Text

Table a of Administrative Changes to the CTS
	ML032810159
Person / Time
Site:	Indian Point
Issue date:	10/02/2003
From:	Vissing G; NRC/NRR/DLPM/LPD1
To:	Kansler M; Entergy Nuclear Operations
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ML032810165	List: ML032810159; ML032810176; ML032810196; ML032810199; ML032810204;
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TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 1.0 - USE AND APPLICATION Discussion of Summary of Change CTS Section ITS Section Change A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 1.0 1.1 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Removes CTS Definitions that are not used in the ITS because the current Technical 1.4.1 1.1 Specifications that use these definitions are not retained in the ITS. 1.4.2 1.5 1.6.4 1.9 T 1-1 A.3 Clarifies definition of Channel Calibration by adding details that are consistent with a 1.6.3 1.1 reasonable interpretation of the existing definition.

A.4 Clarifies that CTS term "injection of a simulated signal" can be interpreted as allowing use 1.6.2 1.1 of either an actual or simulated signal to verify that a channel is Operable.

A.5 Clarifies definition of Channel Functional Test by adding details that are consistent with a 1.6.2 1.1 reasonable interpretation of the existing definition and changes name of test from Instrument Channel Functional Test to Channel Operational Test (COT).

A.6 Eliminates use of the term 'closed system' from the definition of Identified Leakage without 1.12.a 1.1 changing any requirements about what is considered Identified Leakage.

A.7 Eliminates specific reference to leakage through the RCS/RHR pressure isolation valves in 1.12.c 1.1 the definition of Identified Leakage because it is covered by the general definition of 3.4.13 LCO Identified Leakage. 3.4.14 LCO Indian Point - Unit 2 A-1 Section 1.0

Discussion of Summary of Change CTS Section ITS Section Change A.8 Clarifies that a component is Operable if it is supported by either its normal or its 1.3 1.1 emergency power supply.

A.9 Substitutes the ITS term "total reactor core heat transfer rate to the reactor coolant" for the 1.1.a 1.1 CTS term "steady state reactor thermal power" to clarify that the rated limit for reactor heat production is 3071.4 megawatts thermal.

A.10 Substitutes the ITS clarification that decay heat is excluded when determining if the reactor 1.2.4 1.1 power level places the reactor in Modes 1 and 2 (i.e., neutron flux power range T 1.1-1 instrumentation is used without adjustment for decay heat variations related to recent power level changes) for the CTS clarification that "neutron flux power range instrumentation" is used to determine when reactor power is high enough such that the reactor is considered in the Power Operation Condition.

A.11 Clarifies that CTS LCOs that are Applicable when the reactor is critical are considered 1.2.3 1.1 Applicable during approaches to criticality and power level reductions where keff falls T 1.1-1 below 1.0.

A.12 Clarifies that ITS uses a combination of the definition of Mode 3 and the requirements in 1.2.2 1.1 ITS LCO 3.1.1, Shutdown Margin, to establish requirements for SDM in Mode 3. F 3.10-1 3.1.1 T 1.1-1 A.13 Clarifies that ITS definitions in ITS Table 1.1-1 provides formal recognition of the CTS 1.2.2 1.1 practice of differentiating between Hot Standby when greater than or equal to 350°F T 1.1-1 (Mode 3) and Hot Shutdown when less than 350°F (Mode 4).

A.14 Deletes a footnote that allows the plant to be considered in cold shutdown at a temperature 1.2.2 1.1 up to 250°F during a one time chemical decontamination program when the fuel is removed A.15 Clarifies use of Technical Specifications by adding explanations in TS: Section 1.2 - 1.0 1.2 Logical Connectors; Section 1.3 - Completion Times; and, Section 1.4 - Frequency. 1.3 1.4 Indian Point - Unit 2 A-2 Section 1.0

Discussion of Summary of Change CTS Section ITS Section Change A.16 Adds explicit clarification that RCP seal water injection and leakoff is excluded when 1.12 1.1 calculating Identified Leakage.

Indian Point - Unit 2 A-3 Section 1.0

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 2.0 - SAFETY LIMITS (SLs)

Discussion of Summary of Change CTS Section ITS Section Change A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 2.1 2.1.1 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 2.2 2.1.2 comprehensive ITS Bases. 6.7 2.2 A.2 Deletes CTS statements labeled Objective and Applicability because they do not 2.1 2.0 establish any requirements and do not provide any guidance for the application of CTS 2.2 requirements.

A.3 Clarifies that limitations on reactor power, pressure and temperature apply in Modes 1 and 2.1 2.1.1

2. Clarifies that the limitation on coolant pressure applies to pressurizer pressure.

Clarifies that the limitation on coolant temperature applies to the highest loop average temperature.

A.4 Clarifies that safety limit for the maximum RCS pressure is applicable in Modes 1, 2, 3, 4 2.1 2.1.1 and 5 and in Mode 6 when the reactor vessel head is on. 2.1.2 Indian Point - Unit 2 A-4 Section 2.0

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.0 - LCO APPLICABILITY AND SR APPLICABILITY Discussion of Summary of Change CTS Section ITS Section Change A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.0 3.0 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.0 comprehensive ITS Bases.

A.2 Revises nomenclature for CTS terms including hot shutdown and cold shutdown to the ITS 3.0.1 3.0.3 LCO terms Mode 1, 2, 3, 4, and 5.

A.3 Adds the interim requirement to be in Mode 4 within 13 hours0.542 days 0.0774 weeks 0.0178 months when proceeding to Mode 5 3.0.1 3.0.3 LCO within 37 hours1.542 days 0.22 weeks 0.0507 months .

A.4 Clarifies that ITS LCO 3.0.3 is Applicable only in Modes 1, 2, 3 and 4. 3.0.1 3.0.3 LCO A.5 Maintains existing exemptions from allowance for 25% extension to SR Frequencies to the 4.0.1 3.0.2 SR Programs to which the SR extension does not apply. 3.6.9.6 SR 3.6.10.3 SR 5.5.14 LCO A.6 Clarifies that SRs must be met whenever an LCO is Applicable, unless otherwise stated 4.0.2 3.0.1 SR and that failure to meet a Surveillance during the performance or between performances is 3.0.3 SR a failure to meet the LCO.

A.7 Clarifies that each of the ITS LCOs must be met during the Modes or other specified 3.0 3.0.1 LCO conditions in that LCOs Applicability.

Indian Point - Unit 2 A-5 Section 3.0

Discussion of Summary of Change CTS Section ITS Section Change A.8 Clarifies that associated Required Actions must be met whenever an LCO is not met. 3.0 3.0.2 LCO Additionally, clarifies that completion of the Required Action is not required unless otherwise stated if the LCO is met or is no longer applicable prior to expiration of the specified Completion Time.

A.9 Clarifies that the ITS is designed so that Actions associated with a supported system are 3.0 3.0.6 LCO not required to be performed if the Actions for the support system exist and are met. 3.0.2 LCO A.10 Clarifies that the test exception LCO allows specified Technical Specification requirements 3.0 3.0.7 LCO to be changed (made applicable in part or whole, or suspended) to permit the performance 3.1.8 LCO of special tests or operations that otherwise could not be performed.

Indian Point - Unit 2 A-6 Section 3.0

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.1.1- SHUTDOWN MARGIN (SDM)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10 3.1.1 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.1.1 establish any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 3.1.2 - CORE REACTIVITY A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 4.9 3.1.2 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 4.9 3.1.2 establish any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 3.1.3 - MODERATOR TEMPERATURE COEFFICIENT (MTC)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.C.1 3.1.3 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

Indian Point - Unit 2 A-7 Section 3.1

Discussion of Summary of Change CTS Section ITS Section Change A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.1.3 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Adopts the nomenclature and presentation used in NUREG-1431, Rev. 2, by changing 3.1.C.1 3.1.3 APP "reactor not be made critical at any temperature above which the moderator temperature 3.1.3 LCO coefficient is positive" to Moderator Temperature Coefficient (MTC) maximum upper limit must be less than or equal to 0.0 delta k/k per degree F at hot zero power in Mode 1 and in Mode 2 with keff greater than or equal to 1.0.

ITS SPECIFICATION 3.1.4 - ROD GROUP ALIGNMENT LIMITS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10 3.1.4 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.1.4 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Establishes consistent terminology between the ITS LCO 3.1.4 requirements (rod 3.10.7.1 3.1.4 Operability and alignment), the ITS SRs that verify these LCO requirements are met, and 3.10.5 3.1.4.2 SR the Conditions and Required Actions that are applicable if these requirements are not met. 3.10.8 3.1.4.3 SR A.4 Provides an explicit statement that requirements governing control rod Operability and 3.10.3 3.1.4 APP control rod alignment must be met in Modes 1 and 2. 3.10.4 3.10.5 3.10.8 A.5 Clarifies that the existing requirements to perform drop time of each control rod at 3.10.8 3.1.4.3 SR operating temperature and full flow are met with Tave greater than or equal to 500°F and all reactor coolant pumps operating.

Indian Point - Unit 2 A-8 Section 3.1

Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.1.5 - SHUTDOWN BANK INSERTION LIMITS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.4 3.1.5 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.1.5 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Revises nomenclature for Applicability from "reactor is critical or approaching criticality" to 3.10.4.1 3.1.5 APP "Modes 1 and 2."

A.4 Superceded by Amendment 216. NA NA ITS SPECIFICATION 3.1.6 - CONTROL BANK INSERTION LIMITS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.4 3.1.6 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.1.6 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Reorganizes requirements so that ITS LCO 3.1.4, Rod Group Alignment Limits, and ITS 3.10.4.3 3.1.6 LCO 3.1.5, Shutdown Bank Insertion Limits, establish Limiting Conditions for Operation 3.10.7.1 that ensure appropriate Required Actions are initiated if conditions exist that could invalidate the normal control bank insertion limits specified in the COLR.

A.4 Superceded by Amendment 216. NA NA Indian Point - Unit 2 A-9 Section 3.1

Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.1.7 - ROD POSITION INDICATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.6 3.1.7 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.1.7 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Adds an explicit statement that Separate Condition entry is allowed for each inoperable rod 3.10.6 3.1.7 RA-NOTE position indicator per group and each demand position indicator per bank.

A.4 Deletes explicit statement that the requirements for a misaligned rod must be applied if a 3.10.6.3 3.1.4 rod with an inoperable position indicator is determined to be misaligned because the 3.1.7 structure and presentation of requirements in the ITS eliminate the need for cross references.

A.5 Deletes statement that not more than one rod position indicator (IRPI) channel per group 3.10.6.2 3.1.7 RA-A.1 nor two IRPI channels per bank shall be permitted to be inoperable at any time because 3.1.7 RA-A.2 ITS LCO 3.1.7, Condition B, allows more than one IRPI channel per bank to be inoperable 3.1.7 RA-B.1 for 24 hours1 days 0.143 weeks 0.0329 months if certain operating restrictions are met. 3.1.7 RA-B.2 3.1.7 RA-B.3 3.1.7 RA-B.4 A.6 Clarifies the Frequency for checking rod position indirectly by core instrumentation 3.10.6.1 3.1.7 RA-A.1 whenever a rod position indicator channel is inoperable from "every shift" (defined as "at T 1-1 least twice per calendar day") to once per 12 hours0.5 days 0.0714 weeks 0.0164 months .

Indian Point - Unit 2 A-10 Section 3.1

Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.1.8 - PHYSICS TEST EXCEPTIONS - MODE 2 A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.C 3.1.8 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 3.10 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.1.8 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that physics tests performed in Mode 2 do not require an exemption from the 3.10.2.1 3.1.8 requirements of ITS LCO 3.2.1, Heat Flux Hot Channel Factor, ITS LCO 3.2.2, Nuclear 3.10.2.4 3.2.1 Enthalpy Rise Hot Channel Factor, ITS LCO 3.2.3, Axial Flux Difference (AFD), or ITS 3.10.3.1 3.2.2 LCO 3.2.4, Quadrant Power Tilt Ratio (QPTR) because these LCOs are Applicable in 3.2.3 Mode 1 only. 3.2.4 A.4 Maintains an existing allowance for disabling one channel of the nuclear flux power range T 3.5-2, No.2a 3.1.8 LCO function so that the instrument can be used to support physics testing.

Indian Point - Unit 2 A-11 Section 3.1

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.2 - POWER DISTRIBUTION LIMITS Discussion of Summary of Change CTS Section ITS Section Change ITS SECTION 3.2.1 - HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.2 3.2.1 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.2.1 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Eliminates statement that core power distribution limits do not apply during physics testing 3.10.2.1 3.2.1 LCO because physics testing is permitted in Mode 2 only and core power distribution limits are 3.2.2 LCO applicable only in Mode 1 3.2.3 LCO 3.2.4 LCO 3.1.8 LCO A.4 Explains how ITS 3.2.1 maintains the CTS allowance for a return to power for physics 3.10.2.2.2 3.2.1 APP testing following a shutdown when thermal limits are not met. 3.2.1 RA-A.1 3.2.1 RA-B.1 A.5 Eliminates "following initial core loading" as one of the required SR Frequencies because 3.10.2.2 3.2.1.1 SR initial fuel loading was a one time event that has been completed.

A.6 Separates the CTS Actions for hot channel factors not within limits into the Required 3.10.2.2.2 3.2.1 Actions for ITS LCO 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor (FN delta H), and 3.2.2 ITS LCO 3.2.1, Heat Flux Hot Channel Factor (FQ(Z).

Indian Point - Unit 2 A-12 Section 3.2

Discussion of Summary of Change CTS Section ITS Section Change A.7 Superceded by Amendment 216. NA NA A.8 Clarifies that the requirement that reactor power and high neutron flux trip setpoint are 3.10.2.2.2 3.2.1 RA-A.1 reduced so as not to exceed a fraction of rated value equal to the ratio of the FQ(Z) limit to 3.2.1 RA-A.2 measured value whenever the FQ(Z) limit is exceeded means that reactor power and high neutron flux trip setpoints must be reduced by 1% for each 1% that FQ(Z) exceeds the limit.

N ITS SECTION 3.2.2 - NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.2 3.2.2 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.2.2 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Eliminates statement that core power distribution limits do not apply during physics testing 3.10.2.1 3.2.1 LCO because physics testing is permitted in Mode 2 only and core power distribution limits are 3.2.2 LCO applicable only in Mode 1 3.2.3 LCO 3.2.4 LCO 3.1.8 LCO A.4 Separates the CTS Actions for hot channel factors not within limits into the Required 3.10.2.2.2 3.2.2 LCO Actions for ITS LCO 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor (FN delta H), and 3.2.1 LCO ITS LCO 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)).

A.5 Eliminates "following initial core loading" as one of the required SR Frequencies because 3.10.2.2 3.2.2.1 SR initial fuel loading was a one time event that has been completed.

Indian Point - Unit 2 A-13 Section 3.2

Discussion of Summary of Change CTS Section ITS Section Change ITS SECTION 3.2.3 - AXIAL FLUX DIFFERENCE (AFD)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.2 3.2.3 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10.2 3.2.3 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Eliminates statement that core power distribution limits do not apply during physics testing 3.10.2.4 3.2.1 LCO because physics testing is permitted in Mode 2 only and core power distribution limits are 3.2.2 LCO applicable only in Mode 1 3.2.3 LCO 3.2.4 LCO 3.1.8 LCO A.4 Eliminates cross references between statement of AFD requirements and Actions required 3.10.2.4 3.2.3 LCO if AFD limits are not met. 3.10.2.5 3.10.2.6 3.10.2.7 A.5 Clarifies that within 15 minutes is a reasonable interpretation of the completion time for the 3.10.2.5.1 3.2.3 RA-A.1 CTS requirement that the flux difference shall be returned to its target band immediately. 3.2.3 RA-B.1 A.6 Adds clarification that the AFD is outside the target band when two or more Operable 3.10.2.5 3.2.3 LCO Note 1 excore channels indicate AFD to be outside the target band.

A.7 Superceded by Amendment 216. NA NA A.8 Clarifies existing requirement that a power reduction required as compensatory action for 3.10.2.6.1 3.2.3 RA-C.1 AFD not within limits must be completed even if AFD is within specified limits before power 3.10.2.6.2 reduction is completed.

Indian Point - Unit 2 A-14 Section 3.2

Discussion of Summary of Change CTS Section ITS Section Change A.9 Eliminates CTS statement that duplicates requirements in ITS LCO 3.0.4. 3.10.2.6.3 3.2.3 LCO 3.0.4 LCO A.10 Clarifies that requirement to reduce reactor power immediately is met if power reduction is 3.10.2.6.1 3.2.3 RA-C.1 completed within 30 minutes. 3.10.2.6.2 A.11 Clarifies the requirements for monthly calibrations of upper and lower power range 3.11.B 3.2.3 detector chambers for axial offset is addressed by ITS LCO 3.3.1, Reactor Protection T 4.1-1, No.1 System (RPS) Instrumentation, which establishes requirements, including calibration, for the Operability of the power range detectors that are at least equivalent to those imposed by CTS 3.11.B.

ITS SPECIFICATION 3.2.4 - QUADRANT POWER TILT RATIO (QPTR)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.10.3 3.2.4 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.10 3.2.4 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Eliminates statement that core power distribution limits do not apply during physics testing 3.10.3.1 3.2.1 LCO because physics testing is permitted in Mode 2 only and core power distribution limits are 3.2.2 LCO applicable only in Mode 1 with thermal power greater than or equal to 50% RTP. 3.2.3 LCO 3.2.4 LCO 3.1.8 LCO A.4 Changes the presentation of requirements for QPTR Applicability from "when the core is 3.10.3.1 3.2.4 APP operating above 50% of rated thermal power" to "Mode 1 with thermal power > 50% RTP."

A.5 Clarifies that if an excore detector is inoperable, then excore detectors may be used to 1.8 3.2.4.1 SR determine QPTR only if power is less than or equal to 75% RTP. 3.10.2.9 3.2.4.2 SR Indian Point - Unit 2 A-15 Section 3.2

Discussion of Summary of Change CTS Section ITS Section Change A.6 Clarifies that that core flux maps used to verify QPTR do not use incore thimbles. 3.10.2.9 3.2.4.2 SR Indian Point - Unit 2 A-16 Section 3.2

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.3 - INSTRUMENTATION Discussion Summary of Change CTS Section ITS Section of Change ITS SECTION 3.3.1- REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 2.3 3.3.1 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 3.5 comprehensive ITS Bases. 4.1 A.2 Deletes CTS statements labeled Objective and Applicability because they do not 2.3 3.3.1 establish any requirements and do not provide any guidance for the application of CTS 3.5 requirements. 4.1 A.3 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.1 T 3.3.1-1 No. 1 Function 1, Manual Reactor Trip. T 4.1-1, No.42 A.3.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.1 T 3.3.1-1 No. 1 3.3.1, Function 1, Manual Reactor Trip. T 3.3.1-1 note a A.3.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-2, No.1 3.3.1 RA-B.1 Function 1, Manual Reactor Trip. T 4.1-1, No.42 3.3.1 RA-C.1 T 3.3.1-1 No. 1 A.3.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.0.1 3.0.3 LCO channel for: ITS 3.3.1, Function 1, Manual Reactor Trip. T 3.5-2, No.1 T 3.3.1-1 No. 1 A.3.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.1, Function 1, Manual Reactor Trip. T 3.5-2, No.1 T 3.3.1-1 No. 1 Indian Point - Unit 2 A-17 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.3.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.42 3.3.1.14 SR 3.3.1, Function 1, Manual Reactor Trip. T 3.3.1-1 No. 1 A.3.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 4.1-1, No.42 3.3.1.14 SR ITS 3.3.1, Function 1, Manual Reactor Trip. T 3.3.1-1 No. 1 A.4 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (1) T 3.3.1-1 No. 2a Function 2.a, Power Range Neutron Flux-High. T 3.5-2, No.2 T 4.1-1, No.1 A.4.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.2 T 3.3.1-1 No. 2a 3.3.1, Function 2.a, Power Range Neutron Flux-High.

A.4.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 3.3.1 RA-D.1 Function 2.a, Power Range Neutron Flux-High. T 3.5-2, No.2 T 3.3.1-1 No. 2a A.4.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 3.3.1 RA-D.1 channel for: ITS 3.3.1, Function 2.a, Power Range Neutron Flux-High. 1.8 3.2.4.2 SR 3.10.2.9 T 3.3.1-1 No. 2a 3.5.3 T 3.5-2, No.2 T 3.5-2, note 1 A.4.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.1, Function 2.a, Power Range Neutron Flux-High. T 3.5-2, No.2 3.3.1 RA-D.2 T 3.3.1-1 No. 2a A.4.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.1 T 3.3.1-1 No. 2a 3.3.1, Function 2.a, Power Range Neutron Flux-High. 3.3.1.1 SR 3.3.1.2 SR 3.3.1.7 SR 3.3.1.11 SR Indian Point - Unit 2 A-18 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.4.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.B (1) T 3.3.1-1 No. 2a ITS 3.3.1, Function 2.a, Power Range Neutron Flux-High.

A.5 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.A (1) T 3.3.1-1 No. 2b Function 2.b, Power Range Neutron Flux-Low. T 3.5-2, No.2 T 4.1-1, No.1 A.5.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.2a T 3.3.1-1 No. 2b 3.3.1, Function 2.b, Power Range Neutron Flux-Low.

A.5.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 2b Function 2.b, Power Range Neutron Flux-Low. T 3.5-2, No.2 A.5.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 3.3.1 RA-E.1 channel for: ITS 3.3.1, Function 2.b, Power Range Neutron Flux-Low. 3.5.3 T 3.3.1-1 No. 2b 3.5.4 T 3.5-2, No.2 A.5.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.1, Function 2.b, Power Range Neutron Flux-Low. T 3.5-2, No.2 3.3.1 RA-E.2 T 3.3.1-1 No. 2b A.5.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.1 T 3.3.1-1 No. 2b 3.3.1, Function 2.b, Power Range Neutron Flux-Low. 3.3.1.1 SR 3.3.1.8 SR 3.3.1.11 SR A.5.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.A (1) T 3.3.1-1 No. 2b ITS 3.3.1, Function 2.b, Power Range Neutron Flux-Low.

A.6 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.3 T 3.3.1-1 No. 3 Function 3, Intermediate Range Neutron Flux. T 4.1-1, No.2 Indian Point - Unit 2 A-19 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.6.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.3 T 3.3.1-1 No. 3 3.3.1, Function 3, Intermediate Range Neutron Flux.

