ML041200307

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 3, Rev 0, ITS Chapter 1.0 Use and Application.

ML041200307
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: ML041200307 (105)

Text

Attachment 1, Volume 3, Rev. 0, Page 1 of 105 VOLUME 3 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 1.0 USE AND APPLICATION Revision 0 Attachment 1, Volume 3, Rev. 0, Page 1 of 105

Attachment 1, Volume 3, Rev. 0, Page 2 of 105 LIST OF ATTACHMENTS

1. ITS Chapter 1.0 Attachment 1, Volume 3, Rev. 0, Page 2 of 105

, Volume 3, Rev. 0, Page 3 of 105 ATTACHMENT 1 ITS Chapter 1.0, Use and Application , Volume 3, Rev. 0, Page 3 of 105

, Volume 3, Rev. 0, Page 4 of 105 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 3, Rev. 0, Page 4 of 105

Attachment 1, Volume 3, Rev. 0, Page 5 of 105 ITS Chapter 1.0 A.1 ITS 1.0 USE AND APPLICATION 1 A.1 1.1 NOTE:

A.1 and Bases (RTP)

RTP A.1 moved from A.1 with fuel in Table 1.1 S , -1 the reactor INSERT 1 A.2 vessel S

A.1 INSERT 2 safety A.3 and when A.1 and

, and al or A.4 specified A.3 safety Page 1 of 35 Attachment 1, Volume 3, Rev. 0, Page 5 of 105

Attachment 1, Volume 3, Rev. 0, Page 6 of 105 ITS Chapter 1.0 A.2 INSERT 1

, and reactor vessel head closure bolt tensioning A.1 INSERT 2 that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times Insert Page 1-1 Page 2 of 35 Attachment 1, Volume 3, Rev. 0, Page 6 of 105

Attachment 1, Volume 3, Rev. 0, Page 7 of 105 ITS Chapter 1.0 A.1 ITS A.5 See ITS 3.6.1 See ITS 3.6.1 See ITS 3.6.2 See ITS 3.6.1 1.1 that in A.1 INSERT 3 A.6 means of A.1 A.1 A.1 to Page 3 of 35 Attachment 1, Volume 3, Rev. 0, Page 7 of 105

Attachment 1, Volume 3, Rev. 0, Page 8 of 105 ITS Chapter 1.0 A.6 INSERT 3 all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

Insert Page 1-2 Page 4 of 35 Attachment 1, Volume 3, Rev. 0, Page 8 of 105

Attachment 1, Volume 3, Rev. 0, Page 9 of 105 ITS Chapter 1.0 A.1 ITS OPERATIONAL 1.1 (COT)

COT A.1 INSERT 4 A.7 or actual L.1 INSERT 5 L.2 A.8 S

(SDM) A.1 SDM subcritical control (RCCAs)

A.1

a.

RCCA

, INSERT 6 A.9 LEAKAGE a.

A.10 1.

that from is A.1 INSERT 7 collection systems or s

2. A.10 A.1 (RCS) (SG) 3.

A.10

b. INSERT 8 All A.1

and Page 5 of 35 Attachment 1, Volume 3, Rev. 0, Page 9 of 105

Attachment 1, Volume 3, Rev. 0, Page 10 of 105 ITS Chapter 1.0 A.7 INSERT 4 of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps.

L.2 INSERT 5 fuel, sources, or reactivity control components, A.9 INSERT 6 With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and

b. In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

A.10 INSERT 7 (except reactor coolant pump (RCP) seal water injection or leakoff),

A.10 INSERT 8 (except RCP seal water injection or leakoff) that Insert Page 1-3 Page 6 of 35 Attachment 1, Volume 3, Rev. 0, Page 10 of 105

Attachment 1, Volume 3, Rev. 0, Page 11 of 105 ITS Chapter 1.0 A.1 ITS 1.1 A.10

c. SG A.1 RCS

, n A.10 (QPTR)

A.1 QPTR See ITS 3.2.4 microcuries A.1 that A.1 INSERT 8a AEC, 1962, those listed in , . NRC, Table E-7 of L.4 INSERT 9 A.11 Page 7 of 35 Attachment 1, Volume 3, Rev. 0, Page 11 of 105

Attachment 1, Volume 3, Rev. 0, Page 12 of 105 ITS Chapter 1.0 L.4 INSERT 8a

, or those listed in ICRP 30, Supplement to Part 1, page 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

A.11 INSERT 9 the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

Insert Page 1-4 Page 8 of 35 Attachment 1, Volume 3, Rev. 0, Page 12 of 105

Attachment 1, Volume 3, Rev. 0, Page 13 of 105 ITS Chapter 1.0 A.1 ITS A.12 (RTS)

RTS that 1.1 A.1 INSERT 10 A.13 (ESF)

ESF L.3 A.1 INSERT 11 A.13 (AFD)

AFD L.3 A.1 U

These tests are: , Initial Tests and Operation, b.

. A.1

a. c.  ;

Nuclear Regulatory A.1 A.5 Page 9 of 35 Attachment 1, Volume 3, Rev. 0, Page 13 of 105

Attachment 1, Volume 3, Rev. 0, Page 14 of 105 ITS Chapter 1.0 INSERT 10 The response time may be measured by means of any series of sequential, overlapping, A.13 or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC. L.3 INSERT 11 The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, A.13 response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC. L.3 Insert Page 1-5 Page 10 of 35 Attachment 1, Volume 3, Rev. 0, Page 14 of 105

Attachment 1, Volume 3, Rev. 0, Page 15 of 105 ITS Chapter 1.0 A.1 ITS See CTS 6.0 A.1 See ITS 5.5 A.5 A.5 A.5 A.5 Page 11 of 35 Attachment 1, Volume 3, Rev. 0, Page 15 of 105

Attachment 1, Volume 3, Rev. 0, Page 16 of 105 ITS Chapter 1.0 A.1 ITS A.5 A.5 A.5 A.5 cycle specific parameter 1.1 A.1 5.6.5 parameter (TADOT) INSERT 12 A.14 TADOT A.1 the TADOT so INSERT 13 A.14 necessary INSERT 14 A.15 Page 12 of 35 Attachment 1, Volume 3, Rev. 0, Page 16 of 105

Attachment 1, Volume 3, Rev. 0, Page 17 of 105 ITS Chapter 1.0 A.14 INSERT 12 all devices in the channel required for trip actuating device OPERABILITY A.14 INSERT 13 The TADOT may be performed by means of any series of sequential, overlapping, or total channel steps.

A.15 INSERT 14 ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing all master relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required master relay. The MASTER RELAY TEST shall include a continuity check of each associated required slave relay. The MASTER RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Insert Page 1-7 Page 13 of 35 Attachment 1, Volume 3, Rev. 0, Page 17 of 105

Attachment 1, Volume 3, Rev. 0, Page 18 of 105 ITS Chapter 1.0 A.1 ITS Table A.1 1.1-1 (a) REACTOR A.1 TITLE (°F)

A.1 NA A.16 NA NA A.1 (b) NA A.16 A.1 (b)

NA A.2 (c) NA NA NA A.1 A.16 closure bolts less (a) than fully tensioned LA.1 (c) A.2 One or more Moved to definition of MODE, page 1 of 35 (b) All reactor vessel head closure bolts fully tensioned. A.2 Page 14 of 35 Attachment 1, Volume 3, Rev. 0, Page 18 of 105

Attachment 1, Volume 3, Rev. 0, Page 19 of 105 ITS Chapter 1.0 A.1 ITS A.12 Add proposed ITS Sections 1.2 - Logical Connectors A.17 1.3 - Completion Times 1.4 - Frequency Page 15 of 35 Attachment 1, Volume 3, Rev. 0, Page 19 of 105

Attachment 1, Volume 3, Rev. 0, Page 20 of 105 ITS Chapter 1.0 A.1 ITS See ITS 3.1.1 See ITS 1.1 3.1.4 A.9 See ITS 3.1.6 See ITS 3.1.1 See ITS 3.1.1 Page 16 of 35 Attachment 1, Volume 3, Rev. 0, Page 20 of 105

Attachment 1, Volume 3, Rev. 0, Page 21 of 105 ITS Chapter 1.0 A.1 ITS See ITS 3.1.1 See ITS 3.1.4 1.1 A.9 See ITS 3.1.1 Page 17 of 35 Attachment 1, Volume 3, Rev. 0, Page 21 of 105

Attachment 1, Volume 3, Rev. 0, Page 22 of 105 ITS Chapter 1.0 A.1 ITS 1.0 USE AND APPLICATION A.1 1

1.1 NOTE:

A.1 and Bases (RTP)

RTP A.1 A.1 with fuel in moved from

, A.2 INSERT 1 the reactor Table 1.1 A.1 -1 vessel S

A.1 INSERT 2 A.3

, safety and and when A.1

, specified

, and safety or A.4 A.3 Page 18 of 35 Attachment 1, Volume 3, Rev. 0, Page 22 of 105

Attachment 1, Volume 3, Rev. 0, Page 23 of 105 ITS Chapter 1.0 A.2 INSERT 1

, and reactor vessel head closure bolt tensioning A.1 INSERT 2 that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times Insert Page 1-1 Page 19 of 35 Attachment 1, Volume 3, Rev. 0, Page 23 of 105

Attachment 1, Volume 3, Rev. 0, Page 24 of 105 ITS Chapter 1.0 A.1 ITS A.5 See ITS 3.6.1 See ITS 3.6.1 See ITS 3.6.2 See ITS 3.6.1 See ITS 3.6.1 that in 1.1 A.1 INSERT 3 A.6 means of A.1 A.1 A.1 to Page 20 of 35 Attachment 1, Volume 3, Rev. 0, Page 24 of 105

Attachment 1, Volume 3, Rev. 0, Page 25 of 105 ITS Chapter 1.0 A.6 INSERT 3 all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel Insert Page 1-2 Page 21 of 35 Attachment 1, Volume 3, Rev. 0, Page 25 of 105

Attachment 1, Volume 3, Rev. 0, Page 26 of 105 ITS Chapter 1.0 A.1 ITS L.1 OPERATIONAL 1.1 (COT)

COT A.1 or actual INSERT 4 A.7 A.18 INSERT 5 L.2 A.8 S

(SDM) A.1 SDM control (RCCAs)

a. A.1 RCCA

, INSERT 6 A.9 LEAKAGE a.

