Text

Amendment Conversion to Improved Technical Specifications (TAC No. MA5049), Attachment 4, Table L - Less Restrictive Changes Matrix
	ML021970071
Person / Time
Site:	FitzPatrick
Issue date:	07/03/2002
From:	Vissing G; NRC/NRR/DLPM/LPD1
To:	Kansler M; Entergy Nuclear Operations
	Vissing G, NRR/DLPM, 415-1441
Shared Package
ML021980178	List: ML021620504; ML021970028; ML021970071; ML021970084; ML021970092; ML021970095; ML021970102; ML021970138; ML021970142;
References
	TAC MA5049
	Download: ML021970071 (151)
	v • d • e

ATTACHMENT 4 Table L - Less Restrictive Changes Matrix

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 1.0 - USE AND APPLICATION nDOG #

SUMMARY

ITS SECTION CTS SECTION CHANGE I

ITVYPF Li CORE ALTERATION S definition The definition of Core Alteration is revised so that the term will only apply to those activities that create the potential for a reactivity excursion and warrant special precautions or controls.

Currently, a Core Alteration is defined as "the act of moving any component in the region above the core support plate, below the upper grid and within the shroud." The normal control rod movement (using the control rod hydraulic system) and the movement of in-core instrumentation are specifically exempted from the definition. The ITS definition for CORE ALTERATIONS will only apply to those activities that affect reactivity within the reactor vessel with the head removed and fuel in the vessel. Specifically, under the revised definition, in vessel movement of instruments, cameras, lights, tools, etc., will not be classified as CORE ALTERATIONS. It should also be noted that control rod movement is not considered a CORE ALTERATION provided there are no fuel assemblies in the associated core cell. In addition, the proposed definition has also been modified by providing an allowance that the suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe osition.

The specific contact numbers in the definitions of Primary Containment Isolation Actuation Instrumentation Response Time and Reactor Protection System Response Time are deleted.

The CTS definition of Instrument Channel Functional Test requires the injection of a simulated signal into the instrument. The words "or actual" in reference to the injected signal, have been included in the ITS definition of CHANNEL FUNCTIONAL TEST. Some CHANNEL FUNCTIONAL TESTS can be performed by insertion of the actual signal into the logic (e.g.,

rod block interlocks). For others, there is no reason why an actual signal would preclude satisfactory performance of the test. Use of an actual signal instead of the existing requirement, which limits use to a simulated signal, will not affect the performance of the channel. OPERABILITY can be adequately demonstrated in either case since the channel itself cannot discriminate between "actual" or "simulated".

CHANNEL FUNCTIONA L TEST definition The CTS definition of Instrument Channel Functional Test requires, the injection of a CHAr simulated signal "into the instrument primary sensor where possible." This requirement has FUN(

been changed in the ITS definition of CHANNEL FUNCTIONAL TEST to allow the signal to be L TE injected "as close to the sensor as practicable."

defin The CTS definition of Cold Shutdown requires the reactor vessel to be vented. The ITS definition of MODE 4 does not include this requirement.

JAFNPP NNEL CTIONA ST 1.O.B 1.0.F.6, 1.0.F.10 1.0.F.5 1.0.F.5 I TIr-3 3

3 qition e 1.1-1 1.0.1.3.b 2

PAGE 1 N/A L2 L3 L4 L5 Tabh I

Uu%-ý ft,

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 1.0 - USE AND APPLICATION CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 2

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 2.0 - SAFETY LIMITS

_______________-----7_

DOC #

SUMMARY

Li The power transient safety limit has been deleted since failure to meet this safety limit does not necessarily indicate that an actual safety limit has been exceeded.

IT SECT IO CISSE I

LIjkiUN:

N/A 1.1.C The reactor vessel water level safety limit is being reduced by 12 inches.

2.1.1.3 1.1.D 1

The time to report a safety limit violation to the NRC has been extended from immediately to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , in accordance with 10 CFR 50.72. In addition, since the requirement is covered by 10 CFR 50.72, it is not included in the ITS.

The Safety Limit Applicability at low power or low flow is changed from reactor pressure < 785 psig or core flow < 10% of rated to reactor pressure < 785 psig or core flow < 10% of rated.

The Applicability for the MCPR Safety Limit is relaxed from reactor pressure > 785 psig and core flow> 10% of rated to reactor pressure > 785 psig and core flow > 10% of rated.

2.1.1.1, 2.1.1.2 L5 The Shutdown Cooling Safety Limit is being deleted since it is covered by the Shutdown 3.3.6.1 Cooling System Isolation Reactor Pressure - High instrumentation Allowable Value.

Function 6.a CHANGEUI TYPE 2

1. 2.2 1

CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP 19 Le -

I L3 L4 PAGE 1 I.

I ICTS SECT IONI I

SITS SECTIONI 6,9 N/A 6.7.(B) 1.1.A, 1.1.B

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.0 - LCO AND SR APPLICABILITY DOC #

SUMMARY

ITS CTS SECTION CHANGE SECTION TYPE Li The CTS requires the unit to be placed in COLD SHUTDOWN (MODE 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if LCO 3.0.3 3.0.C 6

the LCO or action requirements cannot be satisfied because of circumstances in excess of those addressed in the Specification. The ITS allows 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to be in MODE 4.

L2 The CTS has had the following sentence added, "If a Completion Time requires periodic SR 3.0.2 4.0.B16 performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance." The ITS includes this statement to provide the consistency in scheduling flexibility for all performances of periodic requirements, whether they are Surveillances or Required Actions. The intent remains to perform the activity, on the average, once during each specified interval.

L3 When it is determined that a Surveillance was not performed, the CTS allows ACTION SR 3.0.3 4.0.C 3

requirements to be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit completion of the Surveillance if the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS continues to allow a delay, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Surveillance Frequency, whichever is greater. This change allows the delay to apply to any Surveillance, instead of just those specifications with ACTION requirements of less than_24_hours.

L4 The CTS allows ACTION requirements to be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit completion SR 3.0.3 4.0.C 3

of the Surveillance if the allowable outage times of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS allows an increase in the delay time of up to the limit of the specified Surveillance Frequency. However, a delay of greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is only allowed provided a risk evaluation is performed and the risk impact of delaying the Surveillance is managed.

CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.0 - LCO AND SR APPLICABILITY

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 2

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.1.1, SHUTDOWN MARGIN NONE NONE NONE NONE NONE 3.1.2, REACTIVITY ANOMALIES Li The CTS does not provide an explicit restoration time when Reactivity Anomalies is not met. The ITS provides a 3.1.2 ACTION 3.3.D 6

Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for the core reactivity difference to be restored to within limits (normally required to A

perform an analysis to determine the reason for the reactivity difference).

12 The CTS requirement to be in a cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the reactivity anomaly requirement is not met is N/A 3.3.E 5

being deleted, since the CTS Applicability for this Specification is only power operation (and CTS 3.0.A only requires theACTIONS to be met during theLCOsApplicability).

L3 The CTS requires the shutdown margin to be verified within limits every full power month (approximately 708 SR 3.1.2.1 4.3.D13 MWD/T). In the ITS, the Frequency has been changed to every "1000 MWD/T during operations in MODE 1" after the first performance (the first performance requirement is described in DOC M3).

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OPI AflII ITV Currently in the CTS, a stuck control rod (not fully inserted) that may be stuck as a result of a collet housing failure or for some other reason requires that the reactor be in a cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . No allowance is provided for repair prior to entering the shutdown statement. The ITS allows continued operation with a stuck control rod and the requirement to be in Cold Shutdown has been deleted. With a single withdrawn control rod stuck, the remaining Operable control rods are capable of providing the required scram and shutdown reactivity.

In addition, to ensure that local scram reactivity assumptions are maintained in this condition, stuck control rod separation criteria must be verified immediately and the stuck control rod must be disarmed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to prevent damaqing the control rod drive.

The existing CTS surveillance requires that all partially or fully withdrawn control rods be exercised at least once per week. The ITS Surveillances will differentiate between fully and partially withdrawn rods. Fully withdrawn rods will still be exercised once per 7 days. However, partially withdrawn rods will be exercised once per 31 days.

PAGE 1 JAFNPP L1 I+ I L2 1 -,.

3.1.3, UUN I HUL hUU urtMMDILI I T I

TABLE L -LESS RESTRICTIVE CHANGES MATRIX SECTION 3.1 -REACTIVITY CONTROL SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L3 Currently in the CTS, if three or more control rods are inoperable but not stuck, all operable control rods must be 3.1.3 Required 4.3.A.2.a 3

exercised once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS requirement for control rods that are inoperable but not stuck is to fully Actions C.1 and insert and disarm the inoperable rod(s). There will be no requirement to exercise the operable rods to verify their C.2 operability other than the normal surveillance requirements.

L4 Currently in the CTS, if one or more control rods are stuck, all operable control rods must be exercised "at least 3.1.3 Required 4.3.A.2.a 3

every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." In the ITS, after discovery of a stuck rod, all withdrawn control rods are required to be exercised Action A.3 only once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when Thermal Power is greater than the low power setpoint of the RWM.

L5 The CTS requirement for the CRD housing support to be in place has been deleted since it is included in the LCO 3.1.3 314.3.B.2 1

Operability requirements for control rods in the ITS.

L6 CTS 3.3.A.2.a requires the plant to be brought to Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the requirements for 3.1.3 3.3.A.2.a 2, 5 "Inoperable Control Rods" cannot be met. This implies the Applicability of CTS 3.3.A.2.a to be Modes 1, 2 and 3.

Applicability, The Applicability in ITS 3.1.3 is Modes 1 and 2 and the default condition has been changed to Mode 3 as reflected 3.1.3 Required in ITS 3.1.3 Required Actions B.1 and E.1.

Actions B.1 and E.1 3.1.4, CONTROL ROD SCRAM TIMES Li The CTS requires that 10% of the operable control rods be scram time tested at "16 week intervals." This 16 SR 3.1.4.2 4.3.C.2 3

week interval equates to 112 days. The ITS Frequency for scram time testing a representative sample of control rods is "120 days cumulative operation in MODE 1." Thus, during plant operation the frequency is being extended for 8 days.

L2 The CTS requires an evaluation to be made, whenever scram time surveillances are performed, to provide N/A 4.3.C.2 3

reasonable assurance that proper control rod drive performance is being maintained. This requirement is essentially a performance tracking requirement to help ensure control rod scram times are maintained within limits and is deleted.

L3 The CTS requirement to be in a cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the Scram Insertion Times are not met is N/A 3.3.E 5

being deleted. A new requirement to be in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months has been added, as described in DOC M5. This actionnwill place*the plant outside theApplicability of CTS_3.3.C.1_(reactor power operation).

PAGE 2 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.1 -REACTIVITY CONTROL SYSTEMS

SUMMARY

The CTS requirement to perform scram time testing at saturation temperatures has been deleted. This change will allow scram time testing to be performed during reactor hydrostatic pressure testing when the reactor vessel is not at saturated conditions.

qq crnlNTRLcI frOD.SCRAM ACCIIMUII ATORS

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.,i Li The CTS requires control rods with inoperable accumulators be considered inoperable immediately. The ITS 3.1.5 ACTIONS 3.3.A.2.d 4

allows a short out of service time (up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , depending upon the number of inoperable accumulators and the A, B, C, and D reactor pressure) for the accumulators prior to declaring the associated control rods inoperable. In addition, the option to declare a control rod with an inoperable accumulator "slow" when reactor pressure is sufficient is also added. The option for declaring the control rod with an inoperable accumulator "slow" is restricted to control rods not previously known to be slow.

L2 The CTS requires a check of the status of the pressure and level alarms for each control rod scram accumulator N/A 4.3.A.2.c 3

once per week. This requirement has been deleted. The ITS does include a requirement to verify accumulator pressure is within limits as described in DOC M1.

3.1.6, RODPATTERN CONTROL Li The CTS requires all rod movement to be stopped except by scram if control rod patterns and sequence of 3.1.6 ACTIONS 3.3.B.3.f 4

withdrawal or insertion limits are not established such that the control rod drop accident limit of 280 cal/g is not A and B exceeded. The ITS requires associated control rod(s) to be moved to the correct position or declared inoperable within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if one or more control rods is not in compliance with BPWS. However, the number of OPERABLE control rods not in compliance with the prescribed sequence is limited to 8, to prevent the operator from attempting to correct a control rod pattern that significantly deviates from the prescribed sequence. In addition, any of the 8 control rods that cannot be restored to its correct position within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months must then be declared inoperable and fully inserted within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

3.1.7, STANDBY LIQUID CONTROL SYSTEM PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li CTS requires that the Standby Liquid Control System be Operable during a period when fuel is in the reactor and 3.1.7 3.4.A 2

prior to startup from cold condition. The current Applicability corresponds to MODES 1,2 and can also imply Applicability MODES 3, 4 and 5 with any control rod withdrawn. This system need not be Operable when the reactor is in the cold condition, control rods are fully inserted and CTS 3.3.A (Reactivity Limitations) is met. Therefore, the ITS Applicability is only MODES 1 and 2.

L2 The CTS includes an action to restore certain components (e.g., tank heaters) or variables (e.g., sodium 3.1.7 ACTION 3.4.C 5

pentaborate volume-concentration and temperature requirements) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or take action to be in hot B

shutdown in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . All the components or variables discussed in this CTS action will cause both subsystems of the SLC System to be inoperable. However, the list is not all inclusive of the possible events which could lead to both subsystems being inoperable. The ITS adds an ACTION to allow the entire SLC System (e.g.,

both pumps) to be inoperable for any reason up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to requiring a plant shutdown. The 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provides time to restore minor problems_(e.g.,_some pump inoperabilities)_prior to requiring a plant shutdown.

L3 The CTS requires that when a SLC subsystem or component becomes inoperable, the redundant subsystem or N/A 4.4.B14 component be verified to be OPERABLE immediately and daily thereafter. The ITS does not have this cross system check. This change will allow credit to be taken for normal periodic Surveillances as a verification of OPERABILITY and availability of the remaining SLC subsystem.

L4 The CTS requires that each SLC subsystem "valve (manual, power operated, or automatic) in the system flowpath SR 3.1.7.6 4.4.A.1 3

that is not locked, sealed or otherwise secured in position, is in the correct position" once per 31 days. The ITS requires that "each SLC subsystem manual valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position, or can be aligned to the correct position" every 31 days. The proposed change permits the SLC subsystem to be considered OPERABLE as long as the valves can be manually realigned to their correcttposition.

PAGE 4 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS PAGE 5 JAFNPP DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L5 The CTS requires that every 24 months demineralized water be injected into the reactor vessel to test that valves SR 3.1.7.8 4.4.A.4, 3

(except explosive valves) not checked by the recirculation test are not clogged. This test involves testing entire 4.4.A.5 subsystems; including portions common to both subsystems as well as non-common portions. As such, testing either subsystem can satisfy the necessary testing for the common portions of both subsystems. To accomplish this, the ITS requires the verification of flow through one SLC subsystem from the pump into the reactor pressure vessel every 24 months on a STAGGERED TEST BASIS (i.e., such that the subsystems used for the test are alternated each 24 months). Since the CTS could be inferred to require testing both subsystems each 24 months, this change is a relaxation in the frequency of testing an individual subsystem (i.e., on the Staggered Test Basis).

In addition, the CTS requries replacing both primer assemblies every 24 months. The ITS will only require replacing one primer assembly every 24 months; the one that has been fired during performance of the flow test.

Over the course of two surveillance intervals_(48_months),_both primer assemblies will be required to be replaced.

3.1.8, SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVES Li CTS 4.3.A.2.b, CTS 4.3.A.2.e and CTS 4.3.C.3 include requirements for SDV vent and drain valves. These 3.1.8 3.3.A.2.e.2, requirements are currently associated with control rod operability. The default action for CTS 4.3.A.2.b and Applicability 3.3.E, 4.3.A.2.b, 4.3.A.2.e is to be in Hot Shutdown (Mode 3) in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (CTS 3.3.A.2.e.2), while the default action for CTS and ACTION C 4.3.A.2.e, 4.3.C.3 4.3.C.3 is to be in a cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (CTS 3.3.E). These default actions are not consistent. In the ITS, all the requirements for SDV vent and drain valves are included in one Specification for consistency. In the ITS, the SDV vent and drain valves are only required to be Operable in MODES 1 and 2. In MODES 1 and 2, a scram may be required; therefore the SDV vent and drain valves must be Operable. In MODES 3 and 4, control

_rodsare not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied.

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L2 The CTS contains Surveillance Requirements for SDV vent and drain valves but the CTS do not provide specific 3.1.8 ACTIONS 4.3.A.2.b, 5

actions if SDV vent and drain valves are inoperable (other than to shut the plant down). The primary safety A, B, and C, 4.3.A.2.e, 4.3.C.3 function of the SDV vent and drain valves is to isolate the SDV during a scram to contain the reactor coolant 3.1.8 ACTIONS leakage past the CRD seals. This isolation function can be satisfied with only one valve OPERABLE in each line Notes 1 and 2 or the line is isolated. Therefore, the ITS provides actions to: a) Allow 7 days to isolate an inoperable SDV vent or drain valve provided at least one valve in each line is Operable; b) Establish an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit when both valves in a line are inoperable and, allowing the option of isolating the line during this time; c) Require the plant to be placed in MODE 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if any Required Action and associated Completion Time is not met (see DOC L1); d)

Recognize that the SDV vent and drain valves are normally open to prevent accumulation of water in the SDV from leakage. Therefore, a Note is added to the ITS ACTIONS, allowing periodic opening of the affected line for draining and venting of the SDV; and e) Provide a Note at the start of the ACTIONS Table (Separate Condition entry is allowed for each SDV vent and drain line) to provide more explicit instructions for proper application of the Actions for ITS 1.3, "Completion Times." Each SDV line is tested independently and allowed a specified period of time to confirm it isolated or capable of isolation, or restore the complete function of the line.

CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement PAGE 6 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.2 - POWER DISTRIBUTION LIMITS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE NONE NONE NONE NONE NONE 3.2.2, MINIMUM CRITICAL POWER RATIO Li The CTS requires that MCPR be determined following any change in power level or N/A 4.1.C 3

distribution that would cause operation with a limiting control rod pattern as described in the Bases for Specification 3.3.B.5. The proposed change deletes this Surveillance Frequency, but retains the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Surveillance Frequency for determining the MCPR value. Since operation with a limiting control rod pattern is, in this case, operating on the operating limit MCPR, the condition is extremelyunlikel and the Surveillance would seldom be required.

3.2.3, LINEAR HEAT GENERATION RATE NONE NONE NONE NONE NONE 3.2.4, APRM GAIN AND SETPOINT Li CTS 4.1.B includes a daily surveillance requirement to determine MFLPD whenever reactor LCO 3.2.4, 4.1.B, 3.0.C 5

power is > 25% RTP and to make any necessary adjustments to APRM high flux scram trip ACTIONS A settings. When the surveillance is not met CTS 3.0.C must be entered and the plant must be and B in COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months since there is no specific LCO or action for not meeting CTS 4.1.B. ITS LCO 3.2.4 and ACTIONS A and B have been added to the current requirements in CTS 4.1.B. The requirements of ITS LCO 3.2.4 are consistent with the requirements in CTS 4.1.B (except as modified by DOCs A3, M1 and R1). ACTION A will allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to satisfy the requirements of LCO 3.2.4. If this Required Action and associated Completion Time can not be met, ACTION B will require a reduction in power to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.2 - POWER DISTRIBUTION LIMITS CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 2

TABLE L-LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.3.1.1, RPS INSTRUMENTATION Li The CTS Applicability of Mode 5 (i.e., reactor is subcritical, fuel is in the vessel and the reactor temperature is less Table 3.3.1.1-1 Table 3.1-1 Trip 2

than 212 OF) for the Mode Switch in Shutdown, Manual Scram, and IRM High Flux Trip Functions and the CTS for Functions Functions 1, 2, 3, Applicability of Mode 5 for the IRM Inoperative Function, is being relaxed. In the ITS, the above Functions are 1.a, 1.b, 10, and 4, including only required to be Operable in Mode 5 with any control rod withdrawn from a core cell containing one or more fuel and 11 Note 7 assemblies.

L2 The CTS provides 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to reach Mode 3 (all rods inserted). In the ITS, the time to reach Mode 3 is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

3.3.1.1 Table 3.1-1 Note 6

Required 3.A Action G.1 L3 The CTS (for Mode Switch in Shutdown, Manual Scram, IRM High Flux, IRM Inoperative, and High Water Level in 3.3.1.1 Table 3.1-1 Note 4

Scram Discharge Volume Functions) requires the insertion of all operable control rods if the channels are not Required 3.A restored or tripped within the allowed completion times. In the ITS, when in MODE 5, only control rods in core Action H.1 cells containing one or more fuel assemblies are required to be inserted.

L4 The CTS requires the APRM Neutron Flux - Startup and APRM Inoperative Functions to be Operable in MODE5.

N/A Table 3.1-1 Trip 2

The ITS does not require these Functions during Mode 5 operations.

Functions 5 and 8, including Note 7, 2.1.A.1.b L5 The CTS requirement associated with the Main Steam Isolation Valve Closure Function to insert all Operable 3.3.1.1 Table 3.1-1 Note 4

control rods (be in MODE 3) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is being relaxed. The ITS will require the plant to be in MODE 2 within Required 3.A 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when the Main Steam Isolation Valve Closure Function is inoperable and not restored, or channels Action F.1 tripped, within the required Completion Times, consistent with the Applicability.

L6 The design details that identify the reliability group (A, B or C) to which each instrument belongs for functional N/A Table 4.1-1 3

testing has not been included in the ITS.

(including Note 6),

Table 4.1-2 (including Note 1)

L7 The details that identify those portions of the instrument channel which require functional testing and the details N/A Table 4.1-1 3

that identify the type of test equipment used to perform a channel calibration have been deleted.

L8 The details concerning testing the automatic scram contactors after maintenance is not included in the ITS since it SR 3.0.1 Table 4.1-1 Note 3

is adequately covered by SR 3.0.1.

1_1 1

11 PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L9 Not used.

N/A N/A N/A L10 The ITS includes a Note to allow entry into Mode 2 from Mode 1 for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to requiring the Channel SR 3.3.1.1.3 N/A 3

Functional Test to be performed on the IRM High Flux, IRM Inop, and APRM Neutron Flux - High (Startup)

Note Functions.

L11 The details relating to the Instrument I.D. numbers for the RPS Instrumentation are not included in the ITS.

N/A 4.1.A 3

L12 The ITS includes a Note that states the APRM heat balance calibration Surveillance is not required to be SR 3.3.1.1.2 N/A 3

performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after Thermal Power Ž 25% RTP.

Note L13 The CTS Frequency for performing the APRM heat balance calibration is being changed from once per day in the SR 3.3.1.1.2 Table 4.1-2 3

CTS to once per 7 days in the ITS.

Calibration requirement for Instrument Channel 2 L14 The Trip Settings/Trip Level Settings (changed to Allowable Value in DOC A19) are being changed a) for the Table 3.3.1.1-1 2.1.A.3, 2.1.A.4, 1

Turbine Stop Valve Closure Function from < 10% valve closure in the CTS to < 15% valve closure in the ITS; and Allowable Table 3.1-1 Trip b) for the Turbine Control Valve Fast Closure Function from > 500 psig and < 850 psig in the CTS to_> 500 psig Values for Level Setting for and < 850 psig in the ITS.

