Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 7, Rev 0, ITS Section 3.2 Power Distribution Limits.
	ML041200360
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	; Indiana Michigan Power Co
To:	; Office of Nuclear Reactor Regulation
References
	AEP:NRC:4901
	Download: ML041200360 (158)
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Attachment 1, Volume 7, Rev. 0, Page 1 of 158 VOLUME 7 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 0 Attachment 1, Volume 7, Rev. 0, Page 1 of 158

Attachment 1, Volume 7, Rev. 0, Page 2 of 158 LIST OF ATTACHMENTS

1. ITS 3.2.1

2. ITS 3.2.2

3. ITS 3.2.3

4. ITS 3.2.4 Attachment 1, Volume 7, Rev. 0, Page 2 of 158

, Volume 7, Rev. 0, Page 3 of 158 ATTACHMENT 1 ITS 3.2.1, Heat Flux Hot Channel Factor , Volume 7, Rev. 0, Page 3 of 158

, Volume 7, Rev. 0, Page 4 of 158 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 0, Page 4 of 158

Attachment 1, Volume 7, Rev. 0, Page 5 of 158 ITS 3.2.1 A.1 ITS C

F (Z) shall be within the limits specified in the COLR.

Q LA.1 LCO 3.2.1 after each determination of FQ(Z) A.2 72 L.1 ACTION A L.2 Add proposed ACTION C M.1 Page 1 of 14 Attachment 1, Volume 7, Rev. 0, Page 5 of 158

Attachment 1, Volume 7, Rev. 0, Page 6 of 158 ITS 3.2.1 A.1 ITS A.3 SR 3.2.1.1 Add proposed 1st Frequency, including Note to SR 3.2.1.1 M.2 Page 2 of 14 Attachment 1, Volume 7, Rev. 0, Page 6 of 158

Attachment 1, Volume 7, Rev. 0, Page 7 of 158 ITS 3.2.1 A.1 ITS 1

Page 3 of 14 Attachment 1, Volume 7, Rev. 0, Page 7 of 158

Attachment 1, Volume 7, Rev. 0, Page 8 of 158 ITS 3.2.1 A.1 ITS Page 4 of 14 Attachment 1, Volume 7, Rev. 0, Page 8 of 158

Attachment 1, Volume 7, Rev. 0, Page 9 of 158 ITS 3.2.1 A.1 ITS W

F (Z)

Q A.4 within the limit specified in the COLR LCO 3.2.1 LA.2 A.4 Note to SR 3.2.1.2 LA.2 Page 5 of 14 Attachment 1, Volume 7, Rev. 0, Page 9 of 158

Attachment 1, Volume 7, Rev. 0, Page 10 of 158 ITS 3.2.1 A.1 ITS A.4 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L.3 ACTION B 72 L.1 Add proposed Required Action B.4 M.3 Add proposed ACTION C M.1 A.3 W

F (Z)

Q A.4 SR 3.2.1.2 A.5 Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months M.2 W

F (Z)

Q A.4 A.4 SR 3.2.1.2 Note 1 M.2 Page 6 of 14 Attachment 1, Volume 7, Rev. 0, Page 10 of 158

Attachment 1, Volume 7, Rev. 0, Page 11 of 158 ITS 3.2.1 A.1 ITS C

F (Z) shall be within the limits specified in the COLR Q

LA.1 LCO 3.2.1 after each determination of FQ(Z) A.2 72 L.1 ACTION A L.2 Add proposed ACTION C M.1 Page 7 of 14 Attachment 1, Volume 7, Rev. 0, Page 11 of 158

Attachment 1, Volume 7, Rev. 0, Page 12 of 158 ITS 3.2.1 A.1 ITS A.3 SR 3.2.1.1 Add proposed 1st Frequency including M.2 Note to SR 3.2.1.1 Page 8 of 14 Attachment 1, Volume 7, Rev. 0, Page 12 of 158

Attachment 1, Volume 7, Rev. 0, Page 13 of 158 ITS 3.2.1 A.1 ITS Page 9 of 14 Attachment 1, Volume 7, Rev. 0, Page 13 of 158

Attachment 1, Volume 7, Rev. 0, Page 14 of 158 ITS 3.2.1 A.1 ITS Page 10 of 14 Attachment 1, Volume 7, Rev. 0, Page 14 of 158

Attachment 1, Volume 7, Rev. 0, Page 15 of 158 ITS 3.2.1 A.1 ITS Page 11 of 14 Attachment 1, Volume 7, Rev. 0, Page 15 of 158

Attachment 1, Volume 7, Rev. 0, Page 16 of 158 ITS 3.2.1 A.1 ITS Page 12 of 14 Attachment 1, Volume 7, Rev. 0, Page 16 of 158

Attachment 1, Volume 7, Rev. 0, Page 17 of 158 ITS 3.2.1 A.1 ITS W

F (Z)

Q A.4 within the limit specified in the COLR LCO 3.2.1 LA.2 A.4 Note to SR 3.2.1.2 LA.2 Page 13 of 14 Attachment 1, Volume 7, Rev. 0, Page 17 of 158

Attachment 1, Volume 7, Rev. 0, Page 18 of 158 ITS 3.2.1 A.1 ITS A.4 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L.3 ACTION B 72 L.1 Add proposed Required Action B.4 M.3 Add proposed ACTION C M.1 A.3 W

F (Z)

Q A.4 SR 3.2.1.2 A.5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months M.2 W

F (Z)

Q A.4 A.4 SR 3.2.1.2 Note 1 M.2 Page 14 of 14 Attachment 1, Volume 7, Rev. 0, Page 18 of 158

Attachment 1, Volume 7, Rev. 0, Page 19 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z)

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 ITS 3.2.1, Required Actions A.2.1, A.2.2, and A.2.3 state that the Required Actions must be taken "after each FCQ(Z) determination." CTS 3.2.2, Action a does not explicitly state this requirement.

This change is acceptable because it does not result in a technical change to the Technical Specifications. The CTS is understood to apply after each measurement of FQ(Z). This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 4.2.2.1 states "The provisions of Specification 4.0.4 are not applicable."

The ITS does not include this statement.

The purpose of a CTS 4.0.4 exception is to allow the plant to enter the MODE of Applicability without performing the required Surveillances. This change is acceptable because the CTS 4.0.4 exception is not necessary. The ITS SR 3.2.1.1 Frequencies are written to allow entry into MODE 1 following a reactor startup. This serves the same purpose as the CTS 4.0.4 exception. This change is designated as administrative because it eliminates a CTS provision which is covered in the ITS in an alternate manner.

A.4 CTS 3/4.2.6 provides a limit, Actions, and Surveillances for the Allowable Power Level (APL). The CTS requires the APL to be greater than THERMAL POWER, and if not, requires the THERMAL POWER to be reduced to APL or less of RATED THERMAL POWER (RTP). It further requires a reduction in the Power Range Neutron Flux - High and Overpower T Trip Setpoints by the same percentage by which APL is below RTP. Surveillance Requirements are provided to periodically confirm APL is within limits. ITS 3.2.1 uses the term FW Q(Z), consistent with NUREG-1431, Rev. 2, in lieu of the term APL. The ITS limit for FWQ(Z) is provided in the COLR. If the FWQ(Z) limit is not met, the ITS Required Actions are to reduce THERMAL POWER by > 1% for each 1% that FWQ(Z) exceeds its limit, and to reduce the trip setpoints by > 1% for each 1% that FWQ(Z) exceeds its limit. In addition, the ITS Surveillances periodically confirm FWQ(Z) is within limit. This changes the CTS by substituting the term FWQ(Z) for the term APL and modifies the Actions accordingly.

The purpose of monitoring and controlling APL is to protect the peaking factors to ensure FQ(Z) is within limits during transient conditions. The ITS term FWQ(Z) performs the same function. As described in the AEP letter to the NRC (letter C0301-05) dated March 7, 2001, APL is analogous to FWQ(Z). The letter described the formula for APL and how it related to the ITS term FWQ(Z). This CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 7, Rev. 0, Page 19 of 158

Attachment 1, Volume 7, Rev. 0, Page 20 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z) letter was reviewed by the NRC as part of an amendment request relating to APL, and was used as the basis for the NRC to approve Amendments 251 (Unit

1) and 233 (Unit 2) (SER letter dated March 29, 2001). Since the two terms are analogous, using the ITS term FWQ(Z) is purely an editorial preference to conform to NUREG-1431, Revision 2. Therefore, this change is acceptable and is designated as an administrative change since conversion to the term FWQ(Z) does not result in any technical changes.

A.5 CTS 4.2.6.2 requires APL (changed to FWQ(Z) per DOC A.4) to be determined "in conjunction with the target flux difference and target band determination." The ITS does not include this cross-reference to the Surveillances of ITS 3.2.3 (the AFD Specification). This changes the CTS by deleting the cross-reference to the AFD Specification.