A.6.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 3 Function 3, Intermediate Range Neutron Flux. T 3.5-2, No.3 A.6.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-2, No.3 T 3.3.1-1 No. 3 channel for: ITS 3.3.1, Function 3, Intermediate Range Neutron Flux. 3.3.1 RA-F.1 3.3.1 RA-F.2 A.6.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.3 T 3.3.1-1 No. 3 extended loss of redundancy for: ITS 3.3.1, Function 3, Intermediate Range Neutron Flux. 3.3.1 RA-G.1 3.3.1 RA-G.2 A.6.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.2 T 3.3.1-1 No. 3 3.3.1, Function 3, Intermediate Range Neutron Flux. 3.3.1.1 SR 3.3.1.8 SR 3.3.1.11 SR A.6.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3 T 3.3.1-1 No. 3 ITS 3.3.1, Function 3, Intermediate Range Neutron Flux. T 3.3.1-1 No. 2b A.7 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.4 T 3.3.1-1 No. 4 Function 4, Source Range Neutron (SRM) Flux. T 4.1-1, No.3 A.7.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.4 T 3.3.1-1 No. 4 3.3.1, Function 4, Source Range Neutron (SRM) Flux. 3.3.1 RA-G.1 A.7.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 4 Function 4, Source Range Neutron (SRM) Flux. T 3.5-2, No.4 Indian Point - Unit 2 A-20 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.7.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-2, No.4 T 3.3.1-1 No. 4 channel for: ITS 3.3.1, Function 4, Source Range Neutron (SRM) Flux. 3.3.1 RA-H.1 3.3.1 RA-J.1 3.3.1 RA-J.2.1 3.3.1 RA-J.2.2 A.7.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.4 T 3.3.1-1 No. 4 extended loss of redundancy for: ITS 3.3.1, Function 4, Source Range Neutron (SRM) Flux. 3.3.1 RA-I.1 A.7.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.3 T 3.3.1-1 No. 4 3.3.1, Function 4, Source Range Neutron (SRM) Flux. 3.3.1.1 SR 3.3.1.7 SR 3.3.1.8 SR 3.3.1.11 SR A.7.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3 T 3.3.1-1 No. 4 ITS 3.3.1, Function 4, Source Range Neutron (SRM) Flux. T 3.3.1-1 No. 2b A.8 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (4) T 3.3.1-1 No. 5 Function 5, Overtemperature delta T. T 3.5-2, No.5 T 4.1-1, No.1 T 4.1-1, No.4 T 4.1-1, No.7 A.8.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.5 T 3.3.1-1 No. 5 3.3.1, Function 5, Overtemperature delta T.

A.8.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 5 Function 5, Overtemperature delta T. T 3.5-2, No.5 3.3.1 RA-E.1 Indian Point - Unit 2 A-21 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.8.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 5 channel for: ITS 3.3.1, Function 5, Overtemperature delta T. 3.5.3 3.3.1 RA-E.1 3.5.4 T 3.5-2, No.5 A.8.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 5 extended loss of redundancy for: ITS 3.3.1, Function 5, Overtemperature delta T. T 3.5-2, No.5 3.3.1 RA-E.2 3.0.3 A.8.E Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (4) T 3.3.1-1 No. 5 Function 5, Overtemperature delta T. T 3.5-2, No.5 T 4.1-1, No.1 T 4.1-1, No.4 T 4.1-1, No.7 A.8.F Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.5 T 3.3.1-1 No. 5 3.3.1, Function 5, Overtemperature delta T.

A.9 Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 5 Function 5, Overtemperature delta T. T 3.5-2, No.5 3.3.1 RA-E.1 A.9.A Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 5 channel for: ITS 3.3.1, Function 5, Overtemperature delta T. 3.5.3 3.3.1 RA-E.1 3.5.4 T 3.5-2, No.5 A.9.B Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 5 extended loss of redundancy for: ITS 3.3.1, Function 5, Overtemperature delta T. T 3.5-2, No.5 3.3.1 RA-E.2 3.0.3 Indian Point - Unit 2 A-22 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.9.C Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (4) T 3.3.1-1 No. 5 Function 5, Overtemperature delta T. T 3.5-2, No.5 T 4.1-1, No.1 T 4.1-1, No.4 T 4.1-1, No.7 A.9.D Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.5 T 3.3.1-1 No. 5 3.3.1, Function 5, Overtemperature delta T.

A.9.E Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 5 Function 5, Overtemperature delta T. T 3.5-2, No.5 3.3.1 RA-E.1 A.9.F Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 5 channel for: ITS 3.3.1, Function 5, Overtemperature delta T. 3.5.3 3.3.1 RA-E.1 3.5.4 T 3.5-2, No.5 A.10 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (3) T 3.3.1-1 No. 7a Function 7.a, Pressurizer Pressure-Low. T 3.5-2, No.7 T 4.1-1, No.7 A.10.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A T 3.3.1-1 No. 7a 3.3.1, Function 7.a, Pressurizer Pressure-Low. T 3.5-2, No.7 A.10.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 7a Function 7.a, Pressurizer Pressure-Low. T 3.5-2, No.7 3.3.1 RA-K.1 A.10.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 7a channel for: ITS 3.3.1, Function 7.a, Pressurizer Pressure-Low. 3.5.3 3.3.1 RA-K.1 3.5.4 T 3.5-2, No.7 Indian Point - Unit 2 A-23 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.10.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 7a extended loss of redundancy for: ITS 3.3.1, Function 7.a, Pressurizer Pressure-Low. 2.3.2.A 3.3.1 RA-K.2 T 3.5-2, No.7 3.0.3 LCO A.10.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.7 T 3.3.1-1 No. 7a 3.3.1, Function 7.a, Pressurizer Pressure-Low. 3.3.1.1 SR 3.3.1.7 SR 3.3.1.10 SR A.10.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.B (3) T 3.3.1-1 No. 7a ITS 3.3.1, Function 7.a, Pressurizer Pressure-Low.

A.11 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (2) T 3.3.1-1 No. 7b Function 7.b, Pressurizer Pressure-High. T 3.5-2, No.8 T 4.1-1, No.7 A.11.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.8 T 3.3.1-1 No. 7b 3.3.1, Function 7.b, Pressurizer Pressure-High.

A.11.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 7b Function 7.b, Pressurizer Pressure-High. T 3.5-2, No.8 3.3.1 RA-E.1 A.11.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 7b channel for: ITS 3.3.1, Function 7.b, Pressurizer Pressure-High. 3.5.3 3.3.1 RA-E.1 3.5.4 T 3.5-2, No.8 A.11.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 7b extended loss of redundancy for: ITS 3.3.1, Function 7.b, Pressurizer Pressure-High. T 3.5-2, No.5 3.3.1 RA-E.2 T 3.5-2, No.8 3.0.3 LCO Indian Point - Unit 2 A-24 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.11.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.7 T 3.3.1-1 No. 7b 3.3.1, Function 7.b, Pressurizer Pressure-High. 3.3.1.1 SR 3.3.1.7 SR 3.3.1.10 SR A.11.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.B (2) T 3.3.1-1 No. 7b ITS 3.3.1, Function 7.b, Pressurizer Pressure-High.

A.12 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.C (1) T 3.3.1-1 No. 8 Function 8, Pressurizer Water Level-High. T 3.5-2, No.9 T 4.1-1, No.6 A.12.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A T 3.3.1-1 No. 8 3.3.1, Function 8, Pressurizer Water Level-High. T 3.5-2, No.9 A.12.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 8 Function 8, Pressurizer Water Level-High. T 3.5-2, No.9 3.3.1 RA-K.1 A.12.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 8 channel for: ITS 3.3.1, Function 8, Pressurizer Water Level-High. 3.5.3 3.3.1 RA-K.1 3.5.4 T 3.5-2, No.9 A.12.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 8 extended loss of redundancy for: ITS 3.3.1, Function 8, Pressurizer Water Level-High. T 3.5-2, No.7 3.3.1 RA-K.2 3.0.3 LCO A.12.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.7 T 3.3.1-1 No. 8 3.3.1, Function 8, Pressurizer Water Level-High. 3.3.1.1 SR 3.3.1.7 SR 3.3.1.10 SR Indian Point - Unit 2 A-25 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.12.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.C (1) T 3.3.1-1 No. 8 ITS 3.3.1, Function 8, Pressurizer Water Level-High.

A.13 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (6) T 3.3.1-1 No. 9 Function 9, Reactor Coolant Flow-Low. 2.3.2.A 2.3.2.B T 3.5-2, No.10 T 4.1-1, No.5 A.13.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A T 3.3.1-1 No. 9 3.3.1, Function 9, Reactor Coolant Flow-Low. 2.3.2.B T 3.5-2, No.10 A.13.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 9 Function 9, Reactor Coolant Flow-Low. T 3.5-2, No.10 3.3.1 RA-K.1 A.13.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 T 3.3.1-1 No. 9 channel for: ITS 3.3.1, Function 9, Reactor Coolant Flow-Low. 3.5.4 3.3.1 RA-K.1 T 3.5-2, No.10 A.13.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 9 extended loss of redundancy for: ITS 3.3.1, Function 9, Reactor Coolant Flow-Low. 2.3.2.A 3.3.1 RA-K.2 T 3.5-2, No.10 3.0.3 LCO T 3.5-2, No. 7 A.13.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.5 T 3.3.1-1 No. 9 3.3.1, Function 9, Reactor Coolant Flow-Low. 3.3.1.1 SR 3.3.1.7 SR 3.3.1.10 SR A.13.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.B (6) T 3.3.1-1 No. 9 ITS 3.3.1, Function 9, Reactor Coolant Flow-Low.

Indian Point - Unit 2 A-26 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.14 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.A T 3.3.1-1 No. 10a Function 10.a, Reactor Coolant Pump (RCP) Breaker Position-Single Loop. 2.3.2.B T 3.5-2, No.13 A.14.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.B T 3.3.1-1 No. 10a 3.3.1, Function 10.a, Reactor Coolant Pump (RCP) Breaker Position-Single Loop. T 3.5-2, No.13 A.14.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 10a Function 10.a, Reactor Coolant Pump (RCP) Breaker Position-Single Loop. T 3.5-2, No.10 3.3.1 RA-L.1 A.14.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 T 3.3.1-1 No. 10a channel for: ITS 3.3.1, Function 10.a, Reactor Coolant Pump (RCP) Breaker Position- 3.5.4 T 3.3.1-1 No. 10b Single Loop. T 3.5-2, No.13 3.3.1 RA-L.1 A.14.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 2.3.2.B T 3.3.1-1 No. 10a extended loss of redundancy for: ITS 3.3.1, Function 10.a, Reactor Coolant Pump (RCP) 3.0.1 3.3.1 RA-L.2 Breaker Position-Single Loop. T 3.5-2, No.13 3.0.3 LCO A.14.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.8 T 3.3.1-1 No. 10a 3.3.1, Function 10.a, Reactor Coolant Pump (RCP) Breaker Position-Single Loop. 3.3.1.14 SR A.14.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3 T 3.3.1-1 No. 10a ITS 3.3.1, Function 10.a, Reactor Coolant Pump (RCP) Breaker Position-Single Loop. 3.5 3.3.1.14 SR 4.1 A.15 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.A T 3.3.1-1 No. 10b Function 10.b, Reactor Coolant Pump (RCP) Breaker Position-Two Loops. T 3.5-2, No.13 A.15.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A T 3.3.1-1 No. 10b 3.3.1, Function 10.b, Reactor Coolant Pump (RCP) Breaker Position-Two Loops. 2.3.2.B T 3.3.1-1 No. 10a T 3.5-2, No.13 Indian Point - Unit 2 A-27 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.15.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 10b Function 10.b, Reactor Coolant Pump (RCP) Breaker Position-Two Loops. T 3.5-2, No.10 3.3.1 RA-K.1 A.15.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 T 3.3.1-1 No. 10b channel for: ITS 3.3.1, Function 10.b, Reactor Coolant Pump (RCP) Breaker Position-Two 3.5.4 3.3.1 RA-L.1 Loops. T 3.5-2, No.13 A.15.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 2.3.2.A T 3.3.1-1 No. 10b extended loss of redundancy for: ITS 3.3.1, Function 10.b, Reactor Coolant Pump (RCP) 3.0.1 3.3.1 RA-M.2 Breaker Position-Two Loops. T 3.5-2, No.13 3.0.3 LCO A.15.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.8b T 3.3.1-1 No. 10b 3.3.1, Function 10.b, Reactor Coolant Pump (RCP) Breaker Position-Two Loops. 3.3.1.14 SR A.15.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5 T 3.3.1-1 No.

ITS 3.3.1, Function 10.b, Reactor Coolant Pump (RCP) Breaker Position-Two Loops. 4.1 A.16 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B(7) T 3.3.1-1 No. 11 Function 11, RCP Undervoltage (6.9 kV bus). 2.3.2.A T 3.3.1-1 No. 10a T 3.5-2, No.12 T 3.3.1-1 No. 10b T 4.1-1, No.8 A.16.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A T 3.3.1-1 No. 11 3.3.1, Function 11, RCP Undervoltage (6.9 kV bus). T 3.5-2, No.12 A.16.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 11 Function 11, RCP Undervoltage (6.9 kV bus). T 3.5-2, No.12 3.3.1 RA-K.1 A.16.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 11 channel for: ITS 3.3.1, Function 11, RCP Undervoltage (6.9 kV bus). 3.5.3 3.3.1 RA-K.1 3.5.4 T 3.5-2, No.12 Indian Point - Unit 2 A-28 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.16.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 11 extended loss of redundancy for: ITS 3.3.1, Function 11, RCP Undervoltage (6.9 kV bus). 2.3.2.A 3.3.1 RA-K.2 T 3.5-2, No.12 3.0.3 LCO T 3.5-2, No. 7 A.16.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.8a T 3.3.1-1 No. 11 3.3.1, Function 11, RCP Undervoltage (6.9 kV bus). 3.3.1.9 SR 3.3.1.10 SR A.16.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.B (7) T 3.3.1-1 No. 11 ITS 3.3.1, Function 11, RCP Undervoltage (6.9 kV bus).

A.17 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.B (6) T 3.3.1-1 No. 12 Function 12, RCP Underfrequency (6.9 kV bus). 2.3.2.A T 3.5-2, No.13 T 4.1-1, No.8 A.17.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A T 3.3.1-1 No. 12 3.3.1, Function 12, RCP Underfrequency (6.9 kV bus). T 3.5-2, No.13 A.17.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 12 Function 12, RCP Underfrequency (6.9 kV bus). T 3.5-2, No.13 3.3.1 RA-K.1 A.17.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 12 channel for: ITS 3.3.1, Function 12, RCP Underfrequency (6.9 kV bus). 3.5.3 3.3.1 RA-K.1 3.5.4 T 3.5-2, No.13 A.17.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.1-1 No. 12 extended loss of redundancy for: ITS 3.3.1, Function 12, RCP Underfrequency (6.9 kV 2.3.2.A 3.3.1 RA-K.2 bus). T 3.5-2, No.7 3.0.3 LCO T 3.5-2, No.13 Indian Point - Unit 2 A-29 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.17.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.8b T 3.3.1-1 No. 12 3.3.1, Function 12, RCP Underfrequency (6.9 kV bus). 3.3.1.9 SR 3.3.1.10 SR A.17.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.B (6) T 3.3.1-1 No. 12 ITS 3.3.1, Function 12, RCP Underfrequency (6.9 kV bus).

A.18 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.1.C (2) T 3.3.1-1 No. 13 Function 13, Steam Generator (SG) Water Level low-low. T 3.5-2, No.11 T 4.1-1, No.11 A.18.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.11 T 3.3.1-1 No. 13 3.3.1, Function 13, Steam Generator (SG) Water Level Low-Low.

A.18.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 3.3.1 RA-E.1 Function 13, Steam Generator (SG) Water Level low-low. T 3.5-2, No.11 T 3.3.1-1 No. 13 A.18.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 T 3.3.1-1 No. 13 channel for: ITS 3.3.1, Function 13, Steam Generator (SG) Water Level low-low. 3.5.4 3.3.1 RA-E.1 T 3.5-2, No.11 3.3.1 RA-K.1 T 3.5-2, Note 1 A.18.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.3.1 RA-E.2 extended loss of redundancy for: ITS 3.3.1, Function 13, Steam Generator (SG) Water T 3.5-2, No.5 T 3.3.1-1 No. 13 Level low-low. T 3.5-2, No.11 3.0.3 LCO A.18.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.11 T 3.3.1-1 No. 13 3.3.1, Function 13, Steam Generator (SG) Water Level low-low. T 4.1-1, No.7 3.3.1.1 SR 3.3.1.7 SR 3.3.1.10 SR A.18.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.1.C (2) T 3.3.1-1 No. 13 ITS 3.3.1, Function 13, Steam Generator (SG) Water Level low-low.

Indian Point - Unit 2 A-30 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.19 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2 T 3.3.1-1 No. 14 Function 14, SG Water Level Low Coincident with Steam Flow/Feedwater Flow Mismatch.

A.19.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3 T 3.3.1-1 No. 13 3.3.1, Function 14, SG Water Level Low Coincident with Steam Flow/Feedwater Flow 3.5 T 3.3.1-1 No. 14 Mismatch. 4.1 A.19.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5 T 3.3.1-1 No. 14 Function 14, SG Water Level Low Coincident with Steam Flow/Feedwater Flow Mismatch. 4.1 A.19.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.4 T 3.3.1-1 No. 14 channel for: ITS 3.3.1, Function 14, SG Water Level Low Coincident with Steam 3.3.1 RA-E.1 Flow/Feedwater Flow Mismatch.

A.19.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2 T 3.3.1-1 No. 14 extended loss of redundancy for: ITS 3.3.1, Function 14, SG Water Level Low Coincident 3.3.1 RA-E.2 with Steam Flow/Feedwater Flow Mismatch.

A.19.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-2 T 3.3.1-1 No. 14 3.3.1, Function 14, SG Water Level Low Coincident with Steam Flow/Feedwater Flow 3.3.1.1 SR Mismatch. 3.3.1.7 SR 3.3.1.10 SR A.19.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-2 T 3.3.1-1 No. 14 ITS 3.3.1, Function 14, SG Water Level Low Coincident with Steam Flow/Feedwater Flow Mismatch.

A.20 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.C T 3.3.1-1 No. 15 Function 15, Turbine Trip-Low Auto Stop Oil Pressure. T 3.5-2, No.17 T 4.1-1, No.27 A.20.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.C T 3.3.1-1 No. 15 3.3.1, Function 15, Turbine Trip-Low Auto Stop Oil Pressure. T 3.5-2, No.17 Indian Point - Unit 2 A-31 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.20.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 3.3.1 RA-N.1 Function 15, Turbine Trip-Low Auto Stop Oil Pressure. T 3.5-2, No.17 T 3.3.1-1 No. 15 A.20.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 T 3.3.1-1 No. 15 channel for: ITS 3.3.1, Function 15, Turbine Trip-Low Auto Stop Oil Pressure. 3.5.3 3.3.1 RA-N.1 3.5.4 T 3.5-2, No.17 T 3.5-2, Note2 A.20.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.17 3.3.1 RA-N.2 extended loss of redundancy for: ITS 3.3.1, Function 15, Turbine Trip-Low Auto Stop Oil T 3.3.1-1 No. 15 Pressure.

A.20.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.27 T 3.3.1-1 No. 15 3.3.1, Function 15, Turbine Trip-Low Auto Stop Oil Pressure. 3.3.1.10 SR 3.3.1.14 SR A.20.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.2.C T 3.3.1-1 No. 15 ITS 3.3.1, Function 15, Turbine Trip-Low Auto Stop Oil Pressure. T 3.5-2, No.17 T 4.1-1, No.27 A.21 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 4.5.A.1 T 3.3.1-1 No. 16 Function 16, (Reactor Trip) Safety Injection (SI) Input from ESFAS. T 3.5-2, No.18a T 3.5-3, No.6 A.21.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.18a T 3.3.1-1 No. 16 3.3.1, Function 16, (Reactor Trip) Safety Injection (SI) Input from ESFAS.

A.21.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-3, No.6 3.3.1 RA-L.1 Function 16, (Reactor Trip) Safety Injection (SI) Input from ESFAS. T 3.3.1-1 No. 16 A.21.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-2, No.18a T 3.3.1-1 No. 16 channel for: ITS 3.3.1, Function 16, (Reactor Trip) Safety Injection (SI) Input from ESFAS. 3.3.1 RA-L.1 Indian Point - Unit 2 A-32 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.21.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.18a 3.3.1 RA-O.2 extended loss of redundancy for: ITS 3.3.1, Function 16, (Reactor Trip) Safety Injection (SI) T 3.3.1-1 No. 16 Input from ESFAS. 3.0.3 LCO A.21.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 4.5.A.1 T 3.3.1-1 No. 16 3.3.1, Function 16, (Reactor Trip) Safety Injection (SI) Input from ESFAS. 3.3.1.14 SR A.21.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 4.5.A.1 T 3.3.1-1 No. 16 ITS 3.3.1, Function 16, (Reactor Trip) Safety Injection (SI) Input from ESFAS.

A.22 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.4 T 3.3.1-1 No. 17a Function 17.a, Intermediate Range (IRM) Neutron Flux (P-6) Interlock. T 3.5-2, Note **

A.22.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.4 T 3.3.1-1 No. 17a 3.3.1, Function 17.a, Intermediate Range (IRM) Neutron Flux (P-6). T 3.5-2, Note ** T 3.3.1-1 No. 4 3.3.1 RA-M.1 A.22.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-2, No.4 T 3.3.1-1 No. 3 Function 17.a, Intermediate Range (IRM) Neutron Flux (P-6). T 3.5-2, Note ** T 3.3.1-1 No. 4 T 3.3.1-1 No. 17a 3.3.1 RA-Q.1 A.22.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-2, No.4 T 3.3.1-1 No. 17a channel for: ITS 3.3.1, Function 17.a, Intermediate Range (IRM) Neutron Flux (P-6). T 3.5-2, Note ** T 3.3.1-1 No. 4 3.3.1 RA-Q.1 A.22.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.4 3.3.1 RA-Q.2 extended loss of redundancy for: ITS 3.3.1, Function 17.a, Intermediate Range (IRM) T 3.5-2, Note ** T 3.3.1-1 No. 17a Neutron Flux (P-6).

A.22.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-2, No.4 3.3.1.11 SR 3.3.1, Function 17.a, Intermediate Range (IRM) Neutron Flux (P-6). T 3.5-2, Note ** 3.3.1.13 SR T 3.3.1-1 No. 17a Indian Point - Unit 2 A-33 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.22.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-2, No.4 T 3.3.1-1 No. 17a ITS 3.3.1, Function 17.a, Intermediate Range (IRM) Neutron Flux (P-6) Interlock. T 3.5-2, Note ** T 3.3.1-1 No. 4 A.23 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.A (1) T 3.3.1-1 No. 17b Function 17.b, Low Power Reactor Trip Block (P-7) Interlock. 2.3.2.A (2) T 3.3.1-1 No. 17d T 3.3.1-1 No. 17e A.23.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A (1) T 3.3.1-1 No. 17b 3.3.1, Function 17.b, Low Power Reactor Trip Block (P-7) Interlock. 2.3.2.A (2)

A.23.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 3.5.3 T 3.3.1-1 No. 17b Function 17.b, Low Power Reactor Trip Block (P-7) Interlock.

