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Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Rcquirement CI'S Requirement 3.3.1 M.7 CTS Table 4.3-I lists the surveillance requirements of CHANNEL CALIBRATION for the Turbine Table 3.3.1 I-1, Table 4.3-1 Trip Function 18.A Auto Stop Oil Pressure and Function 18.B3Turbine Stop Valves Closure as Not SR 3.3. I.1 (0 Applicable (N/A). ITS Table 3.3. I-1 Function 16 Turbine lists the CHANNEL CALIBRATION surveillance requirement for the Auto Stop Oil Pressure and Turbine Stop Valve Closure as SR 3.3. 1. 10. This must be performed at a Frequency of 18 months. This SR is modified by a Note that requires the verification that time constants are adjusted to prescribed values. This changes the CTS by adding a CHANNEL CALIBRATION requirement for the Turbine Trip functions.

3.3.1 M.8 CTS Table 4.3-I contains a Surveillance Requirement for the Intermediate Range channels. A SR 3.3.1. II Table 4.3-1 Note CHANNEL CALIBRATION is required and modified by a footnote. Note i3 states, "The provisions 13 of Specification 4.0.4 are not applicable for entry in MODE 2 or I." ITS SR 3.3. 1.11 for the Intermediate Ranges requires a CHANNEL CALIBRATION every 18 months. This changes the CTS by deleting a portion of the Note reinstating the Speciflication 4.0.4 allowance.

3.3. I M.9 Unit I CTS Table 4.3-1 Function 20, RCP Breaker Position Trip, lists N/A under the column labeled Table 3.3.1 - I 'Table 4.3- I "MODES IN WHICH SURVEILLANCE REQUIREI)." Function 20 ejuires a CHANNEL NOTE ([) and (g)

FUNCTIONAL TEST to be performed on an R (Refueling) frequency. Unit 2 CTS Table 4.3-I Function 18, Turbine Trip on Low Auto Stop Oil Pressure and Turbinc Stop Valve Closure, lists N/A under the "MODES IN WHICH SURVEILLANCE REQUIRED," column. Function 18 requires a CHANNEL FUNCTIONAL TEST to be performed for each portion of ihe function at a frequency of S/U (1). S/U requires the surveillance to be performed prior to each reactor start up. Note (1 states, "If not performed within the previous 31 days." The applicable MODES or other specified conditions for ITS Table 3.3.1-1 Function I1, RCP Breaker Position Trip is MODE I"), with SR 3.3. I. 14 as a required Surveillance. Note M states, "Above the P-7 (Low Power Reactor Trips Block) interlock."

The applicable MODES or other specified conditions for ITS Table 3.3. I-1I Function 16, Turbine 4

Trip on Low Auto Stop Oil Pressure or Turbine Stop Valve Closure, is MODE 19 I with SR 3.3.1.15 as one of the required Surveillances. Note (9) states, "Above the P-8 (Power Range Neutron Flux) interlock." This changes the CTS by requiring the surveillance for thi eRCP Breaker Position Trip and the Turbine Trip Functions to be performed in the ITS when they arc"not required in the CTS.

CTS Table 4.3-I Function 23.b Low Power Reactor Trip Block, P-7, states that a CHANNEL Table 3.3.1-1, Table 4.3-1 3.3.1 M.10 SR 3.3.1.5 CALIBRATION and a CHANNEL FUNCTIONAL TEST are to be perforrmed at a frcquency of R (refueling). ITS Table 3.3. 1-1Function 18.b Low Reactor Powcr Trips Block, P-7, states that SR 3.3.1.5 ACTUATION LOGIC TEST (ALT) is to be perlormed at a Frequency of every 31 days on a STAGGERED TEST BASIS (STB). This changes the CTS by requiring an AIT to be perlormed every 31days on a STB instead of*a CHANNEL CALIBRATION and a CHANNELI FUNCTIONAL TEST being conducted every refueling.

North Ainna Power Station Page 3 of i 3 M - 3.3

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation ITS Rcquircnicnt CT'S Requirement Description of Change II ITS RequLirementII I DOC No. Table 3.3.3-I Table C STF R3.3-1 eq t,ir e m e n0t' be followed for an inoperable Actions I and 14 3.3.1 M. I I CTS Table 3.3-1 Function 21 A, RTBs, lists Actions I and 14 to NOTE (a) the divcrse trip featul:es (undervoltage or channel in MODES I and 2. Action 14 states, "With one of within 48 hours or declare the RTB shunt trip device) inoperable, restore it to OPERABLE status states, "The breaker shall not be bypassed inoperable and apply Action I." Additionally, the Action except for the time required for performing while one of the diverse trip features is inoperable status." ITS 3.3.1 Function 20, RTB maintenance to restore the breaker to OPERABLE requires these mechanisms to be OPERABLE for each Undervoltage and Shunt Trip Mechanism, (a) states, "With the Rod Control RTB in MODES I and 2, and MODES 3(a), 4(a), and 5(a). Note fully inserted." If either function becomes System capable of rod withdrawal or one or more rods not 3(a), 4(a), and 5(a)) must be inoperable Conditions S (MODES I and 2) or Condition C (MODES trip mechanism be restored to entered. Required Actions for Condition C direct that the inoperable place the Rod Control System in a OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 01oinsert all rods and within one hour. This changes the CTS condition where rods cannot be withdrawn. This is required in MODES 3(a), 4(a), and 5(a), and adding by requiring the diverse trip functions to be OPERABLE ITS Condition C requirements.

3.3.1 ACTION P I to be entered for an inoperable

'Table 14 3.3-1 Action M.12 CTS Table 3.3-I Function 21 A Reactor Trip Breakers lists Action NOTE 2 3.3.1 RTBs for the diverse trip function channel in MODES I and 2. CTS Action 14 is applicable for the or shunt trip device) inoperable, and it states, "With one of the diverse trip features (undervoltage breaker inoperable and apply Action restore it to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or declare the trip features is inoperable except for L The breaker shall not be bypassed while one of the diverse to OPERABLE status." ITS the time required for performing maintenance to restore the breaker OPERABLE in MODES I and 2 and Table 3.3.1-1 Function 19 RTB requires 2 trains to be Condition P states that with one train Condition P to be entered if one RTB train is inoperable.

one hour or be in MODF 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months .

inoperable, it must be restored to OPERABLE status in RTB may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Three Notes modify the Condition. Note 2 states, "One provided the other train is OPERAB.LE."

maintenance on undervoltage or shunt trip mechanisms, RTBs by limiting to 2 hours any mainienance on the This changes the CTS requirements for the the RTB train inoperable.

ýl - undervoltage or shunt trip mechanism before declaring j __________________________

Page 4 of I I M - 3.3 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation Des.rip-ion of ChanI IT1 , ~lirem ent S Req uirement DOC No. Description of Change o.n1T I Table 3.3.1 I,

- - - . I. ....

test on the OTAT Functions Table 3.3.1- N1, None 3.3.1 M.13 CTS Table 4.3-I Surveillance Requirements do not require a quarterly SR 3.3.1.9 NOTE Power Range channels. ITS 'Fable 3.3.1 I to ensure an accurate input tor the f(Al) from the required I SR 3.3.1.9 states, "Compare results of the Function 6 states SR 3.3.1.9 must be performed. ITS This SR must be performed every 92 effective excore channels to the incore detector measurements."

the requirement. Note I states, " Adjust NIS channel if full power days (EFPD). Two Notes modify until 72hours after absolute difference is >3%." Note 2 states, "Not required to be performcd by requiring an additional Surveillance THERMAL POWER is >50%." This changes the CTS Requirement for the OTAT Function. t SR 3.3.2.1 1 4.3 .2.1.2 of the ESFAS interlocks to determine SR 3.3.2.1 4.3.2.1.2 3.3.2 M.] CTS Surveillance requirement 4.3.2. 1.1 rcquircs the testing and P-12 arc required to he OPERABLE. No specific OPERABILITY. The two interlocks P-II a CHANNEL CHECK lor the interlocks. ITS SR 3.3.2.1 requirement is stated or implied to perform for the P-1 I and P-12 interlocks. T'his change modifies the is added to the surveillance requirements CHECK to be perlormed every CTS requirements for these interlocks and requires a CHANNEL.

twelve hours.

-t SR 3.3.2.8 NOTE I Table 4.3-2 3.3.2 requiremcnts for a SR 3.3.2.9 NOTH Table 4.3-2 M.2 CTS Surveillance listed in Table 4.3-2 provide CHANNEL CALIBRATION ITS Surveillance Requirement variety of functions to be performed at a R (refueling) frequency.

every I1 months. A Note modifies the 3.3.2.8 specifies a CHANNEL CALIBRATION be performed that the time constants' are adMiusted to the SR that states "This Surveillance shall include verification the requirement to perlorm a verification of prescribed values." This changes the CTS by adding CHANNEL CAIIBRA NON of the various time constants adjusted to prescribed values with a safety functions. I I I

Page 5 of'! M - 3.3 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation lt2; Kequn enient L I tcquirement Description of Change ITS Rl¢.ufemlen I nt 1CTSRequirement DOC No. i i I Table 3.3.2- I None swap over of Low 3.3.2 M.3 CTS for ESF instrumentation do not require the ESFAS function for the automatic Function 7, pumps suction to tile containment sump from thie Refueling Water Action C, Head Safety Injection (LHSI)

Tank (RWST) on a Low-Low level. ITS ESFAS Instrumentation Function 7 is labeled as Action I Storage trains of automatic the "Automatic Switchover to Containment Sump." This requires that two SR 3.3.2. I, I, 2. 3, and 4. This requires actuation logic and actuation relays to be OPERABLE in MODES SR 3.3.2.2, and 3.3.2.5 to be Action C to be entered if a train becomes inoperable, and SRs 3.3.2.2, 3.3.2.3, SR 3.3.2.3, of RWST level to bc performed at specific frequencies. The function requires four channels SR 3.3.2.4, I, 2, 3, and 4. When two of the four channels reach the RWS'I Low-Low SR 3.3.2.5, OPERABLE in MODES a SI signal, the LHSI pump suctions swap from tile RWS°I to the SR 3.3.2.8 level setpoint, coincident with ITS Action I is required to be entered for an inoperable channel, and SRs SR 3.3.2.9 containment sump.

and 3.3.2.9 are required to be perlormed to verify OPERABILITY. ITS 3.3.2.1, 3.3.2.4, 3.3.2.8, or the unit must be Action I requires an inoperable channel to be placed in bypass within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months next 30 hours. A Note that placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the hours for surveillance testing modifies the allows an additional channel to be bypassed for up to 12 Low-Low is >Ž 18.4 % and _<20.4%0voI Required Action. The Allowable Value for the RWST Level from the RWST. This changes the CTS by adding LHSI pump swapover to tile containment sump additional requirements to the CTS. i-

-i require that Action 14 be 3.3.2 ACTION 1)1 Table 3.3-1, Actn 3.3.2 M.4 CTS requirements for LCO 3.3.2.1 in Table 3.3-3 for various Functions bc placed in a blocked entered for an inoperable channel. This requires the inoperable channel to would require the plant condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If this can not be accomplished, CTS LCO 3.0.3 SHUTJDOWN within the to be shutdown to HOT STANDBY within the next 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and HOT require with one channel following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS LCO 3.3.2 Table 3.3.2-1 for these Functions hours by Required Action D).I.

inoperable, the channel is required to be placed in bypass within 72 Action D.2 to be placed in MODE If this can not be accomplished, the plant is required by Requircd six hours. This change decreases tile time 3 within six hours and MODE 4 within the following allowed to reach MODE 3 by one hour.