The AFD Specification (CTS 3.2.1) does not list the normal, periodic Surveillance Frequencies for determining the target flux difference and target band; it simply references the Frequencies of CTS 3.2.6. As such, the CTS Surveillances of the APL Specification also cross-reference back to the AFD Specification Surveillances. In the ITS, each SR has its own distinct Frequency; they do not normally cross-reference the Frequency in another ITS Specification. Therefore, this change is considered acceptable since it does not result in any technical changes to the CTS. Any changes to the CTS Frequencies are discussed in the appropriate Discussion of Changes. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.2.2 and CTS 3.2.6 do not contain an Action to follow if the provided Actions are not followed. Therefore, CTS 3.0.3 would be entered which would require the plant to be in MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.2.1 ACTION B states that when the Required Action and associated Completion Time is not met, the plant must be in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by providing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instead of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to be in MODE 2.

This change is acceptable because, based on operating experience, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is a reasonable time to be in MODE 2 from full power operation in an orderly manner and without challenging plant systems. This change is designated as more restrictive because the ITS allows less time to be in MODE 2 than does the CTS.

M.2 CTS 4.2.2.2 requires FQ(Z) to be determined to be within its limit whenever FQ(Z) is measured for reasons other than meeting the requirement of CTS 4.2.6.2 or at least every 31 effective full power days (EFPD), whichever occurs first. ITS SR 3.2.1.1 requires a verification that FCQ(Z) is within limit a) once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by > 10% RTP, the THERMAL POWER at which FCQ(Z) was last verified; and b) every 31 EFPD thereafter. However, a Note is provided such that the SR is not required to be performed during power escalation at the beginning of each cycle until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after equilibrium conditions at a power level for extended operation are achieved.

CTS 4.2.6.2 requires the APL to be determined to be within limit upon reaching equilibrium conditions after exceeding 10% or more of RTP, the THERMAL CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 7, Rev. 0, Page 20 of 158

Attachment 1, Volume 7, Rev. 0, Page 21 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z)

POWER at which APL was last determined or at least once per 31 EFPD, whichever occurs first. CTS 4.2.6.2 footnote ** however, allows the Surveillance to be deferred during power escalation at the beginning of each cycle until a power level for extended operation has been achieved. ITS SR 3.2.1.2 requires the FWQ(Z) to be verified within the limit: a) once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by > 10% RTP, the THERMAL POWER at which FWQ(Z) was last verified; and b) every 31 EFPD thereafter. (It should be noted that the term APL has been changed to FWQ(Z) per DOC A.4). The ITS also includes a Note (Note 1) that allows the SR not to be performed during power escalation at the beginning of each cycle until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after equilibrium conditions at a power level for extended operation are achieved. This changes the CTS by adding a new Frequency (first Frequency) and new time limit (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the applicable Note) for CTS 4.2.2.2 and adding a new time limit (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) for CTS 4.2.6.2, including footnote **.

The first Frequency for CTS 4.2.2.2 does not really specify a specific time to verify FQ(Z) is within the limit; it essentially means to verify whenever CNP wants to. Thus, the only actual Frequency specified in CTS 4.2.2.2 is the 31 EFPD Frequency. This change is acceptable because it provides an appropriate verification (with a finite time to complete) at a power level for extended operation and if THERMAL POWER is substantially changed and equilibrium conditions are attained during the 31 EFPD window. This change is designated as more restrictive because it applies a Frequency and time limit which did not exist in the CTS.

M.3 The CTS 3.2.6 Action provides actions for when the APL is less than the THERMAL POWER. However, there are no requirements to recalculate APL prior to increasing power, once the APL is less than THERMAL POWER.

ITS 3.2.1 Required Action B.4 requires performance of SR 3.2.1.1 and SR 3.2.1.2 when FWQ(Z) is not within limit prior to increasing THERMAL POWER above the limit established in Required Action B.1. (It should be noted that APL has been changed to FWQ(Z) per DOC A.4). This changes the CTS by adding a new requirement to verify FCQ(Z) and FWQ(Z) are within limits prior to increasing THERMAL POWER after restoring FWQ(Z) to within the limit.

This change is acceptable because it requires a confirmation that FCQ(Z) and FWQ(Z) are within limits, similar to the confirmation required by CTS 3.2.2 Action b.

This ensures that, prior to increasing THERMAL POWER after restoration of FWQ(Z) to within the limit, that FQ(Z) is still within limits. This change is designated as more restrictive because it applies a new requirement which does not exist in the CTS.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 7, Rev. 0, Page 21 of 158

Attachment 1, Volume 7, Rev. 0, Page 22 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z)

REMOVED DETAIL CHANGES LA.1 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.2.2 states that FQ(Z) shall be limited by an equation, which is contained in the LCO. Two of the four parameters in the CTS equation are already located in the CORE OPERATING LIMITS REPORT (COLR). The other two parameters are actually specified in the LCO. ITS LCO 3.2.1 states "FQ(Z), as approximated by FCQ(Z) and FWQ(Z),

shall be within the limits specified in the COLR." This changes the CTS by relocating the two parameters that are in the LCO, as well as the equation, to the COLR. This also changes the CTS by using the term " FCQ(Z)" in lieu of "FQ(Z)".

While the two parameters (P and FQ(Z)) are not cycle specific, the "P" parameter is based on actual THERMAL POWER divided by RTP (i.e., a measured value divided by a constant), and the "FQ(Z)" value is the measured FQ(Z) multiplied by two constant uncertainty factors. Thus, the entire equation for FQ(Z) can be considered cycle specific. In addition, the ITS term " FCQ(Z)" is consistent with the CTS term "FQ(Z)" since both are corrected for the uncertainty factors. The removal of these parameter limits from the Technical Specifications and their relocation into the COLR is acceptable because these limits are developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications," 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 requirements and Surveillances that verify that the cycle-specific parameter limits are being met. The ITS requires that FCQ(Z) be within the limits specified in the COLR. Two of the four parameters for the FCQ(Z) limit are already located in the COLR. Moving the equation itself to the COLR does not change the requirement that the FCQ(Z) limit be met. 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 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 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.2.6 states that Allowable Power Level (APL) shall be limited by an equation, which is contained in the LCO. Three of the five parameters in the CTS equation are already located in the CORE OPERATING LIMITS REPORT (COLR). The other two parameters are actually specified in the LCO. ITS LCO 3.2.2 states "FQ(Z), as approximated by FCQ(Z) and FWQ(Z), shall be within the limits specified in the COLR." This changes the CTS by relocating the two parameters that are in the LCO, as well as the equation and the allowance that the FWQ(Z) limit is not applicable in certain core regions to the COLR. The change from APL to FWQ(Z) is described in DOC A.4.

CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 7, Rev. 0, Page 22 of 158

Attachment 1, Volume 7, Rev. 0, Page 23 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z)

While the two parameters (FQ(Z) and Fp) are not normally cycle-specific, the "FQ(Z)" value is the measured FQ(Z) multiplied by two constant uncertainty factors, and the "FP" parameter is normally a constant (although, under certain circumstances, the parameter value is specified in the COLR). Thus, the entire equation for FWQ(Z) can be considered cycle specific. The removal of these parameter limits from the Technical Specifications and their relocation into the COLR is acceptable because these limits are developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications,"

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 requirements and Surveillances that verify that the cycle specific parameter limits are being met. The ITS requires that FWQ(Z) be within the limits specified in the COLR. Three of the five parameters for the FWQ(Z) limit are already located in the COLR. Moving the equation itself to the COLR does not change the requirement that the FWQ(Z) limit be met. 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 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.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.2.2 Action a states the Power Range Neutron Flux - High trip setpoints must be reduced 1% for each 1% FQ(Z) exceeds its limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The CTS 3.2.6 Action states the Power Range Neutron Flux - High trip setpoints must be reduced by the same percentage which APL is below RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . (It should be noted that the term APL has been changed to FWQ(Z) per DOC A.4). ITS 3.2.1 Required Actions A.2 and B.2 requires the Power Range Neutron Flux - High trip setpoints to be reduced > 1% for each 1% FCQ(Z) exceeds its limit or for each 1% that FWQ(Z) exceeds its limit, respectively, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This changes the CTS by extending the Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The purpose of CTS 3.2.2 Action a and the CTS 3.2.6 Action is to reduce the Power Range Neutron Flux - High trip setpoints when FQ(Z) or APL exceeds its limit to prevent inadvertently exceeding the maximum allowable power level.

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. Following a significant power reduction, a time period of at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is required to reestablish steady state xenon concentration and power distribution prior to taking a flux map, and a time period of approximately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is required to take and analyze a flux map. If it is determined CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 7, Rev. 0, Page 23 of 158

Attachment 1, Volume 7, Rev. 0, Page 24 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z) that FCQ(Z) or FWQ(Z) is still not within its limit, reducing the Power Range Neutron Flux - High trip setpoints takes approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per channel, with additional time required for preparation and channel restoration. Furthermore, setpoint changes should only be required for extended operation in this condition because of the risk of a plant trip during the adjustment. 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 3.2.2 Action b states that when FQ(Z) exceeds its limit, identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER above the reduced power limit.

ITS 3.2.1 Required Action A.4 requires verification that FCQ(Z) is within its limit prior to increasing THERMAL POWER above the reduced power limit. This changes the CTS by eliminating the requirement to identify the cause of the out of limit condition prior to increasing power above the reduced power limit.

