Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 5, Rev 0, ITS Section 3.0 LCO and SR Applicability.
	ML041200353
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Issue date:	04/06/2004
From:	; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
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Attachment 1, Volume 5, Rev. 0, Page 1 of 79 VOLUME 5 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.0 LCO and SR APPLICABILITY Revision 0 Attachment 1, Volume 5, Rev. 0, Page 1 of 79

Attachment 1, Volume 5, Rev. 0, Page 2 of 79 LIST OF ATTACHMENTS

1. ITS Section 3.0 Attachment 1, Volume 5, Rev. 0, Page 2 of 79

, Volume 5, Rev. 0, Page 3 of 79 ATTACHMENT 1 ITS Section 3.0, LCO and SR Applicability , Volume 5, Rev. 0, Page 3 of 79

, Volume 5, Rev. 0, Page 4 of 79 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 5, Rev. 0, Page 4 of 79

Attachment 1, Volume 5, Rev. 0, Page 5 of 79 ITS Section 3.0 A.1 ITS

.0 (LCO)

A.1 LCOs met 3.0.1 A.2 LCO in the Applicability 3.0.2 and LCO 3.0.7 3.0.2 INSERT 1 A.3 an LCO and S

3.0.3 A.4 INSERT 2 MODE 3 7 13 MODE 4 A.5 37 MODE 5 INSERT 3 A.6 this Specification A.1 3.0.4 INSERT 4 A.7 L.1 L.2 See ITS 3.8.1 S

3.0.5 A.1 LCO A.8 INSERT 5 A.9 INSERT 6 A.10 Page 1 of 15 Attachment 1, Volume 5, Rev. 0, Page 5 of 79

Attachment 1, Volume 5, Rev. 0, Page 6 of 79 ITS Section 3.0 A.3 INSERT 1 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

INSERT 2 A.4 are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the A.5 LCO is not applicable.

A.6 INSERT 3 in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

INSERT 4 A.7 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered L.1 permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES A.7 or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

L.2 Exceptions to this Specification are stated in the individual Specifications.

A.7 LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4. L.2 Insert Page 3/4 0-1a Page 2 of 15 Attachment 1, Volume 5, Rev. 0, Page 6 of 79

Attachment 1, Volume 5, Rev. 0, Page 7 of 79 ITS Section 3.0 A.9 INSERT 5 LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

A.10 INSERT 6 LCO 3.0.7 Test Exception LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 2,"

allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

Insert Page 3/4 0-1b Page 3 of 15 Attachment 1, Volume 5, Rev. 0, Page 7 of 79

Attachment 1, Volume 5, Rev. 0, Page 8 of 79 ITS Section 3.0 A.1 ITS

.0 (SR)

A.1 SRs met SR 3.0.1 in the Applicability A.11 INSERT 7 LCOs, the SR SR 3.0.2 A.12 INSERT 8 M.1 SR 3.0.1 L.3 LCO A.11 SR 3.0.3 Frequency A.1 INSERT 9 greater SR 3.0.3 L.4 is entered LCO Condition(s)

SR 3.0.3 A.1 LCO Condition(s)

SR 3.0.1 A.11 INSERT 10 SR 3.0.4 LCOs met A.1 s INSERT 11 their specified Frequency A.13 L.2 See ITS 5.5 Page 4 of 15 Attachment 1, Volume 5, Rev. 0, Page 8 of 79

Attachment 1, Volume 5, Rev. 0, Page 9 of 79 ITS Section 3.0 A.11 INSERT 7 Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

INSERT 8 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 A.12 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

M.1 For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ." basis, the above L.3 Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications. A.12 L.4 INSERT 9 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

A.1 INSERT 10 in the Applicability of an LCO Insert Page 3/4 0-2a Page 5 of 15 Attachment 1, Volume 5, Rev. 0, Page 9 of 79

Attachment 1, Volume 5, Rev. 0, Page 10 of 79 ITS Section 3.0 INSERT 11 A.13 This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of L.2 the unit.

SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4. L.2 Insert Page 3/4 0-2b Page 6 of 15 Attachment 1, Volume 5, Rev. 0, Page 10 of 79

Attachment 1, Volume 5, Rev. 0, Page 11 of 79 ITS Section 3.0 A.1 ITS

.0 (SR)

A.1 See ITS 5.5 Page 7 of 15 Attachment 1, Volume 5, Rev. 0, Page 11 of 79

Attachment 1, Volume 5, Rev. 0, Page 12 of 79 ITS Section 3.0 A.1 ITS

.0 (LCO)

A.1 LCOs met 3.0.1 A.2 LCO 3.0.2 and LCO 3.0.7 in the Applicability 3.0.2 INSERT 1 A.3 an LCO and S 3.0.3 A.4 INSERT 2 MODE 3 7 13 A.5 MODE 4 37 MODE 5 A.6 INSERT 3 A.1 this Specification 3.0.4 INSERT 4 A.7 L.1 L.2 See ITS 3.8.1 S

3.0.5 A.1 LCO A.8 INSERT 5 A.9 INSERT 6 A.10 Page 8 of 15 Attachment 1, Volume 5, Rev. 0, Page 12 of 79

Attachment 1, Volume 5, Rev. 0, Page 13 of 79 ITS Section 3.0 A.3 INSERT 1 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

INSERT 2 A.4 are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the A.5 LCO is not applicable.

A.6 INSERT 3 in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

INSERT 4 A.7 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered L.1 permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES A.7 or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

L.2 Exceptions to this Specification are stated in the individual Specifications.

A.7 LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4. L.2 Insert Page 3/4 0-1a Page 9 of 15 Attachment 1, Volume 5, Rev. 0, Page 13 of 79

Attachment 1, Volume 5, Rev. 0, Page 14 of 79 ITS Section 3.0 A.9 INSERT 5 LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

A.10 INSERT 6 LCO 3.0.7 Test Exception LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 2,"

allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

Insert Page 3/4 0-1b Page 10 of 15 Attachment 1, Volume 5, Rev. 0, Page 14 of 79

Attachment 1, Volume 5, Rev. 0, Page 15 of 79 ITS Section 3.0 A.1 ITS

.0 (SR)

A.1 SRs met SR 3.0.1 A.11 in the Applicability INSERT 7 LCOs, the SR SR 3.0.2 A.12 INSERT 8 M.1 SR 3.0.1 L.3 LCO A.11 SR 3.0.3 Frequency A.1 INSERT 9 greater SR 3.0.3 L.4 entered LCO Condition(s) is SR 3.0.3 A.1 LCO Condition(s)

SR 3.0.1 A.11 INSERT 10 SR 3.0.4 LCOs met A.1 s INSERT 11 their specified Frequency A.13 L.2 See ITS 5.5 Page 11 of 15 Attachment 1, Volume 5, Rev. 0, Page 15 of 79

Attachment 1, Volume 5, Rev. 0, Page 16 of 79 ITS Section 3.0 A.11 INSERT 7 Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

INSERT 8 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 A.12 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

M.1 For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ." basis, the above L.3 Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications. A.12 L.4 INSERT 9 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

A.1 INSERT 10 in the Applicability of an LCO Insert Page 3/4 0-2a Page 12 of 15 Attachment 1, Volume 5, Rev. 0, Page 16 of 79

Attachment 1, Volume 5, Rev. 0, Page 17 of 79 ITS Section 3.0 INSERT 11 A.13 This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of L.2 the unit.

SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4. L.2 Insert Page 3/4 0-2b Page 13 of 15 Attachment 1, Volume 5, Rev. 0, Page 17 of 79

Attachment 1, Volume 5, Rev. 0, Page 18 of 79 ITS Section 3.0 A.1 ITS

.0 (SR)

A.1 See ITS 5.5 Page 14 of 15 Attachment 1, Volume 5, Rev. 0, Page 18 of 79

Attachment 1, Volume 5, Rev. 0, Page 19 of 79 ITS Section 3.0 A.1 ITS

.0 (SR)

A.1 Page 15 of 15 Attachment 1, Volume 5, Rev. 0, Page 19 of 79

Attachment 1, Volume 5, Rev. 0, Page 20 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY 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 3.0.1 states, "Limiting Conditions for Operation and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for each specification, except as provided in Specification 3.0.6." ITS LCO 3.0.1 states, "LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7."

This results in several changes to the CTS.