A.23.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 2.3.2.A (1) 3.3.1 RA-S.1 channel for: ITS 3.3.1, Function 17.b, Low Power Reactor Trip Block (P-7) Interlock. 2.3.2.A (2) T 3.3.1-1 No. 17b A.23.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 2.3.2.A T 3.3.1-1 No. 17b extended loss of redundancy for: ITS 3.3.1, Function 17.b, Low Power Reactor Trip Block 3.3.1 RA-S.2 (P-7) Interlock.

A.23.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 3.5 3.3.1.11 SR 3.3.1, Function 17.b, Low Power Reactor Trip Block (P-7) Interlock. 3.3.1.13 SR T 3.3.1-1 No. 17b A.23.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.2.A T 3.3.1-1 No. 17b ITS 3.3.1, Function 17.b, Low Power Reactor Trip Block (P-7) Interlock. T 3.3.1-1 No. 17d T 3.3.1-1 No. 17e A.24 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.B T 3.3.1-1 No. 17c Function 17.c, Power Range Neutron Flux (P-8) Interlock. 2.3.2.C A.24.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.B T 3.3.1-1 No. 17c 3.3.1, Function 17.c, Power Range Neutron Flux (P-8) Interlock. 2.3.2.C Indian Point - Unit 2 A-34 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.24.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-2 No. 2 T 3.3.1-1 No. 17c Function 17.c, Power Range Neutron Flux (P-8) Interlock. T 3.3.1-1 No. 2a A.24.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 2.3.2.B T 3.3.1-1 No. 17c channel for: ITS 3.3.1, Function 17.c, Power Range Neutron Flux (P-8) Interlock. 2.3.2.C 3.3.1 RA-S.1 A.24.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 2.3.2.B T 3.3.1-1 No. 17c extended loss of redundancy for: ITS 3.3.1, Function 17.c, Power Range Neutron Flux (P-8) 2.3.2.C 3.3.1. RA-S.2 Interlock. 3.0.3 LCO A.24.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 2.3.2.B T 3.3.1-1 No. 17c 3.3.1, Function 17.c, Power Range Neutron Flux (P-8) Interlock. 2.3.2.C 3.3.1.11 SR 3.3.1.13 SR A.24.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.2.B T 3.3.1-1 No. 17c ITS 3.3.1, Function 17.c, Power Range Neutron Flux (P-8) Interlock. 2.3.2.C A.25 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.A (1) T 3.3.1-1 No. 17d Function 17.d, Power Range Neutron Flux (P-10) Interlock. T 3.3.1-1 No. 2b T 3.3.1-1 No. 3 A.25.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A (1) T 3.3.1-1 No. 17d 3.3.1, Function 17.d, Power Range Neutron Flux (P-10) Interlock.

A.25.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-2 No. 2 T 3.3.1-1 No. 17d Function 17.d, Power Range Neutron Flux (P-10) Interlock. T 3.3.1-1 No. 2a A.25.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 2.3.2.A (1) 3.3.1 RA-Q.1 channel for: ITS 3.3.1, Function 17.d, Power Range Neutron Flux (P-10) Interlock. T 3.3.1-1 No. 17d A.25.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 2.3.2.A (1) 3.3.1 RA-Q.2 extended loss of redundancy for: ITS 3.3.1, Function 17.d, Power Range Neutron Flux (P- T 3.3.1-1 No. 17d

10) Interlock.

Indian Point - Unit 2 A-35 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.25.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.1 T 3.3.1-1 No. 17d 3.3.1, Function 17.d, Power Range Neutron Flux (P-10) Interlock. 3.3.1.11 SR 3.3.1.13 SR A.25.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.2.A (2) T 3.3.1-1 No. 17d ITS 3.3.1, Function 17.d, Power Range Neutron Flux (P-10) Interlock.

A.26 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, 2.3.2.A (2) T 3.3.1-1 No. 17e Function 17.e, Turbine First Stage Pressure (P-7 Input) Interlock. T 4.1-1, No.24 A.26.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 2.3.2.A (2) T 3.3.1-1 No. 17e 3.3.1, Function 17.e, Turbine First Stage Pressure (P-7 Input) Interlock.

A.26.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, 2.3.2.A (1) T 3.3.1-1 No. 17e Function 17.e, Turbine First Stage Pressure (P-7 Input) Interlock.

A.26.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 2.3.2.A (2) T 3.3.1-1 No. 17e channel for: ITS 3.3.1, Function 17.e, Turbine First Stage Pressure (P-7 Input) Interlock. T 4.1-1, No.24 3.3.1 RA-S.1 A.26.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 2.3.2.A (2) T 3.3.1-1 No. 17e extended loss of redundancy for: ITS 3.3.1, Function 17.e, Turbine First Stage Pressure (P- 3.5.3 3.3.1 RA-S.2 7 Input) Interlock. T 4.1-1, No.24 3.0.3 LCO A.26.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.24 T 3.3.1-1 No. 17e 3.3.1, Function 17.e, Turbine First Stage Pressure (P-7 Input) Interlock. 3.3.1.1 SR 3.3.1.7 SR 3.3.1.10 SR A.26.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 2.3.2.A (2) T 3.3.1-1 No. 17e ITS 3.3.1, Function 17.e, Turbine First Stage Pressure (P-7 Input) Interlock. T 4.1-1, No.24 Indian Point - Unit 2 A-36 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.27 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.19 T 3.3.1-1 No. 18 Function 18, Reactor Trip Breakers. T 4.1-1, No.43 T 4.1-1, No.44 A.27.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.19 T 3.3.1-1 No. 18 3.3.1, Function 18, Reactor Trip Breakers.

A.27.B Adopts NUREG-1431 presentation of requirements for number of channels for: T 3.5-2, No.19 3.3.1 RA-C.1 ITS 3.3.1, Function 18, Reactor Trip Breakers. 3.3.1 RA-P.1 T 3.3.1-1 No. 18 A.27.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.0.1 3.3.1 RA-C.1 channel for: ITS 3.3.1, Function 18, Reactor Trip Breakers. 3.5.3 3.3.1 RA-C.2.1 1.5 3.3.1 RA-P.1 T 3.5-2, No.19 T 3.3.1-1 No. 18 A.27.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.19 3.3.1 RA-C.2.1 extended loss of redundancy for: ITS 3.3.1, Function 18, Reactor Trip Breakers. 3.3.1 RA-C.2.2 T 3.3.1-1 No. 18 3.0.3 LCO A.27.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.43 T 3.3.1-1 No. 18 3.3.1, Function 18, Reactor Trip Breakers. T 4.1-1, No.44 3.3.1.4 SR T 4.1-1, Note*9 A.27.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5 T 3.3.1-1 No. 18 ITS 3.3.1, Function 18, Reactor Trip Breakers. 4.1 A.28 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.19 T 3.3.1-1 No. 19 Function 19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms. T 4.1-1, No.43 T 4.1-1, No.44 Indian Point - Unit 2 A-37 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.28.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.19 T 3.3.1-1 No. 19 3.3.1, Function 19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms.

A.28.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-2, No.19 T 3.3.1-1 No. 19 Function 19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms.

A.28.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-2, No.19 3.3.1 RA-S.1 channel for: ITS 3.3.1, Function 19, Reactor Trip Breaker Undervoltage and Shunt Trip T 3.3.1-1 No. 19 Mechanisms.

A.28.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-2, No.19 3.3.1 RA-C.2.1 extended loss of redundancy for: ITS 3.3.1, Function 19, Reactor Trip Breaker 3.3.1 RA-C.2.2 Undervoltage and Shunt Trip Mechanisms. T 3.3.1-1 No. 19 3.0.3 LCO A.28.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.43 T 3.3.1-1 No. 19 3.3.1, Function 19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms. T 4.1-1, No.44 3.3.1.4 SR T 3.5-2, No.19 A.28.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5 T 3.3.1-1 No. 19 ITS 3.3.1, Function 19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms. 4.1 A.29 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.1, T 3.5-2, No.18 T 3.3.1-1 No. 20 Function 20, (RPS) Automatic Trip Logic. T 4.1-1, No.25 A.29.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-2, No.18 3.3.1 RA-C.1 3.3.1, Function 20, (RPS) Automatic Trip Logic. 3.3.1 RA-C.2.1 3.3.1 RA-C.2.2 3.3.1 RA-M.1 T 3.3.1-1 No. 20 A.29.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.1, T 3.5-2, No.18 3.3.1 RA-O.1 Function 20, (RPS) Automatic Trip Logic. T 3.3.1-1 No. 20 Indian Point - Unit 2 A-38 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.29.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 1.5 3.3.1 RA-C.1 channel for: ITS 3.3.1, Function 20, (RPS) Automatic Trip Logic. 3.5.3 3.3.1 RA-C.2.1 T 3.5-2, No.18 3.3.1 RA-L.1 T 3.5-2, No.19 3.3.1 RA-O.1 T 3.3.1-1 No. 20 A.29.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.1, Function 20, (RPS) Automatic Trip Logic. T 3.5-2, No.18 3.3.1 RA-L.2 T 3.3.1-1 No. 20 A.29.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.25 T 3.3.1-1 No. 20 3.3.1, Function 20, (RPS) Automatic Trip Logic. 3.3.1.5 SR A.29.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 4.1-1, No.25 T 3.3.1-1 No. 20 ITS 3.3.1, Function 20, (RPS) Automatic Trip Logic.

A.30 Clarifies that CTS 3.5.2, which specifies that "plant operation shall be permitted to continue 3.5.2 3.3.1 in accordance with Tables 3.5-2 through 3.5-4. No more than one channel of a particular T 3.5-2 protection channel set shall be tested at the same time. By definition, an instrumentation T 3.5-3 channel failure shall not be regarded as a channel being tested," is maintained by the T 3.5-4 combination of requirements in ITS Table 3.3.1-1 and ITS 3.3.1, Required Actions, including notes that address testing.

A.31 Clarifies that a channel in bypass for testing is inoperable and that the actions for an 3.5.3 3.3.1 RA-D.1 Note inoperable channel apply. 3.3.1 RA-E.1 Note 3.3.1 RA-H.1 Note 3.3.1 RA-I.1 Note 3.3.1 RA-J.1 Note 3.3.1 RA-K.1 Note 3.3.1 RA-L.1 Note A.32 Clarifies that ITS 3.3.1 requirements in Table 3.3.1-1 and associated Required Actions are T 3.5-2, No.10 T 3.3.1-1 constructed to allow separate condition entry for each function listed in Table 3.3.1-1. T 3.5-2, No.11 3.3.1 RA-Note Indian Point - Unit 2 A-39 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.33 Clarifies how ITS combination of requirements for number of Operable channels and that an 1.5 3.3.1 LCO inoperable channel is placed in trip maintains the CTS requirement for minimum number of 3.5.3 3.3.2 LCO Operable channels and minimum degree of redundancy with no explicit requirement that an T 3.5-2 inoperable channel is placed in trip. T 3.5-3 T 3.5-4 A.34 Superceded by Amendment 225. NA NA A.35 Not Used. NA NA ITS SPECIFICATION 3.3.2 - ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.5 3.3.2 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.1 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.5 3.3.2 establish any requirements and do not provide any guidance for the application of CTS 4.1 requirements.

A.3 ITS 3.3.2. Function 1.a, Safety Injection-Manual Initiation. T 3.5-3, No.1a T 3.3.2-1 No. 1a A.3.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.2 APP 3.3.2, Function 1.a, Safety Injection-Manual Initiation. T 3.5-3, No.1a T 3.3.2-1 No. 1a A.3.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.1a 3.3.2 RA-B.1 Function 1.a, Safety Injection-Manual Initiation. T 3.3.2-1 No. 1a A.3.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.1a 3.3.2 RA-B.1 channel for: ITS 3.3.2, Function 1.a, Safety Injection-Manual Initiation. T 3.3.2-1 No. 1a Indian Point - Unit 2 A-40 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.3.D Adopts NUREG-1431 presentation and organization of Actions for loss of function for: ITS T 3.5-3, No.1a 3.3.2 RA-B.2.1 3.3.2, Function 1.a, Safety Injection-Manual Initiation. 3.3.2 RA-B.2.2 T 3.3.2-1 No. 1a A.3.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 4.5.A.1.A T 3.3.2-1 No. 1a 3.3.2, Function 1.a, Safety Injection-Manual Initiation. T 4.1-1 3.3.2.6 SR A.3.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 4.5.A.1.a 3.3.2.6 SR ITS 3.3.2, Function 1.a, Safety Injection-Manual Initiation. T 3.5-3, No.1a T 3.3.2-1 No. 1a A.4 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 1b Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation Relays.

A.4.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 1b 3.3.2, Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation Relays.

A.4.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 1b Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation Relays. T 3.5-3, No.6 A.4.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-C.1 train for: ITS 3.3.2, Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation T 3.5-3, Note # T 3.3.2-1 No. 1b Relays.

A.4.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 1.b, Safety Injection-Automatic 3.5.1 T 3.3.2-1 No. 1b Actuation Logic and Actuation Relays. T 3.5-3, No.6 3.3.2 RA-C.2.1 T 3.5-3, Note# 3.3.2 RA-C.2.2 A.4.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 3.5.1 T 3.3.2-1 No. 1b 3.3.2, Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation Relays. 4.5.A.1.a 3.3.2 RA-C.1 T 3.5-2, Note # 3.3.2.2 SR T 4.1-1, No.26 3.3.2.3 SR 3.3.2.5 SR Indian Point - Unit 2 A-41 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.4.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5.1 T 3.3.2-1 No. 1b ITS 3.3.2, Function 1.b, Safety Injection-Automatic Actuation Logic and Actuation Relays.

A.5 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.1 T 3.3.2-1 No. 1c Function 1.c, Safety Injection-Containment Pressure-High. T 3.5-3, No.1b T 4.1-1, No.18b A.5.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 1c 3.3.2, Function 1.c, Safety Injection-Containment Pressure-High. T 3.5-1, No.1 T 3.5-3, No.1b A.5.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.1 T 3.3.2-1 No. 1c Function 1.c, Safety Injection-Containment Pressure-High. T 3.5-3, No.1b 3.3.2 RA-D.1 A.5.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 1.c, Safety Injection-Containment Pressure-High. 3.5.4 T 3.3.2-1 No. 1c T 3.5-1, No.1 T 3.5-3, No.1b A.5.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 1.c, Safety Injection-Containment T 3.5-1, No.1 3.3.2 RA-D.2.1 Pressure-High. T 3.5-3, No.1b 3.3.2 RA-D.2.2 T 4.1-1, No.18b T 3.3.2-1 No. 1c A.5.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-1, No.1 T 3.3.2-1 No. 1c 3.3.2, Function 1.c, Safety Injection-Containment Pressure-High. T 4.1-1, No.18b 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.5.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.1 T 3.3.2-1 No. 1c ITS 3.3.2, Function 1.c, Safety Injection-Containment Pressure-High.

Indian Point - Unit 2 A-42 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.6 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.3 T 3.3.2-1 No. 1d Function 1.d, Safety Injection - Pressurizer Pressure - Low. T 3.5-3, No.1d T 4.1-1, No.7 A.6.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-1, No.3 T 3.3.2-1 No. 1d 3.3.2, Function 1.d, Safety Injection - Pressurizer Pressure - Low. T 3.5-3, No.1d A.6.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3 T 3.3.2-1 No. 1d Function 1.d, Safety Injection - Pressurizer Pressure - Low.

A.6.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 1.d, Safety Injection - Pressurizer Pressure - Low. 3.5.4 T 3.3.2-1 No. 1d T 3.5-3, No.1d A.6.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 1.d, Safety Injection - Pressurizer T 3.5-3, No.1d 3.3.2 RA-D.2.1 Pressure - Low. 3.3.2 RA-D.2.2 T 3.3.2-1 No. 1d A.6.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.7 T 3.3.2-1 No. 1d 3.3.2, Function 1.d, Safety Injection - Pressurizer Pressure - Low. 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.6.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.3 T 3.3.2-1 No. 1d ITS 3.3.2, Function 1.d, Safety Injection - Pressurizer Pressure - Low.

A.7 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.4 T 3.3.2-1 No. 1e Function 1.e, Safety Injection-High Differential Pressure Between Steam Lines. T 3.5-3, No.1c T 4.1-1, No.23 Indian Point - Unit 2 A-43 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.7.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-1, No.4 T 3.3.2-1 No. 1e 3.3.2, Function 1.e, Safety Injection-High Differential Pressure Between Steam Lines. T 3.5-3, No.1c T 4.1-1, No.23 A.7.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.4 T 3.3.2-1 No. 1e Function 1.e, Safety Injection-High Differential Pressure Between Steam Lines. T 3.5-3, No.1c T 4.1-1, No.23 A.7.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 1.e, Safety Injection-High Differential Pressure Between T 3.5-1, No.4 T 3.3.2-1 No. 1e Steam Lines. T 3.5-3, No.1c T 4.1-1, No.23 A.7.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 1.e, Safety Injection-High Differential T 3.5-1, No.4 3.3.2 RA-D.2.1 Pressure Between Steam Lines. T 3.5-3, No.1c 3.3.2 RA-D.2.2 T 4.1-1, No.23 T 3.3.2-1 No. 1e A.7.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-1, No.4 T 3.3.2-1 No. 1e 3.3.2, Function 1.e, Safety Injection-High Differential Pressure Between Steam Lines. T 3.5-3, No.1c 3.3.2.1 SR T 4.1-1, No.23 3.3.2.4 SR 3.3.2.7 SR A.7.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.4 T 3.3.2-1 No. 1e ITS 3.3.2, Function 1.e, Safety Injection-High Differential Pressure Between Steam Lines.

A.8 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 1f Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Tave - T 3.5-3, No.1e Low. T 4.1-1, No.4 T 4.1-1, No.24 Indian Point - Unit 2 A-44 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.8.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-1, No.5 T 3.3.2-1 No. 1f 3.3.2, Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident with T 3.5-3, No.1e Tave - Low. T 4.1-1, No.24 T 4.1-1, No.4 A.8.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 1f Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Tave - T 3.5-3, No.1e Low. T 4.1-1, No.24 T 4.1-1, No.4 A.8.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-1, No.5 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines T 3.5-3, No.1e T 3.3.2-1 No. 1f Coincident with Tave - Low. T 4.1-1, No.24 T 4.1-1, No.4 A.8.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 1.f, Safety Injection - High Steam Flow T 3.5-1, No.5 3.3.2 RA-D.2.1 in Two Steam Lines Coincident with Tave - Low. T 3.5-3, No.1e 3.3.2 RA-D.2.2 T 4.1-1, No.24 T 3.3.2-1 No. 1f T 4.1-1, No.4 A.8.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-1, No.5 T 3.3.2-1 No. 1f 3.3.2, Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident with T 3.5-3, No.1e 3.3.2.1 SR Tave - Low. T 4.1-1, No.24 3.3.2.4 SR T 4.1-1, No.4 3.3.2.7 SR A.8.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.5 T 3.3.2-1 No. 1d ITS 3.3.2, Function 1.f, Safety Injection - High Steam Flow in Two Steam Lines Coincident T 3.5-3, No.1e T 3.3.2-1 No. 1e with Tave - Low. T 4.1-1, No.24 T 3.3.2-1 No. 1f T 4.1-1, No.4 T 3.3.2-1 No. 4d T 3.3.2-1 No. 4e Indian Point - Unit 2 A-45 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.9 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 1g Function 1.g, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Steam T 3.5-3, No.1e Line Pressure - Low. T 4.1-1, No.23 T 4.1-1, No.24 A.9.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-1, No.5 T 3.3.2-1 No. 1g 3.3.2, Function 1.g, Safety Injection - High Steam Flow in Two Steam Lines Coincident with T 3.5-3, No.1e Steam Line Pressure - Low. T 4.1-1, No.23 T 4.1-1, No.24 A.9.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 1g Function 1.g, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Steam T 3.5-3, No.1e Line Pressure - Low. T 4.1-1, No.23 T 4.1-1, No.24 A.9.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 1.g, Safety Injection - High Steam Flow in Two Steam Lines T 3.5-1, No.5 T 3.3.2-1 No. 1g Coincident with Steam Line Pressure - Low. T 3.5-3, No.1e T 4.1-1, No.23 T 4.1-1, No.24 A.9.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 1.g, Safety Injection - High Steam T 3.5-1, No.5 3.3.2 RA-D.2.1 Flow in Two Steam Lines Coincident with Steam Line Pressure - Low. T 3.5-3, No.1e 3.3.2 RA-D.2.2 T 4.1-1, No.23 T 3.3.2-1 No. 1g T 4.1-1, No.24 A.9.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-1, No.5 T 3.3.2-1 No. 1g 3.3.2, Function 1.g, Safety Injection - High Steam Flow in Two Steam Lines Coincident with T 3.5-3, No.1e 3.3.2.1 SR Steam Line Pressure - Low. T 4.1-1, No.23 3.3.2.4 SR T 4.1-1, No.24 3.3.2.7 SR Indian Point - Unit 2 A-46 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.9.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.5 T 3.3.2-1 No. 1g ITS 3.3.2, Function 1.g, Safety Injection - High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low.

A.10 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, Function T 3.5-3, No.2a T 3.3.2-1 No. 2a 2.a, Containment Spray-Manual Initiation.

A.10.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.2 APP 3.3.2, Function 2.a, Containment Spray-Manual Initiation. T 3.5-3, No.2a T 3.3.2-1 No. 2a A.10.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.2a 3.3.2 RA-B.1 Function 2.a, Containment Spray-Manual Initiation. T 3.3.2-1 No. 2a A.10.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.2a 3.3.2 RA-B.1 channel for: ITS 3.3.2, Function 2.a, Containment Spray-Manual Initiation. T 3.3.2-1 No. 2a A.10.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-3, No.2a 3.3.2 RA-B.2.1 extended loss of redundancy for: ITS 3.3.2, Function 2.a, Containment Spray-Manual 3.3.2 RA-B.2.2 Initiation. T 3.3.2-1 No. 2a A.10.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 4.5.B.1 3.3.2.6 SR 3.3.2, Function 2.a, Containment Spray-Manual Initiation. T 3.5-3, No.2a T 3.3.2-1 No. 2a A.10.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 1.0 3.3.2.6 SR ITS 3.3.2, Function 2.a, Containment Spray-Manual Initiation. T 3.5-3, No.2a T 3.3.2-1 No. 2a A.11 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 2b Function 2.b, Containment Spray - Automatic Actuation Logic and Actuation Relays.

A.11.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 2b 3.3.2, Function 2.b, Containment Spray - Automatic Actuation Logic and Actuation Relays.

Indian Point - Unit 2 A-47 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.11.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.6 T 3.3.2-1 No. 2b Function 2.b, Containment Spray - Automatic Actuation Logic and Actuation Relays. 3.3.2 RA-C.1 A.11.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-C.1 channel for: ITS 3.3.2, Function 2.b, Containment Spray - Automatic Actuation Logic and T 3.5-3, Note # T 3.3.2-1 No. 2b Actuation Relays.