The purpose of CTS 3.2.2 Action b is to ensure FQ(Z) is within its limit prior to increasing THERMAL POWER above the reduced power limit. 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. Identifying the cause of the out of limit condition is not required to restore compliance with the LCO. Identifying the cause of the condition is a function of the corrective action program required by 10 CFR 50, Appendix B. 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 3 - Relaxation of Completion Time) The CTS 3.2.6 Action states that with APL less than THERMAL POWER, reduce THERMAL POWER to APL or less of RATED THERMAL POWER within 15 minutes. ITS 3.2.1 Required Action B.1 requires, under the similar condition (It should be noted that APL has been changed to FWQ(Z) per DOC A.4), 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to complete the Required Action.

This changes the CTS by extending the Completion Time from 15 minutes to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The purpose of the CTS 3.2.6 Action is to reduce the THERMAL POWER when APL is less than THERMAL POWER to help ensure the peaking factors are not exceeded if a transient were to occur. 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 transient occurring during the allowed Completion Time. During the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time, the actual limit being protected by FWQ(Z), FQ(Z), is not necessarily outside the required limits. If it is, then ITS 3.2.1 ACTION A would be entered, which requires a power reduction in 15 minutes. This change is designated as less CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 7, Rev. 0, Page 24 of 158

Attachment 1, Volume 7, Rev. 0, Page 25 of 158 DISCUSSION OF CHANGES ITS 3.2.1, FQ(Z) restrictive because additional time is allowed to restore parameters to within LCO limits than was allowed in the CTS.

CNP Units 1 and 2 Page 7 of 7 Attachment 1, Volume 7, Rev. 0, Page 25 of 158

Attachment 1, Volume 7, Rev. 0, Page 26 of 158 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 7, Rev. 0, Page 33 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, FQ(Z)

1. The CAOC-W(Z) methodology and the Specification designator "C" are deleted since they are unnecessary (only one FQ(Z) Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-FXY and RAOC-W(Z) methodology Specifications (ISTS 3.2.1A and 3.2.1B) are not used and are not shown.

2. Typographical/grammatical error corrected.

3. The first Frequency of both SR 3.2.1.1 and SR 3.2.1.2 has been deleted. In addition, Notes have been added to the two SRs stating when the SRs are required to be performed following startup at the beginning of a cycle. These two changes are consistent with the current licensing basis of CNP. Currently, CNP only requires the first performance of SR 3.2.1.2 (CTS 4.2.6.2 is the equivalent CTS Surveillance) after achieving equilibrium conditions after exceeding by 10% or more of RTP, the THERMAL POWER at which the parameter was last determined. The CTS modifies this requirement with a footnote (Footnote **) which states that during power escalation at the beginning of each cycle, the design target may be used until a power level for extended operation has been achieved. This essentially means that the first performance is not required until equilibrium conditions are reached at a power level for extended operation (normally 100% RTP). The ITS Note provides this allowance, and also establishes a finite time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) after equilibrium conditions are reached to perform the SR. The CTS equivalent to SR 3.2.1.1 (CTS 4.2.2.2) does not require the first performance until 31 EFPD. Thus, the addition of the entirely new ISTS second Frequency (ITS first Frequency), including the SR Note, is more restrictive than required by CTS. However, it is consistent with the Frequency of CTS 4.2.6.2. Finally, due to the addition of these specific SR Notes, the general Note at the beginning of the SRs is not needed and has also been deleted.

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

5. This punctuation correction has been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

6. ISTS 3.2.1C Required Action B.1 requires AFD limits to be reduced > 1% for each 1% that FWQ(Z) exceeds the limit. ISTS Required Actions B.2 and B.3 require a reduction in Power Range Neutron Flux - High and Overpower T trip setpoints

> 1% for each 1% that the maximum allowable power of the AFD limits is reduced.

The ISTS 3.2.1C Bases for Required Action B.1 state that reducing THERMAL POWER by > 1% for each 1% that FWQ(Z) exceeds its limit maintains an acceptable power density and protects against the consequences of severe transients with unanalyzed power distributions. ISTS 3.2.1C Required Action B.1 has been modified to require a reduction of THERMAL POWER instead of a reduction of the AFD limits, and ISTS 3.2.1C Required Actions B.2 and B.3 have been modified to require the reduction of the associated trip setpoints to be based upon the amount FWQ(Z) exceeds the limit instead of the maximum allowable power that the AFD limits is reduced. These changes establish consistency and clarity between ITS 3.2.1 Required Actions B.1, B.2, and B.3 and the ISTS 3.2.1C Bases. This is acceptable CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 7, Rev. 0, Page 33 of 158

Attachment 1, Volume 7, Rev. 0, Page 34 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, FQ(Z) since reducing THERMAL POWER an amount > FWQ(Z) exceeds its limit ensures acceptable power distribution exists during a severe transient.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 7, Rev. 0, Page 34 of 158

Attachment 1, Volume 7, Rev. 0, Page 35 of 158 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 7, Rev. 0, Page 46 of 158 B 3.2.1 12 INSERT 4 measurements indicate that the 12 INSERT 5 has increased since the previous evaluation of FCQ(Z),

12 INSERT 6 and reverify FWQ(Z) is within limits; or SR 3.2.1.2 must be repeated once per 7 EFPD until either FWQ(Z) is within the limits or two successive flux maps indicate that the maximum over z (FCQ(Z)/K(Z)) has not increased.

Insert Page B 3.2.1C-8 Attachment 1, Volume 7, Rev. 0, Page 46 of 158

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Attachment 1, Volume 7, Rev. 0, Page 50 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, FQ(Z)

1. The CAOC-W(Z) methodology and the Specification designator "C" are deleted since they are unnecessary (only one FQ(Z) Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-FXY and RAOC-W(Z) methodology Specification Bases (ISTS B 3.2.1A and B 3.2.1B) are not used and are not shown.

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. 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.

5. This generic statement is not necessary. The LCO Section of the Bases already states that certain values are specified in the COLR, and providing a "normal" value or Figure that is not the actual one in the COLR can lead to confusion that results in improper limits being applied. Therefore, the statement and the Figure B 3.2.1C-1 have been deleted.

6. The Bases have been changed to reflect changes made to the Specification.

7. These redundant statements in the ACTIONS A.1 Bases, the SR 3.2.1.1 Bases, and the SR 3.2.1.2 Bases have been deleted since the term is already defined and adequately described in the LCO Section of the Bases and does not need to be repeated in these Sections.

8. Typographical/grammatical error corrected.

9. These changes have been made to be consistent with similar phrases in other parts of the ITS Bases.

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

11. This Reviewer's Note has been deleted. The appropriate methodology is listed in the COLR section of the ITS.

12. Changes have been made to be consistent with the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 50 of 158

Attachment 1, Volume 7, Rev. 0, Page 51 of 158 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 51 of 158

Attachment 1, Volume 7, Rev. 0, Page 52 of 158 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, FQ(Z)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 52 of 158

Attachment 1, Volume 7, Rev. 0, Page 53 of 158 ATTACHMENT 2 ITS 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor Attachment 1, Volume 7, Rev. 0, Page 53 of 158

, Volume 7, Rev. 0, Page 54 of 158 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 0, Page 54 of 158

Attachment 1, Volume 7, Rev. 0, Page 55 of 158 ITS 3.2.2 A.1 ITS LCO 3.2.2 within the limits specified in the COLR LA.1 M.1 Add proposed Condition A Note 4

Required Actions L.1 A.1 and A.3 72 LA.2 Required Action A.2 ACTION B 6 L.2 Required Action A.4 A.2 LA.2 Add proposed Required Action A.4 Note A.3 Page 1 of 6 Attachment 1, Volume 7, Rev. 0, Page 55 of 158

Attachment 1, Volume 7, Rev. 0, Page 56 of 158 ITS 3.2.2 A.1 ITS SR 3.2.2.1 LA.2 thereafter A.4 Page 2 of 6 Attachment 1, Volume 7, Rev. 0, Page 56 of 158

Attachment 1, Volume 7, Rev. 0, Page 57 of 158 ITS 3.2.2 A.1 ITS LCO 3.2.2 within the limits specified in the COLR LA.1 Add proposed Condition A Note M.1 4

Required Actions A.1 and A.3 72 L.1 LA.2 Required Action A.2 ACTION B 6 L.2 Required Action A.4 A.2 LA.2 Add proposed Required Action A.4 Note A.3 Page 3 of 6 Attachment 1, Volume 7, Rev. 0, Page 57 of 158

Attachment 1, Volume 7, Rev. 0, Page 58 of 158 ITS 3.2.2 A.1 ITS SR 3.2.2.1 LA.2 thereafter A.4 Page 4 of 6 Attachment 1, Volume 7, Rev. 0, Page 58 of 158

Attachment 1, Volume 7, Rev. 0, Page 59 of 158 ITS 3.2.2 A.1 ITS Page 5 of 6 Attachment 1, Volume 7, Rev. 0, Page 59 of 158

Attachment 1, Volume 7, Rev. 0, Page 60 of 158 ITS 3.2.2 A.1 ITS Page 6 of 6 Attachment 1, Volume 7, Rev. 0, Page 60 of 158

Attachment 1, Volume 7, Rev. 0, Page 61 of 158 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)

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 3.2.3 Action c states that with FNH exceeding its limit "identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER."

