Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 8, Rev 0, ITS Section 3.3 Instrumentation, Pages 1-426
	ML041200365
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP:NRC:4901
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Attachment 1, Volume 8, Rev. 0, Page 1 of 818 VOLUME 8 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.3 INSTRUMENTATION Revision 0 Attachment 1, Volume 8, Rev. 0, Page 1 of 818

Attachment 1, Volume 8, Rev. 0, Page 2 of 818 LIST OF ATTACHMENTS

1. ITS 3.3.1

2. ITS 3.3.2

3. ITS 3.3.3

4. ITS 3.3.4

5. ITS 3.3.5

6. ITS 3.3.6

7. ITS 3.3.7

8. ITS 3.3.8

9. Relocated/Deleted Current Technical Specifications (CTS)

10. Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 8, Rev. 0, Page 2 of 818

Attachment 1, Volume 8, Rev. 0, Page 3 of 818 ATTACHMENT 1 ITS 3.3.1, Reactor Trip System (RTS) Instrumentation Attachment 1, Volume 8, Rev. 0, Page 3 of 818

, Volume 8, Rev. 0, Page 4 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 8, Rev. 0, Page 4 of 818

Attachment 1, Volume 8, Rev. 0, Page 5 of 818 A.1 ITS 3.3.1 LCO 3.3.1 Add proposed ACTIONS Note A.2 ACTION A A.20 SR Table 92 days on a Note STAGGERED TEST BASIS M.8 SR 3.3.1.5 L.1 L.2 SR 3.3.1.13, SR 3.3.1.14, SR 3.3.1.16 24 24 L.3 SR 3.3.1.19 A.17 on a STAGGERED TEST BASIS A.4 SR 3.3.1.19 LA.1 Note Page 1 of 39 Attachment 1, Volume 8, Rev. 0, Page 5 of 818

, Volume 8, Rev. 0, Page 6 of 818 A.1 ITS 3.3.1 Page 2 of 39 , Volume 8, Rev. 0, Page 6 of 818

ITS LA.2 Table 3.3.1-1 REQUIRED A.5 A.7 4 Note a 1 B, P, Q L.5 2.a C, D 2.b A.6 3.a D A.7 A.6 3.b D L.5 4 E, F A.9 A.8 5

Note a G, I, Q A.1 6

D 7 4 See ITS D 3.3.8 A.6 LA.2 A.5 , Volume 8, Rev. 0, Page 7 of 818 Attachment 1, Volume 8, Rev. 0, Page 7 of 818 Page 3 of 39 ITS 3.3.1

Attachment 1, Volume 8, Rev. 0, Page 8 of 818 LA.2 A.5 A.10 A.6 A.5 A.6 A.1 A.5 ITS 3.3.1 A.6 D D D D D D D REQUIRED 3 3 2 4 3 LA.6 Table 3.3.1-1 Footnote (e) 8.a 8.b 9 10 10 14 15 ITS Page 4 of 39 Attachment 1, Volume 8, Rev. 0, Page 8 of 818

ITS LA.2 Table 3.3.1-1 A.5 REQUIRED 1 per bus A.5 12 D A.10 13 D A.6 3

A.5 A.6 16.a D A.10 D

16.b 17 J, P per train A.5 11 Footnote (e) A.1 D A.5 19, K, P M, P 20 B, Q 21 J, P B, Q , Volume 8, Rev. 0, Page 9 of 818 Attachment 1, Volume 8, Rev. 0, Page 9 of 818 A.12 Page 5 of 39 ITS 3.3.1

Attachment 1, Volume 8, Rev. 0, Page 10 of 818 A.1 ITS 3.3.1 ITS A.18 LA.3 Table 3.3.1-1 MODES 3, 4, and 5 or one or more rods M.1 not fully inserted Footnote (a)

A.6 A.9 Footnote (d)

LA.4 Add proposed Required Action J.1 ACTION J L.6 ACTION D ACTION J Note ACTIONS C and D L.6 Required Actions C.1 and D.1 4 ACTIONS C and D Note A.11 L.4 A.11 Add proposed ACTION P ACTION E M.4 Page 6 of 39 Attachment 1, Volume 8, Rev. 0, Page 10 of 818

Attachment 1, Volume 8, Rev. 0, Page 11 of 818 A.1 ITS 3.3.1 ITS Function 4 A.8 Applicability M.5 L.9 ACTION E Add proposed Required Actions E.1 and E.2 M.5 Add proposed ACTION F M.11 Add proposed Required Actions I.1, Q.1, M.2 ACTIONS G, I, Q Add proposed Required Action G.1 for MODE 2 below P-6 and Q.2 for MODES 3(a), 4(a), 5(a)

M.6 Add proposed ACTION H Function 5 Applicability See ITS 3.3.8 L.6 ACTION D 6

4 Add proposed ACTIONS N and P M.7 ACTION D L.7 6

Add proposed ACTIONS N and P M.7 Add proposed NOTE to ACTION D L.6 Page 7 of 39 Attachment 1, Volume 8, Rev. 0, Page 11 of 818

Attachment 1, Volume 8, Rev. 0, Page 12 of 818 A.1 ITS 3.3.1 ITS L.6 ACTION D 6

Add proposed ACTION O M.7 ACTION B ACTION P L.12 Add proposed Required Actions Q.1 and Q.2 ACTION Q ACTION M ACTION P M.9 ACTION B ACTION Q Add proposed Required Actions Q.1 and Q.2 L.13 ACTION K ACTION P ACTION K Note 1 per train Table 3.3.1-1 LA.5 Function 18.a Add proposed Applicability A.19 Add proposed ACTIONS L, P, and Q L.8 Page 8 of 39 Attachment 1, Volume 8, Rev. 0, Page 12 of 818

Attachment 1, Volume 8, Rev. 0, Page 13 of 818 A.1 ITS 3.3.1 ITS A.21 1 per train Table 3.3.1-1 LA.5 Functions 18.b, 18.d, 18.e Add proposed Applicability A.19 Table 3.3.1-1 Function 18.c Table 3.3.1-1 Function 18.d Add proposed Applicability A.19 Add proposed ACTIONS L, O, and P L.8 Page 9 of 39 Attachment 1, Volume 8, Rev. 0, Page 13 of 818

Attachment 1, Volume 8, Rev. 0, Page 14 of 818 A.1 ITS 3.3.1 ITS Page 10 of 39 Attachment 1, Volume 8, Rev. 0, Page 14 of 818

Attachment 1, Volume 8, Rev. 0, Page 15 of 818 A.1 ITS 3.3.1 ITS Page 11 of 39 Attachment 1, Volume 8, Rev. 0, Page 15 of 818

Attachment 1, Volume 8, Rev. 0, Page 16 of 818 A.1 ITS 3.3.1 ITS L.15 Table 3.3.1-1 A.20 L.14 LA.9 LA.9 SR 3.3.1.2, SR 3.3.1.3, SR 3.3.1.8, SR 3.3.1.10, 1 SR 3.3.1.1 SR 3.3.1.9, SR 3.3.1.13 SR 3.3.1.17 24 months SR 3.3.1.14, SR 3.3.1.15

-17

-17 L.16 2.a L.5

-1 2- -3 2.b 31 effective full power days -9 8 A.7 L.2 3.a -14 -8 M.12 24 months 3.b -14 -8 Add proposed SR 3.3.1.10 Note 1 L.5 A.8 L.2 184 days 4 -1 -14 -10 24 months L.16 M.15 5 -1 -14 10-184 days A.18 Add proposed SR 3.3.1.7 L.18 M.13

-1 -10 Add proposed Note 1 to 6 -15 SR 3.3.1.15 A.16 24 months 7 -1 -15 -10 8.a -1 -13 -10 L.2 8.b -1 -13 -10 24 months 9 -1 -13 -10 A.10 10 -1 -13 -10 M.15 L.2 A.22 LA.6 Page 12 of 39 Attachment 1, Volume 8, Rev. 0, Page 16 of 818

Attachment 1, Volume 8, Rev. 0, Page 17 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 A.20 SR 3.3.1.4, SR 3.3.1.5, SR 3.3.1.6, SR 3.3.1.10, SR 3.3.1.12, SR 3.3.1.11, SR 3.3.1.17, SR 3.3.1.18 SR 3.3.1.1 SR 3.3.1.13 LA.6 A.22 10 -1 -13 24 months L.2 14 -1 M.15 -13 -10 184 days L.18 15 -1 -13 -10 184 days Add proposed Note to SR 3.3.1.11 A.3 12 -12 -11 A.10 M.16 M.14 13 -13 -11 A.3 Add proposed SR 3.3.1.13 Add proposed Note to SR 3.3.1.18 L.10 16.a A.15

-18 16.b -18 A.10 17 17 6-24 months L.11 11 -17 A.12 19 LA.9 19, 20 4- L.16 LA.9 19, 20 4-L.16 21 -5 A.13 19 4-Footnote (g) 17-24 months LA.9 L.14 A.13 Page 13 of 39 Attachment 1, Volume 8, Rev. 0, Page 17 of 818

Attachment 1, Volume 8, Rev. 0, Page 18 of 818 A.1 ITS 3.3.1 ITS LA.3 or one or more rods M.1 not fully inserted Table 3.3.1-1 Footnote (a)

L.10 31 SR 3.3.1.18 L.16 SR 3.3.1.2 L.14 SR 3.3.1.3 L.11 SR 3.3.1.17 24 months SR 3.3.1.4 M.15 SR 3.3.1.9, SR 3.3.1.14 Table 3.3.1-1 Function 5 M.3 Applicability Footnote (d)

Note 2 for SR 3.3.1.2 and M.13 SR 3.3.1.3 A.14 SR 3.3.1.15 Note 2 M.10 LA.9 LA.9 SR 3.3.1.4 LA.9 L.17 SR 3.3.1.10 Note 2 M.15 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.10 M.12 Page 14 of 39 Attachment 1, Volume 8, Rev. 0, Page 18 of 818

Attachment 1, Volume 8, Rev. 0, Page 19 of 818 A.1 ITS 3.3.1 ITS LCO 3.3.1 Allowable Value LA.10 A.18 ACTION A Allowable Value LA.10 Page 15 of 39 Attachment 1, Volume 8, Rev. 0, Page 19 of 818

Attachment 1, Volume 8, Rev. 0, Page 20 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 LA.10 1

2.a, 2.b 3.a 3.b 4

5 M.17 6, including Note 1 7, including 1868 L.19 Note 2 8.a 2398 8.b LA.11 93.4 9

89.6 M.17 10 LA.11 LA.10 LA.11 Page 16 of 39 Attachment 1, Volume 8, Rev. 0, Page 20 of 818

Attachment 1, Volume 8, Rev. 0, Page 21 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 LA.10 4.0 L.19 14 LA.11 15 L.19 9.7 LA.11 12 58.22 M.17 13 16.a 16.b 17 11 Page 17 of 39 Attachment 1, Volume 8, Rev. 0, Page 21 of 818

Attachment 1, Volume 8, Rev. 0, Page 22 of 818 A.1 ITS 3.3.1 LA.8 LA.8 LA.8 LA.7 Table 3.3.1-1 ITS Note 1 Page 18 of 39 Attachment 1, Volume 8, Rev. 0, Page 22 of 818

Attachment 1, Volume 8, Rev. 0, Page 23 of 818 A.1 ITS 3.3.1 LA.8 LA.8 LA.8 Table 3.3.1-1 ITS Note 1 Page 19 of 39 Attachment 1, Volume 8, Rev. 0, Page 23 of 818

Attachment 1, Volume 8, Rev. 0, Page 24 of 818 ITS 3.3.1 A.1 L.19 LA.8 LA.8 LA.8 LA.7 0.008

.008 0.037 Table 3.3.1-1 Table 3.3.1-1 Table 3.3.1-1 ITS Note 2 Note 1 Note 2 Page 20 of 39 Attachment 1, Volume 8, Rev. 0, Page 24 of 818

Attachment 1, Volume 8, Rev. 0, Page 25 of 818 ITS 3.3.1 A.1 LCO 3.3.1 Add proposed ACTIONS Note A.2 ACTION A A.20 SR Table 92 days on a Note STAGGERED TEST BASIS M.8 SR 3.3.1.5 L.1 L.2 SR 3.3.1.13, SR 3.3.1.14, SR 3.3.1.16 24 24 L.3 SR 3.3.1.19 A.17 on a STAGGERED TEST BASIS A.4 SR 3.3.1.19 LA.1 Note Page 21 of 39 Attachment 1, Volume 8, Rev. 0, Page 25 of 818

ITS LA.2 Table 3.3.1-1 REQUIRED A.5 A.7 Note a B, P, Q L.5 4

1 2.a C, D 2.b D A.6 3.a A.7 3.b D A.6 E, F 4 L.5 A.9 5 Note a A.8 G, I, Q A.1 See ITS 3.3.8 6 D 4

7 D A.6 LA.2 A.5 , Volume 8, Rev. 0, Page 26 of 818 Attachment 1, Volume 8, Rev. 0, Page 26 of 818 Page 22 of 39 ITS 3.3.1

Attachment 1, Volume 8, Rev. 0, Page 27 of 818 ITS 3.3.1 A.1 LA.2 A.5 A.10 A.6 A.5 A.6 A.5 A.6 D D D D D D D REQUIRED 3 3 2 4 3 LA.6 Table 3.3.1-1 Footnote (e) 8.a 8.b 9 10 10 14 15 ITS Page 23 of 39 Attachment 1, Volume 8, Rev. 0, Page 27 of 818

Attachment 1, Volume 8, Rev. 0, Page 28 of 818 ITS 3.3.1 A.1 ITS LA.2 Table 3.3.1-1 REQUIRED A.5 1 per bus A.6 12 D A.10 13 D A.6 3 D A.10 16.a 4

16.b per D A.6 train 17 J, P A.5 11 Footnote (e) D A.5 19, M, P K, P 20 B, Q 21 J, P B, Q A.12 Page 24 of 39 Attachment 1, Volume 8, Rev. 0, Page 28 of 818

Attachment 1, Volume 8, Rev. 0, Page 29 of 818 ITS 3.3.1 A.1 ITS A.18 Table 3.3.1-1 LA.3 MODES 3, 4, and 5 or one or more rods M.1 not fully inserted Footnote (a)

A.6 A.9 Footnote (d)

LA.4 Add proposed Required Action J.1 L.6 ACTION J ACTION P ACTION J Note ACTIONS C L.6 and D Required Actions C.1 and D.1 4 ACTIONS C and D Note A.11 L.4 A.11 Add proposed ACTION P ACTION E M.4 Page 25 of 39 Attachment 1, Volume 8, Rev. 0, Page 29 of 818

Attachment 1, Volume 8, Rev. 0, Page 30 of 818 ITS 3.3.1 A.1 ITS A.8 Function 4 Add proposed Required Applicability Actions E.1 and E.2 ACTION E L.9 M.5 M.11 Add proposed ACTION F Add proposed Required Actions I.1, Q.1 M.2 ACTIONS G, I, Q Add proposed Required Action G.1 for MODE 2 below P-6 and Q.2 for MODES 3(a), 4(a), 5(a)

Function 5 Add proposed ACTION H M.6 Applicability See ITS 3.3.8 L.6 ACTION D 6

4 M.7 Add proposed ACTIONS N and P ACTION D L.7 6

Add proposed ACTIONS N and P M.7 Add proposed Note to ACTION D L.6 Page 26 of 39 Attachment 1, Volume 8, Rev. 0, Page 30 of 818

Attachment 1, Volume 8, Rev. 0, Page 31 of 818 ITS 3.3.1 A.1 ITS L.6 6

ACTION D M.7 Add proposed ACTION O ACTION B ACTION P L.12 ACTION Q Add proposed Required Actions Q.1 and Q.2 ACTION M ACTION P M.9 ACTION B ACTION Q Add proposed Required Actions Q.1 and Q.2 L.13 ACTION K ACTION P ACTION K Note 1 per train Table 3.3.1-1 Function 18.a LA.5 Add proposed Applicability A.19 Add proposed ACTIONS L, P, and Q L.8 Page 27 of 39 Attachment 1, Volume 8, Rev. 0, Page 31 of 818

Attachment 1, Volume 8, Rev. 0, Page 32 of 818 ITS 3.3.1 A.1 ITS A.21 1 per train Table 3.3.1-1 Functions 18.b, 18.d, 18.e Add proposed Applicability LA.5 A.19 Table 3.3.1-1 Function 18.c Table 3.3.1-1 Function 18.d Add proposed Applicability A.19 Add proposed ACTIONS L, O, and P L.8 Page 28 of 39 Attachment 1, Volume 8, Rev. 0, Page 32 of 818

Attachment 1, Volume 8, Rev. 0, Page 33 of 818 ITS 3.3.1 A.1 ITS Page 29 of 39 Attachment 1, Volume 8, Rev. 0, Page 33 of 818

Attachment 1, Volume 8, Rev. 0, Page 34 of 818 ITS 3.3.1 A.1 ITS Page 30 of 39 Attachment 1, Volume 8, Rev. 0, Page 34 of 818

L.15 ITS SR 3.3.1.2, SR 3.3.1.3, SR 3.3.1.9, SR 3.3.1.13, SR 3.3.1.14, SR 3.3.1.15 Table 3.3.1-1 SR 3.3.1.8, SR 3.3.1.10, SR 3.3.1.17 A.20 L.14 SR 3.3.1.1 LA.9 LA.9 24 months 1

-17 31effective full power 8 -17 L.5 2.a, days

-1 2- -3 2.b -9 Add proposed SR 3.3.1.10 Note 1 A.7 3.a -14 -8 L.16 3.b -14 -8 184 days

-1 -10 M.12 4 -14 10 Add L.5 M.13 5 proposed -1 -14 A.1 SR 3.3.1.7 A.8 6 -1 -15 -10

-10 L.16 7 -1 -15 184 days A.18 8.a -1 -13 -10 8.b -1 -13 -10 L.18

-1 -13 M.15 -10 M.15 9

10 -1 -13 -10 A.10 Add proposed Note 1 to A.22 SR 3.3.1.15 A.16 24 months LA.6 L.2 , Volume 8, Rev. 0, Page 35 of 818 Attachment 1, Volume 8, Rev. 0, Page 35 of 818 Page 31 of 39 ITS 3.3.1

ITS SR 3.3.1.4, SR 3.3.1.5, SR 3.3.1.6, Table 3.3.1-1 SR 3.3.1.10, SR 3.3.1.11, SR 3.3.1.17, SR 3.3.1.18 A.20 LA.6 SR 3.3.1.12, SR 3.3.1.1 SR 3.3.1.13 A.22 10 -1 -13 184 days 14 M.15 -10

-1 -13 L.18 15 -1 -13 -10 Add proposed Note to 184 days A.3 SR 3.3.1.11 12 -12 -11 M.16 13 -13 -11 A.10 Add proposed SR 3.3.1.13 Add proposed Note to SR 3.3.1.18 M.14 16.a -18 A.3 A.15 16.b -18 17 6- -17 A.10 L.10 11 24 months 24 months -17 A.1 19 L.11 19, 20 4-A.12 LA.9 19, 20 4-L.16 A.13 21 -5 19 A.13 4-LA.9 Footnote (g) 17-24 months L.14 , Volume 8, Rev. 0, Page 36 of 818 Attachment 1, Volume 8, Rev. 0, Page 36 of 818 L.2 Page 32 of 39 ITS 3.3.1

Attachment 1, Volume 8, Rev. 0, Page 37 of 818 A.1 ITS 3.3.1 ITS LA.3 or one or more rods M.1 not fully inserted Table 3.3.1-1 Footnote (a)

L.10 31 SR 3.3.1.18 L.16 L.14 SR 3.3.1.2 SR 3.3.1.3 L.11 SR 3.3.1.17 24 months SR 3.3.1.4 M.15 SR 3.3.1.9, SR 3.3.1.14 Table 3.3.1-1 Function 5 M.3 Applicability Footnote (d)

Note 2 for SR 3.3.1.2 and M.13 SR 3.3.1.3 A.14 SR 3.3.1.15 Note 2 M.10 LA.9 LA.9 SR 3.3.1.4 LA.9 SR 3.3.1.10 Note 2 L.17 M.15 SR 3.3.1.5, SR 3.3.1.6 SR 3.3.1.10 M.12 Page 33 of 39 Attachment 1, Volume 8, Rev. 0, Page 37 of 818

Attachment 1, Volume 8, Rev. 0, Page 38 of 818 A.1 ITS 3.3.1 ITS LCO 3.3.1 Allowable Value LA.10 ACTION A Allowable Value LA.10 Page 34 of 39 Attachment 1, Volume 8, Rev. 0, Page 38 of 818

Attachment 1, Volume 8, Rev. 0, Page 39 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 LA.10 1

2.a, 2.b 3.a 3.b 4

5 6, including Note 1 7, including Note 2 8.a L.19 1930 8.b LA.11 93.3 2406 9

M.17 89.6 10 LA.11 LA.10 LA.11 Page 35 of 39 Attachment 1, Volume 8, Rev. 0, Page 39 of 818

Attachment 1, Volume 8, Rev. 0, Page 40 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 LA.10 20.8 M.17 14 LA.11 15 LA.11 25.0 M.17 12 13 57.02 L.19 16.a 16.b 17 11 Page 36 of 39 Attachment 1, Volume 8, Rev. 0, Page 40 of 818

Attachment 1, Volume 8, Rev. 0, Page 41 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 Note 1 LA.8 LA.7 LA.8 Page 37 of 39 Attachment 1, Volume 8, Rev. 0, Page 41 of 818

Attachment 1, Volume 8, Rev. 0, Page 42 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 Note 1 LA.8 LA.8 LA.8 LA.8 Page 38 of 39 Attachment 1, Volume 8, Rev. 0, Page 42 of 818

Attachment 1, Volume 8, Rev. 0, Page 43 of 818 A.1 ITS 3.3.1 ITS Table 3.3.1-1 Note 2 LA.8 LA.8 LA.7 LA.8 Table 3.3.1-1 Note 2 0.012 L.19 Table 3.3.1-1 Note 2 0.038 M.17 Page 39 of 39 Attachment 1, Volume 8, Rev. 0, Page 43 of 818

Attachment 1, Volume 8, Rev. 0, Page 44 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION 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 3.3.1.1 Action and CTS Table 3.3-1 provide the compensatory actions to take when RTS instrumentation is inoperable. ITS 3.3.1 ACTIONS provide the compensatory actions for inoperable RTS Instrumentation. The ITS 3.3.1 ACTIONS includes a Note that allows separate Condition entry for each Function. In addition, separate Condition entry is allowed within a Function as follows: (a) for Function 10 (Reactor Coolant Flow - Low) on a loop basis; and (b) for Function 14 (Steam Generator (SG) Water Level - Low Low) and Function 15 (SG Water Level Low Coincident with Steam Flow/Feedwater Flow Mismatch) on a steam generator basis. This modifies the CTS by providing a specific allowance to enter the Action for each inoperable RTS instrumentation Function and for certain Functions on a loop or steam generator basis.

This change is acceptable because it clearly states the current requirement. The CTS considers each RTS instrumentation Function to be separate and independent from the others. In addition, the channels associated with Functions 10, 14, and 15 are allowed separate Condition entry on the specified basis (i.e., loop or SG) since the channels associated with each loop or steam generator, as applicable, will provide the associated RTS trip based on the logic associated with the channels on the specified basis. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS Table 4.3-1 requires a CHANNEL FUNCTIONAL TEST be performed for the Functional Units 16 (Undervoltage - Reactor Coolant Pumps) and 17 (Underfrequency - Reactor Coolant Pumps) channels. CTS Table 4.3-1 requires a CHANNEL FUNCTIONAL TEST be performed for the Functional Units 18.A (Turbine Trip - Low Fluid Oil Pressure) and 18.B (Turbine Trip - Turbine Stop Valve Closure) channels. ITS Table 3.3.1-1, for Functions 12 and 13, requires performance of SR 3.3.1.11, a TADOT, and for Functions 16.a and 16.b, requires performance of SR 3.3.1.18, a TADOT. However, the Surveillances are modified by a Note that states that a verification of the setpoint is not required. This changes the CTS by explicitly stating that setpoint verification is not part of the TADOT. The change from a CHANNEL FUNCTIONAL TEST to a TADOT is discussed in DOC A.20.

The CTS definition of CHANNEL FUNCTIONAL TEST does not require a setpoint verification. However, the ITS definition of TADOT does include a setpoint verification. Therefore, to be consistent with the current requirements and with current practice, the Note has been added. Since a setpoint verification is not currently required during performance of this test, this change is CNP Units 1 and 2 Page 1 of 45 Attachment 1, Volume 8, Rev. 0, Page 44 of 818

Attachment 1, Volume 8, Rev. 0, Page 45 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION acceptable. This change is designated as administrative because it does not result in a technical change to the CTS.

A.4 CTS 4.3.1.1.3 states, in part, that the RTS RESPONSE TIME of each trip function shall be demonstrated to be within its limit at least once per 18 months.

The requirement specifies that each test shall include at least one logic train such that both logic trains are tested at least once per 36 months, and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-1.

ITS SR 3.3.1.19 requires the verification of RTS RESPONSE TIME every 24 months "on a STAGGERED TEST BASIS." The ITS definition of STAGGERED TEST BASIS is consistent with the CTS testing Frequency. This changes the CTS by utilizing the ITS definition of STAGGERED TEST BASIS.

The extension in the Surveillance Frequency from 18 months to 24 months is discussed in DOC L.4.

This change is acceptable because the requirements for RESPONSE TIME testing for the RTS channels remain unchanged. The ITS definition of STAGGERED TEST BASIS and its application in this requirement do not change the current testing frequency requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS Table 3.3-1 specifies the "TOTAL NO. OF CHANNELS" and the "MINIMUM CHANNELS OPERABLE" associated with each RTS Functional Unit. For CTS Table 3.3-1 Functional Units 2, 3, 4, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18.A, and for Unit 2 only, 18.B, the number of channels listed in the "TOTAL NO. OF CHANNELS" column is greater than that listed in the "MINIMUM OPERABLE CHANNELS" column. CTS Table 3.3-1 Actions 2, 6, and 7 specify the actions to take with the number of channels OPERABLE one less than required by the "TOTAL NO. OF CHANNELS" column. CTS Table 3.3-1 Actions 1, 3, 4, 11, 12, 14, and 15 specify the actions to take with the number of channels OPERABLE, one less than required by the "MINIMUM CHANNELS OPERABLE" column.

ITS LCO 3.3.1 requires the RTS instrumentation for each Function in ITS Table 3.3.1-1 to be OPERABLE, and includes only one column titled REQUIRED CHANNELS. For the associated ITS Table 3.3.1-1 Functions, the number of channels listed in the "REQUIRED CHANNELS" column is equal to the number of channels listed in the CTS "TOTAL NO. OF CHANNELS" column.

The ITS 3.3.1 ACTIONS require entry when the OPERABLE channels are one less than required by the "REQUIRED CHANNELS" column. For CTS Table 3.3-1 Functional Units 12, 13, 14, and 20, the description in the "CHANNELS TO TRIP" (Functional Units 12, 13, and 14 only) and "MINIMUM CHANNELS OPERABLE" columns includes the phrase "in each operating loop."

This description is not included in ITS Table 3.3.1-1 Functions 10, 11, and 14. In addition, CTS Table 3.3-1 Functional Unit 18.B (Turbine Stop Valve Closure) specifies there are 4 channels in the "TOTAL NO. OF CHANNELS" column while the "MINIMUM CHANNELS OPERABLE" column specifies "4" for Unit 1 and "3" for Unit 2. ITS Table 3.3.1-1 Function 16.b specifies 4 channels "per train" in the "REQUIRED CHANNELS" column. This changes the CTS by changing the title of the "MINIMUM CHANNELS OPERABLE" column to "REQUIRED CHANNELS," and increases the number of channels listed to match the number CNP Units 1 and 2 Page 2 of 45 Attachment 1, Volume 8, Rev. 0, Page 45 of 818

Attachment 1, Volume 8, Rev. 0, Page 46 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION listed in the "TOTAL NO. OF CHANNELS" column. It also changes the CTS by deleting the description "in each operating loop" and adding the words "per train."

This change is acceptable because the requirements for when actions must be taken remain unchanged. The "REQUIRED CHANNELS" column reflects the current requirements in the CTS Actions for when actions are required to be taken. The "MINIMUM CHANNELS OPERABLE" column for CTS Table 3.3-1 Functional Units 2, 3, 4, 7 through 17, and 18.A have changed to correspond to the number of channels in the "TOTAL NO. OF CHANNELS" column as reflected in ITS Table 3.3.1-1 Functions 2.a, 2.b, 3.a, 3.b, 6, 7, 8.a, 8.b, 9, 10.a, 10.b, 12, 13, 14, 15, and 16.a. For CTS Table 3.3-1 Functional Units 12, 13, 14, and 20, the description "in each operating loop" is not necessary since all loops are required to be operating in MODE 1. For Unit 1 CTS Table 3.3-1 Functional Unit 18.B, there are two contacts per turbine stop valve limit switch, with both contacts required to be OPERABLE, and for Unit 2 CTS Table 3.3-1 Functional Unit 18.B, there are two limit switches per turbine stop valve, with both limit switches required to be OPERABLE. In the ITS, each Unit 1 contact and each Unit 2 limit switch is considered a channel. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS Table 3.3-1 Note # states that the provisions of CTS 3.0.4 are not applicable. CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted." ITS 3.3.1 does not contain the exception to ITS LCO 3.0.4, since ITS LCO 3.0.4 states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability may be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This changes the CTS by deleting an allowance since it is incorporated into ITS LCO 3.0.4.

This change is considered acceptable because ITS LCO 3.0.4 has been changed such that the CTS allowance is not required to retain the same CTS requirement.

The applicable ITS 3.3.1 ACTIONS allows continued operation for an unlimited period of time, which together with ITS LCO 3.0.4, result in the same technical requirements as the CTS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.7 CTS Table 3.3-1 Functional Unit 2 requires the Power Range Neutron Flux channels to be OPERABLE in MODES 1 and 2. CTS Table 3.3-1 specifies that the P-10 interlock prevents or defeats the manual block of the Power Range Neutron Flux Low setpoint reactor trip. CTS Table 4.3-1 Functional Unit 2 specifies the Surveillance Requirements for the Power Range Neutron Flux channels in MODES 1 and 2. ITS Table 3.3.1-1 Function 2.a requires the Power Range Neutron Flux - High channels to be OPERABLE in MODES 1 and 2 and ITS Table 3.3.1-1 Function 2.b requires the Power Range Neutron Flux - Low channels to be OPERABLE in MODE 1 below the P-10 interlock (as indicated in ITS Table 3.3.1-1 Footnote (b)) and MODE 2. This changes the CTS by splitting CTS Table 3.3-1 Functional Unit 2 into two distinct functions, Power Range Neutron Flux - High and Power Range Neutron Flux - Low, and placing the CNP Units 1 and 2 Page 3 of 45 Attachment 1, Volume 8, Rev. 0, Page 46 of 818

Attachment 1, Volume 8, Rev. 0, Page 47 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION allowances of the P-10 Function requirements associated with the Power Range Neutron Flux - Low channels into the Applicability statement.

This change is considered acceptable because the P-10 interlock prevents the block of the Power Range Neutron Flux reactor trip function below the P-10 interlock. The Power Range Neutron Flux - Low channels are not required to trip the unit when the thermal power is above the P-10 interlock. The Power Range Neutron Flux - High channels provide the appropriate protection in this thermal power range. This change is designated as administrative because it does not result in a technical change to the CTS.

A.8 CTS Tables 3.3-1 and 4.3-1 Functional Unit 5 require the Intermediate Range Neutron Flux channels to be OPERABLE in MODES 1 and 2. CTS Table 3.3-1 Action 3.a specifies that below P-6 an inoperable Intermediate Range Neutron Flux channel must be restored to OPERABLE status prior to increasing THERMAL POWER above the P-6 setpoint. CTS Table 3.3-1 specifies that the P-10 interlock prevents or defeats the manual block of the Intermediate Range Neutron Flux reactor trip when the Power Range Neutron Flux channels are

< 9% RTP. ITS Table 3.3.1-1, including Footnotes (b) and (c), requires Function 4, the Intermediate Range Neutron Flux channels, to be OPERABLE in MODE 1 below the P-10 interlocks and MODE 2 above the P-6 interlocks. This changes the CTS by placing the allowances of CTS Table 3.3-1 Action 3.a and the P-10 reactor trip system interlock into the Applicability statement.

This change is considered acceptable because the P-10 interlock only prevents the block of the Intermediate Range Neutron Flux reactor trip function below the P-10 setpoint. The Intermediate Range Neutron Flux channels are not required to trip the unit when the thermal power is above the P-10 interlock. The Power Range Neutron Flux channels provide the appropriate protection in this thermal power range. During thermal power levels below the P-6 interlock, the Source Range Neutron Flux channels provide the appropriate protection in this thermal power range. The change is administrative since the CTS Actions and interlocks do not require the channels to be OPERABLE outside of the specified Applicability. This change is designated as administrative because it does not result in a technical change to the CTS.

A.9 CTS Table 3.3-1 Functional Unit 6 requires the Source Range Neutron Flux channels to be OPERABLE in MODE 2, as modified by CTS Table 3.3-1 Note ##. CTS Table 3.3-1 Note ## specifies that the high voltage to the Source Range Neutron Flux detectors may be de-energized above P-6. ITS Table 3.3.1-1, including Footnote (d), requires Function 5, the Source Range Neutron Flux channels, to be OPERABLE in MODE 2 below the P-6 interlock.

This changes the CTS by specifically stating that the Source Range Neutron Flux channels are only required in MODE 2 below the P-6 interlock.

This change is considered acceptable because the P-6 interlock prevents the block of the Source Range Neutron Flux reactor trip function below the P-6 interlock. CTS Table 3.3-1 Note ## specifically states that the high voltage to the detectors can be deenergized, which renders the Source Range Neutron Flux channels inoperable. In addition, the CTS Table 4.3-1 Applicability, including Note (7), for the Source Range Neutron Flux channels states the channels are CNP Units 1 and 2 Page 4 of 45 Attachment 1, Volume 8, Rev. 0, Page 47 of 818

Attachment 1, Volume 8, Rev. 0, Page 48 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION only required in MODE 2 below P-6. This change is designated as administrative because it does not result in a technical change to the CTS.

A.10 CTS Table 3.3-1 Functional Units 9, 11, 16, 17, 18.A, and 18.B specify the requirements for Pressurizer Pressure - Low, Pressurizer Water Level - High, Undervoltage - Reactor Coolant Pumps, Underfrequency - Reactor Coolant Pumps, Turbine Trip - Low Fluid Oil Pressure, and Turbine Trip - Turbine Stop Valve Closure. The Applicability of Functional Units 9 and 11 in CTS Table 3.3-1 is MODES 1 and 2, while the Applicability of Functional Units 16, 17, 18.A, and 18.B in CTS Table 3.3-1 is MODE 1. In addition, the Applicability for the Surveillances in CTS Table 4.3-1 for Functional Units 9, 11, 16, and 17 are identical to the Applicability of the associated Function in CTS Table 3.3-1.

