ML041200303

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 2, Rev 0, Generic Determination of No Significant Hazards Consideration and Environmental Assessment.

ML041200303
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:4901
Download: ML041200303 (38)

Text

Attachment 1, Volume 2, Rev. 0, Page 1 of 38 VOLUME 2 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION GENERIC DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION AND ENVIRONMENTAL ASSESSMENT Revision 0 Attachment 1, Volume 2, Rev. 0, Page 1 of 38

Attachment 1, Volume 2, Rev. 0, Page 2 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR ADMINISTRATIVE CHANGES CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve reformatting, renumbering, and rewording of Current Technical Specifications (CTS) with no change in intent. These changes, since they do not involve technical changes to the CTS, are administrative.

This type of change is connected with the movement of requirements within the current requirements, or with the modification of wording that does not affect the technical content of the CTS. These changes also include non-technical modifications of requirements to conform to NEI 01-03, "Writer's Guide for the Improved Standard Technical Specifications," or provide consistency with the Improved Standard Technical Specifications in NUREG-1431. Administrative changes are not intended to add, delete, or relocate any technical requirements of the CTS.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves reformatting, renumbering, and rewording the CTS. The reformatting, renumbering, and rewording process involves no technical changes to the CTS. As such, this change is administrative in nature and does not affect initiators of analyzed events or assumed mitigation of accident or transient events. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change will not impose any new or eliminate any old requirements. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 1 of 36 Attachment 1, Volume 2, Rev. 0, Page 2 of 38

Attachment 1, Volume 2, Rev. 0, Page 3 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change will not reduce a margin of safety because it has no effect on any safety analyses assumptions. This change is administrative in nature.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 2 of 36 Attachment 1, Volume 2, Rev. 0, Page 3 of 38

Attachment 1, Volume 2, Rev. 0, Page 4 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR MORE RESTRICTIVE CHANGES CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve adding more restrictive requirements to the Current Technical Specifications (CTS) by either making current requirements more stringent or by adding new requirements that currently do not exist.

These changes include additional requirements that decrease allowed outage times, increase the Frequency of Surveillances, impose additional Surveillances, increase the scope of Specifications to include additional plant equipment, increase the Applicability of Specifications, or provide additional actions. These changes are generally made to conform with NUREG-1431 and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change provides more stringent Technical Specification requirements for the facility. These more stringent requirements do not result in operations that significantly increase the probability of initiating an analyzed event, and do not alter assumptions relative to mitigation of an accident or transient event. The more restrictive requirements continue to ensure process variables, structures, systems, and components are maintained consistent with the safety analyses and licensing basis. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change does impose different Technical Specification requirements. However, these changes are consistent with the assumptions in the safety analyses and licensing basis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 3 of 36 Attachment 1, Volume 2, Rev. 0, Page 4 of 38

Attachment 1, Volume 2, Rev. 0, Page 5 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The imposition of more restrictive requirements either has no effect on or increases the margin of plant safety. As provided in the discussion of change, each change in this category is, by definition, providing additional restrictions to enhance plant safety. The change maintains requirements within the safety analyses and licensing basis. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 4 of 36 Attachment 1, Volume 2, Rev. 0, Page 5 of 38

Attachment 1, Volume 2, Rev. 0, Page 6 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR RELOCATED SPECIFICATIONS CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve relocating Current Technical Specification (CTS)

Limiting Conditions for Operations (LCOs) to licensee controlled documents.

The Company has evaluated the CTS using the criteria set forth in 10 CFR 50.36.

Specifications identified by this evaluation that did not meet the retention requirements specified in the regulation are not included in the ITS. These specifications have been relocated from the CTS to the Technical Requirements Manual, which is incorporated into the Updated Final Safety Analysis Report (UFSAR).

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relocates requirements and Surveillances for structures, systems, components, or variables that do not meet the criteria of 10 CFR 50.36 (c)(2)(ii) for inclusion in Technical Specifications as identified in the Application of Selection Criteria to the Donald C. Cook Nuclear Plant Units 1 and 2 Technical Specifications. The affected structures, systems, components or variables are not assumed to be initiators of analyzed events and are not assumed to mitigate accident or transient events. The requirements and Surveillances for these affected structures, systems, components, or variables will be relocated from the CTS to an appropriate administratively controlled document which will be incorporated into the UFSAR, thus it will be maintained pursuant to 10 CFR 50.59. In addition, the affected structures, systems, components, or variables are addressed in existing surveillance procedures which are also controlled by 10 CFR 50.59, and are subject to the change control provisions imposed by plant administrative procedures, which endorse applicable regulations and standards. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change in the methods governing normal plant operation. The proposed change will not impose or Page 5 of 36 Attachment 1, Volume 2, Rev. 0, Page 6 of 38

Attachment 1, Volume 2, Rev. 0, Page 7 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES eliminate any requirements, and adequate control of existing requirements will be maintained. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change will not reduce a margin of safety because it has no significant effect on any safety analyses assumptions, as indicated by the fact that the requirements do not meet the 10 CFR 50.36 criteria for retention. In addition, the relocated requirements are moved without change, and any future changes to these requirements will be evaluated per 10 CFR 50.59.