A.10 1

that from is A.1 collection systems or S INSERT 7 2 A.10 (RCS) (SG) A.1 3

Page 22 of 35 Attachment 1, Volume 3, Rev. 0, Page 26 of 105

Attachment 1, Volume 3, Rev. 0, Page 27 of 105 ITS Chapter 1.0 A.7 INSERT 4 of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps.

L.2 INSERT 5 fuel, sources, or reactivity control components, A.9 INSERT 6 With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and

b. In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

A.10 INSERT 7 (except reactor coolant pump (RCP) seal water injection or leakoff),

Insert Page 1-3 Page 23 of 35 Attachment 1, Volume 3, Rev. 0, Page 27 of 105

Attachment 1, Volume 3, Rev. 0, Page 28 of 105 ITS Chapter 1.0 A.1 ITS A.10 1.1 b. INSERT 8 All A.1

and A.10

c. SG A.1 RCS

, n A.10 (QPTR)

QPTR A.1 See ITS 3.2.4 microcuries A.1 that A.1 INSERT 8a AEC, 1962, those listed in , NRC, Table E-7 of L.4 Page 24 of 35 Attachment 1, Volume 3, Rev. 0, Page 28 of 105

Attachment 1, Volume 3, Rev. 0, Page 29 of 105 ITS Chapter 1.0 A.10 INSERT 8 (except RCP seal water injection or leakoff) that L.4 INSERT 8a

, or those listed in ICRP 30, Supplement to Part 1, page 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

Insert Page 1-4 Page 25 of 35 Attachment 1, Volume 3, Rev. 0, Page 29 of 105

Attachment 1, Volume 3, Rev. 0, Page 30 of 105 ITS Chapter 1.0 A.1 ITS 1.1 INSERT 9 A.11 A.12 (RTS)

RTS that INSERT 10 A.13 (ESF)

ESF L.3 A.1 A.13 INSERT 11

, L.3 (AFD)

AFD A.1 Page 26 of 35 Attachment 1, Volume 3, Rev. 0, Page 30 of 105

Attachment 1, Volume 3, Rev. 0, Page 31 of 105 ITS Chapter 1.0 A.11 INSERT 9 the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

INSERT 10 The response time may be measured by means of any series of sequential, overlapping, A.13 or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC. L.3 INSERT 11 The response time may be measured by means of any series of sequential, overlapping, A.13 or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

L.3 Insert Page 1-5 Page 27 of 35 Attachment 1, Volume 3, Rev. 0, Page 31 of 105

Attachment 1, Volume 3, Rev. 0, Page 32 of 105 ITS Chapter 1.0 A.1 ITS U

1.1 These tests are: , Initial Tests and Operation, b.

. A.1

a. c.  ;

Nuclear Regulatory A.1 A.5 See CTS 6.0 Page 28 of 35 Attachment 1, Volume 3, Rev. 0, Page 32 of 105

Attachment 1, Volume 3, Rev. 0, Page 33 of 105 ITS Chapter 1.0 A.1 ITS A.1 See ITS 5.5 A.5 A.5 A.5 A.5 Page 29 of 35 Attachment 1, Volume 3, Rev. 0, Page 33 of 105

Attachment 1, Volume 3, Rev. 0, Page 34 of 105 ITS Chapter 1.0 A.1 ITS A.5 A.5 A.5 A.5 cycle specific parameter 1.1 A.1 5.6.5 parameter (TADOT)

INSERT 12 A.14 TADOT the A.1 TADOT so INSERT 13 A.14 necessary INSERT 14 A.15 Page 30 of 35 Attachment 1, Volume 3, Rev. 0, Page 34 of 105

Attachment 1, Volume 3, Rev. 0, Page 35 of 105 ITS Chapter 1.0 A.14 INSERT 12 all devices in the channel required for trip actuating device OPERABILITY A.14 INSERT 13 The TADOT may be performed by means of any series of sequential, overlapping, or total channel steps.

A.15 INSERT 14 ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing all master relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required master relay. The MASTER RELAY TEST shall include a continuity check of each associated required slave relay. The MASTER RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Insert Page 1-8 Page 31 of 35 Attachment 1, Volume 3, Rev. 0, Page 35 of 105

Attachment 1, Volume 3, Rev. 0, Page 36 of 105 ITS Chapter 1.0 A.1 ITS Table 1.1-1 REACTOR (a)

A.1 TITLE (°F)

A.1 NA NA A.16 NA A.1 (b) NA A.16 A.1 (b)

NA A.2 (c) NA NA NA A.1 A.16 closure bolts less (a) than fully tensioned LA.1 (c)

A.2 One or more Moved to definition of MODE, page 18 of 35 (b) All reactor vessel head closure bolts fully tensioned. A.2 Page 32 of 35 Attachment 1, Volume 3, Rev. 0, Page 36 of 105

Attachment 1, Volume 3, Rev. 0, Page 37 of 105 ITS Chapter 1.0 A.1 ITS A.12 Add proposed ITS Sections 1.2 - Logical Connectors A.17 1.3 - Completion Times 1.4 - Frequency Page 33 of 35 Attachment 1, Volume 3, Rev. 0, Page 37 of 105

Attachment 1, Volume 3, Rev. 0, Page 38 of 105 ITS Chapter 1.0 A.1 ITS See ITS 3.1.1 See ITS 3.1.4 1.1 A.9 See ITS 3.1.6 See ITS 3.1.1 See ITS 3.1.1 Page 34 of 35 Attachment 1, Volume 3, Rev. 0, Page 38 of 105

Attachment 1, Volume 3, Rev. 0, Page 39 of 105 ITS Chapter 1.0 A.1 ITS See ITS 3.1.1 See ITS 1.1 3.1.4 A.9 See ITS 3.1.1 Page 35 of 35 Attachment 1, Volume 3, Rev. 0, Page 39 of 105

Attachment 1, Volume 3, Rev. 0, Page 40 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS Section 1.0 and Table 1.1, "OPERATIONAL MODES," provide a description of the MODES. ITS Section 1.1 and Table 1.1-1, "MODES," changes the CTS MODE definitions in several ways:

• The phrase "Reactor vessel head unbolted or removed" in CTS Table 1.1 Note ** is replaced with "One or more reactor vessel head closure bolts less than fully tensioned" in ITS Table 1.1-1 Note c.

This change is acceptable because the revised phrase is consistent with the current interpretation and usage. MODE 6 is currently declared when the first vessel head closure bolt is detensioned. This change also eliminates a redundant phrase. The reactor vessel head cannot be removed unless the reactor vessel head closure bolts are unbolted.

Since reactor vessel head unbolted is already specified in the CTS Note, including or removed is unnecessary.

• The CTS Table 1.1 Note ** condition "fuel in the vessel" is moved to the ITS MODE definition.

This change is acceptable because it moves information within the Technical Specifications with no change in intent. Each MODE in the Table includes fuel in the vessel.

• ITS Table 1.1-1 contains a new Note b, which applies to MODES 4 and 5.

Note b states "All reactor vessel head closure bolts fully tensioned." This Note is the opposite of CTS Note ** and ITS Table 1.1-1 Note c.

This change is acceptable because it avoids a conflict between the definition of MODE 6 and the other MODES should RCS temperature increase above the CTS MODE 6 temperature limit while a reactor vessel head closure bolt is less than fully tensioned. This ITS Note is included only for clarity. It is consistent with the current use of MODES 4 and 5 and does not result in any technical change to the application of the MODES.

• For consistency with the Notes in ITS Table 1.1-1, the ITS definition of MODE adds "reactor vessel head closure bolt tensioning" to the list of characteristics that define a MODE. Currently, the CTS definition does not include this clarification.

CNP Units 1 and 2 Page 1 of 23 Attachment 1, Volume 3, Rev. 0, Page 40 of 105

Attachment 1, Volume 3, Rev. 0, Page 41 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION This change is acceptable because the definition of MODE should be consistent with the MODE table in order to avoid confusion. This change is made only for consistency and results in no technical changes to the Technical Specifications.

These changes are designated as administrative because they clarify the application of the MODES and no technical changes to the MODE definitions are made. The clarifications are consistent with the current use and application of the MODES.

A.3 The CTS Section 1.0 definition of OPERABLE-OPERABILITY requires a system, subsystem, train, component or device to be capable of performing its "specified function(s)" and all necessary support systems to also be capable of performing their "function(s)." The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires the system, subsystem, train, component, or device to be capable of performing the "specified safety function(s)," and requires all necessary support systems that are required for the system, subsystem, train, component, or device to perform its "specified safety function(s)" to also be capable of performing their related support functions. This changes the CTS by altering the requirement to be able to perform "functions" to a requirement to be able to perform "safety functions."

The purpose of the CTS and ITS definitions of OPERABLE-OPERABILITY is to ensure that the safety analysis assumptions regarding equipment and variables are valid. This change is acceptable because the intent of both the CTS and ITS definitions is to address the safety function(s) assumed in the accident analysis and not encompass other non-safety functions a system may also perform.

These non-safety functions are not assumed in the safety analysis and are not needed in order to protect the public health and safety. This change is consistent with the current interpretation and use of the terms OPERABLE and OPERABILITY. This change is designated as administrative as it does not change the current use and application of the Technical Specifications.

A.4 The CTS Section 1.0 definition of OPERABLE-OPERABILITY requires that all necessary normal and emergency electrical power sources be available for the system, subsystem, train, component, or device to be OPERABLE. The ITS Section 1.1 definition of OPERABLE-OPERABILITY will replace the phrase "normal and emergency electrical power sources" with "normal or emergency electrical power sources." This changes the CTS definition of OPERABLE-OPERABILITY by allowing a device to be considered OPERABLE with either normal or emergency power available.

The OPERABILITY requirements for normal and emergency power sources are clearly addressed in CTS 3.0.5. These requirements allow only the normal or the emergency electrical power source to be OPERABLE, provided its redundant system(s), subsystem(s), train(s), component(s), and device(s) (redundant to the systems, subsystems, trains, components, and devices with an inoperable power source) are OPERABLE. This effectively changes the current "and" to an "or."

The existing requirements (CTS 3.0.5) are incorporated into ITS 3.8.1 ACTIONS for when a normal (offsite) or emergency (diesel generator) power source is inoperable. Therefore, the ITS definition now uses the word "or" instead of the CNP Units 1 and 2 Page 2 of 23 Attachment 1, Volume 3, Rev. 0, Page 41 of 105

Attachment 1, Volume 3, Rev. 0, Page 42 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION current word "and." In ITS 3.8.1, new times are provided to perform the determination of OPERABILITY of the redundant systems, et. al. This change is discussed in the Discussion of Changes (DOCs) for ITS 3.8.1. This change is designated administrative since the ITS definition is effectively the same as the CTS definition.

