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 ITS SECTION CTS SECTION CHANGE nDOG #ft,

SUMMARY

I ITVYPF Uu%-ý I TIr-1.O.B activities CORE Li The definition of Core Alteration is revised so that the term will only apply to those ALTERATION and warrant special precautions or controls. S definition that create the potential for a reactivity excursion act of moving any component in the region Currently, a Core Alteration is defined as "the shroud." The normal control above the core support plate, below the upper grid and within the and the movement of in-core rod movement (using the control rod hydraulic system)

The ITS definition for CORE instrumentation are specifically exempted from the definition. vessel reactivity within the reactor ALTERATIONS will only apply to those activities that affect in under the revised definition, with the head removed and fuel in the vessel. Specifically, not be classified as CORE vessel movement of instruments, cameras, lights, tools, etc., will is not considered a CORE ALTERATIONS. It should also be noted that control rod movement core cell. In addition, ALTERATION provided there are no fuel assemblies in the associated an allowance that the suspension the proposed definition has also been modified by providing movement of a component to a of CORE ALTERATIONS shall not preclude completion of safe osition.

Isolation Actuation N/A 1 .0.F.6, 1.0.F.10 3 L2 The specific contact numbers in the definitions of Primary Containment Response Time are deleted. 3 Instrumentation Response Time and Reactor Protection System 1.0.F.5 the injection of a simulated CHANNEL FUNCTIONA L3 The CTS definition of Instrument Channel Functional Test requires the injected signal, have been L TEST signal into the instrument. The words "or actual" in reference to Some CHANNEL definition included in the ITS definition of CHANNEL FUNCTIONAL TEST.

by insertion of the actual signal into the logic (e.g.,

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

NNEL CTIONA 1.0.F.5 3 L4 The CTS definition of Instrument Channel Functional Test requires, theThis injection of a has CHAr FUN(ST requirement simulated signal "into the instrument primary sensor where possible." L TE of CHANNEL FUNCTIONAL TEST to allow the signal to be in the definition ITS sensor been changed injected "as close to the as practicable." defin qition e 1.1-1 1.0.1.3.b 2 L5 to be vented. The ITS The CTS definition of Cold Shutdown requires the reactor vessel Tabh of MODE 4 does not include this requirement.

I definition PAGE 1 JAFNPP

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 or Refuel

8. Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown

9. Elimination of CTS Reporting Requirement PAGE 2 JAFNPP

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

_______________-----7_

IT SECT IO CISSE I LIjkiUN:

I

SUMMARY

SITS SECTIONI ICTS SECT IONI CHANGEUI TYPE DOC #

limit does N/A 1.1 .C Li The power transient safety limit has been deleted since failure to meet this safety not necessarily indicate that an actual safety limit has been exceeded.

19 Le - I The reactor vessel water level safety limit is being reduced by 12 inches. 2.1.1.3 1.1 .D 1 N/A 6.7.(B) 6,9 immediately to 1 L3 The time to report a safety limit violation to the NRC has been extended from since the requirement is covered by 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , in accordance with 10 CFR 50.72. In addition, I CFR 50.72, it is not included in the ITS.

2.1.1.1, 1.1 .A, 1.1 .B 2 L4 The Safety Limit Applicability at low power or low flow is changed from reactor pressure < 785 2.1.1.2

< 10% of rated.

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

core flow> 10%

I.

3.3.6.1 1.2.2 1 by the Shutdown L5 The Shutdown Cooling Safety Limit is being deleted since it is covered Function 6.a Value.

Cooling System Isolation Reactor Pressure - High instrumentation Allowable 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 Shutdown or Refuel

8. Elimination of the Requirement to Lock the Reactor Mode Switch in

9. Elimination of CTS Reporting Requirement PAGE 1 JAFNPP

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

SUMMARY

SECTION TYPE 24 hours1 days 0.143 weeks 0.0329 months if LCO 3.0.3 3.0.C 6 Li The CTS requires the unit to be placed in COLD SHUTDOWN (MODE 4) within because of circumstances in excess of the LCO or action requirements cannot be satisfied to be in MODE 4.

those addressed in the Specification. The ITS allows 37 hours1.542 days 0.22 weeks 0.0507 months periodic SR 3.0.2 4.0.B16 L2 The CTS has had the following sentence added, "Ifa Completion Time requires performance on a "once per..." basis, the above Frequency extension applies to each the performance after the initial performance." The ITS includes this statement to provide whether consistency in scheduling flexibility for all performances of periodic requirements, Required Actions. The intent remains to perform the activity, on the they are Surveillances or interval.

average, once during each specified SR 3.0.3 4.0.C 3 L3 When it is determined that a Surveillance was not performed, the CTS allows ACTION if the requirements to be delayed for up to 24 hours1 days 0.143 weeks 0.0329 months to permit completion of the Surveillance are less than 24 hours1 days 0.143 weeks 0.0329 months . The ITS allowable outage time limits of the ACTION requirements of the continues to allow a delay, from the time of discovery, up to 24 hours1 days 0.143 weeks 0.0329 months or up to the limit change allows the delay to specified Surveillance Frequency, whichever is greater. This with ACTION requirements of apply to any Surveillance, instead of just those specifications less than_24_hours.

SR 3.0.3 4.0.C 3 L4 The CTS allows ACTION requirements to be delayed for up to 24 hours1 days 0.143 weeks 0.0329 months to permit completion than of the Surveillance if the allowable outage times of the ACTION requirements are less 24 hours1 days 0.143 weeks 0.0329 months . The ITS allows an increase in the delay time of up to the limit of the specified provided Surveillance Frequency. However, a delay of greater than 24 hours1 days 0.143 weeks 0.0329 months is only allowed 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 PAGE 2 JAFNPP

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

SUMMARY

TYPE 3.1.1, SHUTDOWN MARGIN NONE NONE NONE NONE NONE 3.1.2, REACTIVITY ANOMALIES provides a 3.1.2 ACTION 3.3.D 6 Li The CTS does not provide an explicit restoration time when Reactivity Anomalies is not met. The ITS required to A Completion Time of 72 hours3 days 0.429 weeks 0.0986 months for the core reactivity difference to be restored to within limits (normally perform an analysis to determine the reason for the reactivity difference).

is N/A 3.3.E 5 12 The CTS requirement to be ina cold condition within 24 hours1 days 0.143 weeks 0.0329 months ifthe reactivity anomaly requirement is not met only power operation (and CTS 3.0.A only being deleted, since the CTS Applicability for this Specification is requires theACTIONS to be met during theLCOsApplicability).

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

I4 ,* r'r* MTDt fl t OPI AflII ITV 3.1.3, UUN I HUL hUU urtMMDILI I T L1 Currently inthe 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 ina cold shutdown condition within 24 hours1 days 0.143 weeks 0.0329 months . No allowance a stuck is provided for repair prior to entering the shutdown statement. The ITS allows continued operation with single withdrawn control rod control rod and the requirement to be inCold Shutdown has been deleted. With a scram and shutdown reactivity.

stuck, the remaining Operable control rods are capable of providing the required stuck control rod In addition, to ensure that local scram reactivity assumptions are maintained inthis condition, must be disarmed within 2 hours0.0833 days 0.0119 weeks 0.00274 months to separation criteria must be verified immediately and the stuck control rod 1 I+Iprevent damaqing the control rod drive.

L2 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 I will still be exercised once per 7 days.

However, partially withdrawn rods will be exercised once per 31 days.

PAGE 1 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 3.1.3 Required 4.3.A.2.a 3 L3 Currently in the CTS, ifthree or more control rods are inoperable but not stuck, all operable control rods must be exercised once every 24 hours1 days 0.143 weeks 0.0329 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.

3.1.3 Required 4.3.A.2.a 3 L4 Currently inthe CTS, ifone or more control rods are stuck, all operable control rods must be exercised "at least every 24 hours1 days 0.143 weeks 0.0329 months ." Inthe ITS, after discovery of a stuck rod, all withdrawn control rods are required to be exercised Action A.3 only once within 24 hours1 days 0.143 weeks 0.0329 months when Thermal Power is greater than the low power setpoint of the RWM.

LCO 3.1.3 314.3.B.2 1 L5 The CTS requirement for the CRD housing support to be inplace has been deleted since it is included inthe Operability requirements for control rods inthe ITS.

3.1.3 3.3.A.2.a 2, 5 L6 CTS 3.3.A.2.a requires the plant to be brought to Cold Shutdown within 24 hours1 days 0.143 weeks 0.0329 months when the requirements for "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 SR 3.1.4.2 4.3.C.2 3 Li The CTS requires that 10% of the operable control rods be scram time tested at "16 week intervals." This 16 week interval equates to 112 days. The ITS Frequency for scram time testing a representative sample of control rods is "120 days cumulative operation inMODE 1." Thus, during plant operation the frequency is being extended for 8 days.

N/A 4.3.C.2 3 L2 The CTS requires an evaluation to be made, whenever scram time surveillances are performed, to provide reasonable assurance that proper control rod drive performance isbeing maintained. This requirement is essentially a performance tracking requirement to help ensure control rod scram times are maintained within limits and is deleted.

N/A 3.3.E 5 L3 The CTS requirement to be in a cold condition within 24 hours1 days 0.143 weeks 0.0329 months when the Scram Insertion Times are not met is being deleted. Anew requirement to be in MODE 3 in 12 hours0.5 days 0.0714 weeks 0.0164 months has been added, as described inDOC 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

.1.I ,* J .. t. Ifl S . ,VUI k vi

ov v ,v ,v . ,i 3.1.5 ACTIONS 3.3.A.2.d 4 Li The CTS requires control rods with inoperable accumulators be considered inoperable immediately. The ITS allows a short out of service time (up to 8 hours0.333 days 0.0476 weeks 0.011 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.

N/A 4.3.A.2.c 3 L2 The CTS requires a check of the status of the pressure and level alarms for each control rod scram accumulator 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 3.1.6 ACTIONS 3.3.B.3.f 4 Li The CTS requires all rod movement to be stopped except by scram ifcontrol rod patterns and sequence of 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 hours0.333 days 0.0476 weeks 0.011 months ifone 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 hours0.333 days 0.0476 weeks 0.011 months must then be declared inoperable and fully inserted within 3 hours0.125 days 0.0179 weeks 0.00411 months .

3.1.7, STANDBY LIQUID CONTROL SYSTEM JAFNPP PAGE 3

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

SUMMARY

TYPE and 3.1.7 3.4.A 2 Li CTS requires that the Standby Liquid Control System be Operable during a period when fuel is inthe reactor current Applicability corresponds to MODES 1,2 and can also imply Applicability prior to startup from cold condition. The the MODES 3, 4 and 5 with any control rod withdrawn. This system need not be Operable when the reactor is in 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.

3.1.7 ACTION 3.4.C 5 L2 The CTS includes an action to restore certain components (e.g., tank heaters) or variables (e.g., sodium hot B pentaborate volume-concentration and temperature requirements) within 8 hours0.333 days 0.0476 weeks 0.011 months or take action to be in in this CTS action will cause both shutdown in the next 12 hours0.5 days 0.0714 weeks 0.0164 months . All the components or variables discussed inclusive of the possible events which subsystems of the SLC System to be inoperable. However, the list is not all to allow the entire SLC System (e.g.,

could lead to both subsystems being inoperable. The ITS adds an ACTION both pumps) to be inoperable for any reason up to 8 hours0.333 days 0.0476 weeks 0.011 months prior to requiring a plant shutdown. The 8 hours0.333 days 0.0476 weeks 0.011 months provides time to restore minor problems_(e.g.,_some pump inoperabilities)_prior to requiring a plant shutdown.

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

flowpath SR 3.1.7.6 4.4.A.1 3 L4 The CTS requires that each SLC subsystem "valve (manual, power operated, or automatic) inthe system is in the correct position" once per 31 days. The ITS that is not locked, sealed or otherwise secured in position, flow path that is not locked, sealed, or otherwise secured requires that "each SLC subsystem manual valve inthe inposition 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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE SR 3.1.7.8 4.4.A.4, 3 L5 The CTS requires that every 24 months demineralized water be injected into the reactor vessel to test that valves (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 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, Li 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 hours0.5 days 0.0714 weeks 0.0164 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 ina cold condition within 24 hours1 days 0.143 weeks 0.0329 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. InMODES 3 and 4, control

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

PAGE 5 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 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 L2 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 ineach 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 hours0.5 days 0.0714 weeks 0.0164 months ifany 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 inthe 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 ITS SECTION CTS SECTION CHANGE DOC #

SUMMARY

TYPE RATE 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION NONE NONE NONE NONE NONE 3.2.2, MINIMUM CRITICAL POWER RATIO N/A 4.1 .C 3 in power level or Li The CTS requires that MCPR be determined following any change as described in the control rod pattern distribution that would cause operation with a limiting Frequency, deletes this Surveillance Bases for Specification 3.3.B.5. The proposed change value. Since the MCPR but retains the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Surveillance Frequency for determining operating limit operating on the operation with a limiting control rod pattern is, in this case, be required.

would seldom MCPR, the condition is extremelyunlikel and the Surveillance 3.2.3, LINEAR HEAT GENERATION RATE NONE NONE NONE NONE NONE 3.2.4, APRM GAIN AND SETPOINT LCO 3.2.4, 4.1 .B, 3.0.C 5 MFLPD whenever reactor Li CTS 4.1 .B includes a daily surveillance requirement to determine ACTIONS A APRM high flux scram trip power is > 25% RTP and to make any necessary adjustments to and B entered and the plant must be settings. When the surveillance is not met CTS 3.0.C must be LCO or action for not meeting in COLD SHUTDOWN within 24 hours1 days 0.143 weeks 0.0329 months since there is no specific added to the current CTS 4.1 .B. ITS LCO 3.2.4 and ACTIONS A and B have been of ITS LCO 3.2.4 are consistent with the requirements in CTS 4.1 .B. The requirements and R1). ACTION A will requirements in CTS 4.1 .B (except as modified by DOCs A3, M1 Required Action and associated allow 6 hours0.25 days 0.0357 weeks 0.00822 months to satisfy the requirements of LCO 3.2.4. Ifthis require a reduction in power to < 25% RTP Completion Time can not be met, ACTION B will within 4 hours0.167 days 0.0238 weeks 0.00548 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 Mode Switch in Shutdown or Refuel

8. Elimination of the Requirement to Lock the Reactor

9. Elimination of CTS Reporting Requirement PAGE 2 JAFNPP

TABLE L- LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 3.3.1.1, RPS INSTRUMENTATION Table 3.3.1.1-1 Table 3.1-1 Trip 2 Li The CTS Applicability of Mode 5 (i.e., reactor is subcritical, fuel is in the vessel and the reactor temperature is less than 212 OF) for the Mode Switch inShutdown, 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. Inthe 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.

3.3.1.1 Table 3.1-1 Note 6 L2 The CTS provides 4 hours0.167 days 0.0238 weeks 0.00548 months to reach Mode 3 (all rods inserted). Inthe ITS, the time to reach Mode 3 is 12 hours0.5 days 0.0714 weeks 0.0164 months .

Required 3.A Action G.1 3.3.1.1 Table 3.1-1 Note 4 L3 The CTS (for Mode Switch in Shutdown, Manual Scram, IRM High Flux, IRM Inoperative, and High Water Level in Scram Discharge Volume Functions) requires the insertion of all operable control rods ifthe channels are not Required 3.A restored or tripped within the allowed completion times. Inthe ITS, when in MODE 5, only control rods incore Action H.1 cells containing one or more fuel assemblies are required to be inserted.

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 L4 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 hours0.167 days 0.0238 weeks 0.00548 months is being relaxed. The ITS will require the plant to be in MODE 2 within Required 3.A 6 hours0.25 days 0.0357 weeks 0.00822 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 inthe ITS. (including Note 6),

Table 4.1-2 (including Note 1)

The details that identify those portions of the instrument channel which require functional testing and the details N/A Table 4.1-1 3 L7 that identify the type of test equipment used to perform a channel calibration have been deleted.

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 L8 is adequately covered by SR 3.0.1. 1_1 1 11 JAFNPP PAGE 1

TABLE L- LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE N/A N/A N/A L9 Not used.

SR 3.3.1.1.3 N/A 3 L10 The ITS includes a Note to allow entry into Mode 2 from Mode 1 for up to 12 hours0.5 days 0.0714 weeks 0.0164 months prior to requiring the Channel Note Functional Test to be performed on the IRM High Flux, IRM Inop, and APRM Neutron Flux - High (Startup)

Functions.

N/A 4.1 .A 3 L11 The details relating to the Instrument I.D. numbers for the RPS Instrumentation are not included inthe ITS.