NRC prior review and approval of changes to these relocated requirements, in accordance with 10 CFR 50.92, will no longer be required. This review and approval does not provide a specific margin of safety which can be evaluated.

However, the proposed change is consistent with NUREG-1431, issued by the NRC, which allows revising the CTS to relocate these requirements and Surveillances to a licensee controlled document controlled by 10 CFR 50.59.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 6 of 36 Attachment 1, Volume 2, Rev. 0, Page 7 of 38

Attachment 1, Volume 2, Rev. 0, Page 8 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR REMOVED DETAIL CHANGES CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve moving details out of the Current Technical Specifications (CTS) and into the Technical Specifications Bases, the Updated Final Safety Analysis Report (UFSAR), the Technical Requirements Manual (TRM), or other documents under regulatory control such as the CORE OPERATING LIMITS REPORT (COLR), Offsite Dose Calculation Manual (ODCM), Quality Assurance Program Description (QAPD), and Inservice Inspection Program (IIP). The removal of this information is considered to be less restrictive because it is no longer controlled by the Technical Specification change process. Typically, the information moved is descriptive in nature and its removal conforms with NUREG-1431 for format and content.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relocates certain details from the CTS to other documents under regulatory control. The Technical Specification Bases and TRM will be maintained in accordance with 10 CFR 50.59. In addition to 10 CFR 50.59 provisions, the Technical Specification Bases are subject to the change control provisions in the Administrative Controls Chapter of the ITS. The UFSAR is subject to the change control provisions of 10 CFR 50.59 or 10 CFR 50.71(e).

Other documents are subject to controls imposed by ITS or regulations. Since any changes to these documents will be evaluated, no significant increase in the probability or consequences of an accident previously evaluated will be allowed.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operations. The proposed change will not impose or eliminate any requirements, and adequate control of the information will be maintained. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 7 of 36 Attachment 1, Volume 2, Rev. 0, Page 8 of 38

Attachment 1, Volume 2, Rev. 0, Page 9 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change will not reduce a margin of safety because it has no effect on any assumption of the safety analyses. In addition, the details to be moved from the CTS to other documents are not being changed. Since any future changes to these details will be evaluated under the applicable regulatory change control mechanism, no significant reduction in a margin of safety will be allowed. A significant reduction in the margin of safety is not associated with the elimination of the 10 CFR 50.90 requirement for NRC review and approval of future changes to the relocated details. Not including these details in the Technical Specifications is consistent with NUREG-1431, issued by the NRC, which allows revising the Technical Specifications to relocate these requirements and Surveillances to a licensee controlled document controlled by 10 CFR 50.59, 10 CFR 50.71(e), or other Technical Specification controlled or regulation controlled documents. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 8 of 36 Attachment 1, Volume 2, Rev. 0, Page 9 of 38

Attachment 1, Volume 2, Rev. 0, Page 10 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 1 RELAXATION OF LCO REQUIREMENTS CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve relaxation of the Current Technical Specification (CTS) Limiting Conditions for Operation (LCOs) by the elimination of specific items from the LCO or Tables referenced in the LCO, or the addition of exceptions to the LCO.

These changes reflect the ISTS approach to provide LCO requirements that specify the protective conditions that are required to meet safety analysis assumptions for required features. These conditions replace the lists of specific devices used in the CTS to describe the requirements needed to meet the safety analysis assumptions. The ITS also includes LCO Notes which allow exceptions to the LCO for the performance of testing or other operational needs. The ITS provides the protection required by the safety analysis, and provides flexibility for meeting the conditions without adversely affecting operations since equivalent features are required to be OPERABLE. The ITS is also consistent with the plant current licensing basis, as may be modified in the discussion of individual changes. These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change provides less restrictive LCO requirements for operation of the facility. These less restrictive LCO requirements do not result in operation that will significantly increase the probability of initiating an analyzed event and do not alter assumptions relative to mitigation of an accident or transient event in that the requirements continue to ensure process variables, structures, systems, and components are maintained consistent with the current safety analyses and licensing basis. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change does impose different requirements. However, the change is consistent with the assumptions in the Page 9 of 36 Attachment 1, Volume 2, Rev. 0, Page 10 of 38

Attachment 1, Volume 2, Rev. 0, Page 11 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES current safety analyses and licensing basis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The imposition of less restrictive LCO requirements does not involve a significant reduction in the margin of safety. As provided in the discussion of change, this change has been evaluated to ensure that the current safety analyses and licensing basis requirements are maintained. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 10 of 36 Attachment 1, Volume 2, Rev. 0, Page 11 of 38

Attachment 1, Volume 2, Rev. 0, Page 12 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 2 RELAXATION OF APPLICABILITY CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve relaxation of the applicability of Current Technical Specification (CTS) Limiting Conditions for Operation (LCOs) by reducing the conditions under which the LCO requirements must be met.