Functions 8 Trip Functions 14 and 9 and15 3.3.1.2, SRM INSTRUMENTATION Li The CTS does not provide any actions if the required SRMs are inoperable in Mode 2; thus a shutdown to cold 3.3.1.2 N/A 5

shutdown is required. In the ITS, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months will be allowed to restore the 3 required SRM channels to Operable prior ACTIONS A to requiring a shutdown. Also, when there are no Operable SRMs, the ITS will further require suspension of all and B control rod withdrawal (and continue to allow the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the inoperable SRMs).

L2 The CTS requires two SRMs to be Operable; one in the core quadrant where fuel or control rods are being moved Table 3.3.1.2-1 3.10.B1 and one in an adjacent quadrant. If a spiral offload or spiral reload is being performed, the ITS will allow only 1 footnote (b), SR SRM to be Operable, provided that the fueled region includes only that SRM detector. An appropriate SR has 3.3.1.2.2.a, SR been added to ensure this condition, and a Note included to allow one SRM to satisfy multiple location 3.3.1.2.2 Note requirements.

2 PAGE 2 JAFNPP

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SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L3 The CTS requires SRM operability to be verified during spiral reload by using a portable external source every 12 SR 3.3.1.2.4 3.10.B.4 3

hours until the required amount of fuel is loaded to maintain 3 cps. An alternative is provided to load a maximum Note of four fuel assemblies in different cells containing control blades around each SRM to obtain the required 3 cps.

The ITS includes a Note that relaxes the 3 cps requirement with less than or equal to four fuel assemblies adjacent to theSRM and no other fuel assemblies in the associated core quadrant.

L4 With the SRM requirements not met, the CTS requires a shutdown to cold shutdown (Mode 4). In the ITS, a 3.3.1.2 LCO 3.0.C 5

shutdown only to Mode 3 is required.

Required Action C.1 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION Li The requirements when one RBM channel is inoperable concerning verifying operations are not on a limiting N/A Table 3.2-3 Note 5

control rod pattern or if not, then ensuring control rod withdrawal is blocked, when one RBM channel is inoperable 2 Action B.a),

have been deleted.

3.3.8.5 L2 The CTS requirement to perform an instrument check on the RBM - Upscale and - Downscale Functions has been N/A Table 4.2-3 3

deleted.

Instrument Check requirements for Instrument Channels 6 and 7 L3 The CTS requires a demonstration of the rod block function of the RWM (i.e., a Channel Functional Test) be SR 3.3.2.1.2 4.3.B.3.a.(4) 3 performed during a startup prior to the start of control rod withdrawal. In the ITS, the Frequency for the RWM Channel Functional Test is specified as 92 days. Thus if two startups are performed within 92 days of each other, a test prior to the second startup will not be required. In addition, a Note to the ITS Surveillance allows the test to be performed up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after withdrawal of the first control rod.

L4 The Frequency to verify the correctness of the RWM program sequence during startup prior to the start of control SR 3.3.2.1.8 4.3.B.3.a, 3

rod withdrawal and during shutdown prior to attaining 10% rated power during rod insertion has been changed in 4.3.B.3.b the ITS to require the verification only prior to declaring RWM OPERABLE following loading of the Sequence into RWM.

I

_II L5 The ITS includes a Note that excludes the neutron detectors from the RBM - Upscale and - Downscale Functions SR 3.3.2.1.5 N/A 3

Channel Calibration Surveillance.

NoteII PAGE 3 JAFNPP

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SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L6 The CTS requires the performance of a functional test on the RBM channels when a limiting control rod pattern N/A 4.3.B.5 3

exists prior to the withdrawal of the designated rod(s)._ThisSurveillance has been deleted.

L7 The ITS includes a Note that modifies the RBM Applicability requirements, such that the RBM channels are not Table 3.3.2.1-1 N/A 2

required to be Operable when a peripheral control rod is selected (since the RBM is automatically bypassed in this footnote (a) condition).

L8 The requirement to prepare and submit a report to the NRC within 30 days of a plant startup with the RWM N/A 3.3.B.3.d 9

inoperable has been deleted.

3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION Li The explicit requirement to perform an Instrument Functional Test once every 24 months during each refueling N/A Table 4.2-6 Note 3

outage has been deleted since a Channel Calibration is required on a 24 month Frequency and a 92 day Channel 1.a Functional Test is already required.

L2 The CTS requires a reduction in Thermal Power if the inoperable channels are not restored/tripped within the 3.3.2.2 N/A 5

allowed times. In the ITS an additional option is provided if the inoperable channel(s) are the result of inoperable Required feedwater pump turbine or main turbine stop valve. If this is the case, then the ITS will allow removal of the Action C.i affected stop valve(s) from service in lieu of reducing power.

(including Note) 3.3.3.1, PAM INSTRUMENTATION Li The details relating to the Instrument I.D. numbers for the PAM Instrumentation are not included in the ITS.

N/A Table 3.2-8 1

L2 The CTS requires the Containment High Range Radiation Monitors to be Operable in Run, Startup/Hot Standby, 3.3.3.1 Table 3.2-8 Note 2

and Hot Shutdown (Modes 1, 2, and 3). In the ITS, the Mode 3 requirement is not maintained; the monitors are Applicability H

only required in MODES 1 and 2.

L3 The CTS precludes Mode changes if a PAM instrument is inoperable. The ITS includes a Note that allows Mode 3.3.3.1 N/A 7

changes with a PAM instrument inoperable (i.e., LCO 3.0.4 is not applicable).

ACTIONS Note 1

JAFNPP PAGE 4

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SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L4 The CTS requires the plant to be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the one required containment high range 3.3.3.1 Table 3.2-8 Note 5

radiation monitor has not been restored to operable status within 30 days. In the ITS, when both required Required A

containment high range monitors are inoperable and not restored within the allowed time, in lieu of a plant Action F.1 shutdown,_a special report is required to be submitted to theNRC.

L5 Not used.

N/A N/A N/A L6 The CTS Channel Check Frequency is being changed from daily in the CTS to every 31 days in the ITS.

SR 3.3.3.1.1 Table 4.2-8 3

Instrument Check requirement L7 A Note has been added to allow a channel to be Inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months solely for performance of required Surveillance N/A 6

Surveillances provided the other channel in the associated Function is OPERABLE.

Requirements Note 3.3.3.2, REMOTE SHUTDOWNSYSTEM Li A Note has been added to allow a channel to be inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months solely for performance of required Surveillance N/A 6

Surveillances.

Requirements Note 12 The CTS requirement to perform a Functional Test on each required remote shutdown system control circuit is SR 3.3.3.2.2 Table 3.2-10 3

proposed to be changed to verify each required Remote Shutdown System transfer switch and control switch (including Functional Test performs the intended function. This change includes changing the manner of performance of this SR from Bases requirement operating each actuated component from the associated control panel (e.g., Remote Shutdown Panel) to allowing description) performance of a continuity check to confirmOperability_(as specified in theBases).

3.3.4.1. ATWS-RPT INSTRUMENTATION Li JAFNPP The CTS allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to place an inoperable instrument channel in trip if one channel is inoperable for one or more Trip Functions. The ITS will allow 14 days to restore the channel to operable status or to place the associated channel in trip.

PAGE 5

TABLE L -LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L2 3.3.4.1 Table 3.2-7 Note 4

ACTIONS A, B, 1.b and C When two or more channels are inoperable for one or more Functions, the CTS requires that the instrument channel(s) in one trip system and/or that trip system be in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and requires the remaining channel in the other trip system to be restored to Operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In addition, the CTS will allow only one hour to restore trip capability for each Function. In the ITS, if two channels are inoperable for the same Function and trip capability is maintained, 14 days is allowed to restore or trip the channel. In addition, if only one Trip Function's capability is lost, the ITS will allow the restoration of ATWS-RPT trip capability in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . When both Trip Function's capability is lost, the ITS provides 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore ATWS-RPT trip capability for one Trip Function, consistent with the CTS.

The CTS requires the plant be placed in the startup/hot standby mode (Mode 2) if the inoperable channels are not restored/tripped within the allowed times. In the ITS, an additional option is provided if the inoperable channel(s) are the result of an inoperable RPT breaker. If this is the case, then the ITS will allow removal of the affected recirculation umpfrom service in lieu of beingin Mode 2.

3.3.5.1, ECCS INSTRUMENTATION Not used.

The CTS requires restoration of an inoperable CS or LPCI Reactor Pressure-Low (Injection Permissive) channel; placing the channel in the tripped condition is not allowed. In the ITS, the inoperable channels are allowed to be placed in the tripped condition durinn MODE 4 or 5 operations.

The CTS Reactor Pressure-- Low (Recirculation Discharge Valve Permissive) Function is currently required to be Operable whenever the associated Low Pressure Coolant Injection (LPCI) System is required to be Operable (Modes 1, 2, 3, 4, and 5). In the ITS, the Function is only required to be Operable in MODE 1, 2 and 3 when the aso cia,*te, discharg e v alv e, i.s nen.

The CTS require action to be taken in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months upon discovery of loss of initiation capability for the LPCI and CS Systems. In the ITS, these same actions are only required to be taken during MODES 1, 2 and 3.

N/A 3.3.5.1 ACTION B Table 3.3.5.1 -1 Function 2.d, including footnote (c) 3.3.5.1 Required Action B.1 Notes 1 and 2, 3.3.5.1 Required Action C.1 Notes 1 and 2 N/A N/A Table 3.2-2 Note 6

3.2.B, Table 3.2-2 Item No. 24 Table 3.2-2 Notes 2.A and 6.A N/A 4

2 PAGE 6 JAFNPP 3.3.4.1 Required Action D.1 (including Note)4 L3 Li L2 L3 I

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Not used.

N/A N/A N/A The Trip Level Settings (changed to Allowable Value in DOC A12) are being changed a) for the Containment High Table 3.3.5.1-1 Table 3.2-2 Trip 1

Pressure Function from > 1 psig and < 2.7 psig in the CTS to > 1 psig to < 2.7 psig in the ITS; b) for the Reactor Allowable Level Setting for Low Pressure (injection permissive) Function from > 450 psig in the CTS to > 410 psig and < 490 psig in the ITS; Values for Item Nos. 6, 9, and c) for the Reactor Low Pressure (recirculation discharge valve permissive) Function from 285 psig to 335 psig Functions 1.c, and 24 in the CTS to > 295 psig in the ITS.

2.c, 2.d, and 2.h The Trip Level Settings (changed to Allowable Value in DOC A12) are being changed a) for the Core Spray Pump Table 3.3.5.1-1 Table 3.2-2 Trip Start Time Function from 11 + 1.34 seconds in the CTS to < 12.34 seconds in the ITS; and b) for the RHR Pump Allowable Level Settings for Start Timers Function from 1.25 + 0.26 seconds for the first pump in loops A and B and 6.0 + 0.73 seconds for the Values for Item Nos. 11 and second pump in loops A and B in the CTS to < 1.51 seconds for the A and D pumps and < 6.73 seconds for the B Functions 1.d 12 and C pumps in the ITS.

and 2.f 3.3.5.2, RCIC SYSTEM INSTRUMENTATION NN NOENONE NONE NONE 3.3.6.1, PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION Li The CTS Safety Limit and actions when operating the RHR System in the Shutdown Cooling Mode are Table 3.3.6.1-1 1.2.2, 2.2.2 1,2 incorporated into the SDC Reactor Pressure-High Isolation Function. As such the ITS Applicability for the Function 6.a, Function is only MODES 1, 2, and 3, and the actions if the channels are inoperable and not tripped within allowed 3.3.6.1 time is to isolate the affected penetration.

ACTION F L2 The details relating to the Instrument I.D. numbers for the primary containment isolation instrumentation are not N/A 4.2.A, Table 3.2-8 included in the ITS.

Instrument 4 L3 The CTS Applicability for the SDC Reactor Low Water Level Function is MODES 1, 2, and 3 (when primary Table 3.3.6.1-1 Table 3.2-2 Trip 1,2 containment is required). The ITS does not include the Modes 1 and 2 Applicability for this Function. In addition, Function 6.b Functions 1 and 5 the CTS requirement that the Drywell Pressure High Function be Operable in Modes 1, 2, and 3 for the SDC isolation is also not included in the ITS.

PAGE 7 JAFNPP I

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L4 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable RWCU reactor water level low 3.3.6.1 Table 3.2-1 Note 5

or drywell pressure high channels are not tripped within the allowed times. In the ITS, in lieu of a shutdown when ACTION F 3.A the channels are not tripped, the affected penetration flow path s) must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L5 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable SDC reactor water level low 3.3.6.1 Table 3.2-1 Note 5

channels are not tripped within the allowed times. In the ITS, in lieu of a shutdown when the channels are not ACTION J 3.A tripped, immediate action must be initiated to restore the channels to Operable status or to isolate the RHR SDC System.

L6 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable recirculation loop sample and 3.3.6.1 Table 3.2-1 Note recirculation pump seal purge penetrations reactor water level low channels are not tripped within the allowed ACTION F 3.A times. In the ITS, in lieu of a shutdown when the channels are not tripped, the affected penetration flow path(s) must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L7 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable Main Steam Lines and drains 3.3.6.1 Table 3.2-1 Note 5

reactor water level low channels are not tripped within the allowed times. In the ITS, in lieu of a shutdown when Required 3.A the channels are not tripped, an optional action is provided to allow the affected main steam line to be isolated Action D.1 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

L8 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable hydrogen and oxygen sample 3.3.6.1 Table 3.2-1 Note 5

lines and gaseous/particulate sample supply and return lines reactor water level low or drywell pressure high ACTION F 3.A channels are not tripped within the allowed times. In the ITS, in lieu of a shutdown when the channels are not tripped, the affected penetration flow path s) must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L9 The CTS requires the isolation of the affected main steam lines within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when the inoperable main steam 3.3.6.1 Table 3.2-1 Notes 5

line high flow and condenser vacuum low channels are not tripped within the allowed times. In the ITS, in lieu of Required 33B and 3.G isolating the affected lines within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , an optional action is provided to place the plant in Mode 3 within 12 Actions D.2.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and Mode 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

and D.2.2 L10 When more than one channel associated with a trip function is inoperable, the CTS requires action to be taken N/A Table 3.2-1 Note 4, 6 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the channel(s) in trip in one trip system or to take the required actions specified in the Table 1.b.2) and for the associated Function. These actions must be taken even if primary containment isolation capability is footnote **

maintained. The ITS will not include this requirement; 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months will be allowed (depending upon whether or not the channel is common to RPS) to trip an inoperable channel provided isolation capability is maintained. If it is not, then the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action in the CT S and ITS will appIv.

PAGE 8 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L11 The CTS provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reach cold shutdown (Mode 4). In the ITS, the time to reach Mode 4 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

3.3.6.1 Table 3.2-1 Note 6

Required 3.A Actions D.2.2 and H.2 L12 The CTS provides 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to close the MSIVs. In the ITS, the time to close the MSIVs is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

3.3.6.1 Table 3.2-1 Notes 6

Required 3.B and 3.G Action D.i L13 Not used.

N/A N/A N/A L14 The details that identify those portions of the instrument channel which require functional testing and the details N/A Tables 4.1-1 and 3

that identify the type of test equipment used to perform a channel calibration have been deleted.

4.1-2 L15 Not used.

N/A N/A N/A L16 The Trip Level Settings (changed to Allowable Value in DOC Ai6) for the HPCI Turbine Steam Line High Flow Table 3.3.6.1-1 Table 3.2-1 Trip 1

Function is changed from < 160 inches of water dP in the CTS to < 168.24 inches of water dP in the ITS.

Allowable Level Setting for Value for Trip Function 13 Function 3.a L17 The Trip Level Settings (changed to Allowable Value in DOC A16) for the Main Steam Line High Flow Function is Table 3.3.6.1-1 Table 3.2-1 Trip 1

changed from < 140% of rated steam flow in the CTS to < 125.9 psid in the ITS.

Allowable Level Setting for Value for Trip Function 9 Function 1.c L18 The ITS includes an allowance to open, under administrative controls, penetration flow paths closed to comply 3.3.6.1 N/A 4

with the Actions.

ACTIONS Note 1

L19 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable TIP System reactor water 3.3.6.1 Table 3.2-1 Note 5

level low or drywell pressure high channels are not tripped within the allowed times. In the ITS, in lieu of a ACTION G, 3.A shutdown when the channels are not tripped, the affected penetration flow path(s) must be isolated within 24 Table 3.3.6.1-1 hours. Due to this change, the TIP System Functions listed above are called out as separate line items in the ITS.

Functions 7.a and 7.b PAGE 9 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.3.6.2, SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION Li When more than one channel associated with a trip function is inoperable, the CTS requires action to be taken N/A Table 3.2-1 Note 4, 6 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the channel(s) in trip in one trip system or to take the required actions specified in the Table 1.b.2) and for the associated Function. These actions must be taken even if secondary containment isolation capability is footnote **

maintained. The ITS will not include this requirement; 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months will be allowed to trip an inoperable channel provided isolation capability is maintained._If it is not,_then the_1_hour action in theCTS andITS will apply.

L2 The CTS requires the plant to be in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the inoperable reactor water level low or 3.3.6.2 Table 3.2-1 Note 5

drywell pressure high channels are not tripped within the allowed times. In the ITS, in lieu of a shutdown when the ACTION C 3.A channels are not tripped, the associated secondary containment penetration flow paths must be isolated and the associated SGT subsystems must be placed in operation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or the associated features (SCIVs and SGT subsystems) must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L3 Not used.

N/A N/A N/A L4 The RETS requires the associated secondary containment penetration flow paths to be isolated and the 3.3.6.2 RETS Table 3.10-5 associated SGT subsystems to be placed in operation when the inoperable refuel area exhaust monitors or Required 1 Note d reactor building area exhaust monitors channels are not restored to Operable status within the allowed times. In Actions C.1.2 the ITS, in lieu of the requirements above when the channels are not restored, an optional action is provided to and C.2.2 declare the associated features (SCIVs and SGT subsystems) inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L5 Not used.

N/A N/A N/A L6 Not used.

N/A N/A N/A L7 The details that identify those portions of the instrument channel whic6 require functional testing and an instrument N/A Tables 4.1-1 and 3

check and the detail of the method of calibration have been deleted.

4.1-2, RETS Table 3.10-2 L8 The RETS requires both trip systems to have at least one operable or tripped refuel area radiation monitor and 3.3.6.2 RETS Table 3.10-4 reactor building area radiation monitor channel; however no actions are provided if trip capability is lost. The ITS ACTION B 1

includes an ACTION to allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore isolation capability, if it is not maintained.

3.3.7.1, CREVAS SYSTEM INSTRUMENTATION PAGE 10 JAFNPP

TABLE L-LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE NONE NONE NONE NONE NONE 3.3.7.2, CONDENSER AIR REMOVAL PUMP ISOLATION INSTRUMENTATION Li The RETS requires the mechanical vacuum pump to be capable of being automatically isolated and secured 3.3.7.2 RETS 3.9.a, 2, 5 whenever the main steam isolation valves are open. The Applicability is very broad and includes MODES 1, 2, 3, Applicability, Table 3.2-1 Notes 4 and 5. Also, the CTS requires the function to be operable whenever the primary containment integrity is 3.3.7.2 1 and 3.E required by CTS 3.7.A.2, which is essentially Modes 1, 2, and 3. The Applicability of the ITS will be during Required MODES 1 and 2 with any condenser air removal pump not isolated and any main steam line not isolated, since Actions C.2 and this is when the vacuum pumps need to be isolated. In addition, the CTS requires the air removal pumps to be C.3 isolated when the main steam line high radiation channels are inoperable and not tripped. In lieu of this action, the ITS provides an optional action to isolate the main steam lines or to be in Mode 3.

L2 When more than one channel associated with the main steam line high radiation trip function is inoperable, the N/A Table 3.2-1 Note 4, 6 CTS requires action to be taken within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the channel(s) in trip in one trip system or to take the 1.b.2) and required actions specified in the Table for the Function. These actions must be taken even if condenser air footnote **

removal pump isolation capability is maintained. The ITS will not include this requirement; 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months will be allowed to trip an inoperable channel provided isolation capability is maintained. If it is not, then the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action in the CTS and ITS will apply.

L3 The CTS provides 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to isolate the mechanical vacuum (air removal) pump. In the ITS, the time to isolate the 3.3.7.2 Table 3.2-1 Note 6

air removal pump is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Required 3.E Action C.1 L4 The RETS stipulates a "simulated" automatic actuation test of the condenser air removal pump isolation shall be SR 3.3.7.2.4 RETS Table 3.10-3 performed. The ITS allows use of an "actual" isolation signal, in addition to the simulated automatic isolation 2 Note f signal, for verifying that the air removal pump isolates on the proper signal.

L5 The details identifying how the Logic System Functional Test is to be performed (i.e., where possible using test N/A RETS Table 3.10-3 jacks) has been deleted.

2 Note f 3.3.7.3, ESW SYSTEM INSTRUMENTATION PAGE 11 JAFNPP

TABLE L -LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 -INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The CTS does not provide any specific actions for when the instrumentation is inoperable, thus the actions for 3.3.7.3 LCO 3.0.C 5

inoperable ESW subsystems must be taken. Since each channel provides input to both ESW subsystems, both ACTIONS A, B, subsystems would have to be declared inoperable; and since the CTS does not provide any actions for both ESW and C subsystems inoperable, a shutdown per LCO 3.0.C would be required. In lieu of this shutdown action, the ITS provides three ACTIONS that allows operation to continue with inoperable channels if certain conditions are met.

If one or more channels are inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to place the inoperable channels in trip. If isolation capability is not maintained in both trip systems, then 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is permitted to restore initiation capability. Finally, if the two above listed actions are not met, then the associated ESW subsystem(s) must be declared inoperable.

L2 The ITS includes a Note that allows placing a channel in an inoperable status solely for the performance of Surveillance N/A 4

required Surveillances, without entering the associated Conditions and Required Actions for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Requirements provided the associated Function maintains initiation capability.

Note L3 The CTS requirement to perform an ESW instrumentation check once per day has been deleted, since there are N/A 4.11.D.1.e 3

no pressure indicators or recorders associated with this instrumentation.

L4 The CTS requires the Emergency Diesel Generator (EDG) System be demonstrated Operable immediately and at N/A 3.11.D.2 3

least daily thereafter if the ESW System (i.e., the ESW instrumentation) is inoperable. These explicit verifications have all been deleted.

L5 The CTS requires the Emergency Diesel Generator System emergency loads be verified Operable immediately N/A 3.11.D.2 3

and at least daily thereafter if the ESW System (i.e., the ESW instrumentation) is inoperable. These explicit verifications have all been deleted.

3.3.8.1, LOP INSTRUMENTATION Li The CTS Trip Level Settings (changed to Allowable Values) for the 4.16 kV Emergency Bus Undervoltage Loss of Table 3.3.8.1-1 Table 3.2-2 Trip 1

Voltage, Degraded Voltage, and Time Delay Functions have been changed in the ITS, consistent with recent Allowable Level Settings for setpoint calculations.

