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CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 6, Rev 0, ITS Section 3.1 Reactivity Control Systems.
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Issue date:	04/06/2004
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Attachment 1, Volume 6, Rev. 0, Page 1 of 357 VOLUME 6 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.1 REACTIVITY CONTROL SYSTEMS Revision 0 Attachment 1, Volume 6, Rev. 0, Page 1 of 357

Attachment 1, Volume 6, Rev. 0, Page 2 of 357 LIST OF ATTACHMENTS

1. ITS 3.1.1

2. ITS 3.1.2

3. ITS 3.1.3

4. ITS 3.1.4

5. ITS 3.1.5

6. ITS 3.1.6

7. ITS 3.1.7

8. ITS 3.1.8

9. Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 6, Rev. 0, Page 2 of 357

, Volume 6, Rev. 0, Page 3 of 357 ATTACHMENT 1 ITS 3.1.1, SDM , Volume 6, Rev. 0, Page 3 of 357

, Volume 6, Rev. 0, Page 4 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 4 of 357

Attachment 1, Volume 6, Rev. 0, Page 5 of 357 ITS 3.1.1 A.1 ITS A.2 within the limits specified in the COLR LA.1 LCO 3.1.1 with keff < 1.0 A.3 A.4 not within limits within 15 minutes LA.1 ACTION A L.1 L.2 within limits LA.1 SR 3.1.1.1 See ITS 3.1.4 See ITS Chapter 1.0 See ITS 3.1.6 L.3 A.4 Page 1 of 10 Attachment 1, Volume 6, Rev. 0, Page 5 of 357

Attachment 1, Volume 6, Rev. 0, Page 6 of 357 ITS 3.1.1 A.1 ITS MODE 2 with keff < 1.0 M.1 SR 3.1.1.1 LA.2 See ITS 3.1.2 230 Page 2 of 10 Attachment 1, Volume 6, Rev. 0, Page 6 of 357

Attachment 1, Volume 6, Rev. 0, Page 7 of 357 ITS 3.1.1 A.1 ITS A.2 within the limits specified in the COLR LA.1 LCO 3.1.1 LA.1 not within limits within 15 minutes L.1 L.2 ACTION A within limits LA.1 SR 3.1.1.1 See ITS 3.1.4 See ITS Chapter 1.0 SR 3.1.1.1 LA.2 Page 3 of 10 Attachment 1, Volume 6, Rev. 0, Page 7 of 357

Attachment 1, Volume 6, Rev. 0, Page 8 of 357 ITS 3.1.1 A.1 ITS Page 4 of 10 Attachment 1, Volume 6, Rev. 0, Page 8 of 357

Attachment 1, Volume 6, Rev. 0, Page 9 of 357 ITS 3.1.1 A.1 ITS Page 5 of 10 Attachment 1, Volume 6, Rev. 0, Page 9 of 357

Attachment 1, Volume 6, Rev. 0, Page 10 of 357 ITS 3.1.1 A.1 ITS A.2 within the limits specified in the COLR LA.1 LCO 3.1.1 with keff < 1.0 A.3 A.4 not within limits within 15 minutes LA.1 L.1 ACTION A L.2 within limits LA.1 SR 3.1.1.1 See ITS 3.1.4 See ITS Chapter 1.0 See ITS 3.1.6 L.3 A.4 Page 6 of 10 Attachment 1, Volume 6, Rev. 0, Page 10 of 357

Attachment 1, Volume 6, Rev. 0, Page 11 of 357 ITS 3.1.1 A.1 ITS MODE 2 with keff < 1.0 M.1 SR 3.1.1.1 LA.2 See ITS 3.1.2 Page 7 of 10 Attachment 1, Volume 6, Rev. 0, Page 11 of 357

Attachment 1, Volume 6, Rev. 0, Page 12 of 357 ITS 3.1.1 A.1 ITS A.2 within the limits specified in the COLR LA.1 LCO 3.1.1 LA.1 not within limits within 15 minutes L.1 L.2 ACTION A within limits LA.1 SR 3.1.1.1 See ITS 3.1.4 See ITS Chapter 1.0 SR 3.1.1.1 LA.2 Page 8 of 10 Attachment 1, Volume 6, Rev. 0, Page 12 of 357

Attachment 1, Volume 6, Rev. 0, Page 13 of 357 ITS 3.1.1 A.1 ITS Page 9 of 10 Attachment 1, Volume 6, Rev. 0, Page 13 of 357

Attachment 1, Volume 6, Rev. 0, Page 14 of 357 ITS 3.1.1 A.1 ITS Page 10 of 10 Attachment 1, Volume 6, Rev. 0, Page 14 of 357

Attachment 1, Volume 6, Rev. 0, Page 15 of 357 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN (SDM)

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 3.1.1.1 provides SHUTDOWN MARGIN (SDM) requirements in MODES 1, 2, 3, and 4. CTS 3.1.1.2 provides SDM requirements in MODE 5. ITS 3.1.1 provides SDM requirements in MODE 2 with keff < 1.0 and MODES 3, 4, and 5.

This changes the CTS by combining the SDM requirements for MODE 2 with keff < 1.0 and MODES 3, 4, and 5. The change in Applicability for MODE 1 and MODE 2 with keff > 1.0 are described in DOC A.3.

This change is acceptable because the requirements have not changed.

Combining the Specifications is an editorial change. Any technical changes resulting from this combination are discussed in other DOCs. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 3.1.1.1 provides SDM requirements in MODES 1, 2, 3, and 4. CTS 4.1.1.1.1.b states that when in MODES 1 and 2 with keff > 1.0, verify that the control bank withdrawal is within the limits of Specification 3.1.3.5 (Unit 1) and Specification 3.1.3.6 (Unit 2), Control Rod Insertion Limits. ITS 3.1.1 is Applicable in MODE 2 with keff < 1.0 and MODES 3, 4, and 5. ITS 3.1.6 contains the control bank insertion requirements. This changes the CTS by dividing the SDM requirements and placing those applicable in MODE 2 with keff < 1.0 and MODES 3, 4, and 5 in ITS 3.1.1 and placing those applicable in MODE 1 and MODE 2 with keff >1.0 in the control bank Specifications.

The purpose of CTS 3.1.1.1 is to ensure that the SDM assumed in the accident analyses is available. When the reactor is critical, SDM is verified by ensuring that the control rods are within the control rod insertion limits. The Applicability Bases to ITS 3.1.1 states that in MODES 1 and 2, SDM is ensured by complying with LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits." This change is acceptable because the SDM requirements have not changed. Even though CTS 3.1.1.1 is applicable in MODES 1 and 2, the CTS Surveillances only requires the verification that control rod bank withdrawal is within the control rod insertion limits (i.e., CTS 3.1.3.5 (Unit 1) and CTS 3.1.3.6 (Unit 2)). The ITS also verifies SDM in MODES 1 and 2 by the rod insertion limits. Any changes to the rod insertion limit requirements are discussed in DOCs for those Specifications. This change is designated as administrative because it does not result in a technical change to the CTS.

A.4 The Applicability of CTS 3.1.1.1 is MODES 1, 2, 3, and 4 with a footnote for MODE 2 stating "See Special Test Exception 3.10.1." ITS 3.1.1 Applicability does not contain the footnote or a reference to the Special Test Exception.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 6, Rev. 0, Page 15 of 357

Attachment 1, Volume 6, Rev. 0, Page 16 of 357 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN (SDM)

The purpose of the footnote reference is to alert the user that a Special Test Exception exists that may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 4.1.1.1.1.e requires SDM to be determined to be within its limit every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when in MODES 3 and 4. ITS SR 3.1.1.1 requires SDM to be determined to be within its limit not only in MODES 3 and 4, but also in MODE 2 with keff < 1.0. This changes the CTS by expanding the applicability of the Surveillance to include MODE 2 with keff < 1.0.

The purpose of the CTS 4.1.1.1.1.e is to verify that sufficient SDM is available.

CTS 4.1.1.1.1.b states that when the reactor is in MODE 1 and MODE 2 with keff > 1.0, SDM is verified by determining that the control rods are above the rod insertion limits. In MODE 2 with keff < 1.0, CTS 4.1.1.1.1.c verifies SDM by determining that the predicted critical position is within the rod insertion limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving criticality. However, no CTS Surveillance requires a periodic verification of SDM when in MODE 2 with keff < 1.0. This change is acceptable because the ITS requires specific verification that the SDM is within the limit when in MODE 2 with keff < 1.0 on a periodic basis. This change is designated as more restrictive because it expands the conditions under which a Surveillance must be performed.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.1.1.1 and associated Action and CTS 4.1.1.1.1 require that the SDM be > 1.3% k/k when in MODES 1, 2, 3, and 4. CTS 3.1.1.2 and associated Action and CTS 4.1.1.2 requires that the SDM be > 1.0% k/k when in MODE 5. ITS 3.1.1 states that the SDM shall be within the limits of the COLR, ITS 3.1.1 ACTION A provides actions for when the SDM is not within the limits, and ITS SR 3.1.1.1 requires verification that the SDM is within limits. This changes the CTS by relocating the SDM limits, which must be confirmed on a cycle-specific basis, to the COLR.

The removal of these cycle-specific parameter limits from the Technical Specifications to the COLR is acceptable because the cycle-specific limits are developed or utilized under NRC-approved methodologies which will ensure that the Safety Limits are met. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications,"

CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 6, Rev. 0, Page 16 of 357

Attachment 1, Volume 6, Rev. 0, Page 17 of 357 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN (SDM) that this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the SDM requirement. The methodologies used to develop the parameters in the COLR have obtained prior approval by the NRC in accordance with Generic Letter 88-16. Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.5, "Core Operating Limits Report." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.1.1.1.1.e and 4.1.1.2.b require determination that the SDM is within limits, and specifically require the consideration of the following factors: reactor coolant system boron concentration, control rod position, reactor coolant system average temperature, fuel burnup based on gross thermal energy generation, xenon concentration, samarium concentration, and boron penalty (MODES 4 and 5 only). ITS SR 3.1.1.1 requires determination that SDM is within limits, but does not describe the factors that must be considered in the calculation. This information is relocated to the Bases. This changes the CTS by removing details on how the SDM calculation is performed from the Specifications and placing the information in the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the SDM be within limits. The details of how SDM is calculated does not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.1.1.1 and CTS 3.1.1.2 Actions state that when the SDM is less than the applicable limit, boration must be initiated immediately. ITS 3.1.1 ACTION A states that when SDM is not within limits, boration must be initiated within 15 minutes. This changes the CTS by relaxing the Completion Time from "immediately" to 15 minutes.

The purpose of CTS 3.1.1.1 and CTS 3.1.1.2 Actions is to restore the SDM to within its limit promptly. This change is acceptable because the Completion Time CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 6, Rev. 0, Page 17 of 357

Attachment 1, Volume 6, Rev. 0, Page 18 of 357 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN (SDM) is consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. The ITS Completion Time of 15 minutes is adequate for an operator to correctly align and start the required systems and components. In addition, the ITS Bases for the ACTION state that boration must be initiated promptly. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.1.1.1 and CTS 3.1.1.2 Actions state that when the SDM is not within the applicable limits, boration must be initiated and continued at > 34 gpm of a solution containing > 6,550 ppm boron or equivalent until the required SDM is restored. ITS 3.1.1 ACTION A states that with the SDM not within limits, initiate boration to restore SDM to within limits. This changes the CTS by eliminating the specific values of flow rate and boron concentration that must be used to restore compliance with the LCO.

The purpose of the CTS 3.1.1.1 and CTS 3.1.1.2 Actions is to restore the SDM to within its limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Removing the specific values of flow rate and boron concentration from the CTS Action provides flexibility in the restoration of the SDM and eliminates conflicts between the SDM value and the specific boration values in the CTS Action. As stated in the ITS Bases for ACTION A, "In the determination of the required combination of boration flow rate and boron concentration, there is no unique requirement that must be satisfied. Since it is imperative to raise the boron concentration of the RCS as soon as possible, the boron concentration should be a highly concentrated solution, such as that normally found in the boric acid tank or the refueling water storage tank. The operator should borate with the best source available for the unit conditions."

Specifying a minimum flow rate and concentration in the ACTION may not accomplish the objective of raising the RCS boron concentration as soon as possible. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.1.1.1.d requires verification that SDM is within its limit, "Prior to initial operation above 5% RATED THERMAL POWER after each fuel loading, by consideration of the factors of e below, with the control banks at the maximum insertion limit of Specification 3.1.3.5 (Unit 1) and Specification 3.1.3.6 (Unit 2)." The ITS does not contain a similar requirement.

CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 6, Rev. 0, Page 18 of 357

Attachment 1, Volume 6, Rev. 0, Page 19 of 357 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN (SDM)

The purpose of CTS 4.1.1.1.1.d is to verify the core design predictions by determining the SDM with the control rods at the insertion limits. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify the LCO is within limit. The core design predictions, such as rod worth, boron worth, and critical boron concentration, are verified during the startup physics test program. Thus, the SDM continues to be verified in a manner and at a Frequency necessary to give confidence that the parameter is within limit. The critical boron concentration is verified periodically by ITS 3.1.2. Therefore, the core design parameters upon which SDM relies are verified before exceeding 5% RATED THERMAL POWER after each refueling outage. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 6, Rev. 0, Page 19 of 357

Attachment 1, Volume 6, Rev. 0, Page 20 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 20 of 357

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Attachment 1, Volume 6, Rev. 0, Page 22 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.1, SHUTDOWN MARGIN (SDM)

None.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 22 of 357

Attachment 1, Volume 6, Rev. 0, Page 23 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 23 of 357

, Volume 6, Rev. 0, Page 24 of 357 , Volume 6, Rev. 0, Page 24 of 357

Attachment 1, Volume 6, Rev. 0, Page 25 of 357 B 3.1.1 2

INSERT 1 Plant Specific Design Criterion (PSDC) 27 2 INSERT 2 provided. According to PSDC 28 (Ref. 1), the reactivity controls must be 2 INSERT 3 from any hot standby or hot operating condition. According to PSDC 29 (Ref. 1), one of the reactivity control systems provided shall be capable of making the core subcritical under any anticipated operating condition (including anticipated operational transients) sufficiently fast enough to prevent exceeding acceptable fuel damage limits. SDM should assure subcriticality with the most reactive RCCA fully withdrawn. According to PSDC 30, the reactivity control systems provided shall be capable of making the core subcritical under credible accident conditions with appropriate margins for contingencies, and shall be capable of limiting any subsequent return to power such that there will be no undue risk to the health and safety of the public.

2 INSERT 4 along with the shutdown and control rods 3

INSERT 5 When the unit is in MODE 1 or MODE 2 with the reactor critical, 3

INSERT 6 When the unit is in MODE 2 with the reactor subcritical, SDM control is ensured by operating with the shutdown banks fully withdrawn and the control banks within the estimated critical control bank position.

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Attachment 1, Volume 6, Rev. 0, Page 34 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.1 BASES, SHUTDOWN MARGIN (SDM)

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section of the UFSAR.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. Changes are made to the Background section to be consistent with the discussion in the Applicability section.

4. The Applicable Safety Analyses discussion states that SDM satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). It also says that even though SDM is not directly observed from the control room, SDM is considered an initial condition process variable because it is periodically monitored to ensure that the unit is operating within the bounds of the accident analysis assumptions. The additional sentence has been deleted. The NRC Final Policy Statement on Technical Improvements of July 22, 1993 (58 FR 39132) states that process variables captured by Criterion 2 are not limited to only those directly monitored and controlled from the control room.

It also states that Criterion 2 includes other features or characteristics that are specifically assumed in Design Basis Accident and Transient analyses even if they cannot be directly observed in the control room (e.g., moderator temperature coefficient and hot channel factors). Since the Final Policy Statement provides guidance on which types of parameters satisfy Criterion 2, there is no reason to duplicate these words in the CNP ITS.

5. 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.

6. 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 6, Rev. 0, Page 34 of 357

Attachment 1, Volume 6, Rev. 0, Page 35 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 35 of 357

Attachment 1, Volume 6, Rev. 0, Page 36 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.1, SHUTDOWN MARGIN (SDM)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 36 of 357

, Volume 6, Rev. 0, Page 37 of 357 ATTACHMENT 2 ITS 3.1.2, Core Reactivity , Volume 6, Rev. 0, Page 37 of 357

, Volume 6, Rev. 0, Page 38 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 38 of 357

Attachment 1, Volume 6, Rev. 0, Page 39 of 357 ITS 3.1.2 A.1 ITS Core Reactivity A.2 Add proposed LCO 3.1.2 A.2 See ITS 3.1.1 L.1 See ITS 3.1.1 See ITS 3.1.4 See ITS Chapter 1.0 See ITS 3.1.6 See ITS 3.1.1 Add proposed ACTIONS A and B L.2 See ITS 3.1.1 Page 1 of 4 Attachment 1, Volume 6, Rev. 0, Page 39 of 357

Attachment 1, Volume 6, Rev. 0, Page 40 of 357 ITS 3.1.2 A.1 ITS See ITS 3.1.1 M.1 Prior to entering MODE 1 after refueling and SR 3.1.2.1 L.3 LA.1 Page 2 of 4 Attachment 1, Volume 6, Rev. 0, Page 40 of 357

Attachment 1, Volume 6, Rev. 0, Page 41 of 357 ITS 3.1.2 A.1 ITS Core Reactivity A.2 Add proposed LCO 3.1.2 A.2 See ITS 3.1.1 L.1 See ITS 3.1.1 See ITS 3.1.4 See ITS Chapter 1.0 See ITS 3.1.6 See ITS 3.1.1 Add proposed ACTIONS A and B L.2 See ITS 3.1.1 Page 3 of 4 Attachment 1, Volume 6, Rev. 0, Page 41 of 357

Attachment 1, Volume 6, Rev. 0, Page 42 of 357 ITS 3.1.2 A.1 ITS See ITS 3.1.1 M.1 Prior to entering MODE 1 after refueling and SR 3.1.2.1 L.3 LA.1 Page 4 of 4 Attachment 1, Volume 6, Rev. 0, Page 42 of 357

Attachment 1, Volume 6, Rev. 0, Page 43 of 357 DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY 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 4.1.1.1.2 requires the overall core reactivity balance be compared to predicted values to demonstrate agreement within +/- 1% k/k. However, this Surveillance is currently part of the SHUTDOWN MARGIN Specification. A new LCO, ITS LCO 3.1.2, requires the measured core reactivity to be within

+/- 1% k/k of predicted values. This changes the CTS by having a separate Specification for the Core Reactivity requirement.