Reactor operating conditions are used in CTS to define when the LCO features are required to be OPERABLE. CTS Applicabilities can be specific defined terms of reactor conditions or more general such as, "all MODES" or "any operating MODE."

Generalized applicability conditions are not contained in ITS, therefore the ITS eliminates CTS requirements such as "all MODES" or "any operating MODE," replacing them with ITS defined MODES or applicable conditions that are consistent with the application of the plant safety analyses assumptions for OPERABILITY of the required features.

CTS requirements may also be eliminated during conditions for which the safety function of the specified safety system is met because the feature is performing its intended safety function. Deleting applicability requirements that are indeterminate or which are inconsistent with application of accident analyses assumptions is acceptable because when LCOs cannot be met, the ITS may be satisfied by exiting the applicability which takes the plant out of the conditions that require the safety system to be OPERABLE.

This change provides the protection required by the safety analyses, and provides flexibility for meeting limits by restricting the application of the limits to the conditions assumed in the safety analyses. The ITS is also consistent with the plant current licensing basis, as may be modified in the discussion of individual changes. The change is generally made to conform with NUREG-1431, and has been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relaxes the conditions under which the LCO requirements for operation of the facility must be met. These less restrictive applicability requirements for the LCOs do not result in operation that will significantly increase the probability of initiating an analyzed event and do not alter assumptions relative to mitigation of an accident or transient event in that the requirements continue to ensure that process variables, structures, systems, and components are maintained in the MODES and other specified conditions Page 11 of 36 Attachment 1, Volume 2, Rev. 0, Page 12 of 38

Attachment 1, Volume 2, Rev. 0, Page 13 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES assumed in the safety analyses and licensing basis. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change does impose different requirements. However, the requirements are consistent with the assumptions in the safety analyses and licensing basis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The relaxed applicability of LCO requirements does not involve a significant reduction in the margin of safety. As provided in the discussion of change, this change has been evaluated to ensure that the LCO requirements are applied in the MODES and specified conditions assumed in the safety analyses and licensing basis. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 12 of 36 Attachment 1, Volume 2, Rev. 0, Page 13 of 38

Attachment 1, Volume 2, Rev. 0, Page 14 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 3 RELAXATION OF COMPLETION TIME CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve relaxation of the Completion Times for Required Actions in the Current Technical Specifications (CTS).

Upon discovery of a failure to meet a Limiting Condition for Operation (LCO), the ITS specifies times for completing Required Actions of the associated ITS Conditions.

Required Actions of the associated Conditions are used to establish remedial measures that must be taken within specified Completion Times (referred to as Allowed Outage Times (AOTs) in the CTS). These times define limits during which operation in a degraded condition is permitted. Adopting Completion Times from the ITS is acceptable because the Completion Times take into account the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. In addition, the ITS provides consistent Completion Times for similar conditions. These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relaxes the Completion Time for a Required Action.

Required Actions and their associated Completion Times are not initiating conditions for any accident previously evaluated, and the accident analyses do not assume that required equipment is out of service prior to the analyzed event.

Consequently, the relaxed Completion Time does not significantly increase the probability of any accident previously evaluated. The consequences of an analyzed accident during the relaxed Completion Time are the same as the consequences during the existing AOT. As a result, the consequences of any accident previously evaluated are not significantly increased. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Page 13 of 36 Attachment 1, Volume 2, Rev. 0, Page 14 of 38

Attachment 1, Volume 2, Rev. 0, Page 15 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the method governing normal plant operation. The Required Actions and associated Completion Times in the ITS have been evaluated to ensure that no new accident initiators are introduced. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The relaxed Completion Time for a Required Action does not involve a significant reduction in the margin of safety. As provided in the discussion of change, the change has been evaluated to ensure that the allowed Completion Time is consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 14 of 36 Attachment 1, Volume 2, Rev. 0, Page 15 of 38

Attachment 1, Volume 2, Rev. 0, Page 16 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 4 RELAXATION OF REQUIRED ACTION CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve relaxation of the Required Actions in the Current Technical Specifications (CTS).

Upon discovery of a failure to meet a Limiting Condition for Operation (LCO), the ITS specifies Required Actions to complete for the associated Conditions. Required Actions of the associated Conditions are used to establish remedial measures that must be taken in response to the degraded conditions. These actions minimize the risk associated with continued operation while providing time to repair inoperable features.