A.5 CTS Section 1.0 includes the following definitions:

• ALLOWABLE POWER LEVEL

• CONTAINMENT INTEGRITY

• GASEOUS RADWASTE TREATMENT SYSTEM

• MEMBER(S) OF THE PUBLIC

• PURGE - PURGING

• REPORTABLE EVENT

• SITE BOUNDARY

• SOURCE CHECK

• UNRESTRICTED AREA

• VENTILATION EXHAUST TREATMENT SYSTEM

• VENTING The ITS does not use this terminology and ITS Section 1.1 does not contain these definitions.

These changes are acceptable because the terms are not used as defined terms in the ITS. Discussions of any technical changes related to the deletion of these terms are included in the DOCs for the CTS sections in which the terms are used. These changes are designated as administrative because they eliminate defined terms that are no longer used.

A.6 The CTS defines a CHANNEL CALIBRATION as "the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated." ITS defines a CHANNEL CALIBRATION as "the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps." This results in a number of changes to the CTS.

• The CTS definition states, "The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip CNP Units 1 and 2 Page 3 of 23 Attachment 1, Volume 3, Rev. 0, Page 42 of 105

Attachment 1, Volume 3, Rev. 0, Page 43 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION functions." The ITS states, "The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY."

This change is acceptable because the statements are equivalent in that both require that all needed portions of the channel be tested. The ITS definition reflects the CTS understanding that the CHANNEL CALIBRATION includes only those portions of the channel needed to perform the safety function.

• The CTS states that the CHANNEL CALIBRATION "shall include the CHANNEL FUNCTIONAL TEST." The ITS does not include this statement.

This change is acceptable because the eliminated CTS statement does not add any requirements. In both the CTS and the ITS, performance of a single test that fully meets the requirements of other tests can be credited for satisfying the other tests.

• The ITS adds the statement, "Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel."

The purpose of a CHANNEL CALIBRATION is to adjust the channel output so that the channel responds within the necessary range and accuracy to known values of the parameters that the channel monitors.

This change is acceptable because resistance temperature detectors and thermocouples are designed such that they have a fixed input/output response, which cannot be adjusted or changed once installed.

Calibration of a channel containing an RTD or thermocouple is performed by applying the RTD or thermocouple fixed input/output relationship to the remainder of the channel, and making the necessary adjustments to the adjustable devices in the remainder of the channel to obtain the necessary output range and accuracy. Therefore, unlike other sensors, an RTD or thermocouple is not actually calibrated. The ITS CHANNEL CALIBRATION allowance for channels containing RTDs and thermocouples is consistent with the CTS calibration practices of these channels. This information is included in the ITS to avoid confusion, but does not change the current CHANNEL CALIBRATION practices for these types of channels.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A.7 CTS Section 1.0 defines CHANNEL FUNCTIONAL TEST as "the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions." ITS Section 1.1 renames the CTS definition to CHANNEL OPERATIONAL TEST (COT), and defines it as "the injection of a simulated or actual signal into the channel as CNP Units 1 and 2 Page 4 of 23 Attachment 1, Volume 3, Rev. 0, Page 43 of 105

Attachment 1, Volume 3, Rev. 0, Page 44 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps." The addition of use of an actual signal is discussed in DOC L.1. This changes the CTS by stating that the COT shall include adjustments, as necessary, of the devices in the channel so that the setpoints are within the required range and accuracy, changes the example list of devices contained in the definition, and states that the test may be performed by means of any series of sequential, overlapping, or total channel steps.

• The CTS definition states that the CHANNEL FUNCTIONAL TEST shall verify that the channel is OPERABLE "including alarm and/or trip functions." The ITS states that the COT shall verify OPERABILITY of "all devices in the channel required for channel OPERABILITY."

This change is acceptable because the statements are equivalent in that both require that the channel be verified to be OPERABLE. The CTS and the ITS use different examples of what is included in a channel, but this does not change the intent of the requirement. The ITS use of the phrase "all devices in the channel required for channel OPERABILITY" reflects the CTS understanding that the test includes only those portions of the channel needed to perform the safety function.

• The ITS states "The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy."

This change is acceptable because it clarifies that adjustments performed during a COT do not invalidate the test. This is consistent with the current implementation of the CHANNEL FUNCTIONAL TEST and does not result in a technical change to the Technical Specifications.

• The ITS states "The COT may be performed by means of any series of sequential, overlapping, or total channel steps."

This change is acceptable because it states current Industry practice.

This is consistent with the current implementation of the CHANNEL FUNCTIONAL TEST and does not result in a technical change to the Technical Specifications.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A.8 CTS Section 1.0 provides a definition of CORE ALTERATION. The ITS Section 1.1 definition of CORE ALTERATION revises the CTS definition to eliminate two redundant phrases.

CNP Units 1 and 2 Page 5 of 23 Attachment 1, Volume 3, Rev. 0, Page 44 of 105

Attachment 1, Volume 3, Rev. 0, Page 45 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION The CTS definition includes "movement or manipulation" of any component within the reactor pressure vessel. The ITS definition of CORE ALTERATION will only include "movement" of components, not "manipulation."

This change is acceptable because the eliminated phrase adds no value.

In the context of this definition, any manipulation of a component will involve its movement, so stating "movement or manipulation" is redundant and potentially confusing.

• The CTS definition does not preclude completion of movement of a component to a "safe conservative" position. The ITS definition specifies only a "safe" position.

This change is acceptable because the eliminated phrase adds no value.

The Technical Specifications provide no basis for determining whether a movement is conservative, so it is assumed that the word "conservative" is used in the definition to mean "safe." Therefore, stating "safe conservative" is repetitious and potentially confusing.

These changes are designated administrative because they represent the elimination of redundant words and phrases without changing the intent of the definition.

A.9 CTS Section 1.0 provides a definition of SHUTDOWN MARGIN (SDM). CTS 4.1.1.1.1.a and CTS 4.1.1.2.a provide an exception to the SDM definition, such that if a control rod is inoperable due to being immovable or untrippable, the SDM is modified (increased) by the worth of the inoperable rod. The ITS Section 1.1 definition of SDM contains two differences from the CTS definition.

• The CTS definition is changed to indicate that the worth of any Rod Control Cluster Assemblies (RCCAs) which are not capable of being fully inserted must be accounted for in the determination of the SDM.

Currently, this requirement is not in the CTS.

This change is acceptable because it is consistent with the existing SDM requirements in CTS 3.1.1.1 and 3.1.1.2.

• The CTS definition is clarified to include a description of the reactor fuel and moderator temperature conditions (i.e., nominal zero power level) at which the SDM is calculated when in MODE 1 or 2.

This change is acceptable because including this information is not a technical change. SDM calculations are currently performed for nominal zero power conditions.

These changes are designated as administrative because they do not represent a technical change to the Technical Specifications.

A.10 CTS Section 1.0 provides definitions for CONTROLLED LEAKAGE, IDENTIFIED LEAKAGE, PRESSURE BOUNDARY LEAKAGE, and UNIDENTIFIED CNP Units 1 and 2 Page 6 of 23 Attachment 1, Volume 3, Rev. 0, Page 45 of 105

Attachment 1, Volume 3, Rev. 0, Page 46 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION LEAKAGE. ITS Section 1.1 includes these requirements in one definition called LEAKAGE (which includes three categories: identified LEAKAGE, unidentified LEAKAGE, and pressure boundary LEAKAGE). This changes the CTS by incorporating the definitions into the ITS LEAKAGE definition with no technical changes. The CTS term CONTROLLED LEAKAGE, which is the seal water flow supplied to the reactor coolant pump seals, is no longer considered leakage and has its own specification titled "Seal Injection Flow" as ITS 3.5.5. Since seal injection flow is no longer considered leakage, it appears as an exception in the CTS definitions of IDENTIFIED LEAKAGE and UNIDENTIFIED LEAKAGE. As a result, the ITS will not contain a defined term, "CONTROLLED LEAKAGE."

This change is acceptable because it results in no technical changes to the Technical Specifications. This change is designated an administrative change in that it rearranges existing definitions, with no change in intent.

A.11 The CTS Section 1.0 definition of STAGGERED TEST BASIS states, "A STAGGERED TEST BASIS shall consist of: a. A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals, b. The testing of one system, subsystem, train or other designated component at the beginning of each subinterval." The ITS Section 1.1 definition states, "A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function." This changes the CTS to specify the frequency of a Surveillance on one system, subsystem, train, or other designated component in the Frequency column of the ITS instead of specifying the frequency in which all systems, subsystems, trains, or other designated components must be tested.

This change is acceptable because the testing frequency of components on a STAGGERED TEST BASIS is not changed. Unlike the CTS definition, the ITS definition allows the Surveillance interval for one subsystem to be specified in the Frequency column of the applicable Surveillance Requirements, independent of the number of subsystems. As an example, consider a three channel system tested on a STAGGERED TEST BASIS. The CTS would specify testing every three months on a STAGGERED TEST BASIS, which results in one channel being tested each month (three equal subintervals). Under the ITS definition, the Surveillance Frequency would be monthly on a STAGGERED TEST BASIS and, one channel would also be tested each month. In both the CTS and ITS definitions, all channels are tested every three months. Each test under the CTS definition would be performed at the beginning of the subinterval. Under the ITS definition, each Surveillance Frequency starts at the beginning of the CTS definition subinterval. Thus, there are no net changes in the testing interval. This change represents an editorial preference in the ITS. This change is designated as administrative as no technical changes are made to the Technical Specifications.

CNP Units 1 and 2 Page 7 of 23 Attachment 1, Volume 3, Rev. 0, Page 46 of 105

Attachment 1, Volume 3, Rev. 0, Page 47 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION A.12 CTS Section 1.0 provides a definition of FREQUENCY NOTATION and includes CTS Table 1.2, which lists these notations. The ITS will not contain this information in Section 1.1, but will state the requirements in each Surveillance.

This change is acceptable because each ITS Surveillance Requirement (SR) provides the specific frequency without relying on a notation (e.g., "31 days" versus "M"). Providing the specific frequencies in the Surveillance Requirements eliminates the need for the FREQUENCY NOTATION definition and CTS Table 1.2. Any Surveillance Frequencies altered by the elimination of the definition and table will be addressed in a DOC for the affected section. This change is designated as administrative because it does not change any SR frequencies.