This change is acceptable because the requirements have not changed.

Converting the requirement from a Surveillance in the SHUTDOWN MARGIN Specification to an LCO is consistent with the ITS format and content guidance.

Any technical changes resulting from this change are discussed in other DOCs.

This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 ITS SR 3.1.2.1 requires the measured core reactivity to be determined to be within +/- 1% k/k of the predicted value prior to entering MODE 1 after each refueling. The CTS does not contain a similar requirement. This changes the CTS by adding an additional performance requirement for the core reactivity balance SR.

This change is acceptable because it requires a test that demonstrates agreement between the core design and the core design predictions prior to raising core power above 5% after each refueling. This verification, which is currently performed as part of the startup physics testing program, gives additional confidence that the core design is acceptable for operation at full power. This change is designated as more restrictive because it adds a Surveillance Requirement that does not appear in the CTS.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 6, Rev. 0, Page 43 of 357

Attachment 1, Volume 6, Rev. 0, Page 44 of 357 DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.1.1.1.2 requires comparison of the actual and predicted core reactivity balance and specifically requires consideration of at least those factors stated in Specification 4.1.1.1.1.e. CTS 4.1.1.1.1.e requires determination of SDM and requires the consideration of the following factors:

reactor coolant system boron concentration, control rod position, reactor coolant system average temperature, fuel burnup based on gross thermal energy generation, xenon concentration, and samarium concentration. ITS SR 3.1.2.1 requires comparison of the actual and predicted core reactivity, but does not describe the factors that must be considered in the calculation. This information is relocated to the Bases. This changes the CTS by removing details on how the core reactivity balance comparison calculation is performed from the CTS and placing the information in the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the core reactivity balance comparison be within +/- 1% k/k. The details of how this comparison is calculated does not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.

LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.1.1.1 is applicable in MODES 1, 2, 3, and 4. ITS 3.1.2 is applicable in MODES 1 and 2. This changes the CTS by reducing the applicable MODES in which the core reactivity requirement must be met.

The purpose of CTS Surveillance 4.1.1.1.2 is to verify the core design by comparing the actual and predicted core reactivity. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The core reactivity balance can only be determined when the reactor is critical (MODES 1 and 2). Additionally, the Surveillance Frequency is once per 31 EFPD, which only continues to accrue when the reactor is critical. Therefore, reducing the applicable MODES from MODES 1, 2, 3, and 4 to MODES 1 and 2 does not result in a reduction of the verification of this important measure of core design accuracy. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 6, Rev. 0, Page 44 of 357

Attachment 1, Volume 6, Rev. 0, Page 45 of 357 DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY L.2 (Category 4 - Relaxation of Required Action) CTS 3.1.1.1 does not contain Actions to follow if the core reactivity balance Surveillance is not met. If the core reactivity balance Surveillance was not met, LCO 3.0.3 would be entered.

LCO 3.0.3 requires the plant to be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . ITS 3.1.2 contains ACTIONS to follow if the core reactivity balance LCO is not met. If the LCO is not met, 7 days is provided to re-evaluate the core design and safety analysis, to determine that the reactor core is acceptable for continued operation, and to establish appropriate operating restrictions and SRs. If these actions are not completed within the 7 days, the plant must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by providing 7 days to evaluate and provide compensatory measures for not meeting the core reactivity balance requirement and then requiring entry into MODE 3 instead of requiring an immediate shutdown and entry into MODE 5.

The purpose of CTS 4.1.1.1.2 is to verify the accuracy of the core design by comparing the predicted and actual core reactivity throughout core life. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Should the core reactivity balance requirement not be met, time is required to determine the cause of the disagreement and what adjustments may be needed to the operating conditions of the core. The startup physics testing program is used to verify most of the critical core design parameters, such as control rod worth, boron worth, and moderator temperature coefficient. In addition, there is considerable conservatism in the application of these values in the accident analysis. Therefore, allowing a time to evaluate the difference and make any adjustments to the operational controls is acceptable. The 7 day Completion Time is reasonable considering the complexity of the evaluations and the time to meet administrative requirements, such as 10 CFR 50.59 safety evaluation preparation and approval. If it cannot be determined within 7 days that the core is acceptable for continued operation, the unit must be shutdown. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Surveillance 4.1.1.1.2 requires the overall core reactivity balance to be compared with the predicted value once per 31 EFPD. The CTS also requires the predicted reactivity values to be adjusted (normalized) to correspond to the actual core conditions prior to exceeding a fuel burnup of 60 EFPD after each fuel loading. ITS SR 3.1.2.1 also allows the measured core reactivity to be compared to the predicted values every 31 EFPD, but the ITS SR is only required after 60 EFPD of core burnup. The ITS also requires the adjustment of the predicted values to the actual values prior to exceeding a fuel burnup of 60 EFPD after each fuel loading. This changes the CTS by not requiring the periodic, at-power core reactivity comparison until core burnup reaches 60 EFPD.

CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 6, Rev. 0, Page 45 of 357

Attachment 1, Volume 6, Rev. 0, Page 46 of 357 DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY The purpose of CTS 4.1.1.1.2 is to verify the agreement between the actual and predicted core reactivity. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The CTS and the ITS requires the predicted core reactivity values to be normalized to the actual values prior to exceeding 60 EFPD of core burnup. This allows sufficient time for core conditions to reach steady state, but prevents operation for a large fraction of the fuel cycle without establishing a benchmark for the design calculations. The required subsequent Frequency of 31 EFPD, following the initial 60 EFPD after fuel loading, is acceptable, based on the slow rate of core reactivity changes due to fuel depletion and the presence of other indicators (QPTR, AFD, etc.) for prompt indication of an anomaly. In addition, a new Frequency has been added to ensure core reactivity is within limits prior to entering MODE 1 after each refueling (see DOC M.1). This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 6, Rev. 0, Page 46 of 357

Attachment 1, Volume 6, Rev. 0, Page 47 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 47 of 357

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, Volume 6, Rev. 0, Page 49 of 357 , Volume 6, Rev. 0, Page 49 of 357

Attachment 1, Volume 6, Rev. 0, Page 50 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.2, CORE REACTIVITY

1. ISTS SR 3.1.2.1 has been modified to be consistent with the current licensing basis.

The predicted reactivity values must (not may) be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 EFPD after each refueling. This is necessary to ensure there is a benchmark for the design calculations. This change is also consistent with the ISTS Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 50 of 357

Attachment 1, Volume 6, Rev. 0, Page 51 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 51 of 357

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, Volume 6, Rev. 0, Page 53 of 357 , Volume 6, Rev. 0, Page 53 of 357

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Attachment 1, Volume 6, Rev. 0, Page 59 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.2 BASES, CORE REACTIVITY

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section of the UFSAR.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

4. Changes made to be consistent with the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 59 of 357

Attachment 1, Volume 6, Rev. 0, Page 60 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 60 of 357

Attachment 1, Volume 6, Rev. 0, Page 61 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.2, CORE REACTIVITY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 61 of 357

, Volume 6, Rev. 0, Page 62 of 357 ATTACHMENT 3 ITS 3.1.3, Moderator Temperature Coefficient , Volume 6, Rev. 0, Page 62 of 357

, Volume 6, Rev. 0, Page 63 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 63 of 357

Attachment 1, Volume 6, Rev. 0, Page 64 of 357 ITS 3.1.3 A.1 ITS LCO 3.1.3 upper A.2 A.3 lower upper A.2 MODE 2 with keff < 1.0 ACTION A A.4 ACTION B A.5 L.1 L.2 ACTION C lower A.2 Applicability A.3 Page 1 of 6 Attachment 1, Volume 6, Rev. 0, Page 64 of 357

Attachment 1, Volume 6, Rev. 0, Page 65 of 357 ITS 3.1.3 A.1 ITS upper A.2 SR 3.1.3.1 SR 3.1.3.2 lower A.2 L.3 Page 2 of 6 Attachment 1, Volume 6, Rev. 0, Page 65 of 357

Attachment 1, Volume 6, Rev. 0, Page 66 of 357 ITS 3.1.3 A.1 ITS Figure 3.1.3-1

-4 10 A.6 Page 3 of 6 Attachment 1, Volume 6, Rev. 0, Page 66 of 357

Attachment 1, Volume 6, Rev. 0, Page 67 of 357 ITS 3.1.3 A.1 ITS LCO 3.1.3 upper A.2 A.3 lower upper A.2 MODE 2 with keff < 1.0 ACTION A A.4 ACTION B A.5 L.1 L.2 ACTION C lower A.2 Applicability A.3 Page 4 of 6 Attachment 1, Volume 6, Rev. 0, Page 67 of 357

Attachment 1, Volume 6, Rev. 0, Page 68 of 357 ITS 3.1.3 A.1 ITS upper A.2 SR 3.1.3.1 SR 3.1.3.2 L.3 lower A.2 Page 5 of 6 Attachment 1, Volume 6, Rev. 0, Page 68 of 357

Attachment 1, Volume 6, Rev. 0, Page 69 of 357 ITS 3.1.3 A.1 ITS Figure 3.1.3-1 10-4 A.6 Page 6 of 6 Attachment 1, Volume 6, Rev. 0, Page 69 of 357

Attachment 1, Volume 6, Rev. 0, Page 70 of 357 DISCUSSION OF CHANGES ITS 3.1.3, MODERATOR TEMPERATURE COEFFICIENT (MTC)

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 3.1.1.4 refers to the BOL MTC limit and the EOL MTC limit. ITS 3.1.3 refers to these values as the upper MTC limit and lower MTC limit, respectively.

This change is acceptable because the requirements have not changed. The BOL MTC value is the most positive, upper limit and the EOL MTC value is the most negative, lower limit. The terminology used in the ITS is an editorial preference selected for consistency with that used in NUREG-1431. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

A.3 The Applicability of CTS 3.1.1.4 is modified by footnote # stating "See Special Test Exception 3.10.4." ITS 3.1.3 Applicability does not contain the footnote or a reference to the Special Test Exception.

The purpose of the footnote reference is to alert the reader that a Special Test Exception exists that may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

A.4 CTS 3.1.1.4 Action a.1 states that if the MTC is more positive than the BOL (i.e.,

upper) limit, control rod withdrawal limits must be imposed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the unit must be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.1.3 ACTION A states that with the MTC not within the upper limit, establish administrative control rod withdrawal limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or ACTION B requires the unit to be in MODE 2 with keff < 1.0 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by requiring the plant to be in MODE 2 with keff < 1.0 instead of HOT SHUTDOWN (i.e., MODE 3).

This change is acceptable because the requirements have not changed. In accordance with CTS LCO 3.0.1, Actions are only required to be followed while in the MODE of applicability. The CTS upper MTC limit is applicable in MODE 1 and MODE 2 with keff > 1.0. Therefore, under the CTS, the unit does not have to enter MODE 3 because the applicability of the Action ends when in MODE 2 with keff < 1.0. As a result, there is no difference between the CTS and ITS requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

A.5 CTS 3.1.1.4 Action a.1 states that if the MTC is more positive than the BOL limit, then control rod withdrawal limits must be established. It also states that these CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 6, Rev. 0, Page 70 of 357

Attachment 1, Volume 6, Rev. 0, Page 71 of 357 DISCUSSION OF CHANGES ITS 3.1.3, MODERATOR TEMPERATURE COEFFICIENT (MTC) withdrawal limits shall be in addition to the insertion limits of Specification 3.1.3.5 (Unit 1) and Specification 3.1.3.6 (Unit 2). The ITS does not include this sentence.

This change is acceptable because the requirements have not changed. The CTS reference to Specification 3.1.3.5 (Unit 1) and Specification 3.1.3.6 (Unit 2) is an "information only" statement that neither adds, eliminates, or modifies requirements. The ITS convention is to not include these types of statements.

This change is designated as administrative because it does not result in a technical change to the CTS.

A.6 CTS Figure 3.1-2 provides the maximum upper limit for MTC from 0% to 100% RATED THERMAL POWER (RTP). The Figure indicates that the value for MTC can vary from -3.00 to 1.00 x 104 k/k/°F. ITS Figure 3.1.3-1 includes the same curve however the range has changed to -2.00 to 1.00 (x 10-4 k/k/°F).

This changes the CTS by using the correct exponential (104 in the CTS to 10-4 in the ITS) and changing the range for MTC.

This change is acceptable because the requirements have not changed. The maximum upper limit for MTC when < 70% RTP is 0.50 10-4 k/k/°F and the maximum upper limit at 100% RTP is zero. This change is consistent with how similar values are presented in the ITS. Since this curve only provides the maximum upper limit there is no need to provide a wide range from

-3.00 x 10-4 k/k/°F to 1.00 x 10-4 k/k/°F. The lower value of -2.00 x 10-4 k/k/°F is sufficient. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 5 - Deletion of Surveillance Requirement) CTS 3.1.1.4 Action a.2 states that if the measured MTC is more positive than the BOL (i.e., upper) limit, then the control rod withdrawal limits established in Action a.1 must be maintained until subsequent measurement verifies that the MTC has been restored to within its limits for the all rods withdrawn condition. ITS 3.1.3 does CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 6, Rev. 0, Page 71 of 357

Attachment 1, Volume 6, Rev. 0, Page 72 of 357 DISCUSSION OF CHANGES ITS 3.1.3, MODERATOR TEMPERATURE COEFFICIENT (MTC) not contain a requirement that the control rod withdrawal limits be maintained until MTC is confirmed to be within its limit by measurement. However, ITS LCO 3.0.2 states that the Required Actions shall be followed until the LCO is met or no longer applicable. The ITS Bases state that physics calculations may be used to determine the time in cycle life at which the calculated MTC will meet the LCO requirement, and at this point in core life the condition may be exited and the control rod withdrawal limits removed. This changes the CTS by eliminating the Surveillance Requirement verifying the MTC to be within its limit before removing the control rod withdrawal limits.

The purpose of CTS 3.1.1.4 Action a.2 is to ensure that the additional operational restrictions required to maintain the MTC within the assumptions in the safety analyses are maintained until the MTC value without the restrictions is within the LCO limits. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the values used to meet the LCO are consistent with the safety analyses. Thus, appropriate values continue to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. The measurement of the MTC, boron endpoint, and control rod worth prior to entering MODE 1 is sufficient to verify the nuclear design so that it can be accurately predicted when the all rods out, full power equilibrium MTC is within the LCO limit. Performing another measurement of beginning of cycle MTC to confirm this prediction is not necessary to give confidence that MTC is within its limit. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.2 (Category 8 - Deletion of Reporting Requirements) CTS 3.1.1.4 Action a.3 requires that a Special Report be prepared and submitted to the NRC within 10 days if the measured MTC is more positive than the BOL limit. The Special Report must describe the value of the measured MTC, the interim control rod withdrawal limits, and the predicted average core burnup necessary for restoring the positive MTC to within its limit for the all rods withdrawn condition. ITS 3.1.3 does not include this requirement.

The purpose of CTS 3.1.1.4 Action a.3 is to provide information describing the event to the NRC. This change is acceptable because the regulations provide adequate reporting requirements, or the reports do not affect continued plant operation. A Licensee Event Report is required to be submitted by 10 CFR 50.73(a)(2)(i)(B) for any operation or condition outside of the plants Technical Specifications. Therefore, a report to the NRC is still required. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

L.3 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.1.1.4.b) requires MTC to be determined to be within limits. MTC shall be measured at any THERMAL POWER within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm. The measured value shall be compared to the 300 ppm Surveillance limit specified in the COLR. In the event this comparison indicates that the MTC will be more negative than the EOL (i.e.,

lower) limit, the MTC shall be remeasured at least once per 14 EFPD during the remainder of the fuel cycle and the MTC value compared to the EOL limit. ITS CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 6, Rev. 0, Page 72 of 357

Attachment 1, Volume 6, Rev. 0, Page 73 of 357 DISCUSSION OF CHANGES ITS 3.1.3, MODERATOR TEMPERATURE COEFFICIENT (MTC)

SR 3.1.3.2 requires the verification that MTC is within the lower limit. The first proposed Frequency is once each cycle within 7 effective full power days (EFPD) after reaching an equivalent of an equilibrium RTP all rods out (ARO) boron concentration of 300 ppm. The second Frequency is 14 EFPD thereafter if MTC is more negative than the 300 ppm Surveillance limit (not LCO limit) specified in the COLR until the MTC measured at the equivalent of equilibrium RTP-ARO boron concentration of < 60 ppm is less negative than the 60 ppm Surveillance limit specified in the COLR. This changes the CTS by eliminating the requirement to verify that MTC is met at least once per 14 EFPD if the measured MTC at the equivalent of equilibrium RTP-ARO boron concentration of < 60 ppm is less negative than the 60 ppm Surveillance limit specified in the COLR.

The purpose of CTS 4.1.1.4.b) is to periodically verify that the MTC EOL (i.e.,

lower) limit is within limit if the 300 ppm Surveillance limit in the COLR is not met.