A.11.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 2.b, Containment Spray - Automatic 3.5.1 T 3.3.2-1 No. 2b Actuation Logic and Actuation Relays. T 3.5-3, No.6 3.3.2 RA-C.2.1 3.3.2 RA-C.2.2 A.11.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 3.5.1 T 3.3.2-1 No. 2b 3.3.2, Function 2.b, Containment Spray - Automatic Actuation Logic and Actuation Relays. 4.5.B.1 3.3.2 RA-C.1 T 3.5-2, Note # 3.3.2.2 SR T 4.1-1, No.26 3.3.2.3 SR 3.3.2.5 SR A.11.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5.1 T 3.3.2-1 No. 2b ITS 3.3.2, Function 2.b, Containment Spray - Automatic Actuation Logic and Actuation Relays.

A.12 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.2 T 3.3.2-1 No. 2c Function 2.c, Containment Spray - Containment Pressure (High-High). T 3.5-3, No.2b T 4.1-1, No.18a A.12.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 2c 3.3.2, Function 2.c, Containment Spray - Containment Pressure (High-High). T 3.5-1, No.2 T 3.5-3, No.2b A.12.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, 3.5.3 3.3.2 RA-E.1 Function 2.c, Containment Spray - Containment Pressure (High-High). T 3.5-3, No.2b T 3.3.2-1 No. 2c Indian Point - Unit 2 A-48 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.12.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-E.1 channel for: ITS 3.3.2, Function 2.c, Containment Spray - Containment Pressure (High- 3.5.4 T 3.3.2-1 No. 2c High). T 3.5-3, No.2b A.12.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-4 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 2.c, Containment Spray - Containment T 3.5-3, No.2b 3.3.2 RA-E.2.1 Pressure (High-High). 3.3.2 RA-E.2.2 T 3.3.2-1 No. 2c A.12.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.18a T 3.3.2-1 No. 2c 3.3.2, Function 2.c, Containment Spray - Containment Pressure (High-High). 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.12.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.2 T 3.3.2-1 No. 2c ITS 3.3.2, Function 2.c, Containment Spray - Containment Pressure (High-High).

A.13 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-4, No.1c T 3.3.2-1 No. 3a1 Function 3.a.(1), Containment Phase A Isolation-Manual Initiation.

A.13.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.2 APP 3.3.2, Function 3.a.(1), Containment Phase A Isolation-Manual Initiation. T 3.5-4, No.1c T 3.3.2-1 No. 3a1 A.13.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-4, No.1c 3.3.2 RA-B.1 Function 3.a.(1), Containment Phase A Isolation-Manual Initiation. T 3.3.2-1 No. 3a1 A.13.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-4, No.1c 3.3.2 RA-B.1 channel for: ITS 3.3.2, Function 3.a.(1), Containment Phase A Isolation-Manual Initiation. T 3.3.2-1 No. 3a1 A.13.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-4, No.1c 3.3.2 RA-B.2.1 extended loss of redundancy for: ITS 3.3.2, Function 3.a.(1), Containment Phase A 3.3.2 RA-B.2.2 Isolation-Manual Initiation. T 3.3.2-1 No. 3a1 Indian Point - Unit 2 A-49 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.13.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-4, No.1c T 3.3.2-1 No. 3a1 3.3.2, Function 3.a.(1), Containment Phase A Isolation-Manual Initiation. T 4.1-1 3.3.2.6 SR T 4.1-3, No.5 A.13.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 1.0 3.3.2.6 SR ITS 3.3.2, Function 3.a.(1), Containment Phase A Isolation-Manual Initiation. T 3.5-4, No.1c T 3.3.2-1 No. 3a1 A.14 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 3a2 Function 3.a.(2), Containment Phase A Isolation-Automatic Actuation Logic and Actuation Relays.

A.14.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 3a2 3.3.2, Function 3.a.(2), Containment Phase A Isolation-Automatic Actuation Logic and Actuation Relays.

A.14.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.6 T 3.3.2-1 No. 3a2 Function 3.a.(2), Containment Phase A Isolation-Automatic Actuation Logic and Actuation 3.3.2 RA-C.1 Relays.

A.14.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-C.1 channel for: ITS 3.3.2, Function 3.a.(2), Containment Phase A Isolation-Automatic T 3.5-3, Note # T 3.3.2-1 No. 3a2 Actuation Logic and Actuation Relays.

A.14.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 3.a.(2), Containment Phase A 3.5.1 T 3.3.2-1 No. 3a2 Isolation-Automatic Actuation Logic and Actuation Relays. T 3.5-3, No.6 3.3.2 RA-C.2.1 T 3.5-3, Note # 3.3.2 RA-C.2.2 A.14.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-2, Note # T 3.3.2-1 No. 3a2 3.3.2, Function 3.a.(2), Containment Phase A Isolation-Automatic Actuation Logic and T 4.1-1, No.26 3.3.2 RA-C.1 Note Actuation Relays. T 4.1-3, No.5 3.3.2.2 SR 3.3.2.3 SR 3.3.2.5 SR Indian Point - Unit 2 A-50 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.14.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5.1 T 3.3.2-1 No. 3a2 ITS 3.3.2, Function 3.a.(2), Containment Phase A Isolation-Automatic Actuation Logic and Actuation Relays.

A.15 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-4, No.1a T 3.3.2-1 No. 3a3 Function 3.a.(3), Containment Phase A Isolation - Safety Injection. T 3.5-3, No.1 3.3.2 RA-D.1 A.16 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-4, No.1c T 3.3.2-1 No. 3b1 Function 3.b.(1), Containment Phase B Isolation-Manual Initiation.

A.16.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.2 APP 3.3.2, Function 3.b.(1), Containment Phase B Isolation-Manual Initiation. T 3.5-4, No.1c T 3.3.2-1 No. 3b1 A.16.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-4, No.1c 3.3.2 RA-B.1 Function 3.b.(1), Containment Phase B Isolation-Manual Initiation. T 3.3.2-1 No. 3b1 A.16.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-4, No.1c 3.3.2 RA-B.1 channel for: ITS 3.3.2, Function 3.b.(1), Containment Phase B Isolation-Manual Initiation. T 3.3.2-1 No. 3b1 A.16.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-4, No.1c 3.3.2 RA-B.2.1 extended loss of redundancy for: ITS 3.3.2, Function 3.b.(1), Containment Phase B 3.3.2 RA-B.2.2 Isolation-Manual Initiation. T 3.3.2-1 No. 3b1 A.16.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-4, No.3 T 3.3.2-1 No. 3b1 3.3.2, Function 3.b.(1), Containment Phase B Isolation-Manual Initiation. 3.3.2.6 SR A.16.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 1.0 3.3.2.6 SR ITS 3.3.2, Function 3.b.(1), Containment Phase B Isolation-Manual Initiation. T 3.5-4, No.1c T 3.3.2-1 No. 3b1 A.17 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 3b2 Function 3.b.(2), Containment Phase B Isolation-Automatic Actuation Logic and Actuation Relays.

Indian Point - Unit 2 A-51 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.17.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 3b2 3.3.2, Function 3.b.(2), Containment Phase B Isolation-Automatic Actuation Logic and Actuation Relays.

A.17.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.6 T 3.3.2-1 No. 3b2 Function 3.b.(2), Containment Phase B Isolation-Automatic Actuation Logic and Actuation 3.3.2 RA-C.1 Relays.

A.17.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-C.1 channel for: ITS 3.3.2, Function 3.b.(2), Containment Phase B Isolation-Automatic T 3.5-3, Note # T 3.3.2-1 No. 3b2 Actuation Logic and Actuation Relays.

A.17.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 3.b.(2), Containment Phase B T 3.5-3, No.6 T 3.3.2-1 No. 3b2 Isolation-Automatic Actuation Logic and Actuation Relays. T 3.5-3, Note # 3.3.2 RA-C.2.1 3.3.2 RA-C.2.2 A.17.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-2, Note # T 3.3.2-1 No. 3b2 3.3.2, Function 3.b.(2), Containment Phase B Isolation-Automatic Actuation Logic and T 4.1-1, No.26 3.3.2.2 SR Actuation Relays. T 4.1-3, No.5 3.3.2.3 SR 3.3.2.5 SR A.17.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5.1 T 3.3.2-1 No. 3b2 ITS 3.3.2, Function 3.b.(2), Containment Phase B Isolation-Automatic Actuation Logic and Actuation Relays.

A.18 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.2 T 3.3.2-1 No. 3b3 Function 3.b.(3), Containment Phase B Isolation-Containment Pressure (High-High). T 3.5-4, No.1b T 4.1-1, No.18a A.18.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 3b3 3.3.2, Function 3.b.(3), Containment Phase B Isolation-Containment Pressure (High-High). T 3.5-4 Indian Point - Unit 2 A-52 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.18.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3 3.3.2 RA-E.1 Function 3.b.(3), Containment Phase B Isolation-Containment Pressure (High-High). T 3.3.2-1 No. 3b3 A.18.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-4, No.1b 3.3.2 RA-E.1 channel for: ITS 3.3.2, Function 3.b.(3), Containment Phase B Isolation-Containment T 3.5-3, No.2 T 3.3.2-1 No. 3b3 Pressure (High-High).

A.18.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 3.b.(3), Containment Phase B T 3.5-4, No.1b 3.3.2 RA-E.2.1 Isolation-Containment Pressure (High-High). 3.3.2 RA-E.2.2 T 3.3.2-1 No. 3b3 A.18.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.18a T 3.3.2-1 No. 3b3 3.3.2, Function 3.b.(3), Containment Phase B Isolation-Containment Pressure (High-High). 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.18.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.2 T 3.3.2-1 No. 3b3 ITS 3.3.2, Function 3.b.(3), Containment Phase B Isolation-Containment Pressure (High-High).

A.19 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-4, No.2c T 3.3.2-1 No. 4a Function 4.a, Steam Line Isolation-Manual Initiation.

A.19.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.2 App 3.3.2, Function 4.a, Steam Line Isolation-Manual Initiation. T 3.5-4, No.2c T 3.3.2-1 No. 4a A.19.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-4, No.1c 3.3.2 RA-F.1 Function 4.a, Steam Line Isolation-Manual Initiation. T 3.5-4, No.2c T 3.3.2-1 No. 4a A.19.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-4, No.2c 3.3.2 RA-F.1 channel for: ITS 3.3.2, Function 4.a, Steam Line Isolation-Manual Initiation. T 3.3.2-1 No. 4a Indian Point - Unit 2 A-53 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.19.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-4, No.2c 3.3.2 RA-F.2.1 extended loss of redundancy for: ITS 3.3.2, Function 4.a, Steam Line Isolation-Manual 3.3.2 RA-F.2.2 Initiation. T 3.3.2-1 No. 4a A.19.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 4.7 3.3.2.6 SR 3.3.2, Function 4.a, Steam Line Isolation-Manual Initiation. T 4.1-1 T 3.3.2-1 No. 4a A.19.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-4, No.2c 3.3.2.6 SR ITS 3.3.2, Function 4.a, Steam Line Isolation-Manual Initiation. T 3.3.2-1 No. 4a A.20 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 4b Function 4.b, Steam Line Isolation-Automatic Actuation Logic and Actuation Relays.

A.20.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 4b 3.3.2, Function 4.b, Steam Line Isolation-Automatic Actuation Logic and Actuation Relays.

A.20.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.6 T 3.3.2-1 No. 4b Function 4.b, Steam Line Isolation-Automatic Actuation Logic and Actuation Relays.

A.20.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-G.1 channel for: ITS 3.3.2, Function 4.b, Steam Line Isolation-Automatic Actuation Logic and T 3.5-3, Note # T 3.3.2-1 No. 4b Actuation Relays.

A.20.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 T 3.3.2-1 No. 4b extended loss of redundancy for: ITS 3.3.2, Function 4.b, Steam Line Isolation-Automatic T 3.5-3, No.6 Actuation Logic and Actuation Relays. T 3.5-3, Note #

A.20.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 4.7 T 3.3.2-1 No. 4b 3.3.2, Function 4.b, Steam Line Isolation-Automatic Actuation Logic and Actuation Relays. T 3.5-3, Note # 3.3.2.2 SR T 4.1-1, No.26 3.3.2.3 SR 3.3.2.5 SR Indian Point - Unit 2 A-54 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.20.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5.1 T 3.3.2-1 No. 4b ITS 3.3.2, Function 4.b, Steam Line Isolation-Automatic Actuation Logic and Actuation Relays.

A.21 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.2 T 3.3.2-1 No. 4c Function 4.c, Steam Line Isolation - Containment Pressure (High-High). T 3.5-4, No.2b T 4.1-1, No.18a A.21.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 4c 3.3.2, Function 4.c, Steam Line Isolation - Containment Pressure (High-High). T 3.5-1, No.2 T 3.5-4, No.2b A.21.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3 3.3.2 RA-E.1 Function 4.c, Steam Line Isolation - Containment Pressure (High-High). T 3.5-4, No.2b T 3.3.2-1 No. 4c A.21.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-4, No.2b 3.3.2 RA-E.1 channel for: ITS 3.3.2, Function 4.c, Steam Line Isolation - Containment Pressure (High- T 3.5-4, No.1b T 3.3.2-1 No. 4c High).

A.21.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 4.c, Steam Line Isolation - T 3.5-3 3.3.2 RA-E.2.1 Containment Pressure (High-High). T 3.5-4, No.2b 3.3.2 RA-E.2.2 T 3.3.2-1 No. 4c A.21.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.18a T 3.3.2-1 No. 4c 3.3.2, Function 4.c, Steam Line Isolation - Containment Pressure (High-High). 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.21.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.2 T 3.3.2-1 No. 4c ITS 3.3.2, Function 4.c, Steam Line Isolation - Containment Pressure (High-High). T 3.5-4, No.2b T 4.1-1, No.18a Indian Point - Unit 2 A-55 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.22 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 4d Function 4.d, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident with T 3.5-4, No.2a Tave - Low. T 4.1-1, No.4 T 4.1-1, No.24 A.22.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 4d 3.3.2, Function 4.d, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident T 3.5-1, No.5 with Tave - Low. T 3.5-4, No.2a T 4.1-1, No.24 T 4.1-1, No.4 A.22.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 4d Function 4.d, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident with T 3.5-4, No.2a 3.3.2 RA-D.1 Tave - Low. T 4.1-1, No.24 T 4.1-1, No.4 A.22.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 4.d, Steam Line Isolation - High Steam Flow in Two Steam 3.5.4 T 3.3.2-1 No. 4d Lines Coincident with Tave - Low. T 3.5-3, No.1e T 3.5-4, No.2a A.22.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-1, No.5 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 4.d, Steam Line Isolation - High T 3.5-4, No.2a 3.3.2 RA-D.2.1 Steam Flow in Two Steam Lines Coincident with Tave - Low. T 4.1-1, No.24 3.3.2 RA-D.2.2 T 4.1-1, No.4 T 3.3.2-1 No. 4d A.22.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-1, No.5 T 3.3.2-1 No. 4d 3.3.2, Function 4.d, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident T 3.5-4, No.2a 3.3.2.1 SR with Tave - Low. T 4.1-1, No.24 3.3.2.4 SR T 4.1-1, No.4 3.3.2.7 SR Indian Point - Unit 2 A-56 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.22.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.5 T 3.3.2-1 No. 1d ITS 3.3.2, Function 4.d, Steam Line Isolation - High Steam Flow in Two Steam Lines T 3.3.2-1 No. 1e Coincident with Tave - Low. T 3.3.2-1 No. 4d T 3.3.2-1 No. 4e A.23 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 4e Function 4.e, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident with T 3.5-4, No.2a Steam Line Pressure - Low. T 4.1-1, No.23 T 4.1-1, No.24 A.23.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-1, No.5 T 3.3.2-1 No. 4e 3.3.2, Function 4.e, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident T 3.5-4, No.2a with Steam Line Pressure - Low. T 4.1-1, No.23 T 4.1-1, No.24 A.23.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.5 T 3.3.2-1 No. 4e Function 4.e, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident with T 3.5-4, No.2a Steam Line Pressure - Low. T 4.1-1, No.23 T 4.1-1, No.24 A.23.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 4.e, Steam Line Isolation - High Steam Flow in Two Steam T 3.5-3, No.1e 3.3.2 RA-E.1 Lines Coincident with Steam Line Pressure - Low. T 3.5-4, No.2a T 3.3.2-1 No. 4e A.23.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 4.e, Steam Line Isolation - High T 3.5-1, No.5 3.3.2 RA-D.2.1 Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low. T 3.5-4, No.2a 3.3.2 RA-D.2.2 T 4.1-1, No.23 T 3.3.2-1 No. 4e T 4.1-1, No.24 Indian Point - Unit 2 A-57 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.23.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.23 T 3.3.2-1 No. 4e 3.3.2, Function 4.e, Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident T 4.1-1, No.24 3.3.2.1 SR with Steam Line Pressure - Low. 3.3.2.4 SR 3.3.2.7 SR A.23.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.5 T 3.3.2-1 No. 1d ITS 3.3.2, Function 4.e, Steam Line Isolation - High Steam Flow in Two Steam Lines T 3.5-4, No.2a T 3.3.2-1 No. 1e Coincident with Steam Line Pressure - Low. T 4.1-1, No.23 T 3.3.2-1 No. 4d T 4.1-1, No.24 T 3.3.2-1 No. 4e T 4.1-1, No.4 A.24 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 5a Function 5.a, Feedwater Isolation-Automatic Actuation Logic and Actuation Relays.

A.24.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 5a 3.3.2, Function 5.a, Feedwater Isolation-Automatic Actuation Logic and Actuation Relays.

A.24.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.6 T 3.3.2-1 No. 5a Function 5.a, Feedwater Isolation-Automatic Actuation Logic and Actuation Relays. 3.3.2 RA-C.1 A.24.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-C.1 Note channel for: ITS 3.3.2, Function 5.a, Feedwater Isolation-Automatic Actuation Logic and T 3.5-3, Note # 3.3.2 RA-G.1 Actuation Relays. T 3.3.2-1 No. 5a A.24.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 5.a, Feedwater Isolation-Automatic T 3.5-3, No.6 T 3.3.2-1 No. 5a Actuation Logic and Actuation Relays. T 3.5-3, Note # 3.3.2 RA-G.2.1 3.3.2 RA-G.2.2 Indian Point - Unit 2 A-58 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.24.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 3.5-2, Note # T 3.3.2-1 No. 5a 3.3.2, Function 5.a, Feedwater Isolation-Automatic Actuation Logic and Actuation Relays. T 4.1-1, No.26 3.3.2 RA-G.1 Note 3.3.2.2 SR 3.3.2.3 SR 3.3.2.5 SR A.24.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5.1 T 3.3.2-1 No. 5a ITS 3.3.2, Function 5.a, Feedwater Isolation-Automatic Actuation Logic and Actuation Relays.

A.25 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5 T 3.3.2-1 No. 5b Function 5.b, Feedwater Isolation - SG Level (High-High). 4.1 A.25.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5 T 3.3.2-1 No. 5b 3.3.2, Function 5.b, Feedwater Isolation - SG Level (High-High). 4.1 A.25.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, 3.5 T 3.3.2-1 No. 5b Function 5.b, Feedwater Isolation - SG Level (High-High). 4.1 3.3.2 RA-D.1 A.25.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5 T 3.3.2-1 No. 5b channel for: ITS 3.3.2, Function 5.b, Feedwater Isolation - SG Level (High-High). 3.3.2 RA-D.1 A.25.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 4.1-1, No.11 T 3.3.2-1 No. 5b extended loss of redundancy for: ITS 3.3.2, Function 5.b, Feedwater Isolation - SG Level 3.3.2 RA-D.2.1 (High-High). 3.3.2 RA-D.2.2 A.25.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.11 T 3.3.2-1 No. 5b 3.3.2, Function 5.b, Feedwater Isolation - SG Level (High-High). 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.25.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5 T 3.3.2-1 No. 5b ITS 3.3.2, Function 5.b, Feedwater Isolation - SG Level (High-High). 4.1 Indian Point - Unit 2 A-59 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.26 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-4, No.3a T 3.3.2-1 No. 5c Function 5.c, Feedwater Isolation - Safety Injection. T 3.5-3, No.1 T 3.3.2-1 No. 5a A.27 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 6a Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic and Actuation Relays.

A.27.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 6a 3.3.2, Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic and Actuation Relays. T 3.5-3, No.4 A.27.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, 3.5.1 T 3.3.2-1 No. 6a Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic and Actuation Relays. T 3.5-3, No.6 A.27.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.6 3.3.2 RA-C.1 channel for: ITS 3.3.2, Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic and T 3.5-3, Note#

Actuation Relays.

A.27.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 6.a, Auxiliary Feedwater-Automatic 3.5.1 T 3.3.2-1 No. 6a Actuation Logic and Actuation Relays. T 3.5-3, No.6 3.3.2 RA-G.2.1 3.3.2 RA-G.2.2 A.27.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS 4.8.A.1 T 3.3.2-1 No. 4b 3.3.2, Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic and Actuation Relays. T 4.1-1, No.26 3.3.2 RA-G.1 Note T 4.1-1, No.30b 3.3.2.2 SR T 3.5-3, Note# 3.3.2.3 SR 3.3.2.5 SR A.27.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5 T 3.3.2-1 No. 6a ITS 3.3.2, Function 6.a, Auxiliary Feedwater-Automatic Actuation Logic and Actuation Relays.

Indian Point - Unit 2 A-60 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.28 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.6 T 3.3.2-1 No. 6b Function 6.b, Auxiliary Feedwater - SG Water Level - low-low. T 3.5-3, No.4a T 4.1-1, No.11 A.28.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-1, No.6 T 3.3.2-1 No. 6b 3.3.2, Function 6.b, Auxiliary Feedwater - SG Water Level - low-low. T 3.5-3, No.4a T 4.1-1, No.30a A.28.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.6 T 3.3.2-1 No. 6b Function 6.b, Auxiliary Feedwater - SG Water Level - low-low. T 3.5-3, No.4a T 4.1-1, No.30a A.28.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.2 RA-D.1 channel for: ITS 3.3.2, Function 6.b, Auxiliary Feedwater - SG Water Level - low-low. T 3.5-1, No.6 T 3.3.2-1 No. 6b T 3.5-3, No.4a T 4.1-1, No.30a A.28.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.0.1 3.0.3 LCO extended loss of redundancy for: ITS 3.3.2, Function 6.b, Auxiliary Feedwater - SG Water T 3.5-1, No.6 3.3.2 RA-D.2.1 Level - low-low. T 3.5-3, No.4a 3.3.2 RA-D.2.2 T 4.1-1, No.30a T 3.3.2-1 No. 6b A.28.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.30a T 3.3.2-1 No. 6b 3.3.2, Function 6.b, Auxiliary Feedwater - SG Water Level - low-low. 3.3.2.1 SR SR 3.3.2.7 A.28.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.6 T 3.3.2-1 No. 6b ITS 3.3.2, Function 6.b, Auxiliary Feedwater - SG Water Level - low-low.