SR 3.3.1.1.2 N/A 3 L12 The ITS includes a Note that states the APRM heat balance calibration Surveillance is not required to be Note performed until 12 hours0.5 days 0.0714 weeks 0.0164 months after Thermal Power Ž 25% RTP.

SR 3.3.1.1.2 Table 4.1-2 3 L13 The CTS Frequency for performing the APRM heat balance calibration is being changed from once per day inthe Calibration CTS to once per 7 days inthe ITS. requirement for Instrument Channel 2 Table 3.3.1.1-1 2.1.A.3, 2.1.A.4, 1 L14 The Trip Settings/Trip Level Settings (changed to Allowable Value in DOC A19) are being changed a) for the Allowable Table 3.1-1 Trip Turbine Stop Valve Closure Function from < 10% valve closure inthe CTS to < 15% valve closure inthe ITS; and Values for Level Setting for b) for the Turbine Control Valve Fast Closure Function from > 500 psig and < 850 psig inthe CTS to_> 500 psig Functions 8 Trip Functions 14 and < 850 psig inthe ITS. and15 and 9 3.3.1.2, SRM INSTRUMENTATION 3.3.1.2 N/A 5 Li The CTS does not provide any actions ifthe required SRMs are inoperable in Mode 2; thus a shutdown to cold ACTIONS A shutdown is required. In the ITS, 4 hours0.167 days 0.0238 weeks 0.00548 months will be allowed to restore the 3 required SRM channels to Operable prior and B to requiring a shutdown. Also, when there are no Operable SRMs, the ITS will further require suspension of all control rod withdrawal (and continue to allow the 4 hours0.167 days 0.0238 weeks 0.00548 months to restore the inoperable SRMs).

Table 3.3.1.2-1 3.10.B1 L2 The CTS requires two SRMs to be Operable; one inthe core quadrant where fuel or control rods are being moved 1 footnote (b), SR and one in an adjacent quadrant. If a spiral offload or spiral reload is being performed, the ITS will allow only includes only that SRM detector. An appropriate SR has 3.3.1.2.2.a, SR SRM to be Operable, provided that the fueled region 3.3.1.2.2 Note been added to ensure this condition, and a Note included to allow one SRM to satisfy multiple location 2

requirements.

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ITS SECTION CTS SECTION CHANGE DOC #

TYPE 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 L3 hours0.125 days 0.0179 weeks 0.00411 months 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.

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 L4 shutdown only to Mode 3 is required. Required Action C.1 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION N/A Table 3.2-3 Note 5 Li The requirements when one RBM channel is inoperable concerning verifying operations are not on a limiting 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 N/A Table 4.2-3 3 L2 The CTS requirement to perform an instrument check on the RBM - Upscale and - Downscale Functions has been deleted. Instrument Check requirements for Instrument Channels 6 and 7 SR 3.3.2.1.2 4.3.B.3.a.(4) 3 L3 The CTS requires a demonstration of the rod block function of the RWM (i.e., a Channel Functional Test) be performed during a startup prior to the start of control rod withdrawal. Inthe ITS, the Frequency for the RWM Channel Functional Test is specified as 92 days. Thus iftwo 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.

SR 3.3.2.1.8 4.3.B.3.a, 3 L4 The Frequency to verify the correctness of the RWM program sequence during startup prior to the start of control 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 SR 3.3.2.1.5 N/A 3 L5 The ITS includes a Note that excludes the neutron detectors from the RBM - Upscale and - Downscale Functions Channel Calibration Surveillance. NoteII PAGE 3 JAFNPP

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

SUMMARY

TYPE N/A 4.3.B.5 3 L6 The CTS requires the performance of a functional test on the RBM channels when a limiting control rod pattern exists prior to the withdrawal of the designated rod(s)._ThisSurveillance has been deleted.

Table 3.3.2.1-1 N/A 2 L7 The ITS includes a Note that modifies the RBM Applicability requirements, such that the RBM channels are not footnote (a) required to be Operable when a peripheral control rod is selected (since the RBM is automatically bypassed inthis condition).

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

3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION N/A Table 4.2-6 Note 3 Li The explicit requirement to perform an Instrument Functional Test once every 24 months during each refueling 1.a outage has been deleted since a Channel Calibration is required on a 24 month Frequency and a 92 day Channel Functional Test is already required.

3.3.2.2 N/A 5 L2 The CTS requires a reduction inThermal Power ifthe inoperable channels are not restored/tripped within the Required allowed times. In the ITS an additional option is provided ifthe inoperable channel(s) are the result of inoperable the Action C.i feedwater pump turbine or main turbine stop valve. Ifthis is the case, then the ITS will allow removal of (including Note) affected stop valve(s) from service inlieu of reducing power.

3.3.3.1, PAM INSTRUMENTATION N/A Table 3.2-8 1 Li The details relating to the Instrument I.D. numbers for the PAM Instrumentation are not included inthe ITS.

3.3.3.1 Table 3.2-8 Note 2 L2 The CTS requires the Containment High Range Radiation Monitors to be Operable in Run, Startup/Hot Standby, are Applicability H and Hot Shutdown (Modes 1, 2, and 3). In the ITS, the Mode 3 requirement is not maintained; the monitors only required inMODES 1 and 2.

3.3.3.1 N/A 7 L3 The CTS precludes Mode changes if a PAM instrument is inoperable. The ITS includes a Note that allows Mode ACTIONS Note changes with a PAM instrument inoperable (i.e., LCO 3.0.4 is not applicable). 1 PAGE 4 JAFNPP

TABLE L- LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 3.3.3.1 Table 3.2-8 Note 5 L4 The CTS requires the plant to be incold shutdown within 24 hours1 days 0.143 weeks 0.0329 months when the one required containment high range Required A radiation monitor has not been restored to operable status within 30 days. In the ITS, when both required 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.

N/A N/A N/A L5 Not used.

SR 3.3.3.1.1 Table 4.2-8 3 L6 The CTS Channel Check Frequency is being changed from daily in the CTS to every 31 days inthe ITS.

Instrument Check requirement Surveillance N/A 6 L7 A Note has been added to allow a channel to be Inoperable for up to 6 hours0.25 days 0.0357 weeks 0.00822 months solely for performance of required Surveillances provided the other channel in the associated Function is OPERABLE. Requirements Note 3.3.3.2, REMOTE SHUTDOWNSYSTEM Surveillance N/A 6 Li A Note has been added to allow a channel to be inoperable for up to 6 hours0.25 days 0.0357 weeks 0.00822 months solely for performance of required Surveillances. Requirements Note SR 3.3.3.2.2 Table 3.2-10 3 12 The CTS requirement to perform a Functional Test on each required remote shutdown system control circuit is 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 The CTS allows 72 hours3 days 0.429 weeks 0.0986 months to place an inoperable instrument channel intrip ifone 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 intrip.

PAGE 5 JAFNPP

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

SUMMARY

TYPE 3.3.4.1 Table 3.2-7 Note 4 requires that the instrument ACTIONS A, B, 1.b L2 When two or more channels are inoperable for one or more Functions, the CTS within 6 hours0.25 days 0.0357 weeks 0.00822 months and requires the and C channel(s) in one trip system and/or that trip system be inthe tripped condition within 24 hours1 days 0.143 weeks 0.0329 months . In addition, the CTS remaining channel inthe other trip system to be restored to Operable status ITS, iftwo channels are inoperable for will allow only one hour to restore trip capability for each Function. Inthe to restore or trip the channel. In addition, if the same Function and trip capability is maintained, 14 days is allowed in72 ITS the 1 houroftoATWS-RPT restoration trip capability restore ATWS-RPT trip capability hours.oneWhen only Function's Trip both capability capability Trip Function's lost,willtheallow is lost, theisITS provides for one Trip Function, consistent with the CTS.

3.3.4.1 N/A mode (Mode 2) ifthe inoperable channels are not The CTS requires the plant be placed in the startup/hot standby Required option is provided ifthe inoperable channel(s)

L3 restored/tripped within the allowed times. Inthe ITS, an additional Action D.1 ITS will allow removal of the affected are the result of an inoperable RPT breaker. If this is the case, then the (including Note)4 recirculation umpfrom service inlieu of beingin Mode 2.

3.3.5.1, ECCS INSTRUMENTATION N/A N/A N/A Li Not used. Table 3.2-2 Note 4 (Injection Permissive) channel; 3.3.5.1 L2 The CTS requires restoration of an inoperable CS or LPCI Reactor Pressure-Low ACTION B 6 inoperable channels are allowed to be placing the channel inthe tripped condition is not allowed. Inthe ITS, the placed inthe tripped condition durinn MODE 4 or 5 operations. 3.2.B, Table 3.2-2 Table 3.3.5.1 -1 2 Permissive) Functionis required to berequired is currently to Operable L3 be CTS Reactor TheOperable Pressure--

whenever Low (Recirculation the associated Low Pressure Coolant Valve Discharge Injection (LPCI) System Function 2.d, Item No. 24 to be Operable inMODE 1, 2 and 3 when the (Modes 1, 2, 3, 4, and 5). Inthe ITS, the Function is only required including footnote (c) aso cia,*te, discharg e v alv e,i.s nen.

Table 3.2-2 Notes of initiation capability for the LPCI and CS The CTS require action to be taken in1 hour upon discovery of loss 3.3.5.1 2.A and 6.A taken during MODES 1, 2 and 3.

Systems. Inthe ITS, these same actions are only required to be Required Action B.1 Notes 1 and 2, 3.3.5.1 Required Action C.1 Notes 1 and 2 I

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TABLE L- LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION ITS SECTION CTS SECTION CHANGE

SUMMARY

TYPE N/A N/A N/A Not used.

Table 3.3.5.1-1 Table 3.2-2 Trip 1 changed a) for the Containment High The Trip Level Settings (changed to Allowable Value in DOC A12) are being Allowable Level Setting for psig in the ITS; b) for the Reactor Pressure Function from > 1 psig and < 2.7 psig inthe CTS to > 1 psig to < 2.7 Values for Item Nos. 6, 9, from > 450 psig in the CTS to > 410 psig and < 490 psig inthe ITS; Low Pressure (injection permissive) Function Functions 1.c, and 24 Function from 285 psig to 335 psig and c) for the Reactor Low Pressure (recirculation discharge valve permissive) 2.c, 2.d, and inthe CTS to > 295 psig inthe ITS. 2.h I

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

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

isolation instrumentation are not N/A 4.2.A, Table 3.2-8 L2 The details relating to the Instrument I.D. numbers for the primary containment Instrument 4 included in the ITS.

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

PAGE 7 JAFNPP

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

SUMMARY

TYPE 3.3.6.1 Table 3.2-1 Note 5 RWCU reactor water level low L4 The CTS requires the plant to be incold shutdown in24 hours1 days 0.143 weeks 0.0329 months when the inoperable ACTION F 3.A the ITS, in lieu of a shutdown when or drywell pressure high channels are not tripped within the allowed times. In isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

the channels are not tripped, the affected penetration flow path s) must be 3.3.6.1 Table 3.2-1 Note 5 SDC reactor water level low L5 The CTS requires the plant to be incold shutdown in 24 hours1 days 0.143 weeks 0.0329 months when the inoperable ACTION J 3.A lieu of a shutdown when the channels are not channels are not tripped within the allowed times. Inthe ITS, in to Operable status or to isolate the RHR SDC tripped, immediate action must be initiated to restore the channels System.

recirculation loop sample and 3.3.6.1 Table 3.2-1 Note L6 The CTS requires the plant to be incold shutdown in 24 hours1 days 0.143 weeks 0.0329 months when the inoperable ACTION F 3.A not tripped within the allowed recirculation pump seal purge penetrations reactor water level low channels are affected penetration flow path(s) times. In the ITS, in lieu of a shutdown when the channels are not tripped, the must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3.3.6.1 Table 3.2-1 Note 5 Main Steam Lines and drains L7 The CTS requires the plant to be incold shutdown in 24 hours1 days 0.143 weeks 0.0329 months when the inoperable Required 3.A times. In the ITS, in lieu of a shutdown when reactor water level low channels are not tripped within the allowed Action D.1 to allow the affected main steam line to be isolated the channels are not tripped, an optional action is provided within 12 hours0.5 days 0.0714 weeks 0.0164 months .

3.3.6.1 Table 3.2-1 Note 5 hydrogen and oxygen sample L8 The CTS requires the plant to be incold shutdown in24 hours1 days 0.143 weeks 0.0329 months when the inoperable ACTION F 3.A level low or drywell pressure high lines and gaseous/particulate sample supply and return lines reactor water shutdown when the channels are not channels are not tripped within the allowed times. In the ITS, in lieu of a 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 .

3.3.6.1 Table 3.2-1 Notes 5 when the inoperable main steam L9 The CTS requires the isolation of the affected main steam lines within 8 hours0.333 days 0.0476 weeks 0.011 months Required 33B and 3.G are not tripped within the allowed times. In the ITS, inlieu of line high flow and condenser vacuum low channels Actions D.2.1 place the plant inMode 3 within 12 isolating the affected lines within 8 hours0.333 days 0.0476 weeks 0.011 months , an optional action is provided to and D.2.2 hours0.0833 days 0.0119 weeks 0.00274 months and Mode 4 within 36 hours1.5 days 0.214 weeks 0.0493 months .

N/A Table 3.2-1 Note 4, 6 CTS requires action to be taken L10 When more than one channel associated with a trip function is inoperable, the 1.b.2) and take the required actions specified in the Table within 6 hours0.25 days 0.0357 weeks 0.00822 months to place the channel(s) intrip inone trip system or to footnote **

containment isolation capability is for the associated Function. These actions must be taken even if primary will be allowed (depending upon whether or maintained. The ITS will not include this requirement; 12 or 24 hours1 days 0.143 weeks 0.0329 months Ifit is isolation capability is maintained.

not the channel is common to RPS) to trip an inoperable channel provided 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 appIv.

PAGE 8 JAFNPP

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SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 3.3.6.1 Table 3.2-1 Note 6 L11 The CTS provides 24 hours1 days 0.143 weeks 0.0329 months to reach cold shutdown (Mode 4). In the ITS, the time to reach Mode 4 is 36 hours1.5 days 0.214 weeks 0.0493 months .

Required 3.A Actions D.2.2 and H.2 3.3.6.1 Table 3.2-1 Notes 6 L12 The CTS provides 8 hours0.333 days 0.0476 weeks 0.011 months to close the MSIVs. In the ITS, the time to close the MSIVs is 12 hours0.5 days 0.0714 weeks 0.0164 months .

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

N/A Tables 4.1-1 and 3 L14 The details that identify those portions of the instrument channel which require functional testing and the details 4.1-2 that identify the type of test equipment used to perform a channel calibration have been deleted.

N/A N/A N/A L15 Not used.

Table 3.3.6.1-1 Table 3.2-1 Trip 1 L16 The Trip Level Settings (changed to Allowable Value in DOC Ai6) for the HPCI Turbine Steam Line High Flow Allowable Level Setting for Function is changed from < 160 inches of water dP in the CTS to < 168.24 inches of water dP in the ITS.

Value for Trip Function 13 Function 3.a Table 3.3.6.1-1 Table 3.2-1 Trip 1 L17 The Trip Level Settings (changed to Allowable Value inDOC A16) for the Main Steam Line High Flow Function is Allowable Level Setting for changed from < 140% of rated steam flow inthe CTS to < 125.9 psid inthe ITS.

Value for Trip Function 9 Function 1.c 3.3.6.1 N/A 4 L18 The ITS includes an allowance to open, under administrative controls, penetration flow paths closed to comply with the Actions. ACTIONS Note 1

3.3.6.1 Table 3.2-1 Note 5 L19 The CTS requires the plant to be incold shutdown in 24 hours1 days 0.143 weeks 0.0329 months when the inoperable TIP System reactor water ACTION G, 3.A level low or drywell pressure high channels are not tripped within the allowed times. In the ITS, inlieu of 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 hours0.0417 days 0.00595 weeks 0.00137 months . Due to this change, the TIP System Functions listed above are called out as separate line items inthe ITS. Functions 7.a and 7.b PAGE 9 JAFNPP

TABLE L- LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 3.3.6.2, SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION N/A Table 3.2-1 Note 4, 6 Li When more than one channel associated with a trip function is inoperable, the CTS requires action to be taken 1.b.2) and within 6 hours0.25 days 0.0357 weeks 0.00822 months to place the channel(s) in trip inone trip system or to take the required actions specified inthe Table footnote **

for the associated Function. These actions must be taken even ifsecondary containment isolation capability is maintained. The ITS will not include this requirement; 12 hours0.5 days 0.0714 weeks 0.0164 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.