This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of assurance that the MTC lower limit will not be exceeded. This will help ensure that the MTC EOL (lower) limit is not exceeded for the remainder of the cycle. The new 60 ppm Surveillance limit for RTP-ARO boron concentration of < 60 ppm will be incorporated into the COLR. This new limit is conservative. If the measured MTC at 60 ppm is more positive than the 60 ppm Surveillance limit, then the MTC lower limit will not be exceeded because of the gradual manner in which MTC changes with core burnup. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 6, Rev. 0, Page 73 of 357

Attachment 1, Volume 6, Rev. 0, Page 74 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 74 of 357

, Volume 6, Rev. 0, Page 75 of 357 , Volume 6, Rev. 0, Page 75 of 357

, Volume 6, Rev. 0, Page 76 of 357 , Volume 6, Rev. 0, Page 76 of 357

Attachment 1, Volume 6, Rev. 0, Page 77 of 357 3.1.3 2 INSERT 1 Once each cycle within 7 effective full power days (EFPD) after reaching an equivalent of an equilibrium RTP all rods out (ARO) boron concentration of 300 ppm AND 14 EFPD thereafter if MTC is more negative than the 300 ppm Surveillance limit (not LCO limit) specified in the COLR until the MTC measured at the equivalent of equilibrium RTP-ARO boron concentration of < 60 ppm is less negative than the 60 ppm Surveillance limit specified in the COLR Insert Page 3.1.3-2 Attachment 1, Volume 6, Rev. 0, Page 77 of 357

, Volume 6, Rev. 0, Page 78 of 357 , Volume 6, Rev. 0, Page 78 of 357

Attachment 1, Volume 6, Rev. 0, Page 79 of 357 3.1.3 3 INSERT 2 1.00 Unacceptable Region (70, 0.50) 0.50 (0, 0.50)

Moderator Temperature Coefficient (x 10-4 k/k/°F) 0.00 Acceptable (100, 0.00)

Region

-0.50

-1.00

-1.50

-2.00 0 10 20 30 40 50 60 70 80 90 100 RTP (%)

Insert Page 3.1.3-3 Attachment 1, Volume 6, Rev. 0, Page 79 of 357

Attachment 1, Volume 6, Rev. 0, Page 80 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.3, MODERATOR TEMPERATURE COEFFICIENT (MTC)

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

2. The ISTS SR 3.1.3.2 Surveillance Notes and Frequency have been rewritten to be consistent with the usage rules in ITS Section 1.4, Frequency. In addition, the modified Frequency and Notes are consistent with the CTS.

3. The appropriate MTC vs. THERMAL POWER CURVE has been included consistent with the current licensing basis.

4. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 80 of 357

Attachment 1, Volume 6, Rev. 0, Page 81 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 81 of 357

, Volume 6, Rev. 0, Page 82 of 357 , Volume 6, Rev. 0, Page 82 of 357

, Volume 6, Rev. 0, Page 83 of 357 , Volume 6, Rev. 0, Page 83 of 357

Attachment 1, Volume 6, Rev. 0, Page 84 of 357 1 INSERT 1 but also to a significant extent from the effects of buildup of plutonium and fission products Insert Page B 3.1.3-2 Attachment 1, Volume 6, Rev. 0, Page 84 of 357

, Volume 6, Rev. 0, Page 85 of 357 , Volume 6, Rev. 0, Page 85 of 357

, Volume 6, Rev. 0, Page 86 of 357 , Volume 6, Rev. 0, Page 86 of 357

, Volume 6, Rev. 0, Page 87 of 357 , Volume 6, Rev. 0, Page 87 of 357

Attachment 1, Volume 6, Rev. 0, Page 88 of 357 4 INSERT 2 Performing the Surveillance once each cycle within 7 effective full power days (EFPD) after reaching an equivalent of an equilibrium RTP all rods out (ARO) boron concentration of 300 ppm is soon enough after the performance of SR 3.1.3.1 to ensure the lower limit will not be exceeded since the MTC changes after initial performance are gradual with core depletion and boron concentration reduction.

The Frequency of 14 EFPD thereafter, if MTC is more negative than 300 ppm Surveillance limit (not LCO limit) specified in the COLR or until the MTC measured at the equivalent of equilibrium RTP-ARO boron concentration of < 60 ppm is less negative than the 60 ppm Surveillance limit specified in the COLR, is adequate for monitoring the change in MTC with core burnup since changes to MTC are relatively slow. The Surveillance limit for MTC at a RTP-ARO boron concentration of 60 ppm is conservative.

If the measured MTC at 60 ppm is more positive than the 60 ppm Surveillance limit, the lower limit will not be exceeded because of the gradual manner in which MTC changes with core burnup.

Insert Page B 3.1.3-5 Attachment 1, Volume 6, Rev. 0, Page 88 of 357

, Volume 6, Rev. 0, Page 89 of 357 , Volume 6, Rev. 0, Page 89 of 357

Attachment 1, Volume 6, Rev. 0, Page 90 of 357 1

INSERT 3 UFSAR, Section 3.3.1 (Unit 1), 3.3.1.2 (Unit 2).

1 INSERT 4

2. UFSAR, Section 1.4.

Insert Page B 3.1.3-6 Attachment 1, Volume 6, Rev. 0, Page 90 of 357

Attachment 1, Volume 6, Rev. 0, Page 91 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.3 BASES, MODERATOR TEMPERATURE COEFFICIENT (MTC)

1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS Bases variously refer to the "upper MTC limit," the "BOC MTC limit," the "lower MTC limit," and the "EOC MTC limit." References to the BOC and EOC MTC limit are eliminated and "upper" and "lower" are substituted to eliminate confusion and to be consistent with the Specification.

3. Typographical/grammatical error corrected.

4. Changes are made to be consistent with changes made to the Specification.

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

6. The Applicable Safety Analyses discussion states that MTC satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). It also says that even though MTC is not directly observed and controlled from the control room, MTC is considered an initial condition process variable because of its dependence on boron concentration. The additional sentence has been deleted. The NRC Final Policy Statement on Technical Improvements of July 22, 1993 (58 FR 39132) states that process variables captured by Criterion 2 are not limited to only those directly monitored and controlled from the control room. It also states that Criterion 2 includes other features or characteristics that are specifically assumed in Design Basis Accident and Transient analyses even if they cannot be directly observed in the control room (e.g., moderator temperature coefficient and hot channel factors). Since the Final Policy Statement provides guidance on which types of parameters satisfy Criterion 2, there is no reason to duplicate these words in the CNP ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 91 of 357

Attachment 1, Volume 6, Rev. 0, Page 92 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 92 of 357

Attachment 1, Volume 6, Rev. 0, Page 93 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.3, MODERATOR TEMPERATURE COEFFICIENT (MTC)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 93 of 357

, Volume 6, Rev. 0, Page 94 of 357 ATTACHMENT 4 ITS 3.1.4, Rod Group Alignment Limits , Volume 6, Rev. 0, Page 94 of 357

, Volume 6, Rev. 0, Page 95 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 95 of 357

Attachment 1, Volume 6, Rev. 0, Page 96 of 357 ITS 3.1.4 A.1 ITS LCO 3.1.4 A.2 A.3 ACTION A LA.1 Add proposed Required Action A.1.2 L.1 ACTION D L.2 Add proposed Required Actions D.1.1 and D.1.2 M.1 ACTION B L.2 A.4 L.2 Add proposed Required Action B.1.2 L.1 L.3 A.3 Page 1 of 14 Attachment 1, Volume 6, Rev. 0, Page 96 of 357

Attachment 1, Volume 6, Rev. 0, Page 97 of 357 ITS 3.1.4 A.1 ITS ACTION B two L.4 L.5 A.5 Add proposed ACTION C M.2 SR 3.1.4.1 L.6 SR 3.1.4.2 A.6 Page 2 of 14 Attachment 1, Volume 6, Rev. 0, Page 97 of 357

Attachment 1, Volume 6, Rev. 0, Page 98 of 357 ITS 3.1.4 A.1 ITS L.3 Page 3 of 14 Attachment 1, Volume 6, Rev. 0, Page 98 of 357

Attachment 1, Volume 6, Rev. 0, Page 99 of 357 ITS 3.1.4 A.1 ITS Figure 3.1.4-1 A.2 LCO 3.1.4 Note A.6 Page 4 of 14 Attachment 1, Volume 6, Rev. 0, Page 99 of 357

Attachment 1, Volume 6, Rev. 0, Page 100 of 357 ITS 3.1.4 A.1 ITS SR 3.1.4.3 500 L.11 A.7 Add proposed ACTION A M.3 SR 3.1.4.3 criticality L.7 L.8 L.9 Page 5 of 14 Attachment 1, Volume 6, Rev. 0, Page 100 of 357

Attachment 1, Volume 6, Rev. 0, Page 101 of 357 ITS 3.1.4 A.1 ITS See ITS 3.1.1 Required Action A.1.1 L.10 See ITS Chapter 1.0 See ITS 3.1.6 See ITS 3.1.1 See ITS 3.1.1 Page 6 of 14 Attachment 1, Volume 6, Rev. 0, Page 101 of 357

Attachment 1, Volume 6, Rev. 0, Page 102 of 357 ITS 3.1.4 A.1 ITS See ITS 3.1.1 L.10 See ITS Chapter 1.0 See ITS 3.1.1 Page 7 of 14 Attachment 1, Volume 6, Rev. 0, Page 102 of 357

Attachment 1, Volume 6, Rev. 0, Page 103 of 357 ITS 3.1.4 A.1 ITS LCO 3.1.4 A.2 A.3 ACTION A LA.1 Add proposed Required Action A.1.2 L.1 ACTION D L.2 Add proposed Required Actions D.1.1 and D.1.2 ACTION B M.1 L.2 A.4 L.2 Add proposed Required Action B.1.2 L.1 L.3 A.3 Page 8 of 14 Attachment 1, Volume 6, Rev. 0, Page 103 of 357

Attachment 1, Volume 6, Rev. 0, Page 104 of 357 ITS 3.1.4 A.1 ITS ACTION B two L.4 L.5 A.5 Add proposed ACTION C M.2 SR 3.1.4.1 L.6 SR 3.1.4.2 A.6 Page 9 of 14 Attachment 1, Volume 6, Rev. 0, Page 104 of 357

Attachment 1, Volume 6, Rev. 0, Page 105 of 357 ITS 3.1.4 A.1 ITS L.3 Page 10 of 14 Attachment 1, Volume 6, Rev. 0, Page 105 of 357

Attachment 1, Volume 6, Rev. 0, Page 106 of 357 ITS 3.1.4 A.1 ITS Figure 3.1.4-1 A.2 LCO 3.1.4 Note A.6 Page 11 of 14 Attachment 1, Volume 6, Rev. 0, Page 106 of 357

Attachment 1, Volume 6, Rev. 0, Page 107 of 357 ITS 3.1.4 A.1 ITS SR 3.1.4.3 500 L.11 A.7 Add proposed ACTION A M.3 SR 3.1.4.3 criticality L.7 L.8 L.9 Page 12 of 14 Attachment 1, Volume 6, Rev. 0, Page 107 of 357

Attachment 1, Volume 6, Rev. 0, Page 108 of 357 ITS 3.1.4 A.1 ITS See ITS 3.1.1 Required Action A.1.1 L.10 See ITS Chapter 1.0 See ITS 3.1.6 See ITS 3.1.1 See ITS 3.1.1 Page 13 of 14 Attachment 1, Volume 6, Rev. 0, Page 108 of 357

Attachment 1, Volume 6, Rev. 0, Page 109 of 357 ITS 3.1.4 A.1 ITS See ITS 3.1.1 L.10 See ITS Chapter 1.0 See ITS 3.1.1 Page 14 of 14 Attachment 1, Volume 6, Rev. 0, Page 109 of 357

Attachment 1, Volume 6, Rev. 0, Page 110 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS 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 3.1.3.1 specifies the rod misalignment limits for full length (shutdown and control) rods at a THERMAL POWER > 85% RATED THERMAL POWER (RTP) and at THERMAL POWER < 85% RTP. At a THERMAL POWER > 85% RTP the allowed rod misalignment is +/- 12 steps or as determined from Figure 3.1-4.

In addition, CTS 3.1.3.1 states that Figure 3.1-4 permits an allowed rod misalignment from +/- 13 steps (for ALLOWABLE POWER LEVEL (APL) equal to 101%) to +/- 18 steps (for APL greater or equal to 106%) provided the value of R (defined in Figure 3.1-4) is > 1.04. The R limit and definition are maintained in the ITS 3.1.4 Note and the range of rod misalignment allowed is maintained in ITS Figure 3.1.4-1. ITS LCO 3.1.4 states that with THERMAL POWER

> 85% RTP, the individual rod positions shall be within 12 steps of their group step counter demand position or as determined from Figure 3.1.4-1, and the Note to ITS LCO 3.1.4 states the R limit and provides the definition. ITS LCO 3.1.4 does not contain the allowed misalignment range and ITS Figure 3.1.4-1 does not include the R limit or definition.

The purpose of the details of CTS 3.1.3.1 is to clarify the details provided in the CTS Figure. However, the information provided in the two locations is duplicative. This change is acceptable because the technical requirements have not changed. The R limit and definition are maintained in the ITS 3.1.4 Note and the range of rod misalignment allowed is maintained in ITS Figure 3.1.4-1. Since the details are duplicative there is no reason to maintain the information in both locations. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 The Applicability of CTS 3.1.3.1 is modified by footnote

that states "See Special Test Exceptions 3.10.2 and 3.10.4" (Unit 1) and "See Special Test Exceptions 3.10.2 and 3.10.3" (Unit 2). ITS 3.1.4 Applicability does not contain the footnote or a reference to the Special Test Exceptions.

The purpose of the footnote reference is to alert the user that a Special Test Exception exists that may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.1.3.1 Action c.1 states that with one full length rod misaligned from the group step counter demand position by more than the rod misalignment requirements, POWER OPERATION may continue provided that within one hour, the affected rod is restored to OPERABLE status within the above alignment CNP Units 1 and 2 Page 1 of 11 Attachment 1, Volume 6, Rev. 0, Page 110 of 357

Attachment 1, Volume 6, Rev. 0, Page 111 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS requirements, the THERMAL POWER level is reduced to less than or equal to 85% RTP for rod misalignments less than or equal to + 18 steps, or other compensatory measures described in the Action are taken. ITS 3.1.4 does not contain a Required Action stating that the rod must be restored to OPERABLE status within the alignment limits.

This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such restore options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 3.1.3.1 Action c.2.e) states that with one full length rod misaligned from the group step counter demand position by more than the rod misalignment requirements, POWER OPERATION may continue provided that the remainder of the rods in the same group as the inoperable rod are aligned to within the allowed rod misalignment of the inoperable rod within one hour while maintaining the rod sequence and insertion limits as specified in the COLR; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.5 (Unit 1) and Specification 3.1.3.6 (Unit 2) during subsequent operation. ITS 3.1.4 does not contain a Required Action stating that the remainder of the rods in the group must be aligned with the misaligned rod.

This change is acceptable because the technical requirements have not changed. Moving the remainder of the rods in a group to within the LCO limit of the misaligned rod while maintaining compliance with all other rod position requirements is simply restoring compliance with the LCO. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such restore options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS Figure 3.1-4, Allowed Rod Misalignment above 85% RTP, is based upon the current Allowable Power Level (APL) as determined in CTS 3.2.6. In addition, CTS 4.1.3.1.3 requires the allowed rod misalignment for THERMAL POWER > 85% RTP to be determined in conjunction with the measurement of APL as defined in CTS 4.2.6.2. The term APL has been changed to FWQ(Z), as described in the DOCs for ITS 3.2.1. Therefore, in the ITS, the allowed rod misalignment is being based upon FWQ(Z). In order to maintain a similar value in the ITS Figure as is in the CTS Figure, the term in ITS Figure 3.1.4-1 is (CFQ x K(Z))/FWQ(Z). In addition, the ITS does not include a specific SR in ITS 3.1.4 to calculate the new allowed rod misalignment every time an FWQ(Z) determination is made. This changes the CTS by using the term FWQ(Z) in lieu of the term APL, and not including a specific SR to calculate the allowed rod misalignment every time FWQ(Z) is determined.

This change is acceptable since, as described in the DOCs for ITS 3.2.1, the term FWQ(Z) is analogous to APL. Also, the specific SR is not needed because each time the FWQ(Z) Surveillance is performed in ITS 3.2.1, the allowed rod alignment limit (if using ITS Figure 3.1.4-1) must be established based on the CNP Units 1 and 2 Page 2 of 11 Attachment 1, Volume 6, Rev. 0, Page 111 of 357

Attachment 1, Volume 6, Rev. 0, Page 112 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS most recently calculated actual value of FWQ(Z). Thus, the technical requirements have not changed; the verification that the individual rod positions are within alignment limits must always be performed and compared to the existing limit.

This change is designated as administrative because it does not result in a technical change to the CTS.

A.7 The CTS 3.1.3.3 (Unit 1) and CTS 3.1.3.4 (Unit 2) Action requires that with the drop time of any full length rod determined to exceed the limits of the LCO, to restore the rod drop time to within the above limit prior to proceeding to MODE 1 or 2. The ITS does not have a similar requirement.

CTS 4.0.4 and ITS SR 3.0.4 require verification that Surveillances are met prior to entering the MODE in which they apply. CTS 4.0.4 and ITS SR 3.0.4 also prohibit entering a MODE or condition with the Surveillance not met and while relying on Actions. Therefore, since the Applicability of CTS 3.1.3.3 (Unit 1) and CTS 3.1.3.4 (Unit 2) is MODES 1 and 2, the Action prohibiting entry into MODES 1 and 2 with the rod drop time requirements not met is redundant to CTS 4.0.4 and ITS SR 3.0.4. This change is acceptable because the technical requirements have not changed. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.1.3.1 Action b states that with more than one full length rod inoperable or misaligned from the group step counter demand position by more than the allowed rod misalignment, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.1.4 ACTION D states that with more than one rod not within alignment limit, verify SDM is within limits or initiate boration to restore required SDM to within limit within one hour, and be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by adding new requirements to verify SDM limits or to initiate boration to restore SDM limits.

The purpose of CTS 3.1.3.1 Action b is to place the unit in a condition in which the equipment is not required. More than one control rod becoming misaligned from its group average position is not expected, and has the potential to reduce SDM. Therefore, SDM must be evaluated. One hour allows the operator adequate time to determine SDM. Restoration of the required SDM, if necessary, requires increasing the RCS boron concentration to provide negative reactivity. The required Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for initiating boration is reasonable, based on the time required for potential xenon redistribution, the low probability of an accident occurring, and the steps required to complete the action. This allows the operator sufficient time to align the required valves and start the boric acid pumps. Boration will continue until the required SDM is restored. This change is acceptable because it is consistent with the requirements of the assumptions of the safety analyses to be within the SDM limit. The change has been designated as more restrictive because it adds explicit actions to verify SDM or to restore SDM within limits.

M.2 CTS 3.1.3.1 Action c states that with one full length rod misaligned, POWER OPERATION may continue provided that certain actions are completed within one hour. If those actions are not complete, CTS 3.0.3 would be entered CNP Units 1 and 2 Page 3 of 11 Attachment 1, Volume 6, Rev. 0, Page 112 of 357

Attachment 1, Volume 6, Rev. 0, Page 113 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS requiring entry into Hot Standby (MODE 3) within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , for a total time from condition discovery to entry into MODE 3 of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS 3.1.4 ACTION C states that if any Required Action and associated Completion Time of Condition B (one rod not within alignment limits) is not met, the unit must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The shortest Completion Time in ITS ACTION B is one hour. Therefore, under the ITS, the shortest possible time from discovery of the condition to entry into MODE 3 is 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . This changes the CTS by providing one less hour for entry into MODE 3 following discovery of a misaligned rod if Required Actions are not met.