Certain phrases are revised to be consistent with the equivalent phrase used in the ITS. Specifically, "Limiting Conditions for Operation" is changed to "LCOs" and "OPERATIONAL MODES or other conditions specified" is changed to "MODES or other specified conditions" to be consistent with the ITS definition of MODE and the terminology used in the ITS.

These changes are acceptable because they result in no change in the intent or application of the Technical Specification, but merely reflect editorial preferences used in the ITS.

The phrase ". . . ACTION requirements shall be applicable during the OPERATIONAL MODES . . ." is moved from CTS 3.0.1 to ITS LCO 3.0.2 which states that when an LCO is not met, the Required Actions must be met.

The change is acceptable because moving this information within the Technical Specifications results in no change in the intent or application of ACTIONS.

The phrase "shall be applicable" is replaced in ITS LCO 3.0.1 with the phrase "shall be met." This change is made to be consistent with the ITS terminology and to clarify the concept of an LCO being met (i.e., being in compliance with the requirements of the LCO), versus the LCO being applicable or required (i.e., the requirements in the LCO apply).

This change is acceptable because it is an editorial change that does not change the intent of the requirements.

The phrase "except as provided in Specification 3.0.6" is replaced in ITS LCO 3.0.1 with the phrase "except as provided in LCO 3.0.2 and LCO 3.0.7." ITS LCO 3.0.2 describes the appropriate actions to be taken when CNP Units 1 and 2 Page 1 of 23 Attachment 1, Volume 5, Rev. 0, Page 20 of 79

Attachment 1, Volume 5, Rev. 0, Page 21 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS LCO 3.0.1 is not met. LCO 3.0.7 describes Test Exception LCOs, which are exceptions to other LCOs. CTS 3.0.6 (ITS LCO 3.0.5) does not modify ITS LCO 3.0.1 since the ACTION requirements discussion that is in CTS 3.0.1 has been moved to ITS LCO 3.0.2, as described above.

This change is acceptable because adding the exception for LCO 3.0.2 and LCO 3.0.7 prevents a conflict within the Applicability section. This addition is needed for consistency in the ITS requirements and does not change the intent or application of the Technical Specifications.

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

A.3 CTS 3.0.2 states, "Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION within the specified time interval shall constitute compliance with the specification, except as provided in Specification 3.0.6. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required." ITS LCO 3.0.2 states "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated." This results in several changes to the CTS.

The first sentence in CTS 3.0.2 states, in part, "Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION . . . shall constitute compliance with the specification." This requirement is divided into portions of ITS LCO 3.0.1, "LCOs shall be met" and ITS LCO 3.0.2, "Upon discovery of failure to meet an LCO, the Required Actions of the associated Conditions shall be met."

This change is acceptable because the intent of the CTS requirement is preserved, but the aspects of LCO compliance and the performance of ACTIONS when the LCO is not met are separated.

The CTS 3.0.2 term "Specification 3.0.6" has been changed in ITS LCO 3.0.2 to "LCO 3.0.5" due to renumbering and consistency with the terminology in the ITS.

This change is acceptable because it results in no change in the intent or application of the Technical Specification, but merely reflects an editorial preference and renumbering.

CTS 3.0.2 is revised to include an exception for ITS LCO 3.0.6. LCO 3.0.6 is a new allowance that takes exception to the ITS LCO 3.0.2 requirement to take the Required Actions when the associated LCO is not met. This exception is included in LCO 3.0.2 to avoid conflicts between the applicability requirements.

CNP Units 1 and 2 Page 2 of 23 Attachment 1, Volume 5, Rev. 0, Page 21 of 79

Attachment 1, Volume 5, Rev. 0, Page 22 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY This change is acceptable because it includes a reference to a new item in the ITS and results in no change to the CTS. Changes resulting from the incorporation of LCO 3.0.6 are discussed in Discussion of Change (DOC) A.9.

The second sentence of CTS LCO 3.0.2 states "In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required." The sentence is replaced in ITS LCO 3.0.2 with "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s),

completion of the Required Action(s) is not required unless otherwise stated."

This change is acceptable because, while worded differently, both the CTS and ITS state that ACTIONS do not have to be completed once the LCO is met or is no longer applicable. ITS LCO 3.0.2 also adds the phrase, "unless otherwise stated." There are some ITS ACTIONS which must be completed, even if the LCO is met or is no longer applicable.

This change is acceptable because it reflects a new feature in the ITS which did not exist in the CTS. The technical aspects of these changes are discussed in the appropriate ITS sections.

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

A.4 CTS LCO 3.0.3 is applicable "When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements." ITS LCO 3.0.3 expands those applicability requirements so that the requirement is applicable "When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS."

This changes the CTS to add two new applicability conditions.

ITS LCO 3.0.3 is applicable when the LCO is not met and there is no applicable ACTION to be taken.

This change is acceptable because it is consistent with the current understanding and application of CTS 3.0.3.

ITS LCO 3.0.3 is applicable when directed by the associated ACTIONS.

The CTS do not contain requirements that direct entry into LCO 3.0.3.

The ITS does contain such requirements. Any technical changes related to directing LCO 3.0.3 entry in an ACTION will be discussed in the affected Technical Specifications.

This change is acceptable because referencing a new feature in the ITS is an editorial change.

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

CNP Units 1 and 2 Page 3 of 23 Attachment 1, Volume 5, Rev. 0, Page 22 of 79

Attachment 1, Volume 5, Rev. 0, Page 23 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY A.5 CTS 3.0.3 states the shutdown time limits in sequential order; i.e., each time limit is measured from the completion of the previous step. ITS 3.0.3 states the time limits (Completion Times) from the time the condition was entered. In addition, the MODE titles used in CTS 3.0.3 are replaced with the corresponding MODE numbers in ITS LCO 3.0.3. The stated times in CTS 3.0.3 and ITS LCO 3.0.3 are listed below:

Mode Title CTS Time to Enter Mode ITS Time to Enter Mode

-- (Current Mode) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to begin action 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to begin action 3 Hot Standby within the next 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 6 hours 4 Hot Shutdown within the following 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months 6 hours 5 Cold Shutdown within the subsequent 24 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months hours These changes are acceptable because the ITS times are the sum of the CTS times (e.g., the ITS Completion Time of 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to enter MODE 5 is the same as the sum of the CTS allowance of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .)

This changes the CTS presentation only, and the time allowed to enter each MODE is unchanged. Using MODE numbers instead of the corresponding MODE titles is an editorial preference which results in no change to the requirements in the Technical Specifications. In addition, the CTS 3.0.3 statement "within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it" has been editorially reworded in ITS LCO 3.0.3 to "the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. ACTION shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit..." These changes are acceptable because they result in no change in the intent or application of the Technical Specification, but merely reflect editorial preferences used in the ITS.

These changes are designated as administrative as they implement the editorial conventions used in the ITS without resulting in technical changes to the Technical Specifications.

A.6 CTS 3.0.3 states "Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation." ITS LCO 3.0.3 states "Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required."

This change is acceptable because the changes to CTS 3.0.3 are editorial. Both the CTS and ITS state that LCO 3.0.3 can be exited if the LCO which led to the entry into LCO 3.0.3 is met, or if one of the ACTIONS of that LCO is applicable.

The CTS requirement also specifies that the time to complete the ACTIONS in CNP Units 1 and 2 Page 4 of 23 Attachment 1, Volume 5, Rev. 0, Page 23 of 79

Attachment 1, Volume 5, Rev. 0, Page 24 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY the LCO is based on the initial failure to meet the LCO. Reentering the LCO after exiting LCO 3.0.3 does not reset the ACTION statement time requirements. This information is not explicitly stated in ITS LCO 3.0.3 but is true under the multiple condition entry concept of the ITS. In addition, the sentence "LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4" is added to ITS LCO 3.0.3. CTS 3.0.3 and ITS LCO 3.0.3 require the unit to be placed only as low as COLD SHUTDOWN (MODE 5). Once the unit is in MODE 5, there are no further requirements.

Thus, CTS 3.0.3 and ITS LCO 3.0.3 are effectively only applicable in MODES 1, 2, 3, and 4, and the addition of the sentence merely reflects editorial preferences used in the ITS.

These changes are designated as administrative because there is no change in the intent or application of the CTS 3.0.3 requirements.