Some of the Required Actions are modified to place the plant in a MODE in which the LCO does not apply. Adopting Required Actions from the ISTS is acceptable because the Required Actions take into account the OPERABILITY status of redundant systems of required features, the capacity and capability of the remaining features, and the compensatory attributes of the Required Actions as compared to the LCO requirements.

These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relaxes Required Actions. Required Actions and their associated Completion Times are not initiating conditions for any accident previously evaluated, and the accident analyses do not assume that required equipment is out of service prior to the analyzed event. Consequently, the relaxed Required Actions do not significantly increase the probability of any accident previously evaluated. The Required Actions in the ITS have been developed to provide appropriate remedial actions to be taken in response to the degraded condition considering the OPERABILITY status of the redundant systems of required features, and the capacity and capability of remaining features while minimizing the risk associated with continued operation. As a result, the consequences of any accident previously evaluated are not significantly increased. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 15 of 36 Attachment 1, Volume 2, Rev. 0, Page 16 of 38

Attachment 1, Volume 2, Rev. 0, Page 17 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The Required Actions and associated Completion Times in the ITS have been evaluated to ensure that no new accident initiators are introduced. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The relaxed Required Actions do not involve a significant reduction in the margin of safety. As provided in the discussion of change, this change has been evaluated to minimize the risk of continued operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 16 of 36 Attachment 1, Volume 2, Rev. 0, Page 17 of 38

Attachment 1, Volume 2, Rev. 0, Page 18 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 5 DELETION OF SURVEILLANCE REQUIREMENT CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve deletion of Surveillance Requirements in the Current Technical Specifications (CTS).

The CTS require safety systems to be tested and verified OPERABLE prior to entering applicable operating conditions. The ITS eliminates unnecessary CTS Surveillance Requirements that do not contribute to verification that the equipment used to meet the Limiting Condition for Operation (LCO) can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change deletes Surveillance Requirements. Surveillances are not initiators to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be OPERABLE and capable of performing the accident mitigation functions assumed in the accident analyses. As a result, the consequences of any accident previously evaluated are not significantly affected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The remaining Surveillance Requirements are consistent with industry practice, and are considered to be sufficient to prevent the removal of the subject Surveillances from creating a new or different type of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 17 of 36 Attachment 1, Volume 2, Rev. 0, Page 18 of 38

Attachment 1, Volume 2, Rev. 0, Page 19 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The deleted Surveillance Requirements do not result in a significant reduction in the margin of safety. As provided in the discussion of change, the change has been evaluated to ensure that the deleted Surveillance Requirements are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 18 of 36 Attachment 1, Volume 2, Rev. 0, Page 19 of 38

Attachment 1, Volume 2, Rev. 0, Page 20 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 6 RELAXATION OF SURVEILLANCE REQUIREMENT ACCEPTANCE CRITERIA CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the relaxation of Surveillance Requirements acceptance criteria in the Current Technical Specifications (CTS).

The CTS require safety systems to be tested and verified OPERABLE prior to entering applicable operating conditions. The ITS eliminates or relaxes the Surveillance Requirement acceptance criteria that do not contribute to verification that the equipment used to meet the Limiting Condition for Operation (LCO) can perform its required functions. For example, the ITS allows some Surveillance Requirements to verify OPERABILITY under actual or test conditions. Adopting the ITS allowance for "actual" conditions is acceptable because required features cannot distinguish between an "actual" signal or a "test" signal. Also included are changes to CTS requirements that are replaced in the ITS with separate and distinct testing requirements that when combined, include OPERABILITY verification of all components required in the LCO for the features specified in the CTS. Adopting this format preference in the ITS is acceptable because Surveillance Requirements that remain include testing of all previous features required to be verified OPERABLE. Changes which provide exceptions to Surveillance Requirements to provide for variations that do not affect the results of the test are also included in this category. These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relaxes the acceptance criteria of Surveillance Requirements. Surveillances are not initiators to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be OPERABLE and capable of performing the accident mitigation functions assumed in the accident analyses. As a result, the consequences of any accident previously evaluated are not significantly affected. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 19 of 36 Attachment 1, Volume 2, Rev. 0, Page 20 of 38

Attachment 1, Volume 2, Rev. 0, Page 21 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The relaxed acceptance criteria for Surveillance Requirements do not result in a significant reduction in the margin of safety. As provided in the discussion of change, the relaxed Surveillance Requirement acceptance criteria have been evaluated to ensure that they are sufficient to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner that gives confidence that the equipment can perform its assumed safety function. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 20 of 36 Attachment 1, Volume 2, Rev. 0, Page 21 of 38

Attachment 1, Volume 2, Rev. 0, Page 22 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 7 RELAXATION OF SURVEILLANCE FREQUENCY, NON-24 MONTH TYPE CHANGE CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the relaxation of Surveillance Frequencies in the Current Technical Specifications (CTS).