The purpose of requiring a shutdown when a rod misalignment cannot be corrected is to bring the unit to a subcritical condition prior to the build up of an undesirable reactor core power distribution. This change is acceptable because it provides an adequate period of time to correct the condition or be in a MODE in which the requirement does not apply. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, for reaching MODE 3 from full power in an orderly manner and without challenging unit systems.

M.3 The CTS 3.1.3.3 (Unit 1) and CTS 3.1.3.4 (Unit 2) Action requires that with the drop time of any full length rod determined to exceed the limits of the LCO, to restore the rod drop time to within the limit prior to proceeding to MODE 1 or 2.

However, no specific actions are stated in CTS 3.1.3.3 (Unit 1) and CTS 3.1.3.4 (Unit 2) if the unit is in MODE 1 or 2 when the rod drop time is discovered to not be within limits. Therefore, a CTS 3.0.3 entry would be required. CTS 3.0.3 allows one hour to prepare for a shutdown and requires the unit to be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.1.4 ACTION A applies with one or more rod(s) inoperable.

It requires the verification of SDM to be within limits or to initiate boration to restore SDM to within limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by adding new requirements associated with SDM and changing the requirement to be outside of the MODE of Applicability from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The purpose of requiring a shutdown when a drop time of any full length rod is not met is to bring the unit to a subcritical condition. With one or more slow control rod(s) there is a potential to reduce SDM. Therefore, SDM must be evaluated. One hour allows the operator adequate time to determine SDM.

Restoration of the required SDM, if necessary, requires increasing the RCS boron concentration to provide negative reactivity. The required Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for initiating boration is reasonable, based on the time required for potential xenon redistribution in the reactor core, the low probability of an accident occurring, and the steps required to complete the action. This allows the operator sufficient time to align the required valves and start the boric acid pumps. Boration will continue until the required SDM is restored. In addition, the new time to reach MODE 3 is consistent with the time provided in other Specifications. This change is acceptable because it is consistent with the requirements of the assumptions of the safety analyses to be within the SDM limit. The change has been designated as more restrictive because it adds explicit actions to verify SDM or to restore SDM within limits and reduces the time required to be in MODE 3.

CNP Units 1 and 2 Page 4 of 11 Attachment 1, Volume 6, Rev. 0, Page 113 of 357

Attachment 1, Volume 6, Rev. 0, Page 114 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.1.3.1 Action a applies when one or more full length rods are inoperable "due to being immovable as a result of excessive friction or mechanical interferences or known to be untrippable." ITS 3.1.4 Condition A applies when one or more rod(s) are inoperable. ITS 3.1.4 Condition A does not list the ways in which the rods can be inoperable (i.e., "due to being immovable as a result of excessive friction or mechanical interferences or known to be untrippable"). This changes the CTS by moving the details of the reason the rod is considered inoperable to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the shutdown and control rods to be OPERABLE and provides a Condition for when the rod is inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program described in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.1.3.1 Actions a and c.2 require satisfying the SHUTDOWN MARGIN requirement in accordance with Specification 3.1.1.1. In the same conditions, ITS 3.1.4 requires verification that the SHUTDOWN MARGIN is within limits or initiating boration to restore SDM to within limits. This changes the CTS by providing the option to initiate action to establish compliance with the SDM requirement within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months instead of declaring the Required Action not met and following ITS LCO 3.0.3.

The purpose of CTS 3.1.3.1 Actions a and c.2 is to ensure that adequate SHUTDOWN MARGIN exists. Following misalignment of a rod, boration may be required to reestablish compliance with the SHUTDOWN MARGIN requirements.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and CNP Units 1 and 2 Page 5 of 11 Attachment 1, Volume 6, Rev. 0, Page 114 of 357

Attachment 1, Volume 6, Rev. 0, Page 115 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS the low probability of a DBA occurring during the repair period. Providing a short period of time to reestablish the SHUTDOWN MARGIN requirement instead of entering ITS LCO 3.0.3 is justified because of the existing conservatisms in the SHUTDOWN MARGIN calculations and the fact that the rod is still trippable.

This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.1.3.1 Action a specifies requirements for one or more full length rods inoperable due to being immovable as a result of excessive friction or mechanical interference or known to be untrippable. CTS 3.1.3.1 Action b specifies requirements for more than one full length rod inoperable or misaligned from the group step counter demand position by more than the allowed rod misalignment. CTS 3.1.3.1 Action c specifies requirements for one full length rod inoperable due to causes other than those addressed by Action a, above, or misaligned from its group step counter demand position by more than the allowed rod misalignment. CTS 3.1.3.1 Action c.2 requires the affected rod to also be declared inoperable. ITS 3.1.4 ACTION A specifies requirements for one or more rod(s) inoperable. ITS 3.1.4 ACTION B specifies requirements for one rod not within alignment limits. ITS 3.1.4 ACTION D specifies requirements for more than one rod not within alignment limits. This changes the CTS by considering shutdown and control rods that are trippable but misaligned to be OPERABLE and excludes other types of control rod inoperabilies not addressed in CTS 3/4.1.3.1 (e.g., insertion times). The requirement to declare a misaligned rod inoperable in CTS 3.1.3.1, Action c.2, is deleted. The requirements for control rod drop times are addressed in DOC M.3.

The purpose of ITS 3.1.4 is to ensure that the shutdown and control rods are capable of performing their safety function of inserting into the core when required. A secondary function of the control rods is to maintain alignment so that the reactor core power distribution is consistent with the safety analyses.

This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. In the ITS, rod OPERABILITY is related only to trippability, and a misaligned rod is not considered inoperable if it can be tripped. Misalignment is addressed by the ITS 3.1.4 LCO, but is separate from OPERABILITY. In both cases, trippability and misalignment, the ITS continues to provide appropriate compensatory measures. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 4 - Relaxation of Required Action) CTS 3.1.3.1 Action c.2.a) states that when a rod is misaligned, POWER OPERATION may continue if a reevaluation of each accident analysis of Table 3.1-1 is performed within 5 days.

This re-evaluation shall confirm that the previous analyzed results of these accidents remain valid for the duration of operation under these conditions.

ITS 3.1.4 Required Action B.6 states that when one rod is misaligned, re-evaluate the safety analyses and confirm results remain valid for the duration of operation under these conditions. This changes the CTS by eliminating Table 3.1-1, which lists the specific events to be re-evaluated and the Action to evaluate those specific events.

CNP Units 1 and 2 Page 6 of 11 Attachment 1, Volume 6, Rev. 0, Page 115 of 357

Attachment 1, Volume 6, Rev. 0, Page 116 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS The purpose of CTS 3.1.3.1 Action c.2.a) is to ensure that the accident analyses performed for the reload core continue to be acceptable during operation with a misaligned rod. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. The elimination of a specific set of events to be re-evaluated does not change the requirement to verify continued operation is acceptable and places the responsibility on the licensee to re-evaluate all accident analyses which may be affected by a misaligned rod. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.4 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.1 Action c.2.d) states that with one rod misaligned, reduce the THERMAL POWER level to < 75% of RATED THERMAL POWER within one hour. ITS 3.1.4 Required Action B.2 requires THERMAL POWER to be reduced to < 75% RTP within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by changing the Completion Time from one hour to two hours.

The purpose of CTS 3.1.3.1 Action c.2.d) is to reduce reactor core power to ensure that the increases in linear heat generation rate due to misalignment of a rod does not result in exceeding the design limits. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months gives the operator sufficient time to accomplish an orderly power reduction without challenging the Reactor Trip System. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L.5 (Category 4 - Relaxation of Required Action) CTS 3.1.3.1 Action c.2.d) states that with one rod misaligned, reduce the THERMAL POWER level to < 75% of RATED THERMAL POWER and reduce the high neutron flux trip setpoint to

< 85% of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.1.4 Required Action B.2 requires THERMAL POWER to be reduced to < 75% RTP, but does not require the high neutron flux trip setpoint to be reduced. This changes the CTS by eliminating the Required Action to reduce the high neutron flux trip setpoint.

The purpose of CTS 3.1.3.1 Action c.2.d) is to reduce reactor core power to ensure that the increases in linear heat generation rate due to misalignment of a rod does not result in exceeding the design limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, the capacity and capability of remaining features, a CNP Units 1 and 2 Page 7 of 11 Attachment 1, Volume 6, Rev. 0, Page 116 of 357

Attachment 1, Volume 6, Rev. 0, Page 117 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Lowering the high neutron flux trip setpoint increases the chance for an inadvertent reactor trip due to the changes being made to the Reactor Trip System without providing a commensurate amount of added safety. Administrative methods of maintaining reactor power below that allowed by the Required Action are sufficient to protect the core. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.6 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.1.3.1.1 requires the position of each full length rod to be determined to be within the group demand limit by verifying the individual rod positions at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS SR 3.1.4.1 requires verification that the individual rod positions are within the alignment limits every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by eliminating the requirement to verify the individual rod positions to be within alignment limits every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when the Rod Position Deviation Monitor is inoperable.

The purpose of CTS 4.1.3.1.1 is to periodically verify that the rods are within the alignment limits specified in the LCO. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of rod position verification when the Rod Position Deviation Monitor is inoperable is unnecessary, since an inoperability of the alarm does not increase the probability that the rods are misaligned. The Rod Position Deviation Monitor alarm is for indication only. Its use is not credited in any safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.7 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.1.3.3 (Unit 1) and CTS 4.1.3.4 (Unit 2) require the rod drop time test to be performed prior to entering MODE 2 following each removal of the reactor vessel head. ITS SR 3.1.4.3 requires this test to be performed prior to criticality after each removal of the reactor head. This changes the CTS by allowing the rod drop test to be delayed from before entering MODE 2 to prior to criticality.

The purpose of the CTS and ITS is to confirm rod drop times as soon as practicable after the reactor vessel head is re-installed. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. MODE 2 begins at keff 0.99. Criticality occurs when keff = 1.0. Therefore, this change only slightly extends the period when the test must be completed. The test must still be completed before any significant THERMAL POWER level is achieved.

This change is designated as less restrictive because Surveillances will be completed at a later time after the reactor vessel head is re-installed and the plant is in MODE 2.

CNP Units 1 and 2 Page 8 of 11 Attachment 1, Volume 6, Rev. 0, Page 117 of 357

Attachment 1, Volume 6, Rev. 0, Page 118 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS L.8 (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.3.3.b (Unit 1) and CTS 4.1.3.4.b (Unit 2) require the rod drop time of full length rods to be demonstrated through measurement prior to entering MODE 2 for specifically affected individual rods following any maintenance on or modification to the control rod drive system which could affect the drop time of those specific rods.

The ITS does not include this testing requirement.

The purpose of CTS 4.1.3.3.b (Unit 1) and CTS 3.1.3.4.b (Unit 2) is to verify OPERABILITY of the control rods following maintenance that could alter their operation. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post-maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and required under ITS SR 3.0.1. The OPERABILITY requirements for the rod control system are described in the Bases for ITS 3.1.4. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B, is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.9 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.1.3.3.c (Unit 1) and CTS 4.1.3.4.c (Unit 2) require the rod drop time of full length rods to be demonstrated through measurement prior to entering MODE 2 following each removal of the reactor vessel head and at least once per 18 months. ITS SR 3.1.4.3 requires the test to be performed prior to criticality after each removal of the reactor head. The requirements in the CTS to perform the test following each removal of the reactor vessel head and at least once per 18 months normally coincide with one another. The head is removed once each cycle (approximately once every 18 months) unless there is a need to remove the head prior to the end of the cycle. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to prior to criticality after each removal of the reactor head.

This new Surveillance could occur up to once every 24 months (i.e., a maximum of 30 months or greater accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) depending on when the head is removed.

The purpose of CTS 4.1.3.3.c (Unit 1) and CTS 4.1.3.4.c (Unit 2) is to ensure the rods insert within the rod drop criteria. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these CNP Units 1 and 2 Page 9 of 11 Attachment 1, Volume 6, Rev. 0, Page 118 of 357

Attachment 1, Volume 6, Rev. 0, Page 119 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for the rod drop test SR is acceptable because the rods are tested during the cycle to ensure the rods are positioned within the rod alignment criteria and to ensure rod freedom of movement (trippability). This testing, which exercises the rods, helps to ensure the rods are able to drop into the core during the cycle and detect significant failures of the rods. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed Surveillance Frequency of prior to criticality after each removal of the reactor head even if performed at or greater than the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.10 (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.1.1.1.a and CTS 4.1.1.2.a require verification of SHUTDOWN MARGIN within one hour after detection of inoperable control rod(s) and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter while the rod(s) are inoperable. These requirements are applicable in MODES 1, 2, 3, 4, and 5. ITS 3.1.4 Required Action A.1.1 requires the verification of SDM to be within limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . These verifications are required in MODES 1 and 2 with one or more control rod(s) inoperable. This changes the CTS by not requiring any explicit SDM verifications for inoperable control rod(s) in MODES 3, 4, and 5 other than the normal verifications specified in ITS SR 3.1.1.1 (once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). For MODE 1 and 2 operations, this changes the CTS by not requiring the verification of SDM on a once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months basis for one or more inoperable rod(s).

The purpose of CTS 4.1.1.1.1.a and CTS 4.1.1.2.a are to provide the appropriate compensatory measures to determine SDM when control rod(s) are inoperable during operations in MODES 1, 2, 3, 4, and 5. The purpose of the ITS 3.1.4 ACTIONS are to provide the appropriate compensatory actions for inoperable control rods in MODES 1 and 2. The purpose of ITS SR 3.1.1.1 is to provide the normal Frequency for verification of SDM regardless of the status of the control rod(s). When the plant is operating in MODES 1 and 2, with one or more rod(s) inoperable the unit must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . After reaching MODE 3, ITS 3.1.4 no longer applies therefore it is inappropriate to specify additional actions after the unit is outside the Applicability of the Specification.

Nevertheless, SDM must still be verified in accordance with ITS SR 3.1.1.1 every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This SDM verification must also compensate for the reactivity worth of the control rod that is not fully inserted since it is required by the definition of SDM. Therefore, ITS 3.1.4 ACTIONS provide the appropriate compensatory measures. In MODES 3, 4, and 5, SDM will be monitored in accordance with ITS SR 3.1.1.1 every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This change is acceptable since SDM will still be required to be monitored every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and based on the definition of SDM the reactivity worth of any rod not capable of being fully inserted must be accounted for in the determination of SDM. Thus, SDM continues to be monitored in a CNP Units 1 and 2 Page 10 of 11 Attachment 1, Volume 6, Rev. 0, Page 119 of 357

Attachment 1, Volume 6, Rev. 0, Page 120 of 357 DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.11 (Category 1 - Relaxation of LCO Requirements) CTS 3.1.3.3 (Unit 1) and CTS 3.1.3.4 (Unit 2) contains the specific requirements for rod drop time testing.

The CTS specifies that the rod drop time be verified at an RCS Tavg of 541°F.

ITS SR 3.1.4.3 specifies the rod drop time be verified at a RCS Tavg of 500°F.

This changes the CTS by lowering the required temperature at which rod drop time must be verified.

The purpose of CTS 3.1.3.3 (Unit 1) and CTS 3.1.3.4 (Unit 2) is to ensure the rods insert within the rod drop time criteria. The performance of rod drop time tests ensure that the required negative reactivity insertion (amount and rate) from a reactor trip is within the values assumed in the safety analyses. This change will allow rod drop time testing to begin earlier during a startup following a refueling outage. The proposed change is acceptable because the specified rod drop time remains unchanged and the proposed 500°F test temperature is conservative compared to the CTS requirement of 541°F. Since the moderator becomes denser as the RCS temperature is decreased, a lower RCS temperature results in slower rod drops due to the density change of the water.

However, the limiting rod drop time requirement of the CTS (< 2.4 seconds (Unit 1) and < 2.7 seconds (Unit 2)) is maintained in the ITS and must still be met. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 11 of 11 Attachment 1, Volume 6, Rev. 0, Page 120 of 357

Attachment 1, Volume 6, Rev. 0, Page 121 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 126 of 357 3.1.4 1 INSERT 2 20 19 (1.06, 18) (1.08, 18) 18 Unacceptable Region 17 Steps 16 15 Acceptable Region 14 13 (1.00, 12) 12 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 (CFQ x K(Z))/FWQ(Z)

Figure 3.1.4-1 Allowed Rod Misalignment Above 85% RTP Insert Page 3.1.4-3 Attachment 1, Volume 6, Rev. 0, Page 126 of 357

Attachment 1, Volume 6, Rev. 0, Page 127 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS

1. The LCO has been modified to incorporate a CNP specific allowance. The change allows the alignment criteria to vary as a function of FWQ(Z). This change to the LCO has been made consistent with the allowances in License Amendments 193 (Unit 1) and 179 (Unit 2) dated March 15, 1995 (as modified in the ITS 3.1.4 DOCs).

2. Typographical/grammatical error corrected.

3. Changes are made to be consistent with the format of the ITS. The location of where a parameter's limits reside, whether in the COLR or an actual LCO statement, is not normally specified in the Required Action. The Required Action normally states that the parameter shall be "within limits."

4. ISTS 3.1.4 Required Action B.1 requires restoration of a rod not within alignment limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or performance of a number of other actions, such as verification of SHUTDOWN MARGIN, reduction in reactor power, measurement of hot channel factors, and re-evaluation of the safety analyses. The Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 4.1.6.g, states "A Required Action which requires restoration, such that the Condition is no longer met, is considered superfluous. It is only included if it would be the only Required Action for the Condition or it is needed for presentation clarity." Neither exception applies in this case. In fact, the inclusion of Required Action B.1 requires an additional level of indenting and numbering for the remaining Required Actions in Condition B, which reduces its clarity. Therefore, Required Action B.1 is deleted and the subsequent Required Actions renumbered.

5. SR 3.1.4.2 has been modified to incorporate a CNP specific allowance, consistent with the CNP licensing basis. The amount of insertion to verify rod trippability has been changed from 10 steps to 8 steps.