A.13 CTS Section 1.0 provides definitions of ENGINEERED SAFETY FEATURE RESPONSE TIME and REACTOR TRIP SYSTEM RESPONSE TIME. ITS Section 1.1 modifies the definitions to more fully describe how the tests are performed. The ITS states that the "response time test may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured." Currently, the CTS does not describe this manner of testing.

This change is acceptable because the ITS definitions are consistent with current plant practices. Also, the definitions are consistent with the guidance provided in IEEE 338-1977, Section 6.3.4, "Response Time Verification Tests," although CNP is not committed to this standard. The results of the test are unaffected by this allowance. This change is designated as administrative as it does not result in a technical change to the response time tests.

A.14 The CTS defines TRIP ACTUATING DEVICE OPERATIONAL TEST as "A TRIP ACTUATING DEVICE OPERATIONAL TEST shall consist of operating the Trip Actuating Device and verifying OPERABILITY of alarm, interlock, and/or trip functions. The TRIP ACTUATING DEVICE OPERATIONAL TEST shall include adjustment, as necessary, of the Trip Actuating Device such that it actuates at the required setpoint within the required accuracy." ITS defines TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) as "A TADOT shall consist of operating the trip actuating device and verifying OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. The TADOT shall include adjustment, as necessary, of the trip actuating device such that it actuates at the required setpoint within the required accuracy. The TADOT may be performed by means of any series of sequential, overlapping, or total channel steps." This results in a number of changes to the CTS.

• The CTS definition states that the TRIP ACTUATING DEVICE OPERATIONAL TEST shall "verify OPERABILITY of alarm, interlock, and/or trip functions." The ITS states that the TADOT shall "verify the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY."

This change is acceptable because the statements are equivalent in that both require that all needed portions of the channel to be tested. The ITS definition reflects the CTS understanding that the TRIP ACTUATING CNP Units 1 and 2 Page 8 of 23 Attachment 1, Volume 3, Rev. 0, Page 47 of 105

Attachment 1, Volume 3, Rev. 0, Page 48 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION DEVICE OPERATIONAL TEST includes only those portions of the channel needed to perform the safety function.

• The ITS states, "The TADOT may be performed by means of any series of sequential, overlapping, or total channel steps." Currently, the CTS does not describe this manner of testing.

This change is acceptable because it states current Industry practice.

This is consistent with the current implementation of the TADOT.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A.15 ITS Section 1.1 provides definitions of ACTUATION LOGIC TEST, MASTER RELAY TEST, and SLAVE RELAY TEST. These terms are used as defined terms in the ITS but do not appear in the CTS.

This change is acceptable because these changes do not impose any new requirements or alter existing requirements. Any technical changes due to the addition of these terms and definitions will be addressed in the DOCs for the sections of the Technical Specifications in which the terms are used. These changes are designated as administrative as they add defined terms which involve no technical change to the Technical Specifications.

A.16 CTS Table 1.1, OPERATIONAL MODES, is revised. The corresponding table in ITS Section 1.1 is Table 1.1-1, MODES. The changes to the CTS are:

• The CTS Table 1.1 minimum average reactor coolant temperature for MODES 1 and 2 is changed from 350°F to "NA" (not applicable) in ITS Table 1.1-1.

This change is acceptable because ITS LCO 3.4.2, RCS Minimum Temperature for Criticality, provides the minimum reactor coolant temperature limits for MODES 1 and 2. Therefore, the 350°F minimum temperature does not provide any useful information in ITS Table 1.1-1, and is deleted from the CTS.

• The CTS Table 1.1 MODE 6 upper limit on average reactor coolant temperature (< 140°F) is removed. In ITS Table 1.1-1, the MODE 6 average reactor coolant temperature limit is specified as "NA" (not applicable).

This change is acceptable because it eliminates a conflict in the CTS MODE Table. If the average coolant temperature exceeds the upper limit with the reactor vessel head closure bolts less than fully tensioned, the CTS Table could be misinterpreted as no MODE being applicable. This is not the intent of the CTS or ITS MODE 6 definitions. By removing the temperature reference, this ambiguity is eliminated.

CNP Units 1 and 2 Page 9 of 23 Attachment 1, Volume 3, Rev. 0, Page 48 of 105

Attachment 1, Volume 3, Rev. 0, Page 49 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION

• The CTS Table 1.1 % RATED THERMAL POWER limit of 0% for MODES 3, 4, 5, and 6 is changed in ITS Table 1.1-1 to "NA" (not applicable).

This change is acceptable because the reactivity and plant equipment limitations in MODES 3, 4, 5, and 6 do not allow power operation.

Therefore, it is not necessary to have these restrictions in the MODE Table.

These changes are designated as administrative because they result in no technical changes to the Technical Specifications.

A.17 ITS Sections 1.2, 1.3, and 1.4 contain information that is not in the CTS. This change to the CTS adds explanatory information on ITS usage that is not applicable to the CTS. The added sections are:

• Section 1.2 - Logical Connectors Section 1.2 provides specific examples of the logical connectors "AND" and "OR" and the numbering sequence associated with their use.

• Section 1.3 - Completion Times Section 1.3 provides guidance on the proper use and interpretation of Completion Times. The section also provides specific examples that aid in the use and understanding of Completion Times.

• Section 1.4 - Frequency Section 1.4 provides guidance on the proper use and interpretation of Surveillance Frequencies. The section also provides specific examples that aid in the use and understanding of Surveillance Frequency.

This change is acceptable because it aids in the understanding and use of the format and presentation style of the ITS. The addition of these sections does not add or delete technical requirements, and will be discussed specifically in those Technical Specifications where application of the added sections results in a change. This change is designated as administrative because it does not result in a technical change to the Technical Specifications.

A.18 Unit 2 CTS Section 1.0 includes a CHANNEL FUNCTIONAL TEST definition for bistable channels. The definition of CHANNEL FUNCTIONAL TEST for bistable channels requires "the injection of a simulated signal into the channel sensor to verify OPERABILITY including alarm and/or trip functions. However, this CTS definition is essentially duplicative of the TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) definition. Additionally, this part of the CHANNEL FUNCTIONAL TEST definition is not included in the Unit 1 CTS. ITS Section 1.1 does not include this definition, since the requirements for bistable channels are covered by the TADOT definition.

CNP Units 1 and 2 Page 10 of 23 Attachment 1, Volume 3, Rev. 0, Page 49 of 105

Attachment 1, Volume 3, Rev. 0, Page 50 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION This change is acceptable because the TADOT definition adequately covers bistable channels, and does not impose any new requirements or alter any existing requirements. This change is categorized as administrative because the bistable portion of the definition is duplicative of the TADOT definition.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 1.1, "OPERATIONAL MODES," states that MODE 6 is restricted to reactivity conditions with keff < 0.95. ITS Table 1.1-1, "MODES,"

does not contain this restriction.

This change is acceptable because the core reactivity requirements for MODE 6 are covered in ITS 3.9.1, "Boron Concentration," by requiring the boron concentration in the Reactor Coolant System to be maintained within the limits specified in the COLR. The LCO section of the 3.9.1 Bases states "The boron concentration limit specified in the COLR ensures that a core keff of < 0.95 is maintained during fuel handling operations." Moving this detail from the MODE Table to the LCO 3.9.1 Bases eliminates the potential to misinterpret the MODE table and not apply the MODE 6 requirements if the reactor vessel head closure bolts are less than fully tensioned, fuel is in the reactor vessel, and core reactivity exceeds a keff of 0.95. ITS LCO 3.9.1 will ensure that the appropriate reactivity conditions are maintained in MODE 6, so it is not necessary to have this restriction in the MODE Table in order to provide adequate protection of the public health and safety. Once moved to the Bases, any changes to the core reactivity requirement will be controlled by the Technical Specifications Bases Control Program described in Chapter 5 of the ITS. This change is designated a less restrictive movement of detail because it moves information from the Technical Specifications to the Bases.

LESS RESTRICTIVE CHANGES L.1 The CTS Section 1.0 definition of CHANNEL FUNCTIONAL TEST requires the use of a simulated signal when performing the test. ITS Section 1.1 renames the CTS definition to CHANNEL OPERATIONAL TEST (COT) as discussed in DOC A.7. The ITS Section 1.1 COT definition allows the use of an actual or simulated signal when performing the test. This changes the CTS by allowing the use of unplanned actuations to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

CNP Units 1 and 2 Page 11 of 23 Attachment 1, Volume 3, Rev. 0, Page 50 of 105

Attachment 1, Volume 3, Rev. 0, Page 51 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because it allows an actual signal to be credited for a Surveillance where only a simulated signal was previously allowed.

L.2 The CTS Section 1.0 definition of CORE ALTERATION applies to the movement or manipulation of any component in the reactor vessel with the vessel head removed and fuel in the vessel. The ITS Section 1.1 definition of CORE ALTERATION will only apply to the movement of fuel, sources, or reactivity control components in the reactor vessel. This changes the CTS by eliminating from the definition of CORE ALTERATION the movement of any components in the reactor vessel that are not fuel, sources, or reactivity control components.

The elimination of or manipulation from the definition is discussed in DOC A.8.

The defined term CORE ALTERATION in the ITS is used to prevent a core reactivity excursion. Other accidents which can occur during refueling conditions, such as a fuel handling accident or boron dilution accident, are addressed in the ITS by prohibitions on the movement of irradiated fuel or prohibitions on positive reactivity additions. This change is acceptable because the ITS definition of CORE ALTERATION controls the movement of components such as fuel, sources, and reactivity control components that can affect core reactivity. The CTS definition also prohibits the movement of other equipment such as cameras, thimble plugs, and core internals that have little, if any, effect on core reactivity. Therefore, controlling the movement of those items under the definition of CORE ALTERATION is not necessary. This change is designated as less restrictive because the ITS definition applies in fewer circumstances than does the CTS definition.

L.3 The CTS Section 1.0 definitions of ENGINEERED SAFETY FEATURE RESPONSE TIME and REACTOR TRIP SYSTEM RESPONSE TIME require measurement of the response time from the sensor through the actuated equipment. The ITS definitions of ENGINEERED SAFETY FEATURE (ESF)

RESPONSE TIME and REACTOR TRIP SYSTEM (RTS) RESPONSE TIME are modified to state "In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC." This changes the CTS by eliminating the requirement to include all components in a response time test.