CTS Table 3.3-1 also specifies that the P-7 interlock function prevents or defeats the automatic block of reactor trip on these channels. ITS Table 3.3.1-1 Functions 8.a, 9, 10, 12, 13, 16.a, and 16.b require the same Functions to be OPERABLE in MODE 1 above the P-7 interlock. This changes the CTS by placing the allowances of P-7 Reactor Trip System interlock into the Applicability statement for the applicable Functions. The change to the Surveillance Applicability for CTS Functional Units 18.A and 18.B is discussed in DOC A.15.

This change is considered acceptable because the P-7 interlock prevents or defeats the automatic block of the reactor trip on Pressurizer Pressure - Low, Pressurizer Water Level - High, Undervoltage - Reactor Coolant Pumps, Underfrequency - Reactor Coolant Pumps, Turbine Trip - Low Fluid Oil Pressure, and Turbine Trip - Turbine Stop Valve Closure above the P-7 interlock. Below the P-7 interlock, the reactor trips associated with these functions are blocked. This change is designated as administrative because it does not result in a technical change to the CTS.

A.11 CTS Table 3.3-1 Action 2 provides the actions when a Power Range Neutron Flux - High channel is inoperable. The Action, in part, requires either reducing reactor power to < 75% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or monitoring the QPTR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months per Specification 4.2.4.c. This specific requirement is not included in the ITS 3.3.1 ACTIONS. This changes the CTS by not including these requirements in the ITS.

The purpose of these CTS Actions is related to QPTR, not the RTS Instrumentation. This change is acceptable because the specific actions are duplicative of requirements located in the QPTR Specification. CTS 4.2.4.c (ITS SR 3.2.4.2) requires the QPTR to be verified using the incore movable detectors every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when a Power Range Neutron Flux channel input is inoperable and reactor power is > 75% RTP. CTS 4.2.4.a (ITS SR 3.2.4.1), the normal 7 day QPTR verification, can only be performed if all Power Range Neutron Flux channels are OPERABLE, or if three of the channels are OPERABLE (as allowed by the CTS 1.18 QPTR definition and ITS SR 3.2.4.1 Note) and reactor power is < 75% RTP (i.e., when one Power Range Neutron Flux channel is inoperable, reactor power must be < 75% RTP to perform SR 3.2.4.1). In addition, while CTS Table 3.3-1 Action 2 requires reactor power to be reduced within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the alternate option in Action 2 is to perform the Surveillance every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Thus, in actuality, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to reduce CNP Units 1 and 2 Page 5 of 45 Attachment 1, Volume 8, Rev. 0, Page 48 of 818

Attachment 1, Volume 8, Rev. 0, Page 49 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION reactor power. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.12 CTS Table 3.3-1 Functional Unit 21 requires two Reactor Trip Breakers to be OPERABLE, while CTS Table 4.3-1 Functional Unit 21 specifies the Surveillance Requirements for the Reactor Trip Breakers as well as the Shunt Trip and Undervoltage Trip Functions. CTS 3.3-1 Action 13 provides compensatory actions for when the undervoltage or shunt trip feature is inoperable, while Action 15 specifies the compensatory actions for when the Reactor Trip Breakers are inoperable for reasons other than an inoperable diverse trip feature.

ITS 3.3.1-1 Function 19 specifies the requirements for the Reactor Trip Breakers (2 trains are required to be OPERABLE), while Function 20 specifies the requirements for the Reactor Trip Breaker Shunt Trip and Undervoltage Functions (one of each trip feature per Reactor Trip Breaker is required to be OPERABLE). This changes the CTS by splitting the Reactor Trip Breaker Functional Unit into two separate Functions, the Reactor Trip Breaker Function (Function 19) and Reactor Trip Breaker Undervoltage and Shunt Trip Mechanism Function (Function 20).

This change is considered acceptable since the proposed requirements are consistent with current requirements. The CTS currently provides different compensatory actions for when an Undervoltage or Shunt Trip Mechanism is inoperable and when a Reactor Trip Breaker is inoperable for other reasons than Undervoltage and Shunt Trip Mechanism inoperabilities. Therefore, the divided requirements are consistent with the CTS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.13 CTS Table 3.3-1 does not include any LCO requirements for the reactor trip bypass breakers. However, CTS Table 4.3-1 Functional Unit 23 includes Surveillance Requirements for these breakers, and requires them to be performed in MODES consistent with the Surveillances for the reactor trip breakers. ITS Table 3.3.1-1 Function 19 (Reactor Trip Breakers Function) includes Footnote (f), which states the Reactor Trip Breakers Function includes any reactor trip bypass breakers that are racked in and closed for bypassing a reactor trip breaker. This changes the CTS by explicitly stating when the reactor trip bypass breakers are required to be OPERABLE.

The reactor trip bypass breakers are used during testing of the associated reactor trip breaker, and at all other times they are not racked in or closed. This change is acceptable since CTS LCO 3.3.1 does not require the reactor trip bypass breakers to be OPERABLE as they are not listed in CTS Table 3.3-1.

The only time they could be considered as being required is when they are replacing the reactor trip breakers. Thus, even though they are listed in CTS Table 4.3-1, the breakers are not required to meet the Surveillance Requirements when not racked in and closed, since they are not replacing the reactor trip breakers. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.14 CTS Table 4.3-1 requires a CHANNEL CALIBRATION of Functional Unit 8, the Overpower T channels. CTS Table 4.3-1 Note 9 modifies the CHANNEL CALIBRATION requirement by specifying that the provisions of CNP Units 1 and 2 Page 6 of 45 Attachment 1, Volume 8, Rev. 0, Page 49 of 818

Attachment 1, Volume 8, Rev. 0, Page 50 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Specification 4.0.4 are not applicable for the f2 (delta I) penalty. ITS Table 3.3.1-1 Function 7 requires the performance of a CHANNEL CALIBRATION (ITS SR 3.3.1.15) for the Overpower T channels, and does not include an ITS SR 3.0.4 exception. This changes the CTS by deleting the CTS 4.0.4 allowance associated with the f2 (delta I) penalty.

This change is acceptable because it results in no technical change to the Technical Specifications. The f2 (delta I) penalty is associated with the Overpower T Function. Per CTS Table 2.2-1, the f2 (delta I) penalty is always zero. Since the f2 (delta I) penalty is always zero, there is no need to include a CTS 4.0.4 allowance for the calibration of f2 (delta I) penalty portion of the channel when the unit is operating in MODE 1 or 2, which are the MODES the Overpower T Function is required to be OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

A.15 CTS Table 4.3-1 specifies that Surveillance Requirements for Functional Units 18.A (Turbine Trip - Low Fluid Oil Pressure) and 18.B (Turbine Trip -

Turbine Stop Valve Closure) channels are to be performed in MODES 1 and 2.

ITS 3.3.1 does not include any Surveillance Requirements for these Functions in MODE 2. This changes the CTS by deleting Surveillance Requirements for these Functional Units in MODE 2.

This change is considered acceptable since the specified channels do not include any LCO requirements in MODE 2. CTS Table 3.3-1 Functional Units 18.A and 18.B, which specifies LCO requirements for these channels, include requirements for the channels only in MODE 1. Therefore, when in MODE 2, in accordance with CTS 4.0.1 (ITS SR 3.0.1), Surveillances are not required. This change is designated as administrative because it does not result in a technical change to the CTS.

A.16 CTS Table 4.3-1, Functional Units 7 and 8 require the performance of a CHANNEL CALIBRATION of the Overtemperature T and Overpower T channels. ITS Table 3.3.1-1 Functions 6 and 7 also require the performance of a CHANNEL CALIBRATION (ITS SR 3.3.1.15) for the Overtemperature T and Overpower T channels; however, ITS SR 3.3.1.15 is modified by Note 1, which states that this Surveillance shall include verification of Reactor Coolant System (RCS) resistance temperature detector (RTD) bypass loop flow rate. This changes the CTS by adding a clarification Note to the Surveillance to ensure that RCS RTD bypass loop flow rate is verified.

This change is acceptable because the RCS RTD bypass loop flow rate verification is considered necessary to ensure the OPERABILITY of the associated Function channels. The Note is considered a clarification Note and is consistent with the current practice. This change is designated as administrative because it does not result in a technical change to the CTS.

A.17 CTS 4.3.1.1.3 requires REACTOR TRIP SYSTEM RESPONSE TIME testing of "each" reactor trip function. ITS SR 3.3.1.19 is the REACTOR TRIP SYSTEM RESPONSE TIME testing Surveillance, but in ITS Table 3.3.1-1, it is only required for Functions 2.a (Power Range Neutron Flux - High), 2.b (Power Range CNP Units 1 and 2 Page 7 of 45 Attachment 1, Volume 8, Rev. 0, Page 50 of 818

Attachment 1, Volume 8, Rev. 0, Page 51 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Neutron Flux - Low), 6 (Overtemperature T), 7 (Overpower T),

8.a (Pressurizer Pressure - Low), 8.b (Pressurizer Pressure - High),

9 (Pressurizer Water Level - High), 10 (Reactor Coolant Flow - Low),

12 (Undervoltage RCPs), 13 (Underfrequency RCPs), 14 (Steam Generator Water Level - Low Low), and 17 (SI input from ESFAS). This changes the CTS by specifically stating that the Surveillance is only applicable to certain Functions, not "each" function.

The purpose of CTS 4.3.1.1.3 is to ensure that the actuation response times are less than or equal to the maximum values assumed in the accident analysis.

UFSAR Tables 7.2-6 and 7.2-7, which were previously in CTS 3.3.1 as Table 3.3-2 and in CTS 3.3.2 as Table 3.2-5, respectively, only specify response times for those RTS Functions assumed in the CNP safety analyses. These response times were removed from CTS 3.3.1 and 3.3.2 and placed under CNP control as documented in the NRC Safety Evaluation Report for License Amendments 202 (Unit 1) and 187 (Unit 2). This change is acceptable since ITS 3.3.1 requires REACTOR TRIP SYSTEM RESPONSE TIME testing (ITS SR 3.3.1.19) for only those Functions listed in UFSAR Tables 7.2-6 and 7.2-7. This change is designated as administrative because it does not result in technical changes to the CTS.

A.18 CTS Table 3.3-1, including Note *, requires Functional Units 1 (Manual Reactor Trip) and 6 (Source Range, Neutron Flux) channels to be OPERABLE with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal. In addition, CTS Table 4.3-1 requires Functional Unit 6 (Source Range, Neutron Flux) channels to be tested in MODES 3 (below P-6), 4, and 5. ITS Table 3.3.1-1, including Footnote (a),

requires Functions 1 (Manual Reactor Trip) and 5 (Source Range Neutron Flux) channels to be OPERABLE in MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal or with one or more rods not fully inserted. This changes the CTS by specifically stating that the CTS Table 3.3-1 Note Applicability applies in MODES 3, 4, and 5. In addition, this changes the CTS by matching the MODES the Source Range Neutron Flux channels are to be tested with the MODES in which the channels are required to be OPERABLE. The change concerning the details of the reactor trip breakers is discussed in DOC LA.3 and the change that adds the requirement concerning the position of the rods is discussed in DOC M.1.

The purpose of the RTS instrumentation is that it must be OPERABLE so that the rods can be inserted in response to a reactivity excursion. This change is acceptable since it is only clarifying the actual MODES, other than MODES 1 and 2, in which fuel is in the vessel. In addition, while CTS Table 4.3-1 lists MODES 3, 4, and 5 for the Applicability of the two Functional Units, the ITS clarifies that the channels are only required to be tested when they are required to be OPERABLE, consistent with CTS 4.0.1 (ITS SR 3.0.1). This change is designated as administrative because it does not result in a technical change to the CTS.

A.19 CTS LCO 3.3.1.1 states that the interlocks of Table 3.3-1 shall be OPERABLE.

CTS Table 3.3-1 includes the logic description, setpoint, and functional description of the P-6, P-7, P-8, and P-10 interlocks. However, no specific CNP Units 1 and 2 Page 8 of 45 Attachment 1, Volume 8, Rev. 0, Page 51 of 818

Attachment 1, Volume 8, Rev. 0, Page 52 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Applicability requirements are provided. ITS Table 3.3.1-1 specifies the Applicable MODES or other specified conditions associated with the P-6, P-7, P-8, P-10 and P-13 interlocks (Functions 18.a, b, c, d, and e). This changes the CTS by adding specific applicable MODES or other specified conditions associated with the P-6, P-7, P-8, P-10, and P-13 interlocks.

This change is acceptable because the change provides more explicit conditions for when the interlocks are required to be OPERABLE, and are consistent with the RTS Functions they support (i.e., the RTS instruments described in the Functional Unit column of CTS Table 3.3-1). This change is designated as administrative because it does not result in a technical change to the CTS.

A.20 CTS 4.3.1.1.1 requires that the RTS instrumentation channels be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST at the frequencies shown in Table 4.3-1. ITS 3.3.1 requires the performance of either a CHANNEL OPERATIONAL TEST (COT), a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), or, in the case of the Automatic Trip Logic, an ACTUATION LOGIC TEST. This changes the CTS by changing the CHANNEL FUNCTIONAL TEST requirements to either a COT, a TADOT, or an ACTUATION LOGIC TEST.

This change is acceptable because the COT, TADOT, and ACTUATION LOGIC TEST continue to perform tests similar to the current CHANNEL FUNCTIONAL TEST. The change is one of format only and any technical change to the requirements is specifically addressed in an individual Discussion of Change. In addition, the change to the CHANNEL FUNCTIONAL TEST definition is also described in the Discussion of Changes for ITS 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

A.21 CTS LCO 3.3.1.1 states that the interlocks of Table 3.3-1 shall be OPERABLE.

CTS Table 3.3-1 includes the logic description, setpoint, and functional description of the P-7 interlock. ITS 3.3.1.1 breaks out the turbine first stage pressure portion of the P-7 interlock into its own line item, the P-13 interlock.

This changes the CTS by separating out the P-13 portion of the P-7 interlock.

This change is acceptable since the turbine first stage pressure input to the P-7 interlock is retained in the ITS. The change is one of format only, as the ITS continues to provide the requirements of the turbine first stage pressure, P-13 interlock. This change is designated as administrative because it does not result in technical changes to the CTS.

A.22 CTS Table 4.3-1 specifies that Surveillance Requirements for Functional Units 12 (Loss of Flow - Single Loop) and 13 (Loss of Flow - Two Loops) are to be performed in MODE 1. ITS 3.3.1 only requires Surveillances in MODE 1 above the P-7 interlock. This changes the CTS by deleting Surveillance Requirements for the specified Functional Units in MODE 1 below P-7.

This change is acceptable since the specified channels do not include any LCO requirements below P-7. CTS Table 3.3-1 Functional Units 12 and 13, which specify LCO requirements for these channels, do not include requirements for the channels in MODE 1 below P-7. Therefore, when in MODE 1 below P-7, in CNP Units 1 and 2 Page 9 of 45 Attachment 1, Volume 8, Rev. 0, Page 52 of 818

Attachment 1, Volume 8, Rev. 0, Page 53 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION accordance with CTS 4.0.1 (ITS SR 3.0.1), Surveillances are not required. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS Table 3.3-1 requires Functional Units 1 (Manual Reactor Trip) and 6 (Source Range, Neutron Flux) channels to be OPERABLE with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal, as stated in Table 3.3-1 Note *. CTS Table 4.3-1 specifies the Surveillance Requirements for Functional Unit 1 (Manual Reactor Trip) channels are applicable in MODES 3, 4, and 5 with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal, as stated in CTS Table 4.3-1 Note *. CTS Table 4.3-1 specifies the Surveillance Requirements for the Source Range Neutron Flux channels in MODES 3, 4, 5; however there is no reference to CTS Table 4.3-1 Note *. ITS Table 3.3.1-1, including Footnote (a), requires the Functions 1 (Manual Reactor Trip) and 5 (Source Range Neutron Flux) channels to be OPERABLE in MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal or with one or more rods not fully inserted. This changes the CTS by requiring the Manual Reactor Trip and the Source Range Neutron Flux Functions to be OPERABLE when one or more rods are not fully inserted irrespective of the condition of the reactor trip breakers or the Control Rod Drive System. The change concerning the details of the reactor trip breakers are discussed in DOC LA.3 and the change that adds MODES 3, 4, and 5 is discussed in DOC A.18.

The purpose of the RTS instrumentation is that it must be OPERABLE so that the rods can be inserted in response to a reactivity excursion. This change is acceptable because it provides appropriate requirements for when one or more control rods are not fully inserted. This change is designated as more restrictive because it requires the Manual Reactor Trip and the Source Range Neutron Flux Functions to be OPERABLE when one or more rods are not fully inserted irrespective of the condition of the reactor trip breakers or the Control Rod Drive System.

M.2 With one Source Range Neutron Flux channel inoperable in MODE 2 below P-6 or with the RTS breakers in the closed position and the Control Rod Drive System capable of rod withdrawal, CTS Table 3.3-1 Action 4 limits the THERMAL POWER to the P-6 setpoint value until the inoperable channel is restored to OPERABLE status. ITS 3.3.1 ACTION G, which provides the actions for when one Source Range Neutron Flux channel is inoperable in MODE 2 below P-6, requires all operation involving positive reactivity additions to be immediately suspended. The requirement is modified by a Note that states limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM. ITS 3.3.1 ACTION I, which provides the actions for when one Source Range Neutron Flux channel is inoperable during MODE 3, 4, or 5 with Rod Control System capable of rod withdrawal or one or more rods not fully inserted, requires the channel to be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or ITS 3.3.1 ACTION Q must be entered and action must be taken immediately to fully insert all rods and to place the Rod Control System CNP Units 1 and 2 Page 10 of 45 Attachment 1, Volume 8, Rev. 0, Page 53 of 818

Attachment 1, Volume 8, Rev. 0, Page 54 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION in a condition incapable of rod withdrawal within one hour. This changes the CTS requirements for an inoperable Source Range Neutron Flux channel by limiting operation involving positive reactivity additions during operations in MODE 2 below the P-6 limit and limits the time a channel can be inoperable during MODE 3, 4, or 5 operations.

This change is acceptable because in this condition the number of Source Range Neutron Flux channels, which are the only channels providing protection, has been reduced by 50% and additional restrictions are appropriate. Positive reactivity additions must be either prohibited or minimized to ensure reactor reactivity is maintained in a known and controlled condition. Limited positive reactivity additions, temperature decreases or boron dilutions, are reasonable restraints to place on unit operations when only one Source Range channel is OPERABLE. With one Source Range Neutron Flux channel inoperable in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted, the redundancy of the RTS Instrumentation is lost and therefore the time operation can continue in this condition is limited. This change is more restrictive because plant operations are more limited by the ITS requirements than the CTS.

M.3 CTS Table 4.3-1, Functional Unit 2 requires a daily and monthly CHANNEL CALIBRATION of the Power Range Neutron Flux channels. CTS Table 4.3-1 Note 8 specifies that the provision of Specification 4.0.4 are not applicable to these Surveillances. ITS Table 3.3.1-1 Function 2.a requires the performance of SR 3.3.1.2 and SR 3.3.1.3 for the Power Range Neutron Flux - High channels.

ITS SR 3.3.1.2 requires a comparison of the results of calorimetric heat balance calculation to Nuclear Instrumentation System (NIS) channel output every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This Surveillance contains a Note (Note 2) that states that it is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is > 15% RTP.

ITS SR 3.3.1.3 requires a comparison of the results of the incore detector measurements to NIS AFD every 31 effective full power days (EFPD). This Surveillance contains a Note (Note 2) that states that it is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP. This changes the CTS by explicitly specifying the time required to perform the Surveillance after entering the specified Applicability.

The purpose of the CTS 4.0.4 exception is to allow the unit to enter the MODE of Applicability of the instrumentation without calibrating the associated equipment.

This exception is necessary to allow a normal shutdown or startup to be completed and at the same time to allow time to perform the Surveillance. The proposed Surveillance Notes provide finite times in which the Surveillances must be performed after entering the specified condition and therefore this change is considered acceptable. This change is designated as more restrictive as it specifies an explicit time period to perform the tests.

M.4 CTS Table 3.3-1 Functional Units 2 (Power Range Neutron Flux), 3 (Power Range Neutron Flux High Positive Rate) and 4 (Power Range Neutron Flux High Negative Rate) require entry into Action 2 if one channel is inoperable. If the requirements of Action 2 are not met, entry into CTS 3.0.3 will be required since no further actions are specified. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and 6 additional hours for the unit to be placed in MODE 3. ITS 3.3.1 ACTION P, CNP Units 1 and 2 Page 11 of 45 Attachment 1, Volume 8, Rev. 0, Page 54 of 818

Attachment 1, Volume 8, Rev. 0, Page 55 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION which is applicable if any Required Action and associated Completion Time of Condition C or D (as applicable to the above Functions) is not met, requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS requirements by decreasing the time allowed to be in MODE 3 from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in the CTS to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in the ITS.

This change is acceptable because the CTS requirements are modified to provide the necessary Required Actions and appropriate Completion Times. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to reach MODE 3 from 100% RTP, in a safe manner without challenging unit systems, is consistent with other CTS and ITS requirements. This change is designated as more restrictive because the Completion Time for the unit to be placed in MODE 3 has been decreased by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

M.5 With one Intermediate Range Neutron Flux channel inoperable, CTS Table 3.3-1 Action 3.b, when above the P-6 interlock and below 5% of RTP, requires the restoration of the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above 5% RTP. In addition, CTS Table 3.3-1 Action 3.c allows unlimited operation with an inoperable Intermediate Range Neutron Flux channel above 5% RTP. ITS 3.3.1 ACTION E, which provides actions for when one Intermediate Range Neutron Flux channel is inoperable, requires either a reduction of THERMAL POWER to < P-6 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the increase in THERMAL POWER to > P-10 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by limiting the time the unit can operate with an inoperable Intermediate Range Neutron Flux channel above 5% RTP but below the P-10 interlock to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This change is acceptable because a time limit is placed on the length of time the unit may operate with an inoperable Intermediate Range Neutron Flux channel at a power level above 5% RTP and below the P-10 interlock. The requirement to allow 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the instrument to OPERABLE status or to leave the Applicability for when the equipment is required to be OPERABLE is reasonable because a protection function has been significantly degraded and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable period of time to allow for a slow and controlled power adjustment.

This change is more restrictive because it restricts the time the unit can operate with an inoperable Intermediate Range Neutron Flux channel.

M.6 In CTS 3.3.1.1, no action is provided for two inoperable Source Range Neutron Flux channels; therefore CTS 3.0.3 must be entered. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and 6 additional hours for the unit to be placed in MODE 3.

ITS 3.3.1 ACTION H provides actions for two inoperable Source Range Neutron Flux channels and requires the reactor trip breakers (RTBs) to be opened immediately. This changes the CTS by requiring the RTBs to be opened immediately if both Source Range Neutron Flux channels become inoperable, in lieu of performing a controlled shutdown to MODE 3 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months .

This change is acceptable because with no Source Range Neutron Flux channels OPERABLE and with the reactor in a condition of being capable of achieving criticality, the operator may have no automatic safety function capable of shutting down the unit. Therefore, the unit must be placed into a safe condition. This is accomplished by opening the RTBs, which inserts all rods.

CNP Units 1 and 2 Page 12 of 45 Attachment 1, Volume 8, Rev. 0, Page 55 of 818

Attachment 1, Volume 8, Rev. 0, Page 56 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION This change is designated as more restrictive because the actions added are more restrictive than are required by the CTS.

M.7 CTS Table 3.3-1 Functional Units 7, 8, 9, 10, 16, and 17 require entry into CTS Table 3.3-1 Action 6. CTS Table 3.3-1 Action 6 states that with the number of OPERABLE channels one less than the total number of channels, startup and power operations may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . CTS Table 3.3-1 Functional Units 11 through 15, 18.A, and 18.B require entry into CTS Table 3.3-1 Action 7. CTS Table 3.3-1 Action 7 states that with the number of OPERABLE channels one less than the total number of channels, startup and power operations may proceed provided the inoperable channel is place in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

CTS Table 3.3-1 Functional Unit 20 requires entry into CTS Table 3.3-1 Action 11. CTS Table 3.3-1 Action 11 states that with less than the minimum number of channels OPERABLE, operation may continue provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If CTS Table 3.3-1 Action 6, Action 7, or Action 11 is not met, entry into CTS 3.0.3 is required since no further actions are specified. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and 6 additional hours for the unit to be placed in MODE 3.

ITS 3.3.1 ACTIONS N and P, which are applicable if any Required Action and associated Completion Time of Condition D or L is not met (as applicable to the above Functions), require the unit to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (ACTION P) or require a reduction in THERMAL POWER to < P-7 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (ACTION N). This changes the CTS by providing a specific default condition instead of requiring entry into CTS 3.0.3, and reducing the time to reach the applicable condition from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

This change is acceptable because the proposed default condition will require the plant to be in a condition where the RTS instrumentation is no longer required to be OPERABLE. The proposed Completion Times are consistent with the time currently required for the unit to reach these conditions in a safe manner. This change is designated as more restrictive since the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months specified in CTS 3.0.3 no longer applies.

M.8 CTS 4.3.1.1.2 requires the logic for the interlocks be demonstrated OPERABLE prior to each reactor startup unless performed during the preceding 92 days.

ITS Table 3.3.1-1 Functions 18.a through 18.e require the performance of an ACTUATION LOGIC TEST every 92 days on a STAGGERED TEST BASIS (ITS SR 3.3.1.5). This changes the CTS by changing the Surveillance Frequency from prior to each reactor startup unless performed during the preceding 92 days to every 92 days on a STAGGERED TEST BASIS.

The purpose of the CTS Table 4.3.1.1.2 CHANNEL FUNCTIONAL TEST requirement is to ensure the RTS interlocks are OPERABLE. The change is acceptable since the proposed Surveillance Frequency will require performance of the test every 92 days on a STAGGERED TEST BASIS. This ensures that each interlock train is tested every 184 days, even when the unit is operating.

Currently, the test could be performed only once in an 18-month cycle. The Frequency is also consistent with the ACTUATION LOGIC TEST Frequency for the RTS actuation logic and relays. This change is designated as more CNP Units 1 and 2 Page 13 of 45 Attachment 1, Volume 8, Rev. 0, Page 56 of 818

Attachment 1, Volume 8, Rev. 0, Page 57 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION restrictive since the ITS will require the test to be performed more frequently than in the CTS.

M.9 CTS Table 3.3-1 Action 13 does not allow the Reactor Trip Breaker (RTB) to be bypassed while one of the diverse trip features is inoperable except for the time required to perform maintenance to restore the breaker to OPERABLE status.

However, no finite time to perform maintenance is specified. ITS 3.3.1 ACTION K does not include this allowance. This changes the CTS by eliminating the allowance for one RTB to be bypassed for maintenance on undervoltage or shunt trip mechanisms for an unlimited amount of time.

This change is acceptable because the allowance was inadvertently left in the CTS by the License Amendment Request (AEP:NRC:3311) submitted to the NRC to adopt the relaxations of WCAP-15376-P-A, "Risk - Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," Revision 1, dated March 2003. WCAP-15376-P-A justified, in part, extensions of the RTB Completion Times and RTB bypass time and included the deletion of the allowance for bypassing an RTB for maintenance of a diverse trip mechanism. This License Amendment Request was approved by the NRC in License Amendments 277 (Unit 1) and 260 (Unit 2), dated May 23, 2003. This change is designated as more restrictive since an allowance for bypassing an RTB for maintenance on undervoltage or shunt trip mechanisms has been eliminated.

M.10 CTS Table 4.3-1 requires a CHANNEL CALIBRATION of Functional Units 7 and 8, the Overtemperature T and Overpower T channels, respectively. CTS Table 4.3-1 Note 9 modifies these CHANNEL CALIBRATION requirements, and specifies, in part, that the provisions of Specification 4.0.4 are not applicable for measurement of delta T. ITS Table 3.3.1-1 Functions 6 and 7 require the performance of ITS SR 3.3.1.15, a CHANNEL CALIBRATION for the Overtemperature T and Overpower T channels. ITS SR 3.3.1.15 is modified by a Note (Note 2) that states that normalization of the T is not required to be performed until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after THERMAL POWER is > 98% RTP. This changes the CTS by restricting the application of CTS 4.0.4 for measurement of delta T by requiring the performance of the Surveillance no later than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after THERMAL POWER is > 98% RTP.

The purpose of the CTS 4.0.4 exception is to allow the unit to enter the MODE of Applicability of the Overtemperature T and Overpower T channels without completing the normalization of T. The change explicitly specifies that the normalization of T channels is not required to be performed until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after THERMAL POWER is > 98% RTP. This change is acceptable since the proposed Surveillance is consistent with the intent of the current allowance and ensures the normalization of T is performed within a reasonable period of time after the unit is in the condition to perform the normalization. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is necessary for unit conditions to stabilize, obtain the appropriate data, perform calculations, and perform the actual normalization. This change is designated as more restrictive since the added Note explicitly states that the only portion of the CHANNEL CALIBRATION of the Overtemperature T and Overpower T channels that can be performed after entering the MODE of Applicability is the CNP Units 1 and 2 Page 14 of 45 Attachment 1, Volume 8, Rev. 0, Page 57 of 818

Attachment 1, Volume 8, Rev. 0, Page 58 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION normalization of T and that the normalization must be performed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after achieving 98% RTP.

M.11 In CTS 3.3.1.1, no Action is provided for two inoperable Intermediate Range Neutron Flux channels; therefore CTS 3.0.3 must be entered. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and 6 additional hours for the unit to be placed in MODE 3. ITS 3.3.1 ACTION F provides actions for two inoperable Intermediate Range Neutron Flux channels. ITS 3.3.1 Required Action F.1 requires the immediate suspension of operations involving positive reactivity additions. A Note modifies the Required Action and states "Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM."

ITS 3.3.1 Required Action F.2 requires the reduction of THERMAL POWER to

< P-6 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by adding a specific ACTION to cover the condition for two inoperable Intermediate Range Neutron Flux channels.

This change is acceptable because the Required Actions require the unit to be placed in a condition where the Intermediate Range Nuclear Flux channels are no longer required to be OPERABLE. The proposed ACTION precludes a power level increase and allows a reasonable period of time for a slow and controlled power adjustment with no Intermediate Range channels OPERABLE status. The ITS requires the actions of precluding positive reactivity additions and reducing power. These remedial actions are for safe operation. This change is designated as more restrictive because an explicit ACTION is being added which requires the unit to be at a specific condition in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in lieu of the current 7 hour8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months time.

M.12 CTS Table 4.3-1, including Note 17, requires the performance of a CHANNEL FUNCTIONAL TEST for the Functional Unit 5 (Intermediate Range Neutron Flux) channels prior to each reactor startup if not performed in the previous 184 days.

ITS Table 3.3.1-1 Function 4 requires the performance of a COT (SR 3.3.1.10) every 184 days. However, a Note (Note 1) states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reducing THERMAL POWER below the P-10 interlock. This effectively changes the CTS by requiring a COT be performed during a reactor shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing power below the P-10 interlock, if the COT has not been performed in the previous 184 days.

This change is acceptable because it ensures the Intermediate Range Neutron Flux channels are OPERABLE in the MODES or other specified conditions in which the channels are assumed to function. This change is designated as more restrictive since the Surveillance must be performed every 184 days instead of during a startup if not performed in the previous 184 days.

M.13 CTS Table 4.3-1 requires a CHANNEL CALIBRATION of Functional Unit 7, the Overtemperature T channels. CTS Table 4.3-1 Note 9 modifies the CHANNEL CALIBRATION requirement, and specifies, in part, that the provisions of Specification 4.0.4 are not applicable for f1 (delta I) penalty. However, the CTS does not include a requirement to calibrate the excore channels to agree with the incore channels, which are needed to determine the f1 (delta I) penalty.

ITS Table 3.3.1-1 Function 7 requires the performance of ITS SR 3.3.1.7 for the CNP Units 1 and 2 Page 15 of 45 Attachment 1, Volume 8, Rev. 0, Page 58 of 818

Attachment 1, Volume 8, Rev. 0, Page 59 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Overtemperature T channels. ITS SR 3.3.1.7 requires the calibration of excore channels to agree with incore detector measurements every 92 effective full power days. ITS SR 3.3.1.7 is modified by a Note that states that the Surveillance is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 50% RTP. This changes the CTS by adding an explicit Surveillance to calibrate the excore channels to agree with incore detector measurements.

This also changes the CTS by restricting the application of CTS 4.0.4 for the f1 (delta I) penalty by requiring the performance of the Surveillance no later than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 50% RTP.

The purpose of the excore to incore calibration is to ensure that the excore detectors are accurately measuring power. The purpose of CTS 4.0.4 exception is to allow the unit to enter the MODE of Applicability of the Overtemperature T channels without completing a calibration of the excore to incore detectors.

However, no finite time to complete the calibration is provided in the CTS. The change adds an explicit Surveillance to calibrate the excore channels to agree with incore detector measurements every 92 effective full power days with a Note which allows the performance of the Surveillance to be delayed only until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 50% RTP. This change is acceptable since the proposed Surveillance is consistent with the intent of the current allowance and ensures the incore to excore detector calibration is performed periodically. ITS SR 3.3.1.7 is a calibration of the excore channels to the incore channels. This Surveillance is performed to compute the f1 (delta I) input to the Overtemperature T Function Allowable Value. The change is designated as more restrictive since a new Surveillance with an explicit Frequency has been added to the Technical Specifications. In addition, a time period is specified for when the Surveillance must be performed after achieving a THERMAL POWER level at which the calibration can be performed.

M.14 CTS Table 4.3-2 Functional Units 18.A and 18.B specify the Surveillance Requirements for the Turbine Trip - Low Fluid Oil Pressure and Turbine Trip -

Turbine Stop Valve Closure Functions and do not include a CHANNEL CALIBRATION requirement. ITS SR 3.3.1.13 has been added which requires a CHANNEL CALIBRATION of these channels every 24 months (ITS Table 3.3.1-1, Functions 16.a and 16.b). This changes the CTS by adding a CHANNEL CALIBRATION requirement for the Turbine Trip - Low Fluid Oil Pressure and Turbine Trip - Turbine Stop Valve Closure Functions every 24 months.

This change is acceptable because it ensures the Allowable Values for the Turbine Trip - Low Fluid Oil Pressure and Turbine Trip - Turbine Stop Valve Closure Trip Functions are consistent with the plant setpoint methodology. This change is designated as more restrictive since a new Surveillance Requirement has been added to the Turbine Trip Functions.