-i -

Functions rcquire 3.3.2 ACTION F' Table 3.3-3 Action 3.3.2 M.5 CTS requirement for LCO 3.3.2. I in Table 3.3-3 Containment Spray and Isolation 16 11 the inoperable channel to be that Action 16 is to be entered for an inoperable channel. This requires CTS LCO 3.(0.3 placed in a blocked condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If this can not be accomi!1ished, the next 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and HOT would require the plant to be shutdown to HOT STANDBY within 1for these Containment SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS LCO 3.3.2 Table 3.3.2-I be placed in bypass within Functions require with one channel inoperable, the channel is required to the plant is required by Required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by Required Action E.I. If this can not be accomplished, 4 within the following six hours.

Action E.2 to be placed in MODE 3 within six hours and MODE to reach MODE 3 by one hour.

This change the CTS by decreases tile time allowed Page 6 of'1I1 M - 3.3 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation Description of Change ITS Requirement CTS Requirement DOC No.

SR 3.3.2.6 None 3.3.2 M.6 CTS Surveillance Requirements listed in Table 4.3-2 for the Station Blackout start for the Auxiliary Feedwater (AFW) pump (function 6.e) requires a CHANNEL CALIBRATION and ESFAS RESPONSE TIMES test to be conducted on a refueling basis. The CTS does not require a CHANNEL FUNCTIONAL TEST to be performed at any frequency. The ITS 3.3.2 Function for the start of the AFW pump on Loss of Offsite Power (6.d) requires the performance of SRs 3.3.2.8 (CHANNEL CALIBRATION) and 3.3.2.9 (ESFAS RESPONSE TIMES) every 18 months, and 3.3.2.6 (TADOT) every 92 days. The TADOT is modified by a Note that states, "Verification of relay setpoints not required." This changes the CTS by requiring the TADOT to be performed every 92 days.

3.3.2 M.7 CTS requirements in Table 3.3-3 list the Allowable Values for ESFAS Functions and Interlocks. The Table 3.3.2- 1 Table 3.3-3 Allowable Values for the following function are stated as: P-12 Ž_ 541 'F, Safety Injection (SI) on Containment Pressure High _<18.5 psia, SI on Pressurizer Pressure Low-Low > 1755 psig, SI on Steam Flow in Two Steam Lines Coincident with Tare Low-Low or Steam Line Pressure Low _ a AP corresponding to 44% of full steam flow increasing to 111.5% at full load, Containment Spray on Containment Pressure High-High < 29.25 psia, Steam Line Isolation on Containment Pressure Intermediate High-High < 19.3 psia, and Steam Line Isolation on Steam Flow in Two Steam Lines Coincident with Tve Low-Low or Steam Line Pressure Low < a AP corresponding to 44% of full steam flow increasing to 111.5% at full load. ITS requirements in Table 3.3.2-1 lists the Allowable Values for the ESFAS Functions and Interlock as the following: P-12 > 542 'F, SI on Containment Pressure High < 17.7 psia, SI on Pressurizer Pressure Low-Low > 1770 psig, SI on Steam Flow in Two Steam Lines Coincident with Tave Low-Low or Steam Line Pressure Low < a AP corresponding to 42% of full steam flow increasing to 111% at full load, Containment Spray on Containment Pressure High-High

28.45 psia, Steam Line Isolation on Containment Pressure Intermediate High High < 18.5 psia, and Steam Line Isolation on Steam Flow in Two Steam Lines Coincident with "F,..

Low-Low or Steam Line Pressure Low - a AP corresponding to 42% of full steam flow increasing to 111% at full load. This changes the CTS Allowable Values for these functions to more restrictive values in the ITS Allowable Values.

3.3.2 M.8 CTS Table 4.3 - 2 for Functional Unit 8.c, Engineered Safety Feature Actuation System Interlock SR 3.3.2.10 Table 4.3 - 2 Reactor Trip (P - 4), requires the performance of a CHANNEL FUNCTIONAL TEST every refueling (R). ITS Function 8.a, ESFAS Interlock, Reactor Trip (P - 4), requires the performance of SR 3.3.2.10. This SR requires the performance of a TADOT at a frequency of once per reactor trip breaker (RTB) cycle. The SR is modified by a Note that states, "Verification of setpoint not required." The ITS TADOT and CTS CHANNEL FUNCTIONAL TEST requirements are equivalent. This changes the CTS by increasing the testing Frequency from once per refueling cycle to each time the reactor trip breaker is cycled.

North Anna Power Station Page 7 of 11 M - 3.3

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement CTS 3.3.3.6 Action b states that with thie number of OPERABL.E accidint monitoring 3.3.3 ACTION C, 3.3.3.6 Action b 3.3.3 M. I instrumentation channels less than the minimum channels OPERABLE reOuirenlents of Table 3.3-10, 3.3.3 ACTION D either restore the inoperable channel(s) to OPERABLE status within 4k1 hours or be in' at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.3.3 Action C states, "One or more Functions with two required channels inoperable, restore one channel to OPERABLE status, within 7 days." If this is not accomplished, ITS Action D states, "Required Action and associated Completion Time of Condition C not met, be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." This changes the CTS requirement by requiring the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

CTS LCO 3.6.4.1, hydrogen analyzers, is applicable in MODES I and 2. CTS 3.6.4.1 Action b 3.3.3 ACTION 1) 3.6.4.1 Action b 3.3.3 M.2 states if both hydrogen analyzers are inoperable for more than 7 days, the unit must be.placcd in HOT STANDBY within the next six hours. ITS 3.3.3 is applicable in MODES 1; 2, and 3. ITS Action D states if two hydrogen analyzers are inoperable for greater than seven days, the unit to be placed in MODE 3 within six hours and MODE 4 within twelve hours. This changes the CTS requirements for the hydrogen analyzers from MODES I and 2 to MODES 1,2, and 3 and the Required Actions from being in MODE 3 to being in MODE 4.

CTS 3.3.3.6, Table 3.3- 10, Functions 4 and 5, require one channel for the reactor coolant pressure- Table 3.3.3- I, Table 3.3- 10, 3.3.3 M.3 wide range and pressurizer water level functions. ITS 3.3.3, Table 3.3.3-I..EurnjCtions15 and 13 Functions 5 and Functions 4 and 5 require two channels for RCS Pressure (Wide Range) and Pressurizer Level. This changes the CTS 12 requirements for the parameters from one to two required channels.

Page 8 of II M -3.3 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation

. -- 1 .. " If eqtT'eCle Ii DOC No. Description of Change I1ITS Requirement CT R¢equnenment Table 3.3.3-I, None Trable 3.3.3-I,1,2, 8, None 3.3.3 M.4 nuclear instrumentation, CTS 3.3.3.6 does not require Table 3.3-10containment OPERABLE pressure indication channels for the parameters of Functions (narrow range), containment isolation valve position, 10, 14, 16, and containment area radiation levels, wide range steam generator level, the inventory of water to supply 18, Notes (a) and AFW pumps, and high pressure Safety Injection flow. These are added to the CTS and shown in ITS (b) and Source 3.3,3, Table 3.3.3-1, Functions 1, 2, 8, 10, 14, 16, and 18. The Gammanimtric Power I and 2) provide nuclear instrumentation indication, with two channels of range channels (Functions 8). Containment each range. Two channels provide narrow range containment pressure (Function (Function 10) is required for each of two valves per penetration isolation valve position indication is modified by a note that requires only one position indication channel flow path. This requirement flow path with one installed channel located in the Control Room. Steam generator per penetration two requirements level is additionally monitored by wide range indication (Function 14). The last (Function 16) and two are added for two channels of Emergency Condensate Storage Tank level In addition, SRs are added for indications for the High Head Safety Injection flow (Function 18).

Isolation Valve each function. Two Notes modify the requirements for Function 9, Containment penetration is isolated Position. Note (a) states, "Not required for isolation valves whose a'ssociated valve, blind flange, or check by at least one closed and deactivated automatic valve, closed manual "Only on position indication channel is valve with flow through the valve secured." Note (b) states, control room indication channel." This required for penetration flow paths with only one installed changes the CTS by adding new functions, Notes, and SRs. t i-3.3.3 M.5 CTS 3,3.3.6, Table 3.3-10, Function 18 states the total number of channels required for tihe In Core Table 3.3.3- 1, "FabtIe 3.3- 10, F'unction 6.c F;unction 18 Thermocouples (T/Cs) as four per core quadrant. ITS 3.3.3, Table 3.3-.'I;-1, Function 6.: for Core Note c requires a Exit Temperature, states the required number of channels as two per quadrart P'S from one channel to consist of two T/Cs. This changes the CTS to require two T/"Cs he nwered

('TS by rcquiring train and the other two T/Cs be powered from the other train. This chanlges the two trains of T/Cs. 1- 1 ITS LCO None 3.3.3.6, Action c 3.3.3 M.6 CTS 3.3.3.6, Action c states, "The provisions of Specification 3.0.4 are not applicable."

allowance. This changes the CTS by eliminating an explicit 3.3.3 does not contain a similar Specification 3.0.4 exception. -t t 3,3.3.5 Action a CTS 3.3.3.5 Action a requires that if an inoperable channel can not be icturned to OPERABLE 3.3.4 ACTION B 3.3.4 M.1 next 12 hours. ITS 3.3.4 Action B status, the unit must be placed in HOT SHUTDOWN within the be in MODE 3 requires if a required channel can not be returned to OPERABLE status the unit must the next 12 hours. This changes the CTS requirements within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within by specifying that MODE 3 must be achieved within 6 hours.

I I I Page 9 of i I M -3.3 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation Dcscrition o Ch-ng Description of Change IIT R5l~euirenicint CT Rbequ-iremen DOC No. ... . . -

...... ,- LCO 3.3.4,. --

3.3,4 LCO Table 3.3-9 M.2 CTS LCO 3.3.3.5 states, "The auxiliary shutdown panel monitoring ins'rurnentatiofl channels shown Tablc 3.3.4, 133.3.4-l1, I "The Remote Shutdown System in Table 3.3-9 shall be OPERABLE..*" ITS LCO 3.3.4 states, SR 3.3.4.2 control systems are added to Functions shall be OPERABLE." The following functions for various controls, AFW Pump and the ITS requirements: Boric Acid Pump controls, Pressurizer Heaters These control systems are included Valve controls, SG PORV controls, and Charging Pump controls.

verification that each in the Bases Table B3.3.4- 1. ITS SR 3.3.4.2 is also added and requires function once every required control circuit or transfer switch is capable of performing its required k surveillance to verify their 18 months. This changes the CTS by adding the control functions and 18 months.

OPERABILITY every 3..35Acio not applicable." ITS LCO None 3.3.3.5 Action b 3.3.4 M.3 CTS 3.3.3.5, Action b, states, "The provisions of Specification 3.0.4 are This changes the CTS by eliminating an explicit 3.3.4 does not contain a similar allowance.