A.29 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-3, No.4b T 3.3.2-1 No. 6c Function 6.c, Auxiliary Feedwater - Safety Injection. T 3.5-3, No.1 T 3.3.2-1 No. 6a Indian Point - Unit 2 A-61 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.30 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-1, No.7 T 3.3.2-1 No. 6d Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or 6A).

T 3.5-3, No.4c T 4.1-1, No.30c A.30.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 T 3.3.2-1 No. 6d 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or T 3.5-3, No.4c 6A).

A.30.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-1, No.7 T 3.3.2-1 No. 6d Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or 6A). T 3.5-3, No.4c A.30.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-1, No.7 T 3.3.2-1 No. 6d channel for: ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) T 3.5-3, No.4c 3.3.2 RA-F.1 (Undervoltage Bus 5A or 6A). T 4.1-1, No.30c A.30.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-1, No.7 T 3.3.2-1 No. 6d extended loss of redundancy for: ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station T 3.5-3, No.4c 3.3.2 RA-F.2.1 Blackout (SBO) (Undervoltage Bus 5A or 6A). T 4.1-1, No.30c 3.3.2 RA-F.2.2 A.30.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.30c T 3.3.2-1 No. 6d 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A or 3.3.2.6 SR 6A). 3.3.2.7 SR A.30.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.7 T 3.3.2-1 No. 6d ITS 3.3.2, Function 6.d, Auxiliary Feedwater-Station Blackout (SBO) (Undervoltage Bus 5A T 3.5-3, No.4c or 6A).

A.31 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-3, No.4d T 3.3.2-1 No. 6e Function 6.e, Auxiliary Feedwater - Trip of Main Boiler Feedwater Pump. T 4.1-1, No.30d Indian Point - Unit 2 A-62 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.31.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-3, No.4d T 3.3.2-1 No. 6e 3.3.2, Function 6.e, Auxiliary Feedwater - Trip of Main Boiler Feedwater Pump. T 4.1-1, No.30d A.31.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.2, T 3.5-3, No.4d T 3.3.2-1 No. 6e Function 6.e, Auxiliary Feedwater - Trip of Main Boiler Feedwater Pump. T 4.1-1, No.30d A.31.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3, No.4d T 3.3.2-1 No. 6e channel for: ITS 3.3.2, Function 6.e, Auxiliary Feedwater - Trip of Main Boiler Feedwater T 4.1-1, No.30d 3.3.2 RA-H.1 Pump. 3.3.2 RA-H.2 A.31.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-3, No.4d 3.3.2 RA-H.1.2 extended loss of redundancy for: ITS 3.3.2, Function 6.e, Auxiliary Feedwater - Trip of Main 3.3.2 RA-H.2.2 Boiler Feedwater Pump.

A.31.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.30d 3.3.2.6 SR 3.3.2, Function 6.e, Auxiliary Feedwater - Trip of Main Boiler Feedwater Pump. 3.3.2.7 SR A.31.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-3 T 3.3.2-1 No. 6e ITS 3.3.2, Function 6.e, Auxiliary Feedwater - Trip of Main Boiler Feedwater Pump.

A.32 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.2, T 3.5-3, No.1d T 3.3.2-1 No. 7 Function 7, ESFAS Interlock - Pressurizer Pressure. T 3.5-3, No.1d* T 3.3.2-1 No. 1d T 4.1-1, No.7 3.3.2 RA-I.1 3.3.2.1 SR 3.3.2.4 SR 3.3.2.7 SR A.33 Clarifies that in addition to the global statement ESFAS functions must be Operable when 3.5.1 T 3.3.2-1 the plant is not in cold shutdown condition, CTS also provides an explicitly stated or implied Applicability requirement for each of the ESFAS functions and that the Applicability for each ESFAS function is maintained in ITS 3.3.2, Table 3.3.2-1.

Indian Point - Unit 2 A-63 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.34 Clarifies that CTS 3.5.2, which specifies that "plant operation shall be permitted to continue 3.5.2 3.3.2 in accordance with Tables 3.5-2 through 3.5-4. No more than one channel of a particular T 3.5-2 protection channel set shall be tested at the same time. By definition, an instrumentation T 3.5-3 channel failure shall not be regarded as a channel being tested," is maintained by the T 3.5-4 combination of requirements in ITS Table 3.3.2-1 and ITS 3.3.2, Required Actions, including notes that address testing.

A.35 Clarifies that a channel in bypass for testing is inoperable and that the actions for an 3.5.3 3.3.2 RA-C.1 inoperable channel apply. 3.3.2 RA-D.1 3.3.2 RA-E.1 3.3.2 RA-G.1 A.36 Clarifies that ITS 3.3.2 requirements in Table 3.3.2-1 and associated Required Actions are 3.5.3 3.3.2 RA-Note constructed to allow separate condition entry for each function listed in Table 3.3.2-1.

A.37 Clarifies how ITS combination of requirements for number of Operable channels and that an 1.5 3.3.2 inoperable channel is placed in trip maintains the CTS requirement for minimum number of T 3.5-2 3.3.2 RA-A.1 Operable channels and minimum degree of redundancy with no explicit requirement that an T 3.5-3 inoperable channel is placed in trip. T 3.5-4 A.38 Superceded by Amendment 225. NA NA A.39 Clarifies that CTS Amendment 212, dated November 30, 2000, established explicit T 3.5-3, No.6 3.3.2, Function 1b requirements for ESFAS Automatic Actuation Logic and that these requirements are T 3.5-3, Note# 3.3.2, Function 2b maintained in ITS LCO 3.3.2. 3.3.2,Function 3a2 3.3.2,Function 3b2 3.3.2, Function 4b 3.3.2, Function 5a 3.3.2, Function 6a Indian Point - Unit 2 A-64 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.40 Clarifies how ITS combination of requirements for number of Operable channels and that an T 3.5-2 3.3.2 inoperable channel is placed in trip maintains the CTS requirement for minimum number of T 3.5-3 Operable channels and minimum degree of redundancy with no explicit requirement that an T 3.5-4 inoperable channel is placed in trip. 1.5 ITS SPECIFICATION 3.3.3 - POST ACCIDENT MONITORING (PAM) INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.5 3.3.3 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.1 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.5 3.3.3 establish any requirements and do not provide any guidance for the application of CTS 4.1 requirements.

A.3 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.4 3.3.3, Function 1 service time and surveillance testing for ITS 3.3.3, Function 1, RCS Hot Leg Temperature (wide range) which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.4 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.4 3.3.3, Function 2 service time and surveillance testing for ITS 3.3.3, Function 2, RCS Cold Leg Temperature (wide range), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.5 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of 3.5 3.3.3, Function 3 service time and surveillance testing for ITS 3.3.3, Function 3, RCS Pressure (wide range), 4.1 which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

Indian Point - Unit 2 A-65 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.6 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of 3.5 3.3.3, Function 4 service time and surveillance testing for ITS 3.3.3, Function 4, Reactor Vessel Level 4.1 Indication System, which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.7 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.21a 3.3.3, Function 5 service time and surveillance testing for ITS 3.3.3, Function 5, Containment Sump Water T 4.1-1, No.21b Level (Recirculation Sump), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.8 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.21a 3.3.3, Function 6 service time and surveillance testing for ITS 3.3.3, Function 6, Containment Water Level T 4.1-1, No.21b (Containment Sump), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.9 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.18b 3.3.3, Function 7 service time and surveillance testing for ITS 3.3.3, Function 7, Containment Pressure (narrow range), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.10 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 3.5-5, No.7 3.3.3, Function 8 service time and surveillance testing for ITS 3.3.3, Function 8, Containment Pressure (high T 4.1-1, No. 18c 3.3.3 RA-E.1 range), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. 3.3.3 RA-E.2 Guide 1.97 Review of Accident Monitoring Instrumentation. Changes the name of this function from Wide Range Containment Pressure Monitor Containment Pressure (High Range) to more closely match design documents and control room labeling.

A.11 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 3.5-5, No.10 3.3.3, Function 9 service time and surveillance testing for ITS 3.3.3, Function 9, Containment Area Radiation T 4.1-1, No.40 3.3.3 RA-A.1 (high range), which is identified as a Type A, Category I variable in the Indian Point 2 NRC 3.3.3.1 SR Reg. Guide 1.97 Review of Accident Monitoring Instrumentation. 3.3.3.2 SR 5.6.6 Indian Point - Unit 2 A-66 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.12 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 3.5-5, No.11 3.3.3, Function 10 service time and surveillance testing for ITS 3.3.3, Function 10, Containment Hydrogen T 4.1-1, No.41 3.3.3 RA-A.1 Monitors, which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. T 3.5-5, Action3 Guide 1.97 Review of Accident Monitoring Instrumentation.

A.13 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 3.5-5, No.1 3.3.3, Function 11 service time and surveillance testing for ITS 3.3.3, Function 11, Pressurizer Level, which is T 4.1-1, No.6 3.3.3 RA-A.1 identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 3.3.3.1 SR Review of Accident Monitoring Instrumentation. 5.6.6 A.14 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.11 3.3.3, Function 12 service time and surveillance testing for ITS 3.3.3, Function 12, SG Water Level (narrow range), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg.

Guide 1.97 Review of Accident Monitoring Instrumentation.

A.15 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of 3.5 3.3.3, Function 14 service time and surveillance testing for ITS 3.3.3, Function 14, Condensate Storage Tank Level, which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg.

Guide 1.97 Review of Accident Monitoring Instrumentation.

A.16 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of 3.5 3.3.3, Function 15 service time and surveillance testing for ITS 3.3.3, Functions 15 through 18, Core Exit 4.1 3.3.3, Function 16 Temperature (CET) for core quadrants 1 through 4, which is identified as a Type A, 3.3.3, Function 17 Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident 3.3.3, Function 18 Monitoring Instrumentation.

A.17 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 3.5-5, No.6 3.3.3, Function 19 service time and surveillance testing for ITS 3.3.3, Function 19, Auxiliary Feedwater Flow, T 3.5-5, Note*****

which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide T 4.1-1, No.35 1.97 Review of Accident Monitoring Instrumentation.

Indian Point - Unit 2 A-67 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.18 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.23 3.3.3, Function 20 service time and surveillance testing for ITS 3.3.3, Function 20, Steam Line Pressure, which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

A.19 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 3.5-5, No.2 3.3.3, Function 21 service time and surveillance testing for ITS 3.3.3, Function 20, Steam Line Pressure, which T 3.5-5, Action1 is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 T 4.1-1, No.31 Review of Accident Monitoring Instrumentation.

A.20 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of T 4.1-1, No.15 3.3.3, Function 22 service time and surveillance testing for ITS 3.3.3, Function 22, RWST Level, which is 3.3.A.1.k 3.3.3.1 SR identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 3.3.5.4 SR Review of Accident Monitoring Instrumentation.

A.21 Superceded by TSFT-359, Revision 9, Increased Flexibility in MODE Restraints. NA NA A.22 Provides clarification that Separate Condition entry is allowed for each inoperable Post 3.5 3.3.3 RA-Note Accident Monitoring Function. 4.1 1.3 A.23 Clarifies that performing a Channel Check more frequently than is necessary to satisfy PAM 3.5 3.3.3.1 SR Operability requirements has no affect on instrument Operability.

A.24 Adopts NUREG-1431 presentation and organization for the Operability, allowable out of 3.5 3.3.3, Function 13 service time and surveillance testing for ITS 3.3.3, Function 13, Steam Generator Level (wide range), which is identified as a Type A, Category I variable in the Indian Point 2 NRC Reg. Guide 1.97 Review of Accident Monitoring Instrumentation.

ITS SPECIFICATION 3.3.4 - REMOTE SHUTDOWN NONE Indian Point - Unit 2 A-68 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.3.5 - LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.5 3.3.5 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.1 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.5 3.3.5 establish any requirements and do not provide any guidance for the application of CTS 4.1 requirements.

A.3 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.5, 480 V T 3.5-1, No.8a 3.3.5 Bus Undervoltage Function - LOP DG Start Instrumentation. T 3.5-3, No.3a T 4.1-1, No.29a A.3.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.5 3.3.5, 480 V Bus Undervoltage Function - LOP DG Start Instrumentation. T 3.5-1, No.8a 3.5.5 T 3.5-3, No.3a 3.8.2 A.3.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.5, T 3.5-3, No.3a 3.3.5 480 V Bus Undervoltage Function - LOP DG Start Instrumentation.

A.3.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.5 RA-F.1 channel for: ITS 3.3.5, 480 V Bus Undervoltage Function - LOP DG Start Instrumentation. T 3.5-3, No.3a A.3.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.5.3 3.3.5 extended loss of redundancy for: ITS 3.3.5, 480 V Bus Undervoltage Function - LOP DG T 3.5-3, No.3a 3.3.5 RA-C.1 Start Instrumentation.

A.3.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.29a 3.3.5.3 SR 3.3.5, 480 V Bus Undervoltage Function - LOP DG Start Instrumentation. 3.3.5.4 SR 3.3.5.5 SR Indian Point - Unit 2 A-69 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.3.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.8a 3.3.5 ITS 3.3.5, 480 V Bus Undervoltage Function - LOP DG Start Instrumentation. T 4.1-1, No.29a A.4 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.5, 480 V T 3.5-1, No.8b 3.3.5 Bus Degraded Voltage Function - LOP DG Start Instrumentation. T 3.5-3, No.3b T 4.1-1, No.29b A.4.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.5 3.3.5, 480 V Bus Degraded Voltage Function - LOP DG Start Instrumentation. T 3.5-3, Note 3 A.4.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.5, T 3.5-3, No.3b 3.3.5 480 V Bus Degraded Voltage Function - LOP DG Start Instrumentation. T 3.5-3, Note3 A.4.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.5.3 3.3.5 RA-G.1 channel on one or more buses for: ITS 3.3.5, 480 V Bus Degraded Voltage Function - LOP T 3.5-3, No.3b 3.3.5 RA-H.1 DG Start Instrumentation. T 3.5-3, Note 3 A.4.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-3, No.3b 3.3.5 RA-F.1 extended loss of redundancy for: ITS 3.3.5, 480 V Bus Degraded Voltage Function - LOP T 3.5-3, Note3 3.3.5 RA-G.1 DG Start Instrumentation. 3.3.5 RA-H.1 A.4.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No.29b 3.3.5.1 SR 3.3.5, 480 V Bus Degraded Voltage Function - LOP DG Start Instrumentation. 3.3.5.2 SR 3.3.5.5 SR A.4.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-1, No.8b 3.3.5 ITS 3.3.5, 480 V Bus Degraded Voltage Function - LOP DG Start Instrumentation. T 3.5-3, No.3a A.5 Clarifies how ITS combination of requirements for number of Operable channels and that an 1.5 3.3.2 inoperable channel is placed in trip maintains the CTS requirement for minimum number of T 3.5-1 3.3.5 RA-A.1 Operable channels and minimum degree of redundancy with no explicit requirement that an T 3.5-3 3.3.5 RA-B.1 inoperable channel is placed in trip.

Indian Point - Unit 2 A-70 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.6 Superceded by Amendment 225. NA NA A.7 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.5, 480 V T 3.5-1, No. 7 3.3.5 Bus Station Blackout (SBO) Function - LOP DG Start Instrumentation. T 3.5-3, No. 4.c T 4.1-1, No. 30.c A.7.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS 3.5.1 3.3.5 3.3.5, 480 V Bus Station Blackout (SBO) Function - LOP DG Start Instrumentation. T 3.5-3 A.7.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.5, T 3.5-3, No. 4.c 3.3.5 LCO 480 V Bus Station Blackout (SBO) Function - LOP DG Start Instrumentation.

A.7.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable T 3.5-3 3.3.5 channel for: ITS 3.3.5, 480 V Bus Station Blackout (SBO) Function - LOP DG Start Instrumentation.

A.7.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or T 3.5-3, No.4c 3.3.5 extended loss of redundancy for: ITS 3.3.5, 480 V Bus Station Blackout (SBO) Function -

LOP DG Start Instrumentation.

A.7.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No. 30c 3.3.5.3 SR 3.3.5, 480 V Bus Station Blackout (SBO) Function - LOP DG Start Instrumentation. 3.3.5.4 SR 3.3.5.5 SR A.7.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.5-1, No. 7 3.3.5 ITS 3.3.5, 480 V Bus Station Blackout (SBO) Function - LOP DG Start Instrumentation. 3.5-3, No. 4c ITS SPECIFICATION 3.3.6 - CONTAINMENT PURGE SYSTEM AND PRESSURE RELIEF LINE ISOLATION INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 T 3.5-4, No.4a 3.3.6 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 3.1.F.1 comprehensive ITS Bases. 3.8.A.1 Indian Point - Unit 2 A-71 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.F 3.3.6 establish any requirements and do not provide any guidance for the application of CTS 3.8.A.1 requirements. T 3.5-4, No.4a A.3 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.6, T 3.5-4, No.4a T 3.3.6-1, No. 1 Function 1, Containment Purge System and Pressure Relief Line Isolation - Automatic Actuation Logic and Actuation Relays.

A.3.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-4, No.4a 3.3.6 LCO 3.3.6, Function 1, Containment Purge System and Pressure Relief Line Isolation - Automatic 3.1.F.1 Actuation Logic and Actuation Relays. 3.8.A.1 A.3.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.6, T 3.5-3 3.3.6 RA-A.1 Function 1, Containment Purge System and Pressure Relief Line Isolation - Automatic Actuation Logic and Actuation Relays.

A.3.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.1.F.1.b.(6) 3.3.6 RA-B.1 train for: ITS 3.3.6, Function 1, Containment Purge System and Pressure Relief Line 3.1.F.1.c Isolation - Automatic Actuation Logic and Actuation Relays.

A.3.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.1.F 3.3.6 RA-B.1 extended loss of redundancy for: ITS 3.3.6, Function 1, Containment Purge System and T 3.5-3, No.4a Pressure Relief Line Isolation - Automatic Actuation Logic and Actuation Relays.

A.3.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No. 26 3.3.6.2 SR 3.3.6, Function 1, Containment Purge System and Pressure Relief Line Isolation - Automatic T 4.1-3, No. 5 3.3.6.3 SR Actuation Logic and Actuation Relays. 3.3.6.5 SR A.3.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: 3.1.F.1 T 3.3.6-1, No. 1 ITS 3.3.6, Function 1, Containment Purge System and Pressure Relief Line Isolation - 3.8.A.1 Automatic Actuation Logic and Actuation Relays. T 3.5-4, No.4a Indian Point - Unit 2 A-72 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.4 Adopts NUREG-1431 presentation and organization of requirements for: ITS 3.3.6, T 4.1-1, No. 19 T 3.3.6-1, No. 2a Function 2.a, Gaseous Containment Radiation Monitor (R-42) and Function 2.b, Particulate T 3.5-4, No.4a T 3.3.6-1, No. 2b Containment Radiation Monitor (R-41).

A.4.A Adopts NUREG-1431 presentation and organization of Applicability requirements for: ITS T 3.5-4, No.4a 3.3.6 3.3.6, Function 2.a, Gaseous Containment Radiation Monitor (R-42) and 3.3.6, Function 2.b, 3.1.F.1 Particulate Containment Radiation Monitor (R-41). 3.8.A.1 A.4.B Adopts NUREG-1431 presentation of requirements for number of channels for: ITS 3.3.6, 3.1.F.1.b.(6) 3.3.6 Function 2.a, Gaseous Containment Radiation Monitor (R-42) and Function 2.b, Particulate T 3.5-4, No.4a Containment Radiation Monitor (R-41).

A.4.C Adopts NUREG-1431 presentation and organization of Required Actions for one inoperable 3.1.F 3.3.6 RA-A.1 channel: ITS 3.3.6, Function 2.a, Gaseous Containment Radiation Monitor (R-42) or T 3.5-4, No.4a Function 2.b, Particulate Containment Radiation Monitor (R-41).

A.4.D Adopts NUREG-1431 presentation and organization of Actions for loss of function or 3.1.F 3.3.6 RA-B.1 extended loss of redundancy for: ITS 3.3.6, Function 2.a, Gaseous Containment Radiation T 3.5-4, No.4a Monitor (R-42) and Function 2.b, Particulate Containment Radiation Monitor (R-41).

A.4.E Adopts NUREG-1431 presentation and organization of Surveillance requirements for: ITS T 4.1-1, No. 19 3.3.6.1 SR 3.3.6, Function 2.a, Gaseous Containment Radiation Monitor (R-42) and Function 2.b, 3.3.6.3 SR Particulate Containment Radiation Monitor (R-41). 3.3.6.6 SR A.4.F Adopts NUREG-1431 presentation and organization of Allowable Values and Setpoints for: T 3.5-4, No.4a T 3.3.6-1, No. 2a ITS 3.3.6, Function 2.a, Gaseous Containment Radiation Monitor (R-42) and Function 2.b, T 3.3.6-1, No. 2b Particulate Containment Radiation Monitor (R-41).

A.5 Adds explicit requirement that ITS LCO 3.3.6, Function 3, Containment Purge System and 3.1.F T 3.3.6-1, No. 3 Pressure Relief Line Isolation - Containment Isolation - Phase A, is a required function that is actuated by ITS LCO 3.3.2, Function 3.a, Containment Isolation - Phase A.

Indian Point - Unit 2 A-73 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.6 Adds explicit requirement that ITS LCO 3.3.6, Function 4, Containment Purge System and 3.1.F T 3.3.6-1, No. 4 Pressure Relief Line Isolation - Containment Spray, is a required function that is actuated by ITS LCO 3.3.2, Function 2, Containment Spray.

A.7 Clarifies that differences between the requirements in CTS 3.5.2, CTS 3.5.3, CTS 3.5.4 and 3.5.2 T 3.3.6-1, No. 3 CTS 3.5.5 and the equivalent ITS requirements are addressed in ITS 3.3.2 because ITS 3.5.3 T 3.3.6-1, No. 4 3.3.6, Table 3.3.6 Function 3, Containment Isolation - Phase A, and Function 4, 3.5.4 Containment Spray, establish requirements for these functions with the statement "Refer to 3.5.5 LCO 3.3.2, 'ESFAS Instrumentation,' for all initiation functions and requirements." T 3.5-2 T 3.5-3 T 3.5-3 ITS SPECIFICATION 3.3.7 - CONTROL ROOM VENTILATION (CRVS)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.3.H 3.3.7 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.4.E comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.3.H 3.3.7 establish any requirements and do not provide any guidance for the application of CTS requirements. 4.4.E A.3 Clarifies the requirement that the control room ventilation system be operable includes the 3.3.H.1 3.3.7 requirement for automatic actuation on each of the following: 1) Manual Initiation, 2) Control 4.4.E.4.b Building air Intake Radiation Monitor; 3) Control Room air Intake Radiation Manager; and 4)

Safety injection signal. These or a high radiation signal based on the CTS surveillance requirement for periodic verification that the control room ventilation system actuates on a safety injection signal or a high radiation signal.