A.7 CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION statements." ITS LCO 3.0.4 states "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. Exceptions to this Specification are stated in the individual Specifications." The addition of the exception in the first sentence is described in DOC L.1 and the addition of the exceptions in the second sentence and last sentence is described in DOC L.2. The following changes are made to CTS 3.0.4:

The CTS 3.0.4 phrase "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made" is replaced in ITS LCO 3.0.4 with the phrase "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made."

This change is made to be consistent with the ITS terminology and is acceptable since the wording reflects editorial preferences used in the ITS.

CTS 3.0.4 states "This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION statements." ITS LCO 3.0.4 states, in part, "This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS."

This change is acceptable because these statements are equivalent.

Both are stating that LCO 3.0.4 shall not prevent a unit shutdown required by the Technical Specifications. The ITS wording recognizes that there CNP Units 1 and 2 Page 5 of 23 Attachment 1, Volume 5, Rev. 0, Page 24 of 79

Attachment 1, Volume 5, Rev. 0, Page 25 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY are conditions in the Applicability that are not MODES, such as "During CORE ALTERATIONS."

The CTS 3.0.4 phrase "unless otherwise excepted" is replaced in ITS LCO 3.0.4 by the sentence "Exceptions to this Specification are stated in the individual Specifications."

This change is acceptable because the statements are equivalent. The logical place an exception would be located would be in the individual Specification.

These changes are designated as administrative as there is no change in the intent of CTS 3.0.4 and no additional flexibility is granted.

A.8 CTS 3.0.6 has a statement that CTS 3.0.6 is an exception to both CTS 3.0.1 and CTS 3.0.2. ITS LCO 3.0.5 includes only a statement that ITS LCO 3.0.5 is an exception to LCO 3.0.2. The statement that ITS LCO 3.0.5 is an exception to LCO 3.0.1 is not included.

This change is acceptable since ITS LCO 3.0.5 does not modify ITS LCO 3.0.1.

The ACTION requirements discussion that is in CTS 3.0.1 has been moved to ITS LCO 3.0.2 (i.e., it is not included in ITS LCO 3.0.1). This change is designated as administrative since it does not result in any technical change to the Technical Specifications.

A.9 ITS LCO 3.0.6 is added to the CTS to provide guidance regarding the appropriate ACTIONS to be taken when a single inoperability (a support system) also results in the inoperability of one or more related systems (supported system(s)). LCO 3.0.6 states "When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2." In the CTS, based on the intent and interpretation provided by the NRC over the years, there has been an ambiguous approach to the combined support/supported inoperability. Some of this history is summarized below:

Guidance provided in the June 13, 1979, NRC memorandum from Brian K. Grimes (Assistant Director for Engineering and Projects) to Samuel E.

Bryan (Assistant Director for Field Coordination) would indicate an intent/interpretation consistent with the proposed LCO 3.0.6, without the CNP Units 1 and 2 Page 6 of 23 Attachment 1, Volume 5, Rev. 0, Page 25 of 79

Attachment 1, Volume 5, Rev. 0, Page 26 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY necessity of also requiring additional ACTIONS. That is, only the inoperable support system ACTIONS need be taken.

Guidance provided by the NRC in their April 10, 1980, letter to all Licensees, regarding the definition of OPERABILITY and its impact as a support system on the remainder of the CTS, would indicate a similar philosophy of not taking ACTIONS for the inoperable supported equipment. However, in this case, additional actions (similar to the proposed Safety Function Determination Program actions) were addressed and required.

Generic Letter 91-18 and a plain-English reading of the CTS provide an interpretation that inoperability, even as a result of a Technical Specification support system inoperability, requires all associated ACTIONS to be taken.

Certain CTS contain ACTIONS such as "Declare the {supported system}

inoperable and take the ACTIONS of {its Specification}." In many cases, the supported system would likely already be considered inoperable. The implication of this presentation is that the ACTIONS of the inoperable supported system would not have been taken without the specific direction to do so.

Considering the history of misunderstandings in this area, the WOG ISTS, NUREG-1431, Rev. 2, was developed with Industry input and approval of the NRC to include LCO 3.0.6 and a new program, Specification 5.5.13, "Safety Function Determination Program (SFDP)." This change is acceptable since its function is to clarify existing ambiguities and to maintain actions within the realm of previous interpretations. This change is designated as administrative because it does not technically change the Technical Specifications.

A.10 ITS LCO 3.0.7 is added to the CTS. LCO 3.0.7 states "Test Exception LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 2," allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications."

This change is acceptable because the CTS contain test exception specifications which allow certain LCOs to not be met for the purpose of special tests and operations. However, the CTS does not contain the equivalent of ITS LCO 3.0.7.

As a result, there could be confusion regarding which LCOs are applicable during special tests. LCO 3.0.7 was crafted to avoid that possible confusion. LCO 3.0.7 is consistent with the use and application of CTS test exception Specifications and does not provide any new restriction or allowance. This change is designated as administrative because it does not technically change the Technical Specifications.

CNP Units 1 and 2 Page 7 of 23 Attachment 1, Volume 5, Rev. 0, Page 26 of 79

Attachment 1, Volume 5, Rev. 0, Page 27 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY A.11 CTS 4.0.1 states "Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement." The first sentence of CTS 4.0.3 states "Performance of a Surveillance Requirement within the specified time interval shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated ACTION statements unless otherwise required by the specification." The last sentence of CTS 4.0.3 states "Surveillance Requirements do not have to be performed on inoperable equipment." ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits." The changes to the CTS are:

CTS 4.0.1 states "Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement." The first sentence of ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR."

This change is acceptable because the requirements are identical.

Changes from Limiting Conditions for Operation to LCO, Surveillance Requirement to SR, and OPERATIONAL MODES to MODES are editorial preferences made to be consistent with the ITS format. This change is designated as administrative because the intent of the requirement is unchanged.

The first sentence of CTS 4.0.3 states "Performance of a Surveillance Requirement within the specified time interval shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated ACTION statements unless otherwise required by the specification." This information is moved to ITS SR 3.0.1 which states "Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3." This also changes the CTS by adding the clarification "whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance" and the clarification "except as provided in SR 3.0.3."

This change is acceptable because it is consistent with the current use and application of the Technical Specifications and with previous NRC guidance, and moves information within the Technical Specifications with no change in intent. The reference to SR 3.0.3 is editorial and any CNP Units 1 and 2 Page 8 of 23 Attachment 1, Volume 5, Rev. 0, Page 27 of 79

Attachment 1, Volume 5, Rev. 0, Page 28 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY technical changes resulting from SR 3.0.3 are discussed in other DOCs.

This change is designated as administrative because it clarifies the Technical Specifications with no change in intent.

CTS 4.0.3 states, in part, "Surveillance requirements do not have to be performed on inoperable equipment." ITS SR 3.0.1 states "Surveillances do not have to be performed on inoperable equipment or variables outside specified limits." This changes the CTS by including "variables outside specified limits" in recognition that not all Surveillances test equipment, but rather may test variables such as boron concentration, power distribution factors, temperatures, and pressures. This does not change the current use and application of the statement in CTS 4.0.3.

This change is acceptable and is designated as administrative because it moves and clarifies information within the Technical Specifications with no change in intent.

A.12 CTS 4.0.2 states "Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval." ITS SR 3.0.2 states "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications." This results in several changes to the CTS.

ITS SR 3.0.2 adds to the CTS "For Frequencies specified as once, the above interval extension does not apply." This is described in DOC M.1.

ITS SR 3.0.2 adds to the CTS "If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance." This is described in DOC L.3.

CTS 4.0.2 states "Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval." ITS SR 3.0.2 states, in part, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency." This change is made to be consistent with the ITS terminology and to clarify the concept of the specified SR Frequency being met.

The change is acceptable since it does not change the intent of the requirements.

CNP Units 1 and 2 Page 9 of 23 Attachment 1, Volume 5, Rev. 0, Page 28 of 79

Attachment 1, Volume 5, Rev. 0, Page 29 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY

ITS SR 3.0.2 is more specific regarding the start of the Frequency by stating "as measured from the previous performance or as measured from the time a specified condition of the Frequency is met." This direction is consistent with the current use and application of the Technical Specifications.

This change is acceptable because the ITS presentation has the same intent as the CTS requirement.

ITS SR 3.0.2 adds to the CTS "Exceptions to this Specification are stated in the individual Specifications."