Specification 3.0.4 exception.

t SR 3.3.5.2, 1 'Fable 3.3-4 Trip Setpoints, lists SR 3.3.5.2, "I'able 3.3-4 3.3.5 M.1 CTS Table 3.3-4, Engineered Safety Feature Actuation System Instrunmentation for Emcrgcncy Bus Undervoltage the Allowable Values for the Loss of Power on the 4160-Volt as, "Ž> 3688 volts with a time degraded voltage. The degraded voltage Allowable Value is stated 3.3 5..'2 and states the delay of < 63 seconds." This requirements is translated into the ITS SR a time d(.lay of.7.5 +/- 1.5 seconds degraded voltage requirement as, "> 3720V and *3772V with: 1.

and 2. A time delay .'50+/-6 + 7 seconds with a Safety Injection (SI) signal for LCO 3.3.5.a Function; Functions." 'Ihis chan'ges the CFTS by without an SI signal for LCO 3.3.5.a and LCO 3.3.5.b the a range of 3720 V to 3772 V and addin(g changing the Allowable Value from 3688 V to be 7.5 +/- 1.5 seconds aod without an S1 signal be 56 requirement that the time delay with an SI signal

+/- 7 seconds.

-i~1 the 1oss of lPower on the Table 3.3-4 3.3.5 M.2 CTS Table 3.3-4 ESFAS Trip Setpoints lists the Allowable Values for SR 3.3.5.2 los:; of voltage .Aflowable Value is 4160-Volt Emergency Bus Undervoltage for loss of voltagc. The is iranslated into ITS stated as, "> 2989 volts with a time delay of<* 3.0 seconds." This rcqtiiwnimen!

3225 V witli a time delay SR 3.3.5.2 and states the loss of voltage requirement as, "Ž 2935 V and

the CTS by changing of 2 +/- I seconds for LCO 3.3.5.a and LCO 3.3.5.b Functions." This changes adding the requircment that the Allowable Value from 2989 V to a range of 2935 V to 3225 V and the time delay be 2 +/- I seconds instead of < 3.0 seconds.

Page 10 ofl1 M - 3.3 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS RcquiYrCmcont CTS Requirement 3.3.5 M.3 CTS LCO 3.3.2.1, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, states the ICO 3.3.5 Table 3.3-4 trip setpoints for the features arc required to be set consistent with the values listed in the Trip Setpoint column of Table 3.3-4. ITS LCO 3.3.5, "Loss of Power (LOP) Emergency Diesel Generator (EDG) Start Instrumentation," requires three channels per bus for the Urdervoltage and degraded voltage Functions for this unit H -1andJ Train 4160 VAC huses to be OPEFRABLE. 'The LCO additionally requires the H and/or J Train 4160 VAC buses on the other unit that are needed to support shared components to be OPERABLE. This changes the LCO requirements by specifically requiring LOP EDG start instrumentation from the other unit to he OP"FRAPLE when si.,pporting shared components for this unit.

3.3.5 M.4 CTS Surveillance Requirements 4.3.2.1.1 and 4.3.2.1.2 require the periodic testing of Loss of LCO 3.3.5.a, 4.3.2.1.1, Voltage and Degraded Voltage Functions for the Loss of Power on the 4160 kV emergecilcy bus. ITS LCO 3.3.5.b 4.3.2.1.2 SRs 3.3.5.1, 3.3.5.2, and 3.3.5.3 require the testing of the LOP EDG start irtstruments for this unit SR 3.3.5.1, and the other unit that supplies shared electrical power to shared components. These requirements SR 3.3.5.2, are specified as LCO 3.3.5.a and LCO 3.3.5.1)Functions. This changes the CTS by requiring the SR 3.3.5.3 other unit loss of voltage and degraded voltage Functions to be tested1 ".r this unit if they support shared components.

3.3.5 M.5 CTS Table 3.3-3, Functional Unit 7, "LOSS OF POWER," and Table 4.3-2, Functional Unit 7, 3.3.5 Mode of None "LOSS OF POWER," state that the applicable MODES are 1, 2, 3, and 4. ITS 3.3.5 requires Loss of Applicability Power EDG Start Instrumentation to be OPERABLE in MODES I, 2, 3,,and 4 and when the associated EDG is required to be OPERABLE by LCO 3.8.2, "AC SoCce.: - Shutdown." T'his changes the CTS by expanding the conditions under which the Loss of Prv,'!r inslniwcncation Must be OPERABLE.

North Anna Power Station Page 11 ofl'l M - 3.3

Table M - More Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.4.1 None N/A N/A N/A 3.4.2 None N/A N/A N/A 3.4.3 M.I CTS 3.4.9.1 Action states that with any of the P/T limits exceeded, restore the temperature and/or 3.4.3 Condition C 3.4.9.1 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 or be in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce the RCS Tg and pressure to less than 200'F and 500 psig, respectively, within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ITS 3.4.3, Condition C, states that with the requirements of the LCO not met any time in other than in MODE I, 2, 3, or 4, initiate immediate action to restore the parameter(s) to within limits and determine the RCS is acceptable for continued operation prior to entering MODE 4. This changes the CTS by requiring immediate action to restore the parameters to within limits when the LCO is not met any time in other than MODE 1, 2, 3, or 4 when the CTS allows 30 minutes to restore parameters.

3.4.3 M.2 CTS 3.4.9.1 Action states that if the P/T limits are exceeded, an evaluation must be performed to 3.4.3 Actions A.2 3.4.9.1 determine if the RCS remains acceptable for continued operation. No time limit is given for the and C.2 performance of this evaluation. ITS 3.4.3, Actions A.2 states that when the LCO is not met, an evaluation to be performed to determine if the RCS is acceptable for continued operation within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

3.4.4 None N/A N/A N/A 3.4.5 M.I CTS 3.4.1.2, Action a, states that when less than the two required reactor coolant loops are 3.4.5 Actions A 3.4.1.2 OPERABLE, the required loop must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS and C 3.4.1.2, Action b , states that when no reactor coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loop to operation. ITS 3.4.5, Action A, states that when one of the two required RCS loops is inoperable, it must be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Action C states that if two required RCS loops are inoperable or the required RCS loop(s) are not in operation, the Rod Control System must be placed in a condition incapable of rod withdrawal, operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1 must be suspended, and action must be imendiately initiated to restore one RCS loops to operable status and operation, This changes the CTS by revising the actions to be taken if both required RCS loops are inoperable. rhe change in the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3. 1.1 is described in DOC L. 1.

North Anna Power Station Page I of 10 M - 3.4

Table M - More Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

ITS Requirement CTS Requirement DOC No. Description of Change CTS Requirement IITS Requirement SR 3.4.5.2 3.4.1.2 3.4.5 M.2 CTS 3.4.1.2 requires two reactor coolant loops to be OPERABLE with each loop consisting of an RCS loop, its associated steam generator, and the reactor coolant pump. CTS 3.4.1.2 does[ not contain any OPERABILITY requirements for the steam generator. ITS SR 3.4.5.2 requires verification that each required steam generator has a secondary side water level > 17% (narrow range instrumentation) every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

one 3.4.5 3.4.1.2 3.4.5 M.3 CTS 3.4.1.2 states that at least two reactor coolant loops shall be OPERABLE and at least by a note that states that all reactor coolant must be in operation. This requirement is modified pumps may be de-energized for up to I hour. ITS 3.4.5 contains the same allowance, but limits the use of the I hour exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

1 3.4.6 Actions A t 3.4.1.3 Actions a 3.4.6 M.1 CTS 3.4.1.3, Action a, states that when less than the two required coolant loops are OPERABLE, 3.4.6 Actions A 3.4.1.3 Actions a soon as and B and b immediate action must be taken to return the required loops to OPERABLE status as that possible and the unit must be in cold shutdown within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS 3.4.1.3, Action b, states when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loops is coolant loop to operation. ITS 3.4.6, Action A applies when one of the required coolant or inoperable. ITS 3.4.6, Action B, states that if two of the required coolant loops are inoperable the required loop is not in operation, operations that would cause introduction into the RCS, be coolant with boron concentration less than required to meet the SDM of LCO 3. 1.1 must operable status suspended, and action must be immediately initiated to restore one coolant loop to required coolant and operation. This changes the CTS by revising the actions to be taken if both action loops are inoperable. Both the CTS and the ITS require immediate initiation of corrective to return the required loops to OPERABLE status. The change in the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1 is described in DOC L.3.

I t 3.4.6 1 3.4.1.3 3.4.6 M.2 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE and at least one must be in 3.4.6 3.4.1.3 operation. This requirement is modified by a note that states that all reactor coolant pumps and residual heat removal pumps may not be in operation for up to I hour..ITS 3.4.6 contains the same allowance, but limits the use of the I hour exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

I ________________________________________

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Table M - More Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

.l~meurme - I -m I Urc[ICIQ DOCGNo. Description of Change ITI Reql~lrenient CTSI Ie~qulremnlit

_________________________________________________ I.

SR 3.4.6.3 .- - 4 4.4.1.3.2 3.4.6 M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be SR 3.4.6.3 4.4.1.3.2 determined OPERABLE by verifying correct breaker alignment and indicated power availability.

ITS SR 3.4.6.3 requires verification that correct breaker alignment and indicated power are available to the required pump not in operation. LCO 3.4.6 allows a combination of reactor coolant pumps and RIJR pumps. This changes the CTS by requiring verification of correct breaker alignment and indicated power availability on required RHR pumps which are not in operation. -4 i 4I 3.4.7. b CTS 3.4.1.3 states that two coolant loops must be OPERABLE in MODES 4 and 5 and one loop 3.4.1.3.

3.4.7 M.A loops.

must be in operation. The coolant loops may be any combination of RCS loops and RI-jR in operation in MODE 5 and an ITS 3.4.7 states that one RI]R loop must be OPERABLE and loop or a steam generator filled to at least additional loop, consisting of another OPERABLE RI4R RHR loop to be OPERABLE and 17%, must be available. This changes the CTS by requiring one by the CTS. The change to RCS in operation in MODE 5 when an RCS or RIIR loop is allowed loop requirements is described in L.1I. i i

3.4.7 M.2 II 3.4.7 Actions A, 13 3.4.1.3 Actions a less than tile two required coolant loops are OPERABLE, 3.4.7 Actions A, n 3.4.1.3 Actions a CTS 3.4.1.3, Action a, states that when and C and b immediate action must be taken to return the required loops to OPERABLE status as soon as possible and the unit must be in cold shutdown within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS 3.4.1.3, Action b , states that when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required coolant loop to operation. ITS 3.4.7, Action A applies when one required RIIR loop is inoperable and one RHIR loop is OPERABLE and requires immediate action to restore the RHIR or steam generator. ITS 3.4.7, Action B states that when one or more required SGs secondary side water levels are not within limits and one RHR loop is OPERABLE, action must be taken to restore a second RHIR loop to OPERABLE status or to restore the SG secondary side water level within if limit immediately. ITS 3.4.7, Action C, states that if no required RIIR loops are OPERABLE or the required RI-HR loop is not in operation, all operations cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1 be suspended and action This must be immediately initiated to restore one RHR loop to OPERABLE status and operation.

changes the CTS by revising the actions to be taken if both RI-IR loops are inoperable. The change in the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1 is described in DOC L.4.

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Table M - More Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

. . - - I T-n " . - --, I f rc DOC No. Description of Change ITS R~equirement CTS 5 R equirenment 3.4.7 3.4.1.3 3.4.7 M.3 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE and at least one must be in operation. This requirement is modified by a note that states that all reactor coolant pumps and residual heat removal pumps may be de-energized for up to I hour. ITS 3.4.7 also allows the RHR pumps to be stopped for I hour, but limits the use of the I hour exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

SR 3.4.7.3 4.4.1.3.2 3.4.7 M.4 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined OPERABLE by verifying correct breaker alignment and indicated power availability.