A.4 Clarifies that the requirement that the reactor be brought "to a hot shutdown condition 3.3.H.1 3.3.7 RA-B.1 utilizing normal operating procedures" if requirements for the control room ventilation system are not met is equivalent to the ITS requirement that the reactor be in Mode 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months .

Indian Point - Unit 2 A-74 Section 3.3

Discussion Summary of Change CTS Section ITS Section of Change A.5 Clarifies that the ITS is designed to allow completely separate re-entry into any Condition 3.3.H.1 3.3.7 RA-Note including separate tracking of Completion Times based on this re-entry for CRVS actuation on a high radiation signal and CRVS actuation on an SI signal.

A.6 Adds explicit requirement that LCO 3.3.7, Function 4, Control Room Ventilation System 3.3.H 3.3.7 LCO Instrumentation - Safety Injection (LCO 3.3.2, Function 1) will actuate control room ventilation to the pressurization mode.

Indian Point - Unit 2 A-75 Section 3.3

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.4 - REACTOR COOLANT SYSTEM (RCS)

Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.4.1 - RCS PRESSURE, TEMPERATURE, AND FLOW DEPARTURE FROM NUCLEATE BOILING (DNB) LIMITS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.G 3.4.1 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.G 3.4.1 establish any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 3.4.2 - RCS MINIMUM TEMPERATURE FOR CRITICALITY A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.C 3.4.2 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.2 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Revises description of LCO Applicability from "In no case shall the reactor be made critical" 1.0 1.0 to Mode 1 and Mode 2 with Keff greater than or equal to 1.0. 3.4.2 Indian Point - Unit 2 A-76 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.4.3 - RCS PRESSURE AND TEMPERATURE (P/T) LIMITS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.B 3.4.3 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.3 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1 3.4.3 establish any requirements and do not provide any guidance for the application of CTS 4.3 requirements.

A.3 Adds an explicit statement that reactor coolant system temperature and pressure and 3.1.B 3.4.3 App system heatup and cooldown rate limits are applicable at all times.

ITS SPECIFICATION 3.4.4 - RCS LOOPS - MODES 1 AND 2 A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A 3.4.4 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.4 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies the CTS requirement that reactor coolant pumps (RCPs) must be in operation 3.1.A.1.a 3.4.4 LCO means that RCS loop must be Operable and the RCP must be in operation.

ITS SPECIFICATION 3.4.5 - RCS LOOPS MODE 3 A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A 3.4.5 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

Indian Point - Unit 2 A-77 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.5 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Deletes the statement that Operability requirements for reactor coolant pumps and/or 3.1.A.1.c 3.4.5 residual heat removal pumps are contained in CTS Table 3.1.A-1 because the format and T 3.1.A-1 presentation of the ITS eliminates the need for cross references.

A.4 Revised description of LCO Applicability from "Hot Shutdown Tave > 350°F" to "Mode 3." 3.1.A.2 3.4.5 App T 3.1.A-1 A.5 Deletes statement that the Actions for an RCP not in operation must be initiated if an RCP T 3.1.A-1(1) 3.4.5 LCO pump is not restored to operating status within the one hour allowable out of service time. 1.3 ITS SPECIFICATION 3.4.6 - RCS LOOPS MODE 4 A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A 3.4.6 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.6 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Deletes the statement that Operability requirements for reactor coolant pumps and/or 3.1.A.1.c 3.4.6 residual heat removal pumps are contained in CTS Table 3.1.A-1 because the format and T 3.1.A-1 presentation of the ITS eliminates the need for cross references.

A.4 Revises description of LCO Applicability from Hot Shutdown Tave less than or equal to T 3.1.A-1 3.4.6 App 350°F to "Mode 4."

Indian Point - Unit 2 A-78 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.5 Deletes statement that the Actions for an RCP or RHR pump not in operation must be T 3.1.A-1(2) 3.4.6 initiated if an RCP or RHR pump is not restored to operating status within the one hour 1.3 allowable out of service time.

A.6 Clarifies that the CTS required action for no (RHR or RCP) pumps operable applies to both T 3.1.A-1(2) 3.4.6 RA-B.1 a condition when none of the required RCS or RHR loops are operable (as stated in the 3.4.6 RA-B.2 CTS) and a condition when no RCS or RHR loops are in operation (only implied by the CTS). This change eliminates a potential ambiguity that a loop could be inoperable but the associated pump considered to be in Operation.

ITS SPECIFICATION 3.4.7 - RCS LOOPS MODE 5, LOOPS FILLED A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A 3.4.7 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.7 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Deletes the statement that Operability requirements for reactor coolant pumps and/or 3.1.A.1.c 3.4.7 residual heat removal pumps are contained in CTS Table 3.1.A-1 because the format and T 3.1.A-1 presentation of the ITS eliminates the need for cross references.

A.4 Revised description of LCO Applicability from "Cold Shutdown" to "Mode 5, loops filled" and T 3.1.A-1(3) 3.4.7 APP differentiates between "Mode 5, loops filled" and "Mode 5, loops not filled" which is addressed in ITS 3.4.8.

A.5 Clarifies that the required action when fewer than the required number of pumps are T 3.1.A-1(3) 3.4.7 RA-B.1 operable applies to both a condition when no RHR loops are operable (as sated in the CTS) 3.4.7 RA-B.2 and a condition when no RHR loops are in operation (only implied by the CTS). This change eliminates a potential ambiguity that a pump could be inoperable but considered to be in operation.

Indian Point - Unit 2 A-79 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.6 Adds explicit requirements to immediately initiate action to restore the minimum required T 3.1.A-1(3) 3.4.7 RA-A.1 number of RHR loops to Operable and operating status when minimum required RHR loops 3.4.7 RA-B.1 are not operable and/or not in operation. 3.4.7 RA-C.2 ITS SPECIFICATION 3.4.8 - RCS LOOPS MODE 5, LOOPS NOT FILLED A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A 3.4.8 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.8 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Deletes the statement that Operability requirements for reactor coolant pumps and/or 3.1.A.1.c 3.4.8 residual heat removal pumps are contained in CTS Table 3.1.A-1 because the format and T 3.1.A-1 presentation of the ITS eliminates the need for cross references.

ITS SPECIFICATION 3.4.9 - PRESSURIZER A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.C.4 3.4.9 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.9 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Replaces CTS term "reactor coolant system is above 350°F" with Mode 1, 2 and 3; 1.0 3.4.9 App Replaces CTS term "reactor shall be maintained subcritical by at least 1%" with Mode 1 and 3.1.A.6.a 3.4.9 RA-C.1 2; Replaces the CTS term "hot shutdown condition" with Mode 3; and, Replaces the term 3.1.A.6.b 3.4.9 RA-C.2 "cooled to below 350°F" with Mode 4. 3.1.C.4 Indian Point - Unit 2 A-80 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change ITS SPECIFICATION 3.4.10 - PRESSURIZER SAFETY VALVES A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A.3 3.4.10 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A.3 3.4.10 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies the CTS requirement that all pressurizer code safety valves shall be Operable to 3.1.A.3.b 3.4.10 LCO mean that 3 pressurizer code safety valves shall be Operable.

A.4 Clarifies that the CTS requirement that pressurizer code safety valve lift setting shall be 3.1.A.3.c 3.4.10 LCO "set" at 2485 psig with a plus or minus 1% allowance for error means that pressurizer safety 3.4.10.1 SR valve setpoint limit (i.e., Operability requirement) is a plus or minus 1% of the nominal 2485 psig setpoint. The LCO is that the valves must be reset to plus or minus 1% of the nominal 2485 psig setpoint during the Surveillance to allow for drift during the SR interval.

ITS SPECIFICATION 3.4.11 - PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A.5 3.4.11 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1 3.4.11 establish any requirements and do not provide any guidance for the application of CTS requirements.

Indian Point - Unit 2 A-81 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.3 Replaces CTS terms hot shutdown, cold shutdown, RCS is above 350°F, etc. with the 1.0 1.0 equivalent ITS terms Modes 1, 2, 3, 4 and 5 consistent with the definitions in CTS 1.0 and 3.1.A.5.a 3.4.11 LCO ITS 1.0. 3.1.A.5.b 3.1.A.5.c 3.1.A.5.d 3.16.A 3.16.B 3.16.C A.4 Clarifies that separate Condition entry is allowed for each PORV which in conjunction with 3.1.A.5 3.4.11 RA-Note 1 the ITS Specification 1.3, "Completion Times," provides direction consistent with the intent of the ITS Actions for inoperable PORVs or block valves.

A.5 Superceded by TSFT-359, Revision 9, Increased Flexibility in MODE Restraints. NA NA A.6 Deletes cross references between CTS 3.1.A.5, Power Operated Relief Valves 3.1.A.5.e 3.4.11 (PORVs)/Block Valves, and CTS 3.16, Reactor Coolant System Vents, because ITS 3.16 R.7 reorganizes requirements for PORVs into one location and relocates requirements for reactor head vents to a licensee document controlled in accordance with 10 CFR 50.59.

ITS SPECIFICATION 3.4.12 - Low Temperature Overpressure Protection (LTOP)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.A.4 3.4.12 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.18 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 4.18 3.4.12 establish any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that CTS 3.1.A.4.a and CTS Table 3.1.A-2 requirement that "the OPS" is Operable 3.1.A.4.a 3.4.12.a.1 LCO is a requirement for "two power operated relief valves (PORVs)." T 3.1.A-2 Indian Point - Unit 2 A-82 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.4 Replaces CTS requirement that the OPS is "armed and operable" which is used to convey 3.1.A.4.a 3.4.12.a LCO that the power operated relief valves are configured to function as the Overpressure F 3.4.12-1 Protection System with the ITS requirement that the power operated relief valves (PORVs) with lift settings within the limits specified in the Figure 3.4.12-1.

A.5 Establishes Actions for an inoperable PORV without mentioning the status of the 3.1.A.4.b 3.4.12 RA-C.1 associated block valve because the ITS Bases provide the clarification that the block valve associated with each PORV must be fully open for the PORV to be considered OPERABLE.

A.6 Eliminates CTS requirements for special reports to the NRC that duplicate requirements in 3.1.A.4.c 3.4.12 10 CFR 50.72 and 10 CFR 50.73. 6.9.2 A.7 Superceded by Amendment 225. NA NA A.8 Provides clarification that RCP starting requirements apply to a pump being jogged is T 3.1.A-2 3.4.12.8 SR retained in the Bases for ITS SR 3.4.12.8.

A.9 Superceded by Amendment 224. NA NA ITS SECTION 3.4.13 - RCS OPERATIONAL LEAKAGE A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.F 3.4.13 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.16 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.13 establish any requirements and do not provide any guidance for the application of CTS 4.16 requirements.

Indian Point - Unit 2 A-83 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.3 Replaces CTS terms hot shutdown, cold shutdown, etc. with the equivalent ITS terms 3.1.F.2.a.(1) 3.4.13 App Modes 1, 2, 3, 4 and 5 consistent with the definitions in CTS 1.0 and ITS 1.0. 3.1.F.2.c.(1) 1.0 3.1.F.2.c.(2) 3.1.F.2.c.(3) 1.0 A.4 Establishes the link that the Steam Generator (SG) Tube Surveillance Program in CTS 4.13 4.16 3.4.13.2 SR and maintained by ITS 5.5.7 must be met as a prerequisite for meeting Operability 5.5.8 requirements for RCS Operational leakage.

ITS SPECIFICATION 3.4.14 - RCS PRESSURE ISOLATION VALVE (PIV) LEAKAGE A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.F 3.4.14 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.16 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.14 establish any requirements and do not provide any guidance for the application of CTS 4.16 requirements.

A.3 Adds an explicit statement that RCS/RHR leakage limits do not apply to valves in the 3.1.F.2.b.(1) 3.4.14 App residual heat removal (RHR) flow path when in, or during the transition to or from, the RHR 4.16.A.5 mode of operation.

A.4 Adds statement that separate condition entry is allowed for each pressure isolation valve. 3.1.F.2.b(1) 3.4.14 RA-Note 1 This change is needed to support the a new allowance permitting 4 hours0.167 days 0.0238 weeks 0.00548 months to establish 3.1.F.2.b(2) compensatory action and 72 hours3 days 0.429 weeks 0.0986 months for restoration of double barrier protection for the RCS pressure boundary if limits for RCS/RHR leakage are not met.

Indian Point - Unit 2 A-84 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.5 Adds statement that entry into applicable Conditions and Required Actions for systems 3.1.F.2.b(1) 3.4.14 RA-Note 2 made inoperable by an inoperable PIV or the Action taken in response to an inoperable PIV. 3.0.6 LCO This change is needed to support the a new allowance permitting 4 hours0.167 days 0.0238 weeks 0.00548 months to establish compensatory action and 72 hours3 days 0.429 weeks 0.0986 months for restoration of double barrier protection for the RCS pressure boundary if limits for RCS/RHR leakage are not met.

A.6 Clarifies that CT Frequency of "every refueling" for testing RCS/RHR pressure boundary 4.16.A.5 3.4.14.1 SR leakage means "In accordance with the Inservice Testing Program, and 24 months."

A.7 Deletes explicit statement that RCS/RHR pressure boundary leakage testing shall be 4.16.A.5 3.4.14.1 SR performed prior to returning the valve to service after maintenance, repair or other work is 3.0.1 SR performed because the Bases for SR 3.0.1 include the clarification that upon completion of maintenance, appropriate post maintenance testing is required to declare equipment Operable. This includes ensuring applicable Surveillances are not failed.

ITS SPECIFICATION 3.4.15 - RCS LEAKAGE DETECTION INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.F 3.4.15 ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with 4.16 comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.15 establish any requirements and do not provide any guidance for the application of CTS 4.16 requirements.

A.3 Replaces CTS terms hot shutdown, cold shutdown, etc. with the equivalent ITS terms 3.1.F.1.a 3.4.15 App Modes 1, 2, 3, 4 and 5 consistent with the definitions in CTS 1.0 and ITS 1.0. 3.1.F.1.b 1.0 3.1.F.1.c A.4 Superceded by Amendment 225. NA NA Indian Point - Unit 2 A-85 Section 3.4

Discussion of Summary of Change CTS Section ITS Section Change A.5 Clarifies that the CTS requirement for continuous checks of Containment Iodine Particulate T 4.1-2, No.10 3.4.15 LCO Monitor or Gas Monitor is equivalent to the requirements in CTS 3.1.F and ITS 3.4.15 that T4.1-2, one of these instruments is Operable. Footnote 5 3.1.F.1.a.6 ITS SPECIFICATION 3.4.16 - RCS SPECIFIC ACTIVITY A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 3.1.D 3.4.16 LCO ITS consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not 3.1.A 3.4.16 establish any requirements and do not provide any guidance for the application of CTS requirements.

Indian Point - Unit 2 A-86 Section 3.4

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.5 - EMERGENCY CORE COOLING SYSTEM (ECCS)

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.5.1 - ACCUMULATORS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.A 3.5.1 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.A 3.5.1 LCO any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Replaces CTS term "hot shutdown condition utilizing normal operating procedures" with "Be in 3.3.A.2 3.5.1 RA-C.1 Mode 3" within 6 hours0.25 days 0.0357 weeks 0.00822 months .

A.4 Adds explicit statement that entry into ITS LCO 3.0.3 is required if two or more accumulators 3.0.1 3.0.3 are inoperable.

ITS SPECIFICATION 3.5.2 - ECCS - OPERATING A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.A 3.5.2 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.A 3.5.2 any requirements and do not provide any guidance for the application of CTS requirements. 4.5.A A.3 Replaces CTS term "hot shutdown condition utilizing normal operating procedures" with "Be in 3.3.A.2 3.5.2 RA-B.1 Mode 3" within 6 hours0.25 days 0.0357 weeks 0.00822 months .

Indian Point - Unit 2 A-87 Section 3.5

Discussion Summary of Change CTS Section ITS Section of Change A.4 Adds clarification that either an actual or simulated actuation signal to verify valve actuation and 4.5.A.1.a 3.5.2.4 SR pump start on receipt of a safety injection actuation signal is acceptable. 3.5.2.5 SR A.5 Explains general reorganization of Action requirements in the transition from CTS 3.3.A to ITS 3.3.A.2 3.5.2 RA-A.1 3.5.2.

ITS SPECIFICATION 3.5.3 - ECCS - SHUTDOWN A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.A 3.5.3 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.A 3.5.3 LCO any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 3.5.4 - REFUELING WATER STORAGE TANK (RWST)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.A 3.5.4 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.A 3.5.4 LCO any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Adds a clarification that CTS requirement for RWST low level "alarms" is a requirement for two 3.3.A.1.k 3.5.4 LCO redundant channels as specified in the UFSAR.

A.4 Replaces CTS term "hot shutdown condition utilizing normal operating procedures" with "Be in 3.3.A.2 3.5.4 RA-D.1 Mode 3" within 6 hours0.25 days 0.0357 weeks 0.00822 months .

A.5 Clarifies that RWST low level alarm required by Technical Specifications is the alarm 3.3.A.1.k 3.5.4 LCO associated with control room annunciator "RWST level low-low." 3.3.A.2.f 3.5.4 RA-B.1 Indian Point - Unit 2 A-88 Section 3.5

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.6 - CONTAINMENT SYSTEMS Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.6.1 - CONTAINMENT A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 1.7 3.6.1 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 3.6.A Bases. 4.4.A A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.6 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.4 A.3 Explains that IP2 ITS does not include a definition for "Containment Integrity" because the 1.7 3.6.1 requirements for and descriptions of containment integrity described in CTS 1.7 and CTS 3.6.A 3.6.2 3.6.A.1 are maintained in the ITS LCOs and SRs and the associated Bases. ITS maintains 4.4.A 3.6.3 existing requirements by dividing the containment Operability requirements into five separate 3.6.9 LCOs: 3.6.10 ITS 3.6.1 which requires that the containment is Operable; ITS 3.6.2 which requires that the containment air locks are Operable; ITS 3.6.3 which requires that each containment isolation valve is Operable; ITS LCO 3.6.9 which requires that IVSW is Operable; and ITS 3.6.10 which requires that WC&PPS is Operable.

In conjunction with this change, the CTS definition of Containment Integrity is deleted.

A.4 Revises nomenclature for Applicability from "whenever the reactor is above cold shutdown" to 3.6.A.1 3.6.1 APP "Modes 1, 2, 3 and 4."

A.5 Clarifies that requirement for post maintenance testing that is specific to containment integrity 4.4.E SR 3.0.1 is maintained as ITS SR 3.0.1 for post maintenance testing that applies to all systems and components governed by Technical Specifications.

Indian Point - Unit 2 A-89 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.6.2 - CONTAINMENT AIR LOCKS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 1.7.c 3.6.2 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 1.7.e Bases. 3.6.A 4.4.C 4.4.D 4.4.E 4.4.F A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.6 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.4 A.3 Explains that IP2 ITS does not include a definition for "Containment Integrity" because the 1.7 3.6.2 requirements for and descriptions of containment integrity described in CTS 1.7 and CTS 3.6.A.1 3.6.1 3.6.A.1 are maintained in the ITS LCOs and SRs and the associated Bases. ITS maintains 4.4.A 3.6.3 existing requirements by dividing the containment Operability requirements into five separate 3.6.9 LCOs: 3.6.10 ITS 3.6.1 which requires that the containment is Operable; ITS 3.6.2 which requires that the containment air locks are Operable; ITS 3.6.3 which requires that each containment isolation valve is Operable; ITS 3.6.9 which requires that IVSW is Operable; and ITS 3.6.10 which requires that WC&PPS is Operable.

In conjunction with this change, the CTS definition of Containment Integrity is deleted.

A.4 Revises nomenclature for Applicability from "whenever the reactor is above cold shutdown" to 3.6.A.1 3.6.2 APP "Modes 1, 2, 3 and 4."

A.5 Clarifies that the IP2 plant has two personnel containment air locks. 1.7.c LCO 3.6.2 3.6.A.1.d Indian Point - Unit 2 A-90 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change A.6 Clarifies that the ITS term Operable (i.e., capable of performing its specified safety function) is 1.7.c LCO 3.6.2 a reasonable interpretation of the CTS term properly closed when applied to containment 3.6.A.1.d SR 3.6.2.1 airlocks. 3.6.A.1.f 4.4.C A.7 Clarifies that Conditions and Required Actions of ITS 3.6.1, "Containment," are applicable when 3.6.A.3 3.6.2 ACTION-air lock leakage results in exceeding the overall containment leakage rate. Note 3 A.8 Clarifies that Actions for one inoperable airlock door or inoperable air lock door interlock are not 1.7.c 3.6.2 RA-A.1 applicable if both airlock doors are inoperable because Actions for one inoperable airlock door 3.6.A.3 3.6.2 RA-B.1 or inoperable air lock door interlock may interfere with Actions to promptly restore an airlock door to Operable status.

A.9 Clarifies that one inoperable air lock door does not invalidate the previous successful 1.7.e SR 3.6.2.1 performance of the overall air lock leakage test. 3.6.A.1.f 4.4.C A.10 Clarifies that results of airlock tests must be evaluated against acceptance criteria applicable to 3.6.A.1.f SR 3.6.1.1 SR 3.6.1.1, Containment Leakage Rate Testing Program. 1.7.e SR 3.6.2.1 A.11 Not Used. NA NA A.12 Clarifies that Conditions and Required Actions of ITS 3.6.10, "Weld Channel and Penetration 3.6.A 3.6.2 ACTION-Pressurization System," are applicable when required WC&PPS supply to an air lock is Note 4 inoperable. 3.6.10 Indian Point - Unit 2 A-91 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.6.3 - CONTAINMENT ISOLATION VALVES A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 1.7.a 3.6.3 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 1.7.d Bases. 1.7.e 3.6.A 4.4.D 4.4.F 4.4.G A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.6 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.4 A.3 Explains that IP2 ITS does not include a definition for "Containment Integrity" because the 1.7 3.6.1 requirements for and descriptions of containment integrity described in CTS 1.7 and CTS 3.6.A.1 3.6.3 3.6.A.1 are maintained in the ITS LCOs and SRs and the associated Bases. ITS maintains 4.4.A 3.6.2 existing requirements by dividing the containment Operability requirements into five separate 3.6.9 LCOs: 3.6.10 ITS 3.6.1 which requires that the containment is Operable; ITS 3.6.2 which requires that the containment air locks are Operable; ITS 3.6.3 which requires that each containment isolation valve is Operable; ITS 3.6.9 which requires that IVSW is Operable; and ITS 3.6.10 which requires that WC&PPS is Operable.

In conjunction with this change, the CTS definition of Containment Integrity is deleted.