Values for Item Nos. 19, 20, Functions 1.a, 21, 22, and 23 1.b, 2.a, 2.b, and 2.c PAGE 12 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.3.8.2, RPSELECTRICPOWERMONITORING Li The CTS does not provide specific Applicability requirements for the RPS electric power monitoring assemblies 3.3.8.2 3.9.G Bases, 2

(EPAs); however, the CTS Bases for this Specification and Amendment 76 to the JAFNPP Operating License Applicability Amendment 76, specify that this protection is for the RPS. CTS Table 3.1-1 requires the RPS instrumentation to be Operable Table 3.1-1 when in the refuel, startup and run modes. The CTS Applicability can be implied to be Modes 1, 2, and 5. In the ITS, the Applicability for the RPS Electric Power Monitoring is MODES 1 and 2, and MODES 3, 4, and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies; the assemblies are now only required in Mode 5 when a control rod is withdrawn from a core cell containing one or more fuel assemblies. The MODES 3 and 4 requirement is necessary due to an allowance in ITS 3.10.3 and ITS 3.10.4 that allows a single control rod to be withdrawn in MODE 3 or 4.

L2 The time to remove the associated power supply from service when both RPS electric power monitoring 3.3.8.2 3.9.G.2 6

assemblies are inoperable is being extended from 30 minutes in the CTS to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in the ITS.

Required Action B.1 L3 The CTS does not provide any actions if the associated power supply is not removed from service; thus a plant 3.3.8.2 N/A 5

shutdown to cold shutdown (Mode 4) is required. In the ITS, the plant is only required to be placed in Mode 3, ACTION C consistent with the Applicability.

L4 The CTS requires that at least one RPS division be powered from its respective motor generator while in MODE 1.

N/A 3.9.G.3 1,4 If both RPS divisions are powered from the alternate power supply, there is a 7 day allowable outage time to restore at least one of the motor generator power supplies to Operable status, or the reactor is required to be placed in a cold condition within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This requirement and action are not included in the ITS.

L5 The CTS stipulates a "simulated" automatic actuation test of the RPS Electric Power Monitoring Assemblies shall SR 3.3.8.4, 4.9.G.2 3

be performed. The ITS allows use of an "actual" actuation signal (as identified in the Bases), in addition to the including Bases simulated automatic actuation signal, for verifying that the RPS Electric Power Monitoring Assemblies actuate on the proper signal._I CHANGE TYPE PAGE 13 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 14

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.4.1, RECIRCULATIONLOOPS OPERATING L1 The ITS allows the requirements of the LCO to not be met for reasons other than Condition A (i.e., thermal 3.4.1 ACTION B 3.5.K.1, 3.11.A 6

hydraulic stability) for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In this same condition, the CTS would require restoration of requirements within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or would require a plant shutdown within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change relaxes the effective allowed outage time to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to comply with the LCO when the reason for non-compliance is not related to thermal hydraulic stability.

I ________________________________________________________

I _________

J. __________

I 3.4.2. JET PUMPS Li The CTS is revised by adopting two Notes that relax the Frequency by allowing a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months delay to perform the SR 3.4.2.1 4.6.G, 4.6.G.A.b Surveillance after the associated recirculation loop is in operation and a delay in performance of the Surveillance Notes 1 and 2 until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the plant exceeds 25% RTP. The first Note permits a delay because the Surveillance can only be performed during recirculation loop operation, and the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period provides a reasonable time period in which to establish conditions appropriate for data collection and evaluation. The second Note permits a delay in performing the Surveillance until the plant exceeds 25% RTP, because during low flow conditions, jet pump noise approaches the threshold response of the flow instrumentation, which precludes collection of repeatable and meaningful data.

L2 J

The CTS requires that individual jet pump differential pressure not vary from the average of all jet pump differential pressures by more than 10%. The ITS requires that the differential pressure variation from established patterns be not more than 20%. This change is consistent with the recommendations provided in General Electric Service Information Letter (SIL) No. 330, Jet Pump Beam Cracks," and NUREG/CR-3052, "Closeout of IE Bulletin 80-07:

BWR Jet Pump Assembly Failure." SIL-330 recommends the 10% criteria be used for plants designed with individual jet pump flow indicators. When measured by jet pump diffuser-to-lower plenum differential pressure, the equivalent criteria is 20% due to the relationship between flow and differential pressure. Since JAFNPP utilizes jet pump differential pressures measurement, the variance allowed should be 20%.

SR 3.4.2.1 4.6.G.3 3.4.3. SAFETY/RELIEF VALVES The CTS requires the reactor to be placed in a cold condition (MODE 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the minimum number of Operable safety/relief valves is not met. In the ITS, the time allowed for the plant to reduce temperature to be in MODE 4,is extended to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

PAGE 1 JAFNPP I

11

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM ITS SECTION CTS SECTION CHANGE TYPE 3.4.4, RCS OPERATIONAL LEAKAGE The unidentified leakage rate increase limit is changed to be applicable only in MODE 1 instead of the current L.U 3.4.4.d MODES 1, 2, and 3 (i.e., is at operating pressure after a period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). An unidentified LEAKAGE increase of > 2 gpm within the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period indicates a potential flaw in the RCPB and must be quickly evaluated to determine the source and extent of the LEAKAGE. As the plant starts up and increases pressure, leakage will occur due to the increased pressure. Thus, an increase is detected, and if greater than the limit, could require a plant shutdown, even though there is no safety problem. This proposed change will not require the limit to be applied until MODE 1 is achieved, which is when reactor pressure has effectively stabilized at nominal operating pressure.

The CTS requires that total leakage not exceed 25 gpm. The ITS requires that total LEAKAGE not exceed specified limits when averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. Thus the ITS allows the instantaneous leakage to be greater than 25 gpm, as long as the average is less than 25 gpm.

The CTS requires that the source of an increase in the leakage be identified within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The ITS provides an additional option to allow the operators to reduce the leakage (or leakage increase) to within acceptable limits within the same 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

3.6.D.1.b 2

3.6.0.1.c 1

i 3.4.4 Required 3.6.0.3 4

3A4.4 Required Action B.1 I

I

) A r

^f I I

TAVA rf cT~r'TItnNl IN*ITRU INAIeNTATION The CTS allows continued operation for 30 days if only one monitor of the Continous Atmospheric Monitoring System (gaseous or particulate) is inoperable. The CTS also requires a grab sample to be taken every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during the 30 day period. If both are inoperable, a shutdown per CTS 3.0.C is required. The ITS will allow one of the two monitors to be inoperable indefinitely, provided SR 3.4.5.1, a CHANNEL CHECK, is performed on the remaining Operable Containment Atmospheric Monitoring System monitor, every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The ITS will also allow both Containment Atmospheric Monitoring Systems monitors to be inoperable for 30 days, provided a grab sample is taken every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Also, to be consistent with the format of the ITS, the term "one channel" is used in the ITS in lieu of defining in the LCO section of the Bases that the System is OPERABLE if only one of the two gaseous monitors channels) and one of the two particulate monitors (channels) are OPERABLE.

LCO 3.4.5, 3.4.5 ACTIONS B and C

.9 3.4.5 K(;bLLAKAL Ut tU IIUN NO I3.6.D.4,I m3.6-1,D16 DOC #

SUMMARY

Li L2 L3 Li JAFNPP PAGE 2 ITS SECTION CTS SECTION CHANGE TYPE I

LCO 3.4.4.c 3.6.D.3 S3.6.D.4, 3.6.D.6

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L2 The CTS requires that an inoperable sump monitoring system be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

3.4.5 ACTION A 3.6.D.5 6

The ITS requires an inoperable drywell sump monitoring system be restored to OPERABLE status within 30 days.

However, this 30 day Completion Time is allowed provided RCS unidentified and total LEAKAGE can still be determined every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

L3 A statement that LCO 3.0.4 is not applicable for the condition of the drywell floor drain sump monitoring system 3.4.5 ACTIONS N/A 7

inoperable or both drywell atmospheric monitors inoperable has been added as a Note to the ITS ACTIONS.

A and C Notes Currently, this allowance is not provided.

L4 The CTS requirement that an instrument check be performed on the drywell floor drain sump monitor once per day N/A Table 4.2-5 3

is not included in the ITS.

L5 The drywell equipment drain sump monitoring system functions to quantify identified leakage. Since the purpose of N/A 3.6.D.4, 3.6.D.5, 1

ITS 3.4.5, RCS Leakage Detection Instrumentation, is to provide instrumentation requirements for early 4.6.D.4, Table 3.2 identification of unidentified leakage, the drywell equipment drain sump monitoring system requirements have been 5, Table 4.2-5 deleted.

L6 A Note has been added to allow a channel to be inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months solely for performance of required Surveillance N/A 6

Surveillances provided the other Leakage Detection System channel is OPERABLE.

Requirements Note 3.4.6, RCS SPECIFIC ACTIVITY Li The CTS requires that the reactor not be operated more than 5% of its annual power operation with the reactor N/A 3.6.C.1 1

coolant specific activity in excess of 0.2 p Ci/gm DOSE EQUIVALENT 1-131. This requirement is not adopted in the ITS, in accordance with the recommendations in Generic Letter 85-19, Reporting Requirements on Primary Coolant Iodine Spikes.

L2 The CTS requires that, if the iodine concentration exceeds the equilibrium limit by more than a factor of 10, or if the 3.4.6 Required 3.6.C.1, 3.6.C.5 6

equilibrium limit is not met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the reactor be placed in a cold condition (MODE 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Action B.2.2.2 The ITS requires the plant to be in MODE 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , essentially extending the time to reach MODE 4 by 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ._I

_I PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L3 The CTS Applicability is effectively MODES 1, 2, and 3 (while no actual Applicability is specified, the Actions 3.4.6 3.6.C 2, 4 require entry into Mode 4). The ITS Applicability is MODE 1, and MODES 2 and 3 with any main steam line not Applicability, isolated, since in MODES 2 and 3 with the main steam lines isolated, an escape path does not exist for release of 3.4.6 Required radioactive material from the reactor coolant to the environment in the event of a main steam line break outside of Action B.2.1 primary containment. In addition, consistent with the change in the Applicability, an option is provided to isolate the main steam lines instead of commencing a reactor shutdown if the limits are not restored within the applicable completion time.-

L4 A statement that LCO 3.0.4 is not applicable for the condition of the specific activity not within limit but < 2.0 3.4.6 ACTION A N/A 7

p Ci/gm DOSE EQUIVALENT 1-131 has been added as a Note to the ITS. Currently, this allowance is not Note provided.

L5 The requirements to analyze for gross gamma activity have been deleted. In addition, the requirement to perform a N/A 4.6.C.l.a, 3

quantitative determination of 1-131 and 1-133 if the total iodine concentration is in excess of 0.002ktCi/ml as 4.6.C.1.c, indicated by the results of these surveillances is also deleted.

4.6.C.1.d, 4.6.C.1.e L6 The CTS requires that the isotopic analysis of a sample of reactor coolant be taken at least once a month. A Note SR 3.4.6.1 Note 4.6.C.1.b 3

has been added that will require the SR to be performed only in MODE 1, since the level of fission products generated in MODES 2 and 3 is much less than those generated during power operation and, therefore, the limits are not challenged.

3.4.7, RHR SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN NONE NONE NONE NONE NONE 3.4.8, RHR SHUTDOWN COOLING SYSTEM - COLD SHUTDOWN NONE NONE NONE NONE NONE 3.4.9, RCS P/T LIMITS PAGE 4 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM IT-SI EU I UN U I r N rHANIUII

SUMMARY

The CTS requires verification, when Reactor Coolant System temperature is > 140'F, that the temperature differential between the RCS and the reactor vessel bottom head, and between the RCS and an idle recirculation loop, are within limits prior to startup of the idle recirculation loop. In the ITS, these requirements are modified by a Note which states that these P/T verifications are only required to be met in MODES 1, 2, 3, and 4 during recirculation pump startup. Therefore, the overall Applicability of the Specification is reduced since the surveillances are no longer required in MODE 5 with temperatures > 1400F.

The CTS requires the temperature differential between the reactor coolant system and the reactor vessel bottom head drain line be < 145'F during a recirculation pump startup. The ITS 3.4.9 maintains this Surveillance, but provides the option, in lieu of this Surveillance, to verify the active recirculation pump flow exceeds 40% of rated pump flow or the active recirculation pump has been operating below 40% rated flow for a period no longer than 30 minutes.

ITS SECTIOIN SR 3.4.9.3 Note 1, SR 3.4.9.5 Note DOC #

Li L2 4.6.A.6 3.6.A.6.a CTS 314.6.F, STRUCTURAL INTEGRITY 1

CHANGE TYPE Relaxation of LCO Requirement Relaxation of Applicability Relaxation of Surveillance Requirement Relaxation of Required Action Detail Relaxation of Required Actions to Exit Applicability Relaxation of Completion Time Allow Mode Changes When LCO Not Met Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel Elimination of CTS Reporting Requirement PAGE 5 JAFNPP SR 3.4.9.3 Note 2, SR 3.4.9.4 2,3 3

1.

2.

3.

4.

5.

6.

7.

8.

9.

I

.,,ITS SE:G,I IUNl~

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.5 - ECCS AND RCIC SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE I

I TYPE Li L2 SR 3.5.1.10, SR 3.5.1.1 1 N/A 3.5.1, ECCS - OPERATING CTS requirements for actuation testing of CS, LPCI, HPCI, and ADS stipulate a simulated automatic actuation test shall be performed. The phrase "actual or," in reference to the automatic initiation signal, has been added to the ITS Surveillance Requirements for verifying that each ECCS subsystem actuates on an automatic initiation signal.

This allows satisfactory automatic system initiations to be used to fulfill the Surveillance Requirements.

CTS 4.5.A.2 requires the immediate verification that the remaining Core Spray (CS) subsystem and both low pressure coolant injection (LPCI) subsystems are Operable whenever it is determined that one CS subsystem is determined to be inoperable. It also requires the verification that the remaining CS subsystem is Operable daily thereafter. CTS 4.5.A.3.a requires the immediate and daily verification that the remaining LPCI subsystem and both CS subsystems are Operable whenever it is determined that one LPCI subsystem is determined to be inoperable. It also requires the verification that the remaining CS subsystem is Operable daily thereafter. CTS 4.5.C.1.a requires that both LPCI subsystems, both CS subsystems, and the ADS System actuation logic be verified to be Operable immediately when it is determined that HPCI is determined to be inoperable. It also requires that the RCIC System and the ADS System logic be verified to be Operable daily thereafter. When it is determined that two ADS valves are inoperable, CTS 4.5.D.2.a requires the ADS System actuation logic for the operable ADS valves and the HPCI System be verified to be Operable immediately and at least weekly thereafter.

Finally, CTS 4.5.D.2.b requires that when it is determined that more than two relief/safety valves of the ADS are inoperable, the HPCI System shall be verified to be Operable immediately. These explicit verifications have all been deleted.

The pressure at which ADS is required to be Operable is proposed to be increased from > 100 psig to > 150 psig to provide consistency with the Operability requirements for HPCI. Along with this change the default action of the CTS to reduce pressure to less than 100 psig has been changed to reduce reactor steam dome pressure to _< 150 psig consistent with the Applicabiity.

The CTS requires that the reactor be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the ACTIONS for LPCI or CS cannot be satisfied, requires that the reactor be in the cold condition and reactor pressure be reduced to less than 150 psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the ACTIONS for HPCI cannot be satisfied, requires that the reactor be placed in the cold condition and that reactor pressure be reduced to less than 100 psig (modified by DOC L3) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the Required Actions for inoperable ADS valves cannot be satisfied, and requires that the reactor shall be brought to cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when both LPCI independent power supplies are made or found to be inoperable. This specific default action has been interpreted to also require entry when the ACTIONs or Completion Times associated with one inoperable LPCI independent power supply are not met since no other exists. The ITS extends the time allowed for the plant to reduce pressure or be in MODE 4 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

4.5.A.1.a, 4.5.A.3, 4.5.C.1, 4.5.D.1.a, Table 4.2-2 Note 7 4.5.A.2, 4.5.A.3.a, 4.5.C.1.a, 4.5.D.2.a 4.5.D.2.b 3.5.D.1.a, 3.5.D.2 3.5.A.6,3.5.C.1.b, 3.5.D.2,3.9.F.3 PAGE 1 JAFNPP 3.5.1 Applicability, 3.5.1 Required Action G.2 3.5.1 Required Actions B.2 and G.2 L3 L4 3

2 6

3.5.1.11

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.5 - ECCS AND RCIC SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L5 The CTS allows continued operation for a maximum of 7 days after HPCI only is determined to be inoperable. The 3.5.1 Required 3.5.C.i.a 6

ITS allows continued operation for a maximum of 14 days under the same conditions.

Action C.1 L6 The CTS allows continued operation for a limited time if HPCI is inoperable only if the ADS subsystem, the RCIC 3.5.1 ACTION D 3.5.C 4

System, both LPCI subsystems and both core spray subsystems are Operable. The ITS will allow continued operation for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if HPCI and one low pressure ECCS subsystem are inoperable or HPCI and one LPCI pump in each LPCI subsystem are inoperable.

L7 The flow rates specified in the CTS for the Low Pressure Injection System and the High Pressure Injection System SR 3.5.1.7, SR 4.5.A.3, 4.5.C.1i 3

have been decreased from 8910 gpm to 7700 gpm and from 4250 gpm to 3400 gpm, respectively, consistent with 3.5.1.8 the values used in the plant specific LOCA analysis reflected in NEDC-31317P (James A. FitzPatrick Nuclear Power Plant SAFER/GESTR-LOCA Loss of Coolant Accident Analysis).

L8 The CTS requires that with one low pressure coolant injection pump inoperable in each subsystem, the plant be 3.5.1 Condition 3.5.A.3.a 5

shutdown in accordance with the CTS 3.0.C, implying that the plant is outside design basis. This condition is not A (second part) outside design basis, thus the ITS allows continued operation for 7 days in this condition.

L9 The details in the CTS related to the specific inverter buses (MCC-155 and MCC-165) required to be in service are N/A 3.9.F.1 1

not necessary to ensure the LPCI inverter and buses remain Operable. Therefore, they have not been included in the ITS.

L10 The CTS requires, if one independent power supply becomes inoperable, the inoperable independent power supply N/A 3.9.F.2.a 4

be isolated from its associated LPCI MOV bus, and this bus be manually switched to its alternate power source. If this cannot be met, CTS 3.0.C must be entered and the plant must be in Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This requirement has not been included in the ITS since another CTS section (CTS 3.5.A.2) allows a 7 day Completion Time for any other LPCI subsystem inoperability with no other compensatory actions.

L11 The CTS requires the performance of additional Surveillances on the OPERABLE LPCI MOV Independent Power N/A 3.9.F.2.b 4

Supply System if one LPCI MOV Independent Power Supply System is inoperable. The ITS does not include these additional Surveillance Requirements.

L12 The ITS includes a Note that allows the LPCI subsystems to be considered OPERABLE during alignment and SR 3.5.1.2 Note N/A 1

operation in decay heat removal below the RHR cut in permissive in MODE 3, if capable of being manually realigned and not otherwise inoperable. Currently, this is not allowed in the CTS; the LPCI subsystem must be Iconsidered inonperablein this condition.

PAGE 2 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.5 - ECCS AND RCIC SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L13 The CTS requires "all" Automatic Depressurization System (ADS) pilot valves to be opened during the performance SR 3.5.1.11 4.5.D.1 3

of the simulated automatic actuation test. The ITS requires the verification that ADS actuates on an actual (as modified by DOC L1) or simulated automatic initiation signal, and will only require the pilot valves (solenoids) associated with six Operable ADS valves to be tested during the performance of the Surveillance, since only "required" equipment must be OPERABLE to satisfy the conditions of the LCO.

L14 The CTS requires pressure to be reduced to less than 150 psig if HPCI is not restored to Operable status within the 3.5.1 Required 3.5.C.1.b 4

allowed time. The ITS requires reactor steam dome pressure to be reduced to

150 psig under the same Action G.2 condition. This change is slightly less restrictive since a reduction in reactor steam dome pressure to only 150 psig will be considered as satisfying the requirement, whereas in the CTS reactor steam dome pressure must be reduced to < 150 psig.

L15 The CTS requires that HPCI flow be demonstrated "against a system head corresponding to a reactor vessel SR 3.5.1.8, SR 4.5.C.1.b 3

pressure of 1195 to 150 psig." The ITS requires a demonstration of required HPCI flow "against a system head 3.5.1.9 corresponding to reactor pressure." Adopting the ITS wording for the low pressure test results in testing requirements analogous to the CTS specification and current testing practices at the low end of the HPCI operability band. Adopting the ITS wording for the high end of the HPCI operability band, however, constitutes a less restrictive change._II 3.5.2, ECCS - SHUTDOWN Li The CTS requires immediate suspension of OPDRVs when one of the two required low pressure ECCS 3.5.2 ACTION A 3.5.F.4 6

subsystems are inoperable. The ITS will allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore one required ECCS injection/spray subsystem to OPERABLE status, since the remaining OPERABLE subsystem can provide sufficient vessel flooding capability to recover from an inadvertent vessel draindown.

L2 The CTS requires the suppression pool water level and Condensate Storage Tank (CST) level to be verified to be SR 3.5.2.1, SR 4.5.F.3, 4.5.F.4 3

within the specified limits once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The ITS will require these verifications every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

3.5.2.2 L3 The CTS requires the suspension of Core Alterations when the requirements of CTS 3.5.F.1, 3.5.F.2 or 3.5.F.3 are N/A 3.5.F.4 2

not met._TheITS does not retain anyECCS operability requirements durinqCoreAlterations.

JAFNPP PAGE 3

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.5 - ECCS AND RCIC SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L4 CTS requirements for actuation testing of CS and LPCI stipulate a simulated automatic actuation test shall be SR 3.5.2.6 Table 4.2-2 Note 7 3

performed. The phrase "actual or," in reference to the automatic initiation signal, has been added to the ITS Surveillance Requirements for verifying that each required CS and LPCI subsystem actuates on an automatic initiation signal. This allows satisfactory automatic system initiations to be used to fulfill the Surveillance Requirements.

L5 The flow rate specified in the CTS for the Low Pressure Injection System has been decreased from 8910 qpm to SR 3.5.2.5 4.5.F.1 3

7700 gpm, consistent with the values used in the plant specific LOCA analysis reflected in NEDC-31317P (James A. FitzPatrick Nuclear Power Plant SAFER/GESTR-LOCA Loss of Coolant Accident Analysis).

3.5.3, RCIC SYSTEM Li The CTS allows continued operation for a maximum of 7 days after RCIC only is determined to be inoperable. The 3.5.3 Required 3.5.E.1 6

ITS allows continued operation for a maximum of 14 days under the same conditions.

Action A.2 L2 The CTS requires that the reactor be in the cold condition and reactor pressure be reduced to less than 150 psig 3.5.3 Required 3.5.E.2 6

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the ACTIONS for RCIC cannot be satisfied. The ITS extends the time allowed for the plant to Action B.2

-reduce pressure from_24_hours to_36_hours.

The CTS requirement for actuation testing of RCIC stipulates a simulated automatic actuation test shall be performed. The phrase "actual or," in reference to the automatic initiation signal, has been added to the ITS Surveillance Requirement for verifying that the RCIC System actuates on an automatic initiation signal. This allows satisfactory automatic system initiations to be used to fulfill the Surveillance Requirement.

The CTS requires that the HPCI System be verified to be Operable daily whenever the RCIC System is inoperable.

This explicit verification has been deleted.