ITS SR 3.4.7.3 requires verification that correct breaker alignment and indicated power are available to the required RFIR pump not in operation. This changes the CTS by requiring verification of correct breaker alignment and indicated power availability on required PHR pumps that are not in operation.

3.4.8 Actions A 3.4.1.3, Actions a 3.4.8 M.1 CTS 3.4.1.3, Action a, states that when less than the two required coolant loops are OPERABLE, immediate action must be taken to return the required loops to OPERABLE status as soon as and B and b possible and the unit must be in cold shutdown within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS 3.4.1.3, Action b , states that when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required coolant loop to operation. ITS 3.4.8, Action A applies when one required RHR loop is inoperable and requires immediate action to restore the RIIR loop to OPERABLE status. ITS 3.4.8, Action B, states that if no required RHR loops are OPERABLE or tile required RIIR loop is not in operation, all operations involving a reduction in RCS boron concentration must be suspended and action must be immediately initiated to restore one RHR loop to OPERABLE status and operation. This changes the CTS by revising the actions to be taken if both RIIR loops are inoperable from immediate initiation of corrective action to return the required loops to OPERABLE status to take immediate action to suspend RCS boron concentration reductions and restore an RHR loop to OPERABLE status and operation.

3.4.8 3.4.1.3 3.4.8 M.2 CTS 3.4.1.3 contains an allowance for all reactor coolant pumps or RHIR pumps to be de-energized for up to one hour. ITS 3.4.8 allows all R-IR pumps to be removed fiom operation for

< 15 minutes for switching from one loop to the other only and also requires that no draining operations to further reduce the RCS water volume are permitted.

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"Fable M - More Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

.t 1 1q-l1e--ro - - n

.i eurm 11 DOC No. Description of Change ITS Requirement CTS R*equirement 1 SR 3.4.8.3 4.4.1.3.2 M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be SR 3.4.8.3 4.4.1.3.2 3.4.8 determined OPERABLE by verifying correct breaker alignment and indicated power availability.

ITS SR 3.4.8.3 requires verification that correct breaker alignment and indicated power are available to the required RHIR pump not in operation. This changes the CTS by requiring verification of correct breaker alignment and indicated power availability on required RHR pumps which are not in operation.

'I SR 3.4.9.2 I None 3.4.9 M.1 ITS SR 3.4.9.2 requires verification that the capacity of the required groups of pressurizer heaters SR 3.4.9.2 None is >_125 kW every 18 months. This requirement does not exist in the CTS.

I 3.4.10 3.4.3.1 CTS 3.4.3.1, Action, states that when one pressurizer safety valve is inoperable, it must be M.2 3.4.10 3.4.3.1I 3.4.10 restored to OPERABLE status within 15 minutes or be in hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.4.10 states that when one pressurizer safety valve is inoperable, it must be restored to OPERABLE status within 15 minutes or be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 with any RCS cold leg temperature *5235 TF (Unit I), 270TF (Unit 2) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Other changes are discussed in DOC M.2.

1 3.4.10 1 3.4.3.1 3.4.10 M.2 CTS 3.4.3. 1, Action, states that when one pressurizer safety valve is inoperable, it must be 3).4.10 3.4.3.1 restored to OPERABLE status within 15 minutes or be in hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.4.10 states that when one pressurizer safety valve is inoperable, it must be restored to OPERABLE status within 15 minutes or be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 with any 0

RCS cold leg temperature < 235 OF (Unit I), 270'1 (Unit 2) within 24hours. This changes the I),

CTS by requiring the unit to be in MODE 4 with any RCS cold leg temperature *-<235 OF (Unit 270°F (Unit 2) in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months instead of being required to be in MODE 4. Other changes are discussed in DOC M.I.

i 3.4.10 3.4.2 3.4.10 M.3 CTS 3.4.2 requires one pressurizer code safety valve to be OPERABLE in MODE 4. ITS 3.4.10 requires three pressurizer code safety valves to be OPERABLE in MODE 4 when all RCS cold leg temperatures > 235 OF (Unit I), 270'F (Unit 2). This changes the CTS by requiring three safety valves to be OPERABLE in MODE 4.

SR-3.4. . .4 4.4.3.2.1. b.2 3.4.11 M.1 CTS 4.4.3.2. I.b.2 requires operating the solenoid air control valves and check valves on the SR 3.4.1 1.4 4.4.3.2. 1.b.2 associated accumulators in the PORV control systems through one complete cycle of full travel every 18 months. ITS SR 3.4.11.4 requires performing a complete cycle of each solenoid control valve and check valve for the accumulators in the PORV control systems every 18 months. This changes the CTS by specifying that each solenoid control valve and check valve in the normal air and backup nitrogen PORV control systems must be tested every 18 months. I I I1 North Anna Power Station Page 5 ofO10 M - 3.4

Table M - More Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Requirement 3.4.11 M.2 CTS 3.4.3.2, Actions A.6 and 13.3, state, "The provisions of Specification 3.0.4 are not None 3.4.3.2 Actions A.6 applicable." ITS LCO 3.4.11 does not contain a similar allowance. This changes the CTS by and [3.3 eliminating an explicit Specification 3.0.4 exception.

3.4.12 M. I CTS 3.4.9.3, Action f, states that the provisions of Specification 3.0.4 are not applicable. ITS SR 3.4.12.7 Note 3.4.9.3 Action f 3.4.12 does not contain an equivalent Action, but SR 3.4.12.7 states that a COT must be performed oil each required PORV, excluding actuation, and the SR is modified by a Note that states that tile test is not required to be met until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to < 2350 F (Unit I), 270°F (Unit 2).

3.4.12 M.2 CTS 3.5.3, LCO Note #, states that a maximum of one charging pump and one low head safety LCO 3.4.12, 3.5.3 Note "U" injection pump shall be OPERABLE and capable of injecting into the RCS whenever tile 3.4.12 Actions A temperature of one or more of the RCS cold legs is less than or equal to 235'F (Unit 1), 270'F and 13 (Unit 2). The only exception to this requirement is two charging pumps may be OPERABLE and capable of injecting into the RCS during pump switch operation. ']'here are no CTS Actions to be taken if these requirements are not met, so 3.0.3 would be entered. ITS LCO 3.4.12 contains the same requirements on the pumps, and Actions 3.4.12.A and 3.4.12.13 state that if two LHISI pumps or two or more charging pumps, respectively, are capable of injection into the RCS, action must be initiated immediately to limit to a maximum of one LI-ISI pump and charging pump capable of injecting into the RCS.

3.4.12 M.3 CTS 3.5.3, LCO Note H, states that a maximum of one charging pump and one low head safety LCO 3.4.12, 3.5.3 Note "W",

injection pump shall be OPERABLE and capable of injecting into the RCS whenever the LCO 3.4.12 Note 4.5.3.2 Note 0 0 temperature of one or more of the RCS cold legs is less than or equal to 235 F (Unit I), 270 1 (Unit 2). The only exception to this requirement is two charging pumps may be OPERABLE and capable of injecting into the RCS during pump switch operation. CTS SR 4.5.3.2 states that every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months it must be verified that a maximum of one charging pump and one low head safety injection pump is OPERABLE and capable of injecting into the RCS whenever the temperature of 0

one or more of the RCS cold legs is less than or equal to 235'F (Unit I), 2709 (Unit 2). It is modified by a footnote that states that two charging pumps may be OPERABLE and capable of injecting into the RCS during pump switching operations. ITS LCO 3.4.12 states that a maximum of one charging pump and one LHSI pump may be capable of injecting into the RCS. ITS 3.4.12, LCO Note states that two charging puMpS may be capable of injecting into the RCS during pump swap operation for < I hour. This changes the CTS by limiting the amount of time that two charging pumps may be capable of injecting into the RCS for pump swap operations to _Ž4 MSSV inoperable, the unit must be placed in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by providing specific actions for one or more steam generators with >

4 MSSVs inoperable and requiring the unit to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of COLD SHUTDOWN (MODE 5) within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

3.7.2 M. I CTS 3.7.1.5 ACTIONS for MODES 2 and 3 states subsequent operation in MODES 1, 2, or 3 may 3.7,2 Actions C 3.7.1.5 proceed provided the inoperable MSTV is maintained closed. If the valve is not maintained closed, and D the unit must be in HOT SHUTDOWN (MODE 3) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.7.2 Required Actions C. I requires an inoperable MSTV to be closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and Required Action C.2 requires the valve to be verified closed once per 7 days. Otherwise, Action D requires the unit must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by specifying a time within which the inoperable MSTV must be closed (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ), requiring periodic verification that the inoperable MSTV is closed, requiring the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the Required Actions and Associated Completion Times are not met, and requiring the unit to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Required Actions and associated Completion Times are not met.

3.7.2 M.2 The CTS does not require testing to verify that the MSTV close on an actuation signal. ITS SR SR 3.7.2.2 None 3.7.2.2 requires verification that each MSTV actuates to the isolation position on an actual or simulated actuation signal. This changes the CTS by requiring verification that each MSTV actuates to the isolation position on an actual or simulated actuation signal.

North Anna Power Station Page I of9 M - 3.7

Table M - More Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement CTS 3.7.1,5, Actions for MODES 2 and 3, allows continued operation in MODES I, 2, or 3 with an 3.7.2 Action C 3.7.1.5 Actions 3.7.2 M.3 inoperable, closed MSTV and states that the provisions of specification 3.0.4 are not applicable. The specification 3.0.4 exception allows MODE transitions while relying on the CTS 3.7.1.5 Action. ITS 3.7.2, Action C, applies with one or more MSTVs inoperable and does not allow operation in MODE I and does not provide an exception to ITS LCO 3.0.4, so MODE transition to MODE I is not allowed. This changes the CTS by not allowing operation in MODE I with an inoperable, closed MSTV.

None 3.7.1.5 Actions 3.7.2 M.4 CTS 3.7.1.5 ACTION for MODE I specifies that POWER OPERATION may continue when one MSTV is inoperable if the inoperable valve is restored to OPERABLE status or closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.7.2 ACTION A requires restoring the inoperable valve to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The ITS does not provide any allowance for continued operation by closing the valve while in MODE 1. This changes the CTS by deleting the allowance for continued operation in MODE I with a closed, inoperable MSTV.

CTS 3.7.1.5 Actions requires that when one main steam trip valve is inoperable in MODE I, the 3.7.2 Action A 3.7.1.5 Actions 3.7.2 M.5 valve is to be restored to Operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the unit is to be in MODE 3 within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS Action A allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore an inoperable main steam trip valve to OPERABLE status when in MODE I, and an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in MODE 3. This changes the CTS allowed outage time to be in MODE 3 with an inoperable MSTV from 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months to 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months .

The change in time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore an inoperable MSTV is discussed in DOC L.2.

3.7.3 None 3.7.3 M. I CTS does not have any requirement for Main Feedwater Isolation Valves (MFIVs), Main Feedwater Pump Discharge Valves (MFPDVs), Main Feedwater Regulating Valves (MFRVs) and Main Feedwater Regulating Bypass Valves to be OPERABLE, other than a requirement for an actuation signal to be supplied to the valves in CTS 3.3.2.1. ITS 3.7.3 requires the MFIVs, MFPDVs, MFRVs, and MFRBVs be OPERABLE in MODES I, 2, and 3. This changes the CTS by incorporating the requirements of ITS 3.7.3.