3.3.6.2 Table 3.2-1 Note 5 L2 The CTS requires the plant to be in cold shutdown in24 hours1 days 0.143 weeks 0.0329 months when the inoperable reactor water level low or ACTION C 3.A drywell pressure high channels are not tripped within the allowed times. Inthe ITS, inlieu of a shutdown when the 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 .

N/A N/A N/A L3 Not used.

3.3.6.2 RETS Table 3.10- 5 L4 The RETS requires the associated secondary containment penetration flow paths to be isolated and the Required 1 Note d associated SGT subsystems to be placed in operation when the inoperable refuel area exhaust monitors or 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 .

N/A N/A N/A L5 Not used.

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

N/A Tables 4.1-1 and 3 L7 The details that identify those portions of the instrument channel whic6 require functional testing and an instrument 4.1-2, RETS check and the detail of the method of calibration have been deleted. Table 3.10-2 3.3.6.2 RETS Table 3.10- 4 L8 The RETS requires both trip systems to have at least one operable or tripped refuel area radiation monitor and ACTION B 1 reactor building area radiation monitor channel; however no actions are provided iftrip capability is lost. The ITS 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, ifit is not maintained.

3.3.7.1, CREVAS SYSTEM INSTRUMENTATION PAGE 10 JAFNPP

TABLE L- LESS RESTRICTIVE CHANGES MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE NONE NONE NONE NONE NONE 3.3.7.2, CONDENSER AIR REMOVAL PUMP ISOLATION INSTRUMENTATION 3.3.7.2 RETS 3.9.a, 2, 5 Li The RETS requires the mechanical vacuum pump to be capable of being automatically isolated and secured 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 3.3.7.2 1 and 3.E 4 and 5. Also, the CTS requires the function to be operable whenever the primary containment integrity is 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. Inaddition, 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. Inlieu of this action, the 3.

ITS provides an optional action to isolate the main steam lines or to be in Mode 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 hours0.25 days 0.0357 weeks 0.00822 months to place the channel(s) intrip inone trip system or to take the 1.b.2) and footnote **

required actions specified inthe Table for the Function. These actions must be taken even ifcondenser air removal pump isolation capability is maintained. The ITS will not include this requirement; 24 hours1 days 0.143 weeks 0.0329 months will be allowed to trip an inoperable channel provided isolation capability is maintained. Ifitis not, then the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action inthe CTS and ITS will apply.

3.3.7.2 Table 3.2-1 Note 6 L3 The CTS provides 8 hours0.333 days 0.0476 weeks 0.011 months to isolate the mechanical vacuum (air removal) pump. Inthe ITS, the time to isolate the air removal pump is 12 hours0.5 days 0.0714 weeks 0.0164 months . Required 3.E Action C.1 SR 3.3.7.2.4 RETS Table 3.10- 3 L4 The RETS stipulates a "simulated" automatic actuation test of the condenser air removal pump isolation shall be 2 Note f performed. The ITS allows use of an "actual" isolation signal, inaddition to the simulated automatic isolation signal, for verifying that the air removal pump isolates on the proper signal.

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 3.3.7.3 LCO 3.0.C 5 Li The CTS does not provide any specific actions for when the instrumentation is inoperable, thus the actions for ACTIONS A,B, inoperable ESW subsystems must be taken. Since each channel provides input to both ESW subsystems, both and C subsystems would have to be declared inoperable; and since the CTS does not provide any actions for both ESW subsystems inoperable, a shutdown per LCO 3.0.C would be required. Inlieu of this shutdown action, the ITS provides three ACTIONS that allows operation to continue with inoperable channels ifcertain conditions are met.

Ifone or more channels are inoperable, 24 hours1 days 0.143 weeks 0.0329 months is allowed to place the inoperable channels intrip. Ifisolation 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 Requirements required Surveillances, without entering the associated Conditions and Required Actions for up to 6 hours0.25 days 0.0357 weeks 0.00822 months Note provided the associated Function maintains initiation capability.

N/A 4.11.D.1 .e 3 L3 The CTS requirement to perform an ESW instrumentation check once per day has been deleted, since there are no pressure indicators or recorders associated with this instrumentation.

N/A 3.11.D.2 3 L4 The CTS requires the Emergency Diesel Generator (EDG) System be demonstrated Operable immediately and at least daily thereafter ifthe ESW System (i.e., the ESW instrumentation) is inoperable. These explicit verifications have all been deleted.

N/A 3.11.D.2 3 L5 The CTS requires the Emergency Diesel Generator System emergency loads be verified Operable immediately and at least daily thereafter ifthe ESW System (i.e., the ESW instrumentation) is inoperable. These explicit verifications have all been deleted.

3.3.8.1, LOP INSTRUMENTATION Table 3.3.8.1-1 Table 3.2-2 Trip 1 Li The CTS Trip Level Settings (changed to Allowable Values) for the 4.16 kV Emergency Bus Undervoltage Loss of Level Settings for Allowable Voltage, Degraded Voltage, and Time Delay Functions have been changed inthe ITS, consistent with recent Item Nos. 19, 20, Values for setpoint calculations. 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 inthe ITS. Required Action B.1 The CTS does not provide any actions ifthe associated power supply is not removed from service; thus a plant 3.3.8.2 N/A 5 L3 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.

The CTS requires that at least one RPS division be powered from its respective motor generator while inMODE 1. N/A 3.9.G.3 1,4 L4 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 ina cold condition within the next 24 hours1 days 0.143 weeks 0.0329 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 or Refuel

8. Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown

9. Elimination of CTS Reporting Requirement PAGE 14 JAFNPP

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 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 L1 hydraulic stability) for up to 24 hours1 days 0.143 weeks 0.0329 months . In this same condition, the CTS would require restoration of requirements within 8 hours0.333 days 0.0476 weeks 0.011 months or would require a plant shutdown within the following 12 hours0.5 days 0.0714 weeks 0.0164 months . This change relaxes the effective allowed outage time to 24 hours1 days 0.143 weeks 0.0329 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 inoperation and a delay inperformance of the Surveillance Notes 1 and 2 until 24 hours1 days 0.143 weeks 0.0329 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 inwhich 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.

SR 3.4.2.1 4.6.G.3 L2 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 I pump differential pressures measurement, the variance allowed should be 20%.

J 3.4.3. SAFETY/RELIEF VALVES 11 The CTS requires the reactor to be placed in a cold condition (MODE 4) within 24 hours1 days 0.143 weeks 0.0329 months ifthe minimum number of Operable safety/relief valves is not met. Inthe ITS, the time allowed for the plant to reduce temperature to be in MODE 4,is extended to 36 hours1.5 days 0.214 weeks 0.0493 months .

PAGE 1 JAFNPP

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

SUMMARY

TYPE CTS SECTION CHANGE TYPE I ITS SECTION 3.4.4, RCS OPERATIONAL LEAKAGE 2

L.U 3.4.4.d 3.6.D.1.b Li The unidentified leakage rate increase limit is changed to be applicable only inMODE 1 instead of the current LEAKAGE increase MODES 1, 2, and 3 (i.e., is at operating pressure after a period of 24 hours1 days 0.143 weeks 0.0329 months ). An unidentified the RCPB and must be quickly evaluated 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 up and increases pressure, leakage will to determine the source and extent of the LEAKAGE. As the plant starts if greater than the limit, could require a occur due to the increased pressure. Thus, an increase is detected, and change will not require the limit to be plant shutdown, even though there is no safety problem. This proposed stabilized at nominal operating applied until MODE 1 is achieved, which is when reactor pressure has effectively pressure.

LCO 3.4.4.c 3.6.0.1 .c 1 L2 The CTS requires that total leakage not exceed 25 gpm. The ITS requires that total LEAKAGE not exceed leakage to 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 i

be greater than 25 gpm, as long as the average is less than 25 gpm. ________

3.4.4 Required 3.6.0.3 4 hours0.167 days 0.0238 weeks 0.00548 months . The ITS provides an 3A4.4 Required 3.6.D.3 L3 The CTS requires that the source of an increase inthe leakage be identified within 4 Action B.1 within acceptable limits additional option to allow the operators to reduce the leakage (or leakage increase) to within the same 4 hours0.167 days 0.0238 weeks 0.00548 months . I I

) A r ! ^fI rf I cT~r'TItnNl TAVA IN*ITRU INAIeNTATION 3.4.5 Ut tU IIUN K(;bLLAKAL NO I3.6.D.4,I m3.6-1,D16 LCO 3.4.5, 3.4.5 S3.6.D.4, 3.6.D.6 Li The CTS allows continued operation for 30 days ifonly one monitor of the Continous Atmospheric Monitoring ACTIONS B and 24 hours1 days 0.143 weeks 0.0329 months System (gaseous or particulate) is inoperable. The CTS also requires a grab sample to be taken every C is required. The ITS will allow one of during the 30 day period. If both are inoperable, a shutdown per CTS 3.0.C CHECK, is performed on the the two monitors to be inoperable indefinitely, provided SR 3.4.5.1, a CHANNEL The ITS will also allow remaining Operable Containment Atmospheric Monitoring System monitor, every 8 hours0.333 days 0.0476 weeks 0.011 months .

for 30 days, provided a grab sample both Containment Atmospheric Monitoring Systems monitors to be inoperable the term "one channel" is used inthe ITS is taken every 12 hours0.5 days 0.0714 weeks 0.0164 months . Also, to be consistent with the format of the ITS, OPERABLE if only one of the two gaseous inlieu of defining in the LCO section of the Bases that the System is monitors channels) and one of the two particulate monitors (channels) are OPERABLE. .9 PAGE 2 JAFNPP

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

SUMMARY

TYPE 3.4.5 ACTION A 3.6.D.5 6 L2 The CTS requires that an inoperable sump monitoring system be restored to OPERABLE status within 24 hours1 days 0.143 weeks 0.0329 months .

30 days.

The ITS requires an inoperable drywell sump monitoring system be restored to OPERABLE status within However, this 30 day Completion Time is allowed provided RCS unidentified and total LEAKAGE can still be determined every 4 hours0.167 days 0.0238 weeks 0.00548 months .

3.4.5 ACTIONS N/A 7 L3 A statement that LCO 3.0.4 is not applicable for the condition of the drywell floor drain sump monitoring system A and C Notes inoperable or both drywell atmospheric monitors inoperable has been added as a Note to the ITS ACTIONS.

Currently, this allowance is not provided.

per day N/A Table 4.2-5 3 L4 The CTS requirement that an instrument check be performed on the drywell floor drain sump monitor once is not included in the ITS.

of N/A 3.6.D.4, 3.6.D.5, 1 L5 The drywell equipment drain sump monitoring system functions to quantify identified leakage. Since the purpose for early 4.6.D.4, Table 3.2 ITS 3.4.5, RCS Leakage Detection Instrumentation, is to provide instrumentation requirements been 5, Table 4.2-5 identification of unidentified leakage, the drywell equipment drain sump monitoring system requirements have deleted.

Surveillance N/A 6 L6 A Note has been added to allow a channel to be inoperable for up to 6 hours0.25 days 0.0357 weeks 0.00822 months solely for performance of required Requirements Surveillances provided the other Leakage Detection System channel is OPERABLE.

Note 3.4.6, RCS SPECIFIC ACTIVITY N/A 3.6.C.1 1 Li The CTS requires that the reactor not be operated more than 5% of its annual power operation with the reactor adopted inthe coolant specific activity in excess of 0.2 pCi/gm DOSE EQUIVALENT 1-131. This requirement is not ITS, in accordance with the recommendations in Generic Letter 85-19, Reporting Requirements on Primary Coolant Iodine Spikes.

or ifthe 3.4.6 Required 3.6.C.1, 3.6.C.5 6 L2 The CTS requires that, ifthe iodine concentration exceeds the equilibrium limit by more than a factor of 10, placed in a cold condition (MODE 4) within 24 hours1 days 0.143 weeks 0.0329 months . Action B.2.2.2 equilibrium limit is not met within 48 hours2 days 0.286 weeks 0.0658 months , the reactor be 4 by 12 The ITS requires the plant to be inMODE 4 in36 hours1.5 days 0.214 weeks 0.0493 months , essentially extending the time to reach MODE

_I hours._I PAGE 3 JAFNPP

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

SUMMARY

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

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

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

to perform a N/A 4.6.C.l.a, 3 L5 The requirements to analyze for gross gamma activity have been deleted. In addition, the requirement 4.6.C.1 .c, ifthe total iodine concentration is in excess of 0.002ktCi/ml as quantitative determination of 1-131 and 1-133 4.6.C.1 .d, indicated by the results of these surveillances is also deleted.

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

has been added that will require the SR to be performed only in MODE 1, since the level of fission products the limits generated in MODES 2 and 3 is much less than those generated during power operation and, therefore, 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

ITS SECTIOIN I .,,ITS SE:G ,I IUNl~

DOC #

SR 3.4.9.3 Note 2,3 4.6.A.6 that the temperature 1, SR 3.4.9.5 Li The CTS requires verification, when Reactor Coolant System temperature is> 140'F, vessel bottom head, and between the RCS and an idle recirculation Note differential between the RCS and the reactor these requirements are modified by a loop, are within limits prior to startup of the idle recirculation loop. Inthe ITS, MODES 1, 2, 3, and 4 during Note which states that these P/T verifications are only required to be met in overall Applicability of the Specification is reduced since the recirculation pump startup. Therefore, the surveillances are no longer required in MODE 5 with temperatures > 1400F.

SR 3.4.9.3 3.4.9.4Note 3.6.A.6.a 3 and the reactor vessel bottom 2, SR L2 The CTS requires the temperature differential between the reactor coolant system startup. The ITS 3.4.9 maintains this Surveillance, but head drain line be < 145'F during a recirculation pump pump flow exceeds 40% of rated provides the option, in lieu of this Surveillance, to verify the active recirculation below 40% rated flow for a period no longer than 30 pump flow or the active recirculation pump has been operating minutes.

CTS 314.6.F, STRUCTURAL INTEGRITY 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 or Refuel

8. Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown

9. Elimination of CTS Reporting Requirement PAGE 5 JAFNPP

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

SUMMARY

I TYPE I

3.5.1, ECCS - OPERATING SR 3.5.1.10, SR 4.5.A.1 4.5.C.1,.a,4.5.D.1.a, 4.5.A.3, 3 automatic actuation test 3.5.1 .11 Li CTS requirements for actuation testing of CS, LPCI, HPCI, and ADS stipulate a simulated 3.5.1.11 Table 4.2-2 Note 7 initiation signal, has been added to the shall be performed. The phrase "actual or," inreference to the automatic on an automatic initiation signal.

ITS Surveillance Requirements for verifying that each ECCS subsystem actuates Surveillance Requirements.

This allows satisfactory automatic system initiations to be used to fulfill the N/A 4.5.A.2, 4.5.A.3.a, (CS) subsystem and both low 4.5.C.1 .a, L2 CTS 4.5.A.2 requires the immediate verification that the remaining Core Spray that one CS subsystem is 4.5.D.2.a pressure coolant injection (LPCI) subsystems are Operable whenever it is determined CS subsystem is Operable daily 4.5.D.2.b determined to be inoperable. It also requires the verification that the remaining remaining LPCI subsystem and thereafter. CTS 4.5.A.3.a requires the immediate and daily verification that the subsystem is determined to be both CS subsystems are Operable whenever it is determined that one LPCI Operable daily thereafter. CTS inoperable. It also requires the verification that the remaining CS subsystem is System actuation logic be 4.5.C.1 .a requires that both LPCI subsystems, both CS subsystems, and the ADS to be inoperable. Italso requires verified to be Operable immediately when it is determined that HPCI is determined daily thereafter. When it is that the RCIC System and the ADS System logic be verified to be Operable ADS System actuation logic for the determined that two ADS valves are inoperable, CTS 4.5.D.2.a requires the immediately and at least weekly thereafter.

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

been deleted.

3.5.1 3.5.D.1 .a, 3.5.D.2 2 from > 100 psig to > 150 psig to Applicability, L3 The pressure at which ADS is required to be Operable is proposed to be increased this change the default action of the 3.5.1 Required provide consistency with the Operability requirements for HPCI. Along with steam dome pressure to _<150 Action G.2 CTS to reduce pressure to less than 100 psig has been changed to reduce reactor psig consistent with the Applicabiity. 6 3.5.1 Required 3.5.A.6,3.5.C.1.b, 3.5.D.2,3.9.F.3 the ACTIONS for LPCI or CS Actions B.2 and L4 The CTS requires that the reactor be inthe cold condition within 24 hours1 days 0.143 weeks 0.0329 months when pressure be reduced to less than G.2 cannot be satisfied, requires that the reactor be in the cold condition and reactor requires that the reactor be placed in 150 psig within 24 hours1 days 0.143 weeks 0.0329 months when the ACTIONS for HPCI cannot be satisfied, (modified by DOC L3) within 24 hours1 days 0.143 weeks 0.0329 months the cold condition and that reactor pressure be reduced to less than 100 psig and requires that the reactor shall be when the Required Actions for inoperable ADS valves cannot be satisfied, supplies are made or found to be brought to cold condition within 24 hours1 days 0.143 weeks 0.0329 months when both LPCI independent power entry when the ACTIONs or inoperable. This specific default action has been interpreted to also require supply are not met since no other Completion Times associated with one inoperable LPCI independent power inMODE 4 from 24 hours1 days 0.143 weeks 0.0329 months to 36 exists. The ITS extends the time allowed for the plant to reduce pressure or be hours.