A.4 Revises nomenclature for Applicability from "whenever the reactor is above cold shutdown" to 3.6.A.1 3.6.3 APP "Modes 1, 2, 3 and 4."

Indian Point - Unit 2 A-92 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change A.5 Explains how format and structure of ITS 3.6.3 eliminates need for clarification statements in 3.6.A.3.a.1 3.6.3 CTS 3.6.A.3.a.1 and CTS 3.6.A.3.a.1, Note 2. CONDITION A 3.6.3 CONDITION B 3.6.3 CONDITION C A.6 Eliminates explicit statement of the option of restoring inoperable containment isolation valves 3.6.A.3.a.2(a) LCO 3.0.2 to operable status when one or more containment isolation valves are inoperable because LCO 3.0.2 specifies that if an LCO is met or is no longer applicable prior to expiration of the specified Completion Times, completion of the Required Actions is not required unless otherwise stated.

A.7 Adds Note that explicitly requires entry into applicable Conditions and Required Actions for 3.6.A LCO 3.0.6 systems made inoperable by containment isolation valves that are closed to satisfy Required 3.6.3 ACTION-Actions. Note 3 A.8 Adds Note that explicitly requires entry into applicable Conditions and Required Actions of LCO 3.6.A 3.6.1 3.6.1, Containment, when isolation valve leakage results in exceeding the overall containment 3.6.3 ACTION-leakage rate acceptance criteria. Note 4 A.9 Maintains CTS requirements by adding Notes that require entry into Conditions for LCO 3.6.9, 3.6.A 3.6.3 ACTION-Isolation Valve Seal Water (IVSW) System, and LCO 3.6.10, Weld Channel & Penetration Note 5 Pressurization System (WC&PPS), versus declaring the affected containment isolation valves 3.6.3 ACTION-inoperable when IVSW or WC&PPS are inoperable. Note 6 3.6.9 3.6.10 A.10 Superceded by Amendment 225. NA NA A.11 Not Used. NA NA Indian Point - Unit 2 A-93 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change A.12 Adds an explicit statement that separate Condition entry is allowed for each penetration flow 3.6.A.3 3.6.3 ACTION-path which maintains the existing allowance. 3.6.A.3.a Note 2 A.13 Clarifies that requirement for post maintenance testing that is specific to containment integrity 4.4.E SR 3.0.1 is maintained as ITS SR 3.0.1 for post maintenance testing that applies to all systems and components governed by Technical Specifications.

A.14 Clarifies that the information provided by Footnote 3 to CTS 3.6.A.1.b and CTS 3.6.A.1.c 3.6.A.1.b 3.6.3 RA-A.1 provides options that are equivalent to the options provided by ITS LCO 3.6.3, Required 3.6.A.1.c 3.6.3 RA-B.1 Actions A.1, B.1 and C.1 which include use of both the inboard and outboard containment 3.6.3 RA-C.1 isolation valve.

A.15 Clarifies that the existing requirement that the "leakage rate into containment for the isolation 4.4.D.1 SR 3.6.3.8 valves sealed with the service water system shall not exceed 0.36 gpm per fan cooler" is 4.4.D.2.b 5.5.14.e maintained as SR 3.6.3.8 with the acceptance criteria maintained in ITS 5.5.14.e.

ITS SPECIFICATION 3.6.4 - CONTAINMENT PRESSURE A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.6.B 3.6.4 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.6 NA any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that the CTS Surveillance Frequency of at least twice per calendar day is equivalent 3.6.B SR 3.6.4.1 to an ITS Frequency of once per 12 hours0.5 days 0.0714 weeks 0.0164 months . T 4.1-1, No.18b T 1-1 Indian Point - Unit 2 A-94 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.6.5 - CONTAINMENT AIR TEMPERATURE A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.6.C 3.6.5 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.6 NA any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Replaces CTS term "above the cold shutdown condition" with the equivalent ITS term Modes 3.6.C 3.6.5 APP 1, 2, 3, and 4 consistent with the definitions in CTS 1.0 and ITS 1.0.

ITS SPECIFICATION 3.6.6 - CONTAINMENT SPRAY SYSTEM AND CONTAINMENT FAN COOLER (CFU) SYSTEM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.B 3.6.6 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.5.B Bases. 4.5.D A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.5 4.5 A.3 Uses the term "train" to describe the combination of a containment spray pump and its 3.3.B.1.b LCO 3.6.6 associated valves and piping or one or more fan cooler units powered from the same safeguards power train and their associated valves and piping.

A.4 Adds explicit statement that entry into ITS LCO 3.0.3 is required if the combination of 3.0.1 LCO 3.0.3 inoperable fan cooler units (i.e., containment fan cooler trains) and/or inoperable containment 3.3.B 3.6.6 RA-F.1 spray trains result in less than the minimum functional capability assumed in the accident analysis.

Indian Point - Unit 2 A-95 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change A.5 Deletes a one time extension to selected SR Frequencies that expires with the refueling outage 4.5.B.1 NA scheduled to start June 3, 2000. 4.5.D.4.b T 1-1 A.6 Not Used. NA NA A.7 Superceded by Amendment 211. NA NA A.8 Clarifies that CTS Frequency of "once every refueling interval (#)" is equivalent to once every 4.5.D.2 SR 3.6.6.9 24 months as specified in CTS Table 1-1.

ITS SPECIFICATION 3.6.7 - RECIRCULATION PH CONTROL SYSTEM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.B 3.6.7 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.5.H Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.5 A.3 Adopts NUREG-1431 presentation for Surveillance Frequency of 24 months versus CTS use of 4.5.H.1 SR 3.6.7.1 each refueling interval (R#) with reference to CTS Table 1.1. T 1-1 ITS SPECIFICATION 3.6.8 - HYDROGEN RECOMBINERS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.G 3.6.8 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.5.C Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.5 A.3 Not Used. NA NA Indian Point - Unit 2 A-96 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change A.4 Adopts NUREG-1431 presentation for Surveillance Frequency of 24 months versus CTS use of 4.5.C.1 SR 3.6.8.1 each refueling interval (R#) with reference to CTS Table 1.1. 4.5.C.2 SR 3.6.8.2 T 1-1 ITS SPECIFICATION 3.6.9 - ISOLATION VALVE SEAL WATER (IVSW) SYSTEM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.C 3.6.9 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.4.D Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3 NA any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Revises nomenclature for Applicability from "whenever the reactor is above cold shutdown" to 3.3.C.1 3.6.9 APP "Modes 1, 2, 3 and 4."

A.4 Deletes CTS Statement that the shutdown shall start no later than the end of the specified 3.3.C.2 1.3 period because the requirement being deleted is maintained by ITS 1.3, Completion Times. 3.3.C.3.a A.5 Not Used. NA NA A.6 Clarifies that adopting the presentation "one IVSW automatic actuation valve inoperable" 3.3.C.2.b 3.6.9 RA-A.1 eliminates the need for the CTS clarification that the condition applies only if "all valves in the system that provide a duplicate function are operable."

ITS SPECIFICATION 3.6.10 - WELD CHANNEL AND PENETRATION PRESSURIZATION SYSTEM (WC&PPS)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.D 3.6.10 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.4.B Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3 NA any requirements and do not provide any guidance for the application of CTS requirements. 4.4 Indian Point - Unit 2 A-97 Section 3.6

Discussion Summary of Change CTS Section ITS Section of Change A.3 Adds explicit statement that WC&PPS shall be Operable. 3.3.D.1 LCO 3.6.10 A.4 Revises nomenclature for Applicability from "whenever the reactor is above cold shutdown" to 3.3.D.1 3.6.10 APP "Modes 1, 2, 3 and 4." T 1-1 A.5 Deletes CTS Statement that the shutdown shall start no later than the end of the specified 3.3.D.3.a 1.3 period because the requirement being deleted is maintained by ITS 1.3, Completion Times. 3.3.D.2 A.6 Adds clarification that directs entry into the applicable Conditions and Required Actions of LCO 3.3.D 3.6.10 3.6.1 if it is determined that WC&PPS inoperability is indicative of or results in exceeding the ACTIONS-Note 2 overall containment leakage rate. Clarification is needed to provide an exception to ITS LCO 3.0.6.

A.7 Clarifies that small variations in containment pressure during the performance of this test do 4.4.B.1 SR 3.6.10.3 not invalidate test results as long as WC&PPS pressure is maintained greater than or equal to 52 psi above containment pressure.

A.8 Clarifies that the CTS term WC&PPS inoperable refers to a WC&PPS zone with one or more of 3.3.D.1.a 3.6.10 RA-A.1 the individual components supported by WC&PPS not at the specified minimum pressure. 3.3.D.1.b 3.6.10 RA-A.2 3.3.D.2.a 3.3.D.2.b A.9 Deletes a one time extension to selected SR Frequencies that expires with the refueling outage 4.4.B.3 NA scheduled to start June 3, 2000. T 1-1 Indian Point - Unit 2 A-98 Section 3.6

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.7 - PLANT SYSTEMS Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.7.1 - MAIN STEAM SAFETY VALVES (MSSVs)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.4 3.7.1 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.4 3.7.1 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Revises nomenclature for Applicability from "reactor shall not be heated above 350°F unless " 3.4.A 3.7.1 to "Modes 1, 2 and 3."

A.4 Eliminates explicit statement of option of restoring inoperable MSSVs to operable status when 3.4.A.1 3.7.1 LCO one or more MSSVs are inoperable because LCO 3.0.2 specifies that if an LCO is met or is no 3.0.2 LCO longer applicable prior to expiration of the specified Completion Times, completion of the Required Action is not required unless otherwise stated.

A.5 Eliminates CTS statement that heat-up above 350°F and power operation is permissible with 3.4.A.1 3.0.4 LCO up to three of the five main steam line safety valves per steam generator inoperable provided T 3.4-1 3.7.1 RA-A.1 that the Actions for one or more inoperable MSSVs are met because it duplicates allowance in 3.7.1 RA-B.1 ITS LCO 3.0.4. 3.7.1 RA-B.2 3.7.1 RA-C.1 3.7.1 RA-C.2 A.6 Reformats CTS requirement for a minimum ASME code-approved steam-relieving capability of 3.4.A.1 3.7.1 LCO twenty (20) main steam valves to ITS LCO 3.7.1, Table 3.7.1-2, that lists each of the 20 MSSVs T 3.7.1-2 by valve number.

Indian Point - Unit 2 A-99 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change A.7 Adds an explicit statement that Separate Condition entry is allowed for each inoperable MSSV 3.4.A.1 3.7.1 RA-NOTE because complying with the Required Actions for one inoperable MSSV will allow continued operation, and subsequent inoperable MSSVs are governed by separate Condition entry and application of associated Required Actions.

A.8 Eliminates generic statement that system piping and valves directly associated with the MSSVs 3.4.A.4 3.7.1 must be operable when the MSSVs are Operable because system piping and valves directly associated with the MSSVs fall within the ITS definition of Operability.

A.9 Clarifies that a reduction in Power Range Neutron Flux Trip Setpoint whenever more than one 3.4.A.1 3.7.1 RA-B.2 MSSV in one or more SGs is inoperable is not required in Modes 2 and 3 because the P-10 interlock, which is required to be Operable by ITS LCO 3.3.1, will automatically reduce the Power Range Neutron Flux Trip Setpoint to a value lower than any required by ITS Table 3.7.1-1 before reactor power is reduced below approximately 10% (i.e., before entering Mode 2 from Mode 1).

ITS SPECIFICATION 3.7.2 - MAIN STEAM ISOLATION VALVES (MSIVs) AND MAIN STEAM CHECK VALVES (MSCVs)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.4 3.7.2 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.7 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.4 3.7.2 any requirements and do not provide any guidance for the application of CTS requirements. 4.7 ITS SPECIFICATION 3.7.3 - MAIN FEEDWATER ISOLATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.5 3.7.3 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.5 3.7.3 any requirements and do not provide any guidance for the application of CTS requirements.

Indian Point - Unit 2 A-100 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change A.3 Clarifies that the feedwater isolation function (i.e., valve closure and main feed pump trip) is an 3.5.1 3.7.3 implied requirement because the feedwater isolation actuation instrumentation is included in T 3.5-4, No. 3 CTS.

ITS SPECIFICATION 3.7.4 - ATMOSPHERIC DUMP VALVES (ADVs)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.4 3.7.4 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.8 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.4 3.7.4 any requirements and do not provide any guidance for the application of CTS requirements. 4.8 ITS SPECIFICATION 3.7.5 - AUXILIARY FEEDWATER (AFW) SYSTEM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.4 3.7.5 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.4 3.7.5 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Eliminates statement that system piping and valves directly associated with the AFW pump 3.4.A.2 3.7.5 LCO must be operable when the AFW is Operable because system piping and valves directly 3.4.A.4 associated with the AFW pump falls within the ITS definition of Operability for Auxiliary Feedwater.

A.4 Clarifies intent of CTS requirement when 3 AFW pumps are inoperable is equivalent to ITS 3.4.B.1.c 3.7.5 RA-D.1 allowance that LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are 3.4.C.1 suspended until one AFW train is restored to OPERABLE status.

A.5 Specifies that reportable events will be addressed in accordance with 10 CFR 50.72 and 10 3.4.C.3 3.7.5 LCO CFR 50.73 and reporting requirements will not be included in the ITS.

Indian Point - Unit 2 A-101 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change A.6 Clarifies that if 3 AFW pumps are inoperable then both CTS and ITS require immediate 3.4.C.2 3.7.5 RA-D.1 initiation of action to restore an AFW pump to Operable and that these actions continue until successful.

A.7 Deletes generic statement that AFW tests shall be considered satisfactory if control board 4.8.B 3.7.5 indication and subsequent visual observation of the equipment demonstrate that all components have operated properly.

ITS SPECIFICATION 3.7.6 - CONDENSATE STORAGE TANK (CST)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.4 3.7.6 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.4 3.7.6 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Eliminates generic statement that system piping and valves directly associated with the CST 3.4.A.4 3.7.6 must be operable when the CST is Operable because system piping and valves directly 3.7.5 associated with the CST falls within the ITS definition of Operability for CST and Auxiliary Feedwater.

ITS SPECIFICATION 3.7.7 - COMPONENT COOLING WATER (CCW) SYSTEM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.E 3.7.7 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.E 3.7.7 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies the requirement that the reactor shall be placed in the hot shutdown condition (i.e., 3.3.E.2 3.7.7 RA-B.1 Mode 3) utilizing normal operating procedures is met if the reactor is in Mode 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months .

Indian Point - Unit 2 A-102 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change A.4 Clarifies that ITS is designed to ensure that operators are not required to make a determination 3.3.E.2.d 3.7.7 that "the system may still operate at design accident capability."

A.5 Maintains CTS requirement by adding Note taking exception to new allowance provided by ITS 3.3.E 3.7.7 RA-A.1 LCO 3.0.6 which would otherwise allow taking Required Actions for an inoperable CCW train 3.1.A.1.c only when an inoperable CCW train caused an RHR train to be inoperable.

A.6 Clarifies that the isolation of CCW to components or systems may render those components 3.3.E 3.7.7.1 SR inoperable, but does not affect the Operability of the CCW System.

ITS SPECIFICATION 3.7.8 - SERVICE WATER (SW) SYSTEM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.F 3.7.8 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.F 3.7.8 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that the isolation of the components or systems cooled by service water may render 3.3.F 3.7.8.1 SR those components inoperable but does not affect the Operability of the SWS.

A.4 Clarifies that inoperability of "associated piping and valves" that prevents one SW pump from 3.3.F.1 3.7.8 RA-A.1 performing its safety function results in only that SW pump being inoperable and inoperability of 3.3.F.2 3.7.8 RA-B.1 "associated piping and valves" that prevents either the essential or non essential header from 3.7.8.1 SR performing its safety function results in a loss of safety function which requires immediate plant shutdown.

ITS SPECIFICATION 3.7.9 - ULTIMATE HEAT SINK (UHS)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3.F 3.7.9 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

Indian Point - Unit 2 A-103 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3.F 3.7.9 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Deletes statement that CTS Specification 3.0.1 do not apply to service water inlet temperature 3.3.F.4.c 3.7.9 in conjunction with expanding the requirements for UHS availability to include Mode 4. 3.3.F.1.a 3.3.F.2.a ITS SPECIFICATION 3.7.10 - CONTROL ROOM VENTILATION SYSTEM (CRVS)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.3 3.7.10 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 3.5 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.3 3.7.10 any requirements and do not provide any guidance for the application of CTS requirements. 3.5 A.3 Requires that the reactor be in Mode 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months (versus shutdown using normal operating 3.3.H.1 3.7.10 RA-C.1 procedures) if the requirements for the control room ventilation system are not met within the specified completion time.

A.4 Adds clarification that the "control room boundary may be opened intermittently under 3.3.H.1 3.7.10 administrative control" such as normal ingress and egress or minor maintenance when there is a method to rapidly close the opening when a need for control room isolation is indicated.

A.5 Superceded by Amendment 225. NA NA ITS SPECIFICATION 3.7.11 - SPENT FUEL PIT WATER LEVEL A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8.C.2 3.7.11 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Not Used. NA NA Indian Point - Unit 2 A-104 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.7.12 - SPENT FUEL PIT BORON CONCENTRATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8.A 3.7.12 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Not Used. NA NA A.3 Clarifies that requirements for spent fuel pit boron concentration apply only when fuel 3.8.D 3.7.12 App assemblies are stored in the spent fuel pit. 3.8.D.3 ITS SPECIFICATION 3.7.13 - SPENT FUEL PIT STORAGE A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8.D.1 3.7.13 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Not Used NA NA A.3 Adds explicit requirement to verify that requirements for fuel assembly storage locations will be 3.8.D.1 3.7.13.1 SR met before a fuel assembly is inserted in the spent fuel pit.

A.4 Not used. NA NA ITS SPECIFICATION 3.7.14 - SECONDARY SPECIFIC ACTIVITY A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.4.A.6 3.7.14 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.4.A 3.7.14 any requirements and do not provide any guidance for the application of CTS requirements.

Indian Point - Unit 2 A-105 Section 3.7

Discussion Summary of Change CTS Section ITS Section of Change A.3 Restates requirements for steam generator secondary side activity levels for Dose Equivalent 3.4.A.6 3.7.14 I-131 in units of micro curies per 'gram' instead of micro curies per 'cubic centimeter.'

Indian Point - Unit 2 A-106 Section 3.7

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.8 - ELECTRICAL POWER SYSTEMS Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.8.1 - AC SOURCES - OPERATING A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.1 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.6 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.1 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 A.3 Superceded by Amendment 236. NA NA A.4 Superceded by Amendment 225. NA NA A.5 Explains how having only one 138 kV line from an offsite source to Buchanan Substation or 3.7.B.2 3.8.1 RA-A.1 having neither of the two 138/13.8 kV transformers is equivalent to the ITS Condition of having 3.8.1 RA-A.2 one offsite circuit inoperable. 3.8.1 RA-A.3 3.8.1 RA-A.4 A.6 Adds an explicit statement that planned DG starts may be preceded by a prelube period 4.6.A.1 3.8.1.2 SR consistent with the recommendations in Generic Letter 84-15 and current industry practice. 3.8.1.12 SR A.7 Adds explicit statements for the DG endurance run that DG loadings may include gradual 4.6.A.1 3.8.1.3 SR loading as recommended by the manufacturer, momentary transients outside the load range do not invalidate this test, the SR shall be conducted on only one DG at a time and SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 (DG fast start test).

Indian Point - Unit 2 A-107 Section 3.8

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.8.2 - AC SOURCES - SHUTDOWN A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.2 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.6 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.2 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 ITS SPECIFICATION 3.8.3 - DIESEL FUEL OIL AND STARTING AIR A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.3 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.3 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 A.3 Clarifies that Applicability for fuel oil and starting air requirements for DGs must match the 3.7.A 3.8.3 APP Applicability requirements for the DGs being supported.

A.4 Adds an explicit statement that Separate Condition entry is allowed for each DG with an 3.7.A 1.3 inoperable support system.

3.8.3 RA-Note 3.8.3 RA-B.1 A.5 Restates the minimum requirements for DG fuel oil in terms of 'usable' gallons rather than total 3.7.A.5 3.8.3 RA-A.1 volume in the tank. 4.6.B 3.8.3.2 SR Indian Point - Unit 2 A-108 Section 3.8

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.8.4 - DC SOURCES - OPERATING A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.4 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.6 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.4 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 A.3 Superceded by Amendment 225. NA NA A.4 Eliminates explicit requirement that SR data is recorded. 4.6.C.1 3.8.4.1 SR A.5 Clarifies that completion of a battery performance test or modified performance test in 4.6.C.4 3.8.4.3 SR accordance with ITS LCO 3.8.6 satisfies the requirements for the battery service test. 3.8.4.6 SR ITS SPECIFICATION 3.8.5 - DC SOURCES - SHUTDOWN A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.5 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.6 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.5 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 ITS SPECIFICATION 3.8.6 - BATTERY PARAMETERS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.6 3.8.6 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.6 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 Indian Point - Unit 2 A-109 Section 3.8

Discussion Summary of Change CTS Section ITS Section of Change A.3 Deletes statement that surveillance test data must be recorded. 4.6.C.1 3.8.6.2 SR 3.8.6.4 SR ITS SPECIFICATION 3.8.7 - INVERTERS - OPERATING A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.7 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.7 any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 3.8.8 - INVERTERS - SHUTDOWN A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.8 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.8 any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 3.8.9 - DISTRIBUTION SYSTEMS - OPERATING A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.9 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.6 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.9 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 Indian Point - Unit 2 A-110 Section 3.8

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.8.10 - DISTRIBUTION SYSTEMS - SHUTDOWN A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.7 3.8.10 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 4.6 Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.7 3.8.10 any requirements and do not provide any guidance for the application of CTS requirements. 4.6 Indian Point - Unit 2 A-111 Section 3.8

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 3.9 - REFUELING OPERATIONS Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.9.1 - BORON CONCENTRATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8 3.9.1 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.8 3.9.1 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that in both CTS 3.8 and ITS 3.9 requirements that apply "when fuel is in the reactor 3.8.A 3.9.1 vessel and the reactor vessel head bolts are less than fully tensioned" (i.e. Mode 6) also apply 3.8.B.1 when "loading and unloading fuel from the reactor" (i.e., during core alterations).

A.4 Clarifies that ITS definition of CORE ALTERATION in ITS 1.0 and the ITS LCO 3.9.1 Bases 3.8.B.12 1.0 maintains the CTS stipulation that "Suspension of CORE ALTERATIONS shall not preclude 3.9.1 RA-A.1 completion of movement of a component to a safe position."