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

7. 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 6, Rev. 0, Page 127 of 357

Attachment 1, Volume 6, Rev. 0, Page 128 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 128 of 357

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Attachment 1, Volume 6, Rev. 0, Page 133 of 357 B 3.1.4 2 INSERT 2 There are three rod cluster control assembly (RCCA) misalignment accidents which are analyzed which include one or more dropped RCCAs, a dropped RCCA bank, and a statically misaligned RCCA (Ref. 4).

2 INSERT 3 For the dropped RCCA(s) or dropped RCCA bank misalignment accidents a negative reactivity insertion will result. Power may be reestablished either by reactivity feedback or control bank withdrawal. Following plant stabilization, normal rod retrieval or shutdown procedures are followed. For dropped RCCA events in the automatic rod control mode, the Rod Control System detects the drop in power and initiates control bank withdrawal. In all cases, the minimum departure from nucleate boiling ratio (DNBR) remains above the limit.

2 INSERT 4 and the remainder of the bank inserted 2

INSERT 5 within the limits specified in the LCO.

Insert Page B 3.1.4-3 Attachment 1, Volume 6, Rev. 0, Page 133 of 357

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Attachment 1, Volume 6, Rev. 0, Page 137 of 357 B 3.1.4 2 INSERT 8 due to being immovable as a result of excessive friction or mechanical interference or otherwise known to be untrippable 5 INSERT 9 When one or more rods are inoperable Insert Page B 3.1.4-5 Attachment 1, Volume 6, Rev. 0, Page 137 of 357

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Attachment 1, Volume 6, Rev. 0, Page 142 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.4 BASES, ROD GROUP ALIGNMENT LIMITS

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section and description in the UFSAR.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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. The Bases are changed to reflect changes made to the Specification.

5. Changes made to be consistent with the Specification.

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

7. The discussion of the Required Actions when the LCO is not met has been deleted since it is not appropriate in the Applicable Safety Analyses Section. This information is adequately discussed in the Bases for ACTIONS B.2, B.3, B.4, B.5, and B.6. This is also consistent with the format of the ISTS.

8. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 142 of 357

Attachment 1, Volume 6, Rev. 0, Page 143 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 143 of 357

Attachment 1, Volume 6, Rev. 0, Page 144 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 144 of 357

, Volume 6, Rev. 0, Page 145 of 357 ATTACHMENT 5 ITS 3.1.5, Shutdown Bank Insertion Limits , Volume 6, Rev. 0, Page 145 of 357

, Volume 6, Rev. 0, Page 146 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 146 of 357

Attachment 1, Volume 6, Rev. 0, Page 147 of 357 ITS 3.1.5 A.1 ITS LCO 3.1.5 A.2 M.1 one or more shutdown banks ACTION A Applicability Note two L.1 Add proposed Required Actions A.1.1 and A.1.2 Add proposed ACTION B L.1 SR 3.1.5.1 L.2 A.2 M.1 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 147 of 357

Attachment 1, Volume 6, Rev. 0, Page 148 of 357 ITS 3.1.5 A.1 ITS LCO 3.1.5 A.2 M.1 one or more shutdown banks ACTION A Applicability Note two L.1 Add proposed Required Action A.1.1 and A.1.2 Add proposed ACTION B L.1 SR 3.1.5.1 L.2 A.2 M.1 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 148 of 357

Attachment 1, Volume 6, Rev. 0, Page 149 of 357 DISCUSSION OF CHANGES ITS 3.1.5, SHUTDOWN BANK INSERTION LIMITS 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 The Applicability of CTS 3.1.3.4 (Unit 1) and CTS 3.1.3.5 (Unit 2) is modified by footnote

that states "See Special Test Exceptions 3.10.2 and 3.10.4" (Unit 1) and "See Special Test Exceptions 3.10.2 and 3.10.3" (Unit 2). ITS 3.1.5 Applicability does not contain the footnote or a reference to the Special Test Exceptions.

The purpose of the footnote reference is to alert the user that Special Test Exceptions exist that may modify the Applicability of the Specification. This change is acceptable because it is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.1.3.4 (Unit 1) and CTS 3.1.3.5 (Unit 2) are applicable in MODE 1 and MODE 2 with keff > 1.0. ITS 3.1.5 is applicable in MODES 1 and 2. This changes the CTS by expanding the Applicability from MODE 2 with the reactor critical to all of MODE 2.

The purpose of CTS 3.1.3.4 (Unit 1) and CTS 3.1.3.5 (Unit 2) is to ensure that the shutdown banks are fully withdrawn prior to withdrawing the control banks in order to ensure that there is sufficient shutdown margin available to quickly shutdown the reactor. This change is acceptable because applying that requirement prior to removing the control banks and bringing the reactor critical ensures that the shutdown margin is available and is consistent with plant operation, in that the shutdown banks are completely withdrawn before beginning to withdraw the control banks and approaching criticality. This change is designated as more restrictive because it increases the conditions under which Technical Specification controls will be applied.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 6, Rev. 0, Page 149 of 357

Attachment 1, Volume 6, Rev. 0, Page 150 of 357 DISCUSSION OF CHANGES ITS 3.1.5, SHUTDOWN BANK INSERTION LIMITS LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.1.3.4 Action (Unit 1) and CTS 3.1.3.5 Action (Unit 2) provide compensatory actions for a maximum of one shutdown rod inserted beyond the insertion limit specified in the COLR. The actions require that within one hour, either restore the rod to within the insertion limit specified in the COLR or declare the rod inoperable and apply Specification 3.1.3.1. For more than one shutdown rod beyond the insertion limit the CTS would result in an CTS 3.0.3 entry. ITS 3.1.5 ACTION A provides Required Actions for one or more shutdown banks not within limits. ITS 3.1.5 Required Action A.1.1 requires the verification that SDM is within limits in one hour and ITS 3.1.5 Required Action A.1.2 requires the initiation of boration to restore SDM to within limits in one hour (only one of these Required Actions must be performed). In addition, ITS 3.1.5 Required Action A.2 requires the restoration of shutdown banks to within limits in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . With any Required Action and associated Completion Time (of Condition A) not met the unit must be in MODE 3 in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by allowing more than one shutdown rod to be outside the insertion limits specified in the COLR, provides an additional hour to restore the shutdown bank or control rods to within limits, eliminates the allowance to declare the rod inoperable and take the ACTIONS of Specification 3.1.3.1, and adds the requirement to verify SDM or to initiate boration within one hour. It also eliminates the requirement to enter LCO 3.0.3 if more than one shutdown rod is inserted beyond the insertion limits.

The purpose of CTS 3.1.3.4 Action (Unit 1) and CTS 3.1.3.5 Action (Unit 2) is to ensure that the shutdown banks are fully withdrawn in order to ensure that there is sufficient shutdown margin available to quickly shutdown the reactor. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering that only a small amount of time is provided to reestablish the required features and the low probability of a DBA occurring during the repair period. Allowing an additional hour to restore one or more shutdown banks (or more than one shutdown rod) inserted below the insertion limit is appropriate as it avoids a shutdown, a unit transient, while the rod control system is not in fully working order. The ITS requires verification that the shutdown margin requirement is met or actions to restore the shutdown margin to within its limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , so all safety analysis assumptions are being met. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.3.4.a (Unit 1) and CTS 4.1.3.5.a (Unit 2) require verification that each shutdown rod is within the insertion limit specified in the COLR within 15 minutes prior to withdrawal of any control rods in control rod banks A, B, C, and D during an approach to reactor criticality. ITS 3.1.5 does not require verification that the shutdown rods are above the insertion limits within 15 minutes prior to control bank withdrawal. This changes the CTS by eliminating the requirement that the shutdown banks be verified to be above the insertion limit within 15 minutes prior to withdrawing control banks A, B, C, and D.

CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 6, Rev. 0, Page 150 of 357

Attachment 1, Volume 6, Rev. 0, Page 151 of 357 DISCUSSION OF CHANGES ITS 3.1.5, SHUTDOWN BANK INSERTION LIMITS The purpose of CTS 4.1.3.4.a (Unit 1) and CTS 4.1.3.5.a (Unit 2) is to verify that the shutdown banks are withdrawn above the insertion limit prior to withdrawing the control banks. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. Under the ITS Applicability of MODE 2 and the requirement of ITS LCO 3.0.4, the shutdown banks must be above the insertion limit prior to entering the ITS Applicability of MODE 2.

However, it is not required to verify compliance within a specified time prior to initial control bank withdrawal. Specifying a time is not necessary to ensure that the shutdown banks are above the insertion limit prior to initial control bank withdrawal as long as the shutdown banks are withdrawn before withdrawing the control banks. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 6, Rev. 0, Page 151 of 357

Attachment 1, Volume 6, Rev. 0, Page 152 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 155 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.5, SHUTDOWN BANK INSERTION LIMITS

1. Changes are made to be consistent with the format of the ITS. The location of where a parameter's limits reside, whether in the COLR or an actual LCO statement, is not normally specified in the Required Action. The Required Action normally states that the parameter shall be "within limits."

2. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 155 of 357

Attachment 1, Volume 6, Rev. 0, Page 156 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 163 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.5 BASES, SHUTDOWN BANK INSERTION LIMITS

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section and description in the UFSAR.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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. Typographical/grammatical error corrected.

5. Change made to be consistent with the Specification.

6. 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 6, Rev. 0, Page 163 of 357

Attachment 1, Volume 6, Rev. 0, Page 164 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 164 of 357

Attachment 1, Volume 6, Rev. 0, Page 165 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.5, SHUTDOWN BANK INSERTION LIMITS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 165 of 357

, Volume 6, Rev. 0, Page 166 of 357 ATTACHMENT 6 ITS 3.1.6, Control Bank Insertion Limits , Volume 6, Rev. 0, Page 166 of 357

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Attachment 1, Volume 6, Rev. 0, Page 168 of 357 ITS 3.1.6 A.1 ITS

, sequence, and overlap limits M.1 LCO 3.1.6 A.2 ACTION A Applicability Add proposed Required Actions A.1.1 and A.1.2 M.2 Note ACTION A A.3 Add proposed ACTION B M.1 ACTION C MODE 2 with keff < 1.0 A.4 SR 3.1.6.2 L.1 Add proposed SR 3.1.6.3 M.1 A.2 Applicability Page 1 of 7 Attachment 1, Volume 6, Rev. 0, Page 168 of 357

Attachment 1, Volume 6, Rev. 0, Page 169 of 357 ITS 3.1.6 A.1 ITS Page 2 of 7 Attachment 1, Volume 6, Rev. 0, Page 169 of 357

Attachment 1, Volume 6, Rev. 0, Page 170 of 357 ITS 3.1.6 A.1 ITS See ITS 3.1.1 See ITS 3.1.4 See ITS Chapter 1.0 SR 3.1.6.2 SR 3.1.6.1 See ITS 3.1.1 See ITS 3.1.1 Page 3 of 7 Attachment 1, Volume 6, Rev. 0, Page 170 of 357

Attachment 1, Volume 6, Rev. 0, Page 171 of 357 ITS 3.1.6 A.1 ITS

, sequence, and overlap limits M.1 LCO 3.1.6 A.2 ACTION A Applicability Note Add proposed Required Actions A.1.1 and A.1.2 M.2 ACTION A A.3 Add proposed ACTION B M.1 ACTION C MODE 2 with keff < 1.0 A.4 SR 3.1.6.2 L.1 Add proposed SR 3.1.6.3 M.1 A.2 Applicability Page 4 of 7 Attachment 1, Volume 6, Rev. 0, Page 171 of 357

Attachment 1, Volume 6, Rev. 0, Page 172 of 357 ITS 3.1.6 A.1 ITS Page 5 of 7 Attachment 1, Volume 6, Rev. 0, Page 172 of 357

Attachment 1, Volume 6, Rev. 0, Page 173 of 357 ITS 3.1.6 A.1 ITS Page 6 of 7 Attachment 1, Volume 6, Rev. 0, Page 173 of 357

Attachment 1, Volume 6, Rev. 0, Page 174 of 357 ITS 3.1.6 A.1 ITS See ITS 3.1.1 See ITS 3.1.4 See ITS Chapter 1.0 SR 3.1.6.2 SR 3.1.6.1 See ITS 3.1.1 See ITS 3.1.1 Page 7 of 7 Attachment 1, Volume 6, Rev. 0, Page 174 of 357

Attachment 1, Volume 6, Rev. 0, Page 175 of 357 DISCUSSION OF CHANGES ITS 3.1.6, CONTROL BANK INSERTION LIMITS 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 The Applicability of CTS 3.1.3.5 (Unit 1) and CTS 3.1.3.6 (Unit 2) is modified by footnote

that states "See Special Test Exceptions 3.10.2 and 3.10.4" (Unit 1) and "See Special Test Exceptions 3.10.2 and 3.10.3" (Unit 2). ITS 3.1.6 Applicability does not contain the footnote or a reference to the Special Test Exceptions.

The purpose of the footnote reference is to alert the user that Special Test Exceptions exist that may modify the Applicability of the Specification. This change is acceptable because it is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

A.3 CTS 3.1.3.5 Actions a and b (Unit 1) and CTS 3.1.3.6 Actions a and b (Unit 2) state that with the control banks inserted beyond the insertion limits, restore the control banks to within the insertion limits within two hours or reduce the THERMAL POWER within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the group position using the insertion limits specified in the COLR. ITS 3.1.6 Required Action A.2 requires the control bank to be restored to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by eliminating the explicit statement that compliance with the LCO can be restored in order to exit the Action.

This change is acceptable because the requirements have not changed.

Reducing THERMAL POWER so that the insertion limits, which are a function of power, are lowered and the control bank inserted below the insertion limits comes within the limit is the same as the CTS Action a option to "restore the control banks to within the insertion limit." This change is considered administrative because the technical requirements have not changed.

A.4 CTS 3.1.3.5 Action c (Unit 1) and CTS 3.1.3.6 Action c (Unit 2) require the unit to be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if Actions a or b are not met. The CTS Applicability is MODE 1 and 2 with keff 1.0. ITS 3.1.6 ACTION C requires the unit to be in MODE 2 with keff < 1.0 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by requiring the plant to be in MODE 2 with keff < 1.0 instead of HOT SHUTDOWN (i.e., MODE 3).

This change is acceptable because the requirements have not changed. In accordance with CTS LCO 3.0.1, Actions are only required to be followed while in the Mode of Applicability. The CTS control bank physical insertion limits are applicable in MODES 1 and 2 with keff > 1.0. Therefore, under the CTS, the unit does not have to enter MODE 3 because the Applicability of the CTS LCO has been exited when in MODE 2 with keff < 1.0. As a result, there is no difference CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 6, Rev. 0, Page 175 of 357

Attachment 1, Volume 6, Rev. 0, Page 176 of 357 DISCUSSION OF CHANGES ITS 3.1.6, CONTROL BANK INSERTION LIMITS between the CTS and ITS requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.1.3.5 (Unit 1) and CTS 3.1.3.6 (Unit 2) require the control banks to be limited in physical insertion as specified in the COLR. ITS 3.1.6 requires the control banks to be within the insertion, sequence, and overlap limits specified in the COLR. ITS 3.1.6 ACTION B provides requirements when not meeting the overlap and sequence limits, and ITS SR 3.1.6.3 requires verification of the overlap and sequence every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by adding requirements on the control bank overlap and sequence limits to the Technical Specifications.

This change is acceptable because the control bank sequence and overlap are important assumptions in the core power distribution analyses. The addition of these requirements, ACTIONS, and Surveillance Requirement provides assurance that the core power distribution is maintained within the design predictions. This change is designated as more restrictive because new requirements are added to the CTS.

M.2 The CTS 3.1.3.5 Action (Unit 1) and the CTS 3.1.3.6 Action (Unit 2) require control banks inserted beyond the insertion limits to be restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

ITS 3.1.6 ACTION A contains the same requirement and adds the requirement to verify the SDM is within limits or initiate boration to restore SDM to within limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This changes the CTS by adding the requirement to verify SDM or to initiate boration to restore the required SDM within one hour when control banks are below the insertion limits.

This change is acceptable because it verifies that the initial conditions of the accident analyses are maintained. In MODE 1 and MODE 2 with keff > 1.0, SDM is normally ensured by adhering to the control and shutdown bank insertion limits. If the control banks are not within their insertion limits, then SDM must be verified to be within limits or actions must be initiated to restore SDM to within limits. This change is designated as more restrictive because requirements are added to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 6, Rev. 0, Page 176 of 357

Attachment 1, Volume 6, Rev. 0, Page 177 of 357 DISCUSSION OF CHANGES ITS 3.1.6, CONTROL BANK INSERTION LIMITS LESS RESTRICTIVE CHANGES L.1 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.1.3.5 (Unit 1) and CTS 4.1.3.6 (Unit 2) require the position of each control bank to be determined to be within the insertion limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Insertion Limit Monitor is inoperable, then verify the individual rod positions at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS SR 3.1.6.2 requires verification that each control bank insertion is within the insertion limits specified in the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by eliminating the requirement to verify the control bank insertion to be within limits every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when the Rod Insertion Limit Monitor is inoperable.

The purpose of CTS 4.1.3.5 (Unit 1) and CTS 4.1.3.6 (Unit 2) is to periodically verify that the rods are within the alignment limit specified in the LCO. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of rod position verification when the Rod Insertion Limit Monitor is inoperable is unnecessary because inoperability of the alarm does not increase the probability that the control banks are inserted below the limits. The Rod Insertion Limit Monitor alarm is for indication only; its use is not credited in any of the safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 6, Rev. 0, Page 177 of 357

Attachment 1, Volume 6, Rev. 0, Page 178 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 181 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.6, CONTROL BANK INSERTION LIMITS

1. Changes are made to be consistent with changes made to the Specifications

2. SR 3.1.6.1 is clarified to state that the estimated critical control bank position must be verified to be within the "insertion limits," instead of just "limits, specified in the COLR. Many limits are specified in the COLR and the clarification is needed to avoid confusion. This is also consistent with the ISTS Bases, which clarifies that the limits to be met are the insertion limits.