PAGE 1 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 3.5.1 Required 3.5.C.i .a 6 L5 The CTS allows continued operation for a maximum of 7 days after HPCI only is determined to be inoperable. The ITS allows continued operation for a maximum of 14 days under the same conditions. Action C.1 3.5.1 ACTION D 3.5.C 4 L6 The CTS allows continued operation for a limited time ifHPCI is inoperable only ifthe ADS subsystem, the RCIC System, both LPCI subsystems and both core spray subsystems are Operable. The ITS will allow continued operation for 72 hours3 days 0.429 weeks 0.0986 months ifHPCI and one low pressure ECCS subsystem are inoperable or HPCI and one LPCI pump in each LPCI subsystem are inoperable.

SR 3.5.1.7, SR 4.5.A.3, 4.5.C.1i 3 L7 The flow rates specified inthe CTS for the Low Pressure Injection System and the High Pressure Injection System 3.5.1.8 have been decreased from 8910 gpm to 7700 gpm and from 4250 gpm to 3400 gpm, respectively, consistent with the values used in the plant specific LOCA analysis reflected inNEDC-31317P (James A.FitzPatrick Nuclear Power Plant SAFER/GESTR-LOCA Loss of Coolant Accident Analysis).

3.5.1 Condition 3.5.A.3.a 5 L8 The CTS requires that with one low pressure coolant injection pump inoperable ineach subsystem, the plant be A (second part) shutdown in accordance with the CTS 3.0.C, implying that the plant is outside design basis. This condition is not outside design basis, thus the ITS allows continued operation for 7 days inthis condition.

N/A 3.9.F.1 1 L9 The details in the CTS related to the specific inverter buses (MCC-155 and MCC-165) required to be inservice are not necessary to ensure the LPCI inverter and buses remain Operable. Therefore, they have not been included in the ITS.

N/A 3.9.F.2.a 4 L10 The CTS requires, ifone independent power supply becomes inoperable, the inoperable independent power supply 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 inCold Shutdown within 24 hours1 days 0.143 weeks 0.0329 months . This requirement has not been included inthe 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.

N/A 3.9.F.2.b 4 L11 The CTS requires the performance of additional Surveillances on the OPERABLE LPCI MOV Independent Power Supply System ifone LPCI MOV Independent Power Supply System is inoperable. The ITS does not include these additional Surveillance Requirements.

SR 3.5.1.2 Note N/A 1 L12 The ITS includes a Note that allows the LPCI subsystems to be considered OPERABLE during alignment and operation indecay heat removal below the RHR cut inpermissive in MODE 3, ifcapable 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 ifHPCI 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 inthe 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 intesting 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 hours0.167 days 0.0238 weeks 0.00548 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 hours0.333 days 0.0476 weeks 0.011 months . The ITS will require these verifications every 12 hours0.5 days 0.0714 weeks 0.0164 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 ITS SECTION CTS SECTION CHANGE DOC #

SUMMARY

TYPE test shall be SR 3.5.2.6 Table 4.2-2 Note 7 3 L4 CTS requirements for actuation testing of CS and LPCI stipulate a simulated automatic actuation initiation signal, has been added to the ITS performed. The phrase "actual or," in reference to the automatic and LPCI subsystem actuates on an automatic Surveillance Requirements for verifying that each required CS to be used to fulfill the Surveillance initiation signal. This allows satisfactory automatic system initiations Requirements.

from 8910 qpm to SR 3.5.2.5 4.5.F.1 3 L5 The flow rate specified in the CTS for the Low Pressure Injection System has been decreased reflected in NEDC-31317P (James 7700 gpm, consistent with the values used in the plant specific LOCA analysis A.FitzPatrick Nuclear Power Plant SAFER/GESTR-LOCA Loss of Coolant Accident Analysis).

3.5.3, RCIC SYSTEM to be inoperable. The 3.5.3 Required 3.5.E.1 6 Li The CTS allows continued operation for a maximum of 7 days after RCIC only is determined the same conditions. Action A.2 ITS allows continued operation for a maximum of 14 days under to less than 150 psig 3.5.3 Required 3.5.E.2 6 L2 The CTS requires that the reactor be in the cold condition and reactor pressure be reduced Action B.2 ITS extends the time allowed for the plant to within 24 hours1 days 0.143 weeks 0.0329 months when the ACTIONS for RCIC cannot be satisfied. The

-reduce pressure from_24_hours to_36_hours.

be SR 3.5.3.5 4.5.E.1 .a L3 The CTS requirement for actuation testing of RCIC stipulates a simulated automatic actuation test shall added to the ITS performed. The phrase "actual or," in reference to the automatic initiation signal, has been initiation signal. This allows Surveillance Requirement for verifying that the RCIC System actuates on an automatic system initiations to be used to fulfill the Surveillance Requirement.

I !satisfactory automatic N/A t 4.5.E.2 I 4 is inoperable. N/A 4.5.E.2 L4 The CTS requires that the HPCI System be verified to be Operable daily whenever the RCIC System This explicit verification has been deleted. -l 3.5.3 Required 3.5.E.2 I 4 status within 3.5.3 Required 3.5.E.2 L5 The CTS requires pressure to be reduced to less than 150 psig if RCIC is not restored to Operable Action B.2 dome pressure to be reduced to _< 150 psig under the same the allowed time. The ITS requires reactor steam since a reduction in reactor steam dome pressure to only 150 psig condition. This change is slightly less restrictive whereas in the CTS reactor steam dome pressure must be will be considered as satisfying the requirement, reduced to < 150 Psin.

PAGE 4 JAFNPP

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

SUMMARY

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

SUMMARY

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

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 commencement of a plant shutdown.

In 3.6.1.1 Required 3.7.A.8 6 L2 When a plant shutdown is required, the CTS requires the plant to be incold shutdown (Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months .

to place the plant in MODE 4. Action B.2 the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided the SR 3.6.1.1.1 4.7.A.1 3 L3 The Frequency for performing a visual inspection of the accessible interior surfaces of the drywell and above for evidence of deterioration is being changed from every 24 months water line of the torus (suppression chamber) to three times in a ten year period inthe ITS. The ITS will effectively require the visual inspection to be performed prior to each Type Atest and two additional times during each 10 year interval.

3.6.1.2, PRIMARY CONTAINMENT AIR LOCKS door 3.6.1.2 N/A 4 Li The ITS includes a Note to permit entry through a closed or locked air lock door (closed due to an inoperable for the purpose of making repairs. The proposed allowance will have strict administrative ACTIONS Note inthe associated air lock) 1 controls, which are detailed inthe proposed Bases.

door 3.6.1.2 Required N/A 4 L2 The ITS includes a Note to permit entry through a closed or locked air lock door (closed due to an inoperable for up to 7 days. The proposed allowance will have strict administrative Action A Note 2 inthe associated air lock) for any purpose controls, which are detailed in the proposed Bases.

3.6.1.2 ACTION N/A 4, 6 L3 A new ACTION is included inthe ITS for when a primary containment air lock is inoperable for reasons other than C, 3.6.1.2 one primary air lock door inoperable or a primary containment air lock interlock mechanism inoperable. The ITS is ACTIONS Note will allow up to 24 hours1 days 0.143 weeks 0.0329 months to restore the inoperable air lock under this condition, provided the primary containment 3

not rendered inoperable by the air lock inoperability.

In 3.6.1.2 Required 3.7.A.8 6 L4 When a plant shutdown is required, the CTS requires the plant to be incold shutdown (Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months .

Action D.2 the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant inMODE 4.

3.6.1.2, 3.6.1.3 3.7.A.4 4 L5 Adds ITS ACTIONS Note "Separate Condition entry is allowed for each air lock."

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 4.7.D.1 .a, Table 3 SR 3.6.1.3.7 shall be performed. The ITS allows for use 4.2-1 Note 7 LI The CTS stipulates a "simulated" automatic actuation test of the PCIVs automatic isolation signal, for verifying that each PCIV of an "actual" isolation signal, in addition to the simulated actuates on an automatic isolation signal. N/A N/A N/A L2 Not used. 5 In the ITS, PCIVs more inoperable two24or hours. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is 3.6.1.3 ACTION I 3.D.3 L3 The to anot does CTSdue specific ACTIONS provideproblem);

leakage for those thus the plant must beopen incold shutdownwith penetrations within (except BB lant shutdown.

allowed to isolate the affected penetration flow ahpirt eurn that have only one PCIV and the PCIV is 3.6.1.3 ACTION 3.7.D.3 5 The CTS does not provide specific ACTIONS for those open penetrations 3 L4 In the ITS, 4 hours0.167 days 0.0238 weeks 0.00548 months is provided it the inoperable; thus the plant must be incold shutdown within 24 hours1 days 0.143 weeks 0.0329 months . cC provided ifthe inoperable PCIV is an inoperable PCIV is not an EFCV or not ina closed system and 72 hours3 days 0.429 weeks 0.0986 months is a plant shutdown. In addition, a periodic EFCV or is in a closed system, to isolate the penetration prior to requiring verification of the isolated_.enetration is required eve 31 days. 3.6.1.3 Required 3.7.D.2.b penetration is inoperable. In the ITS, 8 Action A.1, L5 The CTS allows 4 hours0.167 days 0.0238 weeks 0.00548 months to isolate a penetration when one PCIV inthe second hours is allowed to isolate a main steam line penetration.

Completion Time 3.6.1.3 Required N/A 4

inoperable. The ITS will allow the Action A.1 L6 The ITS includes an additional method of isolating a penetration when a PCIV is through the valve secured.

penetration to be isolated by use of a check valve with flow 3.6.1.3 Required 3.7.D.3, 3.7.A.8 6

shutdown (Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months . In Action F.2 L7 When a plant shutdown is required, the CTS requires the plant to be incold the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to lace the lant in MODE 4. 3.6.1.3 Required 4.7.D.2 6 to comply with other actions) is changed from Action A.2 and L8 The periodic verification that a penetration is isolated (when isolated "Prior to entering MODE 2 or 3 C.2 a daily recording requirement inthe CTS to a monthly verification or a verification 4, if not performed within the previous 92 from MODE 4, ifprimary containment was de-inerted while in MODE da*_s for isolation devices inside rinam containment" in the ITS.

PAGE 2 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 3.6.1.3 ACTION 3.7.A.8 5 L9 The CTS does not provide specific ACTIONS for those MSIVs that are inoperable due to a leakage problem; thus the plant must be incold shutdown within 24 hours1 days 0.143 weeks 0.0329 months . In the ITS, 8 hours0.333 days 0.0476 weeks 0.011 months are allowed to restore MSIV leakage to D within limits prior to requiring a plant shutdown.

3.6.1.3 ACTION 3.7.A.8 5 L10 The CTS does not provide specific ACTIONS for the air operated testable check valves associated with the LPCI and CS systems injection penetrations that are inoperable due to a leakage problem; thus the plant must be in cold E shutdown within 24 hours1 days 0.143 weeks 0.0329 months . Inthe ITS, 72 hours3 days 0.429 weeks 0.0986 months are allowed to restore the leakage to within limits prior to requiring a plant shutdown.

3.6.1.3 Required 4.7.D.2 3, 4 L11 The CTS requires a verification that a penetration flow path with an inoperable PCIV is isolated. The ITS includes 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 N/A 4.7.A.2.c 3 L12 The CTS identifies the plant specific valve numbers for the air operated testable check valves associated with the LPCIlandCS systems injection penetrations._TheITS does not include these plant specific valve numbers.

SR 3.6.1.3.11 4.7.D.2.c 3 L13 The CTS requirement to demonstrate the leakage rate of the Low Pressure Coolant Injection (LPCI) System and 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 'tMA MFAI:I \IAC'I II I*IMR EA I(F:RS 3.6.1.6,, EACTOR IU UILUINI-T IU-bUr'r'nE1ooJ u*I'L'I VJM

-,rLm r ....

3.6.1.6 N/AC4 Li Adds ITS ACTIONS Note "Separate Condition entry is allowed for each lineA" ACTIONS Note

4) within 24 hours1 days 0.143 weeks 0.0329 months . In 3.6.1.6 Required 3.7.A.8 6 L2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode in MODE 4. Action E.2 the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant 3.6.1.7, SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS when N/A 4.7.A.5.b 3 Li The CTS requires that "When it is determined that one vacuum breaker is inoperable for fully closing breakers shall be exercised immediately, and every 15 days thereafter until the operability is required, the operable intheITS.

inoperable valve has been returned to normal service."_This requirement has not been included within 24 hours1 days 0.143 weeks 0.0329 months . In 3.6.1.7 Required 3.7.A.8 6 12 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown (Mode 4) the plant in MODE 4. Action C.2 the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place N/A N/A N/A L3 Not used.

an open-close SR 3.6.1.7.2 4.7.A.5.a 3 L4 The Frequency of the exercising of each Suppression Chamber-to-Drywell vacuum breaker through with the Inservice Testing (IST) Program" cycle is being extended from "monthly" inthe CTS to "InAccordance (i.e., 92 days) in the ITS.

o3 c 4 re, KA r-l TAUL I r-AVAr"E ~r-MII ErTIt"NM YVqTIFIM 3.6J.1 .8, MAU'I~INTEAM LEArVA'.t ULLtU IU IOT VJ1- ~'I NONE 1 INONEkI INONE INONE NONE ......

i I I I I I I 3 a 1n La n ,',r ,KITAIIMPArMT .RDIAV KHK UUN IAINMUN I orMMT I N/A I N/A I N/A I L I Not used.

PAGE 4 JAFNPP

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

SUMMARY

TYPE 3.6.1.9 Required 3.5.B.4 6 (Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months . In L2 When a plant shutdown is required, the CTS requires the plant to be incold shutdown Action C.2 the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant in MODE 4.

SR 3.6.1.9.3 4.5.B.1 .f 3 and nozzles has been extended L3 The Frequency for performance of an air test on the containment spray header from 5 years in the CTS to 10 years inthe ITS.

LCO 3.6.1.9 3.5.B.1 1 in each containment spray mode L4 The CTS requires two Residual Heat Removal (RHR) pumps to be Operable (including required to be Operable in each subsystem. In the ITS, only one RHR pump, as indicated inthe Bases, will be RHR containment spray subsystem.,bases) 3.6.1.9 ACTION N/A 5 are inoperable; thus a plant I L5 No actions are provided inthe CTS for when two RHR containment spray subsystems B to allow both RHR containment shutdown to cold shutdown is required. In the ITS, a new ACTION is provided spray subsystems to be inoperable for up to 8 hours0.333 days 0.0476 weeks 0.011 months prior to requiring a plant shutdown.

I 3.6.2.1, SUPPRESSION POOL AVERAGE TEMPERATURE 5 3.6.2.1 Required 3.7.A.1 the Action A.2 L1 No specific actions are provided in the CTS for when the suppression pool temperature is exceeding a plant shutdown to cold shutdown is temperature limit during normal power operation (i.e., not due to testing); thus temperature to < 95 OF, provided the required aInthe ITS, 24 hours1 days 0.143 weeks 0.0329 months is allowed to restore the suppression pool pool is in progress. t 5 temperature is < 110 O and no testing that adds heat to the suppression 3.7.A.8 is exceeding the 3.6.2.1 ACTION 3.7.A.8 L2 No specific actions are provided inthe CTS for when the suppression pool temperature B inDOC L1Inhas ITS, theexpired, after the timelimit temperature allowed restore power to normal during operation; pool the suppression a plant shutdown thus temperature to cold to within limits describedis required.

shutdown to cold shutdown).

12 hours0.5 days 0.0714 weeks 0.0164 months are allowed to reduce power to < 1%RTP (i.e., the ITS does not require a shutdown is indication of relief N/A 4.7.A.1 The CTS requires an external visual inspection of the suppression chamber whenever there L3 primary coolant valve operation with the local suppression pool temperature reaching 160O°F or greater and the system pressure greater than 200 psig. This Surveillance is not included inthe ITS.