ITS 3.2.2 does not include this requirement. This changes the CTS by eliminating the statement that the cause of the out-of-limit condition must be identified and corrected prior to increasing power.

This change is acceptable because the requirements have not changed. Stating that the cause of the FNH limit violation must be identified and corrected prior to increasing power (i.e., exiting the Action which required power reduction) is unnecessary. Restoration of compliance with the LCO is always an option and allows exiting the ACTION per ITS 3.0.2. Therefore, it does not have to be stated. In addition, CTS 3.2.3 Action c and ITS 3.2.2 Required Action A.4 require FNH to be within limit prior to exceeding 50% RTP and 75% RTP, which ensures FNH limit is identified and corrected. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.2.3 Action c states that with FNH exceeding its limit, FNH must be demonstrated to be within its limit prior to exceeding 50% RTP and 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 95% RTP. ITS 3.2.2 Required Action A.4 contains the same requirements. However, ITS 3.2.2 Required Action A.4 is modified by a Note which states "THERMAL POWER does not have to be reduced to comply with this Required Action." This modifies the CTS by adding a Note stating that THERMAL POWER does not have to be reduced to comply with the Required Action.

This change is acceptable because the requirements have not changed. The Note is included in the ITS to make clear that THERMAL POWER does not have to be reduced to perform the Required Action. For example, if FNH exceeded its limit and power was reduced to 60% RTP before FNH is demonstrated to be within its limit, under the Note THERMAL POWER does not have to be reduced to less N

than 50% RTP for a FH measurement. However, FNH must still be measured prior to exceeding 75% RTP and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 95% RTP. The Note is needed because the ITS contains a Note in ITS 3.2.2 Condition A that states "Required Actions A.2 and A.4 must be completed whenever Condition A is entered." The Condition A Note does not exist in the CTS and could be construed as requiring THERMAL POWER to be reduced to comply with Required Action A.4. The Condition A Note is described in DOC M.1. As a result, the Required Action A.4 Note makes the ITS and CTS actions consistent.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 7, Rev. 0, Page 61 of 158

Attachment 1, Volume 7, Rev. 0, Page 62 of 158 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)

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

A.4 CTS 4.2.3.c states "The provisions of Specification 4.0.4 are not applicable."

The ITS does not include this statement. In addition, CTS 4.2.3.b requires the FNH to be determined at least once per 31 Effective Full Power Days. The ITS SR 3.2.2.1 Frequency is 31 EFPD thereafter. This changes the CTS by adding the word "thereafter" to the Frequency.

The purpose of a CTS 4.0.4 exception is to allow the plant to enter the MODE of Applicability without performing the required Surveillances. This change is acceptable because the CTS 4.0.4 exception is not required in the ITS.

CTS 4.2.3 is required to be performed prior to operation above 75% RTP after each fuel loading and once per 31 EFPD. Without the CTS 4.0.4 exception, MODE 1 could not be entered without a measurement if the "once per 31 EFPD" Frequency was not met, because Surveillances must be met prior to entering the MODE of Applicability. However, the likelihood of this occurring (needing to enter MODE 1 with the 31 EFPD Frequency not met) is very small; the 31 EFPD Frequency only runs when the reactor is critical and a 25% grace period is allowed by CTS 4.0.2 (ITS SR 3.0.2). Also, the addition of the word "thereafter" in ITS SR 3.2.2.1 ensures that the 31 EFPD Frequency starts only after the first performance of the SR, which is required prior to exceeding 75% RTP after each fuel loading. This is essentially the way the CTS Frequencies work. Therefore, the deletion of the CTS 4.0.4 exception and addition of the word "thereafter" are considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.2.3 Action c states that with FNH exceeding its limit "subsequent POWER OPERATION may proceed, provided that FNH is demonstrated through incore mapping to be within its limit at a nominal 50% of RATED THERMAL POWER prior to exceeding this THERMAL POWER, at a nominal 75% of RATED THERMAL POWER prior to exceeding this THERMAL POWER, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after attaining 95% or greater RATED THERMAL POWER." However, under CTS 3.0.2, these measurements do not have to be completed if compliance with the LCO is reestablished. ITS 3.2.2 Condition A contains a Note which states, Required Actions A.2 and A.4 must be completed whenever Condition A is entered. ITS Required Actions A.2 and A.4 require performance of a FNH measurement every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and prior to exceeding 50% RTP and 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 95% RTP. This changes the CTS by requiring the FNH measurements to be made even if FNH is restored to within its limit.

This change is acceptable because it establishes appropriate compensatory measurements for violation of the FNH limit. As power is reduced under ITS Required Action A.1, the margin to the FNH limit increases. Therefore, compliance with the LCO could be reestablished during the power reduction.

Verifying that the limit is met as power is increased ensures that the limit CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 7, Rev. 0, Page 62 of 158

Attachment 1, Volume 7, Rev. 0, Page 63 of 158 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH) continues to be met and does not remain unmeasured for up to 31 EFPD. This change is designated as more restrictive because it imposes requirements in addition to those in the CTS.

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 3.2.3 states that FNH shall be limited by an equation, which is contained in the LCO. Two of the three parameters in the CTS equation are as specified in the CORE OPERATING LIMITS REPORT (COLR). ITS LCO 3.2.2 states "FNH shall be within the limits specified in the COLR." This changes the CTS by relocating the entire equation to the COLR.

The removal of these cycle specific parameter limits from the Technical Specifications and their relocation into the COLR is acceptable because these limits are developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications," 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 requirements and Surveillances that verify that the cycle-specific parameter limits are being met.

N The ITS requires that FH be within the limits specified in the COLR. Two of the three parameters for the FNH limit are already located in the COLR. Moving the equation itself to the COLR does not change the requirement that the FNH limit be met. 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 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 3.2.3 Actions b and c require FNH to be determined to be within its limit through in-core mapping and CTS 4.2.3 requires FNH to be determined to be within its limit by using the movable incore detectors to obtain a power distribution map. ITS SR 3.2.2.1 just requires verification that FNH is within its limit. This changes the CTS by relocating to the ITS Bases the N

manner in which the FH determination is performed.

CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 7, Rev. 0, Page 63 of 158

Attachment 1, Volume 7, Rev. 0, Page 64 of 158 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)

The removal of these details for performing actions and a Surveillance Requirement 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 to determine the FNH is within its limit. 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 Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 Action a states that when FNH exceeds its limit, reduce THERMAL POWER to less than 50% RTP within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the Power Range Neutron Flux - High Trip Setpoints to less than or equal to 55% of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.2.2 Required Actions A.1 and A.3 state than with FNH not within this limit, reduce THERMAL POWER to < 50% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and reduce the Power Range Neutron Flux - High trip setpoints to < 55% RTP within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This changes the CTS by allowing a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time to reduce power to < 50% RTP and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to reduce the trip setpoints.

The purpose of CTS 3.2.3 Action a is to reduce power, which increases the N

margin to the FH limit, and to lower the trip setpoints, which avoids inappropriately increasing power and violating the FNH limit. 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. The revised Completion Times allow reactor power to be reduced in a controlled manner without challenging operators, technicians, or plant systems. Following a significant power reduction, a time period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to reestablish steady state xenon concentration and power distribution and to take and analyze a flux map. If it is determined that FNH is still not within its limit, reducing the Power Range Neutron Flux - High Trip Setpoints takes approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per channel, with additional time required for preparation and channel restoration.

Furthermore, setpoint changes should only be required for extended operation in this condition because of the risk of a plant trip during the adjustment. 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 3 - Relaxation of Completion Time) CTS 3.2.3 Action b states that when FNH exceeds its limit, demonstrate through incore mapping that FNH is within its limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or reduce THERMAL POWER to less than 5% within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.2.2 ACTION B states that with the Required Action and CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 7, Rev. 0, Page 64 of 158

Attachment 1, Volume 7, Rev. 0, Page 65 of 158 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH) associated Completion Time not met, be in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by allowing a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time to reduce power to

< 5% RTP in instead of the current 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time limit.

The purpose of CTS 3.2.3, Action b is to reduce power when compliance with the FNH limits cannot be obtained to a MODE in which the LCO is not applicable.

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. The revised Completion Times allow reactor power to be reduced in a controlled manner without challenging operators, technicians, or plant systems. 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.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 7, Rev. 0, Page 65 of 158

Attachment 1, Volume 7, Rev. 0, Page 66 of 158 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 66 of 158

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Attachment 1, Volume 7, Rev. 0, Page 70 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)

1. ISTS 3.2.2 Required Action A.1.1 requires restoration of FNH to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or performance of a number of other actions, such as a power reduction to < 50% RTP. 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. If fact, the inclusion of Required Action A.1.1 requires an additional level of indenting and numbering for the remaining Required Actions in Condition A, which reduces its clarity. Therefore, Required Action A.1.1 is deleted and the subsequent Required Actions renumbered.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 70 of 158

Attachment 1, Volume 7, Rev. 0, Page 71 of 158 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 71 of 158

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Attachment 1, Volume 7, Rev. 0, Page 78 of 158 B 3.2.2 7 INSERT 4 N

even if FH is restored to within limits Insert Page B 3.2.2-4 Attachment 1, Volume 7, Rev. 0, Page 78 of 158

, Volume 7, Rev. 0, Page 79 of 158 , Volume 7, Rev. 0, Page 79 of 158

Attachment 1, Volume 7, Rev. 0, Page 80 of 158 B 3.2.2 7 INSERT 4A If FNH continues to be not within limits, the Power Range Neutron Flux - High trip setpoints must be reduced to < 55% RTP per Required Action A.3.