M.15 CTS Table 4.3-1, Functional Units 2, 5, and 6 require a 92 day (for Functional Unit 2) and an 18 month (for Functional Units 5, 6, 12, and 13) CHANNEL CALIBRATION of the Power Range Neutron Flux, Intermediate Range Neutron Flux, Source Range Neutron Flux, Loss of Flow-Single Loop, and Loss of Flow-Two Loops channels, respectively. CTS Table 4.3-1 Note 8 specifies that the provision of Specification 4.0.4 are not applicable to the Functional Units 2, 5, CNP Units 1 and 2 Page 16 of 45 Attachment 1, Volume 8, Rev. 0, Page 59 of 818

Attachment 1, Volume 8, Rev. 0, Page 60 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION 12, and 13 Surveillances and CTS Table 4.3-1 Note 14 specifies that the provisions of Specification 4.0.4 are not applicable to the Functional Unit 6 Surveillance when leaving MODE 1 and requires the Surveillance to be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after leaving MODE 1. The ITS does not include these exceptions for the Power Range Neutron Flux, Intermediate Range Neutron Flux, Source Range Neutron Flux, and Loss of Flow (Single Loop and Two Loops) CHANNEL CALIBRATION Surveillances (ITS SRs 3.3.1.9, 3.3.1.13, and 3.3.1.14). This changes the CTS by deleting a CTS 4.0.4 exception for performing CHANNEL CALIBRATIONS of certain RTS channels.

The purpose of the CTS 4.0.4 exception is to allow the unit to enter the MODE of Applicability of the instrumentation without calibrating the associated equipment.

However, since the CHANNEL CALIBRATION Surveillances are normally performed while shutdown for the Intermediate Range Neutron Flux, Source Range Neutron Flux, and Loss of Flow channels, and the Frequency of the ITS Surveillance is 24 months, the exceptions are no longer needed. For the Power Range Neutron Flux channels, the Surveillance can be performed prior to entering the applicable MODES of the channels, thus the exception is no longer needed. The ITS will require the Surveillances to be current prior to entering the MODE of Applicability for the Power Range Neutron Flux, Intermediate Range Neutron Flux, Source Range Neutron Flux, and Loss of Flow channels. This change is designated as more restrictive since current exceptions are being deleted.

M.16 CTS Table 4.3-1, Functional Unit 16 (Undervoltage - Reactor Coolant Pumps) requires the performance of a CHANNEL CALIBRATION every 18 months, however the Surveillance is currently being performed more frequently. ITS Table 3.3.1-1 Function 12 (Undervoltage RCPs) requires the performance of CHANNEL CALIBRATION every 184 days (ITS SR 3.3.1.12). This changes the CTS by changing the Frequency of the Surveillance from 18 months to 184 days.

The purpose of the CHANNEL CALIBRATION is to ensure the Undervoltage -

Reactor Coolant Pumps channels will function as designed during an analyzed event. Changing the SR Frequency is acceptable because a 184 day calibration interval is assumed in the setpoint analysis. This change is designated as more restrictive because Surveillances will be performed more frequently under the ITS than under the CTS.

M.17 CTS Table 2.2-1 provides the Allowable Values for Functional Unit 8 (Overpower T) (Unit 2 only), Functional Unit 9 (Pressurizer Pressure - Low) (Unit 1 only),

Functional Unit 12 (Loss of Flow), Functional Unit 13, (Steam Generator Water Level - Low Low) (Unit 2 only), Functional Unit 14, (Steam/Feedwater Flow Mismatch and Steam Generator Water Level - Low) (Steam Generator Water Level - Low portion only is covered by this change) (Unit 2 only), and Functional Unit 16 (Underfrequency - Reactor Coolant Pumps) (Unit 1 only ). ITS Table 3.3.1-1 provides the Allowable Values for all the RTS Instrumentation Functions, including ITS Table 3.3.1-1 Functions 7, 8.a, 10, 13, 14, and 15. This change revises the above specified CTS RTS Table 2.2-1 Allowable Values to the ITS Allowable Values.

CNP Units 1 and 2 Page 17 of 45 Attachment 1, Volume 8, Rev. 0, Page 60 of 818

Attachment 1, Volume 8, Rev. 0, Page 61 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION The purpose of the Allowable Values is to ensure the instruments function as assumed in the safety analyses. ITS 3.3.1 reflects Allowable Values consistent with the philosophy of Westinghouse ISTS, NUREG-1431. These Allowable Values have been established consistent with the methods described in I&M's Instrument Setpoint Methodology (EG-IC-004, "Instrument Setpoint Uncertainty,"

Rev. 4). For most cases, the Allowable Value determinations were calculated using plant specific operating and Surveillance trend data. There were no changes to Safety Analysis Limits (SALs) required due to instrument performance. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ANSI/ISA S67.04-Part I-1994 and ANSI/ISA RP67.04-Part II-1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Nominal Trip Setpoints (NTSPs) for each design or SAL have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy using the instrument setpoint methodology. The Allowable Values have also been established from each SAL by combining the errors associated with the CHANNEL OPERATIONAL TEST (COT) (e.g., device accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint using the instrument setpoint methodology. Where a SAL exists, trigger values are used to ensure that the Allowable Value provides sufficient margin from the SAL to account for any associated errors not confirmed by the COT Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints, and analyzing channel/instrument performance ensure that the design basis and associated SALs will not be exceeded during plant operation. These evaluations, determinations, and analyses now form a portion of the CNP design bases. Additionally, each applicable channel/instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These drift evaluations and drift analyses have been performed utilizing the guidance provided in EPRI TR-103335, "Statistical Analysis of Instrument Calibration Data/ Guidelines for Instrument Calibration Extension/Reduction Programs," Rev. 1. The EPRI guidance was used to demonstrate that the data collected by the operating plant (from Surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Therefore, based on the above discussion, the changes to the Allowable Values are acceptable. This change is designated as more restrictive because more stringent Allowable Values are being applied in the ITS than were applied in the CTS.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 18 of 45 Attachment 1, Volume 8, Rev. 0, Page 61 of 818

Attachment 1, Volume 8, Rev. 0, Page 62 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.3.1.1.3 requires each RTS trip function to be response time tested. However, CTS 4.3.1.1.3 Note

exempts the neutron detectors from response time testing and specifies that the "response time of the neutron flux signal portion of the channel shall be measured from the detector output or input of first electronic component in channel." ITS SR 3.3.1.19 Note exempts the neutron detectors from response time testing, but does not include the detail of how to test the neutron flux signal portion of the channel. This changes the CTS by moving the descriptive wording from the Specification to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform RESPONSE TIME TESTING. 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.

LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-1 for RTS instrumentation has three columns stating various requirements for each function. These columns are labeled, "TOTAL NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." ITS Table 3.3.1-1 does not retain the "TOTAL NO.

OF CHANNELS" or "CHANNELS TO TRIP" columns. This changes the CTS by moving the information of the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.3-1, including Note *, requires Functional Units 1 (Manual Reactor Trip) and 6 (Source Range Neutron Flux) channels to CNP Units 1 and 2 Page 19 of 45 Attachment 1, Volume 8, Rev. 0, Page 62 of 818

Attachment 1, Volume 8, Rev. 0, Page 63 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION be OPERABLE "with the reactor trip system breakers in the closed position" and the control rod drive system capable of rod withdrawal. CTS Table 4.3-1 specifies the Surveillance Requirements for the Manual Reactor Trip channels and includes a similar applicability in Note *. ITS Table 3.3.1-1, including Footnote (a), requires Functions 1 (Manual Reactor Trip) and 5 (Source Range Neutron Flux) channels to be OPERABLE in MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal or with one or more rods not fully inserted. This changes the CTS by moving the details on how to place the Rod Control System in a state capable of rod withdrawal (i.e., by using the reactor trip breakers) from the Technical Specifications to the Bases. The change that adds the requirement concerning the position of the rods is discussed in DOC M.1 and the change that adds MODES 3, 4, and 5 is discussed in DOC A.18.

The removal of these details for performing actions 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 continues to specify requirements on the RTS depending on the status of the Rod Control System's capability to withdraw rods. 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.

LA.4 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-1 Function 6 requires two Source Range Neutron Flux channels be OPERABLE in MODE 2 ##. Note ## states that the high voltage to the detector may be de-energized above P-6. ITS Table 3.3.1-1 Function 5, including Footnote (d), requires two OPERABLE Source Range Neutron Flux channels in MODE 2 below the P-6 (Intermediate Range Neutron Flux) interlock, and maintains the intent of the CTS requirement. This changes the CTS by moving the allowance that the high voltage to the detector may be de-energized above P-6 from the Specification to the Bases.

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

LA.5 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-1 specifies the functions and logic of the P-6, P-7, P-8, and P-10 interlocks. ITS Table 3.3-1 Functions 18.a, b, c, and d, do not CNP Units 1 and 2 Page 20 of 45 Attachment 1, Volume 8, Rev. 0, Page 63 of 818

Attachment 1, Volume 8, Rev. 0, Page 64 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION include this information. The ITS only specifies that there is 1 channel per train of each of the interlocks. This changes the CTS by moving the functional description and logic associated with each of the interlocks specified in CTS Table 3.3-1 to the Bases.

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

LA.6 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-1 breaks down the Loss of Flow Function into two separate Functional Units; the reactor trips on Loss of Flow - Single Loop and on Loss of Flow - Two Loops. As stated in CTS Table 3.3-1 Functional Unit 12, the Loss of Flow - Single Loop is enabled above P-8, and as stated in CTS Table 3.3-1 Functional Unit 13, the Loss of Flow - Two Loops is enabled above P-7 and below P-8. The two separate Functional Units are also listed in CTS Table 4.3-1 (Functional Units 12 and 13). ITS Table 3.3.1-1 Function 10 provides the requirements for the Reactor Coolant Flow - Low Function, but does not include the logic description of the Reactor Coolant Flow - Low Function (i.e.,

on a two loop loss of flow above P-7 and below P-8 and on a single loop loss of flow above P-8). This changes the CTS by moving the logic details to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the Reactor Coolant Flow - Low Function. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.7 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 2.2-1 Notes 1 and 2 provide descriptions of some of the factors in the Allowable Value formulas for the Overtemperature T and Overpower T Functional Units, specifically the descriptions concerning the lead-lag and rate lag controllers for Tavg dynamic compensation. ITS Table 3.3-1 Notes 1 and 2 include the same Allowable Value formula, but do not include these specific factor descriptions. This changes the CTS by moving these factor descriptions to the UFSAR.

CNP Units 1 and 2 Page 21 of 45 Attachment 1, Volume 8, Rev. 0, Page 64 of 818

Attachment 1, Volume 8, Rev. 0, Page 65 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the Allowable Value formula for the Overtemperature T and Overpower T Functions. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.8 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS Table 2.2-1 for the Limiting Safety System Settings states the formulas for Overtemperature T and Overpower T Functional Units. ITS 3.3.1 in Table 3.3.1-1 lists the formulas for the Overtemperature T and Overpower T Functions with a reference that certain variables/constants are contained in the CORE OPERATING LIMITS REPORT (COLR). This changes the CTS by relocating specific parameters for the Overtemperature T and Overpower T Functions, which must be confirmed on a cycle-specific basis, from the Technical Specifications 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.

The functional requirements of the Overtemperature T and Overpower T Functions are retained in the Technical Specifications to ensure core protection.

Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.5, "CORE OPERATING LIMITS REPORT." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the Technical Specifications.

LA.9 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 4.3-1 Functional Unit 1 requires the performance of a CHANNEL FUNCTIONAL TEST for the Manual Reactor Trip Function, including the shunt and undervoltage trip devices. In addition, Table 4.3-1 Note 10 states that the CHANNEL FUNCTIONAL TEST shall "independently verify the OPERABILITY of the undervoltage and shunt trip circuits" and "verify the OPERABILITY of the bypass breaker trip circuits."

CTS Table 4.3-1 Functional Unit 21 requires the performance of a CHANNEL CNP Units 1 and 2 Page 22 of 45 Attachment 1, Volume 8, Rev. 0, Page 65 of 818

Attachment 1, Volume 8, Rev. 0, Page 66 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION FUNCTIONAL TEST for the Reactor Trip Breaker Shunt and Undervoltage Trip Functions. In addition, CTS Table 4.3-1 Note 11 states that the CHANNEL FUNCTIONAL TEST shall "independently verify the OPERABILITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers."

CTS Table 4.3-1, Functional Unit 23 requires the performance of a CHANNEL FUNCTIONAL TEST for each Reactor Trip Bypass Breaker every 124 days and prior to each reactor startup if not performed in the previous 7 days. In addition, Note 12 states that the 124 day test includes a verification of the "local manual shunt trip" prior to placing the breaker in service, and Note 13 states that the prior to each startup test includes the "automatic undervoltage trip." ITS 3.3.1 requires a similar Surveillance (ITS SR 3.3.1.17) to be performed, however, the Surveillance does not include these quoted details. This changes the CTS by moving the details of the scope of the tests from the CTS to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform a TADOT. 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.

LA.10 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 2.2.1 requires the RTS instrumentation setpoints to be set consistent with the Trip Setpoint values shown in Table 2.2-1.

However, the CTS 2.2.1 Action is only required to be taken when the setpoint is less conservative than the Allowable Value column of Table 2.2-1. When the setpoint is less conservative than the Allowable Value, the channel is to be declared inoperable and adjusted consistent with the Trip Setpoint value.

CTS Table 2.2-1 specifies both the Trip Setpoints and Allowable Values for the RTS Instrumentation Functional Units. ITS 3.3.1 requires the RTS instrumentation for each Function in Table 3.3.1-1 to be OPERABLE. ITS Table 3.3.1-1 specifies only the Allowable Values for the RTS Instrumentation Functions. The ITS also ties OPERABILITY of channels to the Allowable Values.

This changes the CTS by moving the Trip Setpoints to the Technical Requirements Manual (TRM).

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the Allowable Values associated with the RTS Instrumentation. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting CNP Units 1 and 2 Page 23 of 45 Attachment 1, Volume 8, Rev. 0, Page 66 of 818

Attachment 1, Volume 8, Rev. 0, Page 67 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Technical Specification requirements are being removed from the Technical Specifications.

LA.11 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 2.2-1 Functional Unit 11 provides an Allowable Value of < 93% of instrument span for the Pressurizer Water Level - High channels.

CTS Table 2.2-1 Functional Unit 12 provides an Allowable Value of > 89.1% of the design flow per loop for the Loss of Flow channels. In addition, Unit 1 CTS Table 2.2-1 Note

states that design flow is 1/4 Reactor Coolant System total flow rate from Table 3.2-1 (i.e., 341,100 gpm) and Unit 2 CTS Table 2.2-1 Note

states design flow is 91,600 gpm per loop. CTS Table 2.2-1 Functional Unit 13 provides an Allowable Value of > 16% (Unit 1) and > 19.2% (Unit 2) of narrow range instrument span for the Steam Generator Water Level - Low Low channels. CTS Table 2.2-1 Functional Unit 14 provides an Allowable Value of

> 4% of the narrow range instrument span for the SG Water Level - Low portion of the Steam/Feedwater Flow Mismatch and Low Steam Generator Water Level channels. ITS Table 3.3.1-1 Function 9 provides an Allowable Value for the Pressurizer Water Level - High channels in terms of percent, but does not include the detail of the associated instrument span. ITS Table 3.3.1-1 Function 10 provides an Allowable Value for the Reactor Coolant Flow - Low channels in terms of percent, but does not include the detail of the associated design flow per loop. ITS Table 3.3.1-1 Function 14 provides an Allowable Value for the Steam Generator Water Level - Low Low channels in terms of percent, but does not include the detail of the associated narrow range instrument span. ITS Table 3.3.1-1 Function 15 provides an Allowable Value for the Steam Generator Water Level - Low portion of the Steam Generator Level - Low Coincident with Steam Flow/Feedwater Flow Mismatch channels in terms of percent, but does not include the detail of the associated narrow range instrument span. This changes the CTS by moving the details of what the setting in % is based upon to the Technical Requirements Manual (TRM).

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the value for each of the Allowable Values. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated.

This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.3.1.1.2 requires the total interlock function to be demonstrated OPERABLE at least once per 18 months. ITS SR 3.3.1.16 requires the performance of a CHANNEL OPERATIONAL TEST (COT), which tests a portion of the total interlock function, every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a CNP Units 1 and 2 Page 24 of 45 Attachment 1, Volume 8, Rev. 0, Page 67 of 818

Attachment 1, Volume 8, Rev. 0, Page 68 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.3.1.1.2 is to ensure the proper operation of the RTS interlock functions. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for this COT is acceptable because during the operating cycle, there is sufficient indication of THERMAL POWER and RTS interlock status to ensure the interlocks are in the correct status. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis.

This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS 4.3.1.1.2 requires the total interlock function to be demonstrated OPERABLE at least once per 18 months. CTS Table 4.3-1 requires a CHANNEL CALIBRATION of Functional Units 3 through 15 and 17 every 18 months. ITS Table 3.3.1-1 Functional Units 3 through 10, 13 through 15, and 18 require the performance of a CHANNEL CALIBRATION every 24 months (ITS SRs 3.3.1.12, 3.3.1.13, and 3.3.1.14). This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of the CHANNEL CALIBRATION required by CTS 4.3.1.1.2 and Table 4.3-1 is to ensure the RTS instrumentation and interlocks are calibrated correctly to ensure the safety analysis can be met. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. This change is acceptable because the RTS, including the actuation logic, is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one of the channel components. Furthermore, CTS Table 4.3-1 Functional Units 3 through 15 and 17, and the Interlock Functions of the impacted RTS instrumentation have been evaluated for drift using both quantitative and qualitative analysis, based on manufacturer and model number to determine that the instrumentation's actual drift falls within the design allowance in the associated setpoint calculation.

CNP Units 1 and 2 Page 25 of 45 Attachment 1, Volume 8, Rev. 0, Page 68 of 818

Attachment 1, Volume 8, Rev. 0, Page 69 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Functional Unit 3, Power Range Neutron Flux High Positive Rate This function is performed by the Westinghouse Top and Bottom Half Core Power Detectors and Top and Bottom Half Core Power Drawers (Westinghouse Models 6051D51G01 and 6051D53G01, respectively). These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the Power Range Neutron Flux, High Positive Rate Function are verified by more frequent CHANNEL CHECKS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , comparison tests between indicated power and calculated power (i.e.,

calorimetric verification) every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and CHANNEL OPERATIONAL TESTS (COTs) every 92 days. This testing ensures a significant portion of the circuitry is operating properly and accurately, and will detect significant failures of this circuitry. Additionally, since the flux measurement is evaluated and corrected on a daily basis by the calorimetric verification using high accuracy measurement devices, any drift associated with the circuit is normalized. Therefore, long term drift has no impact on the accuracy of this trip. The results of these analyses will support a 24 month Surveillance interval.

Functional Unit 4, Power Range Neutron Flux High Negative Rate This function is performed by the Westinghouse Top and Bottom Half Core Power Detectors and Top and Bottom Half Core Power Drawers (Westinghouse Models 6051D51G01 and 6051D53G01, respectively). These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the Power Range Neutron Flux, High Negative Rate Function are verified by more frequent CHANNEL CHECKS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , comparison tests between indicated power and calculated power (i.e.,

calorimetric verification) every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and COTs every 92 days. This testing ensures a significant portion of the circuitry is operating properly and accurately, and will detect significant failures of this circuitry. Additionally, since the flux measurement is evaluated and corrected on a daily basis by the calorimetric verification using high accuracy measurement devices, any drift associated with the circuit is normalized. Therefore, long term drift has no impact on the accuracy of this trip. The results of these analyses will support a 24 month Surveillance interval.

Functional Unit 5, Intermediate Range Neutron Flux This function is performed by IRM Neutron Flux Detectors (Westinghouse Model WL-23707) and IRM Neutron Flux Drawers (Westinghouse Model 6051D46G01).

These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the Intermediate Range Neutron Flux Function are verified by more frequent CHANNEL CHECKS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and COTs every 184 days. The IRMs are only required in MODE 1 below the P-10 interlock and in MODE 2 above the P-6 interlock. While operating in MODE 1, operation is normally above the P-10 interlock and the IRM trip is inactive. Also, before the IRM detectors are used for operation, an overlap check is routinely performed to determine if the instruments are reading and CNP Units 1 and 2 Page 26 of 45 Attachment 1, Volume 8, Rev. 0, Page 69 of 818

Attachment 1, Volume 8, Rev. 0, Page 70 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION tracking with the power range and the source range neutron detectors, as applicable. Therefore, long term drift has no impact on the accuracy of this circuit. The results of these analyses will support a 24 month Surveillance interval.

Functional Unit 6, Source Range Neutron Flux This function is performed by SRM Neutron Flux Detectors (Westinghouse Model WL-23706) and SRM Neutron Flux Drawers (Westinghouse Model 6051D50G01). These system components were not evaluated for drift but were justified for extension based on engineering judgment. SRMs satisfy their design function if calibration is sufficient to ensure neutron level is observable when the reactor is shutdown. This is verified by CHANNEL CHECKS at least every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the reactor is shutdown. The SRMs must be operational in MODE 2 below the P-6 interlock. SRM response to reactivity changes is distinctive and well known to plant operators, and SRM response is closely monitored during these reactivity changes. Additionally, since there is very little neutron activity during loading, refueling, shutdown, and approach to criticality, a neutron source is placed in the reactor during approach to criticality to provide a minimum observable SRM neutron count rate attributable to core neutrons of at least 2 counts per second. During plant shutdowns and startups, overlap between the IRM channels and the SRM channels is routinely verified to ensure performance of the SRM channels. There is also more frequent testing, including a COT every 184 days in MODES 1 and 2 and every 31 days in MODES 3, 4, and 5, to verify operation of the electronics for the source range trip. Therefore, any substantial degradation of the SRMs will be evident and long term drift has no impact on the accuracy of this circuit. The results of these analyses will support a 24 month Surveillance interval.

Functional Unit 7, Overtemperature T This function is performed by a loop consisting of a 200 Platinum RTD and Foxboro N-E11 Series Transmitter as the sensing elements with the signal conditioned by Foxboro N-2AI-P2V and N-2AI-H2V Input Cards, and Foxboro N-2CCA-DC Control Cards performing the trip functions. This function utilizes a reactor power input from the Power Range Monitors that is conditioned by a Foxboro N-2AI-T2V+VE Series Converter and N-2CCA-SC Control Card. The Input Cards, Converters and Control Cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified by a COT every 184 days, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The RTDs are not calibrated, and as such, instrument drift does not apply to these devices. Response of the RTDs to temperature variations during normal plant operation and during the more frequent testing verifies proper operation of the input signal. The flux input for this trip is derived from excore detectors that are calibrated to match the incore neutron detectors every 92 EFPD. The incore detectors are compared to a calorimetric every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined has been used in the development of, confirmation of, or revision to the current plant setpoint and the Technical CNP Units 1 and 2 Page 27 of 45 Attachment 1, Volume 8, Rev. 0, Page 70 of 818

Attachment 1, Volume 8, Rev. 0, Page 71 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Specification Allowable Values. The results of this analysis will support a 24 month Surveillance interval.

Functional Unit 8, Overpower T This function is performed by a loop consisting of a 200 Platinum RTD with the signal conditioned by Foxboro N-2AI-P2V and N-2AI-H2V Input Cards, and Foxboro N-2CCA-DC Control Cards performing the trip functions. This function utilizes a reactor power input from the Power Range Monitors that is conditioned by a Foxboro N-2AI-T2V+VE Series Converter and N-2CCA-SC Control Card.

The Input Cards, Converters and Control Cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified by a COT every 184 days, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The RTDs are not calibrated, and as such, instrument drift does not apply to these devices. Response of the RTDs to temperature variations during normal plant operation and during the more frequent testing verifies proper operation of the input signal. Although the reactor power input is available for input to this function, input value is set to zero and has no impact on trip operation. The results of this analysis will support a 24 month Surveillance interval.

Functional Unit 9, Pressurizer Pressure - Low This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip function. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Unit 10, Pressurizer Pressure - High This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip function. The signal conditioner and control card are part of the Foxboro Spec 200 Micro digital rack.

The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the CNP Units 1 and 2 Page 28 of 45 Attachment 1, Volume 8, Rev. 0, Page 71 of 818

Attachment 1, Volume 8, Rev. 0, Page 72 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Unit 11, Pressurizer Water Level - High This function is performed by a Foxboro (N-)E13 Series Differential Pressure Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip function. The signal conditioner and control card are part of the Foxboro Spec 200 Micro digital rack.

The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Unit 12, Loss of Flow - Single Loop This function is performed by a Foxboro (N-)E13 Series Differential Pressure Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval or the interval.

Functional Unit 13, Loss of Flow - Two Loops This function is performed by a Foxboro (N-)E13 Series Differential Pressure Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip function. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

CNP Units 1 and 2 Page 29 of 45 Attachment 1, Volume 8, Rev. 0, Page 72 of 818

Attachment 1, Volume 8, Rev. 0, Page 73 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Functional Unit 14, Steam Generator (SG) Water Level - Low Low This function is performed by a Foxboro (N-)E13 Series Differential Pressure Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval or the interval.

Functional Unit 15, Steam/Feedwater Flow Mismatch and Low Steam Generator Water Level This function is performed by Foxboro (N-)E13 Series Differential Pressure Transmitters with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip function. The signal conditioners and control cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval or the interval.

Functional Unit 17, Underfrequency - RCPs This function is performed by General Electric Model SFF99AE002A Underfrequency Relays. The Underfrequency Relays drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

P-6 Interlock This P-6 Interlock receives an input from the Intermediate Range Monitoring System. The function is performed by IRM Neutron Flux Detectors (Westinghouse Model WL-23707) and IRM Neutron Flux Drawers (Westinghouse Model 6051D46G01). These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the P-6 Interlock Function are verified by more frequent CHANNEL CHECKS every CNP Units 1 and 2 Page 30 of 45 Attachment 1, Volume 8, Rev. 0, Page 73 of 818

Attachment 1, Volume 8, Rev. 0, Page 74 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , COTs every 184 days, and an ACTUATION LOGIC TEST every 184 days. The IRMs are only required in MODE 1 below the P-10 interlock and in MODE 2 above the P-6 interlock. While operating in MODE 1, operation is normally above the P-10 interlock and the IRM trip is inactive. Also, before the IRM detectors are used for operation, an overlap check is routinely performed to determine if the instruments are reading and tracking with the power range and the source range neutron detectors, as applicable. Therefore, long term drift has no impact on the accuracy of this circuit. The results of these analyses will support a 24 month Surveillance interval.

P-7 Interlock The P-7 Interlock receives an input from the Power Range Neutron Monitoring System and the Turbine Impulse Pressure instrumentation. The Power Range Neutron Monitoring System portion of the Function is performed by the Westinghouse Top and Bottom Half Core Power Detectors and Top and Bottom Half Core Power Drawers (Westinghouse Models 6051D51 and 6051D53, respectively). These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the Power Range Neutron Monitoring System - P-7 Interlock Function are verified by more frequent CHANNEL CHECKS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , comparison tests between indicated power and calculated power (i.e., calorimetric verification) every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and COTs every 92 days. This testing ensures a significant portion of the circuitry is operating properly and accurately, and will detect significant failures of this circuitry. Additionally, since the flux measurement is evaluated and corrected on a daily basis by the calorimetric verification using high accuracy measurement devices, any drift associated with the circuit is normalized.

Therefore, long term drift has no impact on the accuracy of this portion of the Function. The Turbine Impulse Pressure portion of the Function (the P-13 interlock) is performed by a Foxboro E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip function. The Input Card and Control Card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated.

These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined has been used in the development of, confirmation of, or revision to the current plant setpoint. The results of these analyses will support a 24 month Surveillance interval.

P-8 Interlock The P-8 Interlock receives an input from the Power Range Neutron Monitoring System. This function is performed by the Westinghouse Top and Bottom Half Core Power Detectors and Top and Bottom Half Core Power Drawers (Westinghouse Models 6051D51G01 and 6051D53G01, respectively). These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the Power Range Neutron Monitoring CNP Units 1 and 2 Page 31 of 45 Attachment 1, Volume 8, Rev. 0, Page 74 of 818

Attachment 1, Volume 8, Rev. 0, Page 75 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION System - P-8 Interlock are verified by more frequent CHANNEL CHECKS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , comparison tests between indicated power and calculated power (i.e.,

calorimetric verification) every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and COTs every 92 days. This testing ensures a significant portion of the circuitry is operating properly and accurately, and will detect significant failures of this circuitry. Additionally, since the flux measurement is evaluated and corrected on a daily basis by the calorimetric verification using high accuracy measurement devices, any drift associated with the circuit is normalized. Therefore, long term drift has no impact on the accuracy of this Function. The results of these analyses will support a 24 month Surveillance interval.

P-10 Interlock The P-10 Interlock receives an input from the Power Range Neutron Monitoring System. This function is performed by the Westinghouse Top and Bottom Half Core Power Detectors and Top and Bottom Half Core Power Drawers (Westinghouse Models 6051D51G01 and 6051D53G01, respectively). These system components were not evaluated for drift but were justified for extension based on engineering judgment. Extension of this SR is acceptable because the operation of the circuits associated with the Power Range Neutron Monitoring System - P-10 Interlock are verified by more frequent CHANNEL CHECKS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , comparison tests between indicated power and calculated power (i.e.,

calorimetric verification) every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and COTs every 92 days. This testing ensures a significant portion of the circuitry is operating properly and accurately, and will detect significant failures of this circuitry. Additionally, since the flux measurement is evaluated and corrected on a daily basis by the calorimetric verification using high accuracy measurement devices, any drift associated with the circuit is normalized. Therefore, long term drift has no impact on the accuracy of this Function. The results of these analyses will support a 24 month Surveillance interval.

Based on the design of the instrumentation and the drift evaluations, it is concluded that the impact, if any, from this change on system availability is minimal. A review of the Surveillance test history was performed to validate the above conclusion. There were approximately 41 Intermediate Range and Power Range Monitor tests classified as failures. However, these tests were evaluated and the vast majority involved components found with out of tolerance calibration data. The other failures were reviewed and those failures did not invalidate the conclusion that the impact, if any, on system availability from this change is minimal. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.3.1.1.3 requires the RTS RESPONSE TIME of each reactor trip function to be demonstrated to be within limit at least once per 18 months. ITS SR 3.3.1.19 requires the same test at a 24 month Frequency.

This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace CNP Units 1 and 2 Page 32 of 45 Attachment 1, Volume 8, Rev. 0, Page 75 of 818

Attachment 1, Volume 8, Rev. 0, Page 76 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.3.1.1.3 is to ensure the actuation response times are less than or equal to the maximum values assumed in the accident analysis. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for the RTS RESPONSE TIME TEST is acceptable because the RTS instrumentation is verified to be operating properly throughout the operating cycle by the performance of CHANNEL OPERATIONAL TESTS and, in some cases, CHANNEL CHECKS.

This testing ensures that a significant portion of the RTS circuitry is operating properly and will detect significant failures of this circuitry. Additional justification for extending the Surveillance test interval is that the RTS, including the actuating logic, is designed to be single failure proof and therefore, is highly reliable.

Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.4 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 requires that when a Functional Unit 2 (Power Range Neutron Flux) channel is inoperable, CTS Table 3.3-1 Action 2 be entered. Action 2 requires, in part, the Power Range Neutron Flux trip setpoint to be reduced to 85% RTP within the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ITS 3.3.1 does not include this Required Action. This changes the CTS by deleting the requirement to reduce the Power Range Neutron Flux - High trip setpoint to 85% RTP.

The purpose of the CTS Actions is to ensure proper compensatory measures are taken in the event of an inoperable Power Range Neutron Flux channel is inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

The resetting of the Power Range Neutron Flux - High trip setpoints to

< 85% RTP would increase the potential for an inadvertent reactor trip and does CNP Units 1 and 2 Page 33 of 45 Attachment 1, Volume 8, Rev. 0, Page 76 of 818

Attachment 1, Volume 8, Rev. 0, Page 77 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION not provide significant additional assurance of safety. The ITS retains the requirement to place the inoperable channel in trip, which performs the intended function of the channel. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.5 (Category 2 - Relaxation of Applicability) CTS Table 3.3-1 requires Functional Units 2 (Power Range Neutron Flux) and 5 (Intermediate Range Neutron Flux) channels to be OPERABLE with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal, as stated in CTS Table 3.3-1 Note *. A similar Note is provided in CTS Table 4.3-1 for Functional Units 2 and 5. ITS Table 3.3.1-1 does not include this Applicability for either of these Functions (Functions 2.a, 2.b, and 4). This changes the CTS by deleting the requirements for OPERABILITY of the Power Range Neutron Flux and Intermediate Range Neutron Flux channels with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal.