- j I SR 3.6.2.1.1 I 4.7.A.1 13 is indication of relief valve operation or SR 3.6.2.1.1 4.7.A.1 L4 The CTS requires monitoring suppression pool temperature when "there monitoring of the suppression testing which adds heat to the suppression pool." The ITS only requires increased to monitor when there is indication of relief valve operation is not pool temperature during testing; the requirement -- I _. I___

with a specific test.

luluuvv inthe ITS unless it is associated included ". I.-

PAGE 5 JAFNPP

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

SUMMARY

is exceeded, the In the CTS, ifthe testing limit of 105 OF (95 OF plus the 10 OF increase allowed during testing)

In the ITS, ifthe suppression pool CTS requires the reactor to be placed inthe cold condition within 24 hours1 days 0.143 weeks 0.0329 months . restore and 24 hours is then allowed to temperature exceeds 105 OF, then testing must be immediately suspended temperature to <:95 OF prior to requiring a plant shutdown.

3.6.2.2, SUPPRESSION POOL WATER LEVEL 3.6.2.2 ACTION water level is not within the limits; thus a A No specific actions are provided inthe CTS for when the suppression pool restore the water level to within limits plant shutdown to cold shutdown is required. In the ITS, 2 hours0.0833 days 0.0119 weeks 0.00274 months is allowed to prior to requiring a plant shutdown.

(Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months . In 3.6.2.2 Required I 3.7.A.8 Action B.2 When a plant shutdown is required, the CTS requires the plant to be in cold shutdown the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant inMODE 4.

Not used.

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

(Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months . In When a plant shutdown is required, the CTS requires the plant to be incold shutdown the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant in MODE 4.

subsystems are inoperable; thus a No actions are provided inthe CTS for when two RHR suppression pool cooling ITS, a new ACTION is provided to allow both RHR plant shutdown to cold shutdown is required. Inthe inoperable for up to 8 hours0.333 days 0.0476 weeks 0.011 months prior to requiring a plant shutdown.

su~nnresinn nool cooling subsystems to be 3.6.2.4, DRYWELL-TO-SUPPRESSION CHAMBER DIFFERENTIAL PRESSURE pressure has been changed from once SR 3.6.2.4.1 The Frequency to monitor the drywell-to-suppression chamber differential PAGE 6 JAFNPP

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

SUMMARY

1)0, ,12DIL1APl~rf'fMTAIkNkAFNT AYVIF~M kIFNITRATICON 3.6.3.1I, HlKlV/*IMAKY.UUlN A1Ni

I*V~I 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 3.6.4.1 ACTION 3.7.C.2 5 Li The CTS does not provide any time to restore the secondary containment to Operable status if it is found to be inoperable. The CTS requires the plant to be in essentially cold shutdown within 24 hours1 days 0.143 weeks 0.0329 months ifthe secondary A containment is inoperable. In the ITS, 4 hours0.167 days 0.0238 weeks 0.00548 months is allowed to restore secondary containment to OPERABLE status prior to the commencement of a plant shutdown.

3.6.4.1 Required 3.7.C.2 6 L2 When a plant shutdown is required, the CTS requires the plant to be incold shutdown (Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months . In the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant in MODE 4. Action B.2_-A N/A 3.7.C.1 .b 2 L3 The CTS requires the Reactor Coolant System to be vented inorder for secondary containment to not be required.

The ITS does not include this requirement.

N/A 4.7.C.1 .c 3 L4 The requirement to perform the secondary containment capability test "prior to refueling" is not included inthe ITS since the normal periodic Surveillance Frequency is sufficient.

3.6.4.1 Required 3.7.C.2 5 L5 CTS 3.7.C.2 requires all four conditions of CTS 3.7.C.1 to be met ifsecondary containment is inoperable. If 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 hours1 days 0.143 weeks 0.0329 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, ifsecondary containment is inoperable when operating inMODE 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 (Mode 4) within 24 hours1 days 0.143 weeks 0.0329 months . In 3.6.4.2 Required 3.7.C.2 6 L1 When a plant shutdown is required, the CTS requires the plant to be incold shutdown Action C.2 the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to place the plant inMODE 4. 3.6.4.2 4

administrative NIA L2 The ITS includes a Note that allows penetration flow paths to be unisolated intermittently under ACTIONS Note controls, ifthey were closed to comply with actions. 1

_______I 3.6.4.2 ACTION 3.7.C.2 5 valve in a L3 The CTS does not provide any time to restore one inoperable secondary containment isolation A CTS requires the plant to be in essentially cold penetration to Operable status if it is found to be inoperable. The is inoperable. In the ITS, 8 hours is allowed to shutdown within 24 hours1 days 0.143 weeks 0.0329 months ifa secondary containment isolation valve isolate the affected secondary containment penetration prior to the commencement of a plant shutdown.

-i1 t i isolation valves in a 3.6.4.2 ACTION 3.7.C.2 L4 The CTS does not provide any time to restore both inoperable secondary containment B penetration to Operable status ifthey are found to be inoperable. The CTS requires the plant to be in essentially are inoperable. In the ITS, 4 hours0.167 days 0.0238 weeks 0.00548 months is cold shutdown within 24 hours1 days 0.143 weeks 0.0329 months ifany secondary containment isolation valves prior to the commencement of a plant shutdown.

allowed to isolate the affected secondary containment penetration valves to N/A 3.7.C.1 .b 2 L5 The CTS requires the Reactor Coolant System to be vented inorder for secondary containment isolation not be required. The ITS does not include this requirement.

N/A N/A N/A L6 Not used. 3 SR 3.6.4.2.3 Table 7, RETS4.2-1 Note Table The ITS allows L7 The CTS/RETS stipulates a "simulated" automatic actuation test of the SCIVs shall be performed.

to the simulated automatic isolation signal, for verifying that each 3.10-2 Note 7 for use of an "actual" isolation signal, inaddition SCIV actuates on an automatic isolation signal. -I 3.6.4.2 I N/A t 4 flow path." 3.6.4.2 N/A L8 Adds ITS ACTIONS Note "Separate Condition entry is allowed for each penetration ACTIONS Note 2

I I I PAGE 8 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 3.6.4.2 Required N/A 5 L9 Inthe CTS, ifsecondary containment is inoperable (due to SCIV inoperability) during movement of irradiated fuel, or during CORE ALTERATIONS, while operating in MODE 1,2, or 3, CTS requires plant shutdown and cooldown Actions D.A actions within 24 hours1 days 0.143 weeks 0.0329 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). InITS 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 hours0.333 days 0.0476 weeks 0.011 months or 4 hours0.167 days 0.0238 weeks 0.00548 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 3.6.4.3 Required N/A 5 Li The CTS prohibits irradiated fuel handling operations and operations that could reduce the shutdown margin (i.e.,

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

N/A N/A N/A L2 Not used.

N/A 3.7.C.l.b 2 L3 The CTS requires the Reactor Coolant System to be vented inorder for the SGT system to not be required. The ITS does not include this requirement.

SR 3.6.4.3.3 Table 4.2-1 Note 3 L4 The CTS/RETS stipulates a "simulated" automatic actuation test of the SGT subsystems shall be performed. The ITS allows for use of an "actual" isolation signal, inaddition 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

N/A N/A N/A L5 Not used.

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 inShutdown or Refuel

9. Elimination of CTS Reporting Requirement PAGE 10 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

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

3.7.1 3.0.C 6 L2 The CTS does not provide specific ACTIONS for two Residual Heat Removal (RHR) service 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 hours1 days 0.143 weeks 0.0329 months . In the ITS, when both RHRSW subsystems are inoperable for reasons other than one pump in each subsystem inoperable, 8 hours0.333 days 0.0476 weeks 0.011 months is allowed to restore one RHR service water subsystem to OPERABLE status.

3.7.1 3.5.B.4 6 L3 The CTS requires that the reactor be in the cold condition within 24 hours1 days 0.143 weeks 0.0329 months when the ACTIONS for RHRSW inoperabilities cannot be satisfied. The ITS extends the time allowed for the plant Required to be in MODE 4 from 24 hours1 days 0.143 weeks 0.0329 months to 36 hours1.5 days 0.214 weeks 0.0493 months . Action E.2 N/A 4.5.B.2, 4.5.B.3 4 L4 The CTS requires the remaining components of the containment cooling mode subsystems to be verified to be operable immediately and daily thereafter when an RHRSW component is inoperable. These explicit verifications have all been deleted.

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

SUMMARY

TYPE SR 3.7.2.7 4.11 .D.1 .a 3 Li The CTS requirement for actuation testing of the ESW System 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 ESW System actuates on an automatic initiation signal. This allows satisfactory automatic system initiations to be used to fulfill the Surveillance Requirement.

N/A 3.11 .D.2 4 L2 The CTS requires the Emergency Diesel Generator System emergency loads be verified Operable immediately and at least daily thereafter if the ESW System is inoperable. These explicit verifications have all been deleted.

3.7.2 3.11 .D.3, 3.0.C 6 L3 The CTS requires that the reactor be in the cold condition within 24 hours1 days 0.143 weeks 0.0329 months when the ACTIONS time Required for ESW and Ultimate heat sink inoperabilities cannot be satisfied. The ITS extends the Action C.2 allowed for the plant to be in MODE 4 from 24 hours1 days 0.143 weeks 0.0329 months to 36 hours1.5 days 0.214 weeks 0.0493 months .

3.8.1 3.11.D.2 4 L4 The CTS requires the Emergency Diesel Generator (EDG) System be demonstrated Operable Required immediately and at least daily thereafter if the ESW System is inoperable. These explicit Actions B.3.1 verifications have all been deleted. The ITS will only require a single verification (through the and B.3.2 EDG Technical Specification ACTIONS) of EDG Operability, either through an evaluation or demonstration, within 24 hours1 days 0.143 weeks 0.0329 months .

N/A 4.11 .E.2 3 L5 The CTS requirement to monitor individual heater current whenever large deviations are identified in the feeder checks has been deleted.

3.7.3, CREVAS SYSTEM SR 3.7.3.3 4.11 .A.5 3 Li The CTS requires the main control room emergency ventilation air supply system capacity to The be tested every 18 months to assure that it is within 10% of the design value of 1000 cfm.

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 ITS SECTION CTS SECTION CHANGE DOC #

SUMMARY

TYPE 3.7.5, MAIN CONDENSER STEAM JET AIR EJECTOR OFFGAS 3.7.5 N/A 4 Li The RETS requires the plant to isolate the SJAE or all main steam lines within the next 12 within 72 hours3 days 0.429 weeks 0.0986 months . The ITS includes an Required hours ifthe SJAE release rate is not below the trip level 12 hours and in MODE 4 within 36 Actions B.3.1 additional option allowing the plant to be in MODE 3 within and B.3.2 hours0.0833 days 0.0119 weeks 0.00274 months , in lieu of isolating the SJAE or main steam lines, is LCO 3.7.5, RETS 3.5.a L2 The RETS 3.5.a (LCO) specifies that the limits of gross radioactivity rate of noble gases (LCO section),

setting for the SJAE SR 3.7.5.1 given on Table 3.10-1. RETS Table 3.10-1 specifies the trip level RETS Table to Radiation Monitors as 500,000 pCi/sec. This LCO limit has been increased from 500,000 3.10-1 600,000 kCi/sec consistent with the value used in the Offgas System Failure accident of UFSAR, Section 11.4.7.2.

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

Note within limit must be current prior to entry into the mode of applicability in accordance with CTS 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 rates.

fission gases may be in the Main Steam Offgas System at significant 3.7.6, MAIN TURBINE BYPASS SYSTEM NONE NONE NONE NONE NONE 3.7.7, SPENT FUEL STORAGE POOL WATER LEVEL 3.7.7 3/4.1 0.C 2 Li The CTS requires the spent fuel storage pool level to be greater than or equal to the minimum Applicability level whenever irradiated fuel is stored in the spent fuel storage pool. The ITS Applicability is 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.

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

8. Elimination of the Requirement to Lock the Reactor Mode Switch in Shutdown

9. Elimination of CTS Reporting Requirement PAGE 4 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 3.8.1, AC SOURCES - OPERATING 3.8.1 ACTION N/A 5 Li The CTS does not provide a specific Action for the condition of one inoperable offsite circuit 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 hours1 days 0.143 weeks 0.0329 months . The ITS includes a new ACTION that provides 12 hours0.5 days 0.0714 weeks 0.0164 months to restore either the inoperable EDG or the inoperable offsite circuit in this condition prior to requiring a plant shutdown.

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

4) within 24 hours1 days 0.143 weeks 0.0329 months . In the ITS, 36 hours1.5 days 0.214 weeks 0.0493 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 SR 3.8.1.3 4.9.B.1 3 L3 The CTS requires that each EDG subsystem be force paralleled and loaded to 5200 kW, and 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.

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

3.8.1 4.9.B.5 6 L5 The CTS provides a Completion Time of 8 hours0.333 days 0.0476 weeks 0.011 months when an EDG subsystem is inoperable to 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 hours1 days 0.143 weeks 0.0329 months to verify the remaining EDG is not inoperable due to a common cause failure.

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE N/A 3.9.C.2.a L6 The CTS has an action that allows for operation to continue for 60 days with one inoperable 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.

3.8.1 3.0.E 5 L7 CTS 3.0.E requires the plant to be in cold shutdown within 24 hours1 days 0.143 weeks 0.0329 months when a redundant feature 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 hours1 days 0.143 weeks 0.0329 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 hours0.167 days 0.0238 weeks 0.00548 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 hours0.5 days 0.0714 weeks 0.0164 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.

SR 3.8.1.3 N/A 3 L8 The ITS includes a Note that allows gradual loading of the EDG as recommended by the manufacturer during the monthly load test. Note 1 SR 3.8.1.3 N/A 3 L9 The ITS includes a Note that allows momentary load transients to be outside the load range 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 ITS SECTION CTS SECTION CHANGE DOC #

SUMMARY

TYPE 3.8.2 3.9.D 4 Li The CTS requires, when the required EDG subsystem and offsite power source are not ACTIONS A Operable, suspension of all work that could cause draining of the reactor vessel, suspension and B of core alterations, suspension of handling of irradiated fuel assemblies in the secondary core containment, initiating action to restore the inoperable AC source, and declaring required and containment systems inoperable. In the ITS, when an offsite circuit is inoperable, the restore option of either suspending the above activities (and immediately initiating action to that is not the offsite circuit to Operable status) or declaring the associated equipment the receiving offsite power inoperable is provided. In addition, when the EDG is inoperable, not allowed.

option to declare the associated equipment inoperable is 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR N/A 3.9.C.1 1 Li The CTS allowance, to continue reactor operation indefinitely, ifthe affected fuel oil storage tank level is manually measured at least once per day when the fuel oil storage tank level oil indicator is found to be inoperable for any reason, is not retained in the ITS, since the fuel 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).

a 3.8.3 ACTION 3.9.C.3 4 L2 The CTS allows that, ifthe available diesel fuel decreases below the required quantity as Specification requirements, A result of operation of the diesel generators to meet Technical Specification 3.0.C does not apply, and 48 hours2 days 0.286 weeks 0.0658 months are allowed to restore the required diesel fuel supply. In the ITS, 48 hours2 days 0.286 weeks 0.0658 months is provided to restore the diesel fuel supply to within limits, regardless of the reason it is not within limits.

N/A 4.6.B.2 1,3 L3 The CTS requires the EDG starting air compressor to be checked for operation and its ability to to recharge air receivers. In the ITS, only the air receiver pressure is required to be verified be within limits. The manner in which the air receivers are recharged is not an attribute of Operability.38 4 D S U E -O R I starting air 3.8.4, DC SOURCES - OPERATING PAGE 3 JAFNPP

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

SUMMARY

TYPE D

to be N/A 3.9.E.2.b, 3 Li The CTS requires the pilot cell voltage, specific gravity, overall voltage, and temperature 3.9.E.2.c, the measured immediately and daily thereafter for the Operable battery and requires 3.9.F.2.b when availability of the unaffected Emergency Diesel Generator System to be demonstrated, of additional one 125 VDC battery is inoperable. Similarly, the CTS requires the performance if one LPCI Surveillances on the Operable LPCI MOV independent power supply subsystem are not MOV independent power supply subsystem is inoperable. These verifications required in the ITS.