The purpose of response time testing is to ensure that the system response time, from measurement of a parameter to actuation of the appropriate device, is consistent with the assumptions in the safety analyses. WCAP-13632-P-A, Rev. 2, "Elimination of Pressure Sensor Response Time Testing Requirements,"

dated January 1996, justified the elimination of the pressure sensor response time testing requirements and allows the response time for selected components to be verified instead of measured. WCAP-14036-P-A, Rev. 1, "Elimination of Periodic Protection Channel Response Time Tests," provides the basis for using allocated signal processing actuation logic response times in the overall verification of the protection system channel response time. This change is acceptable because the cited Topical Reports have demonstrated that modified CNP Units 1 and 2 Page 12 of 23 Attachment 1, Volume 3, Rev. 0, Page 51 of 105

Attachment 1, Volume 3, Rev. 0, Page 52 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION response time tests will continue to provide assurance that the systems will perform their functions as assumed in the safety analysis. In addition, the Topical Reports have been determined to be applicable to the specific components for which CNP is requesting this allowance.

WCAP-13632-P-A, Rev. 2, contains the technical basis and methodology for eliminating response time testing requirements for pressure and differential pressure sensors identified in the WCAP. The program described in the WCAP utilizes the methods contained in EPRI Report NP-7243, Rev. 1, Investigation of Response Time Testing Requirements, for justifying elimination of response time testing surveillance requirements for certain pressure and differential pressure sensors. The EPRI report justifies the elimination of response time testing based on Failure Modes and Effects Analyses (FMEA) that show that component degradation that impacts pressure and differential pressure sensor response time can be detected in other routine tests such as calibration tests.

The report concludes that response time testing of pressure and differential pressure sensors is redundant to other surveillance requirements such as sensor calibrations. The EPRI report only applied to those specific sensors included in the FMEA.

To address other sensors installed in Westinghouse designed plants, the WCAP contains a similarity analysis to sensors in the EPRI report or a specific FMEA to provide justification for elimination of response time testing requirements for those other sensors. Each pressure and differential pressure sensor that is identified as a candidate for elimination of periodic response time testing requirements is listed in Table 9-1 of the WCAP.

WCAP-13632-P-A, Rev. 2, has been reviewed and evaluated against the actual RTS and Engineered Safety Feature Actuation System (ESFAS) pressure and differential pressure sensors used at CNP to determine applicability. Sensors for the following RTS Functions (as shown in ITS Table 3.3.1-1) have been confirmed to be specifically addressed by WCAP-13632-P-A, and are proposed to have their response times optionally verified in lieu of measurement using the WCAP-13632-P-A methodology:

RTS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.1-1) Instruments Model Number

6. Overtemperature T 1-PT-455, 457, 458 Foxboro (Pressurizer Pressure Input) 2-PT-455, 457, 458 N-E11GM-HIE2-AL

6. Overtemperature T 1-PT-456 Foxboro (Pressurizer Pressure Input) 2-PT-456 N-E11GM-HIE2 8.a. Pressurizer Pressure - Low 1-PT-455, 457, 458 Foxboro 2-PT-455, 457, 458 N-E11GM-HIE2-AL 8.a. Pressurizer Pressure - Low 1-PT-456 Foxboro 2-PT-456 N-E11GM-HIE2 8.b. Pressurizer Pressure - High 1-PT-455, 457, 458 Foxboro 2-PT-455, 457, 458 N-E11GM-HIE2-AL CNP Units 1 and 2 Page 13 of 23 Attachment 1, Volume 3, Rev. 0, Page 52 of 105

Attachment 1, Volume 3, Rev. 0, Page 53 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION RTS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.1-1) Instruments Model Number 8.b. Pressurizer Pressure - High 1-PT-456 Foxboro 2-PT-456 N-E11GM-HIE2

9. Pressurizer Water Level - High 1-LT-459 Foxboro 2-LT-459 N-E13DH-HIH2-AL

9. Pressurizer Water Level - High 1-LT-460, 461 Foxboro 2-LT-460, 461 N-E13DH-HIH2

10. Reactor Coolant Flow - Low 1-FT-414, 415, 416 Foxboro 1-FT-424, 425, 426 E13DH 1-FT-434, 435, 436 1-FT-444, 445, 446 2-FT-414, 415, 416 2-FT-424, 425, 426 2-FT-434, 435, 436 2-FT-444, 445, 446

14. Steam Generator (SG) Water 1-LT-517, 519 Foxboro Level - Low Low 1-LT-527, 528, 529 N-E13DM-H1M2-BL 1-LT-537, 538, 539 1-LT-547, 548, 549 2-LT-517, 518, 519 2-LT-529 2-LT-538, 539 2-LT-547, 548, 549

14. Steam Generator (SG) Water 1-LT-518 Foxboro Level - Low Low N-E13DM-H1M2-AL

14. Steam Generator (SG) Water Foxboro Level - Low Low 2-LT-527, 528 N-E13DM-H1M2 2-LT-537 Sensors for the following ESFAS Functions (as shown in ITS Table 3.3.2-1) have been confirmed to be specifically addressed by WCAP-13632-P-A, and are proposed to have their response times optionally verified in lieu of measurement using the WCAP-13632-P-A methodology:

ESFAS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.2-1) Instruments Model Number 1.c. Safety Injection, 1-PT-934, 935, 936 Foxboro Containment Pressure - High 2-PT-934, 935, 936 E11GM-HSAA1 1.d. Safety Injection, 1-PT-455, 457 Foxboro Pressurizer Pressure - Low 2-PT-455, 457 N-E11GM-HIE2-AL 1.d. Safety Injection, 1-PT-456 Foxboro Pressurizer Pressure - Low 2-PT-456 N-E11GM-HIE2 CNP Units 1 and 2 Page 14 of 23 Attachment 1, Volume 3, Rev. 0, Page 53 of 105

Attachment 1, Volume 3, Rev. 0, Page 54 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION ESFAS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.2-1) Instruments Model Number 1.e.(1)Safety Injection, 1-PT-514, 525, 536, Foxboro Steam Line Pressure - Low 546 N-E11GM-HIE2-B 2-PT-514, 525, 536, 546 2.c. Containment Spray, 1-PT-934, 935, 936, Foxboro Containment Pressure - High 937 E11GM-HSAA1 High 2-PT-934, 935, 936, 937 3.a.(3)Containment Isolation, Phase 1-PT-934, 935, 936 Foxboro A, 2-PT-934, 935, 936 E11GM-HSAA1 SI Input from ESFAS, Containment Pressure - High 3.a.(3)Containment Isolation, Phase 1-PT-455, 457 Foxboro A, 2-PT-455, 457 N-E11GM-HIE2-AL SI Input from ESFAS, Pressurizer Pressure - Low 3.a.(3)Containment Isolation, Phase 1-PT-456 Foxboro A, 2-PT-456 N-E11GM-HIE2 SI Input from ESFAS, Pressurizer Pressure - Low 3.a.(3)Containment Isolation, Phase 1-PT-514, 525, 536, Foxboro A, 546 N-E11GM-HIE2-B SI Input from ESFAS, 2-PT-514, 525, 536, Steam Line Pressure - Low 546 3.b.(3)Containment Isolation, Phase 1-PT-934, 935, 936, Foxboro B, 937 E11GM-HSAA1 Containment Pressure - High 2-PT-934, 935, 936, High 937 4.c. Steam Line Isolation, 1-PT-934, 935, 936, Foxboro Containment Pressure - High 937 E11GM-HSAA1 High 2-PT-934, 935, 936, 937 4.d. Steam Line Isolation, 1-PT-514, 525, 536, Foxboro Steam Line Pressure - Low 546 N-E11GM-HIE2-B 2-PT-514, 525, 536, 546 CNP Units 1 and 2 Page 15 of 23 Attachment 1, Volume 3, Rev. 0, Page 54 of 105

Attachment 1, Volume 3, Rev. 0, Page 55 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION ESFAS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.2-1) Instruments Model Number 5.b. Turbine Trip and Feedwater 1-LT-517, 519 Foxboro Isolation, 1-LT-527, 528, 529 N-E13DM-H1M2-BL Steam Generator (SG) Water 1-LT-537, 538, 539 Level - High High 1-LT-547, 548, 549 2-LT-517, 518, 519 2-LT-529 2-LT-538, 539 2-LT-547, 548, 549 5.b. Turbine Trip and Feedwater 1-LT-518 Foxboro Isolation, N-E13DM-H1M2-AL Steam Generator (SG) Water Level - High High 5.b. Turbine Trip and Feedwater 2-LT-527, 528 Foxboro Isolation, 2-LT-537 N-E13DM-H1M2 Steam Generator (SG) Water Level - High High 5.c. Turbine Trip and Feedwater 1-PT-934, 935, 936 Foxboro Isolation, 2-PT-934, 935, 936 E11GM-HSAA1 SI Input from ESFAS, Containment Pressure - High 5.c. Turbine Trip and Feedwater 1-PT-455, 457 Foxboro Isolation, 2-PT-455, 457 N-E11GM-HIE2-AL SI Input from ESFAS, Pressurizer Pressure - Low 5.c. Turbine Trip and Feedwater 1-PT-456 Foxboro Isolation, 2-PT-456 N-E11GM-HIE2 SI Input from ESFAS, Pressurizer Pressure - Low 5.c. Turbine Trip and Feedwater 1-PT-514, 525, 536, Foxboro Isolation, 546 N-E11GM-HIE2-B SI Input from ESFAS, 2-PT-514, 525, 536, Steam Line Pressure - Low 546 6.c. Auxiliary Feedwater, 1-LT-517, 519 Foxboro Steam Generator (SG) Water 1-LT-527, 528, 529 N-E13DM-H1M2-BL Level - Low Low 1-LT-537, 538, 539 1-LT-547, 548, 549 2-LT-517, 518, 519 2-LT-529 2-LT-538, 539 2-LT-547, 548, 549 6.c. Auxiliary Feedwater, 1-LT-518 Foxboro Steam Generator (SG) Water N-E13DM-H1M2-AL Level - Low Low CNP Units 1 and 2 Page 16 of 23 Attachment 1, Volume 3, Rev. 0, Page 55 of 105