3.7.4 None 3.7.4 M.1 CTS does not have any Technical Specification requirements for atmospheric dump valves. ITS 3.7.4 specifies the requirements for the "Steam Generator Power Operated Relief Valves,"

SGPORVs, consistent with the requirements of ISTS 3.7.4, "Atmospheric Dump Valves." This changes the CTS by incorporating the requirements of ITS 3.7.4.

Page 2 of 9 M - 3.7 North Anna Power Station

Table M - More Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.5 M. I CTS LCO 3.7.1.2 is applicable in Modes 1, 2, and 3. ITS LCO 3.7.5 is applicable in Modes 1, 2, 3.7.5 3.7.1.2 and 3, and MODE 4 when the steam generator is relied upon for heat removal for the system.

To support this change in the Applicability, the following additional requirements are added to the CTS:

"* A note is added to the LCO that requires an AFW train, supported by a motor driven pump, to be operable in MODE 4;

" A new ACTION E is added which requires an immediate action to restore a required inoperable AFW train to OPERABLE status when the SG is required in MODE 4; and

" The addition of Notes to ITS SRs 3.7.5.3 and 3.7.5.4. which state the requirements are not applicable in MODE 4 when a steam generator is reli d upon for heat removal.

3.7.6 M. I The CTS requirements on the ECST are applicable in MODES I, 2, and 3. ITS 3.7.6 is applicable 3.7.6 3.7.1.3 in MODES I, 2, and 3, and in addition, MODE 4 when a SG is relied upon for heat removal. Applicability Applicability Consistent with this change in applicability, the phrase "Be in MODE 4, without reliance on steam generator for heat removal" is added to ITS ACTION B. This changes the CTS requirements by requiring the ECST to be OPERABLE in MODE 4 when a SG is relied upon for heat removal.

3.7.6 M.2 CTS ACTION b requires the plant must be in HOT SHUTDOWN within the next twelve hours if the 3.7.6 Action B 3.7.1.3 Action b ECST is inoperable for seven days. ITS Action B states "Required Action and associated Completion

'rime not met, be in MODE 3 within six hours and MODE 4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." This changes the CTS to require the plant to be in MODE 3 within six hours. The change in the time to reach MODE 4 is discussed in DOC L. I.

3.7.7 M. I CTS Table 4.7-1 item #2 allows the sampling frequency for the DOSE EQUIVALENT 1-131 to be SR 3.7.7.1 Table 4.7-1, Item 2 extended to once per 6 months whenever the gross activity determination indicates the iodine concentrations are below 10% of the allowable limits. ITS SR 3.7.7.1 does not provide for this extended time frame for determining the DOSE EQUIVALENT 1-131 and requires verification of specific activity of the secondary coolant every 31 days whenever the unit is in MODES 1, 2, 3, and