N/A N/A N/A L2 Not used.

battery if the N/A 3.9.E.2.a, 4 L3 The CTS allows power operation to continue with an inoperable 125 VDC 3.9.F.2.a 125 VDC electrical power subsystem battery distribution system associated with the Operable to continue with an inoperable LPCI is Operable. Similarly, the CTS allows power operation system associated with the Operable independent power supply if the inverter and distribution not retain these explicit LPCI independent power supply is Operable. The ITS does control the Operability of the requirements, since other Technical Specifications adequately distribution subsystems.

thus a 3.8.4 ACTION N/A 5 L4 No actions are provided in the CTS for when a 125 VDC battery charger is inoperable; ACTION (encompassed by the A plant shutdown to cold shutdown is required. In the ITS, a new charger to be inoperable for up inoperable 125 VDC source ACTION) is provided to allow one to 8 hours0.333 days 0.0476 weeks 0.011 months prior to requiring a plant shutdown.

month and N/A 4.9.E.7 3 L5 The CTS requirement to open the battery charger output breakers once per VDC battery observe performance for proper operation has been deleted since the 125 charger output breaker is not required to open during any accident sequence.

N/A 4.9.F.2.c 4 L6 The CTS requires that if one independent power supply becomes inoperable, the inoperable this bus independent power supply must be isolated from its associated LPCI MOV bus, and to be manually switched to its alternate power source. If this cannot be met, a plant shutdown CTS allows cold shutdown is required. This requirement is not maintained in the ITS since the a 7 day Completion Time for any other LPCI subsystem inoperability with no other compensatory actions. I ______________

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

SUMMARY

TYPE shutdown (Mode 3.8.4 3.9.E, 3.9.F.3, 6 L7 When a plant shutdown is required, the CTS requires the plant to be in cold 3.9.F.2 place the plant in Mode 4. In addition, Required

4) within 24 hours1 days 0.143 weeks 0.0329 months . In the ITS, 36 hours1.5 days 0.214 weeks 0.0493 months are provided to 24 hours1 days 0.143 weeks 0.0329 months if both LPCI MOV Actions B.2 the CTS requires the plant to be in cold shutdown within subsystems and C.1 Independent Power Supplies are inoperable. In the ITS, the associated LPCI hours is provided to place the must be declared inoperable, and once declared inoperable, 36 4.

plant in Mode has been included SR 3.8.4.3 4.9.E.3, 4.9.E.4 3 L8 The CTS requirement to perform CTS 4.9.E.3 and 4.9.E.4 during shutdown can be SR 3.8.4.4 in the ITS. However, the ITS includes an allowance that portions of the Surveillance the safety of the performed to reestablish OPERABILITY provided an assessment determines to satisfy plant is maintained or enhanced and that credit for unplanned events can be taken this SR.

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

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

days, is being SR 3.8.6.3 4.9.E.2.c, 3 L3 The CTS requirement to measure the temperature of every fifth cell every 92 4.9.F.2.c of representative cells (10%

changed. The ITS requires the average electrolyte temperature reduces the number of cells of the total) be verified within limits every 92 days. This change batteries and from 38 to 19 tested from 12 to 6 based on a total of 60 cells in the 125 VDC 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 3.8.7 N/A 5 No actions are provided in the CTS for when an AC or 125 VDC distribution bus is inoperable; thus a plant shutdown to cold shutdown is required. In the ITS, new ACTIONS are provided ACTIONS A and B to: a) allow AC distribution buses to be inoperable for up to 8 hours0.333 days 0.0476 weeks 0.011 months , provided a loss of 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 hours0.333 days 0.0476 weeks 0.011 months prior to requiring a plant shutdown. In addition, a maximum time the LCO cannot be met is also provided (16 hours0.667 days 0.0952 weeks 0.0219 months ).

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

4) within 24 hours1 days 0.143 weeks 0.0329 months . In the ITS, 36 hours1.5 days 0.214 weeks 0.0493 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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE N/A 4.10.A.1 3 L3 The CTS requires a functional test required following any repair work associated with the interlock. This specific post maintenance testing is not retained in the ITS.

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

SUMMARY

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 PAGE 3 JAFNPP

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 ifan 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 inreactor coolant temperature to _<2120OF. Action A.2.2 The Applicability of this Specification is when reactor coolant temperature is > 212 0 F, therefore, reducing the coolant temperature as specified inthe 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 inMODE 1 or 2, as applicable. This testing can proceed only ifthere are no Core Alterations inprogress, and if all control rods remain fully inserted incore cells containing one or more fuel assemblies. When these two conditions are met, the situation is equivalent to maintaining the reactor mode switch inshutdown. Control rods are not required to be inserted inempty core cells (i.e., those containing no fuel) because, with one or more core cells inthis 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 inthe refuel position, allow a single 3.10.3 N/A control rod to be withdrawn, and still be considered to be inMODE 3, provided certain MODE 5 requirements are met. Currently, rods are not allowed to be withdrawn while inMODE 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 inwhich SDM is met. These additional requirements effectively compensate for the reactor mode switch not being inthe 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 inMODE 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 ina 5 x 5 array centered on the withdrawn rod are disarmed, allowing a modification to the way inwhich SDM is met. These additional requirements effectively compensate for the reactor mode switch not being inthe shutdown position with a rod withdrawn.

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

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SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The CTS requires the reactor mode switch to be locked inthe 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 inCTS 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 inthe 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 inaccordance 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 ifall 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 hours0.167 days 0.0238 weeks 0.00548 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 intwo 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.

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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 inthe 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 JAFNPP PAGE 4

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

SUMMARY

ITS SECTION CTS SECTION CHANGE TYPE Li The allowances inCTS 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 instartup/hot standby position 3.7.A.5, 3.7.D.1, (ITS 3.10.8 Applicability). In addition, the allowances inCTS 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). Inthese 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 intwo 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 inthe 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 inthe Discussion of Changes for ITS Chapter 1.0. However, inthe 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 instartup/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 inprogress; 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 PAGE 6 JAFNPP

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC # TYPE 4.2.1 N/A Li The ITS includes an allowance for a limited number of lead test assemblies that have not 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.

4.2.1 5.2.1 L2 The CTS requires that each fuel assembly consist of Zircaloy clad fuel rods. The ITS also 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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 5.1, RESPONSIBILITY NONE NONE NONE NONE NONE 5.2, ORGANIZATION Not used. N/A N/A N/A Li 5.3, PLANT STAFF QUALIFICATIONS NONE NONE NONE NONE NONE 5.4, PROCEDURES NONE NONE NONE NONE NONE 5.5, PROGRAMS ANDMANUALS N/A 4.7.B.1 .b 3 L1 The CTS requirement that certain SGT System filter tests be performed at a Frequency of "at least once during each scheduled secondary containment leak rate test," is not retained in the ITS.

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

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 L3 TheITS requires that this test be performed at a flowrate of_5400 to_6600_scfm.

JAFNPP PAGE 1

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

SUMMARY

ITS SECTION CTS SECTION CHANGE DOC #

TYPE 5.5.7 N/A 4 L4 The ITS provides an allowance for the application of SR 3.0.3 to the IST Program requirements. This change, which applies SR 3.0.3 to the existing requirements, allows 24 hours1 days 0.143 weeks 0.0329 months to perform the required testing (or inspection) of equipment if it was not performed within the specified Frequency.

5.5.2 N/A 3, 4 L5 The ITS includes a statement of applicability of ITS SR 3.0.2 and SR 3.0.3 to the Primary 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 hours1 days 0.143 weeks 0.0329 months to perform the required testing (or inspection) of equipment if it was not performed within the specified Frequency.

5.5.9 N/A 3, 4 L6 The ITS includes a statement of applicability of ITS SR 3.0.2 and SR 3.0.3 to the Storage 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 hours1 days 0.143 weeks 0.0329 months to perform the required testing (or inspection) of equipment if it was not performed within the specified Frequency.

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

5.6, REPORTING REQUIREMENTS 5.6.1 6.9.A.2.a 1 Li The CTS requires that, "at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions." The ITS changes the word "shall" to "should."

5.6.2 RETS 7.3.d 1 L2 The RETS requires that the Annual Radiological Environmental Operating Report be submitted prior to May 1 of each year. The ITS requires this report to be submitted by May 15 of each year.

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

2. Relaxation of Applicability

3. Relaxation of Surveillance Requirement

4. 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 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 hours1 days 0.143 weeks 0.0329 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 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 SECTION 3.0 - LCO AND SR APPLICABILITY

SUMMARY

LOCATION CHANGE CHANGE ITS SECTION CTS CONTROL TYPE AND DOC # SECTIO PROCESS N

NONE NONE NONE NONE NONE NONE CHANGE TYPE

1. Details of system design and system description including design limits

2. Description of system operation specification requirements

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

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

SUMMARY

CHANGE CONTROL ITS SECTION AND CTS PROCESS DOC # SECTION L-31 .. SHUTI"WN I MARGIN 11 Details of the method to perform the CTS 4.3.A.1 (e.g., sufficient control rods shall Bases Bases Control Program 3.1.1 - LA1 4.3.A.1 be withdrawn) and the details of the requirements inCTS 3.3.A.1 and 4.3.A.1 (e.g.,

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

3.1.2, REACTIVITY ANOMALIES 11 4.3.D Details of the method to perform the Surveillance and the purposes for the Bases Bases Control Program 3.1.2 - LAl Reactivity Anomalies Surveillance (that the comparison will be used as the base for future reactivity anomaly checks).

q) I 'q rCNITDRO*l t3PAPII RA*l TV 0.I. 9I.J

, WJ~INIIM ,.L ! vu , rJ u MI I 1. 1uu Plant FitzPatrick procedure 3 3.1.3 - LA1 4.3.A.2.d The requirement that an attempt should be made to fully insert a control rod ifit is initially determined to be incapable of normal insertion. Procedures control process Bases Bases Control Program 3 3.1.3 - LA2 3.3.A.2.b, Details of the methods for disarming CRDs.

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

31.4. CONTROL ROD SCRAM TIMES

a. I 3.1.4 - LA1 4.3.C.2 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 I I representative sample (i.e., at least 10% of the control rods) has been relocated.

_ __ _ _ _ _ _ _ 1_ __I_ _ _ _ _ _ _ _ __I_ _ _ _

PAGE 1 JAFNPP

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

SUMMARY

DOC # SECTION 3.1.5, CONTROL ROD SCRAM ACCUMULATORS I NONE1*1* INONE INONE NONE NONE NONE I....

I I I I I I 3.1.6, ROD PATTERN CONTROL Bases Bases Control Program 3.1.6 -LA1 3.3.B.3.e 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 I

result in a peak fuel enthalpy greater than 280 calories/gm). I .3 I

______ .1____ 1 ________________________ J_____

q 17 qTA M n n 1V I It l IIrCl ONIT ROI L VST FM J. 1.1,t, b AIII LJ TL IU IUUI UL0 . 01

- rrI Bases Bases Control Program 3.1.7 - LA1 4.4.A.2, The details of the method for performing the SLC pump flow test (by recirculating 4.4.A.3, demineralized water to the test tank); the details of the method for demonstrating all 4.4.A.4, piping between the SLC storage tank and the pump suction is unblocked (by 4.4.A.5 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 inthe same batch to verify proper function and then the replacement primer assembly to the one fired inthe 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).

I .--. - - - -- -i 1ST Program t 10 CFR 50.59 I 3 10 CFR 50.59 3.1.7 - LA2 4.4.A.6, The requirements to verify the proper operation and setpoints of the relief valves IST Program I44.A.7 and to disassemble and inspect one explosive valve. -I I 'I Bases Bases Control Program Bases Bases Control Program 1 3.1.7 -LA3I 3.4.C The detailed information concerning the boron solution for the SLC storage tank, and what support components and variables are required to assure SLC I OPERABILITY is maintained. I I i PAGE 2 JAFNPP

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

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND CTS TYPE PROCESS DOC # SECTION temperature of enriched sodium pentaborate solution Bases Bases Control Program 1 3.1.7- LA4 Figure The detail that the saturation 0F margin.

3.4-2 curve includes a 10 TRM 10 CFR 50.59 3 3.1.7 - LB1 4.4.C.3 The requirements to calibrate the temperature and level elements.

3.1.8, SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVES IST Program 10 CFR 50.59 3 3.1.8 - LAl 4.3.A.2.e The requirement concerning the scram discharge volume drain and vent valve closure time criteria (30 seconds).

CHANGE TYPE

1. Details of system design and system description including design limits

2. Description of system operation requirements

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

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

ITS SECTION CTS

SUMMARY

AND DOC # SECTIO N

3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATI _________________ 1*

3 Bases Bases Control 3 The details that require action be initiated within 15 minutes to Program 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.

I Bases Bases Control 3 The details related to APLHGR and APLHGR limits. Program I

3.2.2, MINIMUM CRITICAL POWER RATIO Bases Control 3 3.2.2 - LA1 3.1.B The CTS requirement that during reactor power operation with core Bases Program 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).

Bases Bases Control 3 3.2.2 - LA2 3.1.B The details that require action be initiated within 15 minutes to Program 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.

i

__ J

____ I ________________________ I _____ J ________

3.2.3, LINEAR HEAT GENERATION RATE 1 Bases Bases Control 1 3.2.3 - LA1 3.5.1 The detail that specifies that the linear heat generation rate (LHGR) Program is at any rod in any fuel assembly at any axial location.

.- .Bases i Bases Control I

3.5-1 The details that require action be initiated within 15 minutes to Bases Program 3 3.2.3 - LA2 restore operation to within prescribed limits are being relocated in the form of a discussion that "prompt action" should be taken to restore I the parameter to within limits.

I I ______________________________________ j _______ .3____________ .7_______

PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.2 - POWER DISTRIBUTION 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 PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION CATION CHANGE CONTROL CHANGE CTS

SUMMARY

ITS SECTION AND PROCESS TYPE DOC # SECTION 3.3.1.1, RPS INSTRUMENTATION Bases Bases Control Program 1.0.Z, 2.1 .A.2, I The detail that the top of active fuel, which corresponds to the top of the enriched 3.3.1.1 -LA1 Table 3.1-1 fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point inthe 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 Bases Bases Control Program 3.3.1.1 -LA2 Table 3.1-1 The information in the column "Total Number of Instrument Channels Provided by Design for Both Trip Sstems." 1 Bases Bases Control Program 3.3.1.1 -LA3 Table 3.1-1 The detail stating that the APRM Neutron Flux-Startup scram function is a fixed Notes 13 and point and is increased when the reactor mode switch is placed inthe Run 15 position, and the detail stating that the APRM Flow Referenced Neutron Flux scram function is varied as a function of recirculation flow (W).

Bases Bases Control Program 3.3.1.1 -LA4 Table 3.1-1 The requirement that an APRM will be considered inoperable ifthere are less Note 10 than 2 LPRM inputs per level or less than 11 Operable LPRM detectors to an APRM.

Bases Bases Control Program 3.3.1.1 -LA5 Table 3.1-1 The statement regarding the Main Steam Line Isolation Valve Closure and Note 6 Turbine Stop Valve Closure Functions design that permits closure of any two lines without a scram being initiated.

Bases Bases Control Program 3.3.1.1 -LA6 Table 3.1-1 The detail regarding the physical location of the Turbine Control Valve Fast Closure Function's pressure switches.

Bases Bases Control Program P2 3.3.1.1 -LA7 Table 3.1-1 The details concerning conditions and precautions for placing an inoperable footnote

channel or trip system intrip.

Bases Bases Control Program 3 3.3.1.1 -LA8 Table 4.1-1 The detail on how to perform a Functional Test of the Mode Switch inShutdown Function (place the Mode Switch inshutdown).

Bases Bases Control Program 3 3.3.1.1 -LA9 Table 4.1-1 The detail that describes how to exercise the automatic scram contactors (by Note 1 performing a functional test of an automatic scram function or by using the RPS Channel Test Switch).

PAGE 1 JAFNPP

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

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND PROCESS TYPE DOC# SECTION The detail that the RPS Drywell High Pressure and Reactor Low Water Level UFSAR 10 CFR 50.59 1 3.3.1.1 - LAl0 Table 3.1-1 Note 16 instrumentation is common to the PCIS.

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

The listing of the Turbine First Stage Pressure Permissive as an attribute of the Bases Bases Control Program 1 3.3.1.1 - LA12 Table 4.1-1, Table 4.1-2 Turbine Stop Valve Closure and Turbine Control Valve Fast Closure Functions.

The requirement that, with channels inboth trip systems inoperable, the trip Bases Bases Control Program 3 3.3.1.1 - LA13 Table 3.1-1 footnote ** system with the greatest number of inoperable channels be the trip system that is placed intrip.

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

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

The details that the measured level for the SDV Hight Water Level Scram Bases Bases Control Program 1 3.3.1.1 - LA15 Tables 3.1-1, 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 r I The information inthe column "Total Number of Instrument Channels Provided Bases Bases Control Program 1 1.i it --

gnostic test and the proper annunciation of the TRM 10 CFR 50.59 3 PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION CHANGE CONTROL CHANGE LOCATION CHANGE CONTROL PROCESS TYPE ITS SECTION AND CTS

SUMMARY

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

N/A N/A N/A 3.3.2.1 - LA4 N/A Not used.