This change is acceptable because it reflects practices used in the ITS that are not used in the CTS. Any changes to a Technical Specification, by inclusion of such an exception, will be addressed in the affected Technical Specification.

The changes are designated as administrative because they reflect presentation and usage rules of the ITS without making technical changes to the Technical Specifications.

A.13 CTS 4.0.4 restricts entry into MODES or other conditions specified in the Applicability unless the applicable SRs have been successfully performed. ITS SR 3.0.4 contains the same restriction, but adds an allowance that "This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. . . " This changes the CTS by adding an allowance to ITS SR 3.0.4 that failure to perform a Surveillance will not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

This change is acceptable because it is consistent with the current understanding and application of CTS 4.0.4 and is necessary to avoid a conflict between SR 3.0.4 and other Specifications. This change is designated as administrative because there is no change in the intent of CTS 4.0.4 and no additional flexibility is granted.

MORE RESTRICTIVE CHANGES M.1 CTS 4.0.2 states "Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval." ITS SR 3.0.2 states "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications." This changes the CTS by adding "For CNP Units 1 and 2 Page 10 of 23 Attachment 1, Volume 5, Rev. 0, Page 29 of 79

Attachment 1, Volume 5, Rev. 0, Page 30 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY Frequencies specified as once, the above interval extension does not apply."

The remaining changes to CTS 4.0.2 are discussed in DOC A.12 and DOC L.3.

The purpose of the 1.25 extension allowance to Surveillance Frequencies is to allow for flexibility in scheduling tests. This change is acceptable because Frequencies specified as "once" are typically condition-based Surveillances in which the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Frequency without extension in order to avoid operation in unacceptable conditions. This change is designated as more restrictive because an allowance to extend Frequencies by 25% is eliminated from some Surveillances.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statement." ITS LCO 3.0.4 states "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time." The ITS now allows MODE or other specified condition changes while relying on ACTIONS, provided the ACTIONS permit continued operation in the MODE or other specified condition in the Applicability for an unlimited amount of time.

The allowance to enter a MODE or other specified condition in the Applicability with the LCO not met when the ACTIONS allow unlimited operation is acceptable because ACTIONS which allow unlimited operation provide appropriate compensatory measures which protect the safety functions affected by the LCO not being met. In such a condition, allowing the unit to enter a MODE or other specified condition in which the LCO is applicable will have no detrimental effect on safety. For example, the ACTIONS for an inoperable containment isolation valve allow unlimited operation provided that the valve is in its required position assumed in the safety analysis. Therefore, the safety function being protected by the LCO (in this example, containment isolation) continues to be protected. This change is designated as less restrictive because it will allow changes in MODES or other specified conditions in the Applicability under circumstances that would be prohibited in the CTS.

CNP Units 1 and 2 Page 11 of 23 Attachment 1, Volume 5, Rev. 0, Page 30 of 79

Attachment 1, Volume 5, Rev. 0, Page 31 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY L.2 CTS 3.0.4 and CTS 4.0.4 are applicable in all MODES and prevent entry into a MODE or other specified condition in the Applicability unless the LCO or SR, respectively, is satisfied. ITS LCO 3.0.4 and ITS SR 3.0.4 add a statement that they are "only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4." In addition, ITS LCO 3.0.4 and ITS SR 3.0.4 add a statement that "This provision shall not prevent entry into MODES or other specified conditions in the Applicability . . . that are part of a shutdown of the unit."

This change in Applicability from all MODES to MODES 1, 2, 3, and 4 is acceptable because the applicable Technical Specifications contain adequate measures to allow MODE changes while relying on ACTIONS. A review of the ITS that are applicable in the MODES and conditions other than MODES 1, 2, 3, and 4 is provided in the table below. The "Discussion" column describes why moving from the Specifications Applicability to other MODES or specified conditions, other than MODES 1, 2, 3, and 4, while relying on ACTIONS, does not have an adverse effect on safety.

ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION MODE 2 with If moving from MODE 5 to MODE 6, LCO 3.1.1 Shutdown Margin keff < 1.0, 3.9.1 becomes applicable. If the boron MODES 3, 4, concentration SDM is not within limits, both and 5 LCO 3.9.1 and 3.1.1 require immediate boration. Therefore, the SDM limits are protected when moving from MODE 5 to MODE 6. CORE ALTERATIONS or movement of irradiated fuel assemblies within the containment cannot be started from MODE 5.

CNP Units 1 and 2 Page 12 of 23 Attachment 1, Volume 5, Rev. 0, Page 31 of 79

Attachment 1, Volume 5, Rev. 0, Page 32 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.3.1 Reactor Trip Manual In MODES 5 and 6, the reactor trip circuit System reactor trip, breakers are open. There is no effect on Instrumentation source range RTS from moving from MODE 5 to MODE neutron flux 6. The consequences of inoperable automatic source range neutron flux channels are reactor trip, P- discussed under LCO 3.9.2 below.

6 interlock, reactor trip breaker undervoltage and shunt trip mechanisms, automatic trip logic, and reactor trip breakers, are required to be OPERABLE in MODE 5 with Rod Control System capable of rod withdrawal or one or more rods not fully inserted 3.3.5 Loss of Power MODES 1, 2, See Discussion for ITS 3.8.2.

Diesel Generator 3, and 4, Start When Instrumentation associated DG is required to be OPERABLE by LCO 3.8.2 for the Loss of Voltage Function only 3.3.6 Containment MODES 1, 2, The ACTIONS are the same in all MODES Purge Supply and 3, and 4, and conditions. Therefore, moving Exhaust System During between MODES while relying on Isolation movement of ACTIONS will have no effect on the Instrumentation irradiated fuel ACTIONS being taken and has no adverse assemblies effect on safety.

within containment CNP Units 1 and 2 Page 13 of 23 Attachment 1, Volume 5, Rev. 0, Page 32 of 79

Attachment 1, Volume 5, Rev. 0, Page 33 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.3.8 Boron Dilution MODES 3, 4, The ACTIONS are the same in all Monitoring and 5 MODES. Therefore, moving between Instrumentation MODES while relying on ACTIONS will have no effect on the ACTIONS being taken and has no adverse effect on safety.

3.4.3 Reactor Coolant At all times LCO 3.4.3 is applicable at all times. The System (RCS) ACTION required for not meeting the LCO Pressure and is to immediately restore the parameters to Temperature within limits. Therefore, moving between Limits MODES and conditions while relying on the ACTION has no effect on the ACTIONS taken or the level of protection provided.

3.4.7 RCS Loops - MODE 5 with When in this Specification, it is possible to MODE 5, Loops RCS loops move to MODE 5, loops not filled. The Filled filled ACTIONS for LCO 3.4.7 and LCO 3.4.8, RCS Loops - MODE 5, Loops Not Filled, are essentially the same. Therefore, transitioning from MODE 5, loops filled, to MODE 5, loops not filled, while relying on ACTIONS has no effect on the ACTIONS taken or the level of protection provided.

3.4.8 RCS Loops - MODE 5 with The Actions taken in LCO 3.4.8 for MODE MODE 5, Loops RCS loops 5, loops not filled are encompassed in the Not Filled not filled Actions taken in LCO 3.9.6, RHR and Coolant Circulation - Low Water Level and LCO 3.4.7, RCS Loops - MODE 5, Loops Filled. As a result, moving between these MODES and conditions while relying on the ACTIONS of LCO 3.4.8 provides the same level of protection. Therefore, moving between MODES and conditions while relying on the ACTIONS has no effect on the ACTIONS taken or the level of protection provided.

CNP Units 1 and 2 Page 14 of 23 Attachment 1, Volume 5, Rev. 0, Page 33 of 79

Attachment 1, Volume 5, Rev. 0, Page 34 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.4.12 Low Temperature MODE 4 The MODES 5 and 6 LTOP requirements Overpressure when any and ACTIONS are the same. Therefore, Protection (LTOP) RCS cold leg moving between MODE 6 and MODE 5 System temperature while relying on the ACTIONS has no is 266°F effect on the level of protection provided.

(Unit 1) and CORE ALTERATIONS and movement of 299°F (Unit irradiated fuel do not occur in MODE 6 2), MODE 5, with the reactor vessel head on.