Insert Page B 3.2.2-5 Attachment 1, Volume 7, Rev. 0, Page 80 of 158

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Attachment 1, Volume 7, Rev. 0, Page 83 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2 BASES, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)

1. The Bases are revised to reflect the CNP DNB limits and correlation. The CNP safety analyses utilize different DNB limits for various analyses, so a specific value is not provided in the Bases. Also, the correlation used is subject to change and it is an analytical detail that does not add to the understanding of the FNH Specification.

Therefore, this information is not specified in the Bases.

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. 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.

4. 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.

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

6. ISTS LCO 3.2.2 Bases state "The limiting value of FNH is allowed to increase 0.3%

for every 1% RTP reduction in THERMAL POWER." This sentence is removed. The first sentence of the LCO Bases states "FNH shall be maintained within the limits of the relationship provided in the COLR." Part of the relationship specified in the COLR describes how the FNH limit changes as a function of power. Describing part N

of the FH limit relationship in the Bases is inconsistent and does not provide any value without the rest of the relationship contained in the COLR. Therefore, the sentence is removed.

7. The Bases have been changed to reflect changes made to the Specification.

8. Typographical/grammatical error corrected.

9. These changes have been made to be consistent with similar phrases in other parts of the ITS Bases.

10. The Bases are revised to reflect the CNP FNH limit. The Bases state that the N

measured value of FH must be increased by 1.04 to account for measurement uncertainty. At CNP, the FNH limit includes 1.04 adjustment for measurement uncertainty. Therefore, adjusting the measured value is not necessary.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 83 of 158

Attachment 1, Volume 7, Rev. 0, Page 84 of 158 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 84 of 158

Attachment 1, Volume 7, Rev. 0, Page 85 of 158 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 85 of 158

, Volume 7, Rev. 0, Page 86 of 158 ATTACHMENT 3 ITS 3.2.3, Axial Flux Difference , Volume 7, Rev. 0, Page 86 of 158

, Volume 7, Rev. 0, Page 87 of 158 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 0, Page 87 of 158

Attachment 1, Volume 7, Rev. 0, Page 88 of 158 ITS 3.2.3 A.1 ITS LCO 3.2.3.a A.2 Add proposed LCO 3.2.3.c A.3 15% A.2 LA.1 ACTION A L.1 ACTION B LA.1 LCO 3.2.3.b ACTION C Add proposed Condition C Note M.1 L.2 LCO 3.2.3 Note 4 A.3 Page 1 of 10 Attachment 1, Volume 7, Rev. 0, Page 88 of 158

Attachment 1, Volume 7, Rev. 0, Page 89 of 158 ITS 3.2.3 A.1 ITS A.4 SR 3.2.3.1 L.3 Page 2 of 10 Attachment 1, Volume 7, Rev. 0, Page 89 of 158

Attachment 1, Volume 7, Rev. 0, Page 90 of 158 ITS 3.2.3 A.1 ITS LCO 3.2.3 Note 1 LCO 3.2.3 Notes 2 and 3 LCO 3.2.3 Note 2 LCO 3.2.3 Note 3 SR 3.2.3.3 L.4 SR 3.2.3.2 A.5 L.4 Page 3 of 10 Attachment 1, Volume 7, Rev. 0, Page 90 of 158

Attachment 1, Volume 7, Rev. 0, Page 91 of 158 ITS 3.2.3 A.1 ITS Page 4 of 10 Attachment 1, Volume 7, Rev. 0, Page 91 of 158

Attachment 1, Volume 7, Rev. 0, Page 92 of 158 ITS 3.2.3 A.1 ITS See ITS 3.2.1 SR 3.2.3.2, SR 3.2.3.3 once within 31 EFPD after each refueling thereafter L.4 See ITS 3.2.1 SR 3.2.3.3 Note Page 5 of 10 Attachment 1, Volume 7, Rev. 0, Page 92 of 158

Attachment 1, Volume 7, Rev. 0, Page 93 of 158 ITS 3.2.3 A.1 ITS LCO 3.2.3.a A.2 Add proposed LCO 3.2.3.c A.3 15 A.2 LA.1 ACTION A L.1 ACTION B LA.1 LCO 3.2.3.b ACTION C Add proposed Condition C Note M.1 L.2 LCO 3.2.3 Note 4 A.3 Page 6 of 10 Attachment 1, Volume 7, Rev. 0, Page 93 of 158

Attachment 1, Volume 7, Rev. 0, Page 94 of 158 ITS 3.2.3 A.1 ITS A.4 SR 3.2.3.1 L.3 Page 7 of 10 Attachment 1, Volume 7, Rev. 0, Page 94 of 158

Attachment 1, Volume 7, Rev. 0, Page 95 of 158 ITS 3.2.3 A.1 ITS LCO 3.2.3 Note 1 LCO 3.2.3 Notes 2 and 3 LCO 3.2.3 Note 2 LCO 3.2.3 Note 3 SR 3.2.3.3 L.4 SR 3.2.3.2 A.5 L.4 Page 8 of 10 Attachment 1, Volume 7, Rev. 0, Page 95 of 158

Attachment 1, Volume 7, Rev. 0, Page 96 of 158 ITS 3.2.3 A.1 ITS Page 9 of 10 Attachment 1, Volume 7, Rev. 0, Page 96 of 158

Attachment 1, Volume 7, Rev. 0, Page 97 of 158 ITS 3.2.3 A.1 ITS See ITS 3.2.1 SR 3.2.3.2, SR 3.2.3.3 Once within 31 EFPD after each refueling thereafter L.4 See ITS 3.2.1 SR 3.2.3.3 Note Page 10 of 10 Attachment 1, Volume 7, Rev. 0, Page 97 of 158

Attachment 1, Volume 7, Rev. 0, Page 98 of 158 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

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 CTS 3.2.1 Applicability is MODE 1 above 50% RATED THERMAL POWER.

However, CTS 4.2.1.2.b provides a penalty deviation for operation outside of the target band at THERMAL POWER levels between 15% RTP and 50% RTP. The ITS 3.2.3 Applicability is MODE 1 with THERMAL POWER > 15% RTP, and ITS LCO 3.2.3.c states that the AFD may deviate outside the target band with THERMAL POWER < 50% RTP. This changes the CTS by clearly stating that the AFD limit is Applicable between 15% RTP and 50% RTP, but that there is no maximum time limit it can be outside the limit; only the time has to be tracked (so that it can be used for the LCO 3.2.3.b limit).

The purpose of tracking the time limit as required by CTS 4.2.1.2.b is to ensure that power is not increased above 50% RTP if the AFD has been outside its target band longer than allowed in the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS continues to track this time, but properly displays the requirements in the format consistent with other ITS requirements. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.3 The Applicability of CTS 3.2.1 is modified by a footnote

stating "See Special Test Exception 3.10.2." ITS 3.2.3 Applicability does not contain the footnote or a reference to the Special Test Exception.

The purpose of the CTS 3.2.1 footnote

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

A.4 CTS 3.2.1 Action b states "THERMAL POWER shall not be increased above 90% or 0.9 x APL (whichever is less) of RATED THERMAL POWER unless the indicated AFD is within the target band and ACTION 2.a)1), above has been satisfied." CTS 3.2.1 Action c states "THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD has not been outside of the target band for more than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months penalty deviation cumulative during the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." ITS 3.2.3 does not contain similar requirements. This changes the CTS by eliminating prohibitions contained in the CTS.

This change is acceptable because the requirements have not changed.

CTS 3.0.4 and ITS LCO 3.0.4 prohibit entering the MODE of Applicability of a CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 7, Rev. 0, Page 98 of 158

Attachment 1, Volume 7, Rev. 0, Page 99 of 158 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Technical Specification unless the requirements of the LCO are met. CTS 3.2.1 and ITS 3.2.3 are applicable in MODE 1 with THERMAL POWER > 50% RTP (CTS) and > 15% RTP (ITS). Therefore, both the CTS and ITS prohibit exceeding 50% RTP without the LCO requirements being met. CTS 3.2.1 Actions b and c are duplicative of CTS 3.0.4 and ITS LCO 3.0.4, and their elimination does not make a technical change to the Specification. This change is designated as an administrative change because it does not result in a technical change to the CTS.

A.5 CTS 4.2.1.4 states that the allowable values of the target band are specified in the COLR. The ITS does not include this statement in ITS SR 3.2.3.2. This change deletes the statement from the CTS Surveillance concerning where the target band limits are located.