The purpose of CTS Table 3.3-1 Functional Units 2 and 5 is to ensure the Power Range Neutron Flux and Intermediate Range Neutron Flux channels are OPERABLE. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. This change deletes the shutdown requirements for both the Power Range Neutron Flux and Intermediate Range Neutron Flux channels. The Source Range Neutron Flux channels are sufficient to mitigate any reactivity excursions in these conditions. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.6 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 requires that when a Functional Unit 19 (Safety Injection input from ESF) or a Functional Unit 22 (Automatic Trip Logic) train is inoperable, CTS Table 3.3-1 Action 1 be entered. CTS Table 3.3-1 Action 1 requires, in part, the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . In addition, this Action allows one channel to be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per CTS 4.3.1.1.1. CTS Table 3.3-1 requires that when a Functional Unit 2 (Power Range, Neutron Flux), Functional Unit 3 (Power Range, Neutron Flux, High Positive Rate), or Functional Unit 4 (Power Range, Neutron Flux, High Negative Rate) channel is inoperable, CTS Table 3.3-1 Action 2 be entered. CTS Table 3.3-1 Action 2 allows the inoperable channel be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing of the other channels per CTS 4.3.1.1.1. CTS Table 3.3-1 requires that when a Functional Unit 7 (Overtemperature T), Functional Unit 8 (Overpower T), Functional Unit 9 (Pressurizer Pressure - Low), Functional Unit 10 (Pressurizer Pressure -

High), Functional Unit 16 (Undervoltage - Reactor Coolant Pumps), or Functional Unit 17 (Underfrequency - Reactor Coolant Pumps) channel is inoperable, CTS Table 3.3-1 Action 6 be entered. CTS Table 3.3-1 Action 6 requires that the inoperable channel be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In addition, this Action allows the inoperable channel be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing of the other channels per CTS 4.3.1.1.1. CTS Table 3.3-1 requires that when a Functional Unit 11 (Pressurizer Water Level - High),

Functional Unit 12 (Loss of Flow - Single Loop), Functional Unit 13 (Loss of Flow CNP Units 1 and 2 Page 34 of 45 Attachment 1, Volume 8, Rev. 0, Page 77 of 818

Attachment 1, Volume 8, Rev. 0, Page 78 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION

- Two Loops), Functional Unit 14 (Steam Generator Water Level - Low Low),

Functional Unit 15 (Steam/Feedwater Flow Mismatch and Low Steam Generator Water), Functional Unit 18.A (Turbine Trip Low Fluid Oil Pressure), or Functional Unit 18.B (Turbine Trip Turbine Stop Valve Closure) channel is inoperable, CTS Table 3.3-1 Action 7 be entered. CTS Table 3.3-1 Action 7 requires, in part, the inoperable channel be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . No allowance is provided in this Action to allow an inoperable channel to be bypassed for surveillance testing. CTS Table 3.3-1 requires that when a Functional Unit 20 (Reactor Coolant Pump Breaker Position) channel is inoperable, CTS Table 3.3-1 Action 11 be entered. CTS Table 3.3-1 Action 11 requires the inoperable channel be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS Table 3.3.1-1 Functions 17 and 21 require entry into ITS 3.3.1 ACTION J if one Safety Injection Input from ESFAS train or one Automatic Trip Logic train is inoperable. ITS 3.3.1 ACTION J requires the restoration of the inoperable train to OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If the inoperable train cannot be restored to OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the unit must be in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (ITS 3.3.1 ACTION P). In addition, ITS 3.3.1 ACTION J includes an allowance to bypass one train for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE. ITS 3.3.1 ACTION C applies when one Power Range Neutron Flux - High channel (ITS 3.3.1 Function 2.a) is inoperable. ITS 3.3.1 ACTION C requires the placement of the inoperable channel in the trip condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and includes an allowance to bypass the inoperable channel for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing and setpoint adjustment of other channels. ITS 3.3.1 ACTION D applies when one channel is inoperable and applies to ITS 3.3.1 Functions 2.b, 3.a, 3.b, 6, 7, 8.a, 8.b, 9 through 15, 16.a, and 16.b. ITS 3.3.1 ACTION D requires the placement of the inoperable channel in the trip condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and includes an allowance to bypass the inoperable channel (except for the Function 11 channel) for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels. This changes the CTS by: a) allowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the CTS Table 3.3-1 Functional Units 19 and 22 trains to OPERABLE status prior to requiring a shutdown to MODE 3 and extends the bypass time for these Functional Units from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; b) extending the time allowed to place an inoperable channel in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for CTS Table 3.3-1 Functional Units 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18.A, 18.B, and 20; c) extending the time allowed to bypass an inoperable channel or train from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for CTS Table 3.3-1 Functional Units 2, 3, 4, 7, 8, 9, 10, 16, and 17; and d) adds an allowance to bypass the inoperable CTS Table 3.3-1 Functional Units 11, 12, 13, 14, 15, 18.A, and 18.B channels for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The purpose of the current Actions is to provide a short period of time to restore the inoperable channel or train to OPERABLE status. The proposed bypass time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in ITS 3.3.1 ACTIONS C, D, and J is a sufficient time to perform train or channel surveillance. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time period is acceptable since it is considered an acceptable amount of time based on the risk analysis of WCAP-10271-P, "Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System." The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time specified in ITS 3.3.1 ACTIONS C, D, and J is also acceptable since the change results in a small, and therefore acceptable, impact on plant risk as stated in the NRC Safety Evaluation Reports (SERs) associated with WCAP-10271-P. I&M has performed an evaluation to ensure that the conditions CNP Units 1 and 2 Page 35 of 45 Attachment 1, Volume 8, Rev. 0, Page 78 of 818

Attachment 1, Volume 8, Rev. 0, Page 79 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION of the three NRC SERs supporting WCAP-10271-P, including Supplements 1 and 2 and Supplement 2, Rev. 1, have been met for the proposed ITS Completion Time and/or bypass time. Specifically, the NRC imposed five conditions on utilities seeking to implement the Technical Specification changes approved generically as a result of their review of WCAP-10271 and WCAP-10271 Supplement 1, and two conditions as a result of their review of WCAP-10271 Supplement 2 and Supplement 2, Rev. 1. Two of the conditions imposed in the Reactor Trip System (RTS) SER are now not applicable due to approvals given in the ESFAS SER. Conditions given in the RTS SER are considered to apply equally to the ESFAS Functions and equipment, and the conditions given in the ESFAS SER are considered to apply equally to the RTS Functions and equipment. I&M provided results of this evaluation to the NRC by application dated August 30, 2002, as supplemented by letters dated February 27, April 7, April 29, and May 2, 2003, that requested approval for increasing the CHANNEL OPERATIONAL TEST Surveillance intervals for analog channels, logic cabinets, and reactor trip breakers, and increasing the Completion Time and bypass time for the reactor trip breakers, as allowed by WCAP-15376-P, Rev. 0, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," and the Nuclear Regulatory Commission (NRC) staffs approved Technical Specification Task Force (TSTF) Traveler TSTF-411, Rev. 1, "Surveillance Test Interval Extension for Components of the Reactor Protection System." The NRC granted approval for these new requirements based upon WCAP-15376 by issuing License Amendments 277 (Unit 1) and 260 (Unit 2) on May 23, 2003. In the NRC SER for these amendments, the NRC stated that the December 20, 2002, acceptance letter for WCAP-15376 noted that this topical report was built on the foundation established by WCAP-10271-P and WCAP-14333, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times." As a result, the NRC staffs review of I&Ms application, as supplemented, verified that the applicable implementation requirements associated with the NRC staff acceptance of WCAP-10271 was also adequately addressed by I&M. Therefore, this change is considered acceptable. 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.7 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 Action 7 states, in part, that with the number of OPERABLE channels one less than the total number of channels, startup and power operation may proceed "until performance of the next required CHANNEL FUNCTIONAL TEST." This CTS Action applies to CTS Table 3.3-1 Functional Units 11 through 15, 18.A, and 18.B. ITS 3.3.1 ACTION D is the applicable ACTION for the above Functions when one channel is inoperable, and does not include the restoration time limit of "until performance of the next required CHANNEL FUNCTIONAL TEST." This changes the CTS by allowing operation with an inoperable channel for an unlimited amount of time provided the inoperable channel is in the tripped condition.

The purpose of CTS Table 3.3-1 Action 7 is to only allow operation until performance of the next required CHANNEL FUNCTIONAL TEST. This requirement is based upon the assumption that when it is time to test the other OPERABLE channels in the associated Function, the OPERABLE channels CNP Units 1 and 2 Page 36 of 45 Attachment 1, Volume 8, Rev. 0, Page 79 of 818

Attachment 1, Volume 8, Rev. 0, Page 80 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION cannot be tested with the inoperable channel in trip. However, CTS 3.0.6 (ITS LCO 3.0.5) is a generic allowance that will allow the inoperable channel to be restored to service in order to perform Surveillances on the other OPERABLE channels in the associated Function. Thus, using this generic allowance, it is possible to test the remaining OPERABLE channels in the associated Function and there is no reason to restrict the generic allowance from applying to these specific channels. As such, the CTS Table 3.3-1 Action 7 statement is not necessary and has been deleted. The administrative controls required by ITS LCO 3.0.5 will ensure the time the channel is returned to service in conflict with the requirements of ITS 3.3.1 ACTION D is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY of the other channels. In addition, this specific example (taking an inoperable channel out of the tripped condition) is discussed in the Bases of ISTS SR 3.0.5.

Therefore, this change is acceptable for the above described reasons. 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.8 (Category 4 - Relaxation of Required Action) CTS LCO 3.3.1.1 states that the interlocks of Table 3.3-1 shall be OPERABLE. However, no specific Actions are provided for when an interlock is inoperable. Therefore, all affected RTS instrumentation is required to be declared inoperable, which will result in a CTS 3.0.3 entry. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and then requires the unit to be in MODES 3, 4, and 5 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , respectively. ITS 3.3.1 ACTION L provides the actions for when one or more interlock channels are inoperable. ACTION L requires a verification that the interlock is in the required state for existing unit conditions within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS 3.3.1 ACTIONS O, P, and Q, which are applicable if any Required Action and associated Completion Time of Condition L is not met, requires the unit to be placed in MODE or other specified condition outside the Applicability of the associated interlock. This changes the CTS by allowing continued operation as long as the interlock is placed in the correct state and providing actions if the inoperable interlock is not placed in the correct state.

The purpose of the interlocks is to ensure the associated RTS instrumentation is automatically enabled or disabled when required. This change is acceptable since the proposed ACTIONS ensure that the interlock is either manually placed in the correct state for the existing unit conditions or that the unit is placed in a MODE or specified Condition outside the Applicability of the associated interlock.

ITS 3.3.1 Required Action L.1 requires the interlock to be placed in the same state as it would be normally placed in if it were automatically functioning (i.e.,

this performs the intended function of the interlock). If this Required Action is not accomplished within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then ITS 3.3.1 ACTIONS O, P, and Q will require the unit to be placed in a MODE or specified condition that is outside the Applicability of the associated interlock. The Required Actions and Completion Times for placing the unit in the MODES or specified conditions outside the Applicabilities of the interlocks are consistent with the Required Actions and Completion Times associated with exiting the Applicabilities for RTS Instrumentation Functions supported by the interlocks. With the unit placed in a MODE or specified condition that is outside the Applicability of the associated interlock, the interlock is no longer required to function to support the required OPERABILITY of the associated RTS Instrumentation Function. This change is designated as less CNP Units 1 and 2 Page 37 of 45 Attachment 1, Volume 8, Rev. 0, Page 80 of 818

Attachment 1, Volume 8, Rev. 0, Page 81 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.9 (Category 4 - Relaxation of Required Action) With one Intermediate Range Neutron Flux channel inoperable, CTS Table 3.3-1 Action 3.b requires, when above the P-6 interlock and below 5% of RTP, the restoration of the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above 5% RTP. ITS 3.3.1 ACTION E, which provides the actions when one Intermediate Range Neutron Flux channel is inoperable, provides two optional Required Actions. Required Action E.1 requires the reduction of THERMAL POWER to < P-6 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , while Required Action E.2 requires the increase of THERMAL POWER to > P-10 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by allowing the unit to change power level to exit the MODE of Applicability instead of requiring the restoration of the equipment.

The purpose of CTS Table 3.3-1 Action 3.b is to ensure the appropriate actions are taken when an Intermediate Range Neutron Flux channel is inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The Intermediate Range Neutron Flux channels are required to mitigate events within the proposed Applicability of above the P-6 interlock and below the P-10 interlock. While the unit is within the Applicability of the LCO, the other Intermediate Range Neutron Flux channel can perform the required safety function. With the unit outside the proposed Applicability of the equipment, the equipment is not credited in any transient. Other instrumentation is available to mitigate the consequences of a transient event. 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.10 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.3-1, including Note 1, require the performance of CHANNEL FUNCTIONAL TEST for Functional Units 18.A (Turbine Trip - Low Fluid Oil Pressure) and 18.B (Turbine Trip - Turbine Stop Valve Closure) channels prior to each reactor startup if not performed in previous 7 days.

ITS Table 3.3.1-1, Functions 16.a and 16.b require the performance of a TADOT (ITS SR 3.3.1.18) prior to exceeding the P-7 interlock whenever the unit has been in MODE 3, if not performed within the previous 31 days. This changes the CTS by extending the requirement to perform the test from "if not performed within the previous 7 days" to "if not performed within the previous 31 days."

The purpose of the CHANNEL FUNCTIONAL TEST/TADOT is to ensure the instrumentation is functioning properly. This changes the CTS by extending the requirement to perform the test from "if not performed within the previous 7 days" to "if not performed within the previous 31 days." Currently this Surveillance is only required to be performed prior to each reactor startup. During a normal CNP Units 1 and 2 Page 38 of 45 Attachment 1, Volume 8, Rev. 0, Page 81 of 818

Attachment 1, Volume 8, Rev. 0, Page 82 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION cycle, the unit is in MODE 1 for a time period in excess of 31 days and the Surveillance is not performed. A review of maintenance history has shown that when the Surveillance is performed after an extended time period in MODE 1 (i.e., > 31 days), the Surveillance normally passes. Thus, allowing the reactor startup to proceed without performing the Surveillance if the Surveillance has been performed within the previous 31 days versus the current 7 days is acceptable. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.11 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS Table 4.3-1 Functional Unit 20 requires the performance of a CHANNEL FUNCTIONAL TEST on the Reactor Coolant Pump Breaker Position Trip channels every 18 months. CTS Table 4.3-1 Functional Unit 19 requires the performance of a CHANNEL FUNCTIONAL TEST on the Safety Injection Input from ESF (Manual ESF functional input check) every 18 months.

ITS Table 3.3.1-1 Functions 11 and 17 require the performance of ITS SR 3.3.1.17, a TADOT, every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2). The change from a CHANNEL FUNCTIONAL TEST to a TADOT is discussed in DOC A.20.

The purpose of the CHANNEL FUNCTIONAL TEST required by CTS Table 4.3-1 is to ensure the RTS instrumentation can perform its intended function. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval associated with the Reactor Coolant Pump Breaker Position Trip is acceptable since the RTS Instrumentation includes redundant instrumentation to monitor Reactor Coolant Flow (i.e., Loss of Flow - Single Loop, Loss of Flow - Two Loops, Underfrequency - Reactor Coolant Pump, Undervoltage - Reactor Coolant Pump). Extending the Surveillance interval for the Safety Injection Input from ESF is also acceptable since redundant trains exist. Based on the inherent system and component reliability, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.12 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 Functional Unit 1 specifies the requirements for the Manual Reactor Trip channels. The CTS requirement specifies that Action 12 applies with the number of channels CNP Units 1 and 2 Page 39 of 45 Attachment 1, Volume 8, Rev. 0, Page 82 of 818

Attachment 1, Volume 8, Rev. 0, Page 83 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION OPERABLE one less than required by the minimum channels OPERABLE requirement. CTS Table 3.3-1 Action 12 requires the restoration of the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or to be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and/or open the reactor trip breakers. ITS Table 3.3.1-1 Function 1 requires entry in ITS 3.3.1 ACTION B if a required channel is inoperable. ITS 3.3.1 Required Action B.1 requires restoration of the channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . If this cannot be met in MODE 1 and 2, ACTION P must be entered and Required Action P.1 requires the unit to be in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If the inoperable channel cannot be restored to OPERABLE status in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted, ACTION Q must be entered and Required Action Q.1 requires the immediate initiation of action to fully insert all rods and Required Action Q.2 requires the Rod Control System to be in a condition incapable of rod withdrawal within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This changes the CTS by not specifically requiring the reactor trip breakers to be opened and providing 1 additional hour to ensure the Rod Control System is incapable of rod withdrawal.

The purpose of CTS Table 3.3-1 Action 12 is allow time to restore an inoperable channel and if not, to place the unit in a condition where the equipment is not required to be OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change deletes the requirement to open the reactor trip breakers. The proposed Required Action ensures the unit is outside of the Applicability of the Manual Reactor Trip channels. The Required Actions require immediate action to insert all rods and, once inserted, the Rod Control System must be placed in a condition incapable of rod withdrawal within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , which is the purpose of opening the reactor trip breakers. This is normally performed by opening the reactor trip breakers. 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.13 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 Functional Units 21 (Reactor Trip Breakers) and 22 (Automatic Trip Logic) specifies that Action 14 applies with the number of channels OPERABLE one less than required by the minimum channels OPERABLE requirement when in MODES 3, 4, and 5 with the reactor trip breakers closed and the rod control system capable of rod withdrawal. CTS Table 3.3-1 Action 14 requires the restoration of the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months "or open the reactor trip breakers within the next hour." In the ITS for the same Functions, if an inoperable channel/train is not restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months as specified in ITS 3.3.1 ACTION B, then ITS 3.3.1 ACTION Q must be entered.

ITS 3.3.1 Required Actions Q.1 and Q.2 require the unit to initiate action to fully insert all rods immediately and to place the Rod Control System in a condition CNP Units 1 and 2 Page 40 of 45 Attachment 1, Volume 8, Rev. 0, Page 83 of 818

Attachment 1, Volume 8, Rev. 0, Page 84 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION incapable of rod withdrawal within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This changes the CTS by not requiring the reactor trip breakers to be opened.

The purpose of CTS Table 3.3-1 Action14 is allow time to restore an inoperable channel and if this cannot be accomplished to place the unit in a condition where the equipment is not required to be OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change deletes the requirement to open the reactor trip breakers. The proposed Required Action ensures the unit is outside of the Applicability of the Reactor Trip Breaker and Automatic Trip Logic Functions. The actions require immediate action to insert all rods which is the purpose of opening the reactor trip breakers. Once inserted, the Rod Control System is placed in a condition incapable of rod withdrawal within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This is normally performed by opening the reactor trip breakers. 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.14 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.3-1 Functional Unit 1, including Note 1, requires the performance of a CHANNEL FUNCTIONAL TEST of the Manual Reactor Trip Function prior to each reactor startup if not performed in the previous 7 days.

CTS Table 4.3-1 Functional Unit 23, including Note 1, requires the performance of a CHANNEL FUNCTIONAL TEST of each Reactor Trip Bypass Breaker prior to each reactor startup if not performed in the previous 7 days. ITS SR 3.3.1.17 requires these tests to be performed every 24 months. This changes the CTS by changing the Surveillance Frequency from prior to each reactor startup if not performed in the previous 7 days to 24 months.

The purpose of the CTS Table 4.3-1 CHANNEL FUNCTIONAL TEST requirement is to ensure the Manual Reactor Trip and the Reactor Trip Bypass Breaker Functions are OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. If a unit operates a complete cycle without requiring a shutdown, this Surveillance will only be performed once per cycle (approximately 18 months). Testing these channels once per cycle is considered acceptable. A review of the Surveillance test history for the Manual Reactor Trip and Reactor Trip Bypass Breaker Functions indicates that an extension to 24 months is acceptable. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.15 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.3-1 Functional Unit 2, including Note 3, requires a monthly comparison of the incore to excore axial imbalance above 15% of RATED THERMAL POWER and that recalibration is necessary if the absolute CNP Units 1 and 2 Page 41 of 45 Attachment 1, Volume 8, Rev. 0, Page 84 of 818

Attachment 1, Volume 8, Rev. 0, Page 85 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION difference is greater than or equal to 3 percent. ITS Table 3.3.1-1, Function 2.a requires the performance of this same test (ITS SR 3.3.1.3); however, the Frequency has been changed to 31 effective full power days (EFPD). This changes the CTS by allowing this Surveillance to be performed every 31 EFPD instead of 31 days.

The purpose of the ITS SR Frequency expressed in EFPD is to relate the requirement to a meaningful time frame. This change is acceptable because the new Surveillance Frequency has been evaluated and has been shown to provide an acceptable level of equipment reliability. The allowance for performing the comparison of the NIS channels indications to the incore indications are a function of burn up and not calendar days. The relationship of incore to excore measurement changes with the burnup of the fuel in the reactor, and depends upon power distribution in the reactor core. The burnup of the fuel is not a function of calendar days, but of total power produced by the reactor. A Frequency stated in EFPD is the appropriate unit for the Surveillance Frequency.

This change is designated as less restrictive because Surveillances may be performed less frequently under the ITS than under the CTS.

L.16 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.3-1 Functional Unit 2 (Power Range Neutron Flux),

including Note 1, requires the performance of a CHANNEL FUNCTIONAL TEST during startup if not performed in previous 7 days. CTS Table 4.3-1 Functional Unit 6 (Source Range Neutron Flux), including Note 1, requires the performance of a CHANNEL FUNCTIONAL TEST during startup if not performed in previous 7 days. CTS Table 4.3-1 Functional Unit 21 (Reactor Trip Breakers, Shunt Trip and Undervoltage Trip), including Note 1, requires the performance of a CHANNEL FUNCTIONAL TEST during startup if not performed in previous 7 days. The ITS does not require these during startup if not performed in the previous 7 days tests. This changes the CTS by deleting the requirement to perform the startup Surveillance on the Power Range Neutron Flux, Source Range Neutron Flux, and Reactor Trip Breakers, including the Shunt and Undervoltage trip channels.

The purpose of the CTS Table 4.3-1 CHANNEL FUNCTIONAL TEST is to ensure the RTS instrumentation is functioning properly. This change is acceptable because the normal periodic CHANNEL FUNCTIONAL TEST (changed to COT or TADOT per DOC A.20) Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

This change deletes the requirement to perform the startup Surveillance on the Power Range Neutron Flux, Source Range Neutron Flux, and Reactor Trip Breakers, including the Shunt Trip and Undervoltage trip channels. ITS SR 3.0.4 requires the normal periodic Surveillances to be performed and be current prior to entry into the applicable operational conditions. Once the applicable conditions are entered, the normal, periodic Surveillance Frequency provides adequate assurance of OPERABILITY. Therefore, the removal of this Frequency is considered acceptable. 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 42 of 45 Attachment 1, Volume 8, Rev. 0, Page 85 of 818

Attachment 1, Volume 8, Rev. 0, Page 86 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION L.17 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.3-1 Functional Unit 6 requires the performance of a CHANNEL FUNCTIONAL TEST every 31 days. This Surveillance is modified by a Note (CTS Table 4.3-1 Note 14), which states that the provisions of Specification 4.0.4 are not applicable when leaving MODE 1 and shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after leaving MODE 1. ITS Table 3.3.1-1 Function 5 requires the performance of a COT (ITS SR 3.3.1.10) at a Frequency of 184 days. This Surveillance is modified by a Note (Note 2) that states that the Surveillance is not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after power is below the P-6 interlock. This changes the CTS by changing the point at which the required completion time begins (leaving MODE 1 in the CTS and power below P-6 in the ITS) to perform the Surveillance, and reduces the time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) to perform the Surveillance after reaching that point. The change from a CHANNEL FUNCTIONAL TEST to a COT is discussed in DOC A.20 and the change in the Frequency is discussed in DOC L.18.

The purpose of CTS Table 4.3-1 Note 14 is to allow time for the Surveillance to be performed after power is reduced to the conditions where the equipment is required to function. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Since the Applicability of the Source Range Neutron Flux channels is below P-6, this interlock is a more convenient reference point since instrument panels in the Control Room indicate when the condition has been met. The unit leaves MODE 1 when it reaches 5% RTP. The nuclear instrumentation available in the control room is not as accurate at this THERMAL POWER level, and it is therefore difficult to determine when the unit actually leaves MODE 1. This change modifies the point at which the required completion time begins (leaving MODE 1 in the CTS and power below P-6 in the ITS) to perform the Surveillances and reduces the time allowed (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) to perform the Surveillance after reaching that point. The change is considered less restrictive since the point at which the required completion time begins is reduced to a lower power level, and the actual time to reach the P-6 interlock point could be greater than 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . This change is designated as less restrictive because Surveillances may be performed less frequently under the ITS than under the CTS.

L.18 (Category 9 - Surveillance Frequency Change Using GL 91-04 Guidelines, Non-24 Month Type Change) CTS Table 4.3-1 requires a CHANNEL FUNCTIONAL TEST of Functional Units 6 (Source Range Neutron Flux), 16 (Undervoltage -

Reactor Coolant Pumps), and 17 (Underfrequency - Reactor Coolant Pumps) instrumentation every 31 days. ITS SR 3.3.1.10 requires the performance of a COT for the Source Range Neutron Flux instrumentation every 184 days and ITS SR 3.3.1.11 requires the performance of a TADOT for the Undervoltage RCPs and Underfrequency RCPs instrumentation every 184 days. This changes the CTS by extending the Frequency of the Surveillance from 31 days (i.e., a maximum of 38.75 days accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 184 days (i.e., a maximum of 230 days accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2). The change from a CHANNEL FUNCTIONAL TEST to a COT or TADOT is discussed in DOC A.20.

CNP Units 1 and 2 Page 43 of 45 Attachment 1, Volume 8, Rev. 0, Page 86 of 818

Attachment 1, Volume 8, Rev. 0, Page 87 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION The purpose of the CHANNEL FUNCTIONAL TEST requirement in CTS Table 4.3-1 is to ensure the channels of the Source Range Neutron Flux, Undervoltage - Reactor Coolant Pumps, and Underfrequency - Reactor Coolant Pumps Functions will function as designed during an analyzed event. An evaluation of the surveillance interval extension was performed, based on the same approach described in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for this COT and TADOT is acceptable because for the Undervoltage RCPs and Underfrequency RCPs trips, the probability of significant variations of the RCP pump power supply is remote due to the plant electrical system and the offsite grid reliability, and for the Source Range Neutron Flux trip, the source range monitors are always checked prior to use and overlap is confirmed between the source and intermediate range monitors during startup and shutdown. During operations where the Source Range Neutron Flux trip is required, a significant change in detected power level would be noticed and investigated by plant operators. Based on the inherent system and component reliability the impact, if any, from this change on system availability is minimal.

The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 184 day Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (230 days) does not invalidate any assumptions in the plant licensing basis.

This change is designated as less restrictive because Surveillances may be performed less frequently under the ITS than under the CTS.

L.19 (Category 14 - Changing Instrumentation Allowable Values) CTS Table 2.2-1 provides the Allowable Values for Functional Unit 7 (Overtemperature T),

Functional Unit 8 (Overpower T) (Unit 1 only), Functional Unit 9 (Pressurizer Pressure - Low) (Unit 2 only), Functional Unit 10, (Pressurizer Pressure - High),

Functional Unit 11 (Pressurizer Water Level - High), Functional Unit 13, (Steam Generator Water Level - Low Low) (Unit 1 only), Functional Unit 14 (Steam/Feedwater Flow Mismatch and Steam Generator Water Level - Low)

(Steam Generator Water Level - Low portion only is covered by this change)

(Unit 1 only), and Functional Unit 16 (Underfrequency - Reactor Coolant Pumps)

(Unit 2 only). ITS Table 3.3.1-1 provides the Allowable Values for all the RTS Instrumentation Functions, including ITS Table 3.3.1-1 Function 6, 7, 8.a, 8.b, 9, 13, 14, and 15. This change revises the above specified CTS RTS Table 2.2-1 Allowable Values to the ITS Allowable Values.

The purpose of the Allowable Values is to ensure the instruments function as assumed in the safety analyses. ITS 3.3.1 reflects Allowable Values consistent with the philosophy of Westinghouse ISTS, NUREG-1431. These Allowable Values have been established consistent with the methods described in I&M's Instrument Setpoint Methodology (EG-IC-004, "Instrument Setpoint Uncertainty,"

Rev. 4). For all cases where a SAL exists, the Allowable Value determinations were calculated using plant specific operating and Surveillance trend data. For all other cases, existing Allowable Values were converted directly to the ITS CNP Units 1 and 2 Page 44 of 45 Attachment 1, Volume 8, Rev. 0, Page 87 of 818

Attachment 1, Volume 8, Rev. 0, Page 88 of 818 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Allowable Values. The Allowable Value verification used actual plant operating and surveillance trend information to ensure the validity of the developed Allowable Value. There were no changes to SALs required due to instrument performance. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ANSI/ISA S67.04-Part I-1994 and ANSI/ISA RP67.04-Part II-1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for each SAL have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy using the instrument setpoint methodology. The Allowable Values have also been established from each SAL by combining the errors associated with the COT (e.g., device accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint using the instrument setpoint methodology. Where a SAL exists, trigger values are used to ensure that the Allowable Value provides sufficient margin from the SAL to account for any associated errors not confirmed by the COT. Use of the previously discussed methodologies for determining Allowable Values, NTSPs, and analyzing channel/instrument performance ensure that the design basis and associated SALs will not be exceeded during plant operation. These evaluations, determinations, and analyses now form a portion of the CNP design bases. Additionally, each applicable channel/instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These drift evaluations and drift analyses have been performed utilizing the guidance provided in EPRI TR-103335, "Statistical Analysis of Instrument Calibration Data/ Guidelines for Instrument Calibration Extension/Reduction Programs," Rev. 1. The EPRI guidance was used to demonstrate that the data collected by the operating plant (from Surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Therefore, based on the above discussion, the changes to the Allowable Values are acceptable. This change is designated as less restrictive because the less stringent Allowable Values are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 45 of 45 Attachment 1, Volume 8, Rev. 0, Page 88 of 818

Attachment 1, Volume 8, Rev. 0, Page 89 of 818 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 104 of 818 8

INSERT 4 Table 4.3-1 SR 3.3.1.9 ----------------------------------------------------------

Function 2, -NOTE-including Note Neutron detectors are excluded from 6

CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. 92 days 9 INSERT 5

1. For Function 4, not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is below the P-10 interlock.

2 For Function 5, not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after THERMAL POWER is below the P-6 interlock.

8 INSERT 5A Table 4.3-1 Function 16, SR 3.3.1.12 Perform CHANNEL CALIBRATION. 184 days DOC M.16 Insert Page 3.3.1-10 Attachment 1, Volume 8, Rev. 0, Page 104 of 818

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2. Normalization of the T is not required to be performed until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after THERMAL POWER is > 98% RTP.

22 INSERT 7 The automatic portion of the SI Input from ESFAS Function is excluded from the TADOT.

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Attachment 1, Volume 8, Rev. 0, Page 114 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION

1. ISTS 3.3.1 ACTIONS B, C, D, E, J, K, L, M, N, O, P, Q, and R provide Required Actions and associated Completion Times for various RTS instrumentation inoperabilities. Each of these ACTIONS include Required Actions to either trip a channel or restore a channel to OPERABLE status (depending on the associated RTS Instrumentation Function). Each of these ACTIONS also include Required Actions that require placing the unit outside the applicable MODE or condition of the associated RTS Instrumentation Function (i.e., default Required Action). In each of these ACTIONS, the Required Actions to restore or trip the affected channels are connected to the default Required Action by the logical connector OR. The Completion Times for the Required Actions to restore or trip affected channels are inconsistent with the Completion Times for the default Required Actions. This presentation is inconsistent with the format and convention used in all but one other specification in ISTS 3.3, all other sections of the ISTS, and other NSSS vendor ISTS (e.g., NUREG-1433, Revision 2 and NUREG-1434, Revision 2). This presentation can also cause confusion with respect to the correct application of the requirements of ISTS Section 3.0, "LCO Applicability." For example, ISTS LCO 3.0.4 includes an exception that allows entry into an applicable MODE or other specified condition when an LCO is not met if the ACTIONS permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.

However, with an ACTION that includes both the Required Action to trip a channel and the default Required Action to exit the applicable MODE, it could be argued that this ACTION would not allow continued operation. Therefore, these ACTIONS have been revised or deleted to eliminate the default Required Actions from the ACTIONS with Required Actions to restore or trip the affected channels. As a result, additional ACTIONS (ITS 3.3.1 ACTIONS N, O, P, and Q) have been added, which include the default Required Actions consistent with placing the unit outside the applicable MODE or other specified condition of the associated RTS Instrumentation Function.

In addition, ISTS ACTIONS K, L, and M have been incorporated in ITS ACTION D since the bypass time and Completion Times are the same. Subsequent Conditions and Required Actions have been renumbered, as necessary.

2. ISTS 3.3.1 Functions 1 (Manual Reactor Trip), 19 (Reactor Trip Breakers (RTBs), 20 (Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms), and 21 (Automatic Trip Logic) during shutdown conditions require entry into ISTS 3.3.1 ACTION C.

ISTS 3.3.1 ACTION C has been deleted based on the discussion in JFD 1 above.

Since the Required Action and associated Completion Time of ISTS 3.3.1 Required Actions B.1 and C.1 are similar, ITS Table 3.3.1-1, for Functions 1, 19, 20, and 21, has been revised to require entry into ITS 3.3.1 ACTION B, instead of ISTS 3.3.1 ACTION C. Since ISTS 3.3.1-1 Functions 19 and 21 require 2 trains to be OPERABLE, ISTS 3.3.1 ACTION B (ITS 3.3.1 ACTION B) has been revised to address an inoperable train.

3. The ISTS 3.3.1 ACTION E Note (ITS 3.3.1 ACTION D Note) has been modified to exclude Function 11 channels. This change is necessary since the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months bypass time is not supported by WCAP-10271-A for the Function 11 channels.

4. ISTS 3.3.1 ACTION D (ITS 3.3.1 ACTION C) provides requirements for an inoperable Power Range Neutron Flux - High channel. ISTS 3.3.1 Required Actions D.1.2 , D.2.1, and D.2.2 include requirements that are duplicative of the requirements in the Surveillance Requirements for ISTS 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)" (ITS 3.2.4). In addition, the inoperability of the RTS CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 8, Rev. 0, Page 114 of 818

Attachment 1, Volume 8, Rev. 0, Page 115 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION Power Range Neutron Flux - High channel does not necessarily result in the Power Range Neutron Flux Monitor being inoperable such that QPTR cannot be determined. Therefore, ITS 3.3.1 ACTION D has been revised to delete the duplicative requirements.

5. The ISTS 3.3.1 ACTIONS NOTE has been revised to allow separate Condition entry for certain Functions specified on a loop or steam generator basis. This change is acceptable since the channels associated with each loop or steam generator, as applicable, will provide the associated RTS trip based on the logic associated with the channels on the specified basis. This change has been made to be consistent with the allowances specified in the Bases for ISTS 3.3.2 for similar type Functions and the modified ACTIONS Note in ITS 3.3.2.

6. TSTF-286, Rev. 2, was approved by the NRC on April 13, 2000. When NUREG-1431, Rev. 2, was issued, this TSTF was incorporated, but included a typographical error. Therefore, this change corrects the typographical error to be consistent with the approved TSTF-286, Rev. 2.

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

8. ITS SR 3.3.1.6 (Perform TADOT once per 92 days on a STAGGERED TEST BASIS), SR 3.3.1.9 (Perform CHANNEL CALIBRATION once per 92 days) and ITS SR 3.3.1.12 (Perform CHANNEL CALIBRATION once per 184 days) have been added to ISTS 3.3.1 to be consistent with the CNP Units 1 and 2 CTS. Subsequent SRs have been renumbered, as necessary. In addition, an ACTUATION LOGIC TEST (ITS SR 3.3.1.5) has been added for the RTS Interlock Functions (ITS Table 3.3.1-1 Functions 18.a through e) and an RTS RESPONSE TIME test (ITS SR 3.3.1.19) has been added for ITS Table 3.3.1-1 Function 17 (SI Input From ESFAS), consistent with the current licensing basis requirements. The addition of ITS SR 3.3.1.5 for Function 18.b is also consistent with approved TSTF-347.

However, the deletion of the other two SRs of Function 18.b has not been adopted, since the SRs are required for OPERABILITY of Function 18.b.

9. The Notes in ISTS SR 3.3.1.7 and ISTS SR 3.3.1.8 provide allowances to enter the applicable MODES or other specified conditions without having performed the required COT. The allowances of these ISTS Notes have been incorporated into the ITS SR for performance of a COT only for the intermediate range and source range neutron flux instrumentation (ITS SR 3.3.1.10, Notes 1 and 2). The allowances for the power range neutron flux instrumentation are not needed. A similar Note has also been provided for ISTS SR 3.3.1.12 (ITS SR 3.3.1.15) for ITS Table 3.3.1-1 Function 6 (Overtemperature T) and Function 7 (Overpower T), to reflect the CNP Units 1 and 2 CTS allowances and current practice.

10. The Note to ISTS SR 3.3.1.8 (ITS SR 3.3.1.10) associated with the verification that the P-6 and P-10 are in their required state for existing unit conditions has been deleted consistent with the CNP Units 1 and 2 CTS. This change is acceptable since these verifications are made more frequently since status of the interlocks is available in the control room. In addition, this type of verification is not normally part of a COT.

CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 8, Rev. 0, Page 115 of 818

Attachment 1, Volume 8, Rev. 0, Page 116 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION

11. A Note to ISTS SR 3.3.1.10 requires the CHANNEL CALIBRATION to include verification that time constants are adjusted to the prescribed values.

ITS SR 3.3.1.13 does not include this Note since it does not apply to any ITS Table 3.3.1-1 Functions that include time constants.

12. The Nominal Trip Setpoint column has been deleted as allowed by the Reviewers Note at the end of ISTS Table 3.3.1-1. This Reviewers Note allows the unit specific implementation to contain only the Allowable Value. The nominal trip setpoints for each of the applicable ITS Table 3.3.1-1 Functions will be controlled in accordance with the Note in the ISTS 3.3.1 Bases Background section.