MODE 6 when the reactor vessel head is on 3.7.10 Control Room MODES 1, 2, The ACTIONS are the same in all MODES Emergency 3, and 4, and conditions, or the ACTIONS preclude Ventilation System During moving irradiated fuel assemblies.

movement of Therefore, moving between MODES while irradiated fuel relying on ACTIONS will have no effect on assemblies in the ACTIONS being taken and has no the adverse effect on safety.

containment, auxiliary building, and opposite unit containment 3.7.11 Control Room Air MODES 1, 2, The ACTIONS are the same in all MODES Conditioning 3, and 4, and conditions, or the ACTIONS preclude System During moving irradiated fuel assemblies.

movement of Therefore, moving between MODES while irradiated fuel relying on ACTIONS will have no effect on assemblies the ACTIONS being taken and has no adverse effect on safety.

3.7.13 Fuel Handling During The ACTIONS require the immediate Area Exhaust movement of suspension of movement of irradiated fuel Ventilation System irradiated fuel assemblies within the auxiliary building.

assemblies in As a result, if the LCO is not met, it is the auxiliary immediately exited. It is not possible to building transition to other MODES or specified conditions while relying on the ACTIONS.

Therefore, changing MODES or conditions while relying on ACTIONS has no effect on safety.

CNP Units 1 and 2 Page 15 of 23 Attachment 1, Volume 5, Rev. 0, Page 34 of 79

Attachment 1, Volume 5, Rev. 0, Page 35 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.7.14 Fuel Storage Pool During The condition of the fuel storage pool is Water Level movement of not MODE-related. That is, fuel may be irradiated fuel moved in the fuel storage pool while the assemblies in reactor is in any MODE. The ACTIONS for the fuel fuel storage pool water level not within limit storage pool (i.e., suspend movement of irradiated fuel assemblies in the fuel storage pool) has no relation to the reactor MODE. Therefore, changing MODES or conditions while relying on ACTIONS has no effect on safety.

3.7.15 Fuel Storage Pool When fuel The condition of the fuel storage pool Boron assemblies boron concentration is not MODE-related.

Concentration are stored in That is, fuel may be stored in the fuel the fuel storage pool while the reactor is in any storage pool MODE. The ACTIONS for fuel storage and a fuel pool boron concentration not within limit storage pool (i.e., suspend movement of irradiated fuel verification assemblies in the fuel storage pool) has no has not been relation to the reactor MODE. Therefore, performed changing MODES or conditions while since the last relying on ACTIONS has no effect on movement of safety.

fuel assemblies in the fuel storage pool 3.7.16 Spent Fuel Whenever The condition of the location of a fuel Storage Pool any fuel assembly in the fuel storage pool is not assembly is MODE-related. That is, fuel may be stored stored in in the fuel storage pool while the reactor is Region 2 or 3 in any MODE. The ACTIONS for a fuel of the spent assembly stored in an inappropriate fuel storage Region of the fuel storage pool (i.e., initiate pool action to move the noncomplying fuel assembly from Region 2 or 3) has no relation to the reactor MODE. Therefore, changing MODES or conditions while relying on ACTIONS has no effect on safety.

CNP Units 1 and 2 Page 16 of 23 Attachment 1, Volume 5, Rev. 0, Page 35 of 79

Attachment 1, Volume 5, Rev. 0, Page 36 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.8.2 AC Sources - MODES 5 The requirements and Actions for AC Shutdown and 6, During Sources are the same in MODES 5 and 6 movement of and during movement of irradiated fuel irradiated fuel assemblies. As a result, moving between assemblies in MODES 5 and 6, or between MODE 6 and the movement of irradiated fuel assemblies, containment, has no effect on the level of protection auxiliary provided and no effect on safety.

building, and opposite unit containment 3.8.3 Diesel Fuel Oil When Diesel Fuel Oil is required to be within limit associated when the associated DG is required to be DG is OPERABLE. The DGs are required to be required to be OPERABLE in MODES 5 and 6, and OPERABLE during movement of irradiated fuel assemblies in the containment, auxiliary building, and the opposite unit containment. Therefore, see Discussion for ITS 3.8.2.

3.8.5 DC Sources - MODES 5 The requirements and ACTIONS for DC Shutdown and 6, During Sources are the same in MODES 5 and 6 movement of and during movement of irradiated fuel irradiated fuel assemblies. As a result, moving between assemblies in MODES 5 and 6, or between MODE 6 and the movement of irradiated fuel assemblies, containment, has no effect on the level of protection auxiliary provided and no effect on safety.

building, and opposite unit containment 3.8.6 Battery When Battery cell parameters are required to be Parameters associated within limits when the associated DC DC electrical subsystems are required to be power OPERABLE. Those subsystems are subsystems required to be OPERABLE in MODES 5 are required and 6, and during movement of irradiated to be fuel assemblies. Therefore, see OPERABLE Discussion for ITS 3.8.5.

CNP Units 1 and 2 Page 17 of 23 Attachment 1, Volume 5, Rev. 0, Page 36 of 79

Attachment 1, Volume 5, Rev. 0, Page 37 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.8.8 Inverters - MODES 5 The requirements and ACTIONS for Shutdown and 6, During Inverters - Shutdown are the same in movement of MODES 5 and 6 and during movement of irradiated fuel irradiated fuel assemblies. As a result, assemblies in moving between MODES 5 and 6, or the between MODE 6 and movement of containment, irradiated fuel assemblies, has no effect on auxiliary the level of protection provided and no building, and effect on safety.

opposite unit containment 3.8.10 Distribution MODES 5 The requirements and ACTIONS for Systems - and 6, During Distribution Systems - Shutdown are the Shutdown movement of same in MODES 5 and 6 and during irradiated fuel movement of irradiated fuel assemblies.

assemblies in As a result, moving between MODES 5 the and 6, or between MODE 6 and movement containment, of irradiated fuel assemblies, has no effect auxiliary on the level of protection provided and no building, and effect on safety.

opposite unit containment 3.9.1 Boron MODE 6 The boron concentration is required to be Concentration within limits in MODE 6. These limits also apply during CORE ALTERATIONS and movement of irradiated fuel assemblies within the containment, both of which occur in MODE 6. The MODE 5 requirements are less strict (i.e., less boron required) but also require immediate actions to restore the required SDM. As a result, moving between MODES 5 and 6, or between MODE 6 and CORE ALTERATIONS or movement of irradiated fuel assemblies in containment, while relying on the ACTIONS, would continue to require immediate action to restore compliance with the applicable LCO.

Therefore, allowing such movement has no effect on the level of protection provided and no effect on safety.

CNP Units 1 and 2 Page 18 of 23 Attachment 1, Volume 5, Rev. 0, Page 37 of 79

Attachment 1, Volume 5, Rev. 0, Page 38 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.9.2 Nuclear MODE 6 Two source range neutron detectors are Instrumentation required to be OPERABLE in MODE 6 to detect reactivity changes due to the movement of fuel or boron dilution. Failure to meet the LCO requires immediate action to suspend CORE ALTERATIONS and operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet LCO 3.9.1, and immediate action to restore one source range neutron detector to OPERABLE status. These requirements also apply during CORE ALTERATIONS and movement of irradiated fuel assemblies within the containment, both of which occur in MODE

6. The MODE 5 requirements on the source range neutron detectors only require suspension of operations involving positive reactivity additions when the detector(s) are inoperable, as fuel movement cannot occur in MODE 5. As a result, moving from MODE 6 to MODE 5, or between MODE 6 and CORE ALTERATIONS or movement of irradiated fuel in containment, while relying on the ACTIONS, would continue to require immediate action to eliminate initiating events for which the detectors provide protection and immediate action to restore the detector(s) to OPERABLE status.

Therefore, allowing such movement has no effect on the level of protection provided and no effect on safety.

3.9.3 Containment During The ACTIONS require the immediate Penetrations movement of suspension of movement of irradiated fuel irradiated fuel assemblies within the containment. As a assemblies result, if the LCO is not met, it is within immediately exited. It is not possible to containment transition to other MODES or specified conditions while relying on the ACTIONS.

Therefore, allowing movement between MODES 5 and 6 and conditions specified in the Applicability has no effect on the level of protection provided and no effect on safety.