The CTS 4.2.1.4 statement identifies the location of the target band limit.

However, this statement is duplicative of ITS LCO 3.2.1, which already identifies the location of the target band limit (the COLR). Therefore, the deletion of the duplicative and redundant statement from the Surveillance Requirement is acceptable, since it remains in the LCO statement (CTS 3.2.1 and ITS LCO 3.2.3). This change is designated as an administrative change since it does not result in any technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.2.1 Action a.2.a)2) requires THERMAL POWER to be reduced to

< 50% RTP within 30 minutes if the AFD limits are not met when between 50% RTP and 90% RTP or 0.9 of APL (whichever is less). However, if the AFD limits are met during the 30 minute time limit, the CTS does not require continuation of the power reduction (as allowed by CTS 3.0.2). ITS 3.2.3 ACTION C (as stated in the Note to Condition C) requires completion of the power reduction to < 50% RTP, even if the AFD is restored to within limits prior to the expiration of the 30 minute time limit. The CTS is changed by now requiring power to be reduced to < 50% RTP when the Action is entered, even if the AFD is restored to within limits prior to expiration of the 30 minute time limit.

The purpose of the CTS Action is to restore compliance with the LCO. Since unanalyzed xenon axial distributions could result from a different pattern of xenon buildup and decay when > 50% RTP, power must be reduced to below 50% RTP. Completion of the power reduction is required to ensure that the reactor is at a THERMAL POWER level at which AFD is not a significant accident analysis parameter. This change is designated as more restrictive because it imposes a requirement in addition to those in the CTS.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 7, Rev. 0, Page 99 of 158

Attachment 1, Volume 7, Rev. 0, Page 100 of 158 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

REMOVED DETAIL CHANGES LA.1 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.2.1 Actions a.1, a.1.b), and a.2 specify Actions to be taken based upon 90% or 0.9 of Allowable Power Level (APL) (whichever is less) RTP. In ITS LCO 3.2.3.b and ACTIONS A, B, and C, the power level point is defined as "upper limit specified in the COLR." This changes the CTS by relocating the specific power level (with the CTS term APL changed to the appropriate term as described in ITS 3.2.1 DOC A.4) to the COLR.

The purpose of the APL value in this Specification is to ensure that if APL is more limiting than THERMAL POWER, then the THERMAL POWER will be reduced to the APL limit. CTS 3.2.1 specifies that the AFD limits are provided in the COLR.

The 90% RTP limit is the normal upper limit of the AFD curve, as is shown in the typical AFD curve provided in NUREG-1431, Rev. 2, Bases Figure B 3.2.3A-1.

Thus, the 90% RTP limit is already provided in the COLR. In addition, if the FQw(Z) limit is not met, the CNP AFD curve in the COLR already reflects the adjustment (since the y-axis is based on % RTP or 0.9 of APL RTP, whichever is less). The removal of this power level point from the Technical Specifications and the relocation into the COLR is acceptable because this power level point is developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, Removal of Cycle-Specific Parameter Limits From the Technical Specifications, 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 requirements that ensure the proper power level is utilized in the determination of penalty deviation time and the proper power level to which THERMAL POWER must be reduced.

In addition, the actual AFD curve from which the power level is determined is already located in the COLR. Moving the power level point (90% or 0.9 of APL (whichever is less)) RTP does not change the requirements. 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 transient analysis limits and accident analysis limits) of the safety analysis 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.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.2.1 Action a.1 provides two options if the AFD is outside the target band and THERMAL POWER is above 90% or 0.9 of APL (whichever is less) RTP: a) to restore the AFD to within limits in 15 minutes; or b) to reduce THERMAL POWER to less than the upper limit specified in the COLR in 15 minutes. Under the same conditions, ITS 3.2.3 ACTION A maintains the 15 minute time limit for the restoration of AFD to within limits, but ITS 3.2.3 ACTION B provides 30 minutes to reduce the THERMAL CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 7, Rev. 0, Page 100 of 158

Attachment 1, Volume 7, Rev. 0, Page 101 of 158 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

POWER to < 90% RTP. This changes the CTS by allowing an additional 15 minutes to reduce power.

The purpose of CTS 3.2.1 Action a.1 is to restore AFD to within the limits of the LCO. The revised Completion Time allows reactor power to be reduced in a controlled manner without challenging operators or plant systems. It also prioritizes the CTS actions, such that restoring AFD to within the limits should be the first attempted action, followed by (if the first action is not successful) a reduction in THERMAL POWER. The change is acceptable since actions are still provided to reduce power, and only a short time extension (15 minutes) is allowed. In addition, the ITS still provides an action to restore the AFD to within limits in the same time as is currently allowed. This change is designated as less restrictive because additional time is allowed to reduce power than was allowed in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.2.1 Action a.2.a)2) states that when AFD is not within its limit between 50% RTP and 90% or 0.9 of APL (whichever is less) RTP, reduce THERMAL POWER to less than 50% RTP within 30 minutes and reduce the Power Range Neutron Flux - High Trip Setpoints to < 55% of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Under the same conditions, ITS 3.2.3 Required Action C.1 only requires THERMAL POWER to be reduced to less than 50% RTP within 30 minutes when AFD is outside of its limit. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux - High Trip Setpoints to < 55% of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The purpose of CTS 3.2.1 Action a.2.a)2) is to reduce THERMAL POWER to the point at which the LCO is met if AFD is not restored within its limit. 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. With the AFD meeting the Technical Specification requirements, further actions are not required to ensure that the assumptions of the safety analyses are met.

Increases in THERMAL POWER are governed by ITS LCO 3.0.4, which requires the LCO to be met prior to entering a MODE or other specified condition in which the LCO applies. Therefore, power increases are prohibited while avoiding the risk of changing Reactor Trip System setpoints during operation. 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 4.2.1.1 requires the indicated AFD for each OPERABLE excore channel to be determined to be within its limits once per 7 days when the AFD Monitor Alarm is OPERABLE, at least once per hour for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after restoring the AFD Monitor Alarm to OPERABLE status if the AFD has been outside the target band in the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and once per hour for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and once per 30 minutes thereafter when the AFD Monitor Alarm is CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 7, Rev. 0, Page 101 of 158

Attachment 1, Volume 7, Rev. 0, Page 102 of 158 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD) inoperable. ITS SR 3.2.3.1 requires AFD to be verified within its limits for each OPERABLE excore channel every 7 days. This changes the CTS by eliminating all AFD Surveillance Frequencies based on the OPERABILITY of the AFD Monitor Alarm.

The purpose of ITS 3.2.3 is to ensure that AFD is within its limit. This change is acceptable because the remaining Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of monitoring AFD when the AFD Monitor Alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that AFD is outside its limit. The AFD 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.4 (Category 7 - Relaxation of Surveillance Frequency, Non-24 Month Type Change) CTS 4.2.1.3 and CTS 4.2.1.4 require two AFD Surveillances to be performed at the same Frequency as the Allowable Power Level Surveillances in CTS 4.2.6.2. In addition, CTS 4.2.1.3 and CTS 4.2.1.4 state that the provisions of Specification 4.0.4 are not applicable. The CTS 4.2.6.2 Frequency is the first Frequency that occurs of the following: a) upon achieving equilibrium conditions after exceeding 10% or more of RTP, the THERMAL POWER at which the Allowable Power Level was last determined; or b) at least once per 31 EFPD.

ITS SR 3.2.3.2 and SR 3.2.3.3 Frequencies for the same Surveillances are: a) once within 31 EFPD after each refueling; and b) 31 EFPD thereafter. The Frequencies of the CTS are changed to be 31 EFPD after a refueling and every 31 EFPD thereafter, and the Specification 4.0.4 allowance is deleted.

The purpose of CTS 4.2.1.3 and CTS 4.2.1.4 is to determine that the AFD is within limits. The change is acceptable due to the slow rate of change of the AFD, and the fact that in most cases during steady state operation, the 31 EFPD Frequency in the CTS will be the more limiting of the two CTS Frequencies. In addition, since the first ITS Frequency is based on being required at a given point (once with 31 EFPD after each refueling), the Specification 4.0.4 allowance is not necessary as entering MODE 1 is allowed in accordance with ITS SR 3.0.4. This change is designated as less restrictive because Surveillances could be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 7, Rev. 0, Page 102 of 158

Attachment 1, Volume 7, Rev. 0, Page 103 of 158 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 103 of 158

, Volume 7, Rev. 0, Page 104 of 158 , Volume 7, Rev. 0, Page 104 of 158

Attachment 1, Volume 7, Rev. 0, Page 105 of 158 3.2.3 6 INSERT 1 less than the upper limit specified in the COLR Insert Page 3.2.3A-1 Attachment 1, Volume 7, Rev. 0, Page 105 of 158

, Volume 7, Rev. 0, Page 106 of 158 , Volume 7, Rev. 0, Page 106 of 158

Attachment 1, Volume 7, Rev. 0, Page 107 of 158 3.2.3 6 INSERT 2 greater than or equal to the upper limit specified in the COLR 6 INSERT 3 less than the upper limit specified in the COLR Insert Page 3.2.3A-2 Attachment 1, Volume 7, Rev. 0, Page 107 of 158