4. This changes the CTS by deleting CTS Table 4.7-I, item 2.b, and the qualifying statement of, "whenever the gross activity determination indicates iodine concentrations greater than 10% of the allowable limit."
3.7.8 M. I CTS 4.7.4.1 does not contain a requirement to verify each SW System pump starts automatically on SR 3.7.8.3 None an actuation signal. ITS SR 3.7.8.3 states, "Verify each SW pump starts automatically on an actual or simulated actuation signal." This changes the CTS by adding a SR to test the SW Systems pumps.
Page 3 of 9 M - 3.7 North Anna Power Station
I Table M - More Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.9 None N/A N/A N/A 3.7.10 M.l CTS 3.7.7.1 requires the emergency ventilation system to be OPERABLE. ITS 3.7.l10 states, "The 3.7.10 3.7.7.1 following MCRIESGR EVS trains shall be OPERABLE: a. Two MCR/ESGR Emergency Ventilation System (EVS) trains; and b. One MCR/ESGR EVS train on the other unit." This changes CTS by specifying the number and type of MCRIESGR EVS trains required to be OPERABLE.
3.7.10 M.2 CTS 3.7.7.1 Action a states, "With either the emergency ventilation system or the bottled air 3.7. 10 Action A 3.7.7.1 Action a pressurization system inoperable, restore the inoperable system to OPERABLE status within 7 days..." ITS 3.7. 10 Condition A states, "One required LCO 3.7. I0.a or 3.7. 1 0.b MCRIESGR EVS train inoperable." ITS Required Action A. I states, "Restore train to OPERABLE status," within 7 days. This changes CTS by allowing only one required train of the MCR/ESGR EVS to be inoperable for 7 days, but not allowing the entire MCR/ESGR EVS to be inoperable for 7 days.
3.7.10 M.3 CTS 3.7.7.1 Action b states, "With both the emergency ventilation system and the bottled air 3.7.10 Actions B 3.7.7.1 Action b pressurization system inoperable, restore at least one of these systems to OPERABLE status within and C, LCO 3.0.3 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." ITS 3.7.10 Required Action B.I requires that with two or more required LCO 3.7.10.a or LCO 3.7.10.b MCR/ESGR EVS trains inoperable due to an inoperable MSR/ESGR boundary in MODE 1, 2, 3, or 4, restore the MCRIESGR boundary to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The Bases for Required Action B.lI state, "During the period that the MCR/ESGR boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition." ITS 3.7.10 Condition C requires that if the Required Actions and associated Completion Time of Condition A or B are not met, the unit be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ITS LCO 3.0.3 allows 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to place the unit'in MODE 3, and 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 5. This changes CTS by not providing a Completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the two or more required MCR/ESGR EVS trains and two or more required MCR/ESGR bottled air trains are inoperable at the same time, except for an inoperable MCR/ESGR boundary. This also changes CTS by requiring compensatory measures be taken while the MCR/ESGR boundary is inoperable. This results in allowing 23 fewer hours to place the unit in MODE 3 and MODE 5, and requires additional compensatory actions be taken.
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Table M - More Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.10 M.4 CTS 3.7.7.1 Action a states, "With either the emergency ventilation system or the bottled air 3.7. 10 Action D, 3.7.7. I Action a pressurization system inoperable, restore the inoperable system to OPERABLE status within 7 LCO 3.0.3 days..." ITS 3.7.10 Required Action D. I requires that with two or more required LCO 3.7. iO.a or LCO 3.7.10,b MCR/ESGR EVS trains inoperable for reasons other than Condition B, enter LCO 3.0.3 immediately. ITS LCO 3.0.3 allows 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to place the unit in MODE 3, and 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 5. This changes CTS by not providing a Completion time of 7 days when the two or more required MCR/ESGR EVS trains are inoperable resulting in less time allowed to place the unit in MODE 3 and MODE 5.
3.7.10 M.5 CTS 4.7.7.1 states, "Each control room emergency ventilation system shall be demonstrated SR 3.7.10.3 4.7.7.1 OPERABLE: ...d. At least once per 18 months by:...2. Verifying that the normal air supply and exhaust are automatically shutdown on a Safety Injection Actuation Test Signal." ITS SR 3.7.10.3 states, "Verify each LCO 3.7.10.a MCR/ESGR EVS train actuates on an actual or simulated actuation signal." The Frequency is every 18 months. This changes CTS by requiring verification of automatic actuation of each LCO 3.7.10.a MCR/ESGR EVS train on an actual or simulated actuation signal. The change moving details of how the test is performed are addressed in a removed detail discussion of change.
3.7.10 M.6 CTS 4.7.7. l.d.3 uses a reference of "outside atmosphere" with regard to the pressure at which the SR 3.7.10.4 4.7.7. l.d.3 emergency ventilation system must maintain the control room. ITS SR 3.7.10.4 uses the reference "adjacent areas." This changes the reference used when determining whether the MCR/ESGR envelope has been sufficiently pressurized to a more specific reference.
3.7.10 M.7 CTS 4.7.7.I.d.3 specifies positive pressure and flow requirements that must be met by the control SR 3.7.10.4 4.7.7. l.d.3 room emergency ventilation system. ITS SR 3.7.10.4 states the positive pressure and flow requirements that must be met by each required train of the MCRIESGR EVS. This changes the CTS by specifying that the each required train of the MCR/ESGR EVS must be capable of performing the specified Surveillance Requirement.
3.7.11 M.I ITS 3.7.11 Applicability includes, "During movement of recently irradiated fuel assemblies." ITS 3.7.11 None 3.7.11 Condition C is entered when the Required Action and associated Completion Time of Applicability and Condition A is not met during movement of recently irradiated fuel assemblies. The Required Actions Actions require either placing an OPERABLE MCRIESGR ACS subsystem in operation or suspending movement of recently irradiated fuel assemblies. Condition D is entered when less than 100% of the MCR/ESGR ACS cooling equivalent to a single OPERABLE MCR/ESGR ACS subsystem is available during movement of recently irradiated fuel. Required Action D. I requires suspending movement of recently irradiated fuel assemblies immediately. This changes CTS by adding an additional Applicability criteria and associated Conditions and Required Actions.
North Anna Power Station Page 5 of 9 M -3.7
Table M - More Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.11 M.2 CTS 4.7.7.3 states, "Each control room air-conditioning system shall be demonstrated OPERABLE SR 3.7.11 . I 4.7.7.3 at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than or equal to 120 0 F." ITS SR 3.7. 11.1 states, "Verify each MCR/ESGR ACS chiller has the capability to remove the design heat load." The Frequency is every 18 months on a STAGGERED TEST BASIS. This changes CTS by replacing a temperature verification with a test to verify each MCR/ESGR ACS chiller has the capability to remove the design heat load.
3.7.11 M.3 CTS 3.7.7.1 Action d states, "With both the air conditioning systems inoperable, restore at least one 3.7.11 Action E 3.7.7.1 Action d system to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 and LCO 3.0.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." ITS 3.7. II Condition E states that with less than 100% of the MCRIESGR ACS cooling equivalent to a single OPERABLE MCR/ESGR ACS subsystem available in MODES I, 2, 3, or 4, enter LCO 3.0.3 immediately. ITS LCO 3.0.3 allows 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to place the unit in MODE 3, and 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 5.
This changes the CTS by allowing 23 hours2.662037e-4 days 0.00639 hours 3.80291e-5 weeks 8.7515e-6 months less to place the unit in MODE 3 and MODE 5 if the equivalent of one MCR/ESGR ACS subsystem is not available. The change in the criteria for the systems is addressed in another more restrictive discussion of change.
3.7.12 M. I CTS LCO 3.7.8.1 states, "Two safeguards area ventilation systems (SAVS) shall be OPERABLE 3.7.12 and SRs 3.7.8.1 and 4.7.8.1 with: a. one SAVS exhaust fan b. one auxiliary building HEPA filter and charcoal adsorber 3.7.12. I and assembly (shared with Unit 2)." In the Unit 2 CTS, the reference to the other unit states, "(shared 3.7.12.2 with Unit I)." CTS ACTION addresses the inoperability of one SAVS. CTS 4.7.8.1 states, "Each SAVS system shall be demonstrated OPERABLE." CTS 4.7.8.1 .a. I requires, "...verifying that the SAVS operates for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months with the heater on." ITS 3.7.12 states, "Two ECCS PREACS trains shall be OPERABLE." ITS Condition A addresses the inoperability of one ECCS PREACS train. ITS SR 3.7.12.1 and SR 3.7.12.2 require the respective surveillances be performed on each ECCS PREACS train. This changes CTS by applying the requirements to all the components that constitute an ECCS PREACS train, rather than just the SAVS.
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Table M - More Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.7.12 M.2 ITS SR 3.7.12.5 states, "Verify one ECCS PREACS train can maintain a negative pressure relative 3.7.12.5 None to atmospheric pressure during the post accident mode of operation." The Frequency is 18 months on a STAGGERED TEST BASIS. ITS LCO 3.7.12 includes a NOTE that states, "The ECCS pump room boundary openings not open by design may be opened intermittently under administrative control." ITS Required Action B.I requires that when two ECCS PREACS trains are inoperable due to an inoperable ECCS pump room boundary, that the ECCS pump room boundary be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes CTS by adding a requirement that equipment be able to provide a negative pressure relative to atmospheric pressure for the required ECCS PREACS areas. The ITS LCO 3.7.12 NOTE states allowed exceptions to the requirements of ITS SR 3.7.12.5.
The ITS Required Action B. I provides a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time in case two ECCS PREACS trains are inoperable due to an inoperable ECCS pump room boundary.
3.7.13 M. I CTS 3.7.7.1 requires the bottled air pressurization system to be OPERABLE. ITS 3.7.13 states, 3.7.13 3.7.7.1 "Three MCR/ESGR bottled air system trains shall be OPERABLE." This changes CTS by specifying the number of MCRIESGR bottled air system trains required to be OPERABLE.
3.7.13 M.2 CTS 3.7.7.1 Action a states, "With either the emergency ventilation system or the bottled air 3.7.13 Actions A 3.7.7.1 Actions a pressurization system inoperable, restore the inoperable system to OPERABLE status within 7 and C and b days..." CTS 3.7.7.1 Action b states, "With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." ITS 3.7.13 Condition A states, "One required MCR/ESGR bottled air system train inoperable." ITS Required Action A. I states, "Restore train to OPERABLE status," within 7 days.
ITS 3.7.13 Required Action C. I is added, allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore at least two MCR/ESGR bottled air system trains to OPERABLE status if two or more required trains are inoperable for reasons other than an inoperable MCR/ESGR boundary. The Bases for Required Action C. I state, "During the period that two or more required trains of thle MCR/ESGR bottled air system are inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination.
Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition." This changes CTS by allowing only one required train of the MCR/ESGR EVS and MCR/ESGR bottled air system to be inoperable for 7 days, and allowing two or more required trains of the MCR/ESGR bottled air system to be inoperable for any reason for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months instead of 7 days. This also changes CTS by requiring compensatory measures be taken while two or more trains of the MCR/ESGR bottled air system are inoperable. Not allowing both the MCR/ESGR EVS and MCR/ESGR bottled air system to be inoperable concurrently for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months except for an inoperable MCRIESGR boundary is addressed by DOC M.3.
North Anna Power Station Page 7 of 9 M -3.7
Table M - More Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.1 M. I CTS 3.8.1. 1 Actions would allow the LCO to not be met for an indefinite period ofttime, as long as 3.8.1, Required 3.8.1. I Actions the allowed outage time of each individual Action is not exceeded. For example, an EDG may be Actions A.3 and inoperable for a period of 14 days. During the allowed time, an offsite circuit may become B.4 inoperable. This would require a 12-hour action to be entered, until cither the EDG or offisite circuit is restored to OPERABLE status. The restoration of either the EDG or offsite circuit is allowed within the CTS Actions for an unlimited period of time. This could allbw ihe LCO to not be met for a period that could exceed many weeks. ITS Required Actions A.3 and B.4 require the restoration of all required features within 17 days from discovery of failure to meet the LCO. This changes the CTS by limiting the total time that any combination of ot'tsite circuits and EDGs may be inoperable to a total of 17 days.
3.8.1 M.2 CTS requirement 4.8.1.1 .2 for the EDG day tank does not require a periodic surveillance to monitor SR 3.8.1.5 None the fuel oil tank for water. ITS SR 3.8.1.5 requires each EDG's day tank be checked and any accumulated water removed at a Frequency of every 92 days. This changes the CTS by adding an additional Surveillance Requirement.
3.8.I M.3 CTS Surveillance Requirement 4.8.1.1 .2.d.8 requires that the EDG must be capable of transferring SR 3.8.1.15 4.8.1.1 .2.d.8 loads to and from offsite electrical source. Once the capability has been demonstrated', in part c) the EDG may, "proceed through its shutdown sequence." ITS SR 3.8. 1.15 ,verifics the capability of the EDG to transfer loads from and to the offsite electrical source. The SR requires.in part c that the EDG, "Returns to ready-to-load operation." This changes the CTS by stating that the EDG is capable of re-powering the emergency bus by being returned to the ready-to-load condition.
3.8.1 M.4 CTS requirement 4.8.1.1.2.d.4 verifies that on an ESF signal without the loss of offsite power, the SR 3.8. 1.1 1 4.8.1 . 1.2.(..4 EDG starts in < 10 seconds with voltage > 3960 V and frequency > 59.5 Hz and operates in a standby condition > 5 minutes, The steady state voltage and frcquency are required to be > 3740 and
< 4580 volts and >Ž59,5 and
60.5 Hz. ITS SR 3.8. 1.11 states the EDG will start in < 10 seconds with voltage > 3960 V and frequency > 59.5 Hz and operates in a standby condition _>5 minutes. The steady state voltage and frequency are required to be > 3740 to < 4580 volts and _>59.5 to
60.5 lHz.
The ITS also requires verification that each permanently connected load rcmains cnergized from the offsite electrical power system and emergency loads are energized or auto-connecled through the sequencing timing relays are energized from the offlsite clectrical power system. This changes the CTS by requiring the verification of permanently connected loads and auto-connected loads, through their sequencing timing relays, remain energized from offisite circuits.
North Anna Power Station Page I of"6 M -3.8
Table M - More Restrictive Changes ITS Section 3.8 - Electrical Power Systems it ccquirc'IIc'iL I ..) I\.qULi IjL..I3L II1VPQ 111 I (-,Pq R (-rill in-filf-til Description of Change ITS Rquiremelnt 3TIleI 4.8 L3,II DOC No. 3.8.6, Condition 3.8.6, Condition 3Table 4.8-3, A and B parameters not 3.8.6 M. I CTS Table 4.8-3 notes (1) and (2) require specific actions for Category the battery A Notes (I) and (2) the limit(s) shown, within limits. Note I states, "For any Category A parameter(s) outside B measurements are may be considered OPERABLE provided that within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months all the Category all Category A and B parameter(s) taken and found to be within their allowable values, and provided Note 2 states, "For any Category B are restored to within limits within the next six days."