CNP Units 1 and 2 Page 19 of 23 Attachment 1, Volume 5, Rev. 0, Page 38 of 79

Attachment 1, Volume 5, Rev. 0, Page 39 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.9.4 Residual Heat MODE 6 with This Technical Specification also applies Removal and the water during CORE ALTERATIONS and Coolant level 23 feet movement of irradiated fuel within the Circulation - High above the top containment, both of which occur in MODE Water Level of the reactor 6. Moving from MODE 6 to CORE vessel flange ALTERATIONS or movement of irradiated fuel assemblies within the containment has no effect on the ACTIONS and the level of protection provided. Moving to MODE 5 with RCS loops filled or not filled (LCO 3.4.7 or LCO 3.4.8) while relying on ACTIONS is not possible since the water level is above the top of the reactor vessel head. Moving from MODE 6 with water 23 feet to MODE 6 with water < 23 feet (LCO 3.9.5) while relying on ACTIONS will invoke either the same ACTIONS (ACTION B) or requires immediately initiation of action to raise the water level to 23 feet, which exits LCO 3.9.5 and re-enters LCO 3.9.4. Therefore, allowing movement between MODES and conditions specified in the Applicability has no effect on the level of protection provided and no effect on safety.

3.9.5 Residual Heat MODE 6 with CORE ALTERATIONS and movement of Removal and the water irradiated fuel within the containment are Coolant level < 23 feet prohibited in this condition by LCO 3.9.6.

Circulation - Low above the top Moving to MODE 5 with RCS loops filled or Water Level of the reactor not filled (LCO 3.4.7 or LCO 3.4.8) while vessel flange relying on ACTIONS will invoke ACTIONS that are equivalent to the those provided in this Technical Specification. Therefore, there is no effect on the level of protection provided. Moving from MODE 6 with water

< 23 feet to MODE 6 with water 23 feet (LCO 3.9.4) while relying on ACTIONS is allowed by LCO 3.9.5, Required Action A.2. Therefore, allowing movement between MODES and conditions specified in the Applicability has no effect on the level of protection provided and no effect on safety.

CNP Units 1 and 2 Page 20 of 23 Attachment 1, Volume 5, Rev. 0, Page 39 of 79

Attachment 1, Volume 5, Rev. 0, Page 40 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY ITS SPECIFICATION REQUIREMENT APPLICABILITY DISCUSSION 3.9.6 Refueling Cavity During The ACTIONS require the immediate Water Level movement of suspension of movement of irradiated fuel irradiated fuel assemblies within the containment. As a assemblies result, the ACTIONS require the exiting of within the Technical Specification. Therefore, it containment is not possible to change MODES or conditions while relying on the ACTIONS.

No circumstances were discovered in which restrictions should be applied to prevent moving from the Technical Specifications Applicability to other MODES or specified conditions, other than MODES 1, 2, 3, and 4, while relying on ACTIONS.

The addition of the ITS LCO 3.0.4 and ITS SR 3.0.4 phrase "or that are part of a shutdown of the unit" is necessary to clarify that transitioning to lower MODES is acceptable during the normal shutdown of the unit. Normal shutdowns may be shutdowns required by Technical Specifications that are commenced early (e.g.,

prior to the absolutely required shutdown, such as day 2 of an allowed 7 day Completion Time) or shutdowns for other purposes such as refueling. Normal shutdowns would typically be performed with a full complement of OPERABLE safety systems consistent with the Bases of ITS LCO 3.0.4, which states "The provisions of this Specification are not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability."

The addition of the allowance to perform a normal shutdown while relying on ACTIONS is appropriate because the Technical Specifications contain appropriate controls to ensure the safety of the unit in these conditions. As the unit transitions to lower MODES, less equipment is required to be OPERABLE.

For the equipment that is required to be OPERABLE in lower MODES, Required Actions can be divided into three categories.

Some Required Actions provide a limited period of time to restore compliance with the LCO, and then require that the unit be transitioned to a lower MODE to exit the Applicability of the LCO. Entering the Applicability of these LCOs while relying on ACTIONS as part of a normal shutdown does not provide any additional flexibility than entering the ACTION while already in the Applicability, as the Required Actions of the LCO would eventually require this transition.

Some Required Actions provide a requirement to immediately take action to restore compliance with the LCO or exit the Applicability of the LCO (e.g., immediately stop CORE ALTERATIONS). It is not permissible to intentionally enter Conditions in which the Required Action requires immediate action to remedy the condition. Therefore, these ACTIONS do not provide additional flexibility.

CNP Units 1 and 2 Page 21 of 23 Attachment 1, Volume 5, Rev. 0, Page 40 of 79

Attachment 1, Volume 5, Rev. 0, Page 41 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY

Some Required Actions allow continued operation in the Condition.

Under ITS LCO 3.0.4, entry into those LCOs is allowed as the Required Actions provide appropriate compensatory measures.

Therefore, the allowance to enter a MODE or other specified condition in the Applicability while relying on ACTIONS during a normal shutdown does not provide inappropriate flexibility, and no additional restrictions are needed in the ITS. This change has been designated as less restrictive as it allows MODE changes in conditions that were prohibited under the CTS.

L.3 CTS 4.0.2 states "Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval." ITS SR 3.0.2 states "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications." This changes the CTS by adding, "If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance." The remaining changes to CTS 4.0.2 are discussed in DOC A.12 and DOC M.1.

This change is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions which must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time without extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because additional time is provided to perform some periodic Required Actions.

L.4 The second paragraph of CTS 4.0.3 puts a limit on the amount of time allowed to delay declaring the LCO not met when it is discovered that a Surveillance has not been performed within its specified Frequency. The limit is "up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is less." ITS SR 3.0.3 allows the limit to be the greater of the two above times: "up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater." In addition, ITS SR 3.0.3 also states "A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed." This changes the CTS by allowing a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and a maximum time of up to the specified Frequency to perform the missed Surveillance, provided a risk evaluation is performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The purpose of CTS 4.0.3 is to permit the delay of the ACTIONS of the LCO when a required Surveillance has not been performed. ITS SR 3.0.3 allows an increase in the delay time to a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and a maximum of up to the CNP Units 1 and 2 Page 22 of 23 Attachment 1, Volume 5, Rev. 0, Page 41 of 79

Attachment 1, Volume 5, Rev. 0, Page 42 of 79 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY limit of the specified Surveillance Frequency, if it is greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

However, a delay of greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is only allowed if a risk evaluation is performed and the risk impact of delaying the Surveillance is managed.

The proposed change will not allow equipment known to be inoperable to be considered OPERABLE until the missed Surveillance is performed. If it is known that the missed Surveillance could not be met, SR 3.0.3 requires the affected LCO to be declared not met and the appropriate Condition(s) be entered. In addition, the Bases for SR 3.0.3 state that the use of the delay period is not intended to be used as an operational convenience to extend Surveillance intervals, but only for the performance of missed Surveillance(s).

This change also includes details in the Bases on how to implement the new allowance. The Bases provide guidance for Surveillance Frequencies that are not based on time intervals, but are based on specified plant conditions, operating conditions, or requirements of regulations. In addition, the Bases state that the licensee is expected to perform any missed Surveillance at the first reasonable opportunity, taking into account appropriate considerations such as impact on plant risk and analysis assumptions, consideration of plant conditions, planning, availability of personnel, and the time required to perform the Surveillance. The Bases further states that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, Regulatory Guide (RG) 1.182, and that the missed Surveillance should be treated as an emergent condition as discussed in RG 1.182. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine that the risk increase is significant, the evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Since the most probable result of performing a missed Surveillance is the verification of conformance with the requirements, and the risk of extending the performance of the missed Surveillance greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is controlled as discussed above, this change is considered acceptable. The change is also consistent with the guidance provided in the Federal Register on September 28, 2001 (66 FR 49714), which provided the notice of availability for licensees to incorporate TSTF-358, as modified, through the Consolidated Line Item Improvement Process. The time allowed to perform a missed Surveillance prior to taking the ACTIONS is based on the allowed outage time in CTS 4.0.3 and on the Surveillance Frequency in ITS SR 3.0.3.

This change is designated as less restrictive because it provides additional time to perform a missed Surveillance prior to declaring the LCO not met and taking the ACTIONS.

CNP Units 1 and 2 Page 23 of 23 Attachment 1, Volume 5, Rev. 0, Page 42 of 79

Attachment 1, Volume 5, Rev. 0, Page 43 of 79 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 5, Rev. 0, Page 49 of 79 JUSTIFICATION FOR DEVIATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY

1. Typographical/grammatical error corrected.

2. Reviewers Notes are deleted as they are not part of the plant-specific ITS.

3. 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.