3. Typographical/grammatical error corrected.

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Attachment 1, Volume 6, Rev. 0, Page 182 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 192 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.6 BASES, CONTROL BANK INSERTION LIMITS

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section and description in the UFSAR.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. Since the ITS states the actual control bank insertion limits are specified in the COLR, the example is not needed in the Bases and has been deleted.

4. LCO 3.1.6 governs control bank insertion, sequence, and overlap limits. The Background section of the ITS 3.1.6 Bases discusses insertion and overlap, but does not discuss sequence. A discussion of control bank sequence is added for completeness.

5. 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.

6. The Bases are changed to be consistent with the ITS.

7. 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 6, Rev. 0, Page 192 of 357

Attachment 1, Volume 6, Rev. 0, Page 193 of 357 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 6, Rev. 0, Page 194 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.6, CONTROL BANK INSERTION LIMITS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 194 of 357

, Volume 6, Rev. 0, Page 195 of 357 ATTACHMENT 7 ITS 3.1.7, Rod Position Indication , Volume 6, Rev. 0, Page 195 of 357

, Volume 6, Rev. 0, Page 196 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 196 of 357

Attachment 1, Volume 6, Rev. 0, Page 197 of 357 ITS 3.1.7 A.1 ITS LCO 3.1.7 LA.1 Add proposed ACTIONS Note L.1 ACTION A 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L.2 or equal to L.3 ACTION C one or more L.4 or equal to L.3 Add proposed ACTION B L.5 Add proposed ACTION D M.1 M.2 Add proposed SR 3.1.7.1 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 197 of 357

Attachment 1, Volume 6, Rev. 0, Page 198 of 357 ITS 3.1.7 A.1 ITS LCO 3.1.7 LA.1 Add proposed ACTIONS Note L.1 ACTION A 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L.2 or equal to L.3 one or more L.4 ACTION C or equal to L.3 Add proposed ACTION B L.5 Add proposed ACTION D M.1 M.2 Add proposed SR 3.1.7.1 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 198 of 357

Attachment 1, Volume 6, Rev. 0, Page 199 of 357 DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION 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.

MORE RESTRICTIVE CHANGES M.1 CTS 3.1.3.2 does not contain an Action to follow if the provided Actions cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.1.7 contains ACTION D, which states that the plant must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shutdown and, consequently, allowing one hour less for the unit to be in MODE 3.

This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODES 1 and 2. Requiring a shutdown to MODE 3 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shutdown is not needed because the operators have had time to prepare for the shutdown while attempting to follow the Required Actions and associated Completion Times. This change is designated as more restrictive because it allows less time to shutdown than does the CTS.

M.2 CTS 4.1.3.2 requires that each rod position indicator channel be determined to be OPERABLE by verifying the demand position indication system and the rod position indicator channels agree within the allowed rod misalignment at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the demand position indication system and the rod position indicator channels at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.1.7 does not contain this requirement because it is duplicative of the requirement in CTS 4.1.3.1.1 (ITS SR 3.1.4.1). A new Surveillance has been added (ITS SR 3.1.7.1) to perform a CHANNEL CALIBRATION of each rod position channel every 24 months. This changes the CTS by adding the ITS requirement of SR 3.1.7.1.

The purpose of ITS SR 3.1.7.1 is to provide additional assurance that the rod position indicator channels are calibrated. This change is acceptable because it provides additional assurance that the rod position indicator channels are OPERABLE. This change is designated as more restrictive, because it adds a new Surveillance Requirement to the CTS.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 6, Rev. 0, Page 199 of 357

Attachment 1, Volume 6, Rev. 0, Page 200 of 357 DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.1.3.2 requires all shutdown and control rod position indicator channels and the demand position indication system to be OPERABLE and capable of determining the control rod positions within the allowed rod misalignment specified in Specification 3.1.3.1. ITS LCO 3.1.7 requires both the Rod Position Indication System and the Demand Position Indication System to be OPERABLE, but the details of what constitutes an OPERABLE system are moved to the Bases. This changes the CTS by removing details of what constitutes an OPERABLE system to the Bases.

The removal of these details, which are related to the system design capabilities, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the Rod Position Indication System and the Demand Position Indication System be OPERABLE. The details on the capability requirements of the systems do not need to appear in the specification in order for the requirement to apply. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 Action a covers the inoperabilities for a maximum of one rod position indicator channel per group.

CTS 3.1.3.2 Action b covers the inoperabilities for a maximum of one demand position indicator per bank. ITS 3.1.7 ACTIONS are modified by a Note that states "Separate Condition entry is allowed for each rod position indicator and each demand position indicator." ITS ACTION A covers inoperabilities for one rod position indication (RPI) per group for one or more groups and ITS ACTION B covers inoperabilities for more than one RPI per group. ITS ACTION C covers the inoperabilities for one or more demand position indicators.

This changes the CTS by allowing separate Condition entry for each inoperable rod position indicator and each inoperable demand position indicator instead of for a maximum of one rod position indicator channel per group and a maximum of one demand position indicator per bank. Other modifications associated with CTS 3.1.3.2 Action b (ITS 3.1.7 ACTION C) are discussed in DOC L.4, while the addition of ITS ACTION B is discussed in DOC L.5.

CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 6, Rev. 0, Page 200 of 357

Attachment 1, Volume 6, Rev. 0, Page 201 of 357 DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION The purpose of CTS 3.1.3.2 Action a is to provide compensatory actions for a maximum of one inoperable rod position indicator channel per group while the purpose of CTS 3.1.3.2 Action b is to provide compensatory actions for a maximum of one inoperable demand position indicator per bank. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change will allow separate Condition entry for each inoperable rod position indicator and each inoperable demand position indicator while the CTS do not. CTS 3.1.3.2 Action a only allows the unit to operate in this Action for only one inoperable rod position indication per group, while CTS 3.1.3.2 Action b only allows the unit to operate in this Action for a maximum of one demand position indicator per bank.

The ITS will allow each inoperable rod position indication or each inoperable demand position indicator inoperability to be tracked separately. This change is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.2 Action a.1 states that with a maximum of one individual rod position indicator channel per group inoperable, determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and "immediately" after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rods position. ITS 3.1.7 Required Action A.1 states to verify the position of the rod with an inoperable position indicator by using the movable incore detectors once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and "once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months " after a rod with an inoperable position indicator has been moved in excess of 24 steps in one direction since the last determination of the rods position. This changes the CTS by allowing 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to verify the rod position instead of requiring the verification immediately.

The purpose of CTS 3.1.3.2 Action a.1 is to verify rod position using the movable incore detector system after the rods have been moved significantly. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time.

Using the movable incore detector system to determine the position of a rod cannot be performed immediately. Four hours is a reasonable time to use the movable incore detector system to measure the core flux around the control rod and analyze the data to determine the control rod position. This short period of time to determine the position will not result in significant perturbation of the core power distribution if the rod is misaligned, and since the probability of a DBA or transient that would be affected by the potentially misaligned rod is very low for CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 6, Rev. 0, Page 201 of 357

Attachment 1, Volume 6, Rev. 0, Page 202 of 357 DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION the short period of time allowed to determine the rod position. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L.3 (Category 4 - Relaxation of Required Action) CTS 3.1.2.1 Action a.2 and Action b.2 require the unit to reduce THERMAL POWER to less than 50% of RATED THERMAL POWER. ITS 3.1.7 Required Actions A.2 and C.2 require the unit to be at a THERMAL POWER of less than or equal to 50% RATED THERMAL POWER under the same conditions. This changes the CTS by allowing a unit to be at 50% RATED THERMAL POWER instead of less than 50% RATED THERMAL POWER.

The purpose of CTS 3.1.2.1 Action a.2 and Action b.2 is to place the unit into a condition where rod position or rod position demand is not significantly affecting core peaking factors. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change is acceptable since with THERMAL POWER at 50% RATED THERMAL POWER, rod position and rod position demand do not significantly affect core peaking factors. The specified THERMAL POWER is consistent with safe operation under the specified Condition. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.4 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 Action b covers the inoperabilities associated with a maximum of one demand position indicator per bank inoperable. ITS 3.1.7 ACTION C covers the inoperabilities for one or more demand position indicators. This changes the CTS by allowing more than one demand position indicator to be inoperable without requiring entry into LCO 3.0.3.

The purpose of CTS 3.1.3.2 Action b is to provide compensatory actions for a maximum of one inoperable demand position indicator per bank. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change will allow more than one demand position indicator to be inoperable without requiring entry into LCO 3.0.3. This is acceptable because the compensatory actions require the position of the control rods to be known by verification that the RPIs for the affected bank are OPERABLE and the most withdrawn rod and the least withdrawn rod of the affected bank are within the required misalignment limits, or THERMAL POWER is reduced to < 50% RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . These CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 6, Rev. 0, Page 202 of 357

Attachment 1, Volume 6, Rev. 0, Page 203 of 357 DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION compensatory actions will assure the rods are in the correct position within a short period of time or THERMAL POWER is reduced so that core peaking is minimized. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.5 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 does not have an action for when more than one rod position indicator channel is inoperable per group. CTS 3.0.3 would be entered in this condition. CTS 3.0.3 requires a shutdown to HOT STANDBY within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.1.7 ACTION B applies when more than one RPI per group is inoperable and requires the rods to be placed under manual control immediately, monitoring and recording of RCS Tavg once per hour, and restoration of all but one RPI to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This changes the CTS by allowing operation for an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with more than one RPI per group inoperable.

The purpose of ITS 3.1.7, ACTION B is to provide time to repair inoperable RPIs before requiring a plant shutdown. This change is acceptable because the ITS Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant indications. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. Providing time to repair multiple inoperable RPIs before requiring a shutdown is reasonable as the safest course of action with inoperable RPIs is to not move the control rods. The compensatory measures ensure that the rods are not moved unintentionally and monitor rod position using other indications. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

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Attachment 1, Volume 6, Rev. 0, Page 209 of 357 3.1.7 7 INSERT 2 SR 3.1.7.1 -----------------------------------------------------------

-NOTE-The sensor may be excluded.

Perform a CHANNEL CALIBRATION of 24 months each RPI.

Insert Page 3.1.7-3 Attachment 1, Volume 6, Rev. 0, Page 209 of 357

Attachment 1, Volume 6, Rev. 0, Page 210 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.7, ROD POSITION INDICATION

1. CNP utilizes an analog rod position indication system. Therefore, reference to a digital rod position indication system have been removed.

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

3. ISTS 3.1.7 ACTION C has two Required Actions that are connected with an OR.

However, the stated Completion Times for these two Required Actions are different (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , respectively). Due to the convention in the ISTS as described in Section 1.3, the two Completion Times associated with the two Required Actions OR logical connector must be the same, since either Required Action can be chosen.

Therefore, to be consistent with the format of the ISTS, ISTS 3.1.7 ACTION C has been deleted and a new, conditional Completion Time has been added to Required Action A.1. This ensures that the intent of the ISTS is maintained, in that a verification of the position of the rod with an inoperable position indicator is still being performed once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a rod with an inoperable position indicator has been moved in excess of 24 steps in one direction since the last determination of the rod's position. In addition, since the unit is in both Conditions A and B when more than one rod position indicators per group are inoperable, and Required Action A.1 requires the identical position check required by Required Action B.3, there is no reason to include the position check as Required Action B.3. This is also consistent with the format of the ISTS. Appropriate renumbering changes have also been made due to these deletions.

4. The words in ISTS Required Action A.1, ISTS Required Action D.1.1 (ITS Required Action C.1.1), and ISTS Required Action D.1.2 (ITS Required Action C.1.2) have been modified to be singular, versus plural, when referring to a rod or a bank. This has been done since the ACTIONS Note allows separate Condition entry for each rod position indicator and each demand position indicator; thus the Required Action only applies to the individual rod or bank whose indicator in inoperable. In addition, ISTS 3.1.7 Condition D (ITS 3.1.7 Condition C) has been modified consistent with proposed TSTF-437, Rev. 0.

5. Typographical/grammatical error corrected.

6. The ISTS Required Action D.1.2 alignment criteria has been revised to be consistent with the current licensing basis requirements. The CTS allows the alignment criteria to vary as a function of Allowable Power Level (changed to vary as a function of FWQ(Z) as described in the ITS 3.1.4 DOCs) at THERMAL POWER levels 85% as indicated in CTS Figure 3.1.4-1. This change to the Required Action has been made consistent with the allowances in License Amendments 193 (Unit 1) and 179 (Unit 2) based on a Letter from the NRC dated March 15, 1995 (as modified in the ITS 3.1.4 DOCs). The alignment criteria is specified in ITS 3.1.4.

7. The ISTS requirement to verify each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel prior to criticality after each removal of the reactor vessel head is replaced with the requirement to perform a CHANNEL CALIBRATION of each RPI, except for the sensor. Because of the thermal drift characteristics of the CNP RPIs, performing a full range comparison of RPI and demand position before criticality is not useful, as the RPI response will change with RPI temperature. The ITS requires a CHANNEL CALIBRATION of each CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 210 of 357

Attachment 1, Volume 6, Rev. 0, Page 211 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.7, ROD POSITION INDICATION RPI, which involves calibrating the electronics to known input voltages. Actual RPI position is adjusted for thermal drift.

8. Change made to be consistent with similar Notes in other places in the ISTS.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 211 of 357

Attachment 1, Volume 6, Rev. 0, Page 212 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 224 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.7 BASES, ROD POSITION INDICATION

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section and description in the UFSAR.

2. The Bases are changed to reflect the Specification.

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

4. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

5. The Bases are changed to reflect changes made to the Specification.

6. Typographical/grammatical error corrected.

7. The description in the Bases of ACTIONS A.1 of the alternate manner to perform Required Action A.1 (by verifying LCO 3.2.1, LCO 3.2.2, and LCO 3.1.1 are met every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) has been deleted. This option will not be used at CNP.

8. The requirement that the RPI indicates within the agreement limit of the group step counter demand position has been deleted since the requirement is already covered by ITS LCO 3.1.4. If the agreement limit is not met, then the ACTIONS of LCO 3.1.4, "Rod Group Alignment Limits," should be entered. As written in these Bases, both the ACTIONS of ITS LCO 3.1.4 and ITS LCO 3.1.7 would have to be entered if not within the agreement limit. The appropriate ACTIONS are those of ITS LCO 3.1.4.

ITS LCO 3.1.7 should only cover the actual RPI System, not the agreement limits.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 224 of 357

Attachment 1, Volume 6, Rev. 0, Page 225 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 225 of 357

Attachment 1, Volume 6, Rev. 0, Page 226 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.7, ROD POSITION INDICATION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 226 of 357

, Volume 6, Rev. 0, Page 227 of 357 ATTACHMENT 8 ITS 3.1.8, PHYSICS TESTS Exceptions - MODE 2 , Volume 6, Rev. 0, Page 227 of 357

, Volume 6, Rev. 0, Page 228 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 6, Rev. 0, Page 228 of 357

Attachment 1, Volume 6, Rev. 0, Page 229 of 357 ITS 3.1.8 A.1 ITS and the number of required channels for LCO 3.3.1 Functions 2, 3, and 6 may be reduced to 3 A.2 Add LCO 3.4.2 L.1 LCO 3.1.8 Add proposed LCO 3.1.8.a A.3 Add proposed LCO 3.1.8.b M.1 During PHYSICS TEST initiated in A.4 ACTION B Add proposed ACTION A M.1 Add proposed ACTIONS C and D L.1 SR 3.1.8.2 30 minutes M.2 L.2 Add proposed SR 3.1.8.1 L.1 Add proposed SR 3.1.8.3 M.1 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 229 of 357

Attachment 1, Volume 6, Rev. 0, Page 230 of 357 ITS 3.1.8 A.1 ITS and the number of required channels for LCO 3.3.1 Functions 2, 3, and 6 may be reduced to 3 A.2 Add LCO 3.4.2 L.1 LCO 3.1.8 Add proposed LCO 3.1.8.a A.3 Add proposed LCO 3.1.8.b M.1 During PHYSICS TEST initiated in A.4 ACTION B Add proposed ACTION A M.1 Add proposed ACTIONS C and D L.1 SR 3.1.8.2 30 minutes M.2 L.2 Add proposed SR 3.1.8.1 L.1 Add proposed SR 3.1.8.3 M.1 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 230 of 357

Attachment 1, Volume 6, Rev. 0, Page 231 of 357 DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 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 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) state that the limitations of certain Specifications may be suspended during the performance of PHYSICS TESTS.

ITS LCO 3.1.8 includes an allowance to reduce the required number of channels for ITS LCO 3.3.1, "RTS Instrumentation," Function 2 (Power Range Neutron Flux), Function 3 (Power Range Neutron Flux Rate), and Function 6 (Overtemperature T), from "4" to "3." This changes CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) by adding an allowance to reduce the number of required RTS channels from "4" to " 3" for the specified Functions.

The purpose of CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) is to allow some flexibility during the performance of PHYSICS TESTS while ensuring appropriate limitations are in place to help ensure safe operation. This change is acceptable because the minimum channels required for OPERABILITY for these RTS Functions in CTS Table 3.3-1 is currently "3." This allowance is needed since the "Required Channels" in ITS 3.3.1, Reactor Trip System Instrumentation, is "4." This change from the CTS is discussed in the Discussion of Changes for ITS 3.3.1. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) state that the limitations of certain Specifications may be suspended during the performance of PHYSICS TESTS provided the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are set at 25% of RATED THERMAL POWER. ITS 3.1.8 states that the requirement of certain Specifications may be suspended but contains no requirements on the Intermediate and Power Range Channels. The ITS contains the same requirements on the Intermediate and Power Range Channels in ITS LCO 3.3.1. This changes the CTS by eliminating the requirement that the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are set at < 25% of RATED THERMAL POWER from the test exception.

This change is acceptable because the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are contained in ITS LCO 3.3.1, "RTS Instrumentation." Repeating that requirement in the test exception LCO is unnecessary. This change is designated administrative as it eliminates a repeated requirement from the CTS, resulting in no technical change to the CTS.

A.4 CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) are applicable in MODE 2.

ITS 3.1.8 is applicable "During PHYSICS TESTS initiated in MODE 2." This CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 6, Rev. 0, Page 231 of 357

Attachment 1, Volume 6, Rev. 0, Page 232 of 357 DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 changes the CTS such that the Specification is applicable in MODE 2 only when a PHYSICS TEST is initiated.