be considered OPERABLE provided that parameter(s) outside the limit(s) shown, the battery may limits and restored to within Category B limits the Category B parameters are within their allowable "One or more station or EDG batteries with one or within 7 (lays." ITS 3.8.6 Condition A states, Category A or B limits." If this condition is more battery cell parameters not within Table 3.8.6-I of pilot cells electrolyte level and float entered, the Required Actions A. I requires the verification the CTS by specifying a voltage meet Table 3.8.6-1 Category C limits within I hour. This changes level and voltage are within limits.
time of one hour to verify pilot cell electrolyte k SR 3.8.6.2 1 4.8.2.3.2 .b, within 7 (lay's after a battery SR 3.8.6.2 4.8.2.3.2.h, 3.8.6 M.2 CTS surveillance requirements 4.8.2.3.2.b and 4.8.1.1 .3.b state that in Table 4.8 4.8.1.1.3.b battery parameters discharge below 110 volts or an overcharge above 150 volts, that the EDG battery cell 3 meet the Category B limits. ITS SR 3.8.6.2 requires that the Station and B limits every 92 days and once within 24 parameters be verified to meet Table 3.8.6 - I Category discharge to < I10 volts. This changes the CTS hours after a battery overcharge to > 150 volts or are verified within 24 hours whIere the current requirement by requiring the Category B limits requirements allow 7 days. 4- i
.3 for the EDG SRL3.8.6.2, 4.8.2.3.2.tb, and 4.8.1.1 4.8.1.1.3, 3.8.6 M.3 CTS Surveillance Requirements 4.8.2.3.2.b for thie station batteries of the Category Table 3.8.6-1 the parameters Table 4.8-3, Note batteries specify that after an overcharge or a discharge of a battery, voltage, and specific (b)
B limits must be met. The Category B parameters of electrolyte level, float values to be met. The specific gravity limits gravity are listed in Table 4.8-3, and require specific specify that Note (b) is:applicable for. the station for Category A and Category B allowable value charging current is less that 12 amps when on charge (station batteries. Note (b) states, "Or battery requires verification that the station and FIDG Category B battery batteries only)." ITS SR 3.8.6.2 The Category limits listed B
cell parameters are within limits after a battery overcharge or discharge.
Notes (b) and (c) modify in Table 3.8.6 - I are electrolyte level, float voltage, and specific gravity.
oh'urging onifloat current of less the specific gravity requirements. In part, these notes allow a battery station and EDG batteries. This than 2 amps to substitute for direct specific gravity readings for the current of less than 2 amps changes the CTS requirements by allowing the substitution of charging instead of 12 amps to substitute for specific gravity readings. I I Page 4 of 6 M -3.8 North Anna Power Station
Table M - More Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement 3.8.7 M. I CTS LCO 3.8.2.1 footnote states, "Two inverters may be disconnected from their D.C. Busses for up LCO 3.8.7 Note LCO 3.8.2.1 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as necessary, for the purpose ol performing an equalizing charge on their associated footnote batteries provided (I) their vital busses are energized, and (2) the remaining vital busses are energized from their associated inverters and connected to their associated D.C. Busses." ITS LCO 3.8.7 Note states, "One inverter may be disconnected from its associated DC bus for < 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on its associated battery, provided: a. The associated AC vital bus is energized from its constant voltage source transformer; and b. All other AC vital buses are energized from their associated OPERABLE inverters." This changes the CTS by only allowing one inverter to be disconnected and requiring the associated AC bus to be powered from "its constant voltage source transformer."
3.8.7 M.2 CTS 4.8.2.1 states the specified A.C. busses shall be determined OPERABLE at least once per 7. SR 3.8.7. 1 4.8.2.1 (lays by verifying indicated power availability. ITS SR 3.8.7. I requires the verificationof the correct inverter voltage to required AC vital buses every 7 days. This changes the CTS by requiring the verification of the correct inverter voltage to the required AC vital buses, where the CTS only requires verification of indicated power.
3.8.8 M. I CTS 4.8.2.2.1 states the specified busses shall be energized in the required manner once per 7 days SR 3.8.8.1 4.8.2.2.1 by verifying indicated power availability. ITS SR 3.8.8.1 requires the verification of the correct inverter voltage to required AC vital buses every 7 days. This changes the CTS by requi,-ing the verification of the correct inverter voltage to the required AC vital buses, where the C0ITS only requires verification of indicated power.
3.8.9 M. I CTS 3.8.2.1 Action a. states that with one of the required A.C. emergency busses not fully energized, 3.8.9, ACTIONS 3.8.2.1, Actions a re-energize the bus within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Action b. states within one A.C. Vital Bus not energized, re- A, B, and C and b, energize the A. C. Vital bus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS 3.8.2.3 Action a states with one 125 VDC bus 3.8.2.3, Action a inoperable, restore the inoperable bus to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3:8.9, Action A, states that with one or more AC subsystems inoperable, restore the subsystem(s) to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. Action B states that with one or more AC vital buses inoperable, restore the AC bus.subsystem(s) to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. Action C :,ates ihat with one or more DC vital buses inoperable, restore tei DC bus(es) to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. This changes the CTS by placing a limit of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months for failing to meet the LCO when the CTS does not specify a limit.
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Table M - More Restrictive Changes ITS Section 3.8 - Electrical Power Systems I IMI, Ronmrommit 1,(CCIUII-ClllCllL I CIS P't'llif-ptiloill I DOC No. Description of Change SR 3.8.9.1 4.8.2.1, 3.8.9 M.2 OPERABLE at least once per 7 4.8.2.3.1 cTS 4.8.2.1 states the specified A.C. busses shall be determined states thai eaIch D.C. bus train shall be days by verifying indicated power availability. CTS 4.8.2.3.1 power availability. ITS SR demonstrated OPERABLE at least once per 7 days by verifying indicated DC, and AC vital buses 3.8.9.1 requires the verification of the correct voltage to required AC, the CTS by requiring the electrical power distribution subsystems every 7 days. This changes vital buses electrical power verification of the correct voltages to the required AC, DC, and AC of indicated power.
distribution subsystems, where the CTS only requires verification i 3.8.10 M.1 at least once per 7 days by ISR 3.8. 10.1 4.8.2.2.1 CTS 4.8.2.2.1 states the specified busses shall be determined OPERABLE verification o" the correct verifying indicated power availability. ITS SR 3.8.10.1 requires the buses electrical power distribution subsystems every 7 voltage to required AC, DC, and AC vital voltages to the required AC, days. This changes the CTS by requiring the verification of the correct where the CTS only requires DC, and AC vital buses electrical power distribution subsystems, verification of indicated power. I J----
-L Page 6 of 6 M -3.8 North Anna Power Station
Table M - More Restrictive Changes ITS Section 3.9 - Refueling Operations I
Ill KcquIrcIIIcrIL I rrno .
Description of Changes I*I VITS Rl*equlrenctitll D - - I ICT qP,,II;-II"li I Nu IN
/A Il eLliliI DOC No. i i.IN/A N/A 3.9.1 None N/A 3.9.2 ACTIONS 3.1.1.3.2 are not locked, 3.9.2 ACTIONS 3.1.1.3.2 3.9.2 M.lI Unit I CTS 3.1.1.3.2 states that when the primary grade water flow path isolation valves 6, all operations involving positive scaled, or otherwise secured in the closed position in MODE must be locked, reactivity changes or CORE ALTERATIONS must be suspended, and the valves 15 minutes. Unit 2 CTS 3.1.1.3.2 states that when tile sealed, or secured in the closed position within valves are not locked, sealed, or otherwise secured in the closed primary grade water flow path isolation reactivity changes or CORE ALTERATIONS must be position, all operations involving positive in the closed position suspended, the isolation valves must be locked, sealed, or otherwise secured or equal to 1.77% Ak/k within 15 minutes, and SHUTDOWN MARGIN must be verified greater than aic not secured in the closed within 60 minutes. ITS 3.9.2 Actions state than when one or more valves grade water (low paths position, CORE ALTERATIONS must be suspended immediately, the primary be verified per SR 3.9. I. I within 4 must be isolated within 15 minutes and the boron concentration must verify the RCS boron concentration hours. This changes the Unit I CTS by adding a requirement to 1.77%Ak/k to a reference to SR within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and by changing the shutdown margin requirement from requiring perolrmance of the 3.9. I.1and changes the Unit I and Unit 2 CTS by adding a Note flow path isolation valve is SHUTDOWN MARGIN determination whenever a primary grade water __.
inadvertently opened. -t 3.9.3 Action A an(l T LCO 3.9.2 immediate 3.9.3 AcBion A and ILCO 3.9.2 3.9.3 M.l1 CTS LCO 3.9.2 Action requires with less than two source range channels OPERABLE, B CORE ALTERATIONS or positive reactiviiy changes. Unit 2 suspension of all operations involving boron concentration be CTS in LCO 3.9.2 requires that if both monitors are inoperable, the RCS ITS 3.9.3 Action A requires with one source range neutron flux monitor verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .
immediately, "that inoperable, CORE ALTERATIONS and reactivity changes shall be suspended than required to meet the would cause introduction into the RCS, coolant with boron concentration less ocutron flux monitors boron concentration of LCO 3.9. I." ITS Action B states with two source range a veci fication of inoperable, initiate action immediately to restore one to OPERABLE and perform I CTS requirements by refueling boron concentration once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the Unit both source ranges are inoperable requiring a verification of boron concentration every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when to restore one source range to and the Unit I and Unit 2 CTS by requiring immediate initiation action OPERABLE status. i T channels. SR 3.9.3.2 4.9.2 3,9.3 M.2 CTS Surveillance Requirement 4.9.2 specifies testing for the source range instrumentation to he 1crforined on the ITS SR 3.9.3.2 requires the performance of a CHANNEL CALIBRATION
1CHANNEL source range monitors every 18 months. This changes the CTS by requiring CALIBRATION every 18 months on each source range monitor. t 1
SR 3.9.3.1 4.9.2 4.9.2 per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during CORE ISR 3.9.3.1 3.9.3 M.3 Unit I CTS 4.9.2 requires a CHANNEL CHECK to be performed once Page 1 of 3 M - 3.9 North Anna Power Station
Table M - More Restrictive Changes ITS Section 3.9 - Refueling Operations I ITS Requirement I (itS Requirement OnrD n Description of Changes ITS Requirement I-IcTrS
.1 RequiremlentI Lt I ____________________
ALTERATIONS. ITS SR 3.9.3.1 requires a CHANNEL CHECK to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . i I--
This changes the Unit I CTS by requiring the CHANNEL CHECK to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months even if CORE ALTERATIONS are not in progress.
I, I.. -3.9.2- ý 3.9.3 3.9.2 3.9.3 M .4 CTS 3.9.2 states, in part, that, " two source range neutron flux monitors shall be operating." ITS 3.9.3 states, "Two source range neutron flux monitors shall be OPERABLE." This changes the CTS by requiring the source range neutron flux monitors to be OPERABLE, instead ofjust operating.
me N/A N/A N/A 3.9.4No LCO 3.9.5 Notes 3.9.8.1, Action c 3.9.5 M I CTS 3.9.8. 1, Action c., states that tile RHR loop may be removed From operation For up to I hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period during the performance ol CORE AL'ERATIONS in the vicinity of the reactor pressure from vessel hot legs. ITS LCO 3.9.5 Notes states that the required RHIR loop may be removed provided operations are permitted that would cause operation Ior 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, )no coolant with boron concentration less than required to introduction into the Reactor Coolant System, boron concentration of LCO 3.9. 1. This results in two changes to the CTS.
meet the minimum required to rcmove RHR l1rom operation is no longcr restricted to CORE ALTERATIONS in First, the allowance in the ITS is the vicinity of the reactor pressure vessel hot legs. Second, the use of the allowance on prohibiting operations that will cause introduction into tile RCS, coolant with a boron predicated concentration less than required to meet the boron concentration of LCO 3.9.-I SR, 3.9.5.1 4.9.8.1.2 3.9.5 M1.2 CTS Surveillance 4.9.8.1.2 states that one RHR loop must be verified to be in operation an(d a. if the reactor RCS temperature is > 14(0 'F or the time since entry into MODE 3 is < 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , circulating 140 'F or the time since entry into coolant at a flow rate > 3000 gpm, or b. if the RCS temperature is <
> 2000 gpm. ITS SR 3.9.5. I requ, irCs MODE 3 is > 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , circulating reactor coolant at atflow rate coolant at a flow rate or Ž> 3000 verification that one RHR loop is in operation and circulating reactor RCS gpm. This changes the CTS by eliminating the option to reduce RHR flow to 2000 gpm when temperature is < 140 'F or the time since entry into MODE 3 is < 100 hours.
to be in SR 3.9.6.2 3.9.9.2 3.9.6 M. I CTS 3.9.8.2 requires two independent RHR loops to be OPERABLE and at least one loop 3.9.6.2 requires verification every seven days of correct breaker aligniment and that operation. ITS SR indicated power is available to the RUR purnp not in operation. A Note states thait the Surveillance is not in Requirement is not required to be performned until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RIIR pump operation. This changes the CTS by adding a Surveillance Requirement.
i C .. 3..1.
movement LCO 3.9.7 3.9.10 .1I 3.9.7 M].I CTS 3.9.10.1 Action states that with the reactor vessel water level not within limit, suspentd reactor pressure vessel. ITS 3.9.7 states with tie refueling cavity water of fuel assemblies within the movement of irradiated fuel assemblies within containment. This change level not within limit, suspend of movement of fuel assemblies from within tile reactor pressure I the CTS by expanding the suspension Page 2 oef 3 M -3.9 North Anna Power Station
Table M - More Restrictive Cjianges ITS Section 3.9 - Refueling Operations ITS Requirement CTS Requirement scription of Changes g.... '1 -,)"
M - 3.9 North Anna Power Station vage -) oi -)
Table M - More Restrictive Changes ITS Section 4.0 - Design Features DOC No. Description of Changes ITS Requirement CTS Requirement 4.0 M. I ITS 4.3.1.2.b states that the new fuel storage racks must be designed and maintained with the Kff < 0.95 4.3.1.2.b None if fully flooded with unborated water. The CTS does not contain this information.