4. Change made to be consistent with a change made in another Specification.

5. The brackets have been removed and the proper plant specific information/value has been provided.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 49 of 79

Attachment 1, Volume 5, Rev. 0, Page 50 of 79 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 5, Rev. 0, Page 62 of 79 B 3.0 TSTF-434 INSERT 1 Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the entire Surveillance is performed within the specified Frequency.

Additionally, the definitions related to instrument testing (e.g., CHANNEL CALIBRATION) specify that these tests are performed by means of any series of sequential, overlapping, or total steps.

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Attachment 1, Volume 5, Rev. 0, Page 68 of 79 JUSTIFICATION FOR DEVIATIONS ITS SECTION 3.0 BASES, LCO AND SR APPLICABILITY

1. ITS LCO 3.0.1 and ITS SR 3.0.1 Applicabilities only apply to Specifications in ITS Sections 3.1 through 3.9; they do not apply to Specifications in Chapter 4.0 and Chapter 5.0 unless specifically stated in those Specifications. Therefore, this statement has been added for clarity.

2. Typographical/grammatical error corrected.

3. Changes have been made for consistency with similar discussions/terminology in the Bases.

4. The Bases are changed to reflect a change to the Specifications.

5. The bracketed information has been deleted since the CNP ITS does not include this option.

6. The brackets have been removed and the proper plant specific information/value has been provided.

7. The Figure has been moved to the end of the Section, consistent with the format of the ITS.

8. The ITS SR 3.0.3 Bases allows credit to be taken for unplanned events that satisfy Surveillances. The Bases further states that this allowance also includes those SRs whose performance is normally precluded in a given MODE or other specified condition. This portion of the allowance has been deleted. As documented in Part 9900 of the NRC Inspection Manual, Technical Guidance - Licensee Technical Specifications Interpretations, and in the Bases Control Program (ITS 5.5.12), neither the Technical Specifications Bases nor Licensee generated interpretations can be used to change the Technical Specification requirements. Thus, if the Technical Specifications preclude performance of an SR in certain MODES (as is the case for some SRs in ITS Section 3.8), the Bases cannot change the Technical Specifications requirement and allow the SR to be credited for being performed in the restricted MODES, even if the performance is unplanned.

9. 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 5, Rev. 0, Page 68 of 79

Attachment 1, Volume 5, Rev. 0, Page 69 of 79 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 5, Rev. 0, Page 70 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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.

CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statement." ITS LCO 3.0.4 states "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time." The ITS now allows MODE or other specified condition changes while relying on ACTIONS, provided the ACTIONS permit continued operation in the MODE or other specified condition in the Applicability for an unlimited amount of time.

The allowance to enter a MODE or other specified condition in the Applicability with the LCO not met when the ACTIONS allow unlimited operation is acceptable because ACTIONS which allow unlimited operation provide appropriate compensatory measures which protect the safety functions affected by the LCO not being met. In such a condition, allowing the unit to enter a MODE or other specified condition in which the LCO is applicable will have no detrimental effect on safety. For example, the ACTIONS for an inoperable containment isolation valve allow unlimited operation provided that the valve is in its required position assumed in the safety analysis. Therefore, the safety function being protected by the LCO (in this example, containment isolation) continues to be protected. This change is designated as less restrictive because it will allow changes in MODES or other specified conditions in the Applicability under circumstances that would be prohibited in the CTS.

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

as discussed below:

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

Response: No.

The proposed change allows entering a MODE or other specified condition in the Applicability when the LCO is not met provided that the ACTIONS to be entered permit continued operation for an unlimited period of time. If the inoperability of a component or variable could increase the probability of an accident previously evaluated, the corresponding ACTIONS would not allow operation in that condition for an unlimited period of time. As a result, the probability of an accident previously evaluated is not significantly affected by this change.

CNP Units 1 and 2 Page 1 of 10 Attachment 1, Volume 5, Rev. 0, Page 70 of 79

Attachment 1, Volume 5, Rev. 0, Page 71 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY ACTIONS which allow operation for an unlimited period of time with an inoperable component or variable provide compensatory measures that protect the affected safety function, including any mitigation actions assumed in accidents previously evaluated. For example, inoperable isolation valves are closed or inoperable instrument channels are placed in trip. Since the affected safety functions continue to be protected, the mitigation functions of the component or variable continue to be performed. As a result, the consequences of any accident previously evaluated are not increased significantly. 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 entering a MODE or other specified condition in the Applicability when the LCO is not met provided that the ACTIONS to be entered permit continued operation for an unlimited period of time. 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 in that operation of the unit while complying with ACTIONS is common. 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 entering a MODE or other specified condition in the Applicability when the LCO is not met provided that the ACTIONS to be entered permit continued operation for an unlimited period of time. This change will allow unit operation in MODES or other specified conditions in the Applicability while relying on ACTIONS that would have been previously prohibited. However, ACTIONS that allow operation for an unlimited period of time with an inoperable component or variable provide adequate compensatory measures which ensure the affected safety function is maintained. As a result, the margin of safety is not significantly affected. 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 10 Attachment 1, Volume 5, Rev. 0, Page 71 of 79

Attachment 1, Volume 5, Rev. 0, Page 72 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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.

CTS 3.0.4 and CTS 4.0.4 are applicable in all MODES and prevent entry into a MODE or other specified condition in the Applicability unless the LCO or SR, respectively, is satisfied. ITS LCO 3.0.4 and ITS SR 3.0.4 add a statement that they are "only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4." In addition, ITS LCO 3.0.4 and ITS SR 3.0.4 add a statement that "This provision shall not prevent entry into MODES or other specified conditions in the Applicability . . . that are part of a shutdown of the unit."

This change in Applicability from all MODES to MODES 1, 2, 3, and 4 is acceptable because the applicable Technical Specifications contain adequate measures to allow MODE changes while relying on ACTIONS. A review of the ITS that are applicable in the MODES and conditions other than MODES 1, 2, 3, and 4 has determined that adequate controls are applied so that relying on ACTIONS in this condition does not have an adverse effect on safety. This change has been designated as less restrictive as it restricts applicability of a current requirement to fewer conditions.

The addition of the ITS LCO 3.0.4 and ITS SR 3.0.4 phrase "or that are part of a shutdown of the unit" is necessary to clarify that transitioning to lower MODES is acceptable during the normal shutdown of the unit. Normal shutdowns may be shutdowns required by Technical Specifications that are commenced early (e.g., prior to the absolutely required shutdown, such as day 2 of an allowed 7 day Completion Time) or shutdowns for other purposes such as refueling. Normal shutdowns would typically be performed with a full complement of OPERABLE safety systems consistent with the Bases of ITS LCO 3.0.4, which states "The provisions of this Specification are not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability."

The addition of the allowance to perform a normal shutdown while relying on ACTIONS is appropriate because the Technical Specifications contain appropriate controls to ensure the safety of the unit in these conditions. As the unit transitions to lower MODES, less equipment is required to be OPERABLE. For the equipment that is required to be OPERABLE in lower MODES, Required Actions can be divided into three categories.

Some Required Actions provide a limited period of time to restore compliance with the LCO, and then require that the unit be transitioned to a lower MODE to exit the Applicability of the LCO. Entering the Applicability of these LCOs while relying on ACTIONS as part of a normal shutdown does not provide any additional flexibility than entering the ACTION while already in the Applicability, as the Required Actions of the LCO would eventually require this transition.

CNP Units 1 and 2 Page 3 of 10 Attachment 1, Volume 5, Rev. 0, Page 72 of 79

Attachment 1, Volume 5, Rev. 0, Page 73 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY

Some Required Actions provide a requirement to immediately take action to restore compliance with the LCO or exit the Applicability of the LCO (e.g.,

immediately stop CORE ALTERATIONS). It is not permissible to intentionally enter Conditions in which the Required Action requires immediate action to remedy the condition. Therefore, these ACTIONS do not provide additional flexibility.

Some Required Actions allow continued operation in the Condition. Under ITS LCO 3.0.4, entry into those LCOs is allowed as the Required Actions provide appropriate compensatory measures.