The purpose of the ITS 3.1.8 Applicability is to ensure that the Actions contained in the Specification are followed. The wording of the CTS appears to be contradictory because, if THERMAL POWER exceeds 5% RTP, then the test exception Specification Applicability is exited and the Actions no longer apply.

However, it is clear that the CTS Action should be applied if THERMAL POWER exceeds 5% RTP and PHYSICS TESTS are in progress. The ITS Applicability eliminates this apparent contradiction and allows the test exception Conditions and Required Actions to be applied when the LCO is not met. This is consistent with the wording of the CTS Action. This change is designated as administrative because it clarifies the current wording of the Specification with no change in intent.

MORE RESTRICTIVE CHANGES M.1 CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) state that limitations of certain Specifications may be suspended during the performance of PHYSICS TESTS and provides restrictions that must be followed when utilizing the CTS exception.

ITS 3.1.8 adds a requirement that SHUTDOWN MARGIN must be within the limits provided in ITS LCO 3.1.1 for MODE 2 with keff < 1.0. A Surveillance (SR 3.1.8.3) to verify the SHUTDOWN MARGIN every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and an ACTION (ACTION A) to follow if the SHUTDOWN MARGIN limit is not met are also added. This changes the CTS by imposing an additional requirement on the application of the test exception LCO.

This change is acceptable because it imposes reasonable restrictions on the performance of PHYSICS TESTS when the control rod and RCS minimum temperature Specifications are allowed to be violated. The Bases for ITS 3.1.1, "SHUTDOWN MARGIN," state that in MODE 2 with keff > 1.0, the SHUTDOWN MARGIN is ensured by compliance with the rod insertion limit Specifications.

Under the test exception, those control rod insertion limits are allowed to be violated. Therefore, additional actions must be taken to ensure that sufficient SHUTDOWN MARGIN is available to shutdown the reactor and keep it subcritical if needed when in MODE 2 with keff > 1.0. This change is designated as more restrictive because it imposes additional restrictions not found in the CTS.

M.2 CTS 4.10.4.1 (Unit 1) and CTS 4.10.3.1 (Unit 2) require THERMAL POWER to be verified to be < 5% RTP once per hour. ITS SR 3.1.8.2 requires the same verification be performed every 30 minutes. This changes the CTS by increasing the Frequency of the THERMAL POWER verification.

This change is acceptable because the increased Frequency is consistent with similar verifications performed in the Specification. ITS SR 3.1.8.1, which verifies that the RCS lowest loop average temperature is > 531°F, is also performed every 30 minutes. THERMAL POWER is a parameter readily available in the control room, so imposition of this more stringent requirement will have no effect CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 6, Rev. 0, Page 232 of 357

Attachment 1, Volume 6, Rev. 0, Page 233 of 357 DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 on safety. This change is designated as more restrictive because a Surveillance will be performed more frequently in the ITS than in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) state that limitations of certain Specifications may be suspended during the performance of PHYSICS TESTS. ITS 3.1.8 provides an additional exception to LCO 3.4.2, "RCS Minimum Temperature for Criticality,"

provided the RCS lowest loop average temperature is > 531°F. A Surveillance to verify the RCS lowest loop average temperature is > 531°F every 30 minutes (proposed SR 3.1.8.1) has been added. In addition, ACTION C has been added to cover the situation when RCS lowest loop average temperature is not within limit. The Required Action is to restore RCS lowest loop average temperature to within limit within 15 minutes. If this is not met, then ACTION D requires the unit to be in MODE 3 within 15 minutes. This changes the CTS by allowing the suspension of LCO 3.4.2, "RCS Minimum Temperature for Criticality." However, it places a limitation on the RCS lowest loop average temperature that is allowed.

The purpose of CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) is to allow some flexibility during the performance of PHYSICS TESTS, while ensuring appropriate limitations are in place to help maintain safe operation. This change is acceptable because the LCO requirements continue to ensure that the process variables are maintained consistent with the safety analyses and licensing basis.

This changes the CTS by allowing the suspension of LCO 3.4.2, "RCS Minimum Temperature for Criticality." However, it places a limitation on the RCS lowest loop average temperature that is allowed. CTS 3.1.1.5 (ITS 3.4.2, "RCS Minimum Temperature for Criticality") requires the RCS lowest operating loop temperature to be > 541°F. Therefore, this change reduces the temperature for criticality by 10°F during the performance of PHYSICS TESTS. This is necessary to help facilitate the performance of certain tests, such as the determination of the Isothermal Temperature Coefficient. The lower limit on RCS average temperature is provided in the test exception LCO to ensure that the RCS temperature stays within the analyzed range. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 6, Rev. 0, Page 233 of 357

Attachment 1, Volume 6, Rev. 0, Page 234 of 357 DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.10.4.2 (Unit 1) and CTS 4.10.3.2 (Unit 2) require that CHANNEL FUNCTIONAL TESTS be performed on each Intermediate and Power Range channel within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to initiating PHYSICS TESTS. ITS SR 3.3.1.8 for the Power Range channels and ITS SR 3.3.1.10 for the Intermediate Range channels require the tests to be performed every 92 days and every 184 days, respectively. Since ITS 3.3.1 requires these channels to be OPERABLE in MODE 2 and in MODE 2 above the P-6 Interlock, respectively, this effectively ensures the tests are performed within their required Frequency prior to entering MODE 2 (i.e., prior to performing the PHYSICS TESTS). This changes the CTS by eliminating the time period prior to initiation of PHYSICS TESTS within which the testing must be performed.

The purpose of CTS 3.10.4 (Unit 1) and CTS 3.10.3 (Unit 2) is to allow the performance of PHYSICS TESTS on the reactor. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The performance of the normally scheduled CHANNEL OPERATIONAL TEST is sufficient to ensure the equipment is OPERABLE. LCO 3.3.1 requires a CHANNEL OPERATIONAL TEST on the Power Range channels (SR 3.3.1.8) every 92 days and on the Intermediate Range channels (SR 3.3.1.10) every 184 days. These Frequencies have been determined to be sufficient for verification that the equipment is working properly. The initiation of PHYSICS TESTS does not affect the ability of the equipment to perform its function, does not affect the trip setpoints or the RTS trip capability, and does not invalidate the previous Surveillances.

Therefore, requiring this testing to be performed at a fixed time before the initiation of PHYSICS TESTS has no benefit. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 6, Rev. 0, Page 234 of 357

Attachment 1, Volume 6, Rev. 0, Page 235 of 357 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 6, Rev. 0, Page 235 of 357

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Attachment 1, Volume 6, Rev. 0, Page 237 of 357 3.1.8 3

INSERT 1 for MODE 2 with keff < 1.0 specified in LCO 3.1.1, "SHUTDOWN MARGIN (SDM)"

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Attachment 1, Volume 6, Rev. 0, Page 239 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2

1. 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.

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

3. Changes are made to accurately reflect the requirement that must met, since the COLR lists more than one SDM limit.

4. ISTS SR 3.1.8.1 requires a CHANNEL OPERATIONAL TEST be performed on the Intermediate and Power Range channels "prior to initiation of PHYSICS TESTS."

However, no finite time as to how soon prior to the PHYSICS TESTS is stated. The ITS Applicability for the Intermediate and Power Range channels includes MODE 2 above the P-6 Interlock and MODE 2, respectively, thus the normal, periodic Frequencies for SR 3.3.1.11 and SR 3.3.1.8 must be met prior to entering or soon after entering MODE 2. Therefore, the normal periodic Frequencies already ensure the "prior to initiation of PHYSICS TESTS" is met, and ISTS SR 3.1.8.1 is not necessary and has been deleted. Due to this deletion, the remaining SRs have been renumbered. In addition, ISTS LCO 3.1.8 references LCO 3.3.1 Function 18.e. In ITS Table 3.3.1-1, Function 18.d only has one channel per train, thus an exemption is not necessary in ISTS LCO 3.1.8 for this Function.

5. ISTS LCO 3.1.8.c and ISTS SR 3.1.8.3 have been revised to require THERMAL POWER < 5% RTP. TSTF-14, Rev. 4, approved this change on May 2, 1997, but it was not properly adopted in NUREG-1431, Rev.2.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 239 of 357

Attachment 1, Volume 6, Rev. 0, Page 240 of 357 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 6, Rev. 0, Page 244 of 357 B 3.1.8 1 4 INSERT 1 the Dynamic Rod Worth Measurement Method (Ref. 5), moves the selected control bank over its entire length of travel. The worth of the bank is inferred from the change in the flux level upon insertion of the bank.

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Attachment 1, Volume 6, Rev. 0, Page 246 of 357 B 3.1.8 1

INSERT 1A and WCAP-13360-P-A, Revision 1 (Ref. 5)

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Attachment 1, Volume 6, Rev. 0, Page 248 of 357 B 3.1.8 7

INSERT 2 and the number of required channels for LCO 3.3.1, RTS Instrumentation, Functions 2, 3, and 6 may be reduced to 3 Insert Page B 3.1.8-5 Attachment 1, Volume 6, Rev. 0, Page 248 of 357

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Attachment 1, Volume 6, Rev. 0, Page 250 of 357 B 3.1.8 7

INSERT 3 In addition, the PHYSICS TEST exception must be suspended within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

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Attachment 1, Volume 6, Rev. 0, Page 253 of 357 B 3.1.8 1

INSERT 4 13360-P-A, "Westinghouse Dynamic Rod Worth Measurement Technique," Revision 1, October 1998.

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Attachment 1, Volume 6, Rev. 0, Page 254 of 357 JUSTIFICATION FOR DEVIATIONS ITS 3.1.8 BASES, PHYSICS TESTS EXCEPTIONS - MODE 2

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. 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.

3. The description of PHYSICS TESTS required for reload fuel cycles is revised to be consistent with the current guidelines, ANSI/ANS 19.6.1-1997, and the CNP startup physics testing program.

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

5. The Applicable Safety Analyses description about "other tests" has been deleted since ITS 3.1.8 allows the suspension of the LCOs only for PHYSICS TESTS.

6. The Bases are changed to reflect changes made to the Specifications.

7. The Bases are revised to be consistent with the Specification.

8. Editorial/grammatical error corrected.

9. The LCO and SR 3.1.8.3 Bases Sections have been revised to require THERMAL POWER < 5% RTP. TSTF-14, Rev. 4, approved this change on May 2, 1997, but it was not properly adopted in NUREG-1431, Rev. 2.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 254 of 357

Attachment 1, Volume 6, Rev. 0, Page 255 of 357 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 6, Rev. 0, Page 256 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 256 of 357

Attachment 1, Volume 6, Rev. 0, Page 257 of 357 ATTACHMENT 9 Relocated/Deleted Current Technical Specifications (CTS)

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, Volume 6, Rev. 0, Page 258 of 357 CTS 3/4.1.1.3, Boron Dilution , Volume 6, Rev. 0, Page 258 of 357

Attachment 1, Volume 6, Rev. 0, Page 259 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

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, Volume 6, Rev. 0, Page 260 of 357 CTS 3/4.1.1.3 L.1 Page 1 of 2 , Volume 6, Rev. 0, Page 260 of 357

, Volume 6, Rev. 0, Page 261 of 357 CTS 3/4.1.1.3 L.1 Page 2 of 2 , Volume 6, Rev. 0, Page 261 of 357

Attachment 1, Volume 6, Rev. 0, Page 262 of 357 DISCUSSION OF CHANGES CTS 3/4.1.1.3, BORON DILUTION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS 3.1.1.3 requires the flow rate of reactor coolant through the Reactor Coolant System (RCS) to be greater than or equal to 2000 gpm whenever a reduction in RCS boron concentration is being made. With the flow rate not within limit, immediate suspension of all operations involving a reduction in boron concentration is required. CTS 4.1.1.3 requires the RCS flow rate to be monitored prior to the start of a reduction in the RCS born concentration. The ITS does not include this Specification. This changes the CTS by eliminating this Specification.

The purpose of CTS 3.1.1.3 is to ensure there is enough flow to support adequate mixing, prevent stratification, and prevent and ensure that reactivity changes will be gradual during boron concentration reductions in the RCS. This flow rate will circulate the RCS volume in approximately 30 minutes. Therefore, the reactivity change rate associated with boron reductions will therefore be within the capability for operator recognition and control.

This change is acceptable since the ITS contains several Specifications, each applicable during different MODES of operations, that require a certain number of RCS and/or residual heat removal (RHR) loops to be OPERABLE and in operation regardless of whether or not a reduction in RCS boron concentration is being made. These ITS Specifications also include the appropriate Surveillance to ensure the loops are OPERABLE and in operation. The flow limit is not included in most of the ITS Specifications because the capacity of the RCS pumps is significantly greater than 2000 gpm and because operation of the RHR System is controlled by plant operating procedures to ensure adequate flow. The reactor coolant flow rate of 2000 gpm is retained for MODE 6 operations as indicated in ITS SR 3.9.4.1 and SR 3.9.5.1.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 262 of 357

Attachment 1, Volume 6, Rev. 0, Page 263 of 357 DISCUSSION OF CHANGES CTS 3/4.1.1.3, BORON DILUTION In MODES 1 and 2, if any RCS loop is not OPERABLE and in operation, ITS LCO 3.4.4 ACTION A requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If the unit is operating in MODES 3, 4, and 5 (with the RCS loops filled) and the required loops are not in operation, the associated ITS LCOs provide limitations that prohibit operations that would cause introduction of coolant with boron concentration less than required to meet SDM of ITS LCO 3.1.1. If the required loop is not in operation in MODE 5 (with the RCS loops not filled), ITS LCO 3.4.8 prohibits operations that can cause introduction of coolant with boron concentration less than required to meet ITS LCO 3.1.1 and prohibits draining operations that could further reduce the RCS water volume. If the unit is operating in MODE 6 with high reactor water level and the required loop is not in operation, ITS LCO 3.9.4 prohibits operations that would cause introduction of coolant with boron concentration less than required to meet ITS LCO 3.9.1. If the unit is operating in MODE 6 with low reactor water level and the required loops are not in operation, ITS LCO 3.9.5 prohibits operation that would cause introduction of coolant with boron concentration less than required to meet ITS LCO 3.9.1 and prohibits draining operations which can further reduce the RCS water volume. Since the requirements have been included in various Specifications, the change is appropriate. This change is designated as less restrictive because less stringent LCO requirements (explicit flow rates) are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 263 of 357

Attachment 1, Volume 6, Rev. 0, Page 264 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 264 of 357

Attachment 1, Volume 6, Rev. 0, Page 265 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.1.3, BORON DILUTION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 265 of 357

, Volume 6, Rev. 0, Page 266 of 357 CTS 3/4.1.2.1, Flow Paths - Shutdown , Volume 6, Rev. 0, Page 266 of 357

Attachment 1, Volume 6, Rev. 0, Page 267 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 267 of 357

, Volume 6, Rev. 0, Page 268 of 357 CTS 3/4.1.2.1 R.1 Page 1 of 3 , Volume 6, Rev. 0, Page 268 of 357

, Volume 6, Rev. 0, Page 269 of 357 CTS 3/4.1.2.1 Page 2 of 3 , Volume 6, Rev. 0, Page 269 of 357

, Volume 6, Rev. 0, Page 270 of 357 CTS 3/4.1.2.1 R.1 Page 3 of 3 , Volume 6, Rev. 0, Page 270 of 357

Attachment 1, Volume 6, Rev. 0, Page 271 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.1, FLOW PATHS - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.1 provides requirements on the boration systems flow paths during shutdown. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.1 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Flow Paths - Shutdown Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Flow Paths - Shutdown Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Flow Paths - Shutdown Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-6) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 271 of 357

Attachment 1, Volume 6, Rev. 0, Page 272 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.1, FLOW PATHS - SHUTDOWN significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Flow Paths - Shutdown Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Flow Paths -

Shutdown LCO and Surveillances may be relocated out of the Technical Specifications. The Flow Paths - Shutdown Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59.

This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 272 of 357

Attachment 1, Volume 6, Rev. 0, Page 273 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 273 of 357

Attachment 1, Volume 6, Rev. 0, Page 274 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.1, FLOW PATHS - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 274 of 357

, Volume 6, Rev. 0, Page 275 of 357 CTS 3/4.1.2.2, Flow Paths - Operating , Volume 6, Rev. 0, Page 275 of 357

Attachment 1, Volume 6, Rev. 0, Page 276 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 276 of 357

, Volume 6, Rev. 0, Page 277 of 357 CTS 3/4.1.2.2 R.1 Page 1 of 4 , Volume 6, Rev. 0, Page 277 of 357

, Volume 6, Rev. 0, Page 278 of 357 CTS 3/4.1.2.2 Page 2 of 4 , Volume 6, Rev. 0, Page 278 of 357

, Volume 6, Rev. 0, Page 279 of 357 CTS 3/4.1.2.2 R.1 Page 3 of 4 , Volume 6, Rev. 0, Page 279 of 357

, Volume 6, Rev. 0, Page 280 of 357 CTS 3/4.1.2.2 Page 4 of 4 , Volume 6, Rev. 0, Page 280 of 357

Attachment 1, Volume 6, Rev. 0, Page 281 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.2, FLOW PATHS - OPERATING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.2 provides requirements on the boration systems flow paths during operation. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.2 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Flow Paths - Operating Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Flow Paths - Operating Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Flow Paths - Operating Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-8) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 281 of 357

Attachment 1, Volume 6, Rev. 0, Page 282 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.2, FLOW PATHS - OPERATING significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Flow Paths - Operating Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Flow Paths -

Operating LCO and Surveillances may be relocated out of the Technical Specifications. The Flow Paths - Operating Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59.