13. ISTS SR 3.3.1.16 (ITS SR 3.3.1.19) requires verification that RTS RESPONSE TIME is within limits. This requirement has been deleted from ITS Table 3.3.1-1 Functions 3.b (Power Range Neutron Flux Rate - High Negative Rate), 5 (Source Range Neutron Flux), and 15 (SG Water Level - Low Coincident with Steam Flow/Feedwater Flow Mismatch) and has been added to Function 9 (Pressurizer Water Level - High). These changes are made to achieve consistency with the CNP Units 1 and 2 current licensing basis reflected in UFSAR Table 7.2-6.

14. ISTS SR 3.3.1.3 (ITS SR 3.3.1.3), which requires the comparison of results of the incore detector measurements to NIS AFD, has been added to the Surveillance Requirements for ITS Table 3.3.1-1 Function 2.a (Power Range Neutron Flux - High) and deleted from the Surveillance Requirements for Function 6 (Overtemperature T). These changes are made to achieve consistency with the CNP Units 1 and 2 CTS.

15. The Footnotes which modify the Applicability of ISTS Table 3.3.1-1 (ITS Table 3.3.1-1) Functions 8.a (Pressurizer Pressure - Low), 10 (Reactor Coolant Flow - Low), and 11 (Reactor Coolant Pump (RCP) Breaker Position) have been revised to be consistent with the CNP Units 1 and 2 current design and licensing basis. As a result of this change, ISTS Table 3.3.1-1 Footnotes (f) and (g) are deleted since they are not used. In addition, ISTS Table 3.3.1-1 Functions 11.a (Reactor Coolant Pump (RCP) Breaker Position Single Loop) and 11.b (Reactor Coolant Pump (RCP) Breaker Position Two Loop) requirements are revised into a single requirement (ITS Table 3.3.1-1 Function 11) to be consistent with the CNP Units 1 and 2 current design and licensing basis. Subsequent footnotes are renumbered, as necessary.

16. Editorial changes made for enhanced clarity or to be consistent with the Writers Guide for the Improved Standard Technical Specifications, NEI 01-03.

17. The Applicability for the RTS P-6 Interlock Function has been revised to be consistent with the Functions it supports. The P-6 interlock prevents or defeats the manual block of the Source Range Neutron Flux reactor trip. The logic is such that both channels are required to defeat the block of the Source Range Neutron Flux reactor trip. Therefore, if any one of the two interlock channels are inoperable and not in the correct state, the Required Action should be consistent with ACTIONS for when two Source Range Neutron Flux reactor trip channels are inoperable.

Therefore ISTS 3.3.1 Required Action P.2 (ITS 3.3.1 Required Actions Q.1 and Q.2) has been changed to reflect exiting the applicable MODE or other specified condition.

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Attachment 1, Volume 8, Rev. 0, Page 117 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION

18. The P-9 Interlock Function and Footnotes referencing the P-9 Interlock Function have been deleted since the interlock does not apply to the RTS Instrumentation.

The Applicable Modes for ITS Table 3.3.1-1 Functions 16.a (Turbine Trip - Low Fluid Oil Pressure) and 16.b (Turbine Trip - Turbine Stop Valve Closure) have been corrected as necessary to reflect the unit design. Subsequent Functions and Footnotes have been renumbered, as necessary.

19. The Reviewers Note has been deleted since it is not intended to be included in the ITS.

20. Changes to the ISTS Table 3.3.1-1 (ITS Table 3.3.1-1) Note 1 (the Overtemperature T Allowable Value) and Note 2 (Overpower T Allowable Value) have been made to be consistent with the CNP Units 1 and 2 CTS.

21. ISTS SR 3.3.1.14 (ITS SR 3.3.1.17) requires the performance of a TADOT for ISTS Table 3.3.1-1 (ITS Table 3.3.1-1) Functions 1 (Manual Reactor Trip), 11 (Reactor Coolant Pump (RCP) Breaker Position), and 17 (Safety Injection (SI) Input from Engineered Safety Feature Actuation System (ESFAS)). ISTS SR 3.3.1.14 is modified by a Note, which states "Verification of setpoint is not required." ITS Table 3.3.1-1 Functions 1, 11, and 17 do not have required setpoints. The ISTS definition of TADOT states "The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy." Since no required setpoints apply for ITS Table 3.3.1-1 Functions 1, 11, and 17, the TADOT definition does not require verification of setpoints. Therefore, the Note to ISTS SR 3.3.1.14 is unnecessary and has been deleted.

22. ISTS SR 3.3.1.14 requires the performance of a TADOT once per [18] months. ISTS SR 3.3.1.14 applies, in part, to ISTS Table 3.3.1-1 (ITS Table 3.3.1-1) Function 17 (Safety Injection (SI) Input from Engineered Safety Feature Actuation System (ESFAS)). A Note is added to ISTS SR 3.3.1.14 (ITS SR 3.3.1.17) that states that automatic portion of the SI Input from ESFAS Function is excluded for the TADOT.

This change is made to achieve consistency with the CNP Units 1 and 2 CTS.

23. ISTS Table 3.3.1-1 (ITS Table 3.3.1-1) Function 18 (Reactor Trip System Interlocks) has been revised to reflect the CNP specific design and nomenclature.

24. ISTS Table 3.3.1-1 (ITS Table 3.3.1-1) Function 16.b (Turbine Trip - Turbine Stop Valve Closure) has been revised to reflect the plant design. For Unit 1, each turbine stop valve includes a limit switch that provides input to two contacts (channels). One contact (channel) provides input to Train A while the other contact (channel) provides input to Train B. For Unit 2, each turbine stop valve includes two limit switches. One limit switch (channel) provides input to Train A while the other limit switch (channel) provides input to Train B. Since there are four stop valves installed in each unit, the LCO states that 4 channels per train are required to be OPERABLE.

25. TSTF-418, Rev. 2, which incorporates WCAP-14333, has not been adopted.

26. Approved TSTF-371, Rev. 1 provided a less restrictive change to ISTS SR 3.3.1.2 and ISTS SR 3.3.1.3 that would allow the acceptance criteria for the Nuclear Instrumentation System to be changed from + 2% RTP to + 2% RTP. The TSTF CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 8, Rev. 0, Page 117 of 818

Attachment 1, Volume 8, Rev. 0, Page 118 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION required a plant-specific evaluation. This has not been performed for CNP, thus this less restrictive change is not being adopted.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 8, Rev. 0, Page 118 of 818

Attachment 1, Volume 8, Rev. 0, Page 119 of 818 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 156 of 818 B 3.3.1 1

INSERT 22 A bus undervoltage signal is generated by one out of two undervoltage relays per reactor coolant pump bus, and two-out-of-four bus undervoltage signals will generate a reactor trip.

1 INSERT 23 The settings for the time delays are verified to be within limits during the performance of SR 3.3.1.19.

1 INSERT 24 While there are two Undervoltage RCPs channels per bus, Insert Page B 3.3.1-22 Attachment 1, Volume 8, Rev. 0, Page 156 of 818

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Attachment 1, Volume 8, Rev. 0, Page 158 of 818 B 3.3.1 1

INSERT 25 A bus underfrequency signal is generated by one-out-of-two underfrequency relays per reactor coolant pump bus, and two-out-of-four bus underfrequency signals will generate a reactor trip.

1 INSERT 26 The settings for the time delays are verified to be within limits during the performance of SR 3.3.1.19.

1 INSERT 27 While there are two Underfrequency RCPs channels per bus, 1 INSERT 27A There are three SG Water Level - Low Low channels per SG. The logic is arranged such that any two channels on the same SG will actuate a reactor trip.

1 INSERT 28 There are three SG Water Level-Low Low channels per SG arranged in a two-out-of-three logic per SG.

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Attachment 1, Volume 8, Rev. 0, Page 181 of 818 B 3.3.1 5 INSERT 42

Pressurizer Water Level - High;

Reactor Coolant Flow - Low;

Reactor Coolant Pump (RCP) Breaker Position;

Undervoltage RCPs;

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Attachment 1, Volume 8, Rev. 0, Page 197 of 818 B 3.3.1 5

INSERT 48 SR 3.3.1.9 A CHANNEL CALIBRATION is performed every 92 days. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Frequency of 92 days is based on the assumption of a 92 day calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

This SR is modified by a Note that states that neutron detectors are excluded from the CHANNEL CALIBRATION. Changes in power range neutron detector sensitivity are compensated for by normalization of the channel output based on a power calorimetric and flux map performed above 15% RTP (SR 3.3.1.2).

10 INSERT 49 A COT is performed on each required channel to ensure the entire channel will perform the intended Function.

10 INSERT 49A Setpoints must be within the Allowable Values specified in Table 3.3.1-1.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of Reference 8.

Insert Page B 3.3.1-48a Attachment 1, Volume 8, Rev. 0, Page 197 of 818

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INSERT 50 two Notes. Note 1 provides a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months delay in the requirement to perform this Surveillance for intermediate range instrumentation after reducing THERMAL POWER below the P-10 interlock.

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Attachment 1, Volume 8, Rev. 0, Page 200 of 818 B 3.3.1 5

INSERT 50A Note 2 provides a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months delay in the requirement to perform this Surveillance for source range instrumentation after THERMAL POWER is reduced below the P-6 interlock. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.10 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months this Surveillance must be performed prior to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after THERMAL POWER is reduced below the P-6 interlock.

1 INSERT 51 The Frequency of 184 days is justified in Reference 11.

1 INSERT 52 The Frequency of 184 days is based on operating experience, considering instrument reliability and operating history data.

5 INSERT 53 SR 3.3.1.12 A CHANNEL CALIBRATION is performed every 184 days. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Frequency of 184 days is based on the assumption of an 184 day calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

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Attachment 1, Volume 8, Rev. 0, Page 209 of 818 B 3.3.1 1

INSERT 59 The response time testing of the neutron flux signal portion of the channel shall be measured from either the detector output or the input of the first electronic component in the channel.

1 INSERT 60

1. Regulatory Guide 1.105, Revision 3, Setpoints for Safety Related Instrumentation.

2. UFSAR, Chapter 7.

3. Technical Requirements Manual.

4. IEEE-279, Proposed Criteria for Nuclear Power Plant Protection Systems, August 1968.

5. UFSAR, Table 7.2-1.

6. UFSAR, Table 14.1-2 (Unit 1) and UFSAR, Table 14.1.0-4 (Unit 2).

7. 10 CFR 50.49.

8. EG-IC-004, "Instrument Setpoint Uncertainty," Rev. 4.

9. UFSAR, Chapter 14.

10. WCAP-10271-P-A, "Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System," including Supplement 1, May 1986, and Supplement 2, Rev.1, June 1990.

11

8. WCAP-15376, "Risk-Informed Assessment of the RTS and ESFAS Surveillance TSTF-411 Test Intervals and Reactor Trip Breaker Test and Completion Times,"

October 2000.

12. UFSAR, Table 7.2-6.

Insert Page B 3.3.1-54 Attachment 1, Volume 8, Rev. 0, Page 209 of 818

Attachment 1, Volume 8, Rev. 0, Page 210 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.1 BASES, REACTOR TRIP SYSTEM INSTRUMENTATION

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

2. Grammatical/editorial error corrected.

3. The Note, describing an alternative Technical Specification format with respect to Allowable Values and Trip Setpoints, is deleted because it is not intended to be included in the plant specific ITS submittal.

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

5. Changes are made to reflect changes made to the Specification.

6. Spelling error corrected.

7. Changes are made to reflect the Specifications.

8. The Reviewers Notes are deleted because they are not intended to be included in the plant specific ITS submittal.

9. The discussion in ISTS SR 3.3.1.11 (ITS SR 3.3.1.14) about the normalization of the power range neutron detectors has been deleted since the adjustment is part of ISTS SR 3.3.1.2 (ITS SR 3.3.1.2).

10. Changes are made for consistency with other places of the Bases.

11. 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.

12. This statement has been deleted since the Power Range Neutron Flux and Intermediate Range Neutron Flux instrumentation are not assumed in the accident analyses to prevent automatic or manual rod withdrawal.

13. This statement has been deleted since this feature is not required for OPERABILITY of the Steam Generator Water Level - Low Low RTS Function.

14. This statement has been deleted since it is not relevant to the discussion.

15. This statement has been deleted since this feature is not assumed in the safety analyses.

16. TSTF-418, Rev. 2, which incorporates WCAP-14333, has not been adopted.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 210 of 818

Attachment 1, Volume 8, Rev. 0, Page 211 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 211 of 818

Attachment 1, Volume 8, Rev. 0, Page 212 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 212 of 818

Attachment 1, Volume 8, Rev. 0, Page 213 of 818 ATTACHMENT 2 ITS 3.3.2, Engineered Safety Features Actuation System (ESFAS)

Instrumentation Attachment 1, Volume 8, Rev. 0, Page 213 of 818

, Volume 8, Rev. 0, Page 214 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 8, Rev. 0, Page 214 of 818

Attachment 1, Volume 8, Rev. 0, Page 215 of 818 ITS 3.3.2 A.1 ITS LCO 3.3.2 LA.1 Add proposed ACTIONS Note A.2 ACTIONS A through F LA.1 ACTION A A.10 SR Table Note L.1 24 SR 3.3.2.2 L.2 SR 3.3.2.10, L.3 SR 3.3.2.12 Add proposed Note to SR 3.3.2.13 24 L.4 SR 3.3.2.13 A.3 on a STAGGERED TEST BASIS A.4 Page 1 of 51 Attachment 1, Volume 8, Rev. 0, Page 215 of 818

Attachment 1, Volume 8, Rev. 0, Page 216 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 1

LA.3 1.a LA.2 1.b C, I 3

1.c A.5 D

A.6 1.d D 3

1.e.(2)

A.6 D

A.15 Page 2 of 51 Attachment 1, Volume 8, Rev. 0, Page 216 of 818

Attachment 1, Volume 8, Rev. 0, Page 217 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 1.e.(1) per steam line A.6 D

A.15 Page 3 of 51 Attachment 1, Volume 8, Rev. 0, Page 217 of 818

Attachment 1, Volume 8, Rev. 0, Page 218 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 LA.2 2.a 2.b C, I 4 A.5 2.c E Page 4 of 51 Attachment 1, Volume 8, Rev. 0, Page 218 of 818

Attachment 1, Volume 8, Rev. 0, Page 219 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 Add proposed Function 3.a.(2) A.7 LA.2 3.a.(1) 3.a.(3) C, I LA.2 3.b.(1) 3.b.(2) C, I 4 A.5 3.b.(3) E See ITS 3.3.6 Page 5 of 51 Attachment 1, Volume 8, Rev. 0, Page 219 of 818

Attachment 1, Volume 8, Rev. 0, Page 220 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 LA.2 L.6 4.a Add proposed 4.b Footnote (d) C, H 4 A.5 4.c E Add proposed L.6 4.e Foonote (d) 2 A.5 D

A.6 Add proposed Footnote (d) L.6 A.15 Page 6 of 51 Attachment 1, Volume 8, Rev. 0, Page 220 of 818

Attachment 1, Volume 8, Rev. 0, Page 221 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 L.6 Add proposed Footnote (d) 4.e A.6 D

per loop A.5 A.15 LA.2 Add proposed Footnote (d) L.6 A.6 4.d D per steam line A.5 A.15 LA.2 Add proposed Footnote (f) 3 D L.7 5.b A.6 per SG A.5 Add proposed Function 5.a L.8 A.12 Add proposed Function 5.c A.8 L.15 L.16 Page 7 of 51 Attachment 1, Volume 8, Rev. 0, Page 221 of 818

Attachment 1, Volume 8, Rev. 0, Page 222 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 3 A.6 6.c D 3 A5 6.e B L.21 LA.2 LA.2 6.d B, H B, G A.13 6.g L.17 Add proposed Functions 6.a and 6.b LA.2 3

A.5 A.6 6.c D L.18 A.6 6.f D 1 per bus A.5 See ITS 3.3.5 243 Add proposed Function 6.a L.17 A.13 Page 8 of 51 Attachment 1, Volume 8, Rev. 0, Page 222 of 818

Attachment 1, Volume 8, Rev. 0, Page 223 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 1

L.20 1.a B, I 5.c LA.3 3.a.(3) See ITS 3.3.6 LA.3 6.d LA.2 2.a B, I 3.b.(1) See ITS 3.3.6 B, I LA.2 3.a.(1)

See ITS 3.3.6 4.a B, J L.6 Add proposed Footnote (d) 7.a B, I LA.2 7.a 7.b C, H 7.c D A.6 3

A.5 LA.2 Page 9 of 51 Attachment 1, Volume 8, Rev. 0, Page 223 of 818

Attachment 1, Volume 8, Rev. 0, Page 224 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 Footnote (a)

Footnote (b)

A.15 ACTION B Note A.6 Add proposed Required Action C.1 L.9 ACTION C M.9 ACTIONS H and I 4

ACTION C Note L.5 Add proposed ACTION D Note ACTION D L.10 L.5 6

Add proposed ACTIONS G, H, and I M.4 A.15 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months L.11 ACTION E L.5 4

Add proposed ACTIONS H and I M.4 Page 10 of 51 Attachment 1, Volume 8, Rev. 0, Page 224 of 818

Attachment 1, Volume 8, Rev. 0, Page 225 of 818 ITS 3.3.2 A.1 ITS See ITS 3.3.6 ACTION B ACTIONS G, H, and I M.9 ACTION D A.14 6

L.5 4

Add proposed ACTION J M.4 ACTION B ACTION J Page 11 of 51 Attachment 1, Volume 8, Rev. 0, Page 225 of 818

Attachment 1, Volume 8, Rev. 0, Page 226 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.9 LA.4 1 per train 8.b Add proposed LA.4 Applicability 8.c LA.4 Add proposed ACTIONS F and H Add proposed ACTIONS D and H 538.8 L.22 Add proposed Function 8.a, including ACTIONS and L.12 Surveillance Requirement M.5 Page 12 of 51 Attachment 1, Volume 8, Rev. 0, Page 226 of 818

Attachment 1, Volume 8, Rev. 0, Page 227 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 1

LA.3 1.a 1.b LA.1 1.c 1.17 M.11 1.d 1765 L.22 1.e.(2) 481.3 M.11 1.e.(1)

Add proposed Footnote (c) M.1 Page 13 of 51 Attachment 1, Volume 8, Rev. 0, Page 227 of 818

Attachment 1, Volume 8, Rev. 0, Page 228 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 2.a LA.1 2.b 2.c 2.97 M.11 3.a.(1)

LA.1 3.a.(3) 3.b.(1)

LA.1 3.b.(2) 3.b.(3) 2.97 M.11 See ITS 3.3.6 Page 14 of 51 Attachment 1, Volume 8, Rev. 0, Page 228 of 818

Attachment 1, Volume 8, Rev. 0, Page 229 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 See ITS 3.3.6 4.a LA.1 4.b 4.c 2.97 M.11 4.e 538.8 L.22 M.11 481.3 4.d M.1 Add proposed Footnote (c) 5.b LA.5 Page 15 of 51 Attachment 1, Volume 8, Rev. 0, Page 229 of 818

Attachment 1, Volume 8, Rev. 0, Page 230 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 L.22 4.0 6.c LA.5 6.e 6.d 6.g L.22 4.0 6.c LA.5 6.f See ITS 3.3.5 Page 16 of 51 Attachment 1, Volume 8, Rev. 0, Page 230 of 818

Attachment 1, Volume 8, Rev. 0, Page 231 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 LA.3 1.a 5.c 3.a.(3)

See ITS 3.3.6 6.d LA.3 LA.1 2.a 3.b.(1)

See ITS 3.3.6 LA.1 3.a.(1)

See ITS 3.3.6 4.a LA.1 7.a LA.1 7.a 7.b 7.c 1.17 M.11 Page 17 of 51 Attachment 1, Volume 8, Rev. 0, Page 231 of 818

Attachment 1, Volume 8, Rev. 0, Page 232 of 818 ITS 3.3.2 A.1 ITS Page 18 of 51 Attachment 1, Volume 8, Rev. 0, Page 232 of 818

Attachment 1, Volume 8, Rev. 0, Page 233 of 818 ITS 3.3.2 A.1 ITS Page 19 of 51 Attachment 1, Volume 8, Rev. 0, Page 233 of 818

Attachment 1, Volume 8, Rev. 0, Page 234 of 818 ITS 3.3.2 A.1 ITS Page 20 of 51 Attachment 1, Volume 8, Rev. 0, Page 234 of 818

Attachment 1, Volume 8, Rev. 0, Page 235 of 818 ITS 3.3.2 A.1 ITS Page 21 of 51 Attachment 1, Volume 8, Rev. 0, Page 235 of 818

Attachment 1, Volume 8, Rev. 0, Page 236 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.2, SR 3.3.2.5 SR 3.3.2.1 SR 3.3.2.10 LA.3 L.2 Add proposed SR 3.3.2.4 and SR 3.3.2.8 M.6 1.a 1.b -2 24 months LA.6 1.c -1 -10 -5 1.d -1 -10 -5 1.e.(2) -1 -10 -5 1.e.(1) -1 -10 -5 Add proposed SR 3.3.2.4 and SR 3.3.2.8 M.6 2.a 2.b -2 2.c -1 -10 -5 LA.6 Page 22 of 51 Attachment 1, Volume 8, Rev. 0, Page 236 of 818

Attachment 1, Volume 8, Rev. 0, Page 237 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.2, SR 3.3.2.3, SR 3.3.2.5 SR 3.3.2.1 SR 3.3.2.10 Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for M.8 Function 3.a.(2) 3.a.(1) 3.a.(3) -3 Add proposed SR 3.3.2.4 and SR 3.3.2.8 M.6 3.b.(1) 3.b.(2) -2 L.2 24 months 3.b.(3) -1 -10 -5 LA.6 See ITS 3.3.6 Page 23 of 51 Attachment 1, Volume 8, Rev. 0, Page 237 of 818

Attachment 1, Volume 8, Rev. 0, Page 238 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.2, SR 3.3.2.3, SR 3.3.2.5, SR 3.3.2.6, SR 3.3.2.7, SR 3.3.2.9 SR 3.3.2.1 SR 3.3.2.10 L.2 Add proposed SR 3.3.2.4 and SR 3.3.2.8 4.a L.6 M.6 4.b -2 4.c -1 -10 -5 Add proposed Footnote (d) 4.e -1 -10 -5 LA.6 24 months Add proposed Footnote (d) 4.d -1 -10 -5 L.6 Add proposed Footnote (f)

L.7

-1 -10 -5 5.b Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for Function 5.a M.2 Add proposed SR 3.3.2.9 for Function 5.c M.7 24 months Add proposed Note to SR 3.3.2.6 L.2 6.c -1 -10 -5

-1 A.11 6.e -7 -6 184 days L.19

-3 6.d 6.g -9 24 months L.13 184 days M.10 Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for Function 6.a Add proposed SR 3.3.2.11 for Function 6.b M.3 Page 24 of 51 Attachment 1, Volume 8, Rev. 0, Page 238 of 818

Attachment 1, Volume 8, Rev. 0, Page 239 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.5, SR 3.3.2.7, SR 3.3.2.6 SR 3.3.2.10 SR 3.3.2.1 L.2 184 days L.19 24 months A.11 6.c -1 -10 -5 Add proposed Note to SR 3.3.2.6 L.18 6.f -7 -6 184 days M.10 See ITS 3.3.5 Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for Function 6.a M.3 Page 25 of 51 Attachment 1, Volume 8, Rev. 0, Page 239 of 818

Attachment 1, Volume 8, Rev. 0, Page 240 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.9 SR 3.3.2.2, SR 3.3.2.5 SR 3.3.2.10 L.13 LA.3 1.a -9 24 months 5.c 3.a.(3)

See ITS 3.3.6 6.d 24 months LA.3 L.13 2.a -9 See ITS 3.b.(1) 3.3.6 24 months L.13 3.a.(1) -9 See ITS 3.3.6 24 months Add proposed Footnote (d) L.13 L.6 4.a -9 7.a -9 L.14 Add proposed SR 3.3.2.4 and SR 3.3.2.8 M.6 7.a 7.b -2 7.c -1 -10 -5 LA.6 24 months L.2 Page 26 of 51 Attachment 1, Volume 8, Rev. 0, Page 240 of 818

Attachment 1, Volume 8, Rev. 0, Page 241 of 818 ITS 3.3.2 A.1 ITS A.10 SR 3.3.2.2, SR 3.3.2.3 SR 3.3.2.5 LA.6 Note Page 27 of 51 Attachment 1, Volume 8, Rev. 0, Page 241 of 818

Attachment 1, Volume 8, Rev. 0, Page 242 of 818 ITS 3.3.2 A.1 ITS LCO 3.3.2 LA.1 Add proposed ACTIONS Note A.2 ACTIONS A through F LA.1 ACTION A A.10 SR Table Note L.1 24 SR 3.3.2.2 L.2 SR 3.3.2.10, L.3 SR 3.3.2.12 Add proposed Note to SR 3.3.2.13 L.4 24 SR 3.3.2.13 A.3 on a STAGGERED TEST BASIS A.4 Page 28 of 51 Attachment 1, Volume 8, Rev. 0, Page 242 of 818

Attachment 1, Volume 8, Rev. 0, Page 243 of 818 ITS 3.3.2 A.1 ITS LA.2 Table 3.3.2-1 REQUIRED A.5 1

LA.3 1.a LA.2 1.b C, I 3

A.5 1.c D A.6 1.d D 3

1.e.(2)

A.6 D

A.15 LA.2 1.e.(1) per steam line A.5 D

A.6 A.15 Page 29 of 51 Attachment 1, Volume 8, Rev. 0, Page 243 of 818

Attachment 1, Volume 8, Rev. 0, Page 244 of 818 ITS 3.3.2 A.1 ITS LA.2 Table 3.3.2-1 REQUIRED A.5 LA.2 2.a 2.b C, I 4 A.5 2.c E Page 30 of 51 Attachment 1, Volume 8, Rev. 0, Page 244 of 818

Attachment 1, Volume 8, Rev. 0, Page 245 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 Add proposed Function 3.a.(2) A.7 LA.2 3.a.(1)

C, I 3.a.(3)

LA.2 3.b.(1) 3.b.(2) C, I 4 A.5 3.b.(3) E See ITS 3.3.6 Page 31 of 51 Attachment 1, Volume 8, Rev. 0, Page 245 of 818

Attachment 1, Volume 8, Rev. 0, Page 246 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 Add proposed L.6 Footnote (d) 4.a LA.2 4.b C, H 4 A.5 4.c E Add proposed L.6 Foonote (d) 4.e 2

A.5 D

A.6 Add proposed Footnote (d) L.6 A.15 LA.2 Add proposed L.6 Footnote (d)

A.6 D

per loop A.5 A.15 Page 32 of 51 Attachment 1, Volume 8, Rev. 0, Page 246 of 818

Attachment 1, Volume 8, Rev. 0, Page 247 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 Add proposed 4.d Footnote (d)

L.6 A.6 D

per steam line A.5 A.15 LA.2 Add proposed Footnote (f) 3 L.7 5.b A.6 D

per SG A.5 Add proposed Function 5.a L.8 Add proposed Function 5.c A.12 A.8 6.c D L.16 B L.15 6.e A.6 3 L.21 A.5 LA.2 LA.2 B,H 6.d B,G A.13 6.g Add proposed Functions 6.a and 6.b L.17 Page 33 of 51 Attachment 1, Volume 8, Rev. 0, Page 247 of 818

Attachment 1, Volume 8, Rev. 0, Page 248 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 3 A.6 6.c D L.18 1 per bus 6.f D A.13 Add proposed Function 6.a L.17 See ITS 3.3.5 LA.2 L.20 1

1.a B,I 5.c LA.3 3.a.(3) See ITS 3.3.6 LA.3 6.d LA.2 2.a B,I 3.b.(1) See ITS 3.3.6 B,I LA.2 3.a.(1)

See ITS 3.3.6 4.a B, J Add proposed Footnote (d)

L.6 LA.2 Page 34 of 51 Attachment 1, Volume 8, Rev. 0, Page 248 of 818

Attachment 1, Volume 8, Rev. 0, Page 249 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.2 REQUIRED A.5 7.a B, I 7.a 7.b C, H 7.c D A.6 3

A.5 LA.2 Page 35 of 51 Attachment 1, Volume 8, Rev. 0, Page 249 of 818

Attachment 1, Volume 8, Rev. 0, Page 250 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 Footnote (a)

Footnote (b)

A.15 ACTION B Note A.6 L.9 Add proposed Required Action C.1 ACTION C M.9 ACTIONS H and I 4 L.5 ACTION C Note Add proposed ACTION D Note ACTION D L.10 6

L.5 M.4 Add proposed ACTIONS G, H, and I A.15 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months L.11 ACTION E L.5 4

Add proposed ACTIONS H and I M.4 Page 36 of 51 Attachment 1, Volume 8, Rev. 0, Page 250 of 818

Attachment 1, Volume 8, Rev. 0, Page 251 of 818 ITS 3.3.2 A.1 ITS See ITS 3.3.6 ACTION B ACTIONS G, H, and I M.9 ACTION D A.14 6

L.5 4

Add proposed ACTION J M.4 ACTION B ACTION J Page 37 of 51 Attachment 1, Volume 8, Rev. 0, Page 251 of 818

Attachment 1, Volume 8, Rev. 0, Page 252 of 818 ITS 3.3.2 A.1 ITS A.9 1 per train LA.4 Add proposed Applicability LA.4 Add proposed ACTIONS F and H Add proposed ACTIONS D 538.8 and H L.22 L.12 Add proposed Function 8.a, M.5 including ACTIONS and Surveillance Requirement Page 38 of 51 Attachment 1, Volume 8, Rev. 0, Page 252 of 818

Attachment 1, Volume 8, Rev. 0, Page 253 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 1

LA.3 1.a LA.1 1.b 1.c M.11 1.17 1.d L.22 1765 1.e.(2) 1.e.(1) 481.3 M.1 Add proposed Footnote (c)

Page 39 of 51 Attachment 1, Volume 8, Rev. 0, Page 253 of 818

Attachment 1, Volume 8, Rev. 0, Page 254 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 2.a LA.1 2.b 2.c M.11 2.97 LA.1 3.a.(1) 3.a.(3)

LA.1 3.b.(1) 3.b.(2) 3.b.(3) M.11 2.97 See ITS 3.3.6 Page 40 of 51 Attachment 1, Volume 8, Rev. 0, Page 254 of 818

Attachment 1, Volume 8, Rev. 0, Page 255 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 4.a LA.1 4.b 4.c 2.97 M.11 4.e L.22 538.8 4.d L.22 481.3 Add proposed M.1 Footnote (c) 5.b LA.5 71.6 L.22 Page 41 of 51 Attachment 1, Volume 8, Rev. 0, Page 255 of 818

Attachment 1, Volume 8, Rev. 0, Page 256 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 20.8 M.11 6.c LA.5 6.e 6.d 6.g 20.8 M.11 6.c LA.5 6.f See ITS 3.3.5 Page 42 of 51 Attachment 1, Volume 8, Rev. 0, Page 256 of 818

Attachment 1, Volume 8, Rev. 0, Page 257 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 LA.1 LA.3 1.a 5.c 3.a.(3)

See ITS 3.3.6 6.d LA.3 LA.1 2.a 3.b.(1) See ITS 3.3.6 LA.1 3.a.(1)

See ITS 3.3.6 4.a LA.1 7.a LA.1 7.a 7.b 7.c 1.17 M.11 Page 43 of 51 Attachment 1, Volume 8, Rev. 0, Page 257 of 818

Attachment 1, Volume 8, Rev. 0, Page 258 of 818 ITS 3.3.2 A.1 ITS Page 44 of 51 Attachment 1, Volume 8, Rev. 0, Page 258 of 818

Attachment 1, Volume 8, Rev. 0, Page 259 of 818 ITS 3.3.2 A.1 ITS Page 45 of 51 Attachment 1, Volume 8, Rev. 0, Page 259 of 818

Attachment 1, Volume 8, Rev. 0, Page 260 of 818 ITS 3.3.2 A.1 ITS Page 46 of 51 Attachment 1, Volume 8, Rev. 0, Page 260 of 818

Attachment 1, Volume 8, Rev. 0, Page 261 of 818 ITS 3.3.2 A.1 ITS Page 47 of 51 Attachment 1, Volume 8, Rev. 0, Page 261 of 818

Attachment 1, Volume 8, Rev. 0, Page 262 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.2, SR 3.3.2.3, SR 3.3.2.5 SR 3.3.2.1 LA.3 SR 3.3.2.10 L.2 Add proposed SR 3.3.2.4 and M.6 SR 3.3.2.8 1.a 1.b 24 months -2 LA.6 1.c -1 -10 -5 1.d -1 -10 -5 1.e.(2) -1 -10 -5 1.e.(1) -1 -10 -5 Add proposed SR 3.3.2.4 and SR 3.3.2.8 M.6 2.a

-2 2.b 2.c -1 -10 -5 LA.6 Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for Function 3.a.(2)

M.8 3.a.(1) 3.a.(3) -3 Add proposed SR 3.3.2.4 and SR 3.3.2.8 M.6 3.b.(1) L.2 3.b.(2) -2 24 months 3.b.(3) -1 -10 -5 LA.6 Page 48 of 51 Attachment 1, Volume 8, Rev. 0, Page 262 of 818

Attachment 1, Volume 8, Rev. 0, Page 263 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.2, SR 3.3.2.3, SR 3.3.2.5, SR 3.3.2.6, SR 3.3.2.7, SR 3.3.2.9 SR 3.3.2.1 SR 3.3.2.10 See ITS 3.3.6 L.2 M.6 Add proposed SR 3.3.2.4 and SR 3.3.2.8 4.a 4.b -2 Add proposed L.6 Footnote (d) 4.c -1 -10 -5 4.e -1 -10 -5 LA.6 24 months Add proposed Footnote (d) 4.d -10 -5

-1 L.6 Add proposed Footnote (f)

L.7

-1 -10 -5 5.b Add proposed SRs 3.3.2.2, 3.3.2.4, SR 3.3.2.8 for Function 5.a M.2 Add proposed SR 3.3.2.9 for Function 5.c 24 months M.7 6.c -1 -10 -5 A.11 Add proposed Note to SR 3.3.2.6 6.e -1 -7 -6 L.2 6.d 184 days -3 6.g -9 L.19 184 days 24 months L.13 Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for Function 6.a M.10 Add proposed SR 3.3.2.11 for Function 6.b M.3 Page 49 of 51 Attachment 1, Volume 8, Rev. 0, Page 263 of 818

Attachment 1, Volume 8, Rev. 0, Page 264 of 818 ITS 3.3.2 A.1 ITS Table 3.3.2-1 A.10 SR 3.3.2.9 SR 3.3.2.2, SR 3.3.2.1 SR 3.3.2.7, SR 3.3.2.5, M.10 SR 3.3.2.10 SR 3.3.2.6 L.2 L.19 24 months A.11 184 days 184 days Add proposed Note to SR 3.3.2.6 6.c -1 -10 -5 L.18 6.f -7 -6 Add proposed SRs 3.3.2.2, 3.3.2.4, and 3.3.2.8 for Function 6.a M.3 See ITS 3.3.5 1.a -9 5.c LA.3 24 months L.13 3.a.(3)

See ITS 3.3.6 6.d LA.3 24 months L.13 2.a -9 See ITS 3.b.(1) 3.3.6 3.a.(1) 24 months L.13

-9 24 months Add proposed Footnote (d)

L.6 4.a -9 L.14

-9 7.a M.6 Add proposed SR 3.3.2.4 and SR 3.3.2.8 7.a 7.b -2 7.c -1 -10 -5 LA.6 24 months L.2 Page 50 of 51 Attachment 1, Volume 8, Rev. 0, Page 264 of 818

Attachment 1, Volume 8, Rev. 0, Page 265 of 818 ITS 3.3.2 A.1 ITS A.10 SR 3.3.2.2, SR 3.3.2.3 SR 3.3.2.5 LA.6 Note Page 51 of 51 Attachment 1, Volume 8, Rev. 0, Page 265 of 818

Attachment 1, Volume 8, Rev. 0, Page 266 of 818 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION 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 3.3.2.1 Actions provide the compensatory actions to take when ESFAS instrumentation is inoperable. ITS 3.3.2 ACTIONS provide the compensatory actions for inoperable ESFAS Instrumentation. The ITS 3.3.2 ACTIONS include a Note that allows separate Condition entry for each Function. In addition, separate Condition entry is allowed within a Function as follows: (a) for Function 1.e.(2) (High Differential Pressure Between Steam Lines) on a steam line basis; (b) for Function 5.b (SG Water Level - High High) and Function 6.c (SG Water Level - Low Low) on a steam generator basis; and (c) for Function 6.e (Loss of Voltage) on a bus basis. This modifies the CTS by providing a specific allowance to enter the Action for each inoperable ESFAS instrumentation Function and for certain Functions on a steam line, steam generator, or bus basis.