CTS and ITS Surveillance Frequencies specify time interval requirements for performing Surveillance tests. Increasing the time interval between Surveillance tests in the ITS results in decreased equipment unavailability due to testing which also increases equipment availability. In general, the ITS contain Surveillance Frequencies that are consistent with industry practice or industry standards for achieving acceptable levels of equipment reliability. Adopting testing practices specified in the ITS is acceptable based on similar design, like-component testing for the system application and the availability of other ITS requirements which provide regular checks to ensure limits are met.

Relaxation of Surveillance Frequency can also include the addition of Surveillance Notes which allow testing to be delayed until appropriate unit conditions for the test are established, or exempt testing in certain MODES or specified conditions in which the testing can not be performed.

Reduced testing can result in a safety enhancement because the unavailability due to testing is reduced, and reliability of the affected structure, system or component should remain constant or increase. Reduced testing is acceptable where operating experience, industry practice, or the industry standards such as manufacturers' recommendations have shown that these components usually pass the Surveillance when performed at the specified interval, thus the Surveillance Frequency is acceptable from a reliability standpoint. Surveillance Frequency changes to incorporate alternate train testing have been shown to be acceptable where other qualitative or quantitative test requirements are required that are established predictors of system performance.

Surveillance Frequency extensions can be based on NRC-approved topical reports. The NRC staff has accepted topical report analyses that bound the plant-specific design and component reliability assumptions. These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relaxes Surveillance Frequencies. The relaxed Surveillance Frequencies have been established based on achieving acceptable levels of equipment reliability. Consequently, equipment which could initiate an accident previously evaluated will continue to operate as expected, and the Page 21 of 36 Attachment 1, Volume 2, Rev. 0, Page 22 of 38

Attachment 1, Volume 2, Rev. 0, Page 23 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES probability of the initiation of any accident previously evaluated will not be significantly increased. The equipment being tested is still required to be OPERABLE and capable of performing any accident mitigation functions assumed in the accident analyses. As a result, the consequences of any accident previously evaluated are not significantly affected. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The relaxed Surveillance Frequencies do not result in a significant reduction in the margin of safety. As provided in the discussion of change, the relaxation in the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Thus, appropriate equipment continues to be tested at a Frequency that gives confidence that the equipment can perform its assumed safety function when required. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 22 of 36 Attachment 1, Volume 2, Rev. 0, Page 23 of 38

Attachment 1, Volume 2, Rev. 0, Page 24 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 8 DELETION OF REPORTING REQUIREMENTS CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the deletion of requirements in the Current Technical Specifications (CTS) to send reports to the NRC.

The CTS includes requirements to submit reports to the NRC under certain circumstances. However, the ITS eliminates these requirements for many such reports and, in many cases, relies on the reporting requirements of 10 CFR 50.73 or other regulatory requirements. The ITS changes to reporting requirements are acceptable because the regulations provide adequate reporting requirements, or the reports do not affect continued plant operation. Therefore, this change has no effect on the safe operation of the plant. These changes are generally made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change deletes reporting requirements. Sending reports to the NRC is not an initiator of any accident previously evaluated. Consequently, the probability of any accident previously evaluated is not significantly increased.

Sending reports to the NRC has no effect on the ability of equipment to mitigate an accident previously evaluated. As a result, the consequences of any accident previously evaluated is not significantly affected. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 23 of 36 Attachment 1, Volume 2, Rev. 0, Page 24 of 38

Attachment 1, Volume 2, Rev. 0, Page 25 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The deletion of reporting requirements does not result in a significant reduction in the margin of safety. The ITS eliminates the requirements for many such reports and, in many cases, relies on the reporting requirements of 10 CFR 50.73 or other regulatory requirements. The change to reporting requirements does not affect the margin of safety because the regulations provide adequate reporting requirements, or the reports do not affect continued plant operation. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 24 of 36 Attachment 1, Volume 2, Rev. 0, Page 25 of 38

Attachment 1, Volume 2, Rev. 0, Page 26 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 9 SURVEILLANCE FREQUENCY CHANGE USING GL 91-04 GUIDELINES, NON-24 MONTH TYPE CHANGE CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the relaxation of 7 day, 31 day, or 92 day Surveillance Frequencies for Surveillances in the Current Technical Specifications (CTS).