This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 282 of 357

Attachment 1, Volume 6, Rev. 0, Page 283 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 283 of 357

Attachment 1, Volume 6, Rev. 0, Page 284 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.2, FLOW PATHS - OPERATING There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 284 of 357

, Volume 6, Rev. 0, Page 285 of 357 CTS 3/4.1.2.3, Charging Pump - Shutdown , Volume 6, Rev. 0, Page 285 of 357

Attachment 1, Volume 6, Rev. 0, Page 286 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 286 of 357

, Volume 6, Rev. 0, Page 287 of 357 CTS 3/4.1.2.3 R.1 See ITS 3.4.12 L.1 R.1 L.1 R.1 See ITS 3.4.12 R.1 L.1 R.1 See ITS 3.4.12 Page 1 of 4 , Volume 6, Rev. 0, Page 287 of 357

, Volume 6, Rev. 0, Page 288 of 357 CTS 3/4.1.2.3 R.1 See ITS 3.4.12 L.1 Page 2 of 4 , Volume 6, Rev. 0, Page 288 of 357

, Volume 6, Rev. 0, Page 289 of 357 CTS 3/4.1.2.3 R.1 L.1 See ITS 3.4.12 R.1 L.1 R.1 See ITS 3.4.12 R.1 L.1 R.1 See ITS 3.4.12 Page 3 of 4 , Volume 6, Rev. 0, Page 289 of 357

, Volume 6, Rev. 0, Page 290 of 357 CTS 3/4.1.2.3 R.1 See ITS 3.4.12 L.1 Page 4 of 4 , Volume 6, Rev. 0, Page 290 of 357

Attachment 1, Volume 6, Rev. 0, Page 291 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.3, CHARGING PUMP - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.3 provides requirements on the charging pumps during shutdown when used as part of the boration system. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual. It should be Noted that this Specification also has requirements concerning the maximum number of charging and safety injection pumps that can be OPERABLE. This Discussion of Change does not address these requirements; they are covered in ITS 3.4.12. It should also be Noted that this Specification has requirements associated with the safe shutdown requirements of 10 CFR 50 Appendix R. These requirements are discussed in DOC L.1.

This change is acceptable because CTS 3/4.1.2.3 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Charging Pumps - Shutdown Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Charging Pumps - Shutdown Specification does not satisfy criterion 2.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 291 of 357

Attachment 1, Volume 6, Rev. 0, Page 292 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.3, CHARGING PUMP - SHUTDOWN

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Charging Pumps - Shutdown Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-6) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Charging Pumps -

Shutdown Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Charging Pumps

- Shutdown LCO and Surveillances may be relocated out of the Technical Specifications. The Charging Pumps - Shutdown Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS 3.1.2.3.b states that one charging flow path associated with support of Unit 2 (Unit 1) and Unit 1 (Unit 2) shutdown functions shall be available. The ITS does not include these requirements. This changes the CTS by deleting these requirements from the CTS.

The purpose of CTS 3.1.2.3.b is to satisfy the safe shutdown requirements of 10 CFR 50 Appendix R. This change is acceptable because the LCO requirements in the Technical Requirements Manual continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This change deletes the safe shutdown requirements of 10 CFR 50 Appendix R from the CTS. The opposite unit charging flow path requirements are not needed to satisfy the requirements of the unit safety analyses. CNP is still committed to the safe shutdown requirements of 10 CFR 50 Appendix R. In addition to this change, the Applicability and Action associated with CTS 3.1.2.3.b have been deleted, as well as CTS 4.1.2.3.3, which tests the capability of the unit cross tie valves to cycle.

This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 292 of 357

Attachment 1, Volume 6, Rev. 0, Page 293 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 293 of 357

Attachment 1, Volume 6, Rev. 0, Page 294 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.3, CHARGING PUMP - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 294 of 357

, Volume 6, Rev. 0, Page 295 of 357 CTS 3/4.1.2.4, Charging Pumps - Operating , Volume 6, Rev. 0, Page 295 of 357

Attachment 1, Volume 6, Rev. 0, Page 296 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 296 of 357

, Volume 6, Rev. 0, Page 297 of 357 CTS 3/4.1.2.4 R.1 Page 1 of 2 , Volume 6, Rev. 0, Page 297 of 357

, Volume 6, Rev. 0, Page 298 of 357 CTS 3/4.1.2.4 R.1 Page 2 of 2 , Volume 6, Rev. 0, Page 298 of 357

Attachment 1, Volume 6, Rev. 0, Page 299 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.4, CHARGING PUMPS - OPERATING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.4 provides requirements on the charging pumps during operation when used as part of the boration system. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.4 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Charging Pumps - Operating Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Charging Pumps - Operating Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Charging Pumps - Operating Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-8) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 299 of 357

Attachment 1, Volume 6, Rev. 0, Page 300 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.4, CHARGING PUMPS - OPERATING significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Charging Pumps -

Operating Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Charging Pumps

- Operating LCO and Surveillances may be relocated out of the Technical Specifications. The Charging Pumps - Operating Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 300 of 357

Attachment 1, Volume 6, Rev. 0, Page 301 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 301 of 357

Attachment 1, Volume 6, Rev. 0, Page 302 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.4, CHARGING PUMPS - OPERATING There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 302 of 357

Attachment 1, Volume 6, Rev. 0, Page 303 of 357 CTS 3/4.1.2.5, Boric Acid Transfer Pumps - Shutdown Attachment 1, Volume 6, Rev. 0, Page 303 of 357

Attachment 1, Volume 6, Rev. 0, Page 304 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 304 of 357

, Volume 6, Rev. 0, Page 305 of 357 CTS 3/4.1.2.5 R.1 Page 1 of 2 , Volume 6, Rev. 0, Page 305 of 357

, Volume 6, Rev. 0, Page 306 of 357 CTS 3/4.1.2.5 R.1 Page 2 of 2 , Volume 6, Rev. 0, Page 306 of 357

Attachment 1, Volume 6, Rev. 0, Page 307 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.5, BORIC ACID TRANSFER PUMPS - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.5 provides requirements on the boric acid transfer pumps during shutdown. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.5 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Boric Acid Transfer Pumps - Shutdown Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Boric Acid Transfer Pumps - Shutdown Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Boric Acid Transfer Pumps - Shutdown Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-6) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 307 of 357

Attachment 1, Volume 6, Rev. 0, Page 308 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.5, BORIC ACID TRANSFER PUMPS - SHUTDOWN significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Boric Acid Transfer Pumps

- Shutdown Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Boric Acid Transfer Pumps - Shutdown LCO and Surveillances may be relocated out of the Technical Specifications. The Boric Acid Transfer Pumps - Shutdown Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 308 of 357

Attachment 1, Volume 6, Rev. 0, Page 309 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 309 of 357

Attachment 1, Volume 6, Rev. 0, Page 310 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.5, BORIC ACID TRANSFER PUMPS - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 310 of 357

Attachment 1, Volume 6, Rev. 0, Page 311 of 357 CTS 3/4.1.2.6, Boric Acid Transfer Pumps - Operating Attachment 1, Volume 6, Rev. 0, Page 311 of 357

Attachment 1, Volume 6, Rev. 0, Page 312 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 312 of 357

, Volume 6, Rev. 0, Page 313 of 357 CTS 3/4.1.2.6 R.1 Page 1 of 2 , Volume 6, Rev. 0, Page 313 of 357

, Volume 6, Rev. 0, Page 314 of 357 CTS 3/4.1.2.6 R.1 Page 2 of 2 , Volume 6, Rev. 0, Page 314 of 357

Attachment 1, Volume 6, Rev. 0, Page 315 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.6, BORIC ACID TRANSFER PUMPS - OPERATING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.6 provides requirements on the boric acid transfer pumps during operation. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.6 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Boric Acid Transfer Pumps - Operating Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Boric Acid Transfer Pumps - Operating Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Boric Acid Transfer Pumps - Operating Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-8) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 315 of 357

Attachment 1, Volume 6, Rev. 0, Page 316 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.6, BORIC ACID TRANSFER PUMPS - OPERATING significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Boric Acid Transfer Pumps

- Operating Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Boric Acid Transfer Pumps - Operating LCO and Surveillances may be relocated out of the Technical Specifications. The Boric Acid Transfer Pumps - Operating Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 316 of 357

Attachment 1, Volume 6, Rev. 0, Page 317 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 317 of 357

Attachment 1, Volume 6, Rev. 0, Page 318 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.6, BORIC ACID TRANSFER PUMPS - OPERATING There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 318 of 357

, Volume 6, Rev. 0, Page 319 of 357 CTS 3/4.1.2.7, Borated Water Sources - Shutdown , Volume 6, Rev. 0, Page 319 of 357

Attachment 1, Volume 6, Rev. 0, Page 320 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 320 of 357

, Volume 6, Rev. 0, Page 321 of 357 CTS 3/4.1.2.7 R.1 Page 1 of 2 , Volume 6, Rev. 0, Page 321 of 357

, Volume 6, Rev. 0, Page 322 of 357 CTS 3/4.1.2.7 R.1 Page 2 of 2 , Volume 6, Rev. 0, Page 322 of 357

Attachment 1, Volume 6, Rev. 0, Page 323 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.7, BORATED WATER SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.7 provides requirements on the borated water sources during shutdown. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.7 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Borated Water Sources - Shutdown Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Borated Water Sources - Shutdown Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Borated Water Sources - Shutdown Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-10) and summarized in Table 1 of WCAP-11618, the loss of the CVCS System was found to be a CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 323 of 357

Attachment 1, Volume 6, Rev. 0, Page 324 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.7, BORATED WATER SOURCES - SHUTDOWN non-significant risk contributor to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Borated Water Sources - Shutdown Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Borated Water Sources - Shutdown LCO and Surveillances may be relocated out of the Technical Specifications. The Borated Water Sources - Shutdown Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 324 of 357

Attachment 1, Volume 6, Rev. 0, Page 325 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 325 of 357

Attachment 1, Volume 6, Rev. 0, Page 326 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.7, BORATED WATER SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 326 of 357

Attachment 1, Volume 6, Rev. 0, Page 327 of 357 CTS 3/4.1.2.8, Borated Water Sources - Operations (Unit 1)/

Operating (Unit 2)

Attachment 1, Volume 6, Rev. 0, Page 327 of 357

Attachment 1, Volume 6, Rev. 0, Page 328 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 328 of 357

, Volume 6, Rev. 0, Page 329 of 357 CTS 3/4.1.2.8 R.1 Page 1 of 4 , Volume 6, Rev. 0, Page 329 of 357

, Volume 6, Rev. 0, Page 330 of 357 CTS 3/4.1.2.8 R.1 Page 2 of 4 , Volume 6, Rev. 0, Page 330 of 357

, Volume 6, Rev. 0, Page 331 of 357 CTS 3/4.1.2.8 R.1 Page 3 of 4 , Volume 6, Rev. 0, Page 331 of 357

, Volume 6, Rev. 0, Page 332 of 357 CTS 3/4.1.2.8 R.1 Page 4 of 4 , Volume 6, Rev. 0, Page 332 of 357

Attachment 1, Volume 6, Rev. 0, Page 333 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.8, BORATED WATER SOURCES - OPERATIONS (UNIT 1)/

OPERATING (UNIT 2)

ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.1.2.8 provides requirements on the borated water sources during operation. The boration subsystem of the Chemical and Volume Control System (CVCS) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the SHUTDOWN MARGIN. To accomplish this functional requirement, the CTS requires a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head.

The boration subsystem is not assumed to be OPERABLE to mitigate the consequences of a DBA or transient. In the case of a malfunction of the CVCS that causes a boron dilution event, the response required by the operator is to close the appropriate valves in the reactor makeup system. This action is required before the SHUTDOWN MARGIN is lost. Operation of the boration subsystem is not assumed to mitigate this event. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3/4.1.2.8 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. The CVCS is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Borated Water Sources - Operations/Operating Specification does not satisfy criterion 1.

2. The CVCS is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Borated Water Sources - Operations/Operating Specification does not satisfy criterion 2.

3. The CVCS is not part of a primary success path in the mitigation of a DBA or transient. The Borated Water Sources - Operations/Operating Specification does not satisfy criterion 3.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 6, Rev. 0, Page 333 of 357

Attachment 1, Volume 6, Rev. 0, Page 334 of 357 DISCUSSION OF CHANGES CTS 3/4.1.2.8, BORATED WATER SOURCES - OPERATIONS (UNIT 1)/

OPERATING (UNIT 2)

4. As discussed in Section 4.0 (Appendix A, page A-10) and summarized in Table 1 of WCAP-11618, the loss of the CVCS was found to be a non-significant risk contributor to core damage frequency and offsite releases.

I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Borated Water Sources -

Operations/Operating Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Borated Water Sources - Operations/Operating LCO and Surveillances may be relocated out of the Technical Specifications. The Borated Water Sources -

Operations/Operating Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 6, Rev. 0, Page 334 of 357

Attachment 1, Volume 6, Rev. 0, Page 335 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 335 of 357

Attachment 1, Volume 6, Rev. 0, Page 336 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.1.2.8, BORATED WATER SOURCES - OPERATIONS (UNIT 1)/

OPERATING (UNIT 2)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 336 of 357

, Volume 6, Rev. 0, Page 337 of 357 CTS 3/4.10.1, Shutdown Margin , Volume 6, Rev. 0, Page 337 of 357

Attachment 1, Volume 6, Rev. 0, Page 338 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 338 of 357

, Volume 6, Rev. 0, Page 339 of 357 CTS 3/4.10.1 M.1 Page 1 of 2 , Volume 6, Rev. 0, Page 339 of 357

, Volume 6, Rev. 0, Page 340 of 357 CTS 3/4.10.1 M.1 Page 2 of 2 , Volume 6, Rev. 0, Page 340 of 357

Attachment 1, Volume 6, Rev. 0, Page 341 of 357 DISCUSSION OF CHANGES CTS 3/4.10.1, SHUTDOWN MARGIN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M.1 CTS 3/4.10.1 provides an exception to the SHUTDOWN MARGIN requirements in CTS 3.1.1.1 in MODE 2 for the purpose of measurement of rod worth and shutdown margin provided the reactivity equivalent to at least the highest estimated control rod worth is available for trip insertion from OPERABLE control rod(s). According to the Bases, this special test exception is required to permit the periodic verification of the actual versus predicted core reactivity condition occurring as a result of fuel burnup or fuel cycling operations. The ITS does not contain this special test exception. This changes the CTS by eliminating a special test exception.

This change is acceptable because this method of testing is no longer used. As a result, the CTS special test exception is not needed. Other rod worth measurement techniques that do not violate the SHUTDOWN MARGIN requirements are used. This change is designated as more restrictive because an exception to the CTS is being deleted.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 341 of 357

Attachment 1, Volume 6, Rev. 0, Page 342 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 342 of 357

Attachment 1, Volume 6, Rev. 0, Page 343 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.10.1, SHUTDOWN MARGIN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 343 of 357

Attachment 1, Volume 6, Rev. 0, Page 344 of 357 CTS 3/4.10.2, Group Height, Insertion, and Power Distribution Limits Attachment 1, Volume 6, Rev. 0, Page 344 of 357

Attachment 1, Volume 6, Rev. 0, Page 345 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 345 of 357

, Volume 6, Rev. 0, Page 346 of 357 CTS 3/4.10.2 M.1 Page 1 of 2 , Volume 6, Rev. 0, Page 346 of 357

, Volume 6, Rev. 0, Page 347 of 357 CTS 3/4.10.2 M.1 Page 2 of 2 , Volume 6, Rev. 0, Page 347 of 357

Attachment 1, Volume 6, Rev. 0, Page 348 of 357 DISCUSSION OF CHANGES CTS 3/4.10.2, GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M.1 CTS 3/4.10.2 provides an exception to the rod group height, rod insertion, and power distribution limits Specifications. This special test exception permits individual control rods to be positioned outside of their normal group heights and insertion limits during the performance of such PHYSICS TESTS as those required to 1) measure control rod worth and, 2) determine the reactor stability index and damping factor under xenon oscillation conditions. The ITS does not contain this special test exception. This changes the CTS by eliminating a special test exception.

This change is acceptable because these types of PHYSICS TESTS (measurement of control rod worth and determination of the reactor stability index as well as the damping factor under xenon oscillation conditions) are only performed during initial plant startup test programs. These tests are never performed during post-refueling PHYSICS TESTS. As a result, the CTS special test exception is not needed. This change is designated as more restrictive because an exception to the CTS is being deleted.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 348 of 357

Attachment 1, Volume 6, Rev. 0, Page 349 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 349 of 357

Attachment 1, Volume 6, Rev. 0, Page 350 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.10.2, GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 350 of 357

Attachment 1, Volume 6, Rev. 0, Page 351 of 357 CTS 3/4.10.3, Pressure/Temperature Limitation - Reactor Criticality (Unit 1)

Attachment 1, Volume 6, Rev. 0, Page 351 of 357

Attachment 1, Volume 6, Rev. 0, Page 352 of 357 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 6, Rev. 0, Page 352 of 357

, Volume 6, Rev. 0, Page 353 of 357 CTS 3/4.10.3 M.1 Page 1 of 2 , Volume 6, Rev. 0, Page 353 of 357

, Volume 6, Rev. 0, Page 354 of 357 CTS 3/4.10.3 M.1 Page 2 of 2 , Volume 6, Rev. 0, Page 354 of 357

Attachment 1, Volume 6, Rev. 0, Page 355 of 357 DISCUSSION OF CHANGES CTS 3/4.10.3, PRESSURE/TEMPERATURE LIMITATION - REACTOR CRITICALITY ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M.1 (Unit 1 only) CTS 3/4.10.3 provides an exception to the minimum temperature and pressure conditions for reactor criticality of Specifications 3.1.1.5 and 3.4.9.1 during low temperature PHYSICS TESTS provided some other restrictions are enforced. These restrictions are that THERMAL POWER does not exceed 5% of RATED THERMAL POWER, the reactor trip setpoints for the OPERABLE Intermediate Range, Neutron Flux and the Power Range, Neutron Flux, Low Setpoints are set at < 25% of RATED THERMAL POWER, and the Reactor Coolant System temperature and pressure relationship is maintained within the region of acceptable operation shown on Figures 3.4-2 and 3.4-3. The ITS does not contain this special test exception. This changes the Unit 1 CTS by eliminating a special test exception.

This change is acceptable because low temperature PHYSICS TESTS are no longer performed. This allowance is not available for Unit 2 and is not needed for Unit 1. Future PHYSICS TESTS will be performed under ITS 3.1.8, "PHYSICS TESTS Exceptions - MODE 2," which has been developed from CTS 3/4.10.4, PHYSICS TESTS. As a result, the CTS special test exception is not needed.

This change is designated as more restrictive because an exception to the Unit 1 CTS is being deleted.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 355 of 357

Attachment 1, Volume 6, Rev. 0, Page 356 of 357 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 6, Rev. 0, Page 356 of 357

Attachment 1, Volume 6, Rev. 0, Page 357 of 357 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.10.3, PRESSURE/TEMPERATURE LIMITATION - REACTOR CRITICALITY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 6, Rev. 0, Page 357 of 357

ML041200358

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