This change is acceptable because it clearly states the current requirement. The CTS considers each ESFAS instrumentation Function to be separate and independent from the others. In addition, the channels associated with Functions 1.e.(2), 5.b, 6.c, and 6.e are allowed separate Condition entry on the specified basis (i.e., steam line, steam generator, or bus) since the channels associated with each steam line, steam generator, or bus will provide the associated ESFAS actuation based on the logic associated with the channels on the specified basis.

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

A.3 CTS 4.3.2.1.3 requires ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME testing of "each" ESFAS function. ITS SR 3.3.2.13 is the ESF RESPONSE TIME testing Surveillance, but in ITS Table 3.3.2-1, it is only required for Functions 1.c (Safety Injection Containment Pressure - High), 1.d (Safety Injection Pressurizer Pressure - Low), 1.e.(1) (Safety Injection Steam Line Pressure - Low), 2.c (Containment Spray Containment Pressure - High High), 4.c (Steam Line Isolation Containment Pressure - High High), 4.d (Steam Line Isolation Steam Line Pressure - Low), 5.b (Turbine Trip and Feedwater Isolation SG Water Level - High High), 5.c (Turbine Trip and Feedwater Isolation SI Input from ESFAS), 6.c (Auxiliary Feedwater SG Water Level - Low Low), 6.e (Auxiliary Feedwater Loss of Voltage), 6.f (Auxiliary Feedwater Undervoltage Reactor Coolant Pump), 6.g (Auxiliary Feedwater Trip of All Main Feedwater Pumps), and 7.c (CEQ System Containment Pressure - High). This changes the CTS by specifically stating that the Surveillance is only applicable to certain Functions, not "each" function.

CNP Units 1 and 2 Page 1 of 37 Attachment 1, Volume 8, Rev. 0, Page 266 of 818

Attachment 1, Volume 8, Rev. 0, Page 267 of 818 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION The purpose of CTS 4.3.2.1.3 is to ensure that the actuation response times are less than or equal to the maximum values assumed in the accident analysis.

UFSAR Table 7.2-7, which was previously in CTS 3.3.2 as Table 3.3-5, only specifies response times for those ESFAS Functions assumed in the CNP safety analyses. These response times were removed from CTS 3.3.2 and placed under CNP control as documented in the NRC Safety Evaluation Report for License Amendments 202 (Unit 1) and 187 (Unit 2). This change is acceptable since ITS 3.3.2 requires ESF RESPONSE TIME testing (ITS SR 3.3.2.13) for only those Functions listed in UFSAR Table 7.2-7. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.3.2.1.3 states, in part, that the ESF RESPONSE TIME of each trip function shall be demonstrated to be within its limit at least once per 18 months.

The requirement specifies that each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months, where N is the total number of redundant channels in a specific ESFAS Function as shown in the "TOTAL NO. OF CHANNELS" column of Table 3.3-3. ITS SR 3.3.2.13 requires the verification of ESF RESPONSE TIME every 24 months "on a STAGGERED TEST BASIS." The ITS definition of STAGGERED TEST BASIS is consistent with the CTS testing Frequency. This changes the CTS by utilizing the ITS definition of STAGGERED TEST BASIS. The extension in the Surveillance Frequency from 18 months to 24 months is discussed in DOC L.4.

This change is acceptable because the requirements for ESF RESPONSE TIME testing for the ESFAS channels remain unchanged. The ITS definition of STAGGERED TEST BASIS and its application in this requirement do not change the current testing frequency requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS Table 3.3-3 specifies the "TOTAL NO. OF CHANNELS" and the "MINIMUM CHANNELS OPERABLE" associated with each ESFAS Functional Unit. For CTS Table 3.3-3 Functional Units 1.c, 1.d, 1.e, 1.f, 2.c, 3.b.3), 4.c, 4.d, 4.e, 5.a, 6.a, 6.b, 7.a, 7.b, 9.d, and 10.c, the number of channels listed in the "TOTAL NO.

OF CHANNELS" column is greater than that listed in the "MINIMUM CHANNELS OPERABLE" column. CTS Table 3.3-3 Actions 14, 16, 19, and 20 specify the actions to take with the number of channels OPERABLE one less than required by the "TOTAL NO. OF CHANNELS" column. ITS LCO 3.3.2 requires the ESFAS instrumentation for each Function in Table 3.3.2-1 to be OPERABLE, and ITS Table 3.3.2-1 includes only one column titled "REQUIRED CHANNELS."

For the associated ITS Table 3.3.2-1 Functions, the number of channels listed in the "REQUIRED CHANNELS" column is equal to the number of channels listed in CTS "TOTAL NO. OF CHANNELS" column. The ITS 3.3.2 ACTIONS require entry when the OPERABLE channels are one less than required by the "REQUIRED CHANNELS" column. In addition, the description in the CTS Table 3.3-3 "MINIMUM CHANNELS OPERABLE" column includes: a) the word "loops" for Functional Units 1.f and 4.e; and b) the phrase "loop" for Functional Unit 5.a. In ITS Table 3.3.2-1, the phrases used are a) "per steam line" for Functions 1.e.(1) and 4.d; and b) "per SG" for Function 5.b. This changes the CTS by changing the title of the "MINIMUM CHANNELS OPERABLE" column to CNP Units 1 and 2 Page 2 of 37 Attachment 1, Volume 8, Rev. 0, Page 267 of 818

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INSTRUMENTATION "REQUIRED CHANNELS" and increases the number of channels listed to match the number listed in the "TOTAL NO. OF CHANNELS" column. It also changes the CTS by modifying some of the descriptions in the "MINIMUM CHANNELS OPERABLE" column.

This change is acceptable because the requirements for when actions must be taken remain unchanged. The "REQUIRED CHANNELS" column reflects the current requirements in the CTS Actions for when actions are required to be taken. The "MINIMUM CHANNELS OPERABLE" column for CTS Table 3.3-3 Functional Units 1.c, 1.d, 1.e, 2.c, 3.b.3), 4.c, 4.d, 5.a, 6.a, 6.b, 7.a, 7.b, and 10.c have changed to correspond to the number of channels in the "TOTAL NO. OF CHANNELS" column as reflected in ITS Table 3.3.2-1 Functions 1.c, 1.d, 1.e.(2),

2.c, 3.b.(3), 4.c, 4.e, 5.b, 6.c, 6.e, 6.f, and 7.c. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS Table 3.3-3 Note

states that the provisions of CTS 3.0.4 are not applicable. This Note is associated with CTS Table 3.3-3 Functional Units 1.c, 1.d, 1.e, 1.f, 4.d, 4.e, 5.a, 6.a, 7.a, 7.b and 10.c. CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted." ITS 3.3.2 does not contain the exception to ITS LCO 3.0.4 for the specified Functions, since ITS LCO 3.0.4 states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability may be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This changes the CTS by deleting an allowance since it is incorporated into ITS LCO 3.0.4.

This change is considered acceptable because ITS LCO 3.0.4 has been changed such that the CTS allowance is not required to retain the same CTS requirement.

The applicable ITS 3.3.2 ACTIONS allows continued operation for an unlimited period of time, which together with ITS LCO 3.0.4, result in the same technical requirements as the CTS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.7 CTS Table 3.3-3 Functional Unit 3.a (Containment Isolation Phase "A" Isolation) does not specifically include the Automatic Actuation Logic and Actuation Relays Function. ITS Table 3.3.2-1 Function 3.a.(2) requires the two Automatic Actuation Logic and Actuation Relay trains to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.3.2 ACTIONS C and I have been included for this Function, and provide 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable train if one train is inoperable (ACTION C), and if not restored, provide a shutdown requirement (ACTION I).

This changes the CTS by adding Function 3.a.(2) (Containment Isolation Phase A Isolation Automatic Actuation Logic and Actuation Relays) to the Technical Specifications including the LCO, number of channels (2 trains), and appropriate ACTIONS.

This change is considered acceptable because the Containment Isolation Phase A Isolation Function utilizes the relays associated with the Automatic CNP Units 1 and 2 Page 3 of 37 Attachment 1, Volume 8, Rev. 0, Page 268 of 818

Attachment 1, Volume 8, Rev. 0, Page 269 of 818 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION Actuation Logic and Actuation Relays to initiate the Manual Initiation Function (CTS Table 3.3-3 Functional Units 3.a.1) and 9.c) and the SI Automatic Actuation Logic Function (CTS Table 3.3-3 Functional Unit 3.a.2)). The proposed requirements are consistent with the requirements for both of these Functions.

The Manual Initiation Function currently requires one manual initiation channel in each train. For each Manual Initiation train to function properly the associated Automatic Actuation Logic and Actuation Relays must also operate as designed.

The SI Automatic Actuation Logic also requires two trains. If the relays associated with Train A of the Automatic Actuation Logic and Actuation Relays were inoperable, the current Action is to enter Action 13 (CTS Table 3.3-3 Functional Unit 3.a.2), SI Automatic Actuation Logic) and Action 18 (CTS Table 3.3-3 Functional Unit 9.a, Manual Initiation) since the relays affect both the Manual Initiation Function and the Automatic Actuation Logic. The proposed Action for ITS Table 3.3.2-1 Function 3.a.(2) is ACTION C since it is more restrictive of the two actions. Changes to CTS Table 3.3-3 Action 13 is discussed in DOC L.9. Since the number of channels are consistent with the number of channels for the Manual Initiation and SI Automatic Actuation Logic Functions, and since changes to the Actions are discussed in DOC L.9, this change is considered administrative. This change is designated as administrative because it does not result in a technical change to the CTS.

A.8 CTS Table 3.3-3 Functional Unit 5, Turbine Trip and Feedwater Isolation, does not explicitly contain the OPERABILITY requirements for the SI Input from ESFAS Function. CTS Table 3.3-3 Functional Unit 1 requires the Safety Injection Function to also provide input to the Turbine Trip and Feedwater Isolation Function, as indicated in the title of CTS Table 3.3-3 Functional Unit 1.

ITS Table 3.3.2-1 Function 5.c, SI Input from ESFAS, requires two trains of the SI Input from ESFAS Function to be OPERABLE in MODE 1, and MODES 2 and 3 except when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve. This changes the CTS by adding the explicit requirement that two trains of SI Input from ESFAS must support the Turbine Trip and Feedwater Isolation. The changes related to the Applicability and Actions associated with this Function are discussed in DOCs L.15 and L.16, respectively.

The purpose of ITS Table 3.3.2-1 Function 5.c is to ensure two trains of SI Input from ESFAS Function are OPERABLE to support the Turbine Trip and Feedwater Isolation Function. CTS Table 3.3-3 Functional Unit 1 states that the Safety Injection signals must support the Turbine Trip and Feedwater Isolation Function. This Function requires two trains of Automatic Actuation Logic (CTS Table 3.3-3 Functional Unit 1.b). Therefore, the requirement to have two trains of SI Input from ESFAS Function to support the Turbine Trip and Feedwater Isolation Function is acceptable. This change is designated as administrative because it does not result in a technical change to the CTS.

A.9 CTS LCO 3.3.2.1 states that the interlocks of Table 3.3-3 shall be OPERABLE.

However, CTS Table 3.3-3 provides no specific Applicability requirements for the P-11 and P-12 interlocks. ITS Table 3.3.2-1 specifies MODES 1, 2, and 3 as the Applicability for the P-11 and P-12 interlocks (Functions 8.b and 8.c). This changes the CTS by adding a specific Applicability for the P-11 and P-12 interlocks.

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INSTRUMENTATION This change is acceptable because the change provides more explicit conditions for when the interlocks are required to be OPERABLE, and are consistent with the ESFAS Functions they support. This change is designated as administrative because it does not result in a technical change to the CTS.

A.10 CTS 4.3.2.1.1 requires that the ESFAS instrumentation channels be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST at the frequencies shown in Table 4.3-2. ITS 3.3.2 requires the performance of either a CHANNEL OPERATIONAL TEST (COT), a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), or, in the case of the Automatic Actuation Logic, an ACTUATION LOGIC TEST. This changes the CTS by changing the CHANNEL FUNCTIONAL TEST requirements to either a COT, a TADOT, or an ACTUATION LOGIC TEST.

This change is acceptable because the COT, TADOT, and ACTUATION LOGIC TEST continue to perform tests similar to the current CHANNEL FUNCTIONAL TEST. The change is one of format only and any technical change to the requirements is specifically addressed in an individual Discussion of Change. In addition, the change to the CHANNEL FUNCTIONAL TEST definition is also described in the Discussion of Changes for ITS 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

A.11 CTS Table 4.3-2 requires a CHANNEL FUNCTIONAL TEST be performed for Functional Unit 6.b (4 kV Bus Loss of Voltage) and Functional Unit 7.b (Reactor Coolant Pump Bus Undervoltage). ITS Table 3.3.2-1 Function 6.e (Loss of Voltage) and Function 6.f (Undervoltage Reactor Coolant Pump) require performance of SR 3.3.2.6, a TADOT. However, the Surveillance is modified by a Note that states that a verification of the setpoint is not required. This changes the CTS by explicitly stating that setpoint verification is not part of the TADOT.

The change from a CHANNEL FUNCTIONAL TEST to a TADOT is discussed in DOC A.10.

The CTS definition of CHANNEL FUNCTIONAL TEST does not require a setpoint verification. However, the ITS definition of TADOT does include a setpoint verification. Therefore, to be consistent with the current requirements and with current practice, the Note has been added. Since a setpoint verification is not currently required during performance of this test, this change is acceptable. This change is designated as administrative because it does not result in a technical change to the CTS.

A.12 CTS Table 3.3-3 Functional Unit 5, Turbine Trip and Feedwater Isolation, does not specifically include the Automatic Actuation Logic and Actuation Relay Function. ITS Table 3.3.2-1 Function 5.a requires the two Automatic Actuation Logic and Actuation Relay trains to be OPERABLE in MODE 1, and MODES 2 and 3 except when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve. This changes the CTS by explicitly requiring the two trains of the Automatic Actuation Logic and Actuation Relays Functions for Turbine Trip and Feedwater Isolation to be OPERABLE in MODE 1, and MODES 2 and 3 except when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve.

CNP Units 1 and 2 Page 5 of 37 Attachment 1, Volume 8, Rev. 0, Page 270 of 818

Attachment 1, Volume 8, Rev. 0, Page 271 of 818 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION This change is considered acceptable because the Turbine Trip and Feedwater Isolation Functions require the Automatic Actuation Logic and Actuation Relays to operate properly in order to actuate Turbine Trip and Feedwater Isolation.

Two trains are required to be OPERABLE to help ensure a single failure of a logic train does not prevent the actuation of the Turbine Trip and Feedwater Isolation. The proposed Applicability is consistent with the Applicability of the Functions listed under CTS Table 3.3-3 Functional Unit 5 as modified by DOC L.7. This change is designated as administrative because it does not result in a technical change to the CTS.

A.13 CTS Table 3.3-3 Functional Unit 6, Motor Driven Auxiliary Feedwater Pumps, and Functional Unit 7, Turbine Driven Auxiliary Feedwater Pumps, do not include the Automatic Actuation Logic and Actuation Relays Function. ITS Table 3.3.2-1 Function 6.a includes the requirements for the Automatic Actuation Logic and Actuation Relays (Solid State Protection System) and Function 6.b includes the requirements for the Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS). The Applicability of these Functions is MODES 1, 2, and 3 and two trains of each Function are required to be OPERABLE. This changes the CTS by explicitly requiring the two trains of the Automatic Actuation Logic and Actuation Relays Functions (Solid State Protection System and Balance of Plant ESFAS) for the Auxiliary Feedwater System to be OPERABLE in MODES 1, 2, and 3.

This change is considered acceptable because the Auxiliary Feedwater Pump Functions either requires the Automatic Actuation Logic and Actuation Relays (Solid State Protection System) or the Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS) to operate properly in order to start the associated auxiliary feedwater pump. Two trains are required to be OPERABLE to help ensure a single failure of a logic train does not prevent the actuation of the Auxiliary Feedwater Function. The proposed Applicability is consistent with the Applicability of the Functions listed under CTS Table 3.3-3 Functional Units 6 and 7. This change is designated as administrative because it does not result in a technical change to the CTS.

A.14 CTS Table 3.3-1 Action 18 requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months if a Functional Unit 6.d, Loss of Main Feedwater Pumps, channel is inoperable and not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

However, CTS Table 3.3-3 Functional Unit 6.d is applicable only in MODES 1 and 2. Thus, as described in CTS 3.0.1, CTS Table 3.3-3 Action 18 is only applicable in MODES 1 and 2 for Functional Unit 6.d. ITS 3.3.2 ACTION G is the associated shutdown action for the above Function (ITS Table 3.3.2-1 Function 6.g), and it only requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by explicitly specifying that the unit is only required to be shut down to MODE 3.

The purpose of CTS Table 3.3-3 Action 18 is to place the unit in a MODE in which Functional Unit 6.d does not apply. The change is acceptable because the CTS 3.0.1 specifically states that the Actions are only applicable in the MODES specified by the LCO. Thus, a shutdown only to MODE 3 is actually required by CNP Units 1 and 2 Page 6 of 37 Attachment 1, Volume 8, Rev. 0, Page 271 of 818

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INSTRUMENTATION CTS Table 3.3-3 Action 18 for this Function. This change is designated as administrative because it does not result in a technical change to the CTS.

A.15 CTS Table 3.3-3 Functional Unit 1.e specifies the requirements for the Differential Pressure Between Steam Lines - High Function for four loop operation and three (n-1) loop operation (in MODE 3 above P-12).

CTS Table 3.3-3 Functional Units 1.f and 4.e specify the requirements for the Steam Line Pressure - Low Function for four loop operation and three (n-1) loop operation (in MODE 3 above P-12). CTS Table 3.3-3 Functional Unit 4.d specifies the requirements for the Steam Flow in Two Steam Lines - High Function coincident with Tavg - Low Low for four loop operation and three (n-1) loop operation (in MODE 3 above P-12). Each of these CTS Table 3.3-3 Functional Units "CHANNELS TO TRIP" column is modified by CTS Table 3.3-3 Note ### or ####, as applicable. These Notes require certain channels to be tripped during three (n-1) loop operation. In addition, CTS Table 3.3-3 Action 15 is provided for these three (n-1) loop operation instrumentation requirements.

ITS Table 3.3.2-1 Functions 1.e.(2) (Steam Line Pressure - High Differential Pressure Between Steam Lines), 1.e.(1) and 4.d (Steam Line Pressure - Low),

and 4.e (High Steam Flow in Two Steam Lines coincident with Tavg - Low Low) specify requirements for these Functions based only upon the four loop operation requirements from the CTS. This changes the CTS by eliminating the ESFAS instrumentation requirements that are only associated with three (n-1) loop operation.

The current CNP CTS requirements to trip the instrumentation channels associated with a non-operating RCS loop are based on NUREG-0452, Revision 4. All revisions of NUREG-0452 included these requirements in anticipation of future NRC approval for n-1 loop operation for nuclear power plants that were currently being licensed to operate. However, no nuclear power plant, including CNP, has ever obtained NRC approval for n-1 loop operation, and no interest in requesting NRC approval is evident in the industry. Because of this lack of interest, these requirements were eliminated during the development of NUREG-1431, as reviewed and approved by the NRC.

Consequently, ISTS Table 3.3.2-1 Functions 1.e.(1), 1.e.(2), 1.f, 1.g, 4.d.(1),

4.d.(2), 4.e, 4.f, 4.g, and 4.h do not address requirements for n-1 loop operation.

Since CNP is not currently licensed for n-1 loop operation, the proposed ITS do not include requirements for n-1 loop operation consistent with the ISTS. This change is designated as administrative since this change eliminates requirements that are not applicable to CNP and is consistent with the NUREG-1431 ISTS requirements.

MORE RESTRICTIVE CHANGES M.1 CTS Table 3.3-4 provides Allowable Values for Functional Units 1.f (Safety Injection Steam Line Pressure - Low) and 4.e (Steam Line Isolation Steam Line Pressure - Low), but does not explicitly provide requirements for the time constants of the lead/lag controllers associated with these Functional Units.

ITS Table 3.3.2-1 Footnote (c) is applied to each of these Functions (ITS Table 3.3.2-1 Functions 1.e.(1) and 4.d) and provides requirements for the CNP Units 1 and 2 Page 7 of 37 Attachment 1, Volume 8, Rev. 0, Page 272 of 818

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INSTRUMENTATION time constants for these lead/lag controllers. This changes the CTS by providing explicit values for the time constants of the Steam Line Pressure - Low lead/lag controllers.

This change is acceptable because proper settings of the time constants of the lead/lag controllers are necessary to support the OPERABILITY of the Steam Line Pressure - Low Functions. As such, explicitly including the values for these time constants in the Technical Specifications provides additional assurance that the OPERABILITY of the Safety Injection Steam Line Pressure - Low and Steam Line Isolation Steam Line Pressure - Low Functions will be maintained. The addition of the time constants of the Steam Line Pressure - Low lead/lag controllers is acceptable since these requirements are currently administratively controlled in procedures. The requirements for the Safety Injection Steam Line Pressure - Low and Steam Line Isolation Steam Line Pressure - Low Functions continue to require the time constants of the lead/lag controller to be within required limits to ensure that these instruments function as assumed in the safety analyses. This change is designated as more restrictive because it adds explicit Allowable Values for the time constants of the Steam Line Pressure - Low lead/lag controllers to the CTS.

M.2 CTS Table 4.3-2 Functional Unit 5, which provides the Surveillance Requirements for the Turbine Trip and Feedwater Isolation instrumentation, does not include an Automatic Actuation Logic and Actuation Relays Function. ITS Table 3.3.2-1 Function 5.a requires the two Automatic Actuation Logic and Actuation Relays trains to be OPERABLE and requires the performance of SR 3.3.2.2, an ACTUATION LOGIC TEST, and SR 3.3.2.4, a MASTER RELAY TEST, every 92 days on a STAGGERED TEST BASIS, and SR 3.3.2.8, a SLAVE RELAY TEST, every 24 months. This changes the CTS by adding the explicit Surveillances for proposed Function 5.a, Automatic Actuation Logic and Actuation Relays, to the Technical Specifications. The addition of the LCO, number of channels, and ACTIONS is discussed in DOCs A.12 and L.8.

This change is acceptable because the Automatic Actuation Logic and Actuation Relays Function is required to support the OPERABILITY of Turbine Trip and Feedwater Isolation function. As such, explicitly including requirements for the Automatic Actuation Logic and Actuation Relays Function in the Technical Specifications provides additional assurance that the OPERABILITY of the Turbine Trip and Feedwater Isolation function will be maintained. The change provides explicit requirements for testing the Automatic Actuation Logic and Actuation Relays Function (ITS Table 3.3.2-1 Function 5.a). The addition of SR 3.3.2.2 (an ACTUATION LOGIC TEST), SR 3.3.2.4 (a MASTER RELAY TEST), and SR 3.3.2.8 (a SLAVE RELAY TEST) is acceptable since the proposed Surveillance Requirements are consistent with current practice. The proposed Frequencies of testing of the actuation logic and master relays is consistent with the current Frequency of testing of the CHANNEL FUNCTIONAL TEST associated with the Automatic Actuation Logic and Actuation Relays for other Functions. The Frequency proposed for the slave relays is consistent with the Frequency proposed for the simulated actuation tests. This change is designated as more restrictive because it adds SRs for the Automatic Actuation Logic and Actuation Relays Function to the CTS.

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INSTRUMENTATION M.3 CTS Table 4.3-2 Functional Unit 6, which provides the ESFAS instrumentation Surveillance Requirements for the motor driven AFW Pumps, and CTS Table 4.3-2 Functional Unit 7, which provides the ESFAS instrumentation Surveillance Requirements for the turbine driven AFW pump, do not provide any explicit requirements for the motor driven or turbine auxiliary feedwater (AFW) pump ESFAS Automatic Actuation Logic and Actuation Relays Function. ITS Table 3.3.2-1 Function 6.a requires the two Automatic Actuation Logic and Actuation Relays (Solid State Protection System) trains to be OPERABLE and requires the performance of SR 3.3.2.2, an ACTUATION LOGIC TEST, and SR 3.3.2.4, a MASTER RELAY TEST, every 92 days on a STAGGERED TEST BASIS, and SR 3.3.2.8, a SLAVE RELAY TEST, every 24 months. ITS Table 3.3.2-1 Function 6.b requires the two Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS) trains to be OPERABLE and requires the performance of SR 3.3.2.11, an ACTUATION LOGIC TEST, every 24 months. This changes the CTS by adding the explicit Surveillances for proposed Functions 6.a, Auxiliary Feedwater (AFW) Automatic Actuation Logic and Actuation Relays (Solid State Protection System) and 6.b, AFW Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS) to the Technical Specifications. The addition of the LCO, number of channels, and ACTIONS is discussed in DOCs A.13 and L.17.

This change is acceptable because the Automatic Actuation Logic and Actuation Relays Functions are required to support the OPERABILITY of other AFW System instrumentation Functions. As such, explicitly including requirements for the Automatic Actuation Logic and Actuation Relays Functions in the Technical Specifications provides additional assurance that the OPERABILITY of the other AFW System instrumentation Functions will be maintained. The change provides explicit requirements for testing the AFW Automatic Actuation Logic and Actuation Relays (Solid State Protection System) Function (ITS Table 3.3.2-1 Function 6.a) and the AFW Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS) Function (ITS Table 3.3.2-1 Function 6.b). The addition of SR 3.3.2.2 (an ACTUATION LOGIC TEST), SR 3.3.2.4 (a MASTER RELAY TEST), SR 3.3.2.8 (a SLAVE RELAY TEST), and SR 3.3.2.11 (an ACTUATION LOGIC TEST) is acceptable since the proposed Surveillance Requirements are consistent with current practice. The proposed Frequencies of testing of the actuation logic and master relays associated with the Solid State Protection System is consistent with the Frequency of testing of the CHANNEL FUNCTIONAL TEST associated with the Automatic Actuation Logic for other Functions. The Frequency proposed for the slave relays and the balance of plant ESFAS ACTUATION LOGIC TEST is consistent with the Frequency proposed for the simulated actuation tests. This change is designated as more restrictive because it adds explicit OPERABILITY requirements and SRs for the AFW Automatic Actuation Logic and Actuation Relays Functions to the CTS.

M.4 CTS Table 3.3-3 Action 14 states that with the number of OPERABLE Functional Units 1.c through 1.f, 4.d, 4.e, 5.a, 6.a, 6.b, 7.a, or 10.c channels one less than the total number of channels, operations may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . CTS Table 3.3-3 Action 16 states that with the number of OPERABLE Functional Units 2.c, 3.b.3), or 4.c channels one less than the total number of channels, operations may proceed CNP Units 1 and 2 Page 9 of 37 Attachment 1, Volume 8, Rev. 0, Page 274 of 818

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INSTRUMENTATION provided the inoperable channel is placed in the bypassed condition. CTS Table 3.3-3 Action 19 states that with less than the minimum number of Functional Unit 7.b channels OPERABLE, startup and power operations may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If CTS Table 3.3-3 Action 14, Action 16, or Action 19 is not met, entry into CTS 3.0.3 is required since no further actions are specified. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action, 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months for the unit to be placed in MODE 3, 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months for the unit to be in MODE 4, and 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5.

ITS 3.3.2 ACTION G requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , ITS 3.3.2 ACTION H requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and ITS 3.3.2 ACTION I requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by providing a specific default condition instead of requiring entry into CTS 3.0.3, and reducing the time allowed to reach the applicable conditions.

This change is acceptable because the CTS requirements are modified to provide the necessary Required Actions and appropriate Completion Times. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to reach MODE 3, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 4, and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach MODE 5 from 100% RTP, in a safe manner without challenging unit systems, is consistent with other CTS and ITS requirements.

This change is designated as more restrictive because the Completion Times for the unit to be placed in the specified MODES have been decreased by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

M.5 CTS Table 3.3-3 includes the ESFAS interlocks. The Table does not include the requirements for the P-4 interlock. ITS LCO 3.3.2 and Table 3.3.2-1 Function 8.a requires the OPERABILITY of the Reactor Trip P-4 interlock. This interlock requires one channel per train of this Function in MODES 1, 2, and 3. If one channel is inoperable, ITS 3.3.2 ACTION B provides 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the train to OPERABLE status. If not restored, ACTION H requires a unit shutdown to MODE 4. In addition, a requirement has been added to perform a TADOT (SR 3.3.2.9) every 24 months. This changes the CTS by adding the requirements for the P-4 interlock.

The purpose of the P-4 interlock is to provide the appropriate interlock when the Reactor Trip Breaker and its corresponding bypass breaker are open. The interlock is assumed to block re-actuation of safety injection after manual reset of Safety Injection actuation signal. This function is necessary to meet the accident and transient analyses. This change is designated as more restrictive because it adds an explicit LCO, Applicability, ACTIONS, and Surveillance Requirements for the P-4 interlock to the Technical Specifications.

M.6 CTS Table 4.3-2 Functional Units 1.b, 2.b, 3.b.2), 4.b, and 10.b provide the Surveillance Requirements for the Automatic Actuation Logic. CTS Table 4.3-2 does not provide requirements to test the master and slave relays associated with this logic. ITS Table 3.3.2-1 Functions 1.b, 2.b, 3.b.(2), 4.b, and 7.b (the Automatic Actuation Logic and Actuation Relays Functions) require the performance of a MASTER RELAY TEST (SR 3.3.2.4) every 92 days on a STAGGERED TEST BASIS and a SLAVE RELAY TEST (SR 3.3.2.8) every 24 months. This changes the CTS by explicitly requiring the master and slave relays to be tested at the specified Frequencies.

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INSTRUMENTATION This change is acceptable because these relays are required to support the Automatic Actuation Logic required to support the OPERABILITY of the associated equipment. As such, explicitly including requirements for the master and slave relays in the Technical Specifications provides additional assurance that the OPERABILITY of the associated ESFAS Automatic Actuation Logic and Actuation Relays Functions will be maintained. The proposed Frequencies of testing of the master relays is consistent with the current Frequency of testing of the CHANNEL FUNCTIONAL TEST associated with the Automatic Actuation Logic. The Frequency proposed for the slave relays is consistent with the Frequency proposed for the simulated actuation tests. This change is designated as more restrictive because it adds explicit Surveillance Requirements to the Technical Specifications for the master and slave relays associated with ESFAS instrumentation Functions.

M.7 CTS Table 4.3-2 Functional Unit 5, which provides the Surveillance Requirements for the Turbine Trip and Feedwater Isolation instrumentation, does not include an SI Input from ESFAS Functional Unit. However, CTS Table 4.3-2 Functional Unit 1 requires the Safety Injection Function to also provide input to the Turbine Trip and Feedwater Isolation Function. ITS Table 3.3.2-1 Function 5.c requires the two SI Input from ESFAS trains to be OPERABLE and requires the performance of SR 3.3.2.9, a TADOT, every 24 months. This changes the CTS by adding an explicit requirement to perform a TADOT to test the SI Input from ESFAS Function in order to support the Turbine Trip and Feedwater Isolation instrumentation. The addition of the LCO, number of channels, Applicability, and ACTIONS is discussed in DOCs A.8, L.15, and L.16.

The change is acceptable since SR 3.3.2.9 ensures the SI Input from ESFAS Function is available to support the Turbine Trip and Feedwater Isolation instrumentation. The proposed Surveillance and Frequency is considered adequate to ensure the Function is OPERABLE. This change is designated as more restrictive because it adds an explicit Surveillance Requirement to the Technical Specifications to test the SI Input from ESFAS Function, to ensure this Function is available to support the Turbine Trip and Feedwater Isolation instrumentation.

M.8 CTS Table 4.3-2 Functional Unit 3.a, Containment Isolation Phase "A" Isolation, does not include the Automatic Actuation Logic and Actuation Relays Function.

ITS Table 3.3.2-1 Function 3.a.(2) requires the two Automatic Actuation Logic and Actuation Relays trains to be OPERABLE and requires the performance of SR 3.3.2.2, an ACTUATION LOGIC TEST, and SR 3.3.2.4, a MASTER RELAY TEST, every 92 days on a STAGGERED TEST BASIS and SR 3.3.2.8, a SLAVE RELAY TEST, every 24 months. This changes the CTS by adding the explicit Surveillances for proposed ITS Table 3.3.2-1 Function 3.a.(2), Containment Isolation Phase A Isolation Automatic Actuation Logic and Actuation Relays, to the Technical Specifications. The addition of the LCO, number of channels, and ACTIONS is discussed in DOC A.7.

This change is acceptable because the Automatic Actuation Logic and Actuation Relays Function is required to support the OPERABILITY of the Containment Isolation Phase "A" Isolation Function. As such, explicitly including requirements CNP Units 1 and 2 Page 11 of 37 Attachment 1, Volume 8, Rev. 0, Page 276 of 818

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INSTRUMENTATION for the Automatic Actuation Logic and Actuation Relays Function in the Technical Specifications provides additional assurance that the OPERABILITY of the Containment Isolation Phase "A" Isolation Function will be maintained. The change provides explicit requirements for testing the Automatic Actuation Logic and Actuation Relays Function (ITS Table 3.3.2-1 Function 3.a.(2)). The addition of SR 3.3.2.2 (an ACTUATION LOGIC TEST), SR 3.3.2.4 (a MASTER RELAY TEST), and SR 3.3.2.8 (a SLAVE RELAY TEST) is acceptable since currently the requirements of SR 3.3.2.2 and SR 3.3.2.4 are satisfied during the 92 day performance of the CHANNEL FUNCTIONAL TEST for CTS Table 4.3-2 Functional Unit 3.a.2) (From Safety Injection Automatic Actuation Logic) channels, and the requirements of SR 3.3.2.8 are satisfied during the performance of the TADOT associated with the Manual Initiation Function. This change is designated as more restrictive because it adds SRs for the Automatic Actuation Logic and Actuation Relays Function to the CTS.