, Volume 7, Rev. 0, Page 108 of 158 , Volume 7, Rev. 0, Page 108 of 158

, Volume 7, Rev. 0, Page 109 of 158 , Volume 7, Rev. 0, Page 109 of 158

Attachment 1, Volume 7, Rev. 0, Page 110 of 158 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 110 of 158

, Volume 7, Rev. 0, Page 111 of 158 , Volume 7, Rev. 0, Page 111 of 158

Attachment 1, Volume 7, Rev. 0, Page 112 of 158 B 3.2.3 1 INSERT 1 Constant Axial Offset Control 6 INSERT 1A greater than or equal to the upper limit specified in the COLR (normally 90% RTP) 6 INSERT 1B less than the upper limit specified in the COLR 2 INSERT 2 and at THERMAL POWER levels < 50% RTP but > 15% RTP, 2 INSERT 3 and > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , respectively, Insert Page B 3.2.3A-1 Attachment 1, Volume 7, Rev. 0, Page 112 of 158

, Volume 7, Rev. 0, Page 113 of 158 , Volume 7, Rev. 0, Page 113 of 158

, Volume 7, Rev. 0, Page 114 of 158 , Volume 7, Rev. 0, Page 114 of 158

Attachment 1, Volume 7, Rev. 0, Page 115 of 158 B 3.2.3 6 INSERT 3A greater than or equal to the upper limit specified in the COLR (normally 90% RTP) 6 INSERT 3B greater than or equal to the upper limit specified in the COLR Insert Page B 3.2.3A-3 Attachment 1, Volume 7, Rev. 0, Page 115 of 158

, Volume 7, Rev. 0, Page 116 of 158 , Volume 7, Rev. 0, Page 116 of 158

Attachment 1, Volume 7, Rev. 0, Page 117 of 158 B 3.2.3 6 INSERT 3C less than the upper limit specified in the COLR 6 INSERT 3D the upper limit specified in the COLR Insert Page B 3.2.3A-4 Attachment 1, Volume 7, Rev. 0, Page 117 of 158

, Volume 7, Rev. 0, Page 118 of 158 , Volume 7, Rev. 0, Page 118 of 158

Attachment 1, Volume 7, Rev. 0, Page 119 of 158 B 3.2.3 6 INSERT 3E greater than or equal to the upper limit specified in the COLR 6 INSERT 3F less than the upper limit specified in the COLR Insert Page B 3.2.3A-5 Attachment 1, Volume 7, Rev. 0, Page 119 of 158

, Volume 7, Rev. 0, Page 120 of 158 , Volume 7, Rev. 0, Page 120 of 158

, Volume 7, Rev. 0, Page 121 of 158 , Volume 7, Rev. 0, Page 121 of 158

, Volume 7, Rev. 0, Page 122 of 158 , Volume 7, Rev. 0, Page 122 of 158

, Volume 7, Rev. 0, Page 123 of 158 , Volume 7, Rev. 0, Page 123 of 158

, Volume 7, Rev. 0, Page 124 of 158 , Volume 7, Rev. 0, Page 124 of 158

Attachment 1, Volume 7, Rev. 0, Page 125 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL FLUX DIFFERENCE (AFD)

1. The methodology (CAOC) and the Specification designator "A" are deleted since they are unnecessary (only one AFD Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the RAOC methodology Specification Bases (ISTS B 3.2.3B) is not used and is not shown.

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 AFD target band and operation limits are specified in the COLR, the "typical" example is not needed in the Bases and has been deleted.

4. Typographical/grammatical error corrected.

5. The Frequency of the CHANNEL CALIBRATION is not necessary in these Bases, since the Bases for ITS SR 3.3.1.6 are sufficient.

6. Changes are made to reflect those changes made to the ITS.

7. This option has been deleted since it is not used at CNP.

8. 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.

9. This Bases statement, which adds an additional requirement above that required by the actual SR, has been deleted. The actual SR provides only a 7 day Frequency for verifying AFD. Any requirement for more frequent checks of AFD is more appropriately located in plant procedures, not the Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 125 of 158

Attachment 1, Volume 7, Rev. 0, Page 126 of 158 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 126 of 158

Attachment 1, Volume 7, Rev. 0, Page 127 of 158 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 127 of 158

, Volume 7, Rev. 0, Page 128 of 158 ATTACHMENT 4 ITS 3.2.4, Quadrant Power Tilt Ratio , Volume 7, Rev. 0, Page 128 of 158

, Volume 7, Rev. 0, Page 129 of 158 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 0, Page 129 of 158

Attachment 1, Volume 7, Rev. 0, Page 130 of 158 ITS 3.2.4 A.1 ITS LCO 3.2.4 A.2 ACTION A, ACTION B A.3 L.1 Add proposed Required Actions A.2, A.3, A.4, A.5, A.6, and L.2 ACTION B ACTION A, ACTION B 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months L.3 Add proposed Required Actions A.2, A.3, A.4, A.5, A.6, and L.2 ACTION B A.2 Page 1 of 6 Attachment 1, Volume 7, Rev. 0, Page 130 of 158

Attachment 1, Volume 7, Rev. 0, Page 131 of 158 ITS 3.2.4 A.1 ITS L.2 ACTION A, ACTION B Add proposed Required Actions A.1, A.2, A.3, A.4, A.5, L.2 A.6, and ACTION B Add proposed SR 3.2.4.1 Note 2 L.4 SR 3.2.4.1 L.5 SR 3.2.4.2 Page 2 of 6 Attachment 1, Volume 7, Rev. 0, Page 131 of 158

Attachment 1, Volume 7, Rev. 0, Page 132 of 158 ITS 3.2.4 A.1 ITS See ITS Chapter 1.0 SR 3.2.4.1 Note 1 and THERMAL POWER < 75% RTP A.4 See ITS Chapter 1.0 Page 3 of 6 Attachment 1, Volume 7, Rev. 0, Page 132 of 158

Attachment 1, Volume 7, Rev. 0, Page 133 of 158 ITS 3.2.4 A.1 ITS LCO 3.2.4 A.2 ACTION A, ACTION B A.3 L.1 Add proposed Required Actions A.2, L.2 A.3, A.4, A.5, A.6, and ACTION B ACTION A, ACTION B 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months L.3 Add proposed Required Actions A.2, A.3, A.4, A.5, A.6, and L.2 ACTION B A.2 Page 4 of 6 Attachment 1, Volume 7, Rev. 0, Page 133 of 158

Attachment 1, Volume 7, Rev. 0, Page 134 of 158 ITS 3.2.4 A.1 ITS L.2 ACTION A, ACTION B Add proposed Required Actions A.1, A.2, A.3, A.4, A.5, A.6, and L.2 ACTION B Add proposed SR 3.2.4.1 Note 2 L.4 SR 3.2.4.1 L.5 SR 3.2.4.2 Page 5 of 6 Attachment 1, Volume 7, Rev. 0, Page 134 of 158

Attachment 1, Volume 7, Rev. 0, Page 135 of 158 ITS 3.2.4 A.1 ITS See ITS Chapter 1.0 SR 3.2.4.1 Note 1 and THERMAL POWER < 75% RTP A.4 See ITS Chapter 1.0 Page 6 of 6 Attachment 1, Volume 7, Rev. 0, Page 135 of 158

Attachment 1, Volume 7, Rev. 0, Page 136 of 158 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

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 3.2.4 is modified by footnote

stating "See Special Test Exception 3.10.2." ITS 3.2.4 Applicability does not contain the footnote or a reference to the Special Test Exception.

The purpose of the CTS 3.2.4 footnote

reference is to alert the user that a Special Test Exception exists which 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 an administrative change since it does not result in technical changes to the CTS.

A.3 CTS 3.2.4 Action a.1.a) states that with QPTR > 1.02 and < 1.09, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reduce the QPTR to within its limit. ITS 3.2.4 does not contain a Required Action stating QPTR must be reduced to within its limit.

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 an administrative change since it does not result in technical changes to the CTS.

A.4 CTS 1.18, the definition of QPTR, states, in part, that "With one excore detector inoperable, the remaining three detectors shall be used for computing the average." ITS SR 3.2.4.1 Note 1, which incorporates the QPTR definition portion described above, states that when one Power Range Neutron Flux channel (i.e.,

an excore detector) is inoperable and THERMAL POWER is < 75% RTP, the remaining three Power Range Neutron Flux channels can be used for calculating QPTR. This changes the CTS by specifying the allowance can only be used when < 75% RTP.