The CTS requires pressure to be reduced to less than 150 psig if RCIC is not restored to Operable status within the allowed time. The ITS requires reactor steam dome pressure to be reduced to _< 150 psig under the same condition. This change is slightly less restrictive since a reduction in reactor steam dome pressure to only 150 psig will be considered as satisfying the requirement, whereas in the CTS reactor steam dome pressure must be reduced to < 150 Psin.

t I

N/A 4.5.E.2 4

-l I

3.5.3 Required 3.5.E.2 4

3.5.3 Required Action B.2 PAGE 4 JAFNPP L3 L4 L5 I

SR 3.5.3.5 4.5.E.1.a 4.5.E.2 N/A 3.5.E.2

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.5 - ECCS AND RCIC SYSTEM DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L6 The CTS requires that RCIC flow be demonstrated "against a system head corresponding to a reactor vessel SR 3.5.3.3, SR 4.5.E.1.d 3

pressure of 1195 to 150 psig." The ITS requires a demonstration of required RCIC flow "against a system head 3.5.3.4 corresponding to reactor pressure." Adopting the ITS wording for the low pressure test results in testing requirements analogous to the CTS specification and current testing practices at the low end of the RCIC operability band. Adopting the ITS wording for the high end of the RCIC operability band, however, constitutes a less restrictive change.

I I

II_

I CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement PAGES5 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.6.1.1, PRIMARY CONTAINMENT Li The CTS does not provide any time to restore the primary containment to Operable status if it is found to be 3.6.1.1 ACTION 3.7.A.2 5

inoperable. In the ITS, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore primary containment to OPERABLE status prior to the A

commencement of a plant shutdown.

L2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In 3.6.1.1 Required 3.7.A.8 6

the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Action B.2 L3 The Frequency for performing a visual inspection of the accessible interior surfaces of the drywell and above the SR 3.6.1.1.1 4.7.A.1 3

water line of the torus (suppression chamber) for evidence of deterioration is being changed from every 24 months to three times in a ten year period in the ITS. The ITS will effectively require the visual inspection to be performed prior to each Type A test and two additional times during each 10 year interval.

3.6.1.2, PRIMARY CONTAINMENT AIR LOCKS Li The ITS includes a Note to permit entry through a closed or locked air lock door (closed due to an inoperable door 3.6.1.2 N/A 4

in the associated air lock) for the purpose of making repairs. The proposed allowance will have strict administrative ACTIONS Note controls, which are detailed in the proposed Bases.

1 L2 The ITS includes a Note to permit entry through a closed or locked air lock door (closed due to an inoperable door 3.6.1.2 Required N/A 4

in the associated air lock) for any purpose for up to 7 days. The proposed allowance will have strict administrative Action A Note 2 controls, which are detailed in the proposed Bases.

L3 A new ACTION is included in the ITS for when a primary containment air lock is inoperable for reasons other than 3.6.1.2 ACTION N/A 4, 6 one primary air lock door inoperable or a primary containment air lock interlock mechanism inoperable. The ITS C, 3.6.1.2 will allow up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the inoperable air lock under this condition, provided the primary containment is ACTIONS Note not rendered inoperable by the air lock inoperability.

3 L4 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In 3.6.1.2 Required 3.7.A.8 6

the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Action D.2 L5 Adds ITS ACTIONS Note "Separate Condition entry is allowed for each air lock."

3.6.1.2, 3.6.1.3 3.7.A.4 4

ACTIONS Note 2

PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS I

SUMMARY

3.6.1.3, PRIMARY CONTAINMENT ISOLATION VALVES The CTS stipulates a "simulated" automatic actuation test of the PCIVs shall be performed. The ITS allows for use of an "actual" isolation signal, in addition to the simulated automatic isolation signal, for verifying that each PCIV actuates on an automatic isolation signal.

Not used.

The CTS does not provide specific ACTIONS for those open penetrations with two or more inoperable PCIVs (except due to a leakage problem); thus the plant must be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to isolate the affected penetration flow ahpirt eurn lant shutdown.

The CTS does not provide specific ACTIONS for those open penetrations that have only one PCIV and the PCIV is inoperable; thus the plant must be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is provided it the inoperable PCIV is not an EFCV or not in a closed system and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided if the inoperable PCIV is an EFCV or is in a closed system, to isolate the penetration prior to requiring a plant shutdown. In addition, a periodic verification of the isolated_.enetration is required eve 31 days.

The CTS allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to isolate a penetration when one PCIV in the penetration is inoperable. In the ITS, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is allowed to isolate a main steam line penetration.

L2 L3 L4 L5 L6 L7 L8 SR 3.6.1.3.7 N/A 4.7.D.1.a, Table 4.2-1 Note 7 N/A 3.6.1.3 ACTION I 3.D.3 B

3.6.1.3 ACTION C

3.6.1.3 Required Action A.1, second Completion Time 3.6.1.3 Required Action A.1 3.6.1.3 Required Action F.2 3.6.1.3 Required Action A.2 and C.2 3.7.D.3 5

3.7.D.2.b N/A 3.7.D.3, 3.7.A.8 4.7.D.2 PAGE 2 JAFNPP LI 3

N/A 5

4 6

6 The ITS includes an additional method of isolating a penetration when a PCIV is inoperable. The ITS will allow the penetration to be isolated by use of a check valve with flow through the valve secured.

When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to lace the lant in MODE 4.

The periodic verification that a penetration is isolated (when isolated to comply with other actions) is changed from a daily recording requirement in the CTS to a monthly verification or a verification "Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 da*_s for isolation devices inside rinam containment" in the ITS.

B 3

c

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L9 The CTS does not provide specific ACTIONS for those MSIVs that are inoperable due to a leakage problem; thus 3.6.1.3 ACTION 3.7.A.8 5

the plant must be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months are allowed to restore MSIV leakage to D

within limits prior to requiring a plant shutdown.

L10 The CTS does not provide specific ACTIONS for the air operated testable check valves associated with the LPCI 3.6.1.3 ACTION 3.7.A.8 5

and CS systems injection penetrations that are inoperable due to a leakage problem; thus the plant must be in cold E

shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months are allowed to restore the leakage to within limits prior to requiring a plant shutdown.

L11 The CTS requires a verification that a penetration flow path with an inoperable PCIV is isolated. The ITS includes 3.6.1.3 Required 4.7.D.2 3, 4 Notes that allow the verification to be performed administratively for isolation devices that are in high radiation Actions A.2 and areas and for isolation devices that are locked, sealed, or otherwise secured.

C.2 Note, SR 3.6.1.3.2 Notes 1land 2, SR 3.6.1.3.3 Notes 1 and 2 L12 The CTS identifies the plant specific valve numbers for the air operated testable check valves associated with the N/A 4.7.A.2.c 3

LPCIlandCS systems injection penetrations._TheITS does not include these plant specific valve numbers.

L13 The CTS requirement to demonstrate the leakage rate of the Low Pressure Coolant Injection (LPCI) System and SR 3.6.1.3.11 4.7.D.2.c 3

Core Spray System injection penetration air operated testable check valves is within limits once per 24 months is changed in the ITS to be every 30 months (and the 30 month test interval may be extended to 60 months with satisfactory test performance), as part of the Type C testing required by the Primary Containment Leakage Rate Testing Program.

3.6.1.4, DRYWELL PRESSURE NONE NONE NONE NONE NONE 3.6.1.5, DRYWELL AIR TEMPERATURE NONE NO}NE INONE INONE INONE PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS

SUMMARY

A n........

.,,,,-,II "rrI C', nnnNc I

'tM A M FAI:I \\IAC'I II I*IM R EA I(F:RS 3.6.1.6,,

EACTOR I U UILUINI-T I U-bUr'r'nE1ooJ u*I'L'I -,rLm VJM r

Li Adds ITS ACTIONS Note "Separate Condition entry is allowed for each lineA" 3.6.1.6 N/AC4 ACTIONS Note L2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In 3.6.1.6 Required 3.7.A.8 6

the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Action E.2 3.6.1.7, SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS Li The CTS requires that "When it is determined that one vacuum breaker is inoperable for fully closing when N/A 4.7.A.5.b 3

operability is required, the operable breakers shall be exercised immediately, and every 15 days thereafter until the inoperable valve has been returned to normal service."_This requirement has not been included in theITS.

12 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In 3.6.1.7 Required 3.7.A.8 6

the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Action C.2 L3 Not used.

N/A N/A N/A L4 The Frequency of the exercising of each Suppression Chamber-to-Drywell vacuum breaker through an open-close SR 3.6.1.7.2 4.7.A.5.a 3

cycle is being extended from "monthly" in the CTS to "In Accordance with the Inservice Testing (IST) Program" (i.e., 92 days) in the ITS.

NONE1

3.6J.1.8, MAU'I~IN TEAM LEArVA'.t ULLtU

~'I IU IOT VJ1-NONE I

I 3 a 1n La n,',r,KITAIIMPArMT.RDIAV I

L I

I N/A Not used.

I N/A I N/A PAGE 4 JAFNPP INONEkI KHK UUN I AINMUN I orMMT o3 c 4

KA re,

TAUL r-l I r-AVAr"E ~r-MI I ErTIt"NM YVqTIFIM INONE INONE i

I I

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In 3.6.1.9 Required 3.5.B.4 6

the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Action C.2 L3 The Frequency for performance of an air test on the containment spray header and nozzles has been extended SR 3.6.1.9.3 4.5.B.1.f 3

from 5 years in the CTS to 10 years in the ITS.

L4 The CTS requires two Residual Heat Removal (RHR) pumps to be Operable in each containment spray mode LCO 3.6.1.9 3.5.B.1 1

subsystem. In the ITS, only one RHR pump, as indicated in the Bases, will be required to be Operable in each (including RHR containment spray subsystem.,bases)

L5 No actions are provided in the CTS for when two RHR containment spray subsystems are inoperable; thus a plant 3.6.1.9 ACTION N/A 5

shutdown to cold shutdown is required. In the ITS, a new ACTION is provided to allow both RHR containment B

spray subsystems to be inoperable for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to requiring a plant shutdown.

3.6.2.1, SUPPRESSION POOL AVERAGE TEMPERATURE No specific actions are provided in the CTS for when the suppression pool temperature is exceeding the temperature limit during normal power operation (i.e., not due to testing); thus a plant shutdown to cold shutdown is required aIn the ITS, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to restore the suppression pool temperature to < 95 OF, provided the temperature is < 110 O and no testing that adds heat to the suppression pool is in progress.

No specific actions are provided in the CTS for when the suppression pool temperature is exceeding the temperature limit during normal power operation; thus a plant shutdown to cold shutdown is required. In the ITS, after the time allowed to restore the suppression pool temperature to within limits described in DOC L1 has expired, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are allowed to reduce power to < 1% RTP (i.e., the ITS does not require a shutdown to cold shutdown).

The CTS requires an external visual inspection of the suppression chamber whenever there is indication of relief valve operation with the local suppression pool temperature reaching 160O°F or greater and the primary coolant system pressure greater than 200 psig. This Surveillance is not included in the ITS.

j The CTS requires monitoring suppression pool temperature when "there is indication of relief valve operation or testing which adds heat to the suppression pool." The ITS only requires increased monitoring of the suppression pool temperature during testing; the requirement to monitor when there is indication of relief valve operation is not included in the ITS unless it is associated with a specific test.

3.6.2.1 Required Action A.2 3.7.A.1 5

t 3.7.A.8 5

3.6.2.1 ACTION B

N/A 4.7.A.1 I

I 1

SR 3.6.2.1.1 4.7.A.1 3

-- I I___

PAGE 5 L1 L2 L3 L4 JAFNPP luluuvv ".

I.-

I I

3.7.A.8 SR 3.6.2.1.1 4.7.A.1

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS

SUMMARY

In the CTS, if the testing limit of 105 OF (95 OF plus the 10 OF increase allowed during testing) is exceeded, the CTS requires the reactor to be placed in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, if the suppression pool temperature exceeds 105 OF, then testing must be immediately suspended and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is then allowed to restore temperature to <:95 OF prior to requiring a plant shutdown.

3.6.2.2, SUPPRESSION POOL WATER LEVEL No specific actions are provided in the CTS for when the suppression pool water level is not within the limits; thus a plant shutdown to cold shutdown is required. In the ITS, 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is allowed to restore the water level to within limits prior to requiring a plant shutdown.

When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Not used.

The CTS requires two Residual Heat Removal (RHR) pumps to be Operable in each suppression pool cooling mode subsystem. In the ITS, only one RHR pump, as indicated in the Bases, will be required to be Operable in each RHR suppression pool cooling subsystem.

When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

No actions are provided in the CTS for when two RHR suppression pool cooling subsystems are inoperable; thus a plant shutdown to cold shutdown is required. In the ITS, a new ACTION is provided to allow both RHR su~nnresinn nool cooling subsystems to be inoperable for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to requiring a plant shutdown.

3.6.2.2 ACTION A

3.6.2.2 Required Action B.2 3.6.2.4, DRYWELL-TO-SUPPRESSION CHAMBER DIFFERENTIAL PRESSURE The Frequency to monitor the drywell-to-suppression chamber differential pressure has been changed from once SR 3.6.2.4.1 PAGE 6 JAFNPP 3.7.A.8 I

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS

SUMMARY

1)0,

,12 DIL1APl~rf'fMTAIkNkAFNT AYVIF~M kIFNITRATICON 3.6.3.1I, HlKlV/*IMAKY.UUlN

I*V~I A1Ni tN 1-U

_1r*1 vnlcmn-iv*

i it,,*

NONE NONE NONE NONE NONE 3.6.3.2, CAD SYSTEM NONE NONE NONE NONE NONE 3.6.4.1, SECONDARY CONTAINMENT Li The CTS does not provide any time to restore the secondary containment to Operable status if it is found to be 3.6.4.1 ACTION 3.7.C.2 5

inoperable. The CTS requires the plant to be in essentially cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the secondary A

containment is inoperable. In the ITS, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is allowed to restore secondary containment to OPERABLE status prior to the commencement of a plant shutdown.

L2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In 3.6.4.1 Required 3.7.C.2 6

the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

Action B.2_-A L3 The CTS requires the Reactor Coolant System to be vented in order for secondary containment to not be required.

N/A 3.7.C.1.b 2

The ITS does not include this requirement.

L4 The requirement to perform the secondary containment capability test "prior to refueling" is not included in the ITS N/A 4.7.C.1.c 3

since the normal periodic Surveillance Frequency is sufficient.

L5 CTS 3.7.C.2 requires all four conditions of CTS 3.7.C.1 to be met if secondary containment is inoperable. If 3.6.4.1 Required 3.7.C.2 5

secondary containment is inoperable when moving irradiated fuel while operating in MODE 1, 2, or 3, CTS requires Action C.1 Note plant shutdown and cooldown actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (CTS 3.7.C.1.a and 3.7.C.1.b) in addition to suspension of movement of irradiated fuel (CTS 3.7.C.1.d). In ITS, for the same set of conditions (that is, if secondary containment is inoperable when operating in MODE 1, 2, or 3 and while moving irradiated fuel) the addition of the Note to ITS 3.6.4.1 Required Action C.1 allows plant operation to continue for the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period allowed by ITS 3.6.4.1 ACTIONA,_prior to entering any action that requires plant shutdown and cooldown_(ITS_3.6.4.1_ACTIONB).

PAGE 7 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS

SUMMARY

3.6.4.2, SECONDARY CONTAINMENT ISOLATION VALVES L1 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in MODE 4.

L2

_______I L3 L4 L5 The ITS includes a Note that allows penetration flow paths to be unisolated intermittently under administrative controls, if they were closed to comply with actions.

The CTS does not provide any time to restore one inoperable secondary containment isolation valve in a penetration to Operable status if it is found to be inoperable. The CTS requires the plant to be in essentially cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if a secondary containment isolation valve is inoperable. In the ITS, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is allowed to isolate the affected secondary containment penetration prior to the commencement of a plant shutdown.

3.6.4.2 Required Action C.2 3.6.4.2 ACTIONS Note 1

3.6.4.2 ACTION A

3.7.C.2 NIA 3.7.C.2 5

-i1 t

i The CTS does not provide any time to restore both inoperable secondary containment isolation valves in a 3.6.4.2 ACTION 3.7.C.2 penetration to Operable status if they are found to be inoperable. The CTS requires the plant to be in essentially B

cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if any secondary containment isolation valves are inoperable. In the ITS, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is allowed to isolate the affected secondary containment penetration prior to the commencement of a plant shutdown.

The CTS requires the Reactor Coolant System to be vented in order for secondary containment isolation valves to N/A not be required. The ITS does not include this requirement.

L6 Not used.

The CTS/RETS stipulates a "simulated" automatic actuation test of the SCIVs shall be performed. The ITS allows for use of an "actual" isolation signal, in addition to the simulated automatic isolation signal, for verifying that each SCIV actuates on an automatic isolation signal.

Adds ITS ACTIONS Note "Separate Condition entry is allowed for each penetration flow path."

N/A N/A SR 3.6.4.2.3 Table 4.2-1 Note 7, RETS Table 3.10-2 Note 7

-I I

t 3.6.4.2 N/A 4

3.6.4.2 ACTIONS Note 2

JAFNPP 6

4 L7 L8 2

N/A 3

PAGE 8 I

I I

3.7.C.1.b N/A

TABLE L -LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L9 In the CTS, if secondary containment is inoperable (due to SCIV inoperability) during movement of irradiated fuel, 3.6.4.2 Required N/A 5

or during CORE ALTERATIONS, while operating in MODE 1, 2, or 3, CTS requires plant shutdown and cooldown Actions D.A actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (CTS 3.7.C.1.a and 3.7.C.l.b) in addition to suspension of CORE ALTERATIONS and Note suspension of movement of irradiated fuel (CTS 3.7.C.1.c and CTS 3.7.C.1.d respectively). In ITS the addition of the Note to ITS 3.6.4.2, Required Action D.1, precludes entry into ITS 3.0.3 (and thus the plant shutdown Actions of ITS 3.0.3 are not available) while ITS 3.6.4.2 Required Action A.1 or Required Action B.1, allow plant operation to continue for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , respectively, prior to entering any action that requires plant shutdown and cooldown (ITS 3.6.4.2 ACTION C).

3.6.4.3, STANDBY GAS TREATMENT SYSTEM Li The CTS prohibits irradiated fuel handling operations and operations that could reduce the shutdown margin (i.e.,

3.6.4.3 Required N/A 5

CORE ALTERATIONS) if the inoperable SGT subsystem is not restored to Operable status within the allowed Action C.1 completion time. In the ITS, in lieu of suspending these activities, the option exists to place the OPERABLE SGT subsystem in operation.

L2 Not used.

N/A N/A N/A L3 The CTS requires the Reactor Coolant System to be vented in order for the SGT system to not be required. The N/A 3.7.C.l.b 2

ITS does not include this requirement.

L4 The CTS/RETS stipulates a "simulated" automatic actuation test of the SGT subsystems shall be performed. The SR 3.6.4.3.3 Table 4.2-1 Note 3

ITS allows for use of an "actual" isolation signal, in addition to the simulated automatic isolation signal, for verifying 7, 4.7.B.1.d, RETS that each SGT subsystem actuates on an automatic initiation signal.

Table 3.10-2 Note f

L5 Not used.

N/A N/A N/A CTS 3.7.A.3, CONTAINMENT PURGE THROUGH THE STANDBY GAS TREATMENT SYSTEM NONE NONE NONE NONE NONE PAGE 9 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 10

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.7 - PLANT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.7.1, RHRSW SYSTEM Li The CTS allows operation to continue for 30 days with one RHR service water pump N/A 3.5.B.2, 3.5.B.3 4

inoperable provided that during such 30 days all remaining components of the containment cooling mode subsystems are operable. This means that all four RHR pumps are OPERABLE as well as the remaining RHR service water pumps. The ITS does not include this requirement, since other LCOs and ACTIONS contain the proper actions to take if other components of the containment cooling mode become inoperable.

L2 The CTS does not provide specific ACTIONS for two Residual Heat Removal (RHR) service 3.7.1 3.0.C 6

water subsystems inoperable for reasons other than one inoperable pump in each subsystem.

ACTION D Thus, a shutdown is required by CTS 3.0.C and the plant must be placed in a cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, when both RHRSW subsystems are inoperable for reasons other than one pump in each subsystem inoperable, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is allowed to restore one RHR service water subsystem to OPERABLE status.

L3 The CTS requires that the reactor be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the ACTIONS 3.7.1 3.5.B.4 6

for RHRSW inoperabilities cannot be satisfied. The ITS extends the time allowed for the plant Required to be in MODE 4 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Action E.2 L4 The CTS requires the remaining components of the containment cooling mode subsystems to N/A 4.5.B.2, 4.5.B.3 4

be verified to be operable immediately and daily thereafter when an RHRSW component is inoperable. These explicit verifications have all been deleted.

L5 The CTS requires that each RHRSW subsystem "valve (manual, power operated, or SR 3.7.1.1 4.5.B.1.e 3

automatic) in the flowpath that is not locked, sealed or otherwise secured in position, is in the correct position" once per 31 days. The ITS requires that "each RHRSW manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position" every 31 days.

The proposed change permits the RHRSW subsystem to be considered OPERABLE as long as the valves can be manually realigned to their correct position.

3.7.2, ESW SYSTEM and UHS PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.7 - PLANT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The CTS requirement for actuation testing of the ESW System stipulates a simulated SR 3.7.2.7 4.11.D.1.a 3

automatic actuation test shall be performed. The phrase "actual or," in reference to the automatic initiation signal, has been added to the ITS Surveillance Requirement for verifying that the ESW System actuates on an automatic initiation signal. This allows satisfactory automatic system initiations to be used to fulfill the Surveillance Requirement.

L2 The CTS requires the Emergency Diesel Generator System emergency loads be verified N/A 3.11.D.2 4

Operable immediately and at least daily thereafter if the ESW System is inoperable. These explicit verifications have all been deleted.

L3 The CTS requires that the reactor be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the ACTIONS 3.7.2 3.11.D.3, 3.0.C 6

for ESW and Ultimate heat sink inoperabilities cannot be satisfied. The ITS extends the time Required allowed for the plant to be in MODE 4 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Action C.2 L4 The CTS requires the Emergency Diesel Generator (EDG) System be demonstrated Operable 3.8.1 3.11.D.2 4

immediately and at least daily thereafter if the ESW System is inoperable. These explicit Required verifications have all been deleted. The ITS will only require a single verification (through the Actions B.3.1 EDG Technical Specification ACTIONS) of EDG Operability, either through an evaluation or and B.3.2 demonstration, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

L5 The CTS requirement to monitor individual heater current whenever large deviations are N/A 4.11.E.2 3

identified in the feeder checks has been deleted.

3.7.3, CREVAS SYSTEM Li The CTS requires the main control room emergency ventilation air supply system capacity to SR 3.7.3.3 4.11.A.5 3

be tested every 18 months to assure that it is within 10% of the design value of 1000 cfm. The ITS will allow the test to be performed on a STAGGERED TEST BASIS, such that each subsystem is tested every 36 months instead of the current 18 months.