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Table M - More Restrictive Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Changes ITS Requirement CTS Requirement 5.0 M. I ITS 5.1.1 states, "The plant manager or his designee shall approve, prior to implementation, each 5.5.1 None proposed test, experiment or modification to systems or equipment that affect nuclear safety." The CTS does not include such a statement. This changes the CTS by adding a required action for the plant manager or his designee.
5.0 M.2 ITS 5.4.1 states, "Written procedures shall be established, implemented, and maintained covering the 5.4.1 None following activities:...b. The emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33." The CTS does not include this requirement. This changes the CTS by adopting a new requirement for emergency operating procedures.
5.0 M.3 ITS 5.4.1 states, "Written procedures shall be established, implemented, and maintained covering the 5.4.1 None following activities:...e. All programs specified in Specification 5.5." The CTS does not include this requirement. This changes the CTS by adopting a new requirement for procedures to address programs described in ITS 5.5.
5.0 M.4 CTS 6.12.1 states, "...entrance [into a high radiation area] thereto shall be controlled by requiring 5.7.1.b aild 5.7.2.b 6.12.1 issuance of a Radiation Work Permit." ITS 5.7.L .b and 5.7.2.b state, "Access to, and activities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures." This changes the CTS by specifying certain information is required to be in the RWP or equivalent. The addition of the option to use a means equivalent to the RWP is addressed in DOC L. 16.
5.0 M.5 The CTS does not contain a diesel fuel oil testing program that controls the requirements for testing and 5.5.12 None maintaining the properties of both new and stored fuel oil. ITS 5.5.12 establishes a diesel fuel oil testing program to implement required testing of both new and stored fuel oil. This changes the CTS requirements by adding the requirement for a diesel fuel oil testing program.
5.0 M.6 The CTS does not contain specific requirements for a Technical Specification Bases Control Program 5.5.13 None that controls changes to the Bases. ITS 5.5.13 specifies the programmatic controls for processing changes to the Bases of the ITS. This changes the CTS by adding the requirements for the Technical Specification Bases Control Program.
5.0 M.7 Regarding lines of authority, CTS 6.2.1 .a states, "These requirements shall be documented in the 5.2.1 a 6.2.1 a UFSAR." ITS 5.2.1.a states, "These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the UFSARIQA Plan." This changes the CTS by specifying that the plant-specific titles are specified in the QA Plan, as well as the UFSAR.
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Table M - More Restrictive Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Changes ITS Requirement CTS Requirement 5.0 M.8 The second paragraph of ITS 5.6.2 includes detail to be included in the Annual Radiological 5.6.2 6.9.1.8 Environmental Operating Report. CTS 6.9.1.8 does not contain this level of detail. This changes the CTS by requiring additional detail be included in the Annual Radiological Environmental Operating Report.
5.0 M.9 ITS 5.6.6 requires a report be submitted within 14 days after entering Condition B of ITS 3.3.3, PAM 5.6.6 None Instrumentation. ITS 5.6.6 also states, "The report shall outline the cause of the inoperability and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status."
The CTS do not include these requirements. This changes the CTS by requiring a report to be submitted within 14 days after entering Condition B of ITS 3.3.3 and specifying the contents of the report.
5.0 M. 10 CTS 6.9.1.9, "Annual Radiological Effluent Release Report," states, "A single submittal may be made 5.6.3 6.9.1.9 for a multiple unit station. The submittal should combine those sections that are common to all units at the station..." The ITS 5.6.3 Note replaces the word "should" with "shall." This changes the CTS by clarifying that when a single submittal is made for a multiple unit station, sections common to all units are to be combined.
5.0 M. I I CTS 3.11.2.5, Explosive Gas Mixture, limits the concentration of oxygen allowed in the waste gas 5.5.11 3.11.2.5, 3. 11.2.6 decay tanks. CTS 3.11.2.6, Gas Storage Tanks, limits the quantity of radioactivity contained in each gas and 3. 11.1.4 storage tank. CTS 3.11.1.4 limits the quantity of radioactive material contained in each of the specified unprotected outdoor tanks. ITS 5.5.11, Explosive Gas and Storage Tank Radioactivity Monitoring Program, include limits on hydrogen in addition to oxygen in the waste gas decay tanks, and requires the program address requirements specified in ITS 5,5.11. This changes the CTS by requiring a new program and specifying certain requirements the program must meet. Changes moving Actions and Surveillance Requirements to the TRM are addressed by DOC LA.7.
5.0 M. 12 CTS 6.2.4.1 states, "The Shift Technical Advisor shall serve in an advisory capacity to Shift Supervisor 5.2.2.f 6.2.4.1 on matters pertaining to the engineering aspects of assuring safe operation of the unit." ITS 5.2.2.f states, "An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift," This changes the CTS by adding more detail to technical areas for which the STA is to provide support, and states that the STA will meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
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Table M - More Restrictive Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Changes ITS Requirement CTS Requirement 5.0 M. 13 Unit 2 CTS 6.12.1, High Radiation Area, "*," states, "Health Physics personnel or personnel escorted 5.7.2 6.12.1 and 6.12.2 by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas." Unit 2 CTS 6.12.1 applies for control of entry into high radiation areas in which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr. Unit 2 CTS 6.12.2 states that the requirements of 6.12.1 also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrern/hr, but less than 500 rads/hr at one meter from a radiation source or any surface through which radiation penetrates. ITS 5.7.2, whose applicability is the same as Unit 2 CTS 6.12.2, does not include this allowance. This changes the CTS by deleting the exemption from the RWP issuance requirement for entering the high radiation areas addressed by Unit 2 CTS 6.12.2.
CTS 6.9.1.5.a requires, "A tabulation on an annual basis of the number of station, utility, and other 5.6.1 6.9.1.5.a 5.0 M. 14 personnel (including contractors) receiving exposures greater than 100 mreml/yr and their associated man rem exposure according to work and job functions." CTS 6.9.1.5.a also states, "In the aggregate, at least 80 percent of the total whole body dose received friom external sources should be assigned to specific major work functions." ITS 5.6.1 states, "A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors), for whom monitoring was performed, receiving an annual deep dose equivalent > 100 mrems and the associated deep dose equivalent (reported in person-rein) according to work and job functions." ITS 5.6.1 also states, "In the aggregate, at least 80 percent of the total deep dose equivalent received from external sources should be assigned to specific major work functions." This changes the CTS by changing dose and exposure terminology to the more precise deep dose equivalent terms. It also changes the CTS by clarifying that the personnel for whom reporting is done are those for whom monitoring was performed.
North Anna Power Station Page 3 of 6 M - 5.0
Table M - More Restrictive Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Changes ITS Requirement CTS Requirement 5.0 M. 15 CTS 6.2.l.d states, "The management position responsible for training of the operating staff and the 5.2. Ld 6.2.l.d and management position responsible for the quality assurance functions shall have sufficient organizational 6.2. I.e freedom including sufficient independence from cost and schedule when opposed to safety considerations." CTS 6.2. I.e states, "The management position responsible for health physics shall have direct access to that onsitc individual having responsibility for overall facility management. Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures." ITS 5.2. I.d states, "The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures." This changes the CTS by stating that specified individuals, not just a particular manager, have sufficient organizational freedom and sufficient independence from operating pressures to perform their work. Also, rather than having access to particular managers, or the authority to cease work for reasons specified in the Specifications, the individuals have sufficient freedom to perform their work.
5.0 M. 16 CTS 6.12.l.b states that one of the optional criteria that allows entry into a high radiation area is, "A 5.7.l.e and 5.7.2.e 6.12. L.b radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them." ITS 5.7.l.e and ITS 5.7.2.e state, "Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry." This changes the CTS by expanding the requirement to apply to all the options for conditions allowing entry into a high radiation area, and adding the criteria that, "These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas.
This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry." The phrase, "Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals," is addressed by DOC L. 17.
5.0 M. 17 One option allowed by CTS 6.12.2 for personnel to enter a high radiation area with radiation intensity 5.7.2 6.12.2 greater than 1000 mrem, but less than 500 rads/hr at one meter from a radiation source or any surface through which radiation penetrates, is to have, "A radiation monitoring device which continuously indicates the radiation dose rate in the area." ITS 5.7.2 does not include this allowance. This changes the CTS by deleting one of the acceptable means for providing personnel radiation exposure information.
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Table M - More Restrictive Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Changes ITS Requirement CTS Requirement 5.0 M.18 CTS Table 6.2-1 states, "Procedures will be established to insure that NRC policy statement guidelines 5.2.2.d Table 6.2-1 regarding work hours established for employees are followed." ITS 5.2.2.d states, "Administrative procedures shall be developed and implemented to limit working hours of personnel who perform safety related functions (e.g., licensed Senior Reactor Operators (SROs), licensed Reactor Operators (ROs),
health physicists, auxiliary operators, and key maintenance personnel). The controls shall include guidelines on working hours that ensure adequate shift coverage shall be maintained without routine heavy use of overtime. Any deviation from the above guidelines shall be authorized by the plant manager or the plant manager's designee, in accordance with approved administrative procedures, and with documentation of the basis for granting the deviation. Controls shall be included in the procedures to require a periodic independent review be conducted to ensure that excessive hours have not been assigned. Routine deviation from the working hour guidelines is not authorized." This changes the CTS by adding specific requirements for limiting work hours of personnel who perform safety related functions. The change not referencing the NRC policy statement guidelines regarding work hours is discussed in DOC L.24.
As part of one option for equipment required to enter a high radiation area as specified in ITS 5.7. I.d.4 5.7.1 .d.4 and 6.12. L.c 5.0 M. 19 and 5.7.2.d.3, the specifications require, "A self-reading dosimeter (e.g., pocket ionization chamber or 5.7.2.d.3 electronic dosimeter) and," one of two other criteria be met for entering a high radiation area. CTS 6.12.l.c does not include this requirement. This changes the CTS by adding an additional requirement for entering a high radiation area.
ITS 5.5.15.b states, "The containment design pressure is 45 psig." The CTS does not include such a 5.5.15.b None 5.0 M.20 statement. This changes the CTS by adding a design criterion to the Technical Specifications.
5.0 M.21 CTS 4.7.8. I provides ventilation filter testing requirements for the safeguards area ventilation systems 5.5.10 4.7.8.1 (SAVS). Each system is described as having one SAVS exhaust fan and one auxiliary building HEPA filter and charcoal adsorber assembly. ITS 5.5.10 provides ventilation filter testing requirements for the ECCS Pump Room Exhaust Air Cleanup System (PREACS) trains. Each ECCS PREACS train is described as having one safeguards area exhaust fan, one Auxiliary Euilding Central exhaust system fan, and respective filters, controls, and dampers. This changes CTS by adding additional equipment tested as part of the ventilation filter testing requirements, and changing the testing criteria accordingly, to conform to the system as described in NUREG- 1431. I Page 5 of 6 M - 5.0 North Anna Power Station
Table M - More Restrictive Changes ITS Section 5.0 - Administrative Controls DOC No. Description of Changes ITS Requirement CTS Requirement 5.0 M.22 CTS 6.8.4.c, "Secondary Water Chemistry," requires, "A program for monitoring of secondary water 5.5.10 6.8.4.c chemistry to inhibit steam generator tube degradation." ITS 5.5.9, "Secondary Water Chemistry Program," states, "This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking." This changes CTS by adding the fact that the Secondary Water Chemistry Program provides controls for monitoring secondary water chemistry to inhibit low pressure turbine disc stress corrosion cracking in addition to SG tube degradation.
5.0 M.23 Unit I CTS 6.12, High Radiation Area, footnote "*," states, "Health Physics personnel shall be exempt 5.7.1.c and 5.7.2.c 6.12 footnote "*"
from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas." Unit 2 CTS 6.12, High Radiation Area, footnote "*," states, "Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas." ITS 5.7.1.c states, "Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas." ITS 5.7.2.c states, "Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit friom, and work in such areas." This changes the CTS by requiring that for personnel to be exempt from the RWP issuance requirement, they must be qualified in radiation protection procedures, or escorted by a qualified individual in high radiation areas. Changing the term "Health Physics" to "radiation protection" is addressed by DOC L. I I.
5.0 M.24 CTS Table 6.2-1 requires that with both units in MODE5 or 6 or defueled, two Auxiliary Operators 5.2.2.a Table 6.2-1 (AOs) be part of the staff manning, one AO assigned to each unit. ITS 5.2.2.a states, "Two unit siteg with both units shutdown or defueled require a total of three non-licensed operators for the two units."
This changes the CTS by requiring three AOs with both units shutdown or defueled. Other changes to the AO requirements are addressed by DOC L.9.
5.0 M.25 ITS 5.6.5.b contains two analytical methods, WCAP-8745-P-A and WCAP-14483-A, which do not appear 5.6.5.b None in the CTS. This changes the CTS by adding two analytical methods to those referenced in the Technical Specifications.
5.0 M.26 ITS 5.5.10.e requires testing of MCR/ESGR EVS heaters to verify they dissipate the required wattage. The 5.5. 1l0.e None CTS does not contain this requirement. This changes the CTS by adding a Surveillance Requirement.
North Anna Power Station Page 6 of 6 M - 5.0

v t e Letter Sequence Other
TAC:MB0799, Nis Power Range Channel Daily SR TS Change to Address LOW Power Decalibration, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed) TAC:MB0800, Nis Power Range Channel Daily SR TS Change to Address LOW Power Decalibration, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed)
Initiation Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Questions Answers Results Approval Other: ML020650715, ML020840253, ML021220061, ML021220088, ML021550518
MONTHYEAR2002-02-20 [Table View]

ML021220061

Text

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