This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. While the Generic Letter provided guidance for extending Surveillance Frequencies from 18 months to 24 months, the guidelines in the Generic Letter provide a basis for extending other Surveillance Frequencies based on historical data. Reviews of historical maintenance and Surveillance data have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Based on the inherent system and component reliability and the routine testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical Surveillance data also demonstrates that there have been no failures that would invalidate this conclusion. In addition, the proposed 184 day Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (230 days) does not invalidate any assumptions in the plant licensing basis.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves a change in the Surveillance Frequencies from 7 days, 31 days, or 92 days to 184 days. The proposed change does not physically impact the plant, and does not impact any design or functional requirements of the associated systems. That is, the proposed change does not degrade the performance or increase the challenges of any safety systems assumed to function in the accident analyses. The proposed change does not impact the Surveillance Requirements themselves, and do not change the methods used for performing Surveillances. Additionally, the proposed change does not introduce any new accident initiators, because no accidents previously evaluated have as their initiators anything related to the Frequency of Surveillance testing. The proposed change does not affect the availability of equipment or systems required to mitigate the consequences of an accident, Page 25 of 36 Attachment 1, Volume 2, Rev. 0, Page 26 of 38

Attachment 1, Volume 2, Rev. 0, Page 27 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES because of the availability of redundant systems or equipment and because other tests performed more frequently will identify potential equipment problems.

Furthermore, an historical review of Surveillance test results indicates that all failures identified were unique, non-repetitive, and not related to any time-based failure modes, and indicated no evidence of any failures that would invalidate the above conclusions. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change involves a change in the Surveillance Frequencies from 7 days, 31 days, or 92 days to 184 days. The proposed change does not introduce any failure mechanisms of a different type than those previously evaluated since there are no physical changes being made to the facility. In addition, the Surveillance Requirements themselves and the way Surveillances are performed will remain unchanged. Furthermore, an historical review of Surveillance test results indicates that there is no evidence of any failures that would invalidate the above conclusions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change involves a change in the Surveillance Frequencies from 7 days, 31 days, or 92 days to 184 days. Although the proposed change will result in an increase in the interval between Surveillance tests, the impact on system availability is minimal based on other, more frequent testing or redundant systems or equipment, and there is no evidence of any failures that would impact the availability of the systems. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 26 of 36 Attachment 1, Volume 2, Rev. 0, Page 27 of 38

Attachment 1, Volume 2, Rev. 0, Page 28 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 10 18 TO 24 MONTH SURVEILLANCE FREQUENCY CHANGE, NON-CHANNEL CALIBRATION TYPE CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the extension of 18 month Surveillance Frequencies for non-CHANNEL CALIBRATION type Surveillances in the Current Technical Specifications (CTS) to 24 months.

This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical maintenance and Surveillance data have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Based on the inherent system and component reliability and the routine testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical Surveillance data also demonstrates that there have been no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves a change in the Surveillance Frequencies from 18 months to 24 months. The proposed change does not physically impact the plant, and does not impact any design or functional requirements of the associated systems. That is, the proposed change does not degrade the performance or increase the challenges of any safety systems assumed to function in the accident analyses. The proposed change does not impact the Surveillance Requirements themselves, and does not change the methods used for performing the Surveillances. Additionally, the proposed change does not introduce any new accident initiators, because no accidents previously evaluated have as their initiators anything related to the Frequency of Surveillance testing.

The proposed change does not affect the availability of equipment or systems required to mitigate the consequences of an accident, because of the availability of redundant systems or equipment and because other tests performed more frequently will identify potential equipment problems. Furthermore, an historical review of Surveillance test results indicates that all failures identified were Page 27 of 36 Attachment 1, Volume 2, Rev. 0, Page 28 of 38

Attachment 1, Volume 2, Rev. 0, Page 29 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES unique, non-repetitive, and not related to any time-based failure modes, and indicated no evidence of any failures that would invalidate the above conclusions.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change involves a change in the Surveillance Frequencies from 18 months to 24 months. The proposed change does not introduce any failure mechanisms of a different type than those previously evaluated since there are no physical changes being made to the facility. In addition, the Surveillance Requirements themselves and the way Surveillances are performed will remain unchanged. Furthermore, an historical review of Surveillance test results indicates no evidence of any failures that would invalidate the above conclusions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Although the proposed change will result in an increase in the interval between Surveillance tests, the impact on system availability is minimal based on other, more frequent testing or redundant systems or equipment, and there is no evidence of any failures that would impact the availability of the systems.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 28 of 36 Attachment 1, Volume 2, Rev. 0, Page 29 of 38

Attachment 1, Volume 2, Rev. 0, Page 30 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 11 18 TO 24 MONTH SURVEILLANCE FREQUENCY CHANGE, CHANNEL CALIBRATION TYPE CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the extension of 18 month Surveillance Frequencies for CHANNEL CALIBRATION type Surveillances in the Current Technical Specifications (CTS) to 24 months.