3.7.4, CONTROL ROOM AC SYSTEM NONE NONE NONE NONE NONE PAGE 2 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.7 - PLANT SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.7.5, MAIN CONDENSER STEAM JET AIR EJECTOR OFFGAS Li The RETS requires the plant to isolate the SJAE or all main steam lines within the next 12 3.7.5 N/A 4

hours if the SJAE release rate is not below the trip level within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The ITS includes an Required additional option allowing the plant to be in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 Actions B.3.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , in lieu of isolating the SJAE or main steam lines, and B.3.2 L2 The RETS 3.5.a (LCO) specifies that the limits of gross radioactivity rate of noble gases is LCO 3.7.5, RETS 3.5.a given on Table 3.10-1. RETS Table 3.10-1 specifies the trip level setting for the SJAE SR 3.7.5.1 (LCO section),

Radiation Monitors as 500,000 pCi/sec. This LCO limit has been increased from 500,000 to RETS Table 600,000 kCi/sec consistent with the value used in the Offgas System Failure accident of 3.10-1 UFSAR, Section 11.4.7.2.

L3 The RETS requires that the Survelilance that determines the gross gamma activity rate is SR 3.7.5.1 RETS 3.5.a (SR 3

within limit must be current prior to entry into the mode of applicability in accordance with CTS Note section) 3.0.D. In the ITS, a Note clarifies when the surveillance must be performed. The Note specifies that the surveillance is not required to be performed until 31 days after any main steam line is not isolated and the SJAE are in operation since in this condition radioactive fission gases may be in the Main Steam Offgas System at significant rates.

3.7.6, MAIN TURBINE BYPASS SYSTEM NONE NONE NONE NONE NONE 3.7.7, SPENT FUEL STORAGE POOL WATER LEVEL Li The CTS requires the spent fuel storage pool level to be greater than or equal to the minimum 3.7.7 3/4.1 0.C 2

level whenever irradiated fuel is stored in the spent fuel storage pool. The ITS Applicability is Applicability during movement of irradiated fuel assemblies in the spent fuel storage pool, consistent with the assumptions of the bounding design basis refueling accident described in UFSAR, Section 12.2A.6 Event 10 and UFSAR, Section 14.6.1.4.

L2 The CTS requires the spent fuel storage pool level to be recorded daily. The ITS requires the SR 3.7.7.1 4.10.C 3

_ verification of the spent fuel storage level every 7 days._I

_1___

PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.7 - PLANT SYSTEMS CHANGE TYPE Relaxation of LCO Requirement Relaxation of Applicability Relaxation of Surveillance Requirement Relaxation of Required Action Detail Relaxation of Required Actions to Exit Applicability Relaxation of Completion Time Allow Mode Changes When LCO Not Met Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel Elimination of CTS Reporting Requirement JAFNPP

1.

2.

3.

4.

5.

6.

7.

8.

9.

PAGE 4 I

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.8.1, AC SOURCES - OPERATING Li The CTS does not provide a specific Action for the condition of one inoperable offsite circuit 3.8.1 ACTION N/A 5

and one inoperable EDG subsystem. Therefore, if this Condition existed the plant would be D

required to enter LCO 3.0.C and place the plant in cold shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS includes a new ACTION that provides 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore either the inoperable EDG or the inoperable offsite circuit in this condition prior to requiring a plant shutdown.

L2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 3.8.1 3.9.B.1, 3.9.B.2, 6

4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in Mode 4.

Required 3.9.B.3, 3.9.B.4, Action F.2 3.0.E L3 The CTS requires that each EDG subsystem be force paralleled and loaded to 5200 kW, and SR 3.8.1.3 4.9.B.1 3

load sharing capability checked. The ITS will require each EDG subsystem be paralleled with normal, reserve, or backfeed power and each EDG be loaded and operated at a load Ž 2340 kW and

2600 kW. Thus the change essentially provides a load range of 2340 kW to 2600 kW (and does not use the term "load sharing"), whereas the CTS required a specific limit of 2600 kW per EDG.

L4 The CTS stipulates a simulated automatic actuation test to demonstrate that the pair of diesel SR 3.8.1.9, 4.9.B.4 3

generators will start, accelerate, force parallel, and accept the emergency loads in the SR 3.8.1.10, prescribed sequence. The ITS allows for use of an "actual" automatic initiation signal, in SR 3.9.1.12 addition to the simulated automatic actuation signal, for verifying that each EDG starts on an automatic initiation signal.

L5 The CTS provides a Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when an EDG subsystem is inoperable to 3.8.1 4.9.B.5 6

demonstrate, by manual start and force paralleling, the availability of the OPERABLE EDG Required subsystem or determine that the inoperability is due to preplanned maintenance or testing, an Actions B.3.1 inoperable support system with no potential common mode failure, or an independently and B.3.2 testable component with no potential common mode failure. In the ITS, the Completion Time has been extended to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify the remaining EDG is not inoperable due to a common cause failure.

PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L6 The CTS has an action that allows for operation to continue for 60 days with one inoperable N/A 3.9.C.2.a fuel oil transfer pump associated with a Diesel Generator subsystem provided the remaining fuel oil transfer pumps are demonstrated OPERABLE immediately and weekly thereafter.

This action implies that all EDG subsystem fuel oil transfer pumps are required to be Operable. Each individual diesel generator is provided with an independent fuel oil system consisting of a main fuel oil storage tank, a day tank and two full-capacity motor-driven pumps which are designed to transfer fuel oil from the storage tank to the associated day tank automatically. Therefore, in the ITS, only one pump is required to be OPERABLE for each EDG, as stated in the Bases. Therefore, this specific CTS action has been deleted.

L7 CTS 3.0.E requires the plant to be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when a redundant feature 3.8.1 3.0.E 5

is inoperable and the reserve or onsite power source of a system, subsystem, train, Required component or device is inoperable. The ITS will allow: a) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite Actions A.2, power to one division concurrent with inoperability of redundant required feature(s) to declare B.2, and C.1 required feature(s) with no offsite power available inoperable when the required feature(s) are inoperable; b) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of one inoperable EDG subsystem concurrent with inoperability of redundant required feature(s) to declare the required features supported by the inoperable EDG subsystem inoperable when the redundant required feature(s) are inoperable; and c) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of two offsite circuits inoperable concurrent with inoperability of redundant required feature(s) to declare required feature(s) inoperable when the redundant required feature(s) are inoperable. The ITS provides a restoration time whereas the CTS did not allow any restoration time, and the ITS allows the affected features to be declared inoperable and to take the actions of the individual Specifications in lieu of the automatic shutdown required by the CTS.

L8 The ITS includes a Note that allows gradual loading of the EDG as recommended by the SR 3.8.1.3 N/A 3

manufacturer during the monthly load test.

Note 1 L9 The ITS includes a Note that allows momentary load transients to be outside the load range SR 3.8.1.3 N/A 3

and not invalidate performance of the monthly load test.

Note 2 3.8.2, AC SOURCES - SHUTDOWN PAGE 2 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The CTS requires, when the required EDG subsystem and offsite power source are not 3.8.2 3.9.D 4

Operable, suspension of all work that could cause draining of the reactor vessel, suspension ACTIONS A of core alterations, suspension of handling of irradiated fuel assemblies in the secondary and B containment, initiating action to restore the inoperable AC source, and declaring required core and containment systems inoperable. In the ITS, when an offsite circuit is inoperable, the option of either suspending the above activities (and immediately initiating action to restore the offsite circuit to Operable status) or declaring the associated equipment that is not receiving offsite power inoperable is provided. In addition, when the EDG is inoperable, the option to declare the associated equipment inoperable is not allowed.

3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Li The CTS allowance, to continue reactor operation indefinitely, if the affected fuel oil storage N/A 3.9.C.1 1

tank level is manually measured at least once per day when the fuel oil storage tank level indicator is found to be inoperable for any reason, is not retained in the ITS, since the fuel oil storage tank indicator is not an attribute of fuel oil Operability (the ITS requires the fuel oil level to be determined -the manner in which this is performed is not required to be specified in the ITS).

L2 The CTS allows that, if the available diesel fuel decreases below the required quantity as a 3.8.3 ACTION 3.9.C.3 4

result of operation of the diesel generators to meet Technical Specification requirements, A

Specification 3.0.C does not apply, and 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months are allowed to restore the required diesel fuel supply. In the ITS, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is provided to restore the diesel fuel supply to within limits, regardless of the reason it is not within limits.

L3 The CTS requires the EDG starting air compressor to be checked for operation and its ability N/A 4.6.B.2 1,3 to recharge air receivers. In the ITS, only the air receiver pressure is required to be verified to be within limits. The manner in which the air receivers are recharged is not an attribute of starting air Operability.38 4 D S U E -O R

I 3.8.4, DC SOURCES - OPERATING PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE D

TYPE Li The CTS requires the pilot cell voltage, specific gravity, overall voltage, and temperature to be N/A 3.9.E.2.b, 3

measured immediately and daily thereafter for the Operable battery and requires the 3.9.E.2.c, availability of the unaffected Emergency Diesel Generator System to be demonstrated, when 3.9.F.2.b one 125 VDC battery is inoperable. Similarly, the CTS requires the performance of additional Surveillances on the Operable LPCI MOV independent power supply subsystem if one LPCI MOV independent power supply subsystem is inoperable. These verifications are not required in the ITS.

L2 Not used.

N/A N/A N/A L3 The CTS allows power operation to continue with an inoperable 125 VDC battery if the N/A 3.9.E.2.a, 4

distribution system associated with the Operable 125 VDC electrical power subsystem battery 3.9.F.2.a is Operable. Similarly, the CTS allows power operation to continue with an inoperable LPCI independent power supply if the inverter and distribution system associated with the Operable LPCI independent power supply is Operable. The ITS does not retain these explicit requirements, since other Technical Specifications adequately control the Operability of the distribution subsystems.

L4 No actions are provided in the CTS for when a 125 VDC battery charger is inoperable; thus a 3.8.4 ACTION N/A 5

plant shutdown to cold shutdown is required. In the ITS, a new ACTION (encompassed by the A

inoperable 125 VDC source ACTION) is provided to allow one charger to be inoperable for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to requiring a plant shutdown.

L5 The CTS requirement to open the battery charger output breakers once per month and N/A 4.9.E.7 3

observe performance for proper operation has been deleted since the 125 VDC battery charger output breaker is not required to open during any accident sequence.

L6 The CTS requires that if one independent power supply becomes inoperable, the inoperable independent power supply must be isolated from its associated LPCI MOV bus, and this bus be manually switched to its alternate power source. If this cannot be met, a plant shutdown to cold shutdown is required. This requirement is not maintained in the ITS since the CTS allows a 7 day Completion Time for any other LPCI subsystem inoperability with no other compensatory actions.

I PAGE 4 JAFNPP 4

N/A 4.9.F.2.c

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L7 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 3.8.4 3.9.E, 3.9.F.3, 6

4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in Mode 4. In addition, Required 3.9.F.2 the CTS requires the plant to be in cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if both LPCI MOV Actions B.2 Independent Power Supplies are inoperable. In the ITS, the associated LPCI subsystems and C.1 must be declared inoperable, and once declared inoperable, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is provided to place the plant in Mode 4.

L8 The CTS requirement to perform CTS 4.9.E.3 and 4.9.E.4 during shutdown has been included SR 3.8.4.3 4.9.E.3, 4.9.E.4 3

in the ITS. However, the ITS includes an allowance that portions of the Surveillance can be SR 3.8.4.4 performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced and that credit for unplanned events can be taken to satisfy this SR.

3.8.5, DC SOURCES - SHUTDOWN NONE NONE NONE NONE NONE 3.8.6, BATTERY CELL PARAMETERS Li Not used.

N/A N/A N/A L2 The CTS requirement to measure electrolyte temperature of each pilot cell every 7 days is not N/A 4.9.E.1, 4.9.F.1 3

being included in the ITS.

L3 The CTS requirement to measure the temperature of every fifth cell every 92 days, is being SR 3.8.6.3 4.9.E.2.c, 3

changed. The ITS requires the average electrolyte temperature of representative cells (10%

4.9.F.2.c of the total) be verified within limits every 92 days. This change reduces the number of cells tested from 12 to 6 based on a total of 60 cells in the 125 VDC batteries and from 38 to 19 based on a total of 186 cells in the 419 VDC LPCI MOV independent power supply batteries.

3.8.7, DISTRIBUTION SYSTEMS - OPERATING PAGE 5 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE No actions are provided in the CTS for when an AC or 125 VDC distribution bus is inoperable; 3.8.7 N/A 5

thus a plant shutdown to cold shutdown is required. In the ITS, new ACTIONS are provided ACTIONS A to: a) allow AC distribution buses to be inoperable for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , provided a loss of and B function does not occur, prior to requiring a plant shutdown; and b) allow one 125 VDC distribution bus to be inoperable for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to requiring a plant shutdown. In addition, a maximum time the LCO cannot be met is also provided (16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months ).

When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 3.8.7 3.0.C 6

4) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the ITS, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months are provided to place the plant in Mode 4.

Required Action C.2 3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN NONE NONE NONE NONE NONE CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement PAGE 6 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.9 - REFUELING OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.9.1, REFUELING EQUIPMENT INTERLOCKS Li The CTS requires a functional test required following any repair work associated with the N/A 4.10.A.1 3

interlock. This specific post maintenance testing is not retained in the ITS.

L2 The CTS Applicability for the refueling interlocks is "during Core Alterations". The ITS 3.9.1 3.10.A.1 2,4 Applicability is "during in-vessel fuel movement with equipment associated with the interlocks Applicability, when the reactor mode switch is in the refuel position". The ITS Applicability requires that the 3.9.1 refueling equipment interlocks be Operable only during those situations when the interlocks Required are assumed to operate to prevent inadvertent criticality, i.e., in-vessel fuel movement with Actions A.1 equipment associated with the interlocks when the reactor mode switch is in the refuel and A.2 position. In addition, a new default ACTION has been added for the condition when one or more required refueling equipment interlocks are inoperable. Two options are provided; a) the immediate suspension of in-vessel fuel movement with equipment associated with the inoperable interlocks, or b) the immediate insertion of a control rod withdrawal block and the immediate verification that all control rods are fully inserted.

L3 The CTS requires the refueling interlocks be functionally tested prior to any fuel handling with N/A 4.10.A.1 3

the head off and at a weekly interval thereafter. The ITS does not include the "prior to" frequency since it is redundant to the SR 3.0.1 requirements.

3.9.2, REFUEL POSITION ONE-ROD-OUT INTERLOCK Li The CTS Applicability for the one-rod-out interlock is "during Core Alterations". The ITS 3.9.2 3.10.A.1 2

Applicability is "MODE 5 with the reactor mode switch in the refuel position and any control Applicability rod withdrawn." The ITS Applicability requires that the "one-rod-out interlock" be operable only during those situations when the interlock is assumed to operate to prevent inadvertent criticality, i.e., the mode switch in refuel and any control rod withdrawn.

L2 The CTS requires the one-rod-out interlock be functionally tested prior to any fuel handling SR 3.9.2.2 4.1O.A.1 3

with the head off and at a weekly interval thereafter. The ITS includes a Note that allows Note deferring the performance of this functional test "until one hour after any control rod is withdrawn." This allowance is necessary because the test is performed by entering the applicable condition (i.e., a control rod must be withdrawn from its full-in position) and attempting to withdraw a second control rod.

PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.9 - REFUELING OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L3 The CTS requires a functional test required following any repair work associated with the N/A 4.10.A.1 3

interlock. This specific post maintenance testing is not retained in the ITS.

L4 The CTS requires the refueling interlocks be functionally tested prior to any fuel handling with N/A 4.10.A.1 3

the head off and at a weekly interval thereafter. The ITS does not include the "prior to" frequency since it is redundant to the SR 3.0.1 requirements.

3.9.3, CONTROL ROD POSITION NONE NONE NONE NONE NONE 3.9.4, CONTROL ROD POSITION INDICATION NONE NONE NONE NONE NONE 3.9.5, CONTROL ROD OPERABILITY - REFUELING NONE NONE NONE NONE NONE 3.9.6, REACTOR PRESSURE VESSEL WATER LEVEL NONE NONE NONE NONE NONE 3.9.7, RESIDUAL HEAT REMOVAL - HIGH WATER LEVEL NONE NONE NONE NONE NONE 3.9.8, RESIDUAL HEAT REMOVAL - LOW WATER LEVEL PAGE 2 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.9 - REFUELING OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE NONE NONE NONE NONE NONE CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement

10.

Relaxation of Surveillance Frequency from 18 Months to 24 Months JAFNPP PAGE 3

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.10- SPECIAL OPERATIONS DOC#

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION Li The CTS requires the inservice leak and hydrostatic testing operations to be suspended immediately when the 3.10.1 3.12.A.6 4,5 requirements of CTS 3.12.A are not met. The ITS includes an alternative action to allow entry into the applicable ACTIONS Note, Conditions of the affected LCO if any requirement of ITS LCO 3.10.1 is not met. In addition, a Note has been 3.10.1 Required added to clarify that if an affected Specifications ACTIONS state to be in MODE 4, this includes reducing average Action A.1, coolant temperature to !5 212 OF. Along with this change a NOTE has been added to the ACTIONS Table which including Note allows separate Condition entry for each requirement of the LCO. In conjunction with proposed Specification 1.3 "Completion Times," the Note ("Separate condition entry...") and the Conditions of ITS 3.10.1 provide more explicit direction for the use of the ITS.

L2 The CTS requires the plant to immediately reduce coolant temperature to less than 212°F whenever any 3.10.1 Required 3.12.A.6 5

requirement of CTS 3.12.A is not met. The ITS requires the reduction in reactor coolant temperature to _<

2120OF.

Action A.2.2 The Applicability of this Specification is when reactor coolant temperature is > 212 0F, therefore, reducing the coolant temperature as specified in the ITS places the plant outside the Applicability of this Specification.

3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING Li ITS 3.10.2 is added to allow reactor mode switch interlock testing to be conducted by placing the reactor mode 3.10.2 N/A 1

switch in run, startup/hot standby, or refuel as applicable, while in MODES 3, 4, or 5 and not consider the plant to be in MODE 1 or 2, as applicable. This testing can proceed only if there are no Core Alterations in progress, and if all control rods remain fully inserted in core cells containing one or more fuel assemblies. When these two conditions are met, the situation is equivalent to maintaining the reactor mode switch in shutdown. Control rods are not required to be inserted in empty core cells (i.e., those containing no fuel) because, with one or more core cells in this configuration, the Shutdown Margin is actually greater than when all control rods and all fuel assemblies are inserted.

3.10.3, SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN JAFNPP PAGE 1

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.10 - SPECIAL OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li ITS 3.10.3 has been added to allow the reactor mode switch to be placed in the refuel position, allow a single 3.10.3 N/A control rod to be withdrawn, and still be considered to be in MODE 3, provided certain MODE 5 requirements are met. Currently, rods are not allowed to be withdrawn while in MODE 3. These additional requirements ensure that the one-rod-out interlock is Operable so that: 1) only the one rod is withdrawn, 2) all other control rods are fully inserted, and 3) RPS and control rod MODE 5 operability requirements are met or all other rods in a 5 x 5 array centered on the withdrawn rod are disarmed, allowing a modification to the way in which SDM is met. These additional requirements effectively compensate for the reactor mode switch not being in the shutdown position with a rod withdrawn.

3.10.4, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN Li ITS 3.10.4 has been added to allow the reactor mode switch to be placed in the refuel position, allow a single 3.10.4 N/A control rod to be withdrawn and its associated control rod drive removed, and still be considered to be in MODE 4, provided certain MODE 5 requirements are met. Currently, rods are not allowed to be withdrawn while in MODE 4.

These additional requirements ensure that the one-rod-out interlock is Operable or a control rod withdrawal block is inserted so that: 1) only the one rod is withdrawn, 2) all other control rods are fully inserted, and 3) RPS and control rod operability MODE 5 requirements are met or all other rods in a 5 x 5 array centered on the withdrawn rod are disarmed, allowing a modification to the way in which SDM is met. These additional requirements effectively compensate for the reactor mode switch not being in the shutdown position with a rod withdrawn.

3.10.5, SINGLE CONTROL ROD DRIVE REMOVAL - REFUELING JAFNPP PAGE 2

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.10 - SPECIAL OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The CTS requires the reactor mode switch to be locked in the refuel position and all refueling interlocks operable LCO 3.10.5 3.10.D.1.a, 1,3 except for those necessary to perform the demonstration and maintenance described in CTS 4.1 0.D.1 when two 4.10.D.1.a control rods are withdrawn to perform maintenance. The ITS will allow the requirements of LCO 3.9.1, "Refueling Equipment Interlocks"; LCO 3.9.2, "Refuel Position One-Rod-Out Interlock"; and LCO 3.9.4, "Control Rod Position Indication" be suspended in MODE 5 to allow the removal of a single CRD associated with a control rod withdrawn from a core cell containing one or more fuel assemblies, provided the following requirements are met: 1) all other control rods are fully inserted (as modified by DOC M1); 2) all other control rods in a five by five array centered on the withdrawn control rod are disarmed (as modified by DOC M2); 3) a control rod withdrawal block is inserted and LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," MODE 5 requirements, may be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod (as modified by DOC L2); and 4) no other CORE ALTERATIONS are in progress (as modified by DOC A2). This ITS LCO will not require the Operability of any refueling interlock and will not require the mode switch to be locked in the refuel position. In addition, since the requirements of ITS LCOs 3.9.1 and 3.9.2 may be suspended during the application of this Special Operations LCO, the associated Surveillances of these LCOs are not applicable; therefore, the CTS requirement to perform the Surveillance Requirements of CTS 4.10.A.1 have also been deleted.

L2 The CTS requires the performance of a shutdown margin (SDM) demonstration and that adequate margin is LCO 3.10.5.c, 3.10.D.1.b, 1, 3 maintained during the maintenance with the analytically determined strongest worth operable control rod fully SR 3.10.5.4 4.10.D.1.b withdrawn. This demonstration shall be performed after CTS 3.10.D.1 has been satisfied, but prior to the withdrawal of the control rods for maintenance. The CTS also allows up to two control rods with fuel assemblies loaded into the associated core cells to be withdrawn. Therefore, adequate SDM should be maintained throughout the maintenance work with these two rods and the analytically determined strongest worth operable control rod withdrawn. The SDM demonstration is currently required to be performed prior to performing any maintenance.

The ITS requires SR 3.1.1.1, the SDM verification, to be performed in accordance with its associated surveillance frequency. The ITS allows withdrawal of only one control rod from core cells containing fuel (as modified by DOC M1). Withdrawal/removal of multiple control rods is only allowed in accordance with ITS 3.10.6, and then, only if all four fuel assemblies have been removed from the core cells associated with each control rod or control rod drive being removed. ITS SR 3.1.1.1 requires SDM to be verified to be within limits prior to each in-vessel fuel movement during a fuel loading sequence and once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after criticality following fuel movement within the reactor pressure vessel or control rod replacement. In addition, the ITS 3.10.5.c allows the SDM verification to be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod. This change is less restrictive in two ways. SDM can be verified in accordance with the Frequency of SR 3.1.1.1 instead of demonstrated prior to maintenance and the verification can be met by allowing the single control rod to be withdrawn to be assumed to be the highest worth control rod.

PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.10 - SPECIAL OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L3 The ITS includes an allowance to suspend the requirements for automatic scram capability during control rod and LCO 3.10.5 N/A control rod drive maintenance. The ITS explicitly states that the requirements of LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation"; LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring"; and LCO 3.9.5, "Control Rod OPERABILITY" may be suspended in MODE 5 to allow the removal of a single control rod sequent removal associate CRD associated with a control rod withdrawn from a core cell containing one or more fuel assemblies provided: 1) all other control rods are fully inserted (as modified by DOC M1); 2) all other control rods in a five by five array centered on the withdrawn control rod are disarmed (as modified by DOC M2); 3) a control rod withdrawal block is inserted and LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," MODE5 requirements, may be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod (as modified by DOC L2); and 4) no other CORE ALTERATIONS are in progress.

3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING Li During the removal or withdrawal of multiple control rods during refueling, the CTS requires the reactor mode LCO 3.10.6 3.10.A.5.a, switch to be locked in the Refuel position and the refueling interlocks associated with all control cells containing fuel 3.10.A.5.c, are Operable. In addition, the CTS requires the refueling interlocks to be Operable for any control cell which 3.1 0.A.6.a, contains fuel during spiral off-load or on-load. These requirements are not included in the ITS. ITS only requires 3.10.A.7.d that the reactor be in MODE 5 (mode switch in either shutdown or refuel) while the full-in position signal is defeated for multiple control rods that are withdrawn or removed.

3.10.7, CONTROL ROD TESTING - OPERATING Li ITS 3.10.7 has been added to allow LCO 3.1.6, "Rod Pattern Control," to be suspended to allow performance of 3.10.7 N/A SDM testing, control rod scram time testing, and control rod friction testing, provided the banked position withdrawal sequence (BPWS) requirements of SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequence; or the RWM is bypassed, the requirements of LCO 3.3.2.1, Function 2 are suspended, and conformance to the approved control rod sequence for the specified test is verified by a second licensed operator or reactor engineer. These two requirements for the Special Operation effectively limit the potential amount and rate of reactivity increase that could occur during a control rod drop accident (CRDA). An appropriateACTION andSurveillanceRequirement have also been added.

3.10.8, SHUTDOWN MARGIN TEST - REFUELING PAGE 4 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX SECTION 3.10 - SPECIAL OPERATIONS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The allowances in CTS 3.6.E.3 (S/RVs) to allow the equipment to be inoperable during low power physics tests 3.10.8 3.6.E.3, 3.5.6.5, 2

provided that reactor coolant temperature is < 212°F and the reactor vessel is vented (see M2) or the reactor Applicability 3.7.A.2, 3.7.A.4, vessel head is removed has been changed to MODE 5 with the reactor mode switch in startup/hot standby position 3.7.A.5, 3.7.D.1, (ITS 3.10.8 Applicability). In addition, the allowances in CTS 3.5.B.5 to allow component(s) of the Containment 3.2.A, Table 3.2-1 Cooling Mode of the RHR System to be inoperable during low power physics tests provided that reactor coolant Note 1 temperature is < 212°F has been changed in a similar manner. Similar changes have been made to Specifications associated with the primary containment (CTS 3.7.A.2), reactor building-to-suppression chamber vacuum breakers (CTS 3.7.A.4), suppression chamber-to-drywell vacuum breakers (CTS 3.7.A.5), primary containment isolation valves (CTS 3.7.D.1), and primary containment isolation functions (CTS 3.2.A and Table 3.2-1 Note 1). In these Specifications, explicit reference that the test must be performed at atmospheric pressure and at power levels not to exceed 5 MWt has been deleted. These changes are less restrictive in two ways: a) the first change deletes the explicit requirement to maintain reactor coolant temperature < 212°F; and b) the second change involves a change in the definition made to the definition of the refuel mode.

L2 The CTS requires equipment to be Operable during startup. There is no explicit definition of startup in the CTS 1.0, 3.10.8 3.5.A, 3.5.J, 3.6.B, however, there is a definition for startup/hot standby. This definition has been modified as MODE 2 in the ITS as 3.6.G, 3.3.6.3, discussed in the Discussion of Changes for ITS Chapter 1.0. However, in the CTS, whenever the mode switch is 3.3.A placed in the startup/hot standby position all Technical Specification equipment required during startup must be Operable. ITS 3.10.8 allows the mode switch to be placed in startup/hot standby while the plant can still be considered to be in MODE 5 to allow SDM testing (which requires more than one control rod to be withdrawn),

provided certain MODE 2 requirements are met. This change is less restrictive since certain CTS requirements will not be required to be operable to perform this Special Operations LCO. ITS 3.10.8 will additionally require the following requirements to be met: (a) LCO 3.3.1.1, "Reactor Protection System Instrumentation", MODE 2 requirements for Functions 2.a and 2.d of Table 3.3.1.1-1 (as modified by DOC A4); (b) LCO 3.3.2.1, "Control Rod Block Instrumentation", MODE 2 requirements for Function 2 of Table 3.3.2.1-1, with the Banked Position Withdrawal Sequence requirements of SR 3.3.2.1.8 changed to require the control rod sequence to conform to the SDM test sequence, or conformance to the approved control rod sequence for the SDM test is verified by a second licensed operator or other qualified member of the technical staff; (c) each withdrawn control rod shall be coupled to the associated CRD; (d) all control rod withdrawals during out of sequence control rod moves shall be made in notch out mode; (e) no other CORE ALTERATIONS are in progress; and (f) CRD charging water header pressure

> 940 psig._Also,_appropriateACTIONS andSurveillanceRequirements have been added.

JAFNPP PAG E 5

TABLE L -LESS RESTRICTIVE CHANGES MATRIX SECTION 3.10 - SPECIAL OPERATIONS CHANGE TYPE 1,

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 6

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 4.0 - DESIGN FEATURES DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The ITS includes an allowance for a limited number of lead test assemblies that have not 4.2.1 N/A completed representative testing to be placed in non-limiting core regions. This allowance provides recognition of a specific kind of special test with lead test assemblies that may be performed.

L2 The CTS requires that each fuel assembly consist of Zircaloy clad fuel rods. The ITS also 4.2.1 5.2.1 allows the use of either Zircaloy or ZIRLO clad fuel rods. The allowance to use either Zircaloy or ZIRLO clad fuel rods has been generically approved by the NRC. In addition, prior to use of ZIRLO fuel clad, the ITS requires that JAFNPP analyze the fuel design using NRC approved codes and methods and also ensure that the fuel design complies with all safety design bases.

CHANGE TYPE

1.

Relaxation of LCO Requirement

2.

Relaxation of Applicability

3.

Relaxation of Surveillance Requirement

4.

Relaxation of Required Action Detail

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE 5.1, RESPONSIBILITY NONE NONE NONE NONE NONE 5.2, ORGANIZATION Li Not used.

N/A N/A N/A 5.3, PLANT STAFF QUALIFICATIONS NONE NONE NONE NONE NONE 5.4, PROCEDURES NONE NONE NONE NONE NONE 5.5, PROGRAMS ANDMANUALS L1 The CTS requirement that certain SGT System filter tests be performed at a Frequency of "at N/A 4.7.B.1.b 3

least once during each scheduled secondary containment leak rate test," is not retained in the ITS.

L2 The CTS CREVAS filter bank pressure drop tests, HEPA filter in-place DOP tests, and the 5.5.8 4.7.B.1.b, 3

charcoal adsorber in-place bypass leakage tests and the SGT System HEPA filter in-place 4.11.A.1 DOP tests and the charcoal adsorber in-place bypass leakage tests have been extended from 6 months to 24 months.

L3 The CTS requires that the SGT pressure drop test be performed at a flowrate of 6,000 scfm.

5.5.8.d 4.7.B.1.a(1) 3 TheITS requires that this test be performed at a flowrate of_5400 to_6600_scfm.

PAGE 1 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L4 The ITS provides an allowance for the application of SR 3.0.3 to the IST Program 5.5.7 N/A 4

requirements. This change, which applies SR 3.0.3 to the existing requirements, allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the required testing (or inspection) of equipment if it was not performed within the specified Frequency.

L5 The ITS includes a statement of applicability of ITS SR 3.0.2 and SR 3.0.3 to the Primary 5.5.2 N/A 3, 4 Coolant Sources Outside Containment Program. This change applies SR 3.0.2, which allows a maximum allowable extension not to exceed 25 percent of the specified Surveillance interval and SR 3.0.3, which allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the required testing (or inspection) of equipment if it was not performed within the specified Frequency.

L6 The ITS includes a statement of applicability of ITS SR 3.0.2 and SR 3.0.3 to the Storage 5.5.9 N/A 3, 4 Tank Radioactivity Monitoring Program. This change applies SR 3.0.2, which allows a maximum allowable extension not to exceed 25 percent of the specified Surveillance interval and SR 3.0.3, which allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the required testing (or inspection) of equipment if it was not performed within the specified Frequency.

L7 The CTS requirement to perform a pressure drop test across each filter in the Main Control N/A 4.11.A.1.a 3

Room Ventilation system is being deleted.

5.6, REPORTING REQUIREMENTS Li The CTS requires that, "at least 80% of the total whole body dose received from external 5.6.1 6.9.A.2.a 1

sources shall be assigned to specific major work functions." The ITS changes the word "shall" to "should."

L2 The RETS requires that the Annual Radiological Environmental Operating Report be 5.6.2 RETS 7.3.d 1

submitted prior to May 1 of each year. The ITS requires this report to be submitted by May 15 of each year.

L3 The RETS requires that the Radioactive Effluent Release Report be submitted on a 5.6.3 RETS 7.3.c 1

semiannual basis. The ITS requires that this report be submitted in accordance with 10 CFR 50.36a. on an annual basis.

PAGE 2 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE L4 The CTS requires an annual report of safety/relief valve (S/RV) failures and challenges to be N/A 6.9.A.2.b 9

submitted prior to March 1 of each year. This specific requirement has been deleted. The NRC has stated in approving TSTF-258, Revision 4 that this specific report is not necessary.

This is an after-the-fact report and there is no requirement for the NRC to approve the report.

Completion and submittal of the report is clearly not necessary to ensure safety operation of the plant. Other Technical Specifications provide adequate actions if an S/RV fails and is inoperable.

5.7, HIGH RADIATION AREA L1 The CTS, which provides high radiation area access control alternatives pursuant to 10 CFR 5.7 6.11 (A) 1 20.203(c)(2) (revised 10 CFR 20.1601 (c)), has been significantly revised as a result of the changes to 10 CFR 20, the guidance provided in Regulatory Guide 8.38 (Control of Access to High and Very High Radiation Areas in Nuclear Power Plants), and current industry technology in controlling high radiation areas. The changes incorporated in ITS 5.7 (which are consistent with TSTF-258, Revision 4) include: a) a capping dose rate to differentiate a high radiation area from a very high radiation area, b) additional requirements for groups entering high radiation areas, and c) clarification of the need for control of workers in high radiation areas.

CTS 6.0, ADMINISTRATIVE CONTROLS NONE NONE NONE NONE NONE RETS 2.1, LIQUID EFFLUENT MONITORS NONE NONE NONE NONE NONE RETS 2.2, CONCENTRATION OF LIQUID EFFLUENTS NONE NONE INONE INONE INONE PAGE 3 JAFNPP

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE RETS 2.3, DOSE FROM LIQUID EFFLUENTS NONE NONE NONE NONE NONE RETS 2.4, LIQUID RADIOACTIVE WASTE TREATMENT SYSTEM OPERATIONS NONE NONE NONE INONE INONE RETS 3.1, GASEOUS EFFLUENT MONITORS NONE NONE NONE NONE NONE RETS 3.2, GASEOUS DOSE RATES NONE NONE INONE INONE NONE RETS 3.3, AIR DOSE, NOBLE GASES NONE NONE I NONE INONE NONE RETS 3.4, DOSE DUE TO IODINE-131, IODINE-133, TRITIUM, AND RADIONUCLIDES IN PARTICULATE FORM NONE J NONE NONE NONE NONE RETS 3.6, OFFGAS TREATMENT SYSTEM NONE NONE NONE NONE NONE JAFNPP PAGE 4

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS DOC #

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE RETS 4.0, SOLID RADIOACTIVE WASTE - PROCESS CONTROL PROGRAM NONE NONE NONE NONE NONE RETS 5.0, TOTAL DOSE - TOTAL DOSE FROM URANIUM FUEL CYCLES NONE NONE INONE NONE INONE RETS 6.1, MONITORING PROGRAM NONE NONE NONE NONE NONE RETS 6.2, LAND USE CENSUS PROGRAM NONE NONE NONE NONE NONE RETS 6.3, INTERLABORATORY COMPARISON PROGRAM NONE NONE INONE NONE NONE CHANGE TYPE

1.

2.

3.

4.

Relaxation of LCO Requirement Relaxation of Applicability Relaxation of Surveillance Requirement Relaxation of Required Action Detail JAFNPP PAGE 5

TABLE L - LESS RESTRICTIVE CHANGES MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS

5.

Relaxation of Required Actions to Exit Applicability

6.

Relaxation of Completion Time

7.

Allow Mode Changes When LCO Not Met

8.

Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown or Refuel

9.

Elimination of CTS Reporting Requirement JAFNPP PAGE 6

ATTACHMENT 5 Table LA - Removal Of Details Matrix

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 1.0 - USE AND APPLICATION ITS SECTION CTS

SUMMARY

LOCATION CHANGE CHANGE AND DOC #

SECTIO CONTROL TYPE N

PROCESS NONE NONE NONE NONE NONE NONE CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP PAGE 1

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 2.0 - SAFETY LIMITS CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP ITS SECTION CTS

SUMMARY

LOCATION CHANGE CHANGE AND DOC #

SECTIO CONTROL TYPE N

PROCESS 2.0 - LA1 6.7.(B),

The requirements that the Chief Nuclear Officer, the Director TRM 10 CFR 50.59 3

6.7.(C)

Regulatory Affairs and Special Projects, and the Chairman of the SRC be notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a safety limit is violated. The requirements that the PORC shall prepare a complete investigative report of each safety limit violation and the contents of the report.

2.0 - LA2 1.1.D The detail that the reactor water level safety limit applies when Bases Bases Control irradiated fuel is in the reactor vessel.

_I IProgram PAGE 1

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.0 - LCO AND SR APPLICABILITY ITS SECTION CTS

SUMMARY

LOCATION CHANGE CHANGE AND DOC #

SECTIO CONTROL TYPE N

PROCESS NONE NONE NONE NONE NONE NONE CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS ITS SECTION AND CTS

SUMMARY

DOC #

SECTION CHANGE CONTROL PROCESS 31..

I SHUTI"WN MARGIN 3.1.1 - LA1 4.3.A.1 Details of the method to perform the CTS 4.3.A.1 (e.g., sufficient control rods shall Bases Bases Control Program be withdrawn) and the details of the requirements in CTS 3.3.A.1 and 4.3.A.1 (e.g.,

that the shutdown margin shall be met at any time in the subsequent fuel cycle).

3.1.2, REACTIVITY ANOMALIES 3.1.2 - LAl 4.3.D Details of the method to perform the Surveillance and the purposes for the Bases Bases Control Program Reactivity Anomalies Surveillance (that the comparison will be used as the base for future reactivity anomaly checks).

q) I 'q rCNITDRO*l RA*l t3PAPII TV 0.I.

9I.J

, WJ~INII M,.L ! vu,

rJ MI u

I

1. 1uu 3.1.3 - LA1 4.3.A.2.d The requirement that an attempt should be made to fully insert a control rod if it is Plant FitzPatrick procedure 3

initially determined to be incapable of normal insertion.

Procedures control process 3.1.3 - LA2 3.3.A.2.b, Details of the methods for disarming CRDs.

Bases Bases Control Program 3

3.3.B.1 3.1.3 - LA3 4.3.A.2.f The method used to determine the position of each control rod (an instrument Bases Bases Control Program 3

check of control rod position indication).

a.

I 4.3.C.2 31.4. CONTROL ROD SCRAM TIMES The CTS requires "10% of the control rods" to be scram time tested. This has been changed to "representative sample" and the details of what constitutes a representative sample (i.e., at least 10% of the control rods) has been relocated.

_ 1_

__I_

11 11 3.1.4 -LA1 JAFNPP PAGE 1 L-I I

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS ITS SECTION AND DOC #

SUMMARY

CTS SECTION 3.1.5, CONTROL ROD SCRAM ACCUMULATORS NONE NONE NONE I....

I I

3.3.B.3.e I

I 3.1.6, ROD PATTERN CONTROL The detailed reasons for control rod patterns being equivalent to those prescribed by the BPWS (i.e., such that the drop of any in-sequence control rod would not result in a peak fuel enthalpy greater than 280 calories/gm).

Bases I

.3

.1 1

J _____

Bases Control Program q 1 7 qTA M n n 1V I It l IIrCl ON IT R OI L VS T FM J. 1.1,t, b III A LJ TL IU IUUI

UL0 01 rrI 4.4.A.2, 4.4.A.3, 4.4.A.4, 4.4.A.5 4.4.A.6, I44.A.7 3.4.C The details of the method for performing the SLC pump flow test (by recirculating demineralized water to the test tank); the details of the method for demonstrating all piping between the SLC storage tank and the pump suction is unblocked (by manually initiating the system, except the explosive valves and pump solution in the recirculation path); the details of the method for testing the explosive valves (to explode one of three primer assemblies manufactured in the same batch to verify proper function and then the replacement primer assembly to the one fired in the flow test must be from the same batch previously tested); and the details of the method for verifying flow through the SLC subsystem into the reactor pressure vessel (to test that valves, except explosive valves, not checked by the recirculation test are not clogged).

The requirements to verify the proper operation and setpoints of the relief valves and to disassemble and inspect one explosive valve.

The detailed information concerning the boron solution for the SLC storage tank, and what support components and variables are required to assure SLC OPERABILITY is maintained.

-i t

I 1ST Program 10 CFR 50.59 3

-I I

'I Bases Bases Control Program I

I i

PAGE 2 JAFNPP 3.1.6 -LA1 3.1.7 - LA1 3.1.7 - LA2 3.1.7 -LA3I INONE INONE I

I I

I NONE1*1*

I I

Bases Control Program Bases 10 CFR 50.59 IST Program Bases Control Program 1

Bases

TABLE LA -REMOVAL OF DETAILS MATRIX SECTION 3.1 - REACTIVITY CONTROL SYSTEMS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.1.7-LA4 Figure The detail that the saturation temperature of enriched sodium pentaborate solution Bases Bases Control Program 1

3.4-2 curve includes a 100F margin.

3.1.7 - LB1 4.4.C.3 The requirements to calibrate the temperature and level elements.

TRM 10 CFR 50.59 3

3.1.8, SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVES 3.1.8 - LAl 4.3.A.2.e The requirement concerning the scram discharge volume drain and vent valve IST Program 10 CFR 50.59 3

closure time criteria (30 seconds).

CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements PAGE 3 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.2 - POWER DISTRIBUTION LIMITS ITS SECTION CTS

SUMMARY

AND DOC #

SECTIO N

3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATI The details that require action be initiated within 15 minutes to restore operation to within prescribed limits are being relocated in the form of a discussion that "prompt action" should be taken to restore the parameter to within limits.

The details related to APLHGR and APLHGR limits.

1* 3 Bases Bases Bases Control Program Bases Control Program 3.2.2, MINIMUM CRITICAL POWER RATIO The CTS requirement that during reactor power operation with core flow less than 100% of rated, the MCPR operating limit shall be multiplied by the appropriate Kf as specified in the COLR (the actual value of Kf is remaining in the COLR).

The details that require action be initiated within 15 minutes to restore operation to within prescribed limits are being relocated in the form of a discussion that "prompt action" should be taken to restore the parameter to within limits.

Bases Bases Bases Control 3

Program Bases Control Program 3

J I

I _____

J ________

3.2.3, LINEAR HEAT GENERATION RATE 3.5.1 The detail that specifies that the linear heat generation rate (LHGR) is at any rod in any fuel assembly at any axial location.

3.5-1 I

I The details that require action be initiated within 15 minutes to restore operation to within prescribed limits are being relocated in the form of a discussion that "prompt action" should be taken to restore the parameter to within limits.

Bases I

.Bases Bases Control Program Bases Control Program I

j _______

.3

.7 _______

PAGE 1 JAFNPP 3.2.2 - LA1 3.2.2 - LA2 3

3.1.B 3.1.B 3.2.3 - LA1 3.2.3 - LA2 1

3 Bases r_-

I I

i i

3 1

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.2 - POWER DISTRIBUTION LIMITS CHANGE TYPE

1.

2.

3.

Details of system design and system description including design limits Description of system operation Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP PAGE 2

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

CATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.3.1.1, RPS INSTRUMENTATION 3.3.1.1 -LA1 3.3.1.1 -LA2 3.3.1.1 -LA3 3.3.1.1 -LA4 3.3.1.1 -LA5 3.3.1.1 -LA6 3.3.1.1 -LA7 3.3.1.1 -LA8 3.3.1.1 -LA9 Bases Bases Bases Bases Control Program Bases Control Program Bases Control Program Bases Bases Control Program 1.0.Z, 2.1.A.2, Table 3.1-1 Table 3.1-1 Table 3.1-1 Notes 13 and 15 Table 3.1-1 Note 10 Table 3.1-1 Note 6 Table 3.1-1 Table 3.1-1 footnote

Table 4.1-1 Table 4.1-1 Note 1 I The detail that the top of active fuel, which corresponds to the top of the enriched fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is referenced from the top of active fuel.

The information in the column "Total Number of Instrument Channels Provided by Design for Both Trip Sstems."

The detail stating that the APRM Neutron Flux-Startup scram function is a fixed point and is increased when the reactor mode switch is placed in the Run position, and the detail stating that the APRM Flow Referenced Neutron Flux scram function is varied as a function of recirculation flow (W).

The requirement that an APRM will be considered inoperable if there are less than 2 LPRM inputs per level or less than 11 Operable LPRM detectors to an APRM.

The statement regarding the Main Steam Line Isolation Valve Closure and Turbine Stop Valve Closure Functions design that permits closure of any two lines without a scram being initiated.

The detail regarding the physical location of the Turbine Control Valve Fast Closure Function's pressure switches.

The details concerning conditions and precautions for placing an inoperable channel or trip system in trip.

The detail on how to perform a Functional Test of the Mode Switch in Shutdown Function (place the Mode Switch in shutdown).

The detail that describes how to exercise the automatic scram contactors (by performing a functional test of an automatic scram function or by using the RPS Channel Test Switch).

Bases Bases Control Program Bases Bases Bases Bases 1

1 JAFNPP P2 3

3 PAGE 1 Bases Control Program Bases Control Program Bases Control Program Bases Control Program

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC#

SECTION PROCESS TYPE 3.3.1.1 - LAl0 Table 3.1-1 The detail that the RPS Drywell High Pressure and Reactor Low Water Level UFSAR 10 CFR 50.59 1

Note 16 instrumentation is common to the PCIS.

3.3.1.1 - LAl11 Table 4.1-1 The method for performing the Functional Test and Calibration (utilizing a water Bases Bases Control Program 3

Note 6, Table column or similar device to provide assurance that damage to a float or other 4.1-2 Note 5 portions of the float assembly will be detected).

3.3.1.1 - LA12 Table 4.1-1, The listing of the Turbine First Stage Pressure Permissive as an attribute of the Bases Bases Control Program 1

Table 4.1-2 Turbine Stop Valve Closure and Turbine Control Valve Fast Closure Functions.