Attachment 1, Volume 3, Rev. 0, Page 56 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION ESFAS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.2-1) Instruments Model Number 6.c. Auxiliary Feedwater, 2-LT-527, 528 Foxboro Steam Generator (SG) Water 2-LT-537 N-E13DM-H1M2 Level - Low Low 6.d. Auxiliary Feedwater, 1-PT-934, 935, 936 Foxboro SI Input from ESFAS, 2-PT-934, 935, 936 E11GM-HSAA1 Containment Pressure - High 6.d. Auxiliary Feedwater, 1-PT-455, 457 Foxboro SI Input from ESFAS, 2-PT-455, 457 N-E11GM-HIE2-AL Pressurizer Pressure - Low 6.d. Auxiliary Feedwater, 1-PT-456 Foxboro SI Input from ESFAS, 2-PT-456 N-E11GM-HIE2 Pressurizer Pressure - Low 6.d. Auxiliary Feedwater, 1-PT-514, 525, 536, Foxboro SI Input from ESFAS, 546 N-E11GM-HIE2-B Steam Line Pressure - Low 2-PT-514, 525, 536, 546 7.c. Containment Air 1-PT-934, 935, 936 Foxboro Recirculation/Hydrogen 2-PT-934, 935, 936 E11GM-HSAA1 Skimmer (CEQ) System, Containment Pressure - High The response time to be allocated in place of response times obtained through actual measurement during the period of verification may be obtained according to the methodology described in WCAP-13632-P-A, Rev. 2. As described in the Bases for ITS SR 3.3.1.19 (RTS RESPONSE TIME Surveillance) and ITS SR 3.3.2.13 (ESFAS RESPONSE TIME Surveillance), these verified response times may be chosen from historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests); in place, onsite, or offsite (e.g.,

vendor) test measurements; or utilizing vendor engineering specifications.

The NRC Safety Evaluation Report (SER) for WCAP-13632-P-A, Rev. 2, requires confirmation by the licensee that the generic analysis in the WCAP is applicable to their plant, and that the licensee commit to the following actions:

a. Perform a hydraulic response time test prior to installation of a new transmitter/switch or following refurbishment of the transmitter/switch (e.g., sensor cell or variable damping components) to determine an initial sensor-specific response time value.

b. For transmitter and switches that use capillary tubes, perform a response time test after initial installation and after any maintenance or modification activity that could damage the capillary tubes.

c. If variable damping is used, implement a method to assure that the potentiometer is at the required setting and cannot be inadvertently CNP Units 1 and 2 Page 17 of 23 Attachment 1, Volume 3, Rev. 0, Page 56 of 105

Attachment 1, Volume 3, Rev. 0, Page 57 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION changed, or perform a hydraulic response time test of the sensor following each calibration.

d. Perform periodic drift monitoring of all Model 1151, 1152, 1153, and 1154 Rosemount pressure and differential pressure transmitters, for which response time testing elimination is proposed, in accordance with the guidance contained in Rosemount Technical Bulletin No. 4 and continue to remain in full compliance with any prior commitments to Bulletin 90-01, Supplement 1, "Loss of Fill-Oil in Transmitters Manufactured by Rosemount." As an alternative to performing periodic drift monitoring of Rosemount transmitters, licensees may complete the following actions:

(a) ensure that operators and technicians are aware of the Rosemount transmitter loss of fill-oil issue and make provisions to ensure that technicians monitor for sensor response time degradation during the performance of calibrations and functional tests of these transmitters; and (b) review and revise surveillance testing procedures, if necessary, to ensure that calibrations are being performed using equipment designed to provide a step function or fast ramp in the process variable and that calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of the transmitter under test, thus allowing, with reasonable assurance, the recognition of significant response time degradation.

To comply with the requirements of the WCAP-13632-P-A, Rev. 2, SER, CNP commits to the following:

a. The applicable plant procedures will include requirements that stipulate that pressure and differential pressure sensor response times must be verified by performance of an appropriate response time test prior to placing a sensor into operational service, and re-verified following maintenance that may adversely affect sensor response time.

b. The applicable plant procedures, and/or other appropriate administrative controls, will include requirements that stipulate that pressure and differential pressure sensors (transmitters and switches) utilizing capillary tubes (e.g., containment pressure), shall be subjected to response time testing after initial installation and following any maintenance or modification activity that could damage the transmitter capillary tubes.

The only transmitters that use capillary tubes at CNP, and are being proposed to have their response times optionally verified in lieu of measurement using the WCAP-13632-P-A methodology, are shown in the table below:

RTS Function Unit 1 and Unit 2 Manufacturer and (ITS Table 3.3.1-1) Instruments Model Number

9. Pressurizer Water Level - High 1-LT-459 Foxboro 2-LT-459 N-E13DH-HIH2-AL

9. Pressurizer Water Level - High 1-LT-460, 461 Foxboro 2-LT-460, 461 N-E13DH-HIH2 CNP Units 1 and 2 Page 18 of 23 Attachment 1, Volume 3, Rev. 0, Page 57 of 105

Attachment 1, Volume 3, Rev. 0, Page 58 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION These transmitters for Pressurizer Water Level have filled capillary lines for the reference side of the instrument.

c. CNP has no pressure or differential pressure transmitters with variable damping installed in any RTS or ESFAS application that are being proposed to have their response times optionally verified in lieu of measurement using the WCAP-13632-P-A methodology. However, modifications may be performed in the future to install transmitters with variable damping capability for one or more of the applicable pressure or differential pressure sensors. If this occurs, then the applicable plant procedures, and/or other appropriate administrative controls, will be developed or revised to implement a method to assure that the potentiometer is at the required setting and cannot be inadvertently changed, or that a hydraulic response time test of the sensor is performed following each calibration.

d. I&M responded to NRC Bulletins 90-01, "Loss of Fill-Oil in Transmitters Manufactured by Rosemount," on May 24, 1990, and its supplement (Supplement 1) on March 1, 1993. In these responses, I&M specified that there were no Rosemount transmitters installed in safety-related systems at CNP, and the NRC determined that this confirmation provided an adequate basis to consider NRC's review of the I&M response complete as documented in letters dated December 11, 1990, and April 16, 1993, respectively. No further reviews have been conducted by the NRC regarding the concerns identified in NRC Bulletin 90-01, including Supplement 1, and the concerns identified have been resolved for CNP.

In addition, there are still no Rosemount transmitters installed in safety-related systems at CNP. However, periodic technician training is conducted that addresses awareness of this issue, and technicians are trained to monitor for sluggish response of pressure and differential pressure sensors during maintenance and testing activities. Based on the current status of this issue, no further actions are required.

Based on this evaluation, the change to eliminate response time testing requirements for the specific pressure and differential pressure sensors identified in the two tables above is acceptable because the analysis presented in WCAP-13632-P-A, Rev. 2, has been determined to be applicable to CNP, and I&M has committed to the additional actions required by the NRC SER approving this Topical Report.

WCAP-14036-P-A, Rev. 1, contains the technical basis and methodology for eliminating response time testing requirements for signal processing and actuation logic components of the RTS and ESFAS protection channels identified in the WCAP. The justification for this elimination is based on a Failure Modes and Effects Analysis (FMEA) that either determined that individual component degradation had no response time impact; or identified components that may contribute to RTS or ESFAS response time degradation. Where potential response time impact was identified, testing was conducted to determine the magnitude of the response time degradation, or a bounding response time limit for the system or component was identified. As described in the Bases for ITS SR 3.3.1.19 and ITS SR 3.3.2.13, the allocations for sensor, signal conditioning, CNP Units 1 and 2 Page 19 of 23 Attachment 1, Volume 3, Rev. 0, Page 58 of 105

Attachment 1, Volume 3, Rev. 0, Page 59 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance work that may adversely affect response time. For the identified signal processing and actuation logic components, bounding response time allocation will be derived from design response time specifications for the component.

The NRC Safety Evaluation Report (SER) for WCAP-14036-P-A, Rev. 1, requires confirmation by the licensee that the FMEA in the WCAP is applicable to the equipment actually installed in the facility, and that the analysis is valid for the versions of the boards used in the facility protection system.

WCAP-14036-P-A has been reviewed and evaluated against the actual RTS and ESFAS signal processing and actuation logic used at CNP to determine applicability. At CNP, signal processing of most of the RTS and ESFAS sensor inputs is performed using Foxboro Spec 200 and Foxboro Spec 200µ signal conditioning racks. This signal processing equipment is not included in the specific equipment evaluated in the WCAP. Therefore, I&M will continue to measure the response time of this equipment instead of using allocated response times.

For neutron flux RTS protection channels, signal processing is performed by the Westinghouse Nuclear Instrumentation System (NIS), and the Westinghouse Solid State Protection System (SSPS) is used for the protection channel actuation logic. Neutron detectors are exempted from response time testing as shown in proposed ITS SR 3.3.1.19. For the other RTS and ESFAS protection channels using either Foxboro Spec 200 or Foxboro Spec 200µ signal processing, and for the reactor coolant pump undervoltage and underfrequency RTS and ESFAS protection channels, the Westinghouse SSPS is used for the protection channel actuation logic. Sections 4.6 and 4.8 of WCAP-14036-P-A describe the results of the FMEA for the NIS and SSPS used at CNP, respectively, and I&M has verified that the FMEA is applicable to the NIS and SSPS equipment actually installed at CNP. As described in WCAP-14036-P-A, the FMEA alone was used for the NIS to establish response time degradation limits that are not detectable by other periodic surveillance tests. For the SSPS, response time degradation limits are based on the response time of relays, since the relays are the limiting response time component in this system. In both cases, testing was not required to determine the magnitude of the response time degradation. Therefore, the results of the NIS FMEA and evaluation of SSPS relay response times in the WCAP, and confirmation that the specific equipment used at CNP is addressed by these evaluations in the WCAP, demonstrate the acceptability of eliminating response time testing requirements for components of these two systems.