A.5 Maintains the existing clarification that CTS 3.0.1 and the equivalent requirements in ITS LCO 3.0.1 3.0.3 LCO 3.0.3 are not applicable during refueling operations (i.e. Mode 6). 3.8.E ITS SPECIFICATION 3.9.2 - NUCLEAR INSTRUMENTATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8 3.9.2 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

Indian Point - Unit 2 A-112 Section 3.9

Discussion Summary of Change CTS Section ITS Section of Change A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.8 3.9.2 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that the CTS Applicability statement "when fuel is in the reactor vessel and the reactor 3.8.A 3.9.2 vessel head bolts are less than fully tensioned" is equivalent to the ITS Mode 6. T 1.1-1 A.4 Adds an explicit requirement to immediately "Initiate action to restore one source range neutron 3.8.A.2 3.9.2 RA-B.1 flux monitor to OPERABLE status" if neither of the required SRMs is Operable in Mode 6. 3.9.1.1 SR A.5 Clarifies that the CTS requirement for audible indication for the source range monitor in Mode 3.8.A.2 3.9.2 LCO 6 is satisfied by audible count rate indication (versus an alarm) which is consistent with UFSAR 14.1.5.2.

A.6 Maintains the existing clarification that CTS 3.0.1 and the equivalent requirements in ITS LCO 3.0.1 3.0.3 3.0.3 are not applicable during refueling operations (i.e. Mode 6). 3.8.E ITS SPECIFICATION 3.9.3 - CONTAINMENT PENETRATIONS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8.A 3.9.3 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS 3.8.B Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.8.A 3.9.3 any requirements and do not provide any guidance for the application of CTS requirements. 3.8.B A.3 Clarifies that in both CTS 3.8 and ITS 3.9 requirements that apply "when fuel is in the reactor 3.8.A 3.9.3 vessel and the reactor vessel head bolts are less than fully tensioned" (i.e. Mode 6) also apply 3.8.B.1 when "loading and unloading fuel from the reactor" (i.e., during core alterations).

A.4 Clarifies that ITS definition of CORE ALTERATION in ITS 1.0 and the ITS LCO 3.9.3 Bases 3.8.B.12 3.9.1 RA-A.1 maintains the CTS stipulation that "Suspension of CORE ALTERATIONS shall not preclude 3.9.3 RA-A.1 completion of movement of a component to a safe position."

Indian Point - Unit 2 A-113 Section 3.9

Discussion Summary of Change CTS Section ITS Section of Change A.5 Clarifies that ITS LCO 3.9.3 maintains the existing clarification in CTS 3.8.E that CTS 3.0.1 and 3.8.E 3.0.3 the equivalent requirements in ITS LCO 3.0.3 are not applicable to LCOs that apply during 3.0.1 3.9.3 refueling operations (i.e. Mode 6).

A.6 Clarifies that the CTS requirement for a properly installed "closure plate that restricts direct air 3.8.B.8 3.9.3.a flow from the containment" to establish containment closure during refueling operations is maintained in ITS as "the equipment hatch opening is closed using an equipment hatch closure plate that may include a personnel access door."

ITS SPECIFICATION 3.9.4 - RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8 3.9.4 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.8 3.9.4 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that the CTS Applicability statement "when fuel is in the reactor vessel and the reactor 3.8.A 3.9.4 APP vessel head bolts are less than fully tensioned" is equivalent to the ITS Mode 6. 3.8.A.3 A.4 Clarifies that the term "loop" describes an RHR pump and an associated heat exchanger. 3.8.A.3 3.9.4 LCO A.5 Maintains the existing clarification that CTS 3.0.1 and the equivalent requirements in ITS LCO 3.0.1 3.0.3 LCO 3.0.3 are not applicable during refueling operations (i.e. Mode 6). 3.8.E A.6 Clarifies that ITS definition of CORE ALTERATION in ITS 1.0 and the ITS LCO 3.9.4 Bases 3.8.B.12 3.9.4 RA-A.2 maintains the CTS stipulation that "Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position."

Indian Point - Unit 2 A-114 Section 3.9

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 3.9.5 - RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8 3.9.5 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.8 3.9.5 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Clarifies that the CTS Applicability statement "when fuel is in the reactor vessel and the reactor 3.8.A 3.9.5 APP vessel head bolts are less than fully tensioned" is equivalent to the ITS Mode 6. 3.8.A.4 A.4 Clarifies that the term "loop" describes an RHR pump and an associated heat exchanger. 3.8.A.4 3.9.5 LCO A.5 Adds explicit statement that increasing RPV water level to greater than or equal to 23 feet 3.8.A.3 3.9.5 RA-A.1 above the RPV flange is an option when the requirement for redundant RHR loops (i.e., one 3.8.A.5 3.9.5 RA-A.2 loop in operation and one available for operation) is not met (i.e., one loop in operation but no 3.0.1 backup available) because this water level eliminates LCO requirements for a backup RHR loop that is Operable but not in operation.

A.6 Maintains the existing clarification that CTS 3.0.1 and the equivalent requirements in ITS LCO 3.0.1 3.0.3 LCO 3.0.3 are not applicable during refueling operations (i.e. Mode 6). 3.8.E ITS SPECIFICATION 3.9.6 - REFUELING CAVITY WATER LEVEL A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.8.B 3.9.6 consistent with NUREG-1431. CTS Bases are deleted and replaced with comprehensive ITS Bases.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.8.B 3.9.6 any requirements and do not provide any guidance for the application of CTS requirements.

Indian Point - Unit 2 A-115 Section 3.9

Discussion Summary of Change CTS Section ITS Section of Change A.3 Clarifies that CTS requirements for minimum water level above the top of the reactor pressure 3.8.B 3.9.6 vessel flange applies only "During movement of irradiated fuel assemblies within containment." 3.8.B.11 A.4 Clarifies that in both CTS 3.8 and ITS 3.9 requirements that apply "when fuel is in the reactor 3.8.B 3.9.6 vessel and the reactor vessel head bolts are less than fully tensioned" (i.e. Mode 6) also apply 3.8.B.1 when "loading and unloading fuel from the reactor" (i.e., during core alterations). 3.8.A A.5 Clarifies that ITS 1.0 Definition, CORE ALTERATION, and the ITS LCO 3.9.6 Bases maintains 3.8.B.12 3.9.6 RA-A.1 the CTS stipulation that "Suspension of CORE ALTERATIONS shall not preclude completion of 1.0 movement of a component to a safe position."

A.6 Maintains the existing clarification that CTS 3.0.1 and the equivalent requirements in ITS LCO 3.0.1 3.0.3 3.0.3 are not applicable during refueling operations (i.e. Mode 6). 3.8.E 3.9.6 Indian Point - Unit 2 A-116 Section 3.9

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 4.0 - DESIGN FEATURES Discussion Summary of Change CTS Section ITS Section of Change A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 5.0 4.0 consistent with NUREG-1431.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 5.0 4.0 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Adds a text description of the site location that is consistent with existing description in the 5.1.A 4.1 UFSAR.

A.4 Eliminates cross reference between CTS 5.3.A.3 and CTS 5.4. 5.3.A.3 4.0 5.4 Indian Point - Unit 2 A-117 Section 4.0

TABLE A - ADMINISTRATIVE CHANGES TO THE CTS ITS SECTION 5.0 - ADMINISTRATIVE CONTROLS Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 5.1 - RESPONSIBILITY A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 6.1 5.1 consistent with NUREG-1431.

ITS SPECIFICATION 5.2 - ORGANIZATION A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 6.2 5.2 consistent with NUREG-1431. 6.3 A.2 Substitutes 10 CFR 50.54 (m)(2)(iii) for CTS requirements for two licensed operators in the 6.2.2.c 5.2 control room during reactor startup, scheduled reactor shutdown and during recovery from reactor trips because these requirements are less restrictive than those imposed by 10 CFR 50.54 (m)(2)(iii).

A.3 Clarifies that the minimum qualifications for the Watch Engineer (i.e., Shift Technical Advisor) 6.3.3 5.2.2.f required by CTS are consistent with the (NRC) Commission Policy Statement on Engineering T 6.2-1 Expertise on Shift.

A.4 Superceded by CTS Amendment 231. NA NA A.5 Superceded by CTS Amendment 231. NA NA ITS SPECIFICATION 5.3 - UNIT STAFF QUALIFICATIONS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 6.3 5.3 consistent with NUREG-1431.

Indian Point - Unit 2 A-118 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change A.2 Clarifies that the plant manager is a member of the unit staff and is covered by the requirement 6.3.1 5.3.1 that each member of the facility staff shall meet or exceed the minimum qualifications of ANSI 6.3.2 N18.1-1971 for comparable positions.

A.3 ITS 5.3.2 is added to clarify that a licensed Senior Reactor Operator (SRO) and a licensed 6.3 5.3.1 reactor operator (RO) are those individuals who, in addition to meeting the requirements of ITS 5.3.2 5.3.1, perform the functions described in 10 CFR 50.54(m).

A.4 Clarifies that the operations manager shall meet or exceed the minimum qualifications of ANSI 6.2.2.h 5.2.2.e N18.1-1971 except for the SRO license requirement which shall be in accordance with 6.3.1 5.3.1 Technical Specification 5.2.2.e. ITS 5.2.2.e requires that either the operations manager or assistant operations manager shall hold an SRO license.

ITS SPECIFICATION 5.4 - PROCEDURES A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 6.8 5.4 consistent with NUREG-1431.

A.2 Deletes statement that the quality assurance program described or referenced in the Updated 6.8.3 5.4 FSAR shall describe the mechanism for making temporary procedure changes.

A.3 Clarifies that CTS requirements for written procedures for Process Control Program 6.8.1.b 5.4.1.e implementation and the Offsite Dose Calculation Manual implementation are included in the 6.8.1.c ITS 5.4.1.e requirement that written procedures must be established, implemented, and maintained for all programs required by ITS 5.5.

ITS SPECIFICATION 5.5 - PROGRAMS AND MANUALS ITS SPECIFICATION 5.5.1 - OFFSITE DOSE CALCULATION MANUAL (ODCM)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 6.15 5.5.1 consistent with NUREG-1431.

Indian Point - Unit 2 A-119 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change A.2 Deletes statement that ODCM shall be approved by the Commission prior to implementation 6.15.1 5.5.1 because the IP2 ODCM has already been approved by the Commission and has been 6.15.2 implemented.

A.3 Eliminates explicit requirement that "documentation of the fact the change (to the ODCM) has 5.15.2.C 5.5.1 been revised and found acceptable by the SNSC" must be included when changes to the ODCM are submitted to the NRC in the annual Radioactive Effluents Release Report.

ITS SPECIFICATION 5.5.2 - PRIMARY COOLANT SOURCES OUTSIDE CONTAINMENT A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.4.H 5.5.2 consistent with NUREG-1431. Lic 2.L A.2 Clarifies requirements for the program to reduce leakage from systems outside containment Lic 2.L 5.5.2 that would or could contain highly radioactive fluids during a serious transient or accident by including a list of the systems covered by the program.

A.3 Deletes a one time extension to selected SR Frequencies that expires with the refueling outage Lic 2.L 5.5.2.b scheduled to start June 3, 2000. T 1.1 A.4 Adds an explicit statement that allowances of ITS 3.0.2 (i.e., allowance for 25% extension to 4.0.1 5.5.2 the SR Frequency) is applicable to testing required by ITS 5.5.2, Primary Coolant Sources 4.0.2 3.0.2 SR Outside Containment. This maintains existing allowances in CTS 4.0.1 and CTS 4.0.2. 4.4.H Lic 2.L A.5 Clarifies that acceptance criteria in CTS 4.4.H.2 that leakage from Residual Heat Removal 4.4.H.2 5.5.2 System components outside containment is less than 2 gallons per hour is not necessary because CTS 4.4.H is a subset of the newer requirements imposed by Facility Operating License DPR-26, paragraph 2.L, which limits leakage from all plant systems outside containment likely to contain radioactive material outside containment is less than 2 gallons per hour.

Indian Point - Unit 2 A-120 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 5.5.3 - RADIOACTIVE EFFLUENT CONTROLS PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.9 5.5.3 consistent with NUREG-1431. 4.10 A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 3.9 5.5.4 any requirements and do not provide any guidance for the application of CTS requirements. 4.10 A.3 Adds an explicit statement that allowances of ITS 3.0.2 (i.e., allowance for 25% extension to 4.0.1 5.5.3 the SR Frequency) and ITS SR 3.0.3 (i.e., 24 hours1 days 0.143 weeks 0.0329 months to perform missed SR) are applicable to 4.0.2 3.0.2 SR ITS 5.5.3, Radioactive Effluent Controls Program. This maintains existing allowances in CTS 4.10 3.0.3 SR 4.0.1 and CTS 4.0.2. 5.5.10 ITS SPECIFICATION 5.5.4 - COMPONENT CYCLIC OR TRANSIENT LIMIT NONE ITS SPECIFICATION 5.5.5 - REACTOR COOLANT PUMP FLYWHEEL INSPECTION PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.2.3 5.5.5 consistent with NUREG-1431. T4.2-1 A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 4.2.3 5.5.5 any requirements and do not provide any guidance for the application of CTS requirements. T 4.2-1 A.3 Clarifies requirement that "flywheels shall be visually inspected at the first refueling" was 4.2.3 5.5.5 completed during the first refueling and is no longer applicable. T 4.2-1 A.4 Clarifies that the requirement that "one different flywheel shall be examined" each refueling 4.2.3 5.5.5 means that "the inspection frequency will ensure that each reactor coolant pump flywheel has T 4.2-1 been inspected during one of the four most recent refueling outages."

Indian Point - Unit 2 A-121 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change ITS SPECIFICATION 5.5.6 - INSERVICE TESTING PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.1 5.5.6 consistent with NUREG-1431. 4.2 A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 4.1 5.5.6 any requirements and do not provide any guidance for the application of CTS requirements. 4.2 A.3 Eliminates CTS requirements to perform Inservice testing in accordance with Section XI of the 4.2.1 5.5.6 ASME Boiler and Pressure Vessel Code because these inspections are already required by 10 4.2.2 CFR 50.55.a(g). Requires that IP2 develop and maintain a program to implement these requirements.

A.4 Clarifies testing Frequency nomenclature differences between Section XI of the ASME Boiler 4.1 5.5.6.a and Pressure Vessel Code and the ITS equivalent to what is found in CTS Table 1-1. 4.2 5.5.6.b T 1-1 A.5 Adds an explicit statement that allowances of ITS SR 3.0.2 (i.e., a 25% extension) are 4.0.1 5.5.6.b applicable to the testing frequencies specified in the ASME Code. This maintains allowance 4.2 3.0.2 SR already provided in CTS 4.0.1.

A.6 Adds an explicit statement that allowances of ITS SR 3.0.3 (i.e., 24 hours1 days 0.143 weeks 0.0329 months to perform missed 4.0.2 5.5.6.c SR) are applicable to the testing frequencies specified in the ASME Code. This maintains 3.0.3 SR allowance already provided in CTS 4.0.2.

A.7 Adds an explicit statement that "Nothing in the ASME Boiler and Pressure Vessel Code shall 4.2 5.5.6.d be construed to supersede the requirements of any TS."

ITS SPECIFICATION 5.5.7 - STEAM GENERATOR (SG) TUBE SURVEILLANCE PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.13 5.5.7 consistent with NUREG-1431.

Indian Point - Unit 2 A-122 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 4.13 5.5.7 any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 5.5.8 - SECONDARY WATER CHEMISTRY PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS Lic 2.D (2) 5.5.8 consistent with NUREG-1431.

A.2 Maintains existing requirements for a secondary water chemistry monitoring program to inhibit Lic 2.D (2) 5.5.8 steam generator tube degradation.

ITS SPECIFICATION 5.5.9 - VENTILATION FILTER TESTING PROGRAM (VFTP)

A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.5 5.5.9 consistent with NUREG-1431.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 4.5 5.5.9 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Expresses existing CTS acceptance criteria for HEPA filter bank testing and charcoal adsorber 4.5.E.5 5.5.9.a testing consistent with Regulatory Positions 5.c and 5.d of Regulatory Guide 1.52, Revision 2, 4.5.E.6 5.5.9.b March 1978.

A.4 Clarifies that Regulatory Positions C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 4.5.E.5 5.5.9.a 1978, assume completion of the requirements for visual inspection in accordance with 4.5.E.2.C 5.5.9.b Regulatory Position C.5.a of Regulatory Guide 1.52.

A.5 Adopts NUREG-1431 presentation for Surveillance Frequency of 24 months versus CTS use of 4.5.E.2 5.5.9 each refueling interval (R#) with reference to CTS table 1.1. Uses the term "standby service" to 4.5.E.4 clarify that the Frequency is based on calendar limits and not the amount of time the system is T 1.1 in operation.

Indian Point - Unit 2 A-123 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change A.6 Clarifies that Control Room Air Filtration System ventilation filters must be re-tested "after 4.5.E.2 5.5.9 painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation."

A.7 Adds an explicit statement that allowances of ITS 3.0.2 (i.e., allowance for 25% extension to 4.0.1 3.0.2 SR the SR Frequency) and ITS SR 3.0.3 (i.e., 24 hours1 days 0.143 weeks 0.0329 months to perform missed SR) are applicable to 4.0.2 3.0.3 SR ITS 5.5.9, Ventilation Filter Testing Program (VFTP). This maintains existing allowances in 5.5.9 CTS 4.0.1 and CTS 4.0.2.

ITS SPECIFICATION 5.5.10 - EXPLOSIVE GAS AND STORAGE TANK RADIOACTIVITY MONITORING PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 3.9.B 5.5.10 consistent with NUREG-1431. 4.10.B A.2 Adds an explicit statement that allowances of ITS 3.0.2 (i.e., allowance for 25% extension to 4.0.1 5.5.10 the SR Frequency) and ITS SR 3.0.3 (i.e., 24 hours1 days 0.143 weeks 0.0329 months to perform missed SR) are applicable to 4.0.2 3.0.2 SR ITS 5.5.10, Explosive Gas and Storage Tank Radioactivity Monitoring Program. This maintains 4.10 3.0.3 SR existing allowances in CTS 4.0.1 and CTS 4.0.2.

ITS SPECIFICATION 5.5.11 - DIESEL FUEL OIL TESTING PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.6 5.5.11 consistent with NUREG-1431.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 4.6 5.5.11 any requirements and do not provide any guidance for the application of CTS requirements.

ITS SPECIFICATION 5.5.12 - TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM NONE ITS SPECIFICATION 5.5.13 - SAFETY FUNCTION DETERMINATION PROGRAM (SFDP)

Indian Point - Unit 2 A-124 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change NONE ITS SPECIFICATION 5.5.14 - CONTAINMENT LEAKAGE RATE TESTING PROGRAM A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.4 5.5.14 consistent with NUREG-1431.

A.2 Deletes CTS statements labeled Objective and Applicability because they do not establish 4.4 5.5.14 any requirements and do not provide any guidance for the application of CTS requirements.

A.3 Consolidates various CTS requirements that containment leakage rate testing must be 4.4.A.1.a 5.5.14.a performed in accordance with 10 CFR 50 Appendix J, Option B, and Regulatory Guide 1.163 4.4.A.1.b into a single statement. 4.4.A.1.c 4.4.A.3 4.4.C.1 4.4.D.1.a A.4 Adds reference to 10 CFR 50.54 (o) which requires that 10 CFR 50 Appendix J, is met to an 4.4.A.1.b 5.5.14.a existing requirement that 10 CFR 50 Appendix J, Option B, is met. 4.4.A.3 4.4.C.1 4.4.D.1.a A.5 Clarifies that the more restrictive acceptance criteria for Type B and C tests and not the 4.4.D.1.b 5.5.14.a acceptance criteria for the weld channel and penetration pressurization system sensitive leak 4.4.B.2 5.5.14.d.1 rate test apply to components subject to Type B and C testing by 10 CFR 50, Appendix J. 4.4.D.2.a 3.6.10.3 SR 4.4.8.1 A.6 Clarifies that the IVSW leakage acceptance criteria and not the Type B and C testing leakage 4.4.D.1.c 3.6.9.3 SR criteria applies to valves sealed by IVSW. 4.4.D.2.a 5.5.14.d.1 4.4.D.2.c 5.5.14.d.3 A.7 Uses different terminology to explain that more restrictive acceptance criteria applies to the "as 4.4.A.2 5.5.14.d.1 left" condition than applies to the "as found" containment leakage condition.

Indian Point - Unit 2 A-125 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change A.8 Adopts terminology from 10 CFR 50, Appendix J, (i.e., Type A, Type B and Type C tests). 4.4.A.2 5.5.14.d.1 4.4.D.2.a A.9 Clarifies that nothing in the Technical Specifications shall be construed to modify the testing 4.4 5.5.14.f Frequencies required by 10 CFR 50, Appendix J.

ITS SPECIFICATION 5.5.15 - BATTERY MONITORING AND MAINTENANCE PROGRAM NONE ITS SPECIFICATION 5.6 - REPORTING REQUIREMENTS A.1 Incorporates various editorial changes, reformatting, and revised numbering to make IP2 ITS 4.13 5.6 consistent with NUREG-1431. 6.13 6.16 6.6 6.9 A.2 Deletes statement that the types of records that must be retained and the minimum retention 6.10 5.6 period for these records are described in the Quality Assurance Program Description (QAPD).

A.3 Superceded by CTS Amendment 219. NA NA A.4 Clarifies that the annual Occupational Radiation Exposure Report required per 10 CFR 20, 6.9.1.4 5.6.1 must include only deep dose exposures.

A.5 Clarifies that electronic dosimeters may be used to measure exposures for the purpose of the 6.9.1.4 5.6.1 annual Occupational Radiation Exposure Report.

A.6 Changes the due date for the Annual Radiological Environmental Operating Report from May 1 6.9.1.5 5.6.2 to May 15 of each year.

Indian Point - Unit 2 A-126 Section 5.0

Discussion Summary of Change CTS Section ITS Section of Change A.7 Adds clarification that the Radioactive Effluent Release Report is submitted in accordance with 6.9.1.6 5.6.3 10 CFR 50.36.a.

A.8 Eliminates cross reference to the core operating limit Technical Specification associated with 6.9.1.9 5.6.5 that document from the list of the documents approved by the NRC that describe the analytical methods used to determine the IP2 core operating limits.

A.9 Not Used. NA NA A.10 Eliminates administrative requirement that operating statistics included in the Monthly 6.9.1.7 5.6.4 Operating Report to the NRC must include all challenges to the PORVs or pressurizer safety 6.9.2.I valves because challenges to the PORVs or pressurizer safety valves fall within reporting requirements in 10 CFR 50.73.

Indian Point - Unit 2 A-127 Section 5.0

v t e Letter Sequence Acceptance Review
TAC:MB4739, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed)
Initiation Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Questions 6 August 2002 22 October 2002 22 January 2003 16 May 2003 Answers 10 October 2002 28 October 2002 18 December 2002 23 June 2003 Results Approval, Approval Other: ML021080189, ML032330040, ML032810196, ML032810204, ML033160625, ML033210262, NL-03-186, Implementation of License Amendment 238 for Conversion to Improved Standard Technical Specifications
MONTHYEAR2003-10-02 [Table View]

ML032810159

Text

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