3.3.1.1 - LA13 Table 3.1-1 The requirement that, with channels in both trip systems inoperable, the trip Bases Bases Control Program 3

footnote **

system with the greatest number of inoperable channels be the trip system that is placed in trip.

3.3.1.1 - LA14 4.1.A footnote The allowance that the sensor is eliminated from response time testing for the Bases Bases Control Program 3

RPS actuation logic circuits for Reactor High Pressure and Reactor Water Level Low Functions.

3.3.1.1 - LA15 Tables 3.1-1, The details that the measured level for the SDV Hight Water Level Scram Bases Bases Control Program 1

4.1-1, 4.1-2 Function is in the instrument volume portion of the SDV._II 3.3.1.2, SRM INSTRUMENTATION 3.3.1.2 - LA1 3.10.B.1 The requirement that the SRMs be inserted to the normal operating level during Core Alterations.

3.3.2.1.CONTROL ROD BLOCK INSTRUMENTATION The information in the column "Total Number of Instrument Channels Provided r

I Bases Bases Control Program 1.i it gnostic test and the proper annunciation of the TRM 10 CFR 50.59 1

3 PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

LOCATION DOC #

SECTION 3.3.2.1 - LA3 4.3.B.3.a.4 The method of performing the RWM Channel Functional Test (by withdrawing an Bases out-of-sequence control rod no more than to the block point, then reinserting the subject rod).

3.3.2.1 - LA4 N/A Not used.

N/A 3.3.2.1 - LA5 Table 3.2-3 The detail that the RBM is flow biased.

Bases 3.3.2.1 - LA6 3.3.B.3.a The detail that the second individual be a "reactor" or "senior" operator or a Bases 3.3.B.3.c "reactor engineer" and the detail that when the RWM is inoperable and a control rod is being moved, the individual moving the rod shall comply with BPWS and have no other concurrent duties during the rod withdrawal or insertion.

3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION 3.3.2.2 - LA1 1.0.Z, Table The detail that the top of active fuel, which corresponds to the top of the enriched Bases 3.2-6 fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is referenced from the top of active fuel.

3.3.3.1, PAM INSTRUMENTATION 3.3.3.1 - LAl Table 3.2-8 The information in the column "No. of Instrument Channels Provided by Design."

Bases 3.3.3.1 - LA2 Table 3.2-8 The requirement that, with the Primary Containment Hydrogen/Oxygen monitor TRM Note F inoperable, operation for 30 days is permissible "provided at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either the appropriate parameter(s) is monitored and logged using 27PCX-101NAB, or an appropriate grab sample is obtained and analyzed."

3.3.3.1 - LA3 N/A Not used.

N/A CHANGE CONTROL CHANGE CONTROL PROCESS Bases Control Program N/A Bases Control Program Bases Control Program JAFNPP CHANGE TYPE 3

N/A 1

3 11 PAGE 3

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION The information concerning how many trip systems eacn runctUioinu isbabUaiJLVU with.

The detail that the trip level setting (changed to Allowable Value) for the Bases Condensate Storage Tank Low Level is equivalent to 15.600 gallons available.

PAGE 4 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND ITS SECTION AND DOC #

3.3.5.1 - LA4 CTS SECTION Table 3.2-2, 1.0.Z

SUMMARY

LOCATION CHANGE CONTROL CHANGE PROCESS TYPE The detail that the top of active fuel, which corresponds to the top of the enriched fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is referenced from the top of active fuel.

Bases Bases Control Program 1

.1 L ________

q,

9 1 '..iIt"* V CT r' A

I I 1l4T' I I MF T A T I N '

The information in the column "Minimum No. of Operable Instrument Channels per Trip System" and that RCIC Reactor High Water Level Trip Function include only one trip system.

3.3Bases Bases Control ProgramIE I I vil Bases Control Program L

4-I Bases The information in the column "Remarks."

The detail that the trip level setting (changed to Allowable Value) for the Condensate Storage Tank Low Level is equivalent to 15,600 gallons available.

The detail that the top of active fuel, which corresponds to the top of the enriched fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is referenced from the top of active fuel.

Bases Bases

-t I

Bases Bases Control Program 1

Bases Control Program

-i i

i J __________________________

J

.7 ltion in the column "Total Number of Instrument Channels Provided Bases Bases Control Program I

i Bases Control Program ystem need not be placed in Bases toocuruu.

j---

___I_

PAGE 5 JAFNPP Table 3.2-2, including Note 16 1

3.3.5.2 - LA1 3.3.5.2 - LA2 3.3.5.2 - LA3 3.3.5.2 - LA4 Table 3.2-2 Table 3.2-2, 1.0.Z 1.3. 1 IDI-Kl'lM V-r'f)KT AUI* /'lhlr-IM I Inl-rAIONINSTRU1-MEi NTAT~l I

ON, IBases Bases Control Program Bases Control Program I

I I

I,

I dUlt; O.L-L II

-L 3.3.6.1, PRIMARY UUN I AINMtN I ltýULA I lUlm "%J--"

1 1 m I 1

1 Bases TAble"3.2 -2 Bases Control Program Bases

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.3.6.1 - LA3 Table 3.2-1 The Systems isolated by certain instruments.

Bases Bases Control Program 1

Actions 3.C, 3.D, and 3.E, Table 3.2-8 Footnote

3.3.6.1 - LA4 Table 3.2-8 The details of the logic and penetrations isolated by the Reactor Low Water Bases Bases Control Program 1

Note 8 Level and Drywell High Pressure Trip Functions.

3.3.6.1 - LA5 Table 4.2-1 The details of which valves are isolated by the various instruments during Logic Bases Bases Control Program 1

System Functional Tests.

3.3.6.1 - LA6 Table 3.2-1 The detail that the Reactor Low Water Level and Drywell High Pressure Bases Bases Control Program 1

Note 7 Functions are common to the RPS Instrumentation.

3.3.6.1 - LA7 Table 4.2-1 The methods for performing a detector calibration and a Channel Calibration Bases Bases Control Program 3

thru 4.2.-5 (using a radiation source and a current source, respectively).

Note_11 3.3.6.1 - LA8 Table 3.2-2 The Reactor Low Pressure Trip Function requirements.

TRM 10 CFR 50.59 3

Item 10, including Notes 2 and 12, Table 4.2 2 Instrument Channel 3a) 3.3.6.1 - LA9 Table 3.2-1, The detail that the top of active fuel, which corresponds to the top of the enriched Bases Bases Control Program 1

1.0.Z fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is referenced from the top of active fuel.

3.3.6.1 - LA10 N/A Not used.

N/A N/A N/A 3.3.6.1 -LA11 Table 3.2-1 The detail of what constitutes PCIS Initiation capability (for at least one Bases Bases Control Program 3

Note 2.b containment isolation valve in the affected penetration).

PAGE 6 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL DOC #

SECTION PROCESS 3.3.6.1 - LA12 4.2.A footnote The details that the sensors for the Reactor Low Water Level (Level 1), Low Bases Bases Control Program Steam Line Pressure, and High Steam Line Flow Functions are eliminated from Iresponse time testing of theMSIV actuation logic circuits.

,3.. no ccr n APV fIIAIT I.IIM T ISl1 ATIrlN INSTRIIMFNTATION 3.;3.6.2, 5 ;1",UINUA/'.

Lu rN I A1N*

tN1-VlLI

-I I

.I.*IIVi*III 14 "

UV 3.3.6.2 - LAl Table 3.2-1, The information in the columns "Total Number of Instrument Channels Provided Bases Bases Control Program RETS Table by Design for Both Trip Systems" and "Total Number of Instrument Channels 3.10-1 Provided by Design."

3.3.6.2 - LA2 Table 3.2-1 The allowance that an inoperable channel or trip system need not be placed in Bases Bases Control Program 3

Note 1.a trip when this would cause the trip function to occur.

(including footnote *),

RETS Table 3.10-1 Note a The detail that the Reactor Building and Refuel Areas Exhaust Monitor channel's Trip Level Setting (changed to Allowable Value) is in accordance with the methods and procedures of the ODCM and that the Function includes the isolation capability.

The detail that the Reactor Low Water Level and Drywell High Pressure

-1*

.t Bases Bases Control Program Note 4 Functions start thle SGT S ystem and initiate secondaruy VIntc1inmmisiLIVcLoI.

II I

The detail that the Reactor Low Water Level and Drywell High Pressure Functions are common to the RPS Instrumentation.

The detail that the top of active fuel, which corresponds to the top of the enriched fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point in the inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is referenced from the top of active fuel.

1 1

Bases Bases Control Program 1

PAGE 7 3.3.6.2 - LA3 RETS Table 3.10-1 Note b I

I Table 3.2-1 3.3.6.2 - LA4 3.3.6.2 - LA5 3.3.6.2 - LA6 Table 3.2-1 Note 7 Table 3.2-1, 1.02Z JAFNPP 1

Bases I

Bases Bases Control Program Bases Control Program 1

Bases Bases Control Program 1

Bases Bases Control Program

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

DOC #

SECTION 3.3.6.2 - LA7 Table 3.2-1 The detail of what constitutes PCIS (i.e., Secondary Containment) Initiation Note 2.b capability (for at least one containment isolation valve in the affected Ipenetration).

7 "1

'De':VAq qVYTlM IMITRI IMeNTATION

,....1,,

ZnO'J t.

1 i r V.

i 11,-i.1 i v,.

i.l

.l.I1r NONE NONE NONE NONE NONE NONE 3.3.7.2, CONDENSER AIR REMOVAL PUMP ISOLATION INSTRUMENTATION 3.3.7.2 - LAl Table 3.2-1, The information in the columns "Total Number of Instrument Channels Provided Bases Bases Control Program 1

RETS Table by Design for Both Trip Systems" and "Total Number of Instrument Channels 3.10-1 Provided by Design."

3.3.7.2 - LA2 Table 4.2-1 The methods for performing a detector calibration and a Channel Calibration Bases Bases Control Program 3

thru Table 4.2-(using a radiation source and a current source, respectively).

5, Note 11 3.3.7.2 - LA3 Table 3.2-1 The allowance that an inoperable channel or trip system need not be placed in Bases Bases Control Program 3

Note l.a trip when this would cause the trip function to occur.

footnote

3.3.7.3, ESW SYSTEM INSTRUMENTATION 3.3.7.3 - LAl 3.11.D.1 The statement that the ESW System ensures adequate equipment and area Bases Bases Control Program 1

cooling.

3.3.8.1, LOP INSTRUMENTATION PAGE 8 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.3.8.1 - LA1 Table 3.2-2, The information in the column "Remarks," that the trip level setting (changed to Bases Bases Control Program 1,2 including Allowable Value) units are based on the secondary volts, the correlation of Notes 13, 14, secondary voltage to primary voltage, and the actions of the LOP Instrumentation and 15 (i.e., what the instrumentation actuates).

3.3.8.2, RPS ELECTRIC POWER MONITORING 3.3.8.2 - LA1 4.9.G.2 The details of what constitutes a system functional test.

Bases Bases Control Program 3

CHANGE TYPE

1.

2.

3.

Details of system design and system description including design limits Description of system operation Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements PAGE 9 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM

SUMMARY

II ATIIId I

CDDATINIt

CHANGE CONTROL CHANGE PROCESS TYPE 3.4.1, REI-,

ULP, I II' L

FQ *Jr LM l I_114U 3.4.1 - LA1 3.5.K.2 The requirements that during resumption of two-loop operation following a period of TRM 10 CFR 50.59 single-loop operation, the discharge valve of the lower speed pump not be opened unless the speed of the faster pump is less than 50 percent of its rated speed.

Q.4t.z, itL.i I tivir 3.4.2 - LA1 4.6.G.A The details to obtain base line data for single loop operation.

Bases Bases Control Pro ram 3.4.3, SAFETY/RELIEF VALVES 3.4.3 - LA1 4.6.E.2 The requirement to disassemble and inspect one safety/relief valve every 24 UFSAR 10 CFR 50.59 3

months.

3.4.3 - LA2 4.6.E.4 The methods for verifying the safety/relief valves have opened (i.e., while bypassing Bases Bases Control Program 3

steam to the condenser, etc) and the detail that the test must be performed in Run._

IS rga 10 CERI50.5 4.6.E.1 3.4.3 - LA4 N/A The requirement that at least 5 of the 11 S/RVs be bench checked or replaced with bench checked valves every 24 months; and that all valves be tested every 48 months.

-i

'iI N/A INot usedi.

Pif^

i -

i "

I ___________________________

J _____

,2 A A r'LC rt" rD ATItn NAI I I*A KA(,F:

3.'t.'+, fljQ LJrnr I I'.JI'4I'.L r

r Bases Bases Control Program 3

The details of the methods for performing this surveillance by utilizing the Primary Containment Sump Monitoring System (equipment drain sump monitoring and floor I

I 1

I _________

J PAGE 1 JAFNPP 3.4.3 - LA3 Not used.

I TABL LA 4-lRE 1 TMOVLOFDTILS M.

P~ATRIXr qA A 0IrT DIMPIS 10 CFR 50.59 IST Program N/A Nl/A Bases Control Program Bases

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM ITS SECTION AND CTS

SUMMARY

DOC#

SECTION

3. 4.

RC I FAKAGEF DETECTION INSTRUMENTATION CHANGE CONTROL PROCESS 3.4.5 - LA1 Table 3.2-The details that the "floor drain sump flow integrator" must be Operable and the Bases Bases Control Program 1

6, Table details that the "floor drain sump flow integrator" must be functionally checked and 4.2-5 calibrated.

3.4.5 - LA2 Table 3.2-6 The details that the two flow integrators, one for the equipment drain sump and the UFSAR 10 CFR 50.59 1

Note 1 other for the floor drain sump, comprise the Basic Instrument System that monitors leakage detection inside the drywell.

3.4.6, RCS SPECIFIC ACTIVITY NONE NONE NONE NONE NONE NONE 3.4.7, RHR SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN NONE NONE NONE NONE NONE NONE 3.4.8, RHR SHUTDOWN COOLING SYSTEM - COLD SHUTDOWN NONE NONE NONE NONE NONE NONE 3.4.9. RCS P/T LIMITS The requirement that specifies the criteria for ending the P/T limit surveillances during inservice hydrostatic and leak tests, non-nuclear heatup and cooldown, and core critical operations (performed until two consecutive temperature readings are within 50F of each other).

Bases Control Program PAGE 2 JAFNPP 3.4.9 - LA1 4.6.A.2, 4.6.A.3, 4.6.A.4 I

I VVILI lil I ý I - -

1- -

I I I

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.4 -REACTOR COOLANT SYSTEM CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC#

SECTION PROCESS TYPE 3.4.9 - LA2 3.6.A.5.a The details in CTS 3.6.A.5.a on how to determine the RCS is acceptable for Bases Bases Control Program 3

continued operations (perform an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the RCS).

3.4.9 - LA3 4.6.A.6 The method to evaluate the temperature differential using the temperature at the Bases Bases Control Program 3

reactor vessel bottom head "drain line."

3.4.9 - LA4 N/A Not used.

N/A N/A N/A 3.4.9 - LA5 3.6.A.2, The specific requirements that operation be on or to the right of the curves of Figure Bases Bases Control Program 1

3.6.A.3, 3.6-1 Part 1 or 2.

3.6.A.4 CTS 3/4.6.F, STRUCTURAL INTEGRITY NONE NONE NONE NONE NONE NONE PAGE 3

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.5 ECCS AND RCIC SYSTEM ITS SECTION AND CTS

SUMMARY

DOC #

SECTION I. f ;-

F r q -

IP E R A T IN G 3.5.1 - LA1 4.5.D.1.b The surveillance requirement to demonstrate that a simulated automatic ADS TRM 10 CFR 50.59 3

actuation is inhibited by the override switches.

3.5.1 - LA2 4.5.D.1.a The details that the simulated automatic actuation test for the Automatic Bases Bases Control Program 3

Depressurization System (ADS) opens the solenoids.

3.5.1 - LA3 4.6.E.4 The methods for verifying the safety/relief valves have opened (i.e., while bypassing Bases Bases Control Program 3

steam to the condenser, etc) and the detail that the test must be performed in Run.

3.5.1 - LA4 3.5.A.3.b The detailed descriptions of the requirements for assuring that the LPCI cross-tie Bases Bases Control Program 3

line is isolated.

3.5.1 - LA5 4.6.E.3 The requirement to verify the integrity of the nitrogen system and components that TRM 10 CFR 50.59 3

provide manual andADS actuation of the safety/relief valves every 3_months.

3.5.1 - LA6 4.5.G.1, The method to be employed to assure that the Core Spray, Low Pressure Coolant Bases Bases Control Program 3

4.5.G.2, Injection, and High Pressure Coolant Injection pump discharge lines are full of 4.5.G.3 water (i.e., the discharge piping shall be vented from the high point of the system and water flow observed).

3.5.1 - LA7 4.5.A.1.d, The requirements to perform motor operator valve and testable check valve testing IST Program 10 CFR 50.59 3

4.5.A.1.g, in accordance with the Frequency of the Inservice Testing (IST) Program for the CS 4.5.A.3, System, LPCI System, and HPCI System.

4.5.C.1 3.5.1 - LAB 4.9.F.1, The requirement to perform a weekly visual inspection of the LPCI MOV TRM 10 CFR 50.59 3

4.9.F.6 Independent Power Supply inverters.

3.5.1 - LA9 N/A Not used.

N/A N/A N/A 3.5.1 - LB1 4.5.G.4 The monthly functional test of the Core Spray and RHR level switches located on TRM 10 CFR 50.59 3

the discharge piping high points._II PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.5 ECCS AND RCIC SYSTEM

SUMMARY

LOCATION CHANGE CONTROL

CHAN, PROCESS TYF ta P Instrumentation daily check, quarterly calibration, TRM 10 CFR 50.59 3

t.

3.5.2, ECCS - SHUTDOWN m motor operator valve testing in accordance with the IST Program 10 CFR 50.593 Testing (IST) Program for the required CS and/or LPCI id to assure that the Core Spray and Low Pressure Bases Bases Control Program 3

charge lines are full of water (i.e., the discharge piping gh point of the system and water flow observed).

t of the Core Spray and RHR level switches located on TRM 10 CFR 50.59 3

)oints.

3.5.3, RCIC SYSTEM ed automatic actuation test includes the automatic restart Bases Bases Control Program 3

that is subsequent to a high water level signal.

ed to assure that the RCIC pump discharge line is full of Bases Bases Control Program 3

)iping shall be vented from the high point of the system N/A N/A N/A

)rm RCIC System testable check valve testing and RCIC IST Program 10 CFR 50.59 3

alve testing every 92 days.

PAGE 2 JAFNPP

TABLE LA -REMOVAL OF DETAILS MATRIX SECTION 3.5 ECCS AND RCIC SYSTEM CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP PAGE 3

TABLE LA-REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION AND CTS

SUMMARY

DOC #

SECTION

.6.1.1 PRIMARY CONTAINMENT o.u. 1.1,Fl*, °,,,

1, 3.6.1.1 - LA1 1.0.M The details concerning the manual isolation valves, automatic isolation valves, that Bases Bases Control Program 1

the drywell and pressure suppression chamber are intact, and the requirement that manways are closed for primary containment Operability.

3.6.1.1 - LA2 N/A Not used.

N/A N/A N/A 3.6.1.1 - LA3 3.7.A.5.e The details that the drywell to suppression chamber leakage rate limit of 71 scfm Bases Bases Control Program 3

shall be monitored via the suppression chamber 10 minute pressure transient of 0.25 in. water/mmin.

3.6.1.1 - LA4 4.7.A.3 The requirement that when the primary containment is inerted, it shall be UFSAR 10 CFR 50.59 3

continuously monitored for gross leakage by review of the inerting system makeup requirements.

3.6.1.2, PRIMARY CONTAINMENT AIR LOCKS 3.6.1.2 - LA1 1.0.M.2 The detail that at least one door in each airlock is closed and sealed.

Bases Bases Control Program 1

3.6.1.3, PRIMARY CONTAINMENT ISOLATION VALVES 3.6.1.3 - LA1 4.7.A.2.c The leakage limits and test pressure for the LPCI/CS air-operated testable check Bases Bases Control Program 3

valves (as modified by DOG M6).

3.6.1.3 - LA2 N/A Not used.

N/A N/A N/A 3.6.1.3 - LA3 N/A Not used.

N/A N/A N/A 3.6.1.3 - LA4 N/A Not used.

N/A N/A N/A 3.6.1.3 - LA5 1.0.M.3 The details concerning automatic containment isolation valves (a deactivated valve Bases Bases Control Program 1

1__ _ _1__

in the isolatedposition ensures containment integrity).

PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT'SYSTEMS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.6.1.3 - LA6 3.7.D.1 The design detail that provide the containment vent and purge valve numbers and UFSAR 10 CFR 50.59 1

maximum opening angle limitations._----_L 3.6.1.4, DRYWELL PRESSURE NONE NONE NONE NONE NONE NONE 3.6.1.5, DRYWELL AIR TEMPERATURE NONE NONE NONE NONE NONE NONE 3.6.1.6, REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS NONE NONE NONE NONE NONE NONE 3.6.1.7, SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS 3.6.1.7 - LA1 4.7.A.5.c, The requirements that each vacuum breaker valve be inspected to ensure proper IST Program 10 CFR 50.59 3

4.7.A.5.g maintenance and operation in accordance with the IST Program and that each vacuum breaker valve be inspected and verified to meet design requirements.

3.6.1.7 - LA2 3.7.A.5.b The requirement that one vacuum breaker may be non-fully closed so long as it is Bases Bases Control Program 3

determined to be not more than_1_degree open as indicated by the position lights.

_II 3.6.1.8, MAIN STEAM LEAKAGE COLLECTION SYSTEM NONE NONE NONE NONE NONE NONE PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION AND CTS

SUMMARY

DOC #

SECTION 3.6.1.9. RHR CONTAINMENT SPRAY CHANGE CONTROL PROCESS 3.6.1.9 - LA1 3.5.B.1 The details concerning the number of pumps required in each RHR containment Bases Bases Control Program 1

spray subsystem (i.e., two pumps, but changed by DOC L4 to one pump).

3.6.1.9 -LA2 4.5.B.1.b The inservice testing requirement for the RHR containment cooling mode motor IST Program 10 CFR 50.59 3

operated valves.

3.6.1.9 -LA3 4.5.B.1.f The details on the method to determine the spray headers are unobstructed (i.e., an Bases Bases Control Program 3

air test).

3.6.2.1, SUPPRESSION POOL AVERAGE TEMPERATURE NONE NONE NONE NONE NONE NONE 3.6.2.2, SUPPRESSION POOL WATER LEVEL 3.6.2.2 - LA1 3.7.A.1.b The details of Operability testing that result in the suppression pool water level not Bases Bases Control Program 3

being within limits.

3.6.2.3, RHR SUPPRESSIONPOOL COOLING 3.6.2.3 - LA1 3.5.B.1 The details concerning the number of pumps required in each RHR containment Bases Bases Control Program 1

spray subsystem_(i.e.,_two pumps,_but changed byDOCL2 to one pump).

3.6.2.3 -LA2 4.5.B.1.b The inservice testing requirement for the RHR containment cooling mode motor IST Program 10 CFR 50.59 3

operated valves.

3.6.2.4, DRYWELL-TO-SUPPRESSION CHAMBER DIFFERENTIAL PRESSURE JAFNPP PAGE 3

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.6.2.4 - LA1 3.7.A.7.a.(

The details of Operability testing that result in the drywell-to-suppression chamber Bases Bases Control Program 3

2) pressure not being within limits.