Signal processing components and actuation logic components for the following RTS Functions (as shown in ITS Table 3.3.1-1) have been confirmed to be specifically addressed by WCAP-14036-P-A, and are proposed to have their response times optionally verified in lieu of measurement using the WCAP-14036-P-A methodology:

CNP Units 1 and 2 Page 20 of 23 Attachment 1, Volume 3, Rev. 0, Page 59 of 105

Attachment 1, Volume 3, Rev. 0, Page 60 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION Signal RTS Function Processing Actuation Logic (ITS Table 3.3.1-1) System System 2.a. Power Range Neutron Flux - High Westinghouse Westinghouse NIS SSPS 2.b. Power Range Neutron Flux - Low Westinghouse Westinghouse NIS SSPS

6. Overtemperature T Note(1) Westinghouse SSPS

7. Overpower T Note(1) Westinghouse SSPS 8.a. Pressurizer Pressure - Low Note(1) Westinghouse SSPS 8.b. Pressurizer Pressure - High Note(1) Westinghouse SSPS

10. Reactor Coolant Flow - Low Note(1) Westinghouse SSPS

12. Undervoltage RCPs Note(1) Westinghouse SSPS

13. Underfrequency RCPs Note(1) Westinghouse SSPS

14. Steam Generator (SG) Water Level - Note(1) Westinghouse Low Low SSPS

17. Safety Injection (SI) Input from Note(1) Westinghouse Engineered Safety Feature Actuation SSPS System (ESFAS)

(1) RTS RESPONSE TIME will continue to be measured.

Signal processing components and actuation logic components for the following ESFAS Functions (as shown in ITS Table 3.3.2-1) have been confirmed to be specifically addressed by WCAP-14036-P-A, and are proposed to have their response times optionally verified in lieu of measurement using the WCAP-14036-P-A methodology:

Signal ESFAS Function Processing Actuation Logic (ITS Table 3.3.2-1) System System 1.c. Safety Injection, Note(2) Westinghouse Containment Pressure - High SSPS 1.d. Safety Injection, Note(2) Westinghouse Pressurizer Pressure - Low SSPS CNP Units 1 and 2 Page 21 of 23 Attachment 1, Volume 3, Rev. 0, Page 60 of 105

Attachment 1, Volume 3, Rev. 0, Page 61 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION Signal ESFAS Function Processing Actuation Logic (ITS Table 3.3.2-1) System System 1.e.(1)Safety Injection, Note(2) Westinghouse Steam Line Pressure - Low SSPS 2.c. Containment Spray, Note(2) Westinghouse Containment Pressure - High High SSPS 4.c. Steam Line Isolation, Note(2) Westinghouse Containment Pressure - High High SSPS 4.d. Steam Line Isolation, Note(2) Westinghouse Steam Line Pressure - Low SSPS 5.b. Turbine Trip and Feedwater Isolation, Note(2) Westinghouse Steam Generator (SG) Water Level - SSPS High High 6.c. Auxiliary Feedwater, Note(2) Westinghouse Steam Generator (SG) Water Level - SSPS Low Low 6.f. Auxiliary Feedwater, Note(2) Westinghouse Undervoltage Reactor Coolant Pump SSPS 7.c. Containment Air Note(2) Westinghouse Recirculation/Hydrogen Skimmer SSPS (CEQ) System, Containment Pressure - High (2) ESFAS RESPONSE TIME will continue to be measured.

The response time to be allocated in place of response times obtained through actual measurement during the period of verification may be obtained according to the methodology described in WCAP-14036-P-A, Rev. 1, as described in the Bases for ITS SR 3.3.1.19 and ITS SR 3.3.2.13.

Based on this evaluation, the change to eliminate response time testing requirements for the specific signal processing and actuation logic components of the RTS and ESFAS protection channels described above is acceptable because the analysis presented in WCAP-14036-P-A, Rev. 1, has been determined to be applicable to CNP, as required to be confirmed by the NRC SER approving this Topical Report.

This change is designated as less restrictive because some components which must be response time tested under the CTS will not require response time testing under the ITS.

L.4 The CTS Section 1.0 definition of DOSE EQUIVALENT I-131 requires that the DOSE EQUIVALENT I-131 be calculated using either the thyroid dose conversion factors found in Table III of TID 14844, Calculation of Distance Factors for Power and Test Reactor Sites, or those listed in Regulatory Guide CNP Units 1 and 2 Page 22 of 23 Attachment 1, Volume 3, Rev. 0, Page 61 of 105

Attachment 1, Volume 3, Rev. 0, Page 62 of 105 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION (RG) 1.109, Rev. 1 (Table E-7). The ITS allows DOSE EQUIVALENT I-131 to be calculated using any one of three thyroid dose conversion factors: TID-14844 (1962); Table E-7 of RG 1.109, Rev. 1 (1977); or ICRP 30, Supplement to Part 1, page 192-212, Table Titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity." This changes the CTS by allowing a third method, ICRP 30, Supplement to Part 1, to be used to calculate DOSE EQUIVALENT I-131.

The purpose of the defined term is to provide acceptable methods for computing DOSE EQUIVALENT I-131. Using thyroid dose conversion factors other than those given in TID-14844 results in lower doses and higher allowable activity but is justified by the discussion given in the Federal Register (FR page 23360 Vl 56 No 98 May 21, 1991). This discussion accompanied the final rulemaking on 10 CFR 20 by the NRC. In that discussion, the NRC stated that they were incorporating modifications to existing concepts and recommendations of the ICRP and NCRP into NRC regulations. Incorporation of the methodology of ICRP 30 into the 10 CFR 20 revision was specifically mentioned with the explanation that changes being made result from changes in the scientific techniques and parameters used in calculating dose. In a response to a specific question as to whether or not the ICRP 30 dose parameters should be used, the NRC stated "Appropriate parameters for calculating organ doses can be found in ICRP 30 and its supplements..." Lastly, Commissioner Curtis provided additional views of the revised 10 CFR 20 with respect to the backfit rule. In that discussion, he stated that the AEC, when they issued the original 10 CFR 20, had emphasized that the standards were subject to change with the development of new knowledge and experience. He went on to say that the limits given in the revised 10 CFR 20 were based on up-to-date metabolic models and dose factors. This Federal Register entry shows clearly that, in general, the NRC was updating 10 CFR 20 to incorporate ICRP-30 recommendations and data. Given this discussion, it is concluded that using ICRP thyroid dose conversion factors to calculate DOSE EQUIVALENT I-131 is acceptable. In addition, RG 1.109 was developed by the NRC for the purpose of evaluating compliance with 10 CFR 50, Appendix I. The RG 1.109 thyroid dose conversion factors are higher than the ICRP 30 thyroid dose conversion factors for all five iodine isotopes in question.

Therefore, using RG 1.109 thyroid dose conversion factors to calculate DOSE EQUIVALENT I-131 is more conservative than ICRP 30 and is therefore acceptable.

CNP Units 1 and 2 Page 23 of 23 Attachment 1, Volume 3, Rev. 0, Page 62 of 105

Attachment 1, Volume 3, Rev. 0, Page 63 of 105 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 3, Rev. 0, Page 95 of 105 JUSTIFICATION FOR DEVIATIONS ITS CHAPTER 1.0, USE AND APPLICATION

1. The brackets are removed and the proper plant specific information/value is provided.

2. CNP does not propose to use a PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) and will not relocate the Pressure and Temperature limits from the Technical Specifications. The current limits will be retained in the ITS. Therefore, the definition of PTLR was not incorporated in the ITS.

3. The ISTS SHUTDOWN MARGIN definition includes an exception to not assume a stuck rod if all rods can be verified inserted by two independent means. The CNP plant design does not provide two independent means to verify a rod is fully inserted.

Therefore, the allowance cannot be used and is removed to avoid confusion.

4. Typographical/grammatical error corrected.

5. The proper plant specific information/nomenclature/value is provided.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 3, Rev. 0, Page 95 of 105

Attachment 1, Volume 3, Rev. 0, Page 96 of 105 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 3, Rev. 0, Page 96 of 105

Attachment 1, Volume 3, Rev. 0, Page 97 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.1 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

The CTS Section 1.0 definition of CHANNEL FUNCTIONAL TEST requires the use of a simulated signal when performing the test. ITS Section 1.1 renames the CTS definition to CHANNEL OPERATIONAL TEST (COT) as discussed in DOC A.7. The ITS Section 1.1 COT definition allows the use of an actual or simulated signal when performing the test. This changes the CTS by allowing the use of unplanned actuations to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because it allows an actual signal to be credited for a Surveillance where only a simulated signal was previously allowed.

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 adds an allowance that an actual as well as a simulated signal can be credited during the COT. This change allows taking credit for unplanned actuations if sufficient information is collected to satisfy the surveillance test requirements. This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated signal, and the proposed requirement does not change the technical content or validity of the test. This change will not affect the probability of an accident. The source of the signal sent to components during a Surveillance is not assumed to be an initiator of any analyzed event. The consequence of an accident is not affected by this change. The results of the testing, and, therefore, the likelihood of discovering an inoperable component, are unaffected. As a result, the assurance that equipment will be available to mitigate the consequences of an accident is unaffected. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

CNP Units 1 and 2 Page 1 of 9 Attachment 1, Volume 3, Rev. 0, Page 97 of 105

Attachment 1, Volume 3, Rev. 0, Page 98 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION

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 adds an allowance that an actual as well as a simulated signal can be credited during the COT. This change will not physically alter the plant (no new or different type of equipment will be installed). The change also does not require any new or revised operator actions. 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 adds an allowance that an actual as well as a simulated signal can be credited during the COT. The margin of safety is not affected by this change. This change allows taking credit for unplanned actuations if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated signal. As a result, the proposed requirement does not change the technical content or validity of the test. 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.

CNP Units 1 and 2 Page 2 of 9 Attachment 1, Volume 3, Rev. 0, Page 98 of 105

Attachment 1, Volume 3, Rev. 0, Page 99 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.2 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

The CTS Section 1.0 definition of CORE ALTERATION applies to the movement or manipulation of any component in the reactor vessel with the vessel head removed and fuel in the vessel. The ITS Section 1.1 definition of CORE ALTERATION will only apply to the movement of fuel, sources, or reactivity control components in the reactor vessel.

This changes the CTS by eliminating from the definition of CORE ALTERATION the movement of any components in the reactor vessel that are not fuel, sources, or reactivity control components. The elimination of or manipulation from the definition is discussed in DOC A.8.

The defined term CORE ALTERATION in the ITS is used to prevent a core reactivity excursion. Other accidents which can occur during refueling conditions, such as a fuel handling accident or boron dilution accident, are addressed in the ITS by prohibitions on the movement of irradiated fuel or prohibitions on positive reactivity additions. This change is acceptable because the ITS definition of CORE ALTERATION controls the movement of components such as fuel, sources, and reactivity control components that can affect core reactivity. The CTS definition also prohibits the movement of other equipment such as cameras, thimble plugs, and core internals that have little, if any, effect on core reactivity. Therefore, controlling the movement of those items under the definition of CORE ALTERATION is not necessary. This change is designated as less restrictive because the ITS definition applies in fewer circumstances than does the CTS definition.