This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Furthermore, the impacted instrumentation has been evaluated based on make, manufacturer, and model number to determine that the actual drift of the instrumentation falls within the design allowance in the associated setpoint calculation. Based on the design of the instrumentation and the drift evaluations, it is concluded that the impact, if any, from this change on system availability is minimal. A review of the Surveillance test history was performed to validate the above conclusion. This review demonstrates that there have been no failures that would invalidate the conclusion that the impact, if any, on system availability from this change is minimal. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months),

does not invalidate any assumptions in the plant licensing basis.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves a change in the instrumentation CHANNEL CALIBRATION Surveillance Frequencies from 18 months to 24 months. The proposed change does not physically impact the plant, and does not impact any design or functional requirements of the associated systems. That is, the proposed change does not degrade the performance or increase the challenges of any safety systems assumed to function in the accident analyses. The proposed change does not impact the Surveillance Requirements themselves, and does not change the methods for performing the Surveillances. Additionally, the proposed change does not introduce any new accident initiators, because no accidents previously evaluated have as their initiators anything related to the Frequency of Surveillance testing. The proposed change does not affect the availability of equipment or systems required to mitigate the consequences of an accident, because of the availability of redundant systems or equipment and because other tests performed more frequently will identify potential equipment problems. Furthermore, an historical review of Surveillance test results indicates Page 29 of 36 Attachment 1, Volume 2, Rev. 0, Page 30 of 38

Attachment 1, Volume 2, Rev. 0, Page 31 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES that all failures identified were unique, non-repetitive, and not related to any time-based failure modes, and indicates no evidence of any failures that would invalidate the above conclusions. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change involves a change in the instrumentation CHANNEL CALIBRATION Surveillance Frequencies from 18 months to 24 months. The proposed change does not introduce any failure mechanisms of a different type than those previously evaluated since there are no physical changes being made to the facility. In addition, the Surveillance Requirements themselves and the way Surveillances are performed will remain unchanged. Furthermore, an historical review of Surveillance test results indicates no evidence of any failures that would invalidate the above conclusions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Although the proposed change will result in an increase in the interval between Surveillance tests, the impact on system availability is minimal based on other, more frequent testing or redundant systems or equipment, and there is no evidence of any failures that would impact the availability of the systems.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 30 of 36 Attachment 1, Volume 2, Rev. 0, Page 31 of 38

Attachment 1, Volume 2, Rev. 0, Page 32 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 12 DELETION OF SURVEILLANCE REQUIREMENT SHUTDOWN PERFORMANCE REQUIREMENTS CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes involve the deletion of the requirement to perform Surveillance Requirements while in a shutdown condition in the Current Technical Specifications (CTS).

The CTS require safety systems to be tested and verified OPERABLE periodically. The CTS requires these Surveillances to be performed with the unit in a specified condition, usually in a MODE outside the Applicability of the Limiting Condition for Operation (LCO). The ITS Surveillance does not include the restriction on unit conditions. The control of the unit conditions appropriate to perform the test is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as an ITS restriction. As indicated in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do no dictate unit conditions for the Surveillance. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. These changes are made to conform with NUREG-1431 and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves the deletion of the requirement to perform Surveillance Requirements while in a shutdown condition. Surveillances are not initiators to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The appropriate plant conditions for performance of the Surveillance will continue to be controlled in plant procedures to assure the potential consequences are not significantly increased. This control method has been previously determined to be acceptable as indicated in NRC Generic Letter No. 91-04. The proposed change does not affect the availability of equipment or systems required to mitigate the consequences of an accident because of the availability of redundant systems or equipment. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 31 of 36 Attachment 1, Volume 2, Rev. 0, Page 32 of 38

Attachment 1, Volume 2, Rev. 0, Page 33 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change involves the deletion of the requirement to perform Surveillance Requirements while in a shutdown condition, but does not change the method of performance. The appropriate plant conditions for performance of the Surveillance will continue to be controlled in plant procedures to assure the possibility of a new or different kind of accident are not created. The control method has been previously determined to be acceptable as indicated in NRC Generic Letter No. 91-04. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change involves the deletion of the requirement to perform Surveillance Requirements while in a shutdown condition. However, the appropriate plant conditions for performance of the Surveillance will continue to be controlled in plant procedures. The control method has been previously determined to be acceptable as indicated in NRC Generic Letter No. 91-04.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Page 32 of 36 Attachment 1, Volume 2, Rev. 0, Page 33 of 38

Attachment 1, Volume 2, Rev. 0, Page 34 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 13 ADDITION OF LCO 3.0.4 EXCEPTION CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes to the Current Technical Specifications (CTS) involve the addition of an allowance to permit a MODE change while relying on the ACTIONS of a Specification.