M.9 CTS Table 3.3-3 Action 13 requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months if a Functional Unit 4.b, Steam Line Isolation Automatic Actuation Logic, or Functional Unit 10.b, Containment Air Recirculation Fan Automatic Actuation Logic, channel is inoperable (DOC L.9 discusses the addition of an allowable outage time prior to requiring a unit shutdown). However, CTS Table 3.3-3 Functional Units 4.b and 10.b are applicable only in MODES 1, 2, and 3. Thus, as described in CTS 3.0.1, CTS Table 3.3-3 Action 13 is only applicable in MODES 1, 2, and 3 for Functional Units 4.b and 10.b. CTS Table 3.3-1 Action 18 requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months if a Functional Unit 6.c, Motor Driven Auxiliary Feedwater Pumps Safety Injection, channel is inoperable and not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . However, CTS Table 3.3-3 Functional Unit 6.c is applicable only in MODES 1, 2, and 3. Thus, as described in CTS 3.0.1, CTS Table 3.3-3 Action 18 is only applicable in MODES 1, 2, and 3 for Functional Unit 6.c. ITS 3.3.2 ACTION H is the associated shutdown action for the above Functions, and it only requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by explicitly specifying that the unit is only required to be shut down to MODE 4, and that it must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , not 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The purpose of CTS Table 3.3-3 Actions 13 and 18 is to place the unit in a MODE in which Functional Unit 4.b, 10.b, or 6.c, respectively, does not apply.

The change is acceptable because the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time to reach MODE 4 is consistent with other CTS and ITS requirements, and provides adequate time to reach the MODE in a safe manner without challenging unit systems. This change is designated as more restrictive because the Completion Time for the unit to reach MODE 4 has been decreased by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

M.10 CTS Table 4.3-2, Functional Unit 6.b (Motor Driven AFW Pumps 4 kV Bus Loss of Voltage) and Functional Unit 7.b (Turbine Driven AFW Pump Reactor Coolant Pump Bus Undervoltage) require the performance of a CHANNEL CALIBRATION every 18 months, however the Surveillances are currently being performed more frequently. ITS Table 3.3.2-1 Function 6.e (Auxiliary Feedwater Loss of Voltage) and Function 6.f (Auxiliary Feedwater Undervoltage Reactor Coolant Pump) require the performance of a CHANNEL CALIBRATION every CNP Units 1 and 2 Page 12 of 37 Attachment 1, Volume 8, Rev. 0, Page 277 of 818

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INSTRUMENTATION 184 days (ITS SR 3.3.2.7). This changes the CTS by changing the Frequency of the Surveillance from 18 months to 184 days.

The purpose of the CHANNEL CALIBRATION is to ensure the Motor Driven AFW Pumps 4 kV Bus Loss of Voltage and Turbine Driven AFW Pump Reactor Coolant Pump Bus Undervoltage channels will function as designed during an analyzed event. Changing the SR Frequency is acceptable because a 184 day calibration interval is assumed in the setpoint analysis. This change is designated as more restrictive because Surveillances will be performed more frequently under the ITS than under the CTS.

M.11 CTS Table 3.3-4 provides the Allowable Values for Functional Unit 1.c (Safety Injection Containment Pressure - High), Functional Unit 1.f (Safety Injection Steam Line Pressure - Low) (Unit 1 only), Functional Unit 2.c (Containment Spray - Containment Pressure - High High), Functional Unit 3.b.3 (Containment Isolation Phase "B" Containment Pressure - High High), Functional Unit 4.c (Steam Line Isolation Containment Pressure - High High), Functional Unit 4.e (Steam Line Isolation Steam Line Pressure - Low) (Unit 1 only),

Functional Unit 6.a (Motor Driven Auxiliary Feedwater Pumps Steam Generator Water Level - Low Low) (Unit 2 only), Functional Unit 7.a (Turbine Driven Auxiliary Feedwater Pumps Steam Generator Water Level - Low Low) (Unit 2 only), and Functional Unit 10.c (Containment Pressure - High). ITS Table 3.3.2-1 provides the Allowable Values for all the ESFAS Instrumentation Functions, including ITS Table 3.3.2-1 Functions 1.c, 1.e.(1), 2.c, 3.b.(3), 4.c, 4.d, 6.c, and 7.c. This change revises the above specified CTS ESFAS Table 3.3-4 Allowable Values to the ITS Allowable Values.

The purpose of the Allowable Values is to ensure the instruments function as assumed in the safety analyses. ITS 3.3.2 reflects Allowable Values consistent with the philosophy of Westinghouse ISTS, NUREG-1431. These Allowable Values have been established consistent with the methods described in AEP's Instrument Setpoint Methodology (EG-IC-004, "Instrument Setpoint Uncertainty,"

Rev. 4). For all cases where a SAL exists, the Allowable Value determinations were calculated using plant specific operating and surveillance trend data. For all other cases, existing Allowable Values were converted directly to the ITS Allowable Values. The Allowable Value verification used actual plant operating and surveillance trend information to ensure the validity of the developed Allowable Value. There were no changes to SALs required due to instrument performance. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ANSI/ISA S67.04-Part I-1994 and ANSI/ISA RP67.04-Part II-1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for each SAL have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy using the instrument setpoint methodology. The Allowable Values have also been established from each SAL by combining the errors associated with the CNP Units 1 and 2 Page 13 of 37 Attachment 1, Volume 8, Rev. 0, Page 278 of 818

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INSTRUMENTATION CHANNEL OPERATIONAL TEST (COT) (e.g., device accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint using the instrument setpoint methodology. Where a SAL exists, trigger values are used to ensure that the Allowable Value provides sufficient margin from the SAL to account for any associated errors not confirmed by the COT. Use of the previously discussed methodologies for determining Allowable Values, NTSPs, and analyzing channel/instrument performance ensure that the design basis and associated SALs will not be exceeded during plant operation. These evaluations, determinations, and analyses now form a portion of the CNP design bases.

Additionally, each applicable channel/instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These drift evaluations and drift analyses have been performed utilizing the guidance provided in EPRI TR-103335, "Statistical Analysis of Instrument Calibration Data/

Guidelines for Instrument Calibration Extension/Reduction Programs," Rev. 1.

The EPRI guidance was used to demonstrate that the data collected by the operating plant (from Surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Therefore, based on the above discussion, the changes to the Allowable Values are acceptable. This change is designated as more restrictive because more stringent Allowable Values are being applied in the ITS than were applied in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.3.2.1 requires the ESFAS instrumentation setpoints to be set consistent with the Trip Setpoint values shown in Table 3.3-4.

CTS 3.3.2.1 Action a is required to be entered when the setpoint is less conservative than the Allowable Value. The channel is to be declared inoperable until adjusted consistent with the Trip Setpoint value. CTS Table 3.3-4 specifies the Trip Setpoints and Allowable Values for the ESFAS Instrumentation Functional Units. ITS 3.3.2 requires the ESFAS instrumentation for each Function in Table 3.3.2-1 to be OPERABLE. ITS Table 3.3.2-1 specifies the Allowable Values for the ESFAS Instrumentation Functions. This changes the CTS by moving the Trip Setpoints and associated requirements to the Technical Requirements Manual (TRM).

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the Allowable Values associated with the ESFAS Instrumentation. Also, this change is acceptable because these types of procedural details will be adequately controlled in the CNP Units 1 and 2 Page 14 of 37 Attachment 1, Volume 8, Rev. 0, Page 279 of 818

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INSTRUMENTATION TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. 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.

LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-3 for ESFAS instrumentation has three columns stating various requirements for each Functional Unit. These columns are labeled, "TOTAL NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." In addition, the titles for CTS Table 3.3-3 Functional Units 6 and 7 provide clarifying information concerning motor driven and turbine driven AFW pump logic, and CTS Table 3.3-3 Functional Unit 6.b provides clarifying information concerning motor driven AFW pump and valve actuation logic. ITS Table 3.3.2-1 does not retain the "TOTAL NO. OF CHANNELS" or "CHANNELS TO TRIP" columns, nor the logic description for the motor driven AFW pumps and valves and turbine driven AFW pumps. This changes the CTS by moving the information of the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns and the logic description for the motor driven AFW pumps and valves and turbine driven AFW pump to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.3 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Tables 3.3-3, 3.3-4, and 4.3-2 Functional Unit 1 provides the ESFAS actuation Functions associated with Safety Injection, Turbine Trip, Feedwater Isolation, and Motor Driven Auxiliary Feedwater Pumps.

CTS Tables 3.3-3, 3.3-4, and 4.3-2 Functional Unit 9.a states, in part, the Manual Initiation Function is associated with Reactor Trip (SI) and Essential Service Water System. ITS Table 3.3.2-1 Function 1 provides all the Functions associated with Safety Injection including the Manual Initiation Function. This changes the CTS by moving the details of the logic initiation from the Specification to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for the Functions to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to CNP Units 1 and 2 Page 15 of 37 Attachment 1, Volume 8, Rev. 0, Page 280 of 818

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INSTRUMENTATION the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.4 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-3 specifies the functions and logic of the P-11 and P-12 interlocks. ITS Table 3.3.2-1 Functions 8.b and 8.c do not include this information. The ITS only specifies that there is 1 channel per train of each of the interlocks. This changes the CTS by moving the functional description and logic associated with each of the interlocks specified in the Table to the Bases.

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

LA.5 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-4 Functional Unit 5.a provides an Allowable Value of < 68% of narrow range instrument span for the Steam Generator Water Level -

High High channels. CTS Table 3.3-4 Functional Units 6.a and 7.a provides an Allowable Value of > 16% (Unit 1) and > 19.2% (Unit 2) of narrow range instrument span for the Steam Generator Water Level - Low Low channels. ITS Table 3.3.2-1 Function 5.b provides an Allowable Value for the Steam Generator Water Level - High High channels in terms of percent, but does not include the detail of the associated narrow range instrument span. ITS Table 3.3.2-1 Function 6.c provides an Allowable Value for the Steam Generator Water Level -

Low Low channels in terms of percent, but does not include the detail of the associated narrow range instrument span. This changes the CTS by moving the details of what the setting in % is based upon to the Technical Requirements Manual (TRM).

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the value for each of the Allowable Values. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated.

This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

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INSTRUMENTATION LA.6 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 4.3-2, including Note 3, requires a CHANNEL FUNCTIONAL TEST for Functional Units 1.c and 10.c (Containment Pressure - High), and Functional Units 2.c, 3.b.3), and 4.c (Containment Pressure - High High), and includes requirements for exercising the transmitter "by applying a vacuum or pressure to the appropriate side of the transmitter."

ITS SR 3.3.2.5 and associated Note requires the performance of a COT and the exercising of the transmitter, but does not include the information relating to the method of exercising the transmitter. This changes the CTS by moving the explicit method for performing the transmitter exercise to the Bases. The change which changes this test from a CHANNEL FUNCTIONAL TEST to a COT is discussed in DOC A.10.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements that the Containment Pressure - High and Containment Pressure - High High channels remain OPERABLE and a COT and transmitter exercise is still required to be performed. 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 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.3.2.1.2 requires the total interlock function to be demonstrated OPERABLE at least once per 18 months. ITS SR 3.3.2.12 requires the performance of a CHANNEL OPERATIONAL TEST (COT), which tests a portion of the total interlock function, every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.3.2.1.2 is to ensure the proper operation of the ESFAS interlock functions. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance CNP Units 1 and 2 Page 17 of 37 Attachment 1, Volume 8, Rev. 0, Page 282 of 818

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INSTRUMENTATION test interval for this COT is acceptable because during the operating cycle, there is sufficient indication of the status of Tavg and pressurizer pressure and the ESFAS interlock status to ensure the interlocks are in the correct status. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS 4.3.2.1.2 requires the total interlock function to be demonstrated OPERABLE at least once per 18 months. CTS Table 4.3-2 requires a CHANNEL CALIBRATION of Functional Units 1.c through 1.f, 2.c, 3.b.3), 4.c through 4.e, 5.a, 6.a, 7.a, and 10.c every 18 months. ITS Table 3.3.2-1 Functions 1.c, 1.d, 1.e.(1), 1.e.(2), 2.c, 3.b.(3), 4.c through 4.e, 5.b, 6.c, 7.c, 8.b, and 8.c require the performance of a CHANNEL CALIBRATION every 24 months (ITS SR 3.3.2.10). This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of the CHANNEL CALIBRATION required by CTS 4.3.2.1.2 and Table 4.3-2 is to ensure the ESFAS instrumentation and interlocks be calibrated correctly to ensure the safety analysis can be met. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. This change is acceptable because the ESFAS, including the actuation logic, is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one of the channel componets. Furthermore, the impacted ESFAS instrumentation has been evaluated for drift using both quantitative and qualitative analysis, based on manufacturer and model number to determine that the instrumentation's actual drift falls within the design allowance in the associated setpoint calculation.

Functional Units 1.c, 10.c, Containment Pressure - High This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used CNP Units 1 and 2 Page 18 of 37 Attachment 1, Volume 8, Rev. 0, Page 283 of 818

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INSTRUMENTATION in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Unit 1.d, Pressurizer Pressure - Low This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Unit 1.e, Differential Pressure Between Steam Lines - High This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by Foxboro N-2AI-H2V Input Cards and Foxboro N-2CCA-DC Control Cards performing the trip functions. The signal conditioners and control cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Units 1.f, 4.e, Steam Line Pressure - Low This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioners and control cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

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INSTRUMENTATION Functional Units 2.c, 3.b.3), 4.c, Containment Pressure - High High This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Unit 4.d, Steam Flow in Two Steam Lines - High coincident with Tavg -

Low Low This function is performed by a loop consisting of 200 Platinum RTDs and Foxboro N-E13 Series Differential Pressure Transmitters with the signals conditioned by Foxboro N-2AI-H2V and N-2AI-P2V Input Cards with a Foxboro N-2CCA-DC Control Card performing the trip functions. The trip setpoint is generated using a Foxboro N-2CCA-DC Control Card based on Turbine Impulse Pressure. The Turbine Impulse Pressure portion of the function is performed by a Foxboro E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card. The Foxboro N-2CCA-DC Control Card generates the setpoint signal. The input and Control Cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified by a COT every 184 days, and if necessary, recalibrated (with the exception of the generated setpoint signal which is calibrated every 24 months). These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The RTDs are not calibrated, and as such, instrument drift does not apply to these devices. Response of the RTDs to temperature variations during normal plant operation and during the more frequent testing verifies proper operation of the input signal. The Foxboro Transmitters drift, (for Differential Pressure and Pressure Transmitters) was determined by quantitative analysis as was the drift for the rack equipment used to generate the setpoint.

The drift values determined have been used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of these analyses will support a 24 month Surveillance interval.

Functional Unit 5.a, Steam Generator Water Level - High High This function is performed by a Foxboro (N-)E13 Series Differential Pressure Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, CNP Units 1 and 2 Page 20 of 37 Attachment 1, Volume 8, Rev. 0, Page 285 of 818

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INSTRUMENTATION and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Differential Pressure Transmitters drift was determined by quantitative analysis.

The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

Functional Units 6.a, 7.a, Steam Generator Water Level - Low Low This function is performed by a Foxboro (N-)E13 Series Differential Pressure Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Differential Pressure Transmitters drift was determined by quantitative analysis.

The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

P-11 Interlock This function is performed by a Foxboro (N-)E11 Series Transmitter with the signal conditioned by a Foxboro N-2AI-H2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioner and control card are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged.

Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro Transmitters drift was determined by quantitative analysis. The drift value determined will be used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. The results of this analysis will support a 24 month surveillance interval.

P-12 Interlock This function is performed by a loop consisting of a 200 Platinum RTD as the sensing element with the signal conditioned by a Foxboro N-2AI-P2V Input Card and a Foxboro N-2CCA-DC Control Card performing the trip functions. The signal conditioners and control cards are a part of the Foxboro Spec 200 Micro digital rack. The racks are functionally checked and setpoint verified more frequently, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration surveillance interval does not affect the Foxboro rack components with respect to drift. The RTD sensing element is not subject to drift nor is it calibratable; CNP Units 1 and 2 Page 21 of 37 Attachment 1, Volume 8, Rev. 0, Page 286 of 818

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INSTRUMENTATION therefore a quantitative analysis for the sensing element was not required. The results of this analysis will support a 24 month surveillance interval.

Based on the design of the instrumentation and the drift evaluations, it is concluded that the impact, if any, from this change on system availability is minimal. A review of the Surveillance test history was performed to validate the above conclusion. This review demonstrates that there are no failures that would invalidate the conclusion that the impact, if any, on system availability from this change is minimal. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.3.2.1.3 requires the ESF RESPONSE TIME of each ESFAS function to be demonstrated to be within limit. ITS SR 3.3.2.13 requires the same test, however a Note is included that allows a delay in the performance of the test for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the required steam pressure of

> 850 psig is reached. This changes the CTS by providing an allowance for delaying the performance of required testing without requiring the turbine driven AFW pump to be declared inoperable.

The purpose of CTS 4.3.2.1.3 is to ensure the ESF RESPONSE times are within limit. The allowance provides for entry into MODE 3 before requiring the testing of the pump. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change is necessary because the main steam pressure may be insufficient in MODE 4 to accurately test the pump, and only a short time is allowed without verification of the required testing. The majority of SRs demonstrate equipment is, in fact, OPERABLE when the tests are performed.

Inconsistent testing results may result if testing of the turbine driven AFW pump is required before establishing a sufficient steam pressure. The allowance will permit the establishment of stable unit conditions and sufficient steam pressure to test the pump and will allow an accurate and consistent method for the testing.

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.4 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.3.2.1.3 requires the ESF RESPONSE TIME of each ESFAS function to be demonstrated to be within limit at least once per 18 months. ITS SR 3.3.2.13 requires the same test at a 24 month Frequency.

This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

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INSTRUMENTATION The purpose of CTS 4.3.2.1.3 is to ensure the actuation response times are less than or equal to the maximum values assumed in the accident analysis. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for the ESF RESPONSE TIME test is acceptable because the ESFAS instrumentation is verified to be operating properly throughout the operating cycle by the performance of CHANNEL OPERATIONAL TESTS and, in some cases, CHANNEL CHECKS.

This testing ensures that a significant portion of the ESFAS circuitry is operating properly and will detect significant failures of this circuitry. Additional justification for extending the Surveillance test interval is that the ESFAS, including the actuating logic, is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one of the channel components. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.5 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 13, which applies when a Functional Unit 1.b (Safety Injection Automatic Actuation Logic),

2.b (Containment Spray Automatic Actuation Logic), 3.a.2) (Containment Isolation Phase "A" Isolation From SI Automatic Actuation Logic),

3.b.2) (Containment Isolation Phase "B" Isolation Automatic Actuation Logic), 4.b (Steam Line Isolation Automatic Actuation Logic), or 10.b (Containment Air Recirculation Fan Automatic Actuation Logic) train is inoperable, allows one channel to be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1. CTS Table 3.3-3 Action 14, which applies when a Functional Unit 1.c (Safety Injection Containment Pressure - High), 1.d (Safety Injection Pressurizer Pressure - Low), 1.e (Safety Injection Differential Pressure Between Steam Lines - High), 1.f (Safety Injection Steam Line Pressure - Low),

4.d (Steam Line Isolation Steam Flow in Two Steam Lines - High Coincident with Tavg - Low Low), 4.e (Steam Line Isolation Steam Line Pressure - Low),

5.a (Turbine Trip and Feedwater Isolation Steam Generator Water Level - High High), 6.a (Motor Driven Auxiliary Feedwater Pumps Steam Generator Water Level - Low Low), 7.a (Turbine Driven Auxiliary Feedwater Pumps Steam Generator Water Level - Low Low), or 10.c (Containment Air Recirculation Fan Containment Pressure - High) channel is inoperable, requires the inoperable channel to be placed in trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . No allowance is provided in this Action to allow an inoperable channel to be bypassed for surveillance testing.

CTS Table 3.3-3 Action 16, which applies when a Functional Unit 2.c CNP Units 1 and 2 Page 23 of 37 Attachment 1, Volume 8, Rev. 0, Page 288 of 818

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INSTRUMENTATION (Containment Spray Containment Pressure - High High), 3.b.3) (Containment Isolation Phase "B" Isolation Containment Pressure - High High), or 4.c (Steam Line Isolation Containment Pressure - High High) channel is inoperable, allows one channel to be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1. CTS Table 3.3-3 Action 19, which applies when a Functional Unit 7.b (Turbine Driven Auxiliary Feedwater Pumps Reactor Coolant Pump Bus Undervoltage) channel is inoperable, requires the inoperable channel to be tripped within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and allows one channel to be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1. ITS 3.3.2 ACTION C, which applies to one train inoperable for ITS Table 3.3.2-1 Functional Units 1.b, 2.b, 3.a.(3), 3.b.(2), 4.b, and 7.b, includes an allowance to bypass one train for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

ITS 3.3.2 ACTION D, which applies to one channel inoperable for ITS Table 3.3.2-1 Functions 1.c, 1.d, 1.e.(1), 1.e.(2), 4.d, 4.e, 5.b, 6.c, 6.f, and 7.c, requires the inoperable channel be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and includes an allowance to bypass one channel for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels. ITS 3.3.2 ACTION E, which applies to one channel inoperable for ITS Table 3.3.2-1 Functions 2.c, 3.b.(3), and 4.c, includes an allowance to bypass one train for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE. This changes the CTS by: a) extending the time allowed to bypass an inoperable train from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for CTS Table 3.3-3 Functional Units 1.b, 2.b, 3.a.2), 3.b.2), 4.b, and 10.b; b) extending the time allowed to place an inoperable CTS Table 3.3-3 Functional Units 1.c, 1.d, 1.e, 1.f, 4.d, 4.e, 5.a, 6.a, 7.a, and 10.c channel in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and adding an allowance to bypass an inoperable channels of the above CTS Functional Units for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; c) extending the time allowed to bypass an inoperable channel from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for CTS Table 3.3-3 Functional Units 2.c, 3.b.3), and 4.c; and d) extending the time allowed to place an inoperable CTS Table 3.3-3 Functional Unit 7.b channel in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and extending the time allowed to bypass an inoperable CTS Table 3.3-3 Functional Unit 7.b channel from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The purpose of the current Actions is to provide a short period of time to restore the inoperable channel or train to OPERABLE status. The proposed bypass time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in ITS 3.3.2 ACTIONS C, D, and E is a sufficient time to perform train or channel surveillance. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time period is acceptable since it is considered an acceptable amount of time based on the risk analysis of WCAP-10271-P "Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System." The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time specified in ITS 3.3.2 ACTIONS C, D, and E is also acceptable since the change results in a small and therefore acceptable impact on plant risk as stated in the NRC Safety Evaluation Reports (SERs) associated with WCAP-10271-P. I&M has performed an evaluation to ensure that the conditions of the three NRC SERs supporting WCAP-10271-P, including Supplements 1 and 2 and Supplement 2, Rev. 1, have been met for the proposed ITS Completion Time and/or bypass time. Specifically, the NRC imposed five conditions on utilities seeking to implement the Technical Specification changes approved generically as a result of their review of WCAP-10271 and WCAP-10271 Supplement 1, and two conditions as a result of their review of WCAP-10271 Supplement 2 and Supplement 2, Rev. 1. Two of the conditions CNP Units 1 and 2 Page 24 of 37 Attachment 1, Volume 8, Rev. 0, Page 289 of 818

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INSTRUMENTATION imposed in the Reactor Trip System (RTS) SER are now not applicable due to approvals given in the ESFAS SER. Conditions given in the RTS SER are considered to apply equally to the ESFAS Functions and equipment, and the conditions given in the ESFAS SER are considered to apply equally to the RTS Functions and equipment. I&M provided results of this evaluation to the NRC by application dated August 30, 2002 as supplemented by letters dated February 27, April 7, April 29, and May 2, 2003, that requested approval for increasing the CHANNEL OPERATIONAL TEST Surveillance intervals for analog channels, logic cabinets, and reactor trip breakers, and increasing the Completion Time and bypass time for the reactor trip breakers, as allowed by WCAP-15376-P, Rev. 0, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," and the Nuclear Regulatory Commission (NRC) staffs approved Technical Specification Task Force (TSTF) Traveler TSTF-411, Rev. 1, "Surveillance Test Interval Extension for Components of the Reactor Protection System." The NRC granted approval for these new requirements based upon WCAP-15376 by issuing License Amendments 277 (Unit 1) and 260 (Unit 2) on May 23, 2003. In the NRC SER for these amendments, the NRC stated that the December 20, 2002 acceptance letter for WCAP-15376 noted that this topical report was built on the foundation established by WCAP 10271-P and WCAP-14333, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times." As a result, the NRC staffs review of I&Ms application, as supplemented, verified that the applicable implementation requirements associated with the NRC staff acceptance of WCAP-10271 was also adequately addressed by I&M. Therefore, this change is considered acceptable. The WCAP-10271-P analysis did not review the Containment Air Recirculation Fan Automatic Actuation Logic and Containment Pressure - High Functions.

However, since the design of these Functions are similar to the Safety Injection Actuation Logic and Containment Pressure - High Functions, the risk associated with increasing the Completion Times and bypass time are considered acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.6 (Category 2 - Relaxation of Applicability) CTS Tables 3.3-3 and 4.3-2 require Functional Units 4.b (Steam Line Isolation Automatic Actuation Logic), 4.c (Steam Line Isolation Containment Pressure - High High), 4.d (Steam Line Isolation Steam Line Flow in Two Steam Lines - High), 4.e (Steam Line Isolation Steam Line Pressure - Low), and 9.d (Steam Line Isolation Manual Initiation) to be OPERABLE in MODES 1, 2, and 3. ITS Table 3.3.2-1, including Footnote (d),

requires these same Functions (ITS Table 3.3.2-1 Functions 4.a, 4.b, 4.c, 4.d, and 4.e) to be OPERABLE in MODE 1, and in MODES 2 and 3 except when all steam generator stop valves (SGSVs) are closed. This changes the CTS by making the Specification for these Functions not applicable in MODES 2 and 3 when all SGSVs are closed.

The purpose of the ITS Table 3.3.2-1 Function 4 Applicability exception is to clarify that the Steam Line Isolation instrumentation Functions are not required when the SGSVs are in a position that supports the safety analyses. This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other CNP Units 1 and 2 Page 25 of 37 Attachment 1, Volume 8, Rev. 0, Page 290 of 818

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INSTRUMENTATION specified conditions assumed in the safety analyses and licensing basis. When all the valves are in the closed position, they are in their assumed accident position, thus the isolation instrumentation is not needed. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.7 (Category 2 - Relaxation of Applicability) CTS Tables 3.3-3 and 4.3-2 require Functional Unit 5.a (Turbine Trip and Feedwater Isolation Steam Generator Water Level - High High) to be OPERABLE in MODES 1, 2, and 3. ITS Table 3.3.2-1 requires the same Function (ITS Table 3.3.2-1 Function 5.b) to be OPERABLE in MODE 1, and in MODES 2 and 3 except when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve. This changes the CTS by not requiring the instrumentation to be OPERABLE when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve.

The purpose of the ITS Table 3.3.2-1 Function 5.b Applicability exception is to clarify that the Turbine Trip and Feedwater Isolation Steam Generator Water Level - High High instrumentation is not required when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve. In this condition, the Function will not need to function since the valves are in a position that supports the safety analyses. This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all the valves are in the closed position, they are in their assumed accident position. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.8 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Functional Unit 5, Turbine Trip and Feedwater Isolation, does not include the Automatic Actuation Logic and Actuation Relay Function. ITS Table 3.3.2-1 Function 5.a requires two Automatic Actuation Logic and Actuation Relay trains to be OPERABLE in MODE 1, and MODES 2 and 3 except when all MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve. This addition is discussed in DOC A.12. ITS 3.3.2 ACTIONS C and H have been included for this Function and provide 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable train to OPERABLE status if one train is inoperable (ACTION C), and if not restored, provide a shutdown requirement (ACTION H). This changes the CTS by providing specific ACTIONS to take when an Automatic Actuation Logic and Actuation Relays Function associated with Turbine Trip and Feedwater Isolation instrumentation is inoperable.

The purpose of the ITS 3.3.2 ACTION C is to provide a short period of time to restore an inoperable Automatic Actuation Logic and Actuation Relays train and the purpose of ITS 3.3.2 ACTION H is to place the unit outside the Applicability of the Turbine Trip and Feedwater Isolation instrumentation. Currently, if the Automatic Actuation Logic and Actuation Relays Function is inoperable, the affected Turbine Trip and Feedwater Isolation instrumentation channels would be required to be declared inoperable, resulting in entry into CTS 3.0.3 since no CNP Units 1 and 2 Page 26 of 37 Attachment 1, Volume 8, Rev. 0, Page 291 of 818

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INSTRUMENTATION Action is provided for this case. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action, 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months for the unit to be placed in MODE 3, and 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months for the unit to be placed in MODE 4. If a train is inoperable, ITS 3.3.2 provides 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the train to OPERABLE status (ACTION C), and if not restored, provides a shutdown requirement (ACTION H). ITS 3.3.2 ACTION H requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The proposed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.2 ACTION C is acceptable considering that there is another train OPERABLE and the low probability of an event occurring during this interval. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to reach MODE 3 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 4, in a safe manner without challenging unit systems, is consistent with other CTS and ITS requirements. In addition, this change is consistent with NUREG-1431. 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.9 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 13, which applies when a Functional Unit 1.b (Safety Injection Automatic Actuation Logic),

2.b (Containment Spray Automatic Actuation Logic), 3.a.2) (Containment Isolation Phase "A" Isolation From SI Automatic Actuation Logic), 3.b.2)

(Containment Isolation Phase "B" Isolation Automatic Actuation Logic), 4.b (Steam Line Isolation Automatic Actuation Logic), or 10.b (Containment Air Recirculation Fan Automatic Actuation Logic) train is inoperable, does not provide any time to restore the inoperable train. ITS 3.3.2 Required Action C.1 will allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable Function 1.b, 2.b, 3.a.(3), 3.b.(2), 4.b, or 7.b train to OPERABLE status prior to requiring a unit shutdown. This changes the CTS by allowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the affected train to OPERABLE status prior to commencing a shutdown.

The purpose of the ITS 3.3.2 ACTION C is to provide a short period of time to restore the inoperable train. The proposed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.2 ACTION C is acceptable considering that there is another train OPERABLE and the low probability of an event occurring during this interval. In addition, this change is consistent with NUREG-1431. 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.10 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 14 states, in part, that with the number of OPERABLE channels one less than the total number of channels, operations may proceed "until performance of the next required CHANNEL FUNCTIONAL TEST." This CTS Action applies to CTS Table 3.3-3 Functional Units 1.c through 1.f, 4.d, 4.e, 5.a, 6.a, 7.a, and 10.c.

ITS 3.3.2 ACTION D is the applicable ACTION for the above Functions when one channel is inoperable, and does not include the restoration time limit of "until performance of the next required CHANNEL FUNCTIONAL TEST." This changes the CTS by allowing operation with an inoperable channel for an unlimited amount of time provided the inoperable channel is in the tripped condition.

The purpose of CTS Table 3.3-3 Action 14 is to only allow operation until performance of the next required CHANNEL FUNCTIONAL TEST. This CNP Units 1 and 2 Page 27 of 37 Attachment 1, Volume 8, Rev. 0, Page 292 of 818

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INSTRUMENTATION requirement is based upon the assumption that when it is time to test the other OPERABLE channels in the associated Function, the OPERABLE channels cannot be tested with the inoperable channel in trip. However, CTS 3.0.6 (ITS LCO 3.0.5) is a generic allowance that will allow the inoperable channel to be restored to service in order to perform Surveillances on the other OPERABLE channels in the associated Function. Thus, using this generic allowance, it is possible to test the remaining OPERABLE channels in the associated Function and there is no reason to restrict the generic allowance from applying to these specific channels. As such, the CTS Table 3.3-3 Action 14 statement is not necessary and has been deleted. The administrative controls required by ITS LCO 3.0.5 will ensure the time the channel is returned to service in conflict with the requirements of ITS 3.3.2 ACTION D is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY of the other channels. In addition, this specific example (taking an inoperable channel out of the tripped condition) is discussed in the Bases of ISTS SR 3.0.5.

Therefore, this change is acceptable for the above described reasons. 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.11 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 16 states that with the number of OPERABLE Functional Unit 2.c, 3.b.3), or 4.c channels one less than the total number of channels, operations may proceed provided the inoperable channel is placed in the bypassed condition. ITS 3.3.2 ACTION E includes the same requirement, however a Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months has been added for placing the inoperable channel in bypass. This changes the CTS by allowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the inoperable channel in the bypass condition.

The purpose of the CTS Table 3.3-3 Action 16 is to provide compensatory measures when the Containment Pressure - High High channels are inoperable.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident occurring during the repair period.

In addition, this change is consistent with NUREG-1431. 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.12 (Category 4 - Relaxation of Required Action) CTS LCO 3.3.2.1 states that the interlocks of Table 3.3-3 shall be OPERABLE. However, no specific Actions are provided for when an interlock is inoperable. Therefore, all affected ESFAS instrumentation would be required to be declared inoperable, resulting in a CTS 3.0.3 entry. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and then requires the unit to be in MODES 3, 4, and 5 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , respectively. ITS 3.3.2 ACTION F provides the actions for when one or more P-11 interlock channels are inoperable. ITS 3.3.2 ACTION F requires a verification that the interlock is in the required state for existing unit conditions CNP Units 1 and 2 Page 28 of 37 Attachment 1, Volume 8, Rev. 0, Page 293 of 818

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INSTRUMENTATION within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.3.2 ACTION D provides the actions for when one P-12 interlock channel is inoperable. ITS 3.3.2 ACTION D requires the channel be placed in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If any of these two actions are not met, ITS 3.3.2 ACTION H requires the unit to be shut down to MODE 4. This changes the CTS by allowing continued operation as long as the P-12 interlock channel is placed in trip or as long as the P-11 interlock channel is placed in the correct state and providing shutdown actions if the inoperable interlock is not placed in the correct state.