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 revises the definition of CORE ALTERATION to be the movement of fuel, sources, or reactivity control components within the reactor vessel rather than the movement of any component within the reactor vessel.

This change will not affect the probability of an accident. The only component within the reactor vessel assumed to be an initiator of an event previously evaluated is an irradiated fuel assembly when it is dropped. None of the other components are initiators of any analyzed event. As fuel is retained in the list of components which, when moved, constitute a CORE ALTERATION, the probability of a fuel handling accident is not affected. Also, this change has no CNP Units 1 and 2 Page 3 of 9 Attachment 1, Volume 3, Rev. 0, Page 99 of 105

Attachment 1, Volume 3, Rev. 0, Page 100 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION effect on the probability of a boron dilution event because a boron dilution event is not initiated by movement of components in the reactor vessel. The consequences of an accident are not affected by this change as movement of the components being excluded from the definition of CORE ALTERATION do not act to mitigate the consequences of any accident previously evaluated.

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 revises the definition of CORE ALTERATION to be the movement of fuel, sources, or reactivity control components within the reactor vessel rather than the movement of any component within the reactor vessel.

This change will not physically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. 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 revises the definition of CORE ALTERATION to be the movement of fuel, sources, or reactivity control components within the reactor vessel rather than the movement of any component within the reactor vessel.

The margin of safety is not affected by this change because the safety analysis assumptions are not affected. The safety analyses do not address the movement of components within the reactor vessel other than fuel, sources, and reactivity control components. Fuel continues to be included in the CORE ALTERATION definition. Also, the shutdown margin is unaffected by the movement of components other than fuel, sources, and reactivity control components because the movement of other components will not significantly change core reactivity. No change is being proposed in the application of the definition to the movement of components which are factors in the design basis analyses. 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.

CNP Units 1 and 2 Page 4 of 9 Attachment 1, Volume 3, Rev. 0, Page 100 of 105

Attachment 1, Volume 3, Rev. 0, Page 101 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.3 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

The CTS Section 1.0 definitions of ENGINEERED SAFETY FEATURE RESPONSE TIME and REACTOR TRIP SYSTEM RESPONSE TIME require measurement of the response time from the sensor through the actuated equipment. The ITS definitions of ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME and REACTOR TRIP SYSTEM (RTS) RESPONSE TIME are modified to state "In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC." This changes the CTS by eliminating the requirement to include all components in a response time test.

The purpose of response time testing is to ensure that the system response time, from measurement of a parameter to actuation of the appropriate device, is consistent with the assumptions in the safety analyses. WCAP-13632-P-A, Rev. 2, "Elimination of Pressure Sensor Response Time Testing Requirements," dated January 1996, justified the elimination of the pressure sensor response time testing requirements and allows the response time for selected components to be verified instead of measured.

WCAP-14036-P-A, Rev. 1, "Elimination of Periodic Protection Channel Response Time Tests," provides the basis for using allocated signal processing actuation logic response times in the overall verification of the protection system channel response time. This change is acceptable because the cited Topical Reports have demonstrated that modified response time tests will continue to provide assurance that the systems will perform their functions as assumed in the safety analysis. In addition, the Topical Reports have been determined to be applicable to the specific components for which CNP is requesting this allowance, as described in the Discussion of Change. This change is designated as less restrictive because some components which must be response time tested under the CTS will not require response time testing under the ITS.

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 allows some devices to be assigned an allocated response time, instead of a measured response time, when performing response time testing of the RTS and ESFAS protection channels. This change does not alter the design, material, and construction standards that were applicable prior CNP Units 1 and 2 Page 5 of 9 Attachment 1, Volume 3, Rev. 0, Page 101 of 105

Attachment 1, Volume 3, Rev. 0, Page 102 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION to the change. The same RTS and ESFAS instrumentation is being used, and the time response allocations and modeling assumption in the safety and accident analyses as described in Chapter 14 of the CNP Updated Final Safety Analysis Report (UFSAR) remain the same, with only the method of verifying time response changed. The proposed change does not modify any system interface, and could not increase the probability of an accident because these events are independent of this change. The proposed change does not change, degrade, or prevent actions or alter any assumptions previously made in evaluating the radiological consequences of an accident described in the CNP UFSAR. 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 allows some devices to be assigned an allocated response time, instead of a measured response time, when performing response time testing of the RTS and ESFAS protection channels. This change does not alter the performance of the pressure and differential pressure transmitters and switches, signal processing components, or actuation logic components used in the RTS and ESFAS protection systems. All applicable pressure and differential pressure sensors, signal processing components, and actuation logic components of the RTS and ESFAS protection systems will still have response time verified by test before placing the sensor in operational service and after any maintenance that could affect response time. Changing the method of periodically verifying response for certain components of the RTS and ESFAS protection systems (assuring component operability) from time response testing to calibration and channel checks does not create any new accident initiators or scenarios. Periodic surveillance of these components will continue, and may be used to detect significant degradation in the response characteristic that may cause the total response time allowance of the RTS and ESFAS protection systems to be exceeded. The total time response allowance for each RTS and ESFAS protection function bounds all degradation that cannot be detected by periodic surveillance. 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 allows some devices to be assigned an allocated response time, instead of a measured response time, when performing response time testing of the RTS and ESFAS protection channels. The change does not affect the total system response times assumed in the safety analyses. The periodic system response time verification method for selected pressure and differential pressure sensors, signal processing components, and actuation logic components is modified to allow use of actual test data or engineering data. The method of verification still provides assurance that the total system response is CNP Units 1 and 2 Page 6 of 9 Attachment 1, Volume 3, Rev. 0, Page 102 of 105

Attachment 1, Volume 3, Rev. 0, Page 103 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION within that defined in the safety analyses. Periodic surveillance of these components will continue, and may be used to detect significant degradation in the response characteristic that may cause the total response time allowance of the RTS and ESFAS protection systems to be exceeded. The total time response allowance for each RTS and ESFAS protection function bounds all degradation that cannot be detected by periodic surveillance. 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.

CNP Units 1 and 2 Page 7 of 9 Attachment 1, Volume 3, Rev. 0, Page 103 of 105

Attachment 1, Volume 3, Rev. 0, Page 104 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.4 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

The CTS Section 1.0 definition of DOSE EQUIVALENT I-131 requires that the DOSE EQUIVALENT I-131 be calculated using either the thyroid dose conversion factors found in Table III of TID 14844, Calculation of Distance Factors for Power and Test Reactor Sites, or those listed in Regulatory Guide (RG) 1.109, Rev. 1 (Table E-7). The ITS allows DOSE EQUIVALENT I-131 to be calculated using any one of three thyroid dose conversion factors: TID-14844 (1962); Table E-7 of RG 1.109, Rev. 1 (1977); or ICRP 30, Supplement to Part 1, page 192-212, Table Titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity." This changes the CTS by allowing a third method, ICRP 30, Supplement to Part 1, to be used to calculate DOSE EQUIVALENT I-131.

The purpose of the defined term is to provide acceptable methods for computing DOSE EQUIVALENT I-131. Using thyroid dose conversion factors other than those given in TID-14844 results in lower doses and higher allowable activity but is justified by the discussion given in the Federal Register (FR page 23360 Vl 56 No 98 May 21, 1991).

This discussion accompanied the final rulemaking on 10 CFR 20 by the NRC. In that discussion, the NRC stated that they were incorporating modifications to existing concepts and recommendations of the ICRP and NCRP into NRC regulations.

Incorporation of the methodology of ICRP 30 into the 10 CFR 20 revision was specifically mentioned with the explanation that changes being made result from changes in the scientific techniques and parameters used in calculating dose. In a response to a specific question as to whether or not the ICRP 30 dose parameters should be used, the NRC stated "Appropriate parameters for calculating organ doses can be found in ICRP 30 and its supplements..." Lastly, Commissioner Curtis provided additional views of the revised 10 CFR 20 with respect to the backfit rule. In that discussion, he stated that the AEC, when they issued the original 10 CFR 20, had emphasized that the standards were subject to change with the development of new knowledge and experience. He went on to say that the limits given in the revised 10 CFR 20 were based on up-to-date metabolic models and dose factors. This Federal Register entry shows clearly that, in general, the NRC was updating 10 CFR 20 to incorporate ICRP-30 recommendations and data. Given this discussion, it is concluded that using ICRP thyroid dose conversion factors to calculate DOSE EQUIVALENT I-131 is acceptable. In addition, RG 1.109 was developed by the NRC for the purpose of evaluating compliance with 10 CFR 50, Appendix I. The RG 1.109 thyroid dose conversion factors are higher than the ICRP 30 thyroid dose conversion factors for all five iodine isotopes in question. Therefore, using RG 1.109 thyroid dose conversion factors to calculate DOSE EQUIVALENT I-131 is more conservative than ICRP 30 and is therefore acceptable.

Indiana Michigan Power Company (I&M) has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes CNP Units 1 and 2 Page 8 of 9 Attachment 1, Volume 3, Rev. 0, Page 104 of 105

Attachment 1, Volume 3, Rev. 0, Page 105 of 105 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 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 use of ICRP 30 thyroid dose conversion factors to calculate DOSE EQUIVALENT I-131 is a change in analysis methodology which does not include a physical change to the plant, a new mode of plant operation, or a change in surveillance frequency. Therefore, the probability of a previously analyzed accident would not increase. If ICRP 30 thyroid dose conversion factors are used to calculate maximum dose equivalent iodine specific activity, the total iodine activity (in units of µCi/gm) will increase and this activity is used to calculate the doses resulting from a Main Steam Line Break (MSLB) or other analyzed accident. The calculated thyroid doses resulting from a MSLB or other analyzed accident would not increase as the same dose conversion factors used to calculate the DOSE EQUIVALENT I-131 thyroid activity would also be used to calculate the offsite thyroid doses. However, these dose conversion factors would be less than TID-14844 thyroid dose conversion factors used to calculate doses given in the UFSAR. 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 create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change does not introduce a new mode of plant operation and does not require physical modification of the plant. 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 only refines the method of calculating thyroid doses and DOSE EQUIVALENT I-131 activity. Using this method would not result in the thyroid doses changing significantly, since the same dose factors would be used to calculate the thyroid doses and DOSE EQUIVALENT I-131 activity. 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.

CNP Units 1 and 2 Page 9 of 9 Attachment 1, Volume 3, Rev. 0, Page 105 of 105