Bases Control Program 1 Bases 3.3.2.1 - LA5 Table 3.2-3 The detail that the RBM is flow biased.

Bases Control Program 3 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 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 Bases 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 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 11 Bases 3.3.3.1 - LAl Table 3.2-8 The information in the column "No. of Instrument Channels Provided by Design."

TRM 3.3.3.1 - LA2 Table 3.2-8 The requirement that, with the Primary Containment Hydrogen/Oxygen monitor Note F inoperable, operation for 30 days is permissible "provided at least once per 24 hours1 days 0.143 weeks 0.0329 months , either the appropriate parameter(s) is monitored and logged using 27PCX-101NAB, or an appropriate grab sample is obtained and analyzed."

N/A 3.3.3.1 - LA3 N/A Not used.

PAGE 3 JAFNPP

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

with.

the Bases The detail that the trip level setting (changed to Allowable Value) for 15.600 gallons available.

Condensate Storage Tank Low Level is equivalent to PAGE 4 JAFNPP

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

SUMMARY

TYPE PROCESS DOC # SECTION 1

Bases Bases Control Program 1 The detail that the top of active fuel, which corresponds to the top of the enriched 3.3.5.1 - LA4 1.0.Z 3.2-2, Table fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point inthe inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is I referenced from the top of active fuel.

I

_______ 1_____ .1 _______________________

L ________

q , 9 1 '..iIt"* V CTI r' AI 1l4T' I MF T A T I N '

3.3Bases I I vil Bases Control ProgramIE Bases Bases Control Program 1 3.3.5.2 - LA1 Table 3.2-2, The information inthe column "Minimum No. of Operable Instrument Channels including Note per Trip System" and that RCIC Reactor High Water Level Trip Function include 16 only one trip system.

I ,

L I 4-Bases I The information inthe column "Remarks." Bases Bases Control Program 1 3.3.5.2 - LA2 TAble"3.2 -2 IdUlt; O.L-L Bases Bases Control Program 3.3.5.2 - LA3 Table 3.2-2 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.

II -t I Bases Bases Bases Control Program 3.3.5.2 - LA4 Table 3.2-2, The detail that the top of active fuel, which corresponds to the top of the enriched 1.0.Z fuel column of each fuel bundle, is located 352.5 inches above vessel zero, which is the lowest point inthe inside bottom of the reactor pressure vessel. The detail that the Trip Level Setting of the Reactor Low Water Level Function is

-L referenced from the top of active fuel.

-i i i J __________________________ J_____ .7_________

1.3. 1 ,

IDI-Kl'lM V-r'f)KT AUI*/'lhlr-IM I Inl-rAIONINSTRU1- I ... ON, MEiNTAT~l 3.3.6.1, PRIMARY UUN IAINMtN I ltýULA I lUlm "%J--" 1 1m I Bases Bases Control Program ltion inthe column "Total Number of Instrument Channels Provided IBases Bases Control Program

___________________ I i Bases Control Program ystem need not be placed in Bases Bases Control Program toocuruu. j--- _ ___I_ .

PAGE 5 JAFNPP

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

SUMMARY

LOCATION CHANGE CONTROL CHANGE DOC # SECTION PROCESS TYPE Table 3.2-1 The Systems isolated by certain instruments. Bases Bases Control Program 1 3.3.6.1 - LA3 Actions 3.C, 3.D, and 3.E, Table 3.2-8 Footnote

Table 3.2-8 The details of the logic and penetrations isolated by the Reactor Low Water Bases Bases Control Program 1 3.3.6.1 - LA4 Note 8 Level and Drywell High Pressure Trip Functions.

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

Table 3.2-1 The detail that the Reactor Low Water Level and Drywell High Pressure Bases Bases Control Program 1 3.3.6.1 - LA6 Note 7 Functions are common to the RPS Instrumentation.

Table 4.2-1 The methods for performing a detector calibration and a Channel Calibration Bases Bases Control Program 3 3.3.6.1 - LA7 thru 4.2.-5 (using a radiation source and a current source, respectively).

Note_11 Table 3.2-2 The Reactor Low Pressure Trip Function requirements. TRM 10 CFR 50.59 3 3.3.6.1 - LA8 Item 10, including Notes 2 and 12, Table 4.2 2 Instrument Channel 3a)

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 3.3.6.1 - LA9 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.

N/A Not used. N/A N/A N/A 3.3.6.1 - LA10 Table 3.2-1 The detail of what constitutes PCIS Initiation capability (for at least one Bases Bases Control Program 3 3.3.6.1 -LA11 Note 2.b containment isolation valve inthe affected penetration).

JAFNPP PAGE 6

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.3 - INSTRUMENTATION

SUMMARY

LOCATION CHANGE CONTROL ITS SECTION AND CTS PROCESS DOC # SECTION Bases Bases Control Program 3.3.6.1 - LA12 4.2.A footnote The details that the sensors for the Reactor Low Water Level (Level 1), Low

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 rNIA1N* tN1-VlLI I -I

.I.*IIVi*III 14" ' ................

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

Bases Bases Control Program 3 3.3.6.2 - LA2 Table 3.2-1 The allowance that an inoperable channel or trip system need not be placed in 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 Bases Bases Control Program 3.3.6.2 - LA3 RETS Table 3.10-1 Note b 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.

I I

-1*Bases .t Bases Control Program Bases Bases Control Program 1 3.3.6.2 - LA4 Table 3.2-1 The detail that the Reactor Low Water Level and Drywell High Pressure Note 4 Functions start thle SGT S ystem and initiate secondaruy VIntc1inmmisiLIVcLoI. _______

Bases Bases Control Program 1 3.3.6.2 - LA5 Table 3.2-1 The detail that the Reactor Low Water Level and Drywell High Pressure Note 7 Functions are common to the RPS Instrumentation.

I 1 Bases 1 Bases Control Program 1 Bases Bases Control Program 1 3.3.6.2 - LA6 Table 3.2-1, The detail that the top of active fuel, which corresponds to the top of the enriched 1.02Z 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 II I referenced from the top of active fuel.

PAGE 7 JAFNPP

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 inthe affected Ipenetration).

"1 7 'De':VAq qVYTlM IMITRI IMeNTATION

,....1,,* ZnO'Jt. 1i i r V. 11,-i.1 i i.lv,. . .l.I1r NONE NONE NONE NONE NONE NONE 3.3.7.2, CONDENSER AIR REMOVAL PUMP ISOLATION INSTRUMENTATION Bases Bases Control Program 1 3.3.7.2 - LAl Table 3.2-1, The information inthe columns "Total Number of Instrument Channels Provided RETS Table by Design for Both Trip Systems" and "Total Number of Instrument Channels 3.10-1 Provided by Design."

Bases Bases Control Program 3 3.3.7.2 - LA2 Table 4.2-1 The methods for performing a detector calibration and a Channel Calibration thru Table 4.2- (using a radiation source and a current source, respectively).

5, Note 11 Bases Bases Control Program 3 3.3.7.2 - LA3 Table 3.2-1 The allowance that an inoperable channel or trip system need not be placed in Note l.a trip when this would cause the trip function to occur.

footnote

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

3.3.8.1, LOP INSTRUMENTATION PAGE 8 JAFNPP

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

SUMMARY

PROCESS TYPE DOC # SECTION Bases Bases Control Program 1,2 3.3.8.1 - LA1 Table 3.2-2, The information inthe column "Remarks," that the trip level setting (changed to 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 Bases Bases Control Program 3 3.3.8.2 - LA1 4.9.G.2 The details of what constitutes a system functional test.

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 9 JAFNPP

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

SUMMARY

PROCESS TYPE II ATIIId I CDDATINIt TABL 4- LA lRE 1 TMOVLOFDTILSP~ATRIXr M.

3.4.1, REI-, ULP, I II' L FQ *Jr LM l I_114U TRM 10 CFR 50.59 3.4.1 - LA1 3.5.K.2 The requirements that during resumption of two-loop operation following a period of 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.

qA 0IrT A DIMPIS Q.4t.z, itL.i I tivir Bases Bases Control Pro ram 3.4.2 - LA1 4.6.G.A The details to obtain base line data for single loop operation.

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

Bases Bases Control Program 3 3.4.3 - LA2 4.6.E.4 The methods for verifying the safety/relief valves have opened (i.e., while bypassing steam to the condenser, etc) and the detail that the test must be performed in Run._

IS rga 10 CERI50.5 IST Program 10 CFR 50.59 3.4.3 - LA3 4.6.E.1 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 -i ' ......... 'iI N/A Not used. Nl/A N/A 3.4.3 - LA4 N/A INot usedi. Pif^ i - i "

I ___________________________ J_____

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

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

Bases Control Program 3 Bases The details of the methods for performing this surveillance by utilizing the Primary Bases Bases Control Program Containment Sump Monitoring System (equipment drain sump monitoring and floor

________________________ I IJ 1 I _________

PAGE 1 JAFNPP

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

SUMMARY

CHANGE CONTROL ITS SECTION AND CTS PROCESS DOC# SECTION 3.4. RC I FAKAGEF DETECTION INSTRUMENTATION Table 3.2- The details that the "floor drain sump flow integrator" must be Operable and the Bases Bases Control Program 1 3.4.5 - LA1 6, Table details that the "floor drain sump flow integrator" must be functionally checked and 4.2-5 calibrated.

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 3.4.5 - LA2 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 3.4.9 - LA1 4.6.A.2, The requirement that specifies the criteria for ending the P/T limit surveillances Bases Control Program 4.6.A.3, during inservice hydrostatic and leak tests, non-nuclear heatup and cooldown, and 4.6.A.4 core critical operations (performed until two consecutive temperature readings are 0 of each other).

-- - I I II VVILIlilIý5 IF - -

within -

PAGE 2 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.4 - REACTOR COOLANT SYSTEM 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 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 3.5 ECCS AND RCIC SYSTEM ITS SECTION AND CTS

SUMMARY

DOC # SECTION I. f;- F rq - ER AT IN G IP TRM 10 CFR 50.59 3 3.5.1 - LA1 4.5.D.1 .b The surveillance requirement to demonstrate that a simulated automatic ADS actuation is inhibited by the override switches.

Bases Bases Control Program 3 3.5.1 - LA2 4.5.D.1 .a The details that the simulated automatic actuation test for the Automatic Depressurization System (ADS) opens the solenoids.

Bases Bases Control Program 3 3.5.1 - LA3 4.6.E.4 The methods for verifying the safety/relief valves have opened (i.e., while bypassing steam to the condenser, etc) and the detail that the test must be performed in Run.

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

TRM 10 CFR 50.59 3 3.5.1 - LA5 4.6.E.3 The requirement to verify the integrity of the nitrogen system and components that provide manual andADS actuation of the safety/relief valves every 3_months.

Bases Bases Control Program 3 3.5.1 - LA6 4.5.G.1, The method to be employed to assure that the Core Spray, Low Pressure Coolant 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).

IST Program 10 CFR 50.59 3 3.5.1 - LA7 4.5.A.1 .d, The requirements to perform motor operator valve and testable check valve testing 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 TRM 10 CFR 50.59 3 3.5.1 - LAB 4.9.F.1, The requirement to perform a weekly visual inspection of the LPCI MOV 4.9.F.6 Independent Power Supply inverters.

N/A N/A N/A 3.5.1 - LA9 N/A Not used.

TRM 10 CFR 50.59 3 3.5.1 - LB1 4.5.G.4 The monthly functional test of the Core Spray and RHR level switches located on the discharge piping high points._II PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.5 ECCS AND RCIC SYSTEM LOCATION CHANGE CONTROL CHAN,

SUMMARY

TYF PROCESS TRM 10 CFR 50.59 3 ta P Instrumentation daily check, quarterly calibration, t.

3.5.2, ECCS - SHUTDOWN mmotor operator valve testing in accordance with the IST Program 10 CFR 50.593 Testing (IST) Program for the required CS and/or LPCI Bases Bases Control Program 3 idto assure that the Core Spray and Low Pressure charge lines are full of water (i.e., the discharge piping gh point of the system and water flow observed).

TRM 10 CFR 50.59 3 tof the Core Spray and RHR level switches located on

)oints.

3.5.3, RCIC SYSTEM Bases Bases Control Program 3 ed automatic actuation test includes the automatic restart that is subsequent to a high water level signal.

Bases Bases Control Program 3 ed to assure that the RCIC pump discharge line is full of

)iping shall be vented from the high point of the system N/A N/A N/A IST Program 10 CFR 50.59 3

)rm RCIC System testable check valve testing and RCIC 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 PAGE 3 JAFNPP

TABLE LA- REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION AND CTS

SUMMARY

DOC # SECTION

.6.1.1 PRIMARY o .u . 1.1,Fl* , ° ,,,

CONTAINMENT

..... 1, . ...............

1.0.M The details concerning the manual isolation valves, automatic isolation valves, that Bases Bases Control Program 1 3.6.1.1 - LA1 the drywell and pressure suppression chamber are intact, and the requirement that manways are closed for primary containment Operability.

Not used. N/A N/A N/A 3.6.1.1 - LA2 N/A The details that the drywell to suppression chamber leakage rate limit of 71 scfm Bases Bases Control Program 3 3.6.1.1 - LA3 3.7.A.5.e shall be monitored via the suppression chamber 10 minute pressure transient of 0.25 in.water/mmin.

The requirement that when the primary containment is inerted, it shall be UFSAR 10 CFR 50.59 3 3.6.1.1 - LA4 4.7.A.3 continuously monitored for gross leakage by review of the inerting system makeup requirements.

3.6.1.2, PRIMARY CONTAINMENT AIR LOCKS The detail that at least one door ineach airlock is closed and sealed. Bases Bases Control Program 1 3.6.1.2 - LA1 1.0.M.2 3.6.1.3, PRIMARY CONTAINMENT ISOLATION VALVES 4.7.A.2.c The leakage limits and test pressure for the LPCI/CS air-operated testable check Bases Bases Control Program 3 3.6.1.3 - LA1 valves (as modified by DOG M6).

Not used. N/A N/A N/A 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 The details concerning automatic containment isolation valves (a deactivated valve Bases Bases Control Program 1 3.6.1.3 - LA5 1.0.M.3 1___ _1__ _ in the isolatedposition ensures containment integrity).

PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT'SYSTEMS CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND SECTION PROCESS TYPE DOC #

3.7.D.1 The design detail that provide the containment vent and purge valve numbers and UFSAR 10 CFR 50.59 1 3.6.1.3 - LA6 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 4.7.A.5.c, The requirements that each vacuum breaker valve be inspected to ensure proper IST Program 10 CFR 50.59 3 3.6.1.7 - LA1 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.

3.7.A.5.b The requirement that one vacuum breaker may be non-fully closed so long as it is Bases Bases Control Program 3 3.6.1.7 - LA2 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 JAFNPP PAGE 2

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION AND CTS

SUMMARY

CHANGE CONTROL DOC # SECTION PROCESS 3.6.1.9. RHR CONTAINMENT SPRAY 3.6.1.9 - LA1 3.5.B.1 The details concerning the number of pumps required ineach 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 inthe 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 ineach 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 inthe 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 ifthe 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) ifthe 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) ifthe fuel cask is being moved inthe reactor building.

JAFNPP PAGE 4

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.6 - CONTAINMENT SYSTEMS

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND CTS PROCESS TYPE DOC # SECTION TRM 10 CFR 50.59 3 3.6.4.3 - LB1 4.7.B.1 .f The requirement to calibrate the SGT System differential pressure switches every 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

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND CTS PROCESS TYPE DOC# SECTION 3.7.1, RHRSW SYSTEM Bases Bases Control Program 1 3.7.1 - LA1 3.5.B.1 The details concerning the number of pumps required in each RHR service water subsystem.

IST Program 10 CFR 50.59 3 3.7.1 - LA2 4.5.B.1 .c, The inservice testing requirements for the RHRSW pumps and valves, including the 4.5.B.1 .d pump flow rate.

3.7.2, ESW SYSTEM and UHS IST Program 10 CFR 50.59 3 3.7.2 - LA1 4.11 .D.1 .b, The inservice testing requirements for the ESW pumps and valves, including the 4.11 .D.1 .d pump flow rate and total developed head.

Bases Bases Control Program 2 3.7.2 - LA2 4.11 .D.2 The detail on how to perform ESW surveillances (i.e., that ESW will not be supplied to RBCLC System during testing).

Bases Bases Control Program 3 3.7.2 - LA3 3.11.E The detail that a minimum of 18 heaters out of 88 are required (as modified by DOC M3).