3.6.3.1, PRIMARY CONTAINMENT OXYGEN CONCENTRATION NONE NONE NONE NONE NONE NONE 3.6.3.2, CAD SYSTEM NONE NONE NONE NONE NONE NONE 3.6.4.1, SECONDARY CONTAINMENT 3.6.4.1 - LA1 3.7.C.1.d The requirement that secondary containment be maintained if the fuel cask is being UFSAR 10 CFR 50.59 3

moved in the reactor building.

3.6.4.1 - LA2 4.7.C.1.c The details concerning the required wind conditions during the secondary Bases Bases Control Program 1

containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months vacuum test._I 3.6.4.2, SECONDARY CONTAINMENT ISOLATION VALVES 3.6.4.2 - LA1 3.7.C.1.d The requirement that secondary containment shall be maintained (isolation valves UFSAR 10 CFR 50.59 3

Operable) if the fuel cask is being moved in the reactor building.

3.6.4.3, STANDBY GAS TREATMENT SYSTEM 3.6.4.3 - LA1 3.7.C.1.d The requirement that secondary containment shall be maintained (SGT System UFSAR 10 CFR 50.59 3

Operable) if the fuel cask is being moved in the reactor building.

PAGE 4 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.6.4.3 - LB1 4.7.B.1.f The requirement to calibrate the SGT System differential pressure switches every TRM 10 CFR 50.59 3

24 months.

CTS 3.7.A.3, CONTAINMENT PURGE THROUGH THE STANDBY GAS TREATMENT SYSTEM NONE NONE NONE NONE NONE NONE CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements PAGE 5 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.7 - PLANT SYSTEMS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC#

SECTION PROCESS TYPE 3.7.1, RHRSW SYSTEM 3.7.1 - LA1 3.5.B.1 The details concerning the number of pumps required in each RHR service water Bases Bases Control Program 1

subsystem.

3.7.1 - LA2 4.5.B.1.c, The inservice testing requirements for the RHRSW pumps and valves, including the IST Program 10 CFR 50.59 3

4.5.B.1.d pump flow rate.

3.7.2, ESW SYSTEM and UHS 3.7.2 - LA1 4.11.D.1.b, The inservice testing requirements for the ESW pumps and valves, including the IST Program 10 CFR 50.59 3

4.11.D.1.d pump flow rate and total developed head.

3.7.2 - LA2 4.11.D.2 The detail on how to perform ESW surveillances (i.e., that ESW will not be supplied Bases Bases Control Program 2

to RBCLC System during testing).

3.7.2 - LA3 3.11.E The detail that a minimum of 18 heaters out of 88 are required (as modified by DOC Bases Bases Control Program 3

M3).

3.7.3, CREVAS SYSTEM 3.7.3 - LA1 3.11.A.1 The details concerning the components of the Main Control Room Emergency Bases Bases Control Program 3

Ventilation Subsystem (emergency ventilation air supply fans and fresh air filter trains) required to be OPERABLE.

3.7.3 - LB1 4.11.A.4 The requirement to calibrate the temperature transmitters and differential pressure TRM 10 CFR 50.59 3

switches every 24 months.

3.7.4, CONTROL ROOM AC SYSTEM iNONE NONE NONE I NONE I NONE NONE PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.7 - PLANT SYSTEMS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 3.7.5, MAIN CONDENSER STEAM JET AIR EJECTOR OFFGAS 3.7.5 - LAl RETS The details of the method of performing the Surveillance to verify the gross gamma Bases Bases Control Program 3

3.5.a (SR activity rate is within limit (by performing an isotopic analysis on a representative section) sample of gases and the description of the acceptable sample point).

3.7.6, MAIN TURBINE BYPASS SYSTEM NONE NONE NONE NONE NONE NONE 3.7.7, SPENT FUEL STORAGE POOL WATER LEVEL 3.7.7 - LA1 3.10.C The requirement that whenever irradiated fuel is stored in the spent fuel storage UFSAR 10 CFR 50.59 3

pool, the pool water level shall be maintained at a minimum water level of 33 ft.

CTS 3/4.8, MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES NONE NONE NONE NONE NONE NONE CTS 3/4.11.C, BATTERY ROOM VENTILATION NONE - LA1 3/4.11.C The Battery Room Ventilation Specification.

TRM 10 CFR 50.59 3

CHANGE TYPE

1.

Details of system design and system description including design limits PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.7 - PLANT SYSTEMS

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP PAGE 3

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS

SUMMARY

38 I -ACS.OUI IRCFS - OPFRATING 3.8.1 - LAl 3.9.A.1, The details of Operability "that power is available to the emergency Bases Bases Control 1,3 3.9.A.1.a buses from the following power sources," and the specific design Program details referring to the "115 kV lines and reserve station transformers."

3.8.1 - LA2 4.9.B.3 The requirement to check the EDG instrumentation during monthly TRM 10 CFR 50.59 3

_generator testing.

3.8.2, AC SOURCES - SHUTDOWN NONE NONE NONE NONE NONE NONE 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 3.8.3 - LAl 4.9.C The requirement that the quantity of diesel fuel available in each TRM 10 CFR 50.59 3

storage tank be manually measured once per month and compared to the reading of the local indicators to ensure proper operation thereof.

3.8.3 - LA2 4.9.C.1 The fuel oil property limits.

TRM 10CFR 50.59 3

3.8.4, DCSOURCES - OPERATING 3.8.4 - LAl 3.9.E.1, The details relating to the components of the DC sources (both Bases Bases Control 1

3.9.F.1 batteries and the associated chargers).

Program 3.8.4 - LA2 4.9.E.5.a, The details concerning battery degradation (i.e., if the capacity drops Bases Bases Control 2

4.9.E.5.b, more than 10% from its previous performance test (or modified Program 4.9.F.5.a, performance test) and if capacity is below 90% of manufacturer's 4.9.F.5.b ratinQ), consistent with IEEE-450.

PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS ITS SECTION CTS

SUMMARY

LOCATION CHANGE CHANGE AND DOC #

SECTIO CONTROL TYPE N

PROCESS 3.8.4 - LA3 4.9.E.6, The details relating to the battery charger weekly visual inspection.

TRM 10 CFR 50.59 3

4.9.F.1, 4.9.F.6 3.8.4 - LA4 4.9.F.6 The requirement to perform a test of the LPCI MOV independent TRM 10 CFR 50.59 3

power supply battery charger every 24 months.

3.8.5, DC SOURCES - SHUTDOWN NONE NONE NONE NONE NONE NONE 3.8.6, BATTERY CELL PARAMETERS 3.8.6 - LA1 4.9.E.2.c, The detail to measure the temperature of "every fifth cell" (as Bases Bases Control 3

4.9.F.2.c modified by DOC L3).

Program 3.8.7, DISTRIBUTION SYSTEMS - OPERATING 3.8.7 - LA1 3.9.A.2, The details related to the specific buses required to be Operable and Bases Bases C6ntrol 1

3.9.F.1 the details of what "Operable" means (e.g., energized, in service).

Program 3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN NONE i---7 I

NONE NONE I

-I I

CHANGE TYPE PAGE 2 JAFNPP INONE INONE INONE I

I I

I

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS

1.

Details of system design and system description including design limits

2.

Description of system operation

LOCATION CHANGE CHANGE AND DOC #

SECTIO CONTROL TYPE N

PROCESS 3.10.7, CONTROL ROD TESTING - OPERATING NONE NONE NONE NONE NONE NONE 3.10.8, SHUTDOWN MARGIN TEST - REFUELING NONE NONE NONE NONE NONE NONE CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 4.0 - DESIGN FEATURES CHANGE TYPE

1.

2.

3.

Details of system design and system description including design limits Description of system operation Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP PAGE 1

TABLE LA -REMOVAL OF DETAILS MATRIX CHAPTER 5.0 -ADMINISTRATIVE CONTROLS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC#

SECTION PROCESS TYPE 5.1, RESPONSIBILITY NONE NONE NONE NONE NONE NONE 5.2, ORGANIZATION 5.2 - LA1 Table 6.2-1 The detail that requires both licensed ROs on shift be in the control room during UFSAR 10 CFR 50.59 3

note **

plant startup or planned shutdown.

5.2-LA2 6.2.2.6 The details of limiting the working hours of the plant staff and administrative controls Plant FitzPatrick procedure 3

on the use of overtime.

Procedures control process 5.2 - LA3 6.3.2 Note The detail that the 13 individuals who hold SRO licenses and have completed the UFSAR 10 CFR 50.59 3

1 FitzPatrick Advanced Technical Training Program prior to issuance of License Amendment 111 shall be considered qualified as dual-role SRO/STAs.

5.2 - LA4 Table 6.2-1 The details of the minimum shift crew requirements for the SRO and RO.

UFSAR 10 CFR 50.59 3

5.2 - LA5 RETS The detail that specifies it is the responsibility of the General Manager-Operations to UFSAR 10 CFR 50.59 3

7.1.b implement the Radiological Effluent Technical Specifications (RETS).

5.3, PLANT STAFF QUALIFICATIONS NONE NONE NONE NONE NONE NONE 5.4, PROCEDURES 5.4 - LA1 6.8.(A).1, Details that establish specific requirements for development, review and approval, QA Program 10 CFR 50.54(a) 3 6.8.(B),

and changes of procedures, including temporary changes.

6.8.(C),

RETS 7.2 PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 5.5, PROGRAMS AND MANUALS 5.5 - LA1 Facility The "Iodine Monitoring Program."

UFSAR 10 CFR 50.59 3

Operating License 2.C(5) 5.5 - LA2 Table 6.10-The list of component cyclic or transient limits, by transient condition and number of UFSAR 10 CFR 50.59 3

1 design occurrences.

5.5 - LA3 RETS 2.5, The details that provide limiting conditions for operation and surveillance TRM 10 CFR 50.59 3

RETS 2.7 requirements for explosive gas and storage tank radioactivity in radwaste systems.

5.5 - LA4 4.7.B.1.c(1 The schedular details ("Within 31 days after removal") for performing the laboratory TRM 10 CFR 50.59 3

tests of the filter trains.

4.7.B.1.c(2 4.11.A.2(1) 4.11.A.2(2) 5.6, REPORTING REQUIREMENTS 5.6 - LA1 6.9.A.1 The Startup Report requirements.

UFSAR 10 CFR 50.59 3

5.6 - LA2 RETS The details associated with the contents of the Radioactive Effluent Release Report ODCM ODCM Change Control 3

7.3.c, and the Annual Radiological Environmental Operating Report.

Process in ITS Chapter 5 RETS 7.3.d

_I 5.7, HIGH RADIATION AREA PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 -ADMINISTRATIVE CONTROLS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE 5.7 - LA1 6.11 The details concerning the requirements of the Radiation Protection Program.

UFSAR 10 CFR 50.59 3

CTS 6.0, ADMINISTRATIVE CONTROLS None - LA1 6.4 Details that provide requirements for retraining and replacement training for the UFSAR 10 CFR 50.59 3

plant staff.

None - LA2 6.5 Details that set forth requirements for review and approval of programs and QA Program 10 CFR 50.54(a) 3 procedures, and the review and audit responsibilities of the Plant Operating Review Committee and Safety Review Committee.

None - LA3 6.6(B)

Details that set forth requirements for review and approval of reportable events.

UFSAR 10 CFR 50.59 3

None - LA4 6.10 Details that require that certain records be retained.

QA Program 10 CFR 50.54(a) 3 None - LA5 6.16 The details that provide programmatic requirements for the processing of solid UFSAR 10 CFR 50.59 3

radioactive waste and the Process Control Program (PCP).

None - LA6 6.18 Details associated with the reporting requirements of the major modifications to ODCM ODCM Change Control 3

liquid, gaseous, and solid radwaste treatment systems.

Process in ITS Chapter 5 None - LA7 6.17.C.2 Details that set forth Plant Operating Review Committee review and acceptance of QA Program 10 CFR 50.54(a) 3 changes to theOffsiteDoseCalculationManual.

RETS 2.1, LIQUID EFFLUENT MONITORS NONE NONE NONE NONE NONE NONE RETS 2.2, CONCENTRATION OF LIQUID EFFLUENTS NONE NONE NONE NONE NONE NONE PAGE 3 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION AND CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE RETS 2.3, DOSE FROM LIQUID EFFLUENTS NONE NONE NONE NONE NONE NONE RETS 2.4, LIQUID RADIOACTIVE WASTE TREATMENT SYSTEM OPERATIONS NONE NONE NONE NONE NONE NONE RETS 3.1, GASEOUS EFFLUENT MONITORS NONE NONE NONE NONE NONE NONE RETS 3.2, GASEOUS DOSE RATES NONE NONE NONE NONE NONE NONE RETS 3.3, AIR DOSE, NOBLE GASES NONE NONE NONE NONE NONE NONE RETS 3.4, DOSE DUE TO IODINE-1i31, IODINE-133, TRITIUM, AND RADIONUCLIDES IN PARTICULATE FORM NONE NONE NONE NONE NONE NONE RETS 3.6, OFFGAS TREATMENT SYSTEM NONE NONE NONE NONE INONE INONE PAGE 4 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION AND CTS

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LOCATION CHANGE CONTROL CHANGE DOC #

SECTION PROCESS TYPE RETS 4.0, SOLID RADIOACTIVE WASTE - PROCESS CONTROL PROGRAM NONE NONE NONE NONE NONE NONE RETS 5.0, TOTAL DOSE - TOTAL DOSE FROM URANIUM FUEL CYCLES NONE NONE NONE NONE NONE NONE RETS 6.1, MONITORING PROGRAM NONE NONE NONE NONE NONE NONE RETS 6.2, LAND USE CENSUS PROGRAM NONE NONE NONE NONE NONE NONE RETS 6.3, INTERLABORATORY COMPARISON PROGRAM NONE NONE NONE NONE NONE NONE CHANGE TYPE

1.

Details of system design and system description including design limits

2.

Description of system operation PAGE 5 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS

3.

Procedural details for meeting TS requirement, relocated reporting requirements, and relocated specification requirements JAFNPP PAGE 6

ATTACHMENT 6 Table R - Relocated Specifications Matrix

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 1.0- USE AND APPLICATION ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 2.0 - SAFETY LIMITS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL NANDDOC_#_SECIO PROCESS NONEI NONE NONE NONENONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.0 - LCO AND SR APPLICABILITY ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.1.1, SHUTDOWN MARGIN NONE NONE NONE NONE NONE 3.1.2, REACTIVITY ANOMALIES NONE NONE NONE NONE NONE 3.1.3, CONTROL ROD OPERABILITY NONE NONE NONE NONE NONE 3.1.4, CONTROL ROD SCRAM TIMES NONE NONE NONE NONE NONE 3.1.5, CONTROL ROD SCRAM ACCUMULATORS NONE NONE NONE NONE NONE 3.1.6, ROD PATTERN CONTROL NONE NONE NONE NONE NONE 3.1.7, STANDBY LIQUID CONTROL SYSTEM NONE NONE NONE NONE NONE PAGE 1

JAFNPP PAGE 1

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS ITS SECTION CTS

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LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.1.8, SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVES NONE NONE NONE NONE NONE JAFNPP PAGE 2

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.3.5.1, ECCS INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.5.2, RCIC SYSTEM INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.6.1, PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.6.2, SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.7.1, CREVAS SYSTEM INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.7.2, CONDENSER AIR REMOVAL PUMP ISOLATION INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.7.3, ESW SYSTEM INSTRUMENTATION NONE NONE NONE NONE NONE PAGE 3 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.3 - INSTRUMENTATION ITS SECTION CTS

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SECTIO CONTROL N

PROCESS 3.3.8.1, LOP INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.8.2, RPS ELECTRIC POWER MONITORING NONE NONE NONE NONE NONE PAGE 4 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM ITS SECTION CTS

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LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.4.1, RECIRCULATION LOOPS OPERATING NONE NONE NONE NONE NONE 3.4.2, JET PUMPS NONE NONE NONE NONE NONE 3.4.3, SAFETY/RELIEF VALVES NONE NONE NONE NONE NONE 3.4.4, RCS OPERATIONAL LEAKAGE NONE NONE NONE NONE NONE 3.4.5, RCS LEAKAGE DETECTION INSTRUMENTATION NONE NONE NONE NONE NONE 3.4.6, RCS SPECIFIC ACTIVITY NONE NONE NONE NONE NONE 3.4.7, RHR SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM ITS SECTION CTS

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LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.4.8, RHR SHUTDOWN COOLING SYSTEM - COLD SHUTDOWN NONE NONE NONE NONE NONE 3.4.9, RCS P/T LIMITS NONE NONE NONE NONE NONE CTS 3/4.6.F, STRUCTURAL INTEGRITY None - R1 3/4.6.F The structural integrity inspection requirements.

TRM 10 CFR 50.59 JAFNPP PAGE 2

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.5 - ECCS AND RCIC SYSTEM ITS SECTION CTS

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LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.5.1, ECCS - OPERATING NONE NONE NONE NONE NONE 3.5.2, ECCS - SHUTDOWN NONE NONE NONE NONE NONE 3.5.3, RCIC SYSTEM NONE NONE NONE NONE NONE JAFNPP PAGE 1

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION CTS

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LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.6.1.1, PRIMARY CONTAINMENT NONE NONE NONE NONE NONE 3.6.1.2, PRIMARY CONTAINMENT AIR LOCKS NONE NONE NONE NONE NONE 3.6.1.3, PRIMARY CONTAINMENT ISOLATION VALVES NONE NONE NONE NONE NONE 3.6.1.4, DRYWELL PRESSURE NONE NONE NONE NONE NONE 3.6.1.5, DRYWELL AIR TEMPERATURE NONE NONE NONE NONE NONE 3.6.1.6, REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS NONE NONE NONE NONE NONE 3.6.1.7, SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION CTS

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SECTIO CONTROL N

PROCESS 3.6.1.8, MAIN STEAM LEAKAGE COLLECTION SYSTEM NONE NONE NONE NONE NONE 3.6.1.9, RHR CONTAINMENT SPRAY NONE NONE NONE NONE NONE 3.6.2.1, SUPPRESSION POOL AVERAGE TEMPERATURE NONE NONE NONE NONE NONE 3.6.2.2, SUPPRESSION POOL WATER LEVEL NONE NONE NONE NONE NONE 3.6.2.3, RHR SUPPRESSION POOL COOLING NONE NONE NONE NONE NONE 3.6.2.4, DRYWELL-TO-SUPPRESSION CHAMBER DIFFERENTIAL PRESSURE NONE NONE NONE NONE NONE 3.6.3.1, PRIMARY CONTAINMENT OXYGEN CONCENTRATION NONE NONE NONE NONE NONE JAFNPP PAGE 2

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.6.3.2, CAD SYSTEM NONE NONE NONE NONE NONE 3.6.4.1, SECONDARY CONTAINMENT NONE NONE NONE NONE NONE 3.6.4.2, SECONDARY CONTAINMENT ISOLATION VALVES NONE NONE NONE NONE NONE 3.6.4.3, STANDBY GAS TREATMENT SYSTEM NONE NONE NONE NONE NONE CTS 3.7.A.3, CONTAINMENT PURGE THROUGH THE STANDBY GAS TREATMENT SYSTEM None - R1 3.7.A.3, The requirement to discontinue purging if not purging through the SGT System ODCM ODCM Change 3.7.A.8 whenever primary containment integrity is required, and the associated shutdown Control Process in action.

ITS Chapter 5 PAGE 3 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.7 - PLANT SYSTEMS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS 3.7.1, RHRSW SYSTEM NONE NONE NONE NONE NONE 3.7.2, ESW SYSTEM and UHS NONE NONE NONE NONE NONE 3.7.3, CREVAS SYSTEM NONE NONE NONE NONE NONE 3.7.4, CONTROL ROOM AC SYSTEM NONE NONE NONE NONE NONE 3.7.5, MAIN CONDENSER STEAM JET AIR EJECTOR OFFGAS 3.7.5 - R1 RETS Steam Jet Air Ejector System radiation monitors.

ODCM ODCM Change 3.5.b, Control Process in RETS ITS Chapter 5 Tables 3.10-1 and 3.10 2_

3.7.6, MAIN TURBINE BYPASS SYSTEM NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.7 - PLANT SYSTEMS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

ODCM ODCM Change Control Process in ITS Chapter 5 RETS 2.4, LIQUID RADIOACTIVE WASTE TREATMENT SYSTEM OPERATIONS None - R1 RETS 2.4 Liquid Radwaste Treatment System Operability requirements.

ODCM ODCM Change Control Process in ITS Chapter 5 PAGE 2 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION CTS

SUMMARY

AND DOC #

SECTIO N

RFTS 3.1. GASEOUS EFFLUENT MONITORS None - R1 3.1, The gaseous effluent monitors requirements.

ODCM ODCM Change RETS Control Process in Table ITS Chapter 5 3.10-2 RETS 3.2,_GASEOUSDOSERATES None - R1 RETS 3.2 Limitations on the dose rate due to gaseous effluents.

ODCM ODCM Change Control Process in ITS Chapter 5 RETS 3.3, AIR DOSE, NOBLE GASES None - RI RETS 3.3 Limitations on noble gas releases.

ODCM ODCM Change Control Process in ITS Chapter 5 RETS 3.4, DOSE DUE TO IODINE-1i31, IODINE-1i33, TRITIUM, AND RADIONUCLIDES IN PARTICULATE FORM None - R1 RETS 3.4 Limitations on the dose from iodine-1i31, iodine 133, tritium, and all radioactive ODCM ODCM Change material in particulate form with half lives greater than 8 days.

Control Process in ITS Chapter 5 RETS 3.6, OFFGAS TREATMENT SYSTEM None - R1 RETS 3.6 Limitations on the Offgas Treatment System.

ODCM ODCM Change Control Process in ITS Chapter 5 PAGE 3 JAFNPP 11

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS RETS 4.0, SOLID RADIOACTIVE WASTE - PROCESS CONTROL PROGRAM None - R1 RETS 4.0 Requirements that the Solid Radwaste System shall be used in accordance with PCP 10 CFR 50.59 the PCP to process wet radioactive wastes.

RETS 5.0,_TOTALDOSE - TOTAL DOSEFROMURANIUMFUELCYCLE None - R1 RETS 5.0 Limitations of the annual doses from all plant sources.

ODCM ODCM Change Control Process in ITSChapter 5 RETS 6.1, MONITORING PROGRAM None - R1 RETS 6.1 The radiological environmental monitoring program requirements.

ODCM ODCM Change Control Process in ITSChapter 5 RETS_6.2,_LANDUSECENSUSPROGRAM None - R1 RETS 6.2 The land use census program requirements.

ODCM ODCM Change Control Process in ITS Chapter 5 RETS 6.3, INTERLABORATORY COMPARISON PROGRAM juirements.

ODCM ODCM Change Control Process in ITS Chapter 5 JAFNPP PAGE 4

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC #

SECTIO CONTROL N

PROCESS

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JAFNPP PAGE 5

v t e Letter Sequence Other
TAC:MA5049, (Open)
Initiation Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Meeting Questions Answers Results Approval... Other: ML021970028, ML021970071, ML052060191
MONTHYEAR2002-07-03 [Table View]

ML021970071

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