The purpose of the CTS is to state when fewer than the normal complement of excore detectors can be used to determine QPTR. CTS 4.2.4.a requires the QPTR to be calculated once per 7 days. CTS 4.2.4.c requires the QPTR to be determined using the incore detectors every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when an excore detector is inoperable and THERMAL POWER is > 75% RTP. Thus, this effectively means that the one excore detector inoperable allowance can only be used when

< 75% RTP. When > 75% RTP with one excore detector inoperable, CTS 4.2.4.c must be performed to determine QPTR. Therefore, this change is designated as an administrative change and is acceptable since it does not result in a technical change to the CTS.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 7, Rev. 0, Page 136 of 158

Attachment 1, Volume 7, Rev. 0, Page 137 of 158 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.2.4 Action a.1.b) states that when QPTR is > 1.02 but < 1.09, reduce THERMAL POWER at least 3% from RTP for each 1% of indicated QPTR in excess of 1.0, and similarly reduce the Power Range Neutron Flux - High Trip Setpoints within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ITS 3.2.4 Required Action A.1 includes the requirement to reduce THERMAL POWER similar to the CTS, but does not include a requirement to reduce the Power Range Neutron Flux - High Trip Setpoints. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux - High Trip Setpoints.

The purpose of CTS 3.2.4 Action a.1.b) is to reduce THERMAL POWER to increase the margin to the core power distribution 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. With THERMAL POWER reduced by 3% from RTP for each 1% QPTR > 1.00, further actions are not required to ensure that THERMAL POWER is not increased. Power increases are administratively prohibited by the Technical Specifications while avoiding the risk of changing Reactor Trip System setpoints during operation.

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 3.2.4 Action a.2 states that with QPTR > 1.02 and < 1.09, verify that QPTR is within its limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or reduce THERMAL POWER to < 50% RTP within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the Power Range Neutron Flux - High Trip Setpoints to < 55% RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 3.2.4 Action b.2 states that when QPTR is > 1.09 due to misalignment of a RCCA, verify that QPTR is within its limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or reduce THERMAL POWER to < 50% RTP within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 7, Rev. 0, Page 137 of 158

Attachment 1, Volume 7, Rev. 0, Page 138 of 158 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Power Range Neutron Flux - High Trip Setpoints to < 55% RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 3.2.4 Action c.1 states that when QPTR is > 1.09 for reasons other than misalignment of a RCCA, reduce THERMAL POWER to < 50% RTP within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the Power Range Neutron Flux - High Trip Setpoints to < 55% RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 3.2.4 Actions a.3, b.3, and c.2 state that the cause of the out of limit QPTR must be identified and corrected prior to increasing THERMAL POWER, and that subsequent operation above 50% RTP may proceed provided that the QPTR is verified to be within its limit at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or until verified acceptable at 95% or greater RTP.

ITS 3.2.4, Required Action A.2 requires the QPTR to be determined within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , Required Action A.3 requires FQ(Z) and FNH to be verified to be within limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of achieving equilibrium conditions after the power reduction and every 7 days thereafter, Required Action A.4 requires the safety analyses to be reevaluated to confirm the results are still valid for the duration of operation under this condition prior to increasing power, Required Action A.5 requires (after completion of Required Action A.4) the excore detectors to be normalized to restore QPTR within limit prior to increasing power, and Required Action A.6 requires FQ(Z) and FNH to be verified to be within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium condition at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing power. In addition, for the condition of QPTR > 1.09 for reasons other than misalignment of a RCCA, ITS 3.2.4 Required Action A.1 requires THERMAL POWER to be reduced > 3% from RTP for each 1% of QPTR > 1.00, similar to the CTS Actions a.1.b) and b.1. Furthermore, ITS 3.2.4 ACTION B states that with a Required Action and associated Completion Time (of Condition A) not met, reduce THERMAL POWER to < 50% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This changes the CTS by eliminating requirements to be < 50% RTP within a specified time of exceeding the LCO and substituting compensatory measures in ITS ACTION A, which if not met, result in a reduction in power per ITS ACTION B.

The purpose of the CTS actions is to lower reactor power to less than 50% when QPTR is not within its limit and cannot be restored to within its limit within a reasonable time period. In addition, the Power Range Neutron Flux - High Trip Setpoints are reduced to < 55% to ensure that reactor power is not inadvertently increased without QPTR within its limit. This action is taken because with QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical core parameters such as FQ(Z) and FNH may not be within their limits. A QPTR not within limit may not be an unacceptable condition if the critical core parameters such as FQ(Z) and FNH are within their 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 or restore out of limit parameters. The Required Actions are consistent with safe operation under the specified Condition, considering the status of the redundant indications, the capacity and capability of remaining features, a reasonable time for repairs or restoration of required features, and the low probability of a DBA occurring during the repair period. The ITS requires measurement of FQ(Z) and FNH within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and every 7 days thereafter to verify that those parameters are within limit. In addition, the ITS requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, the ITS allows indefinite CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 7, Rev. 0, Page 138 of 158

Attachment 1, Volume 7, Rev. 0, Page 139 of 158 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR) operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures that the core is operated within the safety analyses. 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 3 - Relaxation of Completion Time) CTS 3.2.4 Action b.1, which applies when QPTR is > 1.09 due to misalignment of a RCCA, requires a THERMAL POWER reduction of 3% from RTP for every 1% QPTR exceeds 1.0 within 30 minutes. ITS 3.2.4 Required Action A.1 requires a THERMAL POWER reduction of 3% from RTP for every 1% QPTR exceeds 1.0 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by allowing 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform the required power reduction.

The purpose of CTS 3.2.4 is provide appropriate compensatory measures for QPTR greater than that assumed in the safety analyses. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering other indications available to the operator, a reasonable time for restoring compliance with the LCO, and the low probability of a DBA occurring during the restoration period. Under the ITS, a QPTR of 1.09 would require THERMAL POWER to be reduced to < 73% RTP. This will provide sufficient thermal margin to account for the radial power distribution. In addition, the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time limit is consistent with the CTS time allowed when QPTR is

> 1.02 but < 1.09. This change is designated as less restrictive because additional time is allowed to decrease power than was allowed in the CTS.

L.4 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.2.4.a states that QPTR shall be determined to be within the limit by calculating the ratio at least once per 7 days. ITS SR 3.2.4.1 Note 2 states that SR 3.2.4.2, which requires verification of QPTR using the movable incore detectors, may be performed in lieu of SR 3.2.4.1. This changes the CTS by allowing the movable incore detectors to be used to determine QPTR instead of the excore detectors.

The purpose of CTS 4.2.4.a is to periodically verify that QPTR is within limit.

This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are sufficient for verification that the parameters meet the LCO. The movable incore detector system provides a more accurate indication of QPTR than the excore detectors. In fact, the movable incore detector system is used to calibrate the excore detectors.

Therefore, allowing the use of the movable incore detector system or the excore detectors is appropriate. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.5 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.2.4.a requires the QPTR to be verified to be within limit every 7 days when the QPTR alarm is OPERABLE and CTS 4.2.4.b requires the verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the QPTR alarm is inoperable. ITS SR 3.2.4.1 requires verification that QPTR is within limit every 7 days. This changes the CTS by eliminating the requirement to verify QPTR more frequently when the QPTR alarm is inoperable.

CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 7, Rev. 0, Page 139 of 158

Attachment 1, Volume 7, Rev. 0, Page 140 of 158 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

The purpose of CTS 4.2.4.a and CTS 4.2.4.b is to periodically verify that QPTR is within limit. 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 QPTR verification when the QPTR alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that QPTR is outside its limit. The QPTR 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 5 of 5 Attachment 1, Volume 7, Rev. 0, Page 140 of 158

Attachment 1, Volume 7, Rev. 0, Page 141 of 158 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 7, Rev. 0, Page 145 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

1. TSTF-109, Rev. 0 was approved by the NRC on October 28, 1996. However, when NUREG-1431, Rev. 2 was issued, this TSTF was not completely incorporated. Therefore, this change approved by TSTF-109, Rev. 0 has been made.

2. TSTF-314, Rev. 0 was approved by the NRC on January, 11 1999. However, when NUREG-1431, Rev. 2 was issued, this TSTF was not completely incorporated. Therefore, this change approved by TSTF-314, Rev. 0 has been made.

3. Typographical/grammatical errors corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 145 of 158

Attachment 1, Volume 7, Rev. 0, Page 146 of 158 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 7, Rev. 0, Page 156 of 158 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT RATIO (QPTR)

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. 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. 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.

4. Editorial changes are made for consistency with the ITS. ITS 3.2.4 Required Action A.1 requires that THERMAL POWER be reduced "> 3% from RTP" for each 1% of QPTR > 1.00. The ISTS Bases state that power is reduced "3% RTP" for each 1% of QPTR > 1.00. The Bases are revised to be consistent with the Specification.

5. The peaking factor FQ(Z) is sufficient. There is no need to state how it is approximated.

6. Typographical/grammatical error corrected.

7. Changes added for clarity and to be consistent with the Specification.

8. These changes have been made to be consistent with similar phrases in other parts of the ITS Bases and to be consistent with the Specification.

9. The statement concerning why FNH and FQ(Z) limits must be maintained has been deleted, since it is duplicative of statements provided in the individual Bases for the two factors (ITS 3.2.2 and ITS 3.2.1). The Bases for QPTR is not appropriate for describing why other factors, covered by their own Technical Specifications, are required.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 156 of 158

Attachment 1, Volume 7, Rev. 0, Page 157 of 158 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 157 of 158

Attachment 1, Volume 7, Rev. 0, Page 158 of 158 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 158 of 158

ML041200360

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