3.7.3, CREVAS SYSTEM Bases Bases Control Program 3 3.7.3 - LA1 3.11 .A.1 The details concerning the components of the Main Control Room Emergency Ventilation Subsystem (emergency ventilation air supply fans and fresh air filter trains) required to be OPERABLE.

TRM 10 CFR 50.59 3 3.7.3 - LB1 4.11 .A.4 The requirement to calibrate the temperature transmitters and differential pressure 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

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND CTS PROCESS TYPE DOC # SECTION 3.7.5, MAIN CONDENSER STEAM JET AIR EJECTOR OFFGAS The details of the method of performing the Surveillance to verify the gross gamma Bases Bases Control Program 3 3.7.5 - LAl RETS 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 UFSAR 10 CFR 50.59 3 3.7.7 - LA1 3.10.C The requirement that whenever irradiated fuel is stored inthe spent fuel storage 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 TRM 10 CFR 50.59 3 NONE - LA1 3/4.11 .C The Battery Room Ventilation Specification.

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 PAGE 3 JAFNPP

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., ifthe 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.

JAFNPP PAGE 1

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.8 - ELECTRICAL POWER SYSTEMS LOCATION CHANGE CHANGE ITS SECTION CTS

SUMMARY

CONTROL TYPE AND DOC # SECTIO PROCESS N

TRM 10 CFR 50.59 3 3.8.4 - LA3 4.9.E.6, The details relating to the battery charger weekly visual inspection.

4.9.F.1, 4.9.F.6 TRM 10 CFR 50.59 3 3.8.4 - LA4 4.9.F.6 The requirement to perform a test of the LPCI MOV independent 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 Bases Bases Control 3 3.8.6 - LA1 4.9.E.2.c, The detail to measure the temperature of "every fifth cell" (as Program 4.9.F.2.c modified by DOC L3).

3.8.7, DISTRIBUTION SYSTEMS - OPERATING Bases Bases C6ntrol 1 3.8.7 - LA1 3.9.A.2, The details related to the specific buses required to be Operable and Program 3.9.F.1 the details of what "Operable" means (e.g., energized, in service).

3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN I - --

INONE INONE INONE NONE NONE NONE i---7 I I I I I -I I CHANGE TYPE PAGE 2 JAFNPP

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

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

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.9 - REFUELING OPERATIONS ITS SECTION CTS

SUMMARY

LOCATION CHANGE CHANGE AND DOC # SECTIO CONTROL TYPE N PROCESS 3.9.1, REFUELING EQUIPMENT INTERLOCKS 3.9.1 - LA1 3.10.A.3, The actual hoist loaded setpoints. TRM 10 CFR 50.59 1 3.1O.A.4 3.9.2, REFUEL POSITION ONE-ROD-OUT INTERLOCK NONE NONE NONE NONE NONE NONE 3.9.3, CONTROL ROD POSITION NONE NONE INONE NONE NONE NONE 3.9.4, CONTROL ROD POSITION INDICATION NONE NONE INONE NONE NONE NONE 3.9.5, CONTROL ROD OPERABILITY - REFUELING NONE NONE INONE NONE NONE NONE 3.9.6, REACTOR PRESSURE VESSEL WATER LEVEL NONE NONE INONE NONE NONE NONE 3.9.7, RESIDUAL HEAT REMOVAL - HIGH WATER LEVEL NONE NONE NONE NONE NONE NONE JAFNPP PAGE 1

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.9 - REFUELING OPERATIONS ITS SECTION CTS

SUMMARY

LOCATION CHANGE CHANGE AND DOC # SECTIO CONTROL TYPE N PROCESS 3.9.8, RESIDUAL HEAT REMOVAL - LOW WATER LEVEL 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 2

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.10 - SPECIAL OPERATIONS

SUMMARY

LOCATION CHANGE CHANGE ITS SECTION CTS CONTROL TYPE AND DOC # SECTIO N PROCESS 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION TRM 10 CFR 50.59 3 3.10.1 - LA1 3.12.A The temperature allowance of up to 300°F to perform the inservice leak or hydrostatic test.

3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING NONE NONE NONE NONE NONE NONE 3.10.3, SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN NONE NONE NONE NONE NONE NONE 3.10.4, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN NONE NONE NONE NONE NONE NONE 3.10.5, SINGLE CONTROL ROD DRIVE REMOVAL - REFUELING NONE NONE NONE NONE NONE NONE 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING Bases Bases Control 2, 3 3.10.6 - LA1 3.10.A.7. The details related to how to perform the spiral on-load sequence.

Program b

Bases Bases Control 3 3.10.6 - LA2 4.10.A.2 The details of the method used to verify that all fuel is removed before the corresponding control rod is withdrawn (by one licensed Program Ioperator and one member of the reactor analyst department)._I _ I_1 ___

PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX SECTION 3.10 - SPECIAL OPERATIONS CTS

SUMMARY

LOCATION CHANGE CHANGE ITS SECTION SECTIO CONTROL TYPE AND DOC #

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. Details of system design and system description including design limits

2. Description of system operation and relocated specification requirements

3. Procedural details for meeting TS requirement, relocated reporting requirements, PAGE 1 JAFNPP

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND CTS TYPE PROCESS DOC# SECTION 5.1, RESPONSIBILITY NONE NONE NONE NONE NONE NONE 5.2, ORGANIZATION UFSAR 10 CFR 50.59 3 5.2 - LA1 Table 6.2-1 The detail that requires both licensed ROs on shift be inthe control room during note ** plant startup or planned shutdown.

Plant FitzPatrick procedure 3 5.2- LA2 6.2.2.6 The details of limiting the working hours of the plant staff and administrative controls on the use of overtime. Procedures control process UFSAR 10 CFR 50.59 3 5.2 - LA3 6.3.2 Note The detail that the 13 individuals who hold SRO licenses and have completed the 1 FitzPatrick Advanced Technical Training Program prior to issuance of License Amendment 111 shall be considered qualified as dual-role SRO/STAs.

UFSAR 10 CFR 50.59 3 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 itis the responsibility of the General Manager-Operations to 7.1 .b implement the Radiological Effluent Technical Specifications (RETS).

5.3, PLANT STAFF QUALIFICATIONS NONE NONE NONE NONE NONE NONE 5.4, PROCEDURES QA Program 10 CFR 50.54(a) 3 5.4 - LA1 6.8.(A).1, Details that establish specific requirements for development, review and approval, 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 CTS

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND PROCESS TYPE DOC # SECTION 5.5, PROGRAMS AND MANUALS The "Iodine Monitoring Program." UFSAR 10 CFR 50.59 3 5.5 - LA1 Facility Operating License 2.C(5)

Table 6.10- The list of component cyclic or transient limits, by transient condition and number of UFSAR 10 CFR 50.59 3 5.5 - LA2 1 design occurrences.

The details that provide limiting conditions for operation and surveillance TRM 10 CFR 50.59 3 5.5 - LA3 RETS 2.5, RETS 2.7 requirements for explosive gas and storage tank radioactivity inradwaste systems.

The schedular details ("Within 31 days after removal") for performing the laboratory TRM 10 CFR 50.59 3 5.5 - LA4 4.7.B.1 .c(1 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 The Startup Report requirements. UFSAR 10 CFR 50.59 3 5.6 - LA1 6.9.A.1 RETS The details associated with the contents of the Radioactive Effluent Release Report ODCM ODCM Change Control 3 5.6 - LA2 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 JAFNPP PAGE 3

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 JAFNPP PAGE 4

TABLE LA - REMOVAL OF DETAILS MATRIX CHAPTER 5.0 - ADMINISTRATIVE CONTROLS

SUMMARY

LOCATION CHANGE CONTROL CHANGE ITS SECTION AND CTS PROCESS TYPE DOC # SECTION 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 CTS

SUMMARY

LOCATION CHANGE ITS SECTION CONTROL AND DOC # SECTIO N PROCESS NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 2.0 - SAFETY LIMITS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS NANDDOC_#_SECIO NONENONE NONEI NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.0 - LCO AND SR APPLICABILITY

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

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 -

PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.1.8, SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVES NONE NONE NONE NONE NONE PAGE 2 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.2 - POWER DISTRIBUTION LIMITS CTS

SUMMARY

LOCATION CHANGE ITS SECTION AND DOC # SECTIO CONTROL N PROCESS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE NONE NONE NONE NONE NONE 3.2.2, MINIMUM CRITICAL POWER RATIO NONE NONE NONE NONE NONE 3.2.3, LINEAR HEAT GENERATION RATE NONE NONE NONE NONE NONE 3.2.4, APRM GAIN AND SETPOINT 3.2.4 - R1 4.1 .B The requirements concerning the APRM Rod Block Setpoints. TRM 10 CFR 50.59 JAFNPP PAGE 1

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.3 - INSTRUMENTATION

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.3.1.1, RPS INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.1.2, SRM INSTRUMENTATION NONE NONE NONE NONE NONE 3.3.2.1, CONTROL ROD BLOCK INSTRUMENTATION TRM 10 CFR 50.59 3.3.2.1 - R1 2.1 .A.1.d, The APRM, IRM, SRM, and Scram Discharge Volume Level Control Rod Blocks.

Table 3.2-3 including Notes 1 .a, 1 .c, 1.d, 2 (Action A and Action C portions),

4,5,6,8, and 10, Table 4.2-3 including Notes 2, 3, and 6 3.3.2.2, FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION NONE NONE NONE NONE NONE I PA GE 1 PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.3 - INSTRUMENTATION

SUMMARY

CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.3.3.1. PAM INSTRUMENTATION r r 3.3.3.1 - R1 Tables The Stack High Range Effluent Monitor, Turbine Building Vent High Range TRM 10 CFR 50.59 3.2-8 and Effluent Monitor, Radwaste Building Vent High Range Effluent Monitor, 4.2-8 Safety/Relief Valve Position Indicator, Torus Water Level (narrow range)

Instrume instrument, and Drywell-Torus Differential Pressure instrument.

nts 1,2, 3, 19,20, and 21, Table 3.2-8 Notes B, C, D, E, and G 3.3.3.1 - R2 Tables The Residual Heat Removal System Flow, Residual Heat Removal Service Water TRM 10 CFR 50.59 3.2-8 and System Flow, Core Spray System Flow, and Core Spray System Pressure 4.2-8 instruments.

Instrume nts 15, 16,17, 18, Table 3.2-8 Notes A and J 3.3.3.2, REMOTE SHUTDOWN SYSTEM NONE NONE NONE NONE NONE 3.3.4.1, ATWS-RPT INSTRUMENTATION NONE NONE NONE NONE NONE JAFNPP PAGE 2

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.3 - INSTRUMENTATION ITS SECTION CTS

SUMMARY

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

SUMMARY

LOCATION CHANGE AND DOC # 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 CTS

SUMMARY

LOCATION CHANGE ITS SECTION SECTIO CONTROL AND DOC #

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

SUMMARY

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

SUMMARY

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 PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.6 - CONTAINMENT SYSTEMS ITS SECTION CTS

SUMMARY

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 JAFNPP PAGE 1

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.6 - CONTAINMENT SYSTEMS CTS

SUMMARY

LOCATION CHANGE ITS SECTION SECTIO CONTROL AND DOC #

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 PAGE 2 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.6 - CONTAINMENT SYSTEMS CTS

SUMMARY

LOCATION CHANGE ITS SECTION 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 3.7.A.3, The requirement to discontinue purging if not purging through the SGT System ODCM ODCM Change None - R1 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 CTS

SUMMARY

LOCATION CHANGE ITS SECTION SECTIO CONTROL AND DOC #

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 RETS Steam Jet Air Ejector System radiation monitors. ODCM ODCM Change 3.7.5 - R1 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 # SECTIO CONTROL N PROCESS 3.7.7, SPENT FUEL STORAGE POOL WATER LEVEL NONE NONE NONE NONE NONE CTS 3/4.8, MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES NONE - Ri 3/4.8 The Miscellaneous Radioactivity Materials Sources Specification. TRM 10 CFR 50.59 CTS 3/4.11 .C, BATTERY ROOM VENTILATION NONE NONE INONE NONE NONE JAFNPP PAGE 2

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.8 - ELECTRICAL POWER SYSTEMS CTS

SUMMARY

LOCATION CHANGE ITS SECTION CONTROL AND DOC # SECTIO N PROCESS 3.8.1, AC SOURCES - OPERATING NONE NONE NONE NONE NONE 3.8.2, AC SOURCES - SHUTDOWN NONE NONE NONE NONE NONE 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR NONE NONE NONE NONE NONE 3.8.4, DC SOURCES - OPERATING NONE NONE NONE NONE NONE 3.8.5, DC SOURCES - SHUTDOWN NONE NONE NONE NONE NONE 3.8.6, BATTERY CELL PARAMETERS NONE NONE NONE NONE NONE 3.8.7, DISTRIBUTION SYSTEMS - OPERATING NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.8 - ELECTRICAL POWER SYSTEMS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.8.8, DISTRIBUTION SYSTEMS - SHUTDOWN NONE NONE NONE NONE NONE PAGE 2 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.9 - REFUELING OPERATIONS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.9.1, REFUELING EQUIPMENT INTERLOCKS NONE NONE NONE NONE NONE 3.9.2, REFUEL POSITION ONE-ROD-OUT INTERLOCK NONE NONE NONE NONE NONE 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 PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.9 - REFUELING OPERATIONS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.9.8, RESIDUAL HEAT REMOVAL - LOW WATER LEVEL NONE NONE NONE NONE NONE PAGE 2 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.10 - SPECIAL OPERATIONS

SUMMARY

LOCATION CHANGE ITS SECTION CTS CONTROL AND DOC # SECTIO PROCESS N

3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION NONE NONE NONE NONE NONE 3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING NONE NONE NONE NONE NONE 3.10.3, SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN NONE NONE NONE NONE NONE 3.10.4, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN NONE NONE NONE NONE NONE 3.10.5, SINGLE CONTROL ROD DRIVE REMOVAL - REFUELING NONE NONE NONE NONE NONE 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING NONE NONE NONE NONE NONE 3.10.7, CONTROL ROD TESTING - OPERATING NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS SECTION 3.10- SPECIAL OPERATIONS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC # SECTIO CONTROL N PROCESS 3.10.8, SHUTDOWN MARGIN TEST- REFUELING NONE NONE NONE NONE NONE JAFNPP PAGE 2

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 4.0 - DESIGN FEATURES ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOCG# SECTIO CONTROL N PROCESS NONE NONE NONE NONE NONE JAFNPP PAGE 1

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 5.0 - ADMINISTRATIVE CONTROLS CTS

SUMMARY

LOCATION CHANGE ITS SECTION SECTIO CONTROL AND DOC #

N PROCESS 5.1, RESPONSIBILITY NONE NONE NONE NONE NONE 5.2, ORGANIZATION NONE NONE NONE NONE NONE 5.3, PLANT STAFF QUALIFICATIONS NONE NONE NONE NONE NONE 5.4, PROCEDURES NONE NONE NONE NONE NONE 5.5, PROGRAMS AND MANUALS NONE NONE NONE NONE NONE 5.6, REPORTING REQUIREMENTS NONE NONE NONE NONE NONE 5.7, HIGH RADIATION AREA NONE NONE NONE NONE NONE PAGE 1 JAFNPP

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION CTS

SUMMARY

LOCATION CHANGE AND DOC # SECTIO CONTROL N PROCESS CTS 6.0, ADMINISTRATIVE CONTROLS NONE NONE NONE NONE NONE RETS_2.1,_LIQUIDEFFLUENT MONITORS None - R1 RETS The liquid effluent monitors requirements. ODCM ODCM Change 2.1, Control Process in RETS ITS Chapter 5 Table 3.10-2 RETS 2.2,_CONCENTRATIONOFLIQUIDEFFLUENTS None - R1 RETS 2.2 Limitation on the concentration of radioactive materials in liquid effluents. ODCM ODCM Change Control Process in ITS Chapter 5 RETS_2.3,_DOSEFROMLIQUIDEFFLUENTS None - R1 RETS 2.3 Dose limitations from liquid effluents to the members of the public. 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 JAFNPP PAGE 2

TABLE R - RELOCATED SPECIFICATIONS CHAPTER 5.0 - ADMINISTRATIVE CONTROLS ITS SECTION CTS

SUMMARY

AND DOC # SECTIO 11 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

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 ODCM ODCM Change juirements.

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 Acceptance Review
TAC:MA5049, (Open)
Initiation Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Meeting Questions Answers Results Approval... Other: ML052060191
MONTHYEAR2002-07-03 [Table View]

ML021970071

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