Therefore, the allowance to enter a MODE or other specified condition in the Applicability while relying on ACTIONS during a normal shutdown does not provide inappropriate flexibility, and no additional restrictions are needed in the ITS. This change has been designated as less restrictive as it allows MODE changes in conditions that were prohibited under the CTS.

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

as discussed below:

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

Response: No.

The proposed change limits the prohibition on entering a MODE or condition specified in the Applicability when the LCO or SR is not met from all MODES to MODES 1, 2, 3, and 4. The proposed change also allows the unit to be shutdown, similar to the allowance already in the CTS to allow a shutdown if it is required by the CTS ACTIONS. This change does not affect the probability of an accident. The ACTIONS for MODES 5 and 6 have been reviewed and it was determined that MODE changes allowed under this change do not alter any initiators to accidents or mitigation of these accidents. The consequences of a normal unit shutdown with inoperable equipment are no different than the consequences of a unit shutdown required by the CTS ACTIONS. 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 limits the prohibition on entering a MODE or condition specified in the Applicability when the LCO or SR is not met from all MODES to MODES 1, 2, 3, and 4, and also allows a normal plant shutdown while relying on the ACTIONS. This change will not physically alter the plant (no new or different CNP Units 1 and 2 Page 4 of 10 Attachment 1, Volume 5, Rev. 0, Page 73 of 79

Attachment 1, Volume 5, Rev. 0, Page 74 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY type of equipment will be installed). Also, the change does not involve 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 limits the prohibition on entering a MODE or condition specified in the Applicability when the LCO or SR is not met from all MODES to MODES 1, 2, 3, and 4, and also allows a normal plant shutdown while relying on the ACTIONS. The margin of safety is not affected by this change because the ACTIONS that are allowed under this change have been verified to contain adequate remedial measures to maintain the safety analysis assumptions. In addition, the CTS already allows a unit shutdown if required by the CTS ACTIONS. Thus, the margin of safety impact is no different during a normal unit shutdown while relying on similar CTS ACTIONS. 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 5 of 10 Attachment 1, Volume 5, Rev. 0, Page 74 of 79

Attachment 1, Volume 5, Rev. 0, Page 75 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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.

CTS 4.0.2 states "Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval." ITS SR 3.0.2 states "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications." This changes the CTS by adding, "If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance." The remaining changes to CTS 4.0.2 are discussed in DOC A.12 and DOC M.1.

This change is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions which must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time without extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because additional time is provided to perform some periodic Required Actions.

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 the Completion Time for periodic actions to be extended by 25%. This change does not affect the probability of an accident.

The length of time between performance of Required Actions is not an initiator to any accident previously evaluated. The consequences of any accident previously evaluated are the same during the Completion Time or during any extension of the Completion Time. As a result, the consequences of any accident previously evaluated are not increased. Therefore, the proposed change does CNP Units 1 and 2 Page 6 of 10 Attachment 1, Volume 5, Rev. 0, Page 75 of 79

Attachment 1, Volume 5, Rev. 0, Page 76 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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 the Completion Time for periodic actions to be extended by 25%. This change will not physically alter the plant (no new or different type of equipment will be installed). Also, the change does not involve 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 allows the Completion Time for periodic actions to be extended by 25%. The 25% extension allowance is provided for scheduling convenience and is not expected to have a significant effect on the average time between Required Actions. As a result, the Required Actions will continue to provide appropriate compensatory measures for the subject Condition.

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 10 Attachment 1, Volume 5, Rev. 0, Page 76 of 79

Attachment 1, Volume 5, Rev. 0, Page 77 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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 second paragraph of CTS 4.0.3 puts a limit on the amount of time allowed to delay declaring the LCO not met when it is discovered that a Surveillance has not been performed within its specified Frequency. The limit is "up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is less." ITS SR 3.0.3 allows the limit to be the greater of the two above times: "up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater." In addition, ITS SR 3.0.3 also states "A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed." This changes the CTS by allowing a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and a maximum time of up to the specified Frequency to perform the missed Surveillance, provided a risk evaluation is performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The purpose of CTS 4.0.3 is to permit the delay of the ACTIONS of the LCO when a required Surveillance has not been performed. ITS SR 3.0.3 allows an increase in the delay time to a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and a maximum of up to the limit of the specified Surveillance Frequency, if it is greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . However, a delay of greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is only allowed if a risk evaluation is performed and the risk impact of delaying the Surveillance is managed.

The proposed change will not allow equipment known to be inoperable to be considered OPERABLE until the missed Surveillance is performed. If it is known that the missed Surveillance could not be met, SR 3.0.3 requires the affected LCO to be declared not met and the appropriate Condition(s) be entered. In addition, the Bases for SR 3.0.3 state that the use of the delay period is not intended to be used as an operational convenience to extend Surveillance intervals, but only for the performance of missed Surveillance(s).

This change also includes details in the Bases on how to implement the new allowance.

The Bases provide guidance for Surveillance Frequencies that are not based on time intervals, but are based on specified plant conditions, operating conditions, or requirements of regulations. In addition, the Bases state that the licensee is expected to perform any missed Surveillance at the first reasonable opportunity, taking into account appropriate considerations, such as impact on plant risk and analysis assumptions, consideration of plant conditions, planning, availability of personnel, and the time required to perform the Surveillance. The Bases further states that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, Regulatory Guide (RG) 1.182, and that the missed Surveillance should be treated as an emergent condition as discussed in RG 1.182. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine that the risk CNP Units 1 and 2 Page 8 of 10 Attachment 1, Volume 5, Rev. 0, Page 77 of 79

Attachment 1, Volume 5, Rev. 0, Page 78 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY increase is significant, the evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Since the most probable result of performing a missed Surveillance is the verification of conformance with the requirements, and the risk of extending the performance of the missed Surveillance greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is controlled as discussed above, this change is considered acceptable. The change is also consistent with the guidance provided in the Federal Register on September 28, 2001 (66 FR 49714), which provided the notice of availability for licensees to incorporate TSTF-358, as modified, through the Consolidated Line Item Improvement Process. The time allowed to perform a missed Surveillance prior to taking the ACTIONS is based on the allowed outage time in CTS 4.0.3 and on the Surveillance Frequency in ITS SR 3.0.3.

This change is designated as less restrictive because it provides additional time to perform a missed Surveillance prior to declaring the LCO not met and taking the ACTIONS.

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

as discussed below:

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

Response: No.

The proposed change relaxes the time allowed to perform a missed Surveillance.

The time between Surveillances is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be OPERABLE and capable of performing the accident mitigation functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly affected. Any reduction in confidence that a standby system might fail to perform its safety function due to a missed Surveillance is small, and in the absence of other unrelated failures would not lead to an increase in consequences beyond those estimated by existing analyses. The addition of a requirement to assess and manage the risk introduced by the missed Surveillance will further minimize possible concerns.

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

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

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. A missed Surveillance will not, in and of itself, CNP Units 1 and 2 Page 9 of 10 Attachment 1, Volume 5, Rev. 0, Page 78 of 79

Attachment 1, Volume 5, Rev. 0, Page 79 of 79 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY introduce new failure modes or effects and any increased chance that a standby system might fail to perform its safety function due to a missed Surveillance would not, in the absence of other unrelated failures, lead to an accident beyond those previously evaluated. The addition of a requirement to assess and manage the risk introduced by the missed Surveillance will further minimize possible concerns. 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?

The extended time allowed to perform a missed Surveillance does not result in a significant reduction in the margin of safety. As supported by the historical data, the likely outcome of any Surveillance is verification that the LCO is met. Failure to perform a Surveillance within the prescribed Frequency does not cause equipment to become inoperable. The only effect of the additional time allowed to perform a missed Surveillance on the margin of safety is the extension of the time until inoperable equipment is discovered to be inoperable by the missed Surveillance. However, given the rare occurrence of inoperable equipment, and the rare occurrence of a missed Surveillance, a missed Surveillance on inoperable equipment would be very unlikely. This must be balanced against the real risk of manipulating the plant equipment or condition to perform the missed Surveillance. In addition, parallel trains and alternate equipment are typically available to perform the safety function of the equipment not tested. Thus, there is confidence that the equipment can perform its assumed safety function.

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

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

CNP Units 1 and 2 Page 10 of 10 Attachment 1, Volume 5, Rev. 0, Page 79 of 79

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