The CTS precludes a change in MODES while relying on the ACTIONS of a Specification. The ITS includes an exception that will allow MODE changes while relying on the ACTIONS of a Specification. The allowance to enter a MODE or other specified condition in the Applicability with the Limiting Condition for Operation (LCO) not met is acceptable because other redundant components are OPERABLE or the ACTIONS provide appropriate compensatory measures which protect the safety functions affected by the LCO not being met. In addition, the allowed out of service time of the inoperable component for which the allowance will be used is usually 30 days. In such a condition, allowing the unit to enter a MODE or other specified condition in which the LCO is applicable will have no detrimental effect on safety. These changes are made to conform with NUREG-1431, and have been evaluated to not be detrimental to plant safety.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves the addition of an allowance to permit a MODE change while relying on the ACTIONS of a Specification. The equipment affected is not considered to be an initiator for any previously evaluated accident.

Consequently, the probability of an accident previously evaluated is not significantly increased. Similar equipment will remain OPERABLE, consistent with the allowances if the equipment were found to be inoperable while in the MODE or other specified condition in the Applicability. Alternately, the ACTIONS will provide adequate compensatory measures to compensate for the inoperability. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Page 33 of 36 Attachment 1, Volume 2, Rev. 0, Page 34 of 38

Attachment 1, Volume 2, Rev. 0, Page 35 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES The proposed change involves the addition of an allowance to permit a MODE change while relying on the ACTIONS of a Specification. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change involves the addition of an allowance to permit a MODE change while relying on the ACTIONS of a Specification. Similar equipment will remain OPERABLE, consistent with the allowances if the equipment were found to be inoperable while in the MODE or other specified condition in the Applicability. Alternately, the ACTIONS will provide adequate compensatory measures to compensate for the inoperability. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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Attachment 1, Volume 2, Rev. 0, Page 36 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES - CATEGORY 14 CHANGING INSTRUMENTATION ALLOWABLE VALUES CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Rev. 2.

Some of the proposed changes to the Current Technical Specifications (CTS) involve a change to the Allowable Values for Technical Specification instrumentation.

The proposed changes in selected Allowable Values for the instrumentation included in Section 3.3 of the ITS are the result of application of the AEP Instrument Setpoint Methodology (EG-IC-004, "Instrument Setpoint Uncertainty," Rev. 4). This methodology incorporates the guidance of ANSI/ISA S67.04-Part I-1994 and RP67.04-Part II-1994.

Application of this methodology results in instrumentation selected Allowable Values that more accurately reflect total instrumentation loop accuracy as well as that of test equipment and setpoint drift between Surveillances.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change involves the change in selected Allowable Values for the instrumentation included in Section 3.3 of the ITS. The proposed changes will not result in any hardware changes. The instrumentation included in the proposed Section 3.3 of the ITS is not assumed to be an initiator of any analyzed event. Existing operating margin between plant conditions and actual plant setpoints is not significantly reduced due to this proposed change. As a result, the proposed change will not result in unnecessary plant transients. The role of the instrumentation included in Section 3.3 of the ITS is in mitigating and thereby limiting the consequences of accidents. The Allowable Values have been developed to ensure that the design and safety analyses limits will be satisfied.

The methodology used for the development of the Allowable Values ensures that the affected instrumentation remains capable of mitigating design basis events as described in the safety analyses, and that the results and consequences described in the safety analyses remain bounding. Additionally, the proposed change does not alter the ability of the instrumentation and associated systems and components to detect and mitigate events. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

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Attachment 1, Volume 2, Rev. 0, Page 37 of 38 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS GENERIC CHANGES The proposed changes are the result of application of the AEP Instrumentation Setpoint Methodology, and do not create the possibility of a new or different kind of accident from any accident previously evaluated. This is based on the fact that the method and manner of plant operation is unchanged. The use of the proposed Allowable Values does not impact safe operation of the plant, in that the safety analyses limits will be maintained. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). These Allowable Values were developed using a methodology to ensure the affected instrumentation and associated systems and components remain capable of mitigating accidents and transients. Plant equipment will not be operated in a manner different from previous operation, except that setpoint may be changed. Since operational methods remain unchanged, and the existing operating parameters have been evaluated to maintain the unit within existing design basis criteria, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change does not involve a reduction in a margin of safety. The proposed changes have been developed using a methodology to ensure safety analyses limits are not exceeded. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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Attachment 1, Volume 2, Rev. 0, Page 38 of 38 ENVIRONMENTAL ASSESSMENT I&M has evaluated this license amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. I&M has determined that this license amendment meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9). This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50, that changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or that changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria.

(i) The amendment involves no significant hazards consideration.

As demonstrated in the generic and specific Determination of No Significant Hazards Considerations, this proposed amendment does not involve a significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed amendment does not affect the generation of any radioactive effluents, and does not affect any of the permitted effluent release paths.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

No new effluents or effluent release paths are created by the proposed amendment.

Therefore, pursuant to 10 CFR 51.22 (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

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