The purpose of the interlocks is to ensure the associated ESFAS instrumentation is automatically enabled or disabled when required. This change is acceptable since the proposed ACTIONS ensure that the interlock is either tripped or manually placed in the correct state for the existing unit conditions, or the unit is placed in a MODE outside the Applicability of the associated interlock. ITS 3.3.2 ACTION D requires the interlock channel to be place in trip (i.e., this performs the intended function of the interlock). ITS 3.3.2 ACTION F requires the interlock to be placed in the same state as it would be normally placed in if it were automatically functioning (i.e., this performs the intended function of the interlock). If any of these actions are not accomplished within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , respectively, then ITS 3.3.2 ACTION H requires the unit to be placed in MODE 4, which is outside the Applicability of the associated interlock. The Required Actions and Completion Times for placing the unit in the MODE outside the Applicability of the interlocks are consistent with the Required Actions and Completion Times associated with exiting the Applicabilities for ESFAS Instrumentation Functions supported by the interlocks. With the unit placed in a MODE that is outside the Applicability of the associated interlock, the interlock is no longer required to function to support the required OPERABILITY of the associated ESFAS Instrumentation Function. 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.13 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS Table 4.3-2 Functional Unit 6.d (Loss of Main Feed Pumps) requires the performance of a CHANNEL FUNCTIONAL TEST every 18 months. CTS Table 4.3-2 Functional Units 9.a, 9.b, 9.c, 9.d, and 9.e (Manual Initiation) require the performance of a TADOT every 18 months. ITS Table 3.3.2-1 Functions 1.a, 2.a, 3.a.(1), 3.b.(1), 4.a, 6.g, and 7.a require the performance of SR 3.3.2.9, a TADOT, every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2). The change from a CHANNEL FUNCTIONAL TEST to a TADOT for CTS Table 4.3-2 Function 6.d is discussed in DOC A.10.

The purpose of the CHANNEL FUNCTIONAL TEST and the TADOT required by CTS Table 4.3-2 is to ensure the ESFAS instrumentation can perform its intended function. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, CNP Units 1 and 2 Page 29 of 37 Attachment 1, Volume 8, Rev. 0, Page 294 of 818

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INSTRUMENTATION 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Based on the inherent system and component reliability, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.14 (Category 5 - Deletion of Surveillance Requirement) CTS Table 4.3-2 Functional Unit 9.d (Steam Line Isolation Manual Initiation) requires the performance of a CHANNEL FUNCTIONAL TEST every 92 days. ITS Table 3.3.2-1 Function 4.a does not require this test. This changes the CTS by deleting the quarterly CHANNEL FUNCTIONAL TEST of the Steam Line Isolation Manual Initiation Function.

The purpose of the quarterly CHANNEL FUNCTIONAL TEST associated with CTS Table 4.3-2 Functional Unit 9.d is to ensure all circuitry associated with the Steam Line Isolation Manual Initiation Function channels are OPERABLE except for the manual actuation switches. The Manual Initiation Function design includes two redundant manual actuation switches per steam line, each of which can close the associated steam generator stop valve. CTS Table 4.3-2 for Functional Unit 9.d also requires the performance of a TADOT every 18 months.

The TADOT verifies the complete circuitry associated with the Manual Initiation Function channels. The Frequency of testing of the TADOT has been changed from 18 months to 24 months as discussed in DOC L.13. In reviewing the test history it has been determined that the performance of the TADOT is sufficient to ensure the circuitry remains OPERABLE. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.15 (Category 2 - Relaxation of Applicability) CTS Table 3.3-3 Functional Unit 5 specifies the requirements for the Turbine Trip and Feedwater Isolation. It does not contain the OPERABILITY requirements for the SI input from ESFAS. CTS Table 3.3-3 Functional Unit 1 requires the Safety Injection Function to also provide input to the Turbine Trip and Feedwater Isolation Function. The Applicability of CTS Table 3.3-3 Functional Unit 1.b, Automatic Actuation Logic is MODES 1, 2, 3, and 4. In addition, when a channel is inoperable, a shutdown to MODE 5 is required (CTS Table 3.3-3 Action 13). A new requirement was added as ITS Table 3.3.2-1 Function 5.c, SI Input from ESFAS, as discussed in DOC A.8. ITS Table 3.3.2-1 will require two trains of the SI Input from ESFAS Function capable of supporting the Turbine Trip and Feedwater Isolation instrumentation in MODE 1, and MODES 2 and 3 except when all main feedwater isolation valves (MFIVs) or main feedwater regulation valves (MFRVs) are closed and de-activated or isolated by a closed manual valve. Also, the ITS CNP Units 1 and 2 Page 30 of 37 Attachment 1, Volume 8, Rev. 0, Page 295 of 818

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INSTRUMENTATION shutdown action (ITS 3.3.2 ACTION H), only requires a shutdown to MODE 4.

This changes the CTS by making the SI Input from ESFAS Function only applicable in MODE 1, and MODES 2 and 3 except when MFIVs or MFRVs are closed and de-activated or isolated by a closed manual valve. Consistent with this change, the CTS shutdown action has been changed to only require a shutdown to MODE 4.

The purpose of the CTS Table 3.3-3 Applicability is to ensure that the SI Input from ESFAS Function that supports the Turbine Trip and Feedwater Isolation instrumentation is OPERABLE when it is needed to support the safety analyses.

This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all the MFIVs or MFRVs are in the closed position or isolated, they are essentially in their assumed accident position. In addition, when in MODE 4, the Turbine and Main Feedwater System are not in operation, thus the trip and isolation are also not needed. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.16 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Functional Unit 5 specifies the requirements for the Turbine Trip and Feedwater Isolation. It does not contain the OPERABILITY requirements for the SI input from ESFAS Function. CTS Table 3.3-3 Functional Unit 1 requires the Safety Injection Functions to also provide input to the Turbine Trip and Feedwater Isolation instrumentation. If a Functional Unit 1.b, Automatic Actuation Logic, train is inoperable, CTS Table 3.3-3 Action 13 (the applicable Action) does not provide any time to restore the inoperable train; a unit shutdown is required. A new requirement was added as ITS Table 3.3.2-1 Function 5.c, SI Input from ESFAS, as discussed in DOC A.8. If a channel of the SI Input from ESFAS Function is inoperable, ITS 3.3.2 ACTION C allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the channel to OPERABLE status. In addition, ITS 3.3.2 ACTION C includes an allowance to bypass one train for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE. If this cannot be met, ITS 3.3.2 ACTION H must be entered and the unit must be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by allowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the affected train to OPERABLE status prior to commencing a shutdown and allows a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months bypass time for Surveillance testing.

The purpose of the ITS 3.3.2 ACTION C is to provide a short period of time to restore the inoperable train to OPERABLE status. The purpose of the proposed bypass time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in ITS 3.3.2 ACTION C is to provide a sufficient time to perform a train Surveillance. The Turbine Trip and Feedwater Isolation SI Input from ESFAS Function receives its input from the output of the SI Automatic Actuation Logic (ITS Table 3.3.2-1 Function 1.b). The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the bypass time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months has been justified for the SI Automatic Actuation Logic in DOC L.9 and DOC L.5, respectively. Since the Turbine Trip and Feedwater Isolation SI Input Function receives its input from the SI Automatic Actuation Logic, extending the Completion Time and bypass times for this Function provides consistency between the Specifications and is considered CNP Units 1 and 2 Page 31 of 37 Attachment 1, Volume 8, Rev. 0, Page 296 of 818

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INSTRUMENTATION acceptable. 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.17 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Functional Units 6 (Motor Driven Auxiliary Feedwater Pumps) and 7 (Turbine Driven Auxiliary Feedwater Pumps) do not include the Automatic Actuation Logic and Actuation Relays Function. New requirements were added as ITS Table 3.3.2-1 Function 6.a, the Automatic Actuation Logic and Actuation Relays (Solid State Protection System) and Function 6.b, the Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS). The Applicability of these Functions is MODES 1, 2, and 3 and two trains of each Function are required to be OPERABLE, as discussed in DOC A.13. ITS 3.3.2 ACTIONS C and H have been included for these Functions and provide 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable train to OPERABLE status if one train is inoperable (ACTION C), and if not restored, provide a shutdown requirement (ACTION H). In addition, ITS 3.3.2 ACTION C includes an allowance to bypass one train for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Surveillance testing provided the other train is OPERABLE. ITS 3.3.2 ACTION H requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

This changes the CTS by providing specific ACTIONS to enter when an Automatic Actuation Logic and Actuation Relays Function associated with AFW instrumentation is inoperable.

The purpose of the ITS 3.3.2 ACTION C is to provide a short period of time to restore an inoperable Automatic Actuation Logic and Actuation Relays train and the purpose of ITS 3.3.2 ACTION H is to place the unit outside the Applicability of the Auxiliary Feedwater instrumentation. The purpose of the proposed bypass time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in ITS 3.3.2 ACTION C is to provide sufficient time to perform a train Surveillance. Currently, if an Automatic Actuation Logic and Actuation Relays Function is inoperable, the affected Auxiliary Feedwater instrumentation channels would be required to be declared inoperable, resulting in entry into CTS 3.0.3 since no Action is provided for this case. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action, 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months for the unit to be placed in MODE 3, and 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months for the unit to be placed in MODE 4. If a train is inoperable, ITS 3.3.2 provides 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the train to OPERABLE status (ACTION C), and if not restored, provides a shutdown requirement (ACTION H). ITS 3.3.2 ACTION H requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The proposed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.2 ACTION C is acceptable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to reach MODE 3 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 4, in a safe manner without challenging unit systems, is consistent with other CTS and ITS requirements. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months bypass time period is acceptable since it is considered an acceptable amount of time based on the risk analysis of WCAP-10271-P, "Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System." I&M has performed an evaluation to ensure that the conditions of the three NRC SERs supporting WCAP-10271-P, including Supplements 1 and 2 and Supplement 2, Rev. 1, have been met for the proposed ITS Completion Time and/or bypass time. Specifically, the NRC imposed five conditions on utilities seeking to implement the Technical Specification changes approved generically as a result of their review of WCAP-10271 and WCAP-10271 Supplement 1, and CNP Units 1 and 2 Page 32 of 37 Attachment 1, Volume 8, Rev. 0, Page 297 of 818

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INSTRUMENTATION two conditions as a result of their review of WCAP-10271 Supplement 2 and Supplement 2, Rev. 1. Two of the conditions imposed in the Reactor Trip System (RTS) SER are now not applicable due to approvals given in the ESFAS SER. Conditions given in the RTS SER are considered to apply equally to the ESFAS Functions and equipment, and the conditions given in the ESFAS SER are considered to apply equally to the RTS Functions and equipment. I&M provided results of this evaluation to the NRC by application dated August 30, 2002, as supplemented by letters dated February 27, April 7, April 29, and May 2, 2003, that requested approval for increasing the CHANNEL OPERATIONAL TEST surveillance intervals for analog channels, logic cabinets, and reactor trip breakers, and increasing the Completion Time and bypass time for the reactor trip breakers, as allowed by WCAP-15376-P, Rev. 0, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," and the Nuclear Regulatory Commission (NRC) staffs approved Technical Specification Task Force (TSTF)

Traveler TSTF-411, Rev. 1, "Surveillance Test Interval Extension for Components of the Reactor Protection System." The NRC granted approval for these new requirements based upon WCAP-15376 by issuing License Amendments 277 (Unit 1) and 260 (Unit 2) on May 23, 2003. In the NRC SER for these amendments, the NRC stated that the December 20, 2002 acceptance letter for WCAP-15376 noted that this topical report was built on the foundation established by WCAP 10271-P and WCAP-14333, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times." As a result, the NRC staffs review of I&Ms application, as supplemented, verified that the applicable implementation requirements associated with the NRC staff acceptance of WCAP-10271 was also adequately addressed by I&M. Therefore this change is considered acceptable. 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.18 (Category 2 - Relaxation of Applicability) CTS Table 3.3-3 Functional Unit 7.b, Reactor Coolant Pump Bus Undervoltage, which actuates the Turbine Driven Auxiliary Feedwater Pumps, is required to be OPERABLE during MODES 1, 2, and 3. ITS Table 3.3.2-1 Function 6.f (AFW Undervoltage Reactor Coolant Pump) is required to be OPERABLE only in MODES 1 and 2. This changes the CTS by reducing the applicable MODES in which the Reactor Coolant Pump Bus Undervoltage channels must be OPERABLE.

The purpose of CTS Table 3.3-3 Functional Unit 7.b, Reactor Coolant Pump Bus Undervoltage, is to ensure that a loss of power on the buses that provide power to the reactor coolant pumps provides indication of a pending loss of reactor coolant pump forced flow in the Reactor Coolant System (RCS). This change is acceptable because the requirements continue to ensure that the components are maintained in the MODES and other specified conditions assumed in the safety analyses. In MODES 1 and 2, all reactor coolant loops are required to be OPERABLE and in operation (ITS 3.4.4). In MODES 3, two RCS loops are required to be OPERABLE, and either two RCS loops are required to be in operation when the Rod Control System is capable of rod withdrawal or one RCS loop is required to be in operation when the Rod Control System is not capable of rod withdrawal (ITS 3.4.5). Therefore, the Reactor Coolant Pump Bus CNP Units 1 and 2 Page 33 of 37 Attachment 1, Volume 8, Rev. 0, Page 298 of 818

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INSTRUMENTATION Undervoltage Function does not actually provide any protection in MODE 3 since all RCS loops are not required to be in operation. Therefore, reducing the applicable MODES from MODES 1, 2, and 3 to MODES 1 and 2 is acceptable.

This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.19 (Category 9 - Surveillance Frequency Change Using GL 91-04 Guidelines, Non-24 Month Type Change) CTS Table 4.3-2 requires a CHANNEL FUNCTIONAL TEST of the Motor Driven Auxiliary Feedwater Pumps 4 kv Bus Loss of Voltage and the Turbine Driven Auxiliary Feedwater Pump Reactor Coolant Pump Bus Undervoltage instrumentation every 31 days. ITS SR 3.3.2.6 requires the performance of a TADOT for the Auxiliary Feedwater Loss of Voltage and Undervoltage Reactor Coolant Pump instrumentation every 184 days. This changes the CTS by extending the Frequency of the Surveillance from 31 days (i.e., a maximum of 38.75 days accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 184 days (i.e., a maximum of 230 days accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2). The change from a CHANNEL FUNCTIONAL TEST to a TADOT is discussed in DOC A.10.

The purpose of the CHANNEL FUNCTIONAL TEST requirement in CTS Table 4.3-2 is to ensure the channels of the Motor Driven Auxiliary Feedwater Pumps 4 kv Bus Loss of Voltage and the Turbine Driven Auxiliary Feedwater Pump Reactor Coolant Pump Bus Undervoltage Functions will function as designed during an analyzed event. An evaluation of the surveillance interval extension was performed, based on the same approach described in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for this CHANNEL FUNCTIONAL TEST (i.e., TADOT) is acceptable because the probability of significant variations of the pump power supply is remote, due to the plant electrical system and the offsite grid reliability. Based on the power supply reliability and on the inherent system and component reliability the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 184 day Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (230 days) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances may be performed less frequently under the ITS than under the CTS.

L.20 CTS Table 3.3-3, Functional Unit 9.a (Safety Injection, Manual Initiation) requires a total of two channels per train to be OPERABLE. ITS Table 3.3.2-1, Function 1.a requires only one channel per train to be OPERABLE. This changes the CTS by decreasing the number of manual channels required OPERABLE from two per train to one per train.

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INSTRUMENTATION The purpose of Safety Injection (SI) Manual Initiation Function is to ensure the capability exists to manually initiate the Safety Injection trains. The SI Manual Initiation Function at CNP is provided by four switches, two per train. Each switch will actuate the associated SI train (i.e., the two train A switches are fully redundant to each other and the two train B switches are fully redundant to each other). The only difference between the two switches within a train are their location within the control room. NUREG-1431 only requires two Manual Initiation channels to be OPERABLE, since a typical Westinghouse plant only has two channels installed. This change is acceptable since each channel within a train is fully redundant to the other channel in that train for the SI Manual Initiation Function, and the fact that it is consistent with the NUREG-1431 requirements. In addition, if the single required manual initiation switch does not function, the associated SI train can still be initiated using the individual component control switches that exist in the control room. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L.21 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Functional Unit 6.b (4 kV Bus Loss of Voltage) requires entry into Action 14, when one channel is inoperable. CTS Table 3.3-3 Action 14 requires the channel to be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In addition, Note

states that the provisions of CTS 3.0.4 are not applicable. ITS Table 3.3.2-1 Function 6.e (Loss of Voltage) requires entry into ACTION B when a channel is inoperable, and ACTION B requires the channel be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and no LCO 3.0.4 exemption is provided. This changes the CTS by deleting the requirement to trip the channel within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and continue to operate indefinitely and provides a Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the channel to OPERABLE status.

The purpose of the ITS 3.3.2 ACTION B is to provide a short period of time to restore the inoperable Loss of Voltage channel. Three undervoltage relays with time delays are provided for each 4.16 kV emergency bus to detect a loss of bus voltage. The relays are combined in a two-out-of-three logic to generate a loss of voltage signal (i.e., the required number of channels required to trip to generate a loss of voltage signal is two per bus). With one channel inoperable the remaining two channels associated with the bus can support the Loss of Voltage Function.

The specified Completion Time is reasonable considering the nature of this Function, the available redundancy, and the low probability of an event occurring during this interval. In addition, this change is consistent with NUREG-1431.

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.22 (Category 14 - Changing Instrumentation Allowable Values) CTS Table 3.3-4 provides the Allowable Values for Functional Unit 1.d (Pressurizer Pressure -

Low), Functional Unit 1.f (Steam Line Pressure - Low) (Unit 2 only), Functional Unit 4.d (Steam Line Isolation Steam Flow in Two Steam Lines - High Coincident with Tavg - Low Low) (Tavg - Low Low portion only is covered by this change),

Functional Unit 4.e (Steam Line Isolation Steam Line Pressure - Low)

(Unit 2 only), Functional Unit 5.a (Turbine Trip and Feedwater Isolation Steam Generator Water Level - High High) (Unit 2 only), Functional Unit 6.a (Motor CNP Units 1 and 2 Page 35 of 37 Attachment 1, Volume 8, Rev. 0, Page 300 of 818

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INSTRUMENTATION Driven Auxiliary Feedwater Pumps Steam Generator Water Level - Low Low)

(Unit 1 only), and Functional Unit 7.a (Turbine Driven Auxiliary Feedwater Pumps Steam Generator Water Level - Low Low) (Unit 1 only). CTS Table 3.3-3 provides the Setpoint (i.e., Allowable Value) for the P-12 Interlock (Tavg - Low Low). ITS Table 3.3.2-1 provides the Allowable Values for all the ESFAS Instrumentation Functions, including ITS Table 3.3.2-1 Functions 1.d, 1.e.(1), 4.d, 4.e, 5.b, 6.c, and 8.c. This change revises the above specified CTS ESFAS Table 3.3-4 Allowable Values to the ITS Allowable Values.

The purpose of the Allowable Values is to ensure the instruments function as assumed in the safety analyses. ITS 3.3.2 reflects Allowable Values consistent with the philosophy of Westinghouse ISTS, NUREG-1431. These Allowable Values have been established consistent with the methods described in AEP's Instrument Setpoint Methodology (EG-IC-004, "Instrument Setpoint Uncertainty,"

Rev. 4). For all cases where an S A L exists, the Allowable Value determinations were calculated using plant specific operating and surveillance trend data. For all other cases, existing Allowable Values were converted directly to the ITS Allowable Values.. The Allowable Value verification used actual plant operating and surveillance trend information to ensure the validity of the developed Allowable Value. There were no changes to SALs required due to instrument performance. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ANSI/ISA S67.04-Part I-1994 and ANSI/ISA RP67.04-Part II-1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for each SAL have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy using the instrument setpoint methodology. The Allowable Values have also been established from each SAL by combining the errors associated with the COT (e.g., device accuracy, setting tolerance, and drift) with the calculated NTSP using the instrument setpoint methodology. Where a SAL exists, trigger values are used to ensure that the Allowable Value provides sufficient margin from the SAL to account for any associated errors not confirmed by the COTUse of the previously discussed methodologies for determining Allowable Values, NTSPs, and analyzing channel/instrument performance ensure that the design basis and associated SALs will not be exceeded during plant operation. These evaluations, determinations, and analyses now form a portion of the CNP design bases.

Additionally, each applicable channel/instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These drift evaluations and drift analyses have been performed utilizing the guidance provided in EPRI TR-103335, "Statistical Analysis of Instrument Calibration Data/

Guidelines for Instrument Calibration Extension/Reduction Programs," Rev. 1.

The EPRI guidance was used to demonstrate that the data collected by the operating plant (from surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Therefore, based on the above discussion, the changes to the Allowable Values are acceptable. This change is designated as less restrictive because the less CNP Units 1 and 2 Page 36 of 37 Attachment 1, Volume 8, Rev. 0, Page 301 of 818

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INSTRUMENTATION stringent Allowable Values are being applied in the ITS than were applied in the CTS.

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Attachment 1, Volume 8, Rev. 0, Page 305 of 818 3.3.2 CTS 4 INSERT 1 In addition, separate Condition entry is allowed within a Function as follows: (a) for Function 1.e.(2) on a steam line basis; (b) for Functions 5.b and 6.c on a steam generator basis; and (c) for Function 6.e on a bus basis.

1 INSERT 1A CTS Table -NOTE-3.3-3 Note

For Functions 6.d and 6.g, LCO 3.0.4 is not applicable.

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Attachment 1, Volume 8, Rev. 0, Page 311 of 818 3.3.2 CTS 2 INSERT 2 (continued)

Action a, H. Required Action and H.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Table 3.3-3 associated Completion Action 18, Time of Condition B not AND DOC M.5 met for Function 6.d, 6.e, or 8.a. H.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR Required Action and Action a, Table 3.3-3 associated Completion Action 13, Time of Condition C not DOCs L.8, met for Function 4.b, 5.a, L.16, and 5.c, 6.a, 6.b, or 7.b.

L.17 OR Required Action and DOC M.4 associated Completion DOC L.12 Time of Condition D not met for Function 1.c, 1.d, 1.e.(1), 1.e.(2), 4.d, 4.e, 5.b, 6.c, 7.c, or 8.c.

OR Required Action and associated Completion DOC M.4 Time of Condition E not met for Function 2.c, 3.b.(3), or 4.c.

OR Required Action and DOC L.12 associated Completion Time of Condition F not met for Function 8.b.

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Attachment 1, Volume 8, Rev. 0, Page 312 of 818 3.3.2 CTS 2 INSERT 2 (continued)

I. Required Action and I.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action a, associated Completion Table 3.3-3 Time of Condition B not AND Action 18 met for Function 1.a, 2.a, 3.a.(1), 3.b.(1), or 7.a. I.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Action a, Required Action and Table 3.3-3 associated Completion Action 13, Time of Condition C not DOC A.7 met for Function 1.b, 2.b, 3.a.(2), 3.a.(3), or 3.b.(2).

J. Required Action and J.1 Declare associated Immediately Action a, associated Completion SGSV inoperable.

Table 3.3-3 Time of Condition B not Action 20 met for Function 4.a.

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Attachment 1, Volume 8, Rev. 0, Page 325 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION

1. ITS ACTION B Note has been added which states that for Functions 6.d (Auxiliary Feedwater Safety Injection Input from ESFAS) and 6.g (Auxiliary Feedwater Trip of all Main Feedwater Pumps) that LCO 3.0.4 is not applicable. This allowance is consistent with the current licensing basis.

2. ISTS 3.3.2 ACTIONS B, C, D, E, F, G, H, I, J, K, and L provide Required Actions and associated Completion Times for various ESFAS instrumentation inoperabilities.

Each of these ACTIONS include Required Actions to either trip a channel, bypass a channel, or restore a channel to OPERABLE status (depending on the associated ESFAS Instrumentation Function). Each of these ACTIONS also include Required Actions that require placing the unit outside the applicable MODE or condition of the associated ESFAS Instrumentation Function (i.e., default Required Action). In each of these ACTIONS, the Required Actions to restore, bypass, or trip the affected channels are connected to the default Required Action by the logical connector "OR."

The Completion Times for the Required Actions to restore, bypass, or trip affected channels are inconsistent with the Completion Times for the default Required Actions. This presentation is inconsistent with the format and convention used in all but one other specification in ISTS 3.3, all other sections of the ISTS, and other NSSS vendor ISTS (e.g., NUREG-1433, Rev. 2 and NUREG-1434, Rev. 2). This presentation can also cause confusion with respect to the correct application of the requirements of ISTS Section 3.0, "LCO Applicability." For example, ISTS LCO 3.0.4 includes an exception that allows entry into an applicable MODE or other specified condition when an LCO is not met if the ACTIONS permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.

However, with an ACTION that includes both the Required Action to trip (or bypass) a channel and the default Required Action to exit the applicable MODE, it could be argued that this ACTION would not allow continued operation. Therefore, these ACTIONS have been revised or deleted to eliminate the default Required Actions from the ACTIONS with Required Actions to restore or trip the affected channels. As a result, additional ACTIONS (ITS 3.3.2 ACTIONS G, H, I, and J) have been added which include the default Required Actions consistent with placing the unit outside the applicable MODE or other specified condition of the associated ESFAS Instrumentation Function. Subsequent Conditions and Required Actions have been renumbered, as necessary.

3. The brackets are removed and the proper plant specific information/value is provided. Subsequent SRs have been renumbered as necessary.

4. The ITS 3.3.2 Bases allows separate Condition entry for those Functions where the channels are specified on a steam line, loop, and steam generator basis. However, this allowance is not specified in the Specifications. As documented in Part 9900 of the NRC Inspection Manual, Technical Guidance - Licensee Technical Specifications Interpretations, and in the ITS Bases Control Program (ITS 5.5.12), neither the Technical Specifications Bases nor Licensee generated interpretations can be used to change the Technical Specification requirements. Thus, if the Technical Specifications do not allow separate Condition entry on a steam line, loop, or steam generator basis, the Bases cannot change the Technical Specifications requirement and allow separate Condition entry on a steam line, loop, or steam generator basis.

Therefore, the appropriate allowance has been added to the Specification. The CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 8, Rev. 0, Page 325 of 818

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INSTRUMENTATION ACTIONS NOTE has been revised to allow separate Condition entry for certain Functions specified on a steam line, steam generator, or bus basis.

5. An ESF RESPONSE TIME TEST (ITS SR 3.3.2.13) has been added for ITS Table 3.3.2-1 Function 5.c (SI Input from ESFAS), and deleted for ITS Table 3.3.2-1 Functions 1.e.(2) (High Differential Pressure Between Stream Lines),

3.b.(3) (Containment Pressure - High High), and 4.e (High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low), consistent with the current licensing basis requirements.

6. ISTS 3.3.2 ACTION E (ITS 3.3.2 ACTION E) requires entry when one "Containment Pressure" channel is inoperable. ISTS Table 3.3.2-1 (ITS Table 3.3.2-1)

Function 1.c, Containment Pressure - High, requires entry into ACTION D when one channel is inoperable. Therefore, to avoid confusion on what type of Containment Pressure channel applies to this action, the words "Containment Pressure" have been deleted. This change is acceptable since the other ACTIONS do not specify which types of channels apply for entry. In addition, ISTS 3.3.2 Required Action A.1 (ITS 3.3.2 Required Action A.1) requires, when one or more required channels or trains are inoperable, immediate entry into the Condition required by Table 3.3.2-1 for the affected channel(s) or train(s). This requires the user to review Table 3.3.2-1 to determine the applicable ACTIONS that must be entered for an inoperable containment pressure channel.

7. ISTS SR 3.3.2.3 is the performance of an ACTUATION LOGIC TEST every 31 days on a STAGGERED TEST BASIS and it applies to the ISTS Table 3.3.2-1 Function 6.b (Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS)). This test is not currently required by the CTS, however ITS SR 3.3.2.11 has been added (perform ACTUATION LOGIC TEST every 24 months) for this Function. This testing Frequency is considered acceptable and the Note in ISTS 3.3.2.3 is not needed for ITS SR 3.3.2.11. ISTS SR 3.3.2.3 (ITS SR 3.3.2.3) has been modified to perform a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) instead of an ACTUATION LOGIC TEST. This test applies to ITS Table 3.3.2-1 Functions 3.a.(3) and 6.d (SI Input from ESFAS). For these Functions, the applicable Surveillance Requirement is the performance of a TADOT (ITS SR 3.3.2.3). The Frequency of ISTS SR 3.3.2.3 (ITS SR 3.3.2.3) is revised to be consistent with CTS requirements for testing instrumentation that receive input for safety injection (i.e., 92 days on a STAGGERED TEST BASIS).

8. ISTS SR 3.3.2.8 (ITS SR 3.3.2.9) requires the performance of a TADOT for ISTS Table 3.3.2-1 (ITS Table 3.3.2-1) Functions 1.a (Safety Injection Manual Initiation),

2.a (Containment Spray Manual Initiation), 3.a.(1) (Containment Isolation Phase A Isolation Manual Initiation), 3.b.(1) (Containment Isolation Phase B Isolation Manual Initiation) and 4.a (Steam Line Isolation Manual Initiation). ISTS SR 3.3.2.8 is modified by a Note, which states "Verification of setpoint is not required for manual initiation functions." ITS Table 3.3.2-1 Functions 1.a, 2.a, 3.a.(1), 3.b.(1), and 4.a do not have required setpoints. The ISTS definition of TADOT states The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy. Since no required setpoints apply for ITS Table 3.3.2-1 Functions 1.a, 2.a, 3.a.(1), 3.b.(1), and 4.a, the TADOT CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 8, Rev. 0, Page 326 of 818

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INSTRUMENTATION definition does not require verification of setpoints. Therefore, the Note to ISTS SR 3.3.2.8 is unnecessary and has been deleted.

9. A Note to ISTS SR 3.3.2.9 requires the CHANNEL CALIBRATION to include verification that time constants are adjusted to the prescribed values.

ITS SR 3.3.2.10 does not include this Note since ITS SR 3.3.2.10 does not apply to any ITS Table 3.3.2-1 Functions that include time constants (time delays/constants are used, but they are listed in the Allowable Value column).

10. ITS SR 3.3.2.12 (a 24 month COT) has been added to ISTS 3.3.2 to be consistent with the CTS. In addition, ITS SR 3.3.2.7 (a 184 day CHANNEL CALIBRATION) has been added to ISTS 3.3.2 as discussed in DOC M.10. Subsequent SRs have been renumbered, as necessary. Also, ISTS SR 3.3.2.9 (CHANNEL CALIBRATION) has not been included for ITS Table 3.3.2-1 Function 6.g, consistent with current licensing basis.

11. ISTS SR 3.3.2.11 (performance of a TADOT once per reactor trip breaker cycle) has been deleted. This SR applies to ISTS Table 3.3.2-1 Function 8.a, Reactor Trip, P-4.

This Function has been added to the Technical Specifications. SR 3.3.2.9 is assigned to this Function and requires the performance of a TADOT every 24 months. This Surveillance is considered acceptable for this Function. In addition, an ACTUATION LOGIC TEST (ITS SR 3.3.2.2) has been added and ISTS SR 3.3.2.1 (CHANNEL CHECK) has been deleted, for the P-11 and P-12 ESFAS Interlock Functions (ITS Table 3.3.2-1 Functions 8.b and 8.c), consistent with the current licensing basis.

12. Editorial changes made for enhanced clarity or to be consistent with the Writers Guide for Improved Standard Technical Specifications, NEI 01-03.

13. ITS Table 3.3.2-1 Functions 1.c, 2.c, 3.b.(3), 4.c, and 6.e have been modified to reflect CNP specific nomenclature.

14. ITS Table 3.3.2-1 Functions 1.a (Safety Injection Manual Initiation) (as modified by a Discussion of Change), 1.e.(1) (Safety Injection Steam Line Pressure Low), 2.a (Containment Spray Manual Initiation), 3.a.(1) (Phase A Isolation Manual Initiation),

3.b.(1) (Phase B Isolation Manual Initiation), 4.a (Steam Line Isolation Manual Initiation), and 4.d (Steam Line Isolation Steam Line Pressure - Low) have been revised to reflect the appropriate number of required channels consistent with the CNP current licensing basis. In addition, the word required has been added to Condition B and Required Action B.1, since not all installed channels are required.

15. The Nominal Trip Setpoint column has been deleted as allowed by the Reviewers Note at the end of ISTS Table 3.3.2-1. This Reviewers Note allows the unit specific implementation to contain only the Allowable Value. The nominal trip setpoints for each of the applicable ITS Table 3.3.2-1 Functions will be controlled in accordance with the Note in the ISTS 3.3.2 Bases Background section.

16. ISTS Table 3.3.2-1 Footnotes (d) and (e) on page 3.3.2-8 have been deleted since they do not apply to the ITS Table 3.3.2-1 Functions listed on the page. Subsequent Footnotes have been renumbered as necessary. In addition, ISTS Table 3.3.2-1 CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 8, Rev. 0, Page 327 of 818

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INSTRUMENTATION Footnote (c) has been renumbered as Footnote (b) and assigned to ITS Table 3.3.2-1 Functions 1.e.(1) and 1.e.(2) consistent with the CTS. As a corresponding change, ISTS Table 3.3.2-1 Footnote (b) is renumbered as Footnote (c). ISTS Table 3.3.2-1 Footnotes (b), (c), (d), and (e) on page 3.3.2-9 have been deleted since they do not apply to any ITS Table 3.3.2-1 Functions on the page. ISTS Table 3.3.2-1 Footnote (a) on page 3.3.2-11 has been renumbered as Footnote (b) and changed from P-11 to P-12 since the P-11 interlock does not apply to the Functions on the page. ISTS Table 3.3.2-1 Footnotes (f) and (g) on page 3.3.2-11 have been deleted since they do not apply to any ITS Table 3.3.2-1 Functions on the page. As a corresponding change, ISTS Table 3.3.2-1 Footnote (b) is renumbered as Footnote (c). Subsequent Footnotes have been renumbered as necessary. ISTS Table 3.3.2-1 Footnotes (b) and (e) on page 3.3.2-12 have been deleted since they do not apply to any ITS Table 3.3.2-1 Functions on the page.

Subsequent Footnotes have been renumbered as necessary. ISTS Table 3.3.2-1 Footnote (d) on page 3.3.2-12 has been renumbered as Footnote (e) and revised as necessary consistent with the current licensing basis. ISTS Table 3.3.2-1 Footnote (h) on page 3.3.2-13 has been deleted since it does not apply to any Functions on the page. The subsequent Footnote has been renumbered as necessary.

17. ISTS Table 3.3.2-1 Functions 1.f (High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low), 1.g (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure Low), 2.c (Containment Pressure High - 3 (Two Loop Plants)),

4.d.(2) (Negative Rate - High), 4.f (High Steam Flow in Two Steam Lines Coincident with Steam Line Pressure - Low), 4.g (High Steam Flow Coincident with Safety Injection and Coincident with Tavg - Low Low), 4.h (High High Steam Flow Coincident with Safety Injection), 6.h (Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low), and all Functions associated with Function 7 (Automatic Switchover to Containment Sump) have been deleted since they do not apply to the CNP design. Subsequent Functions have been renumbered as applicable.

18. ISTS Table 3.3.2-1 Functions 3.a.(3), 5.c, and 6.d are the Safety Injection Functions associated with Containment Isolation Phase A Isolation, Turbine Trip and Feedwater Isolation, and Auxiliary Feedwater Functions, respectively. In the ISTS these Functions simply include a cross reference to Function 1 (Safety Injection) for all initiation functions and requirements. ITS Table 3.3.2-1 Functions 3.a.(3) and 6.d have been revised to reflect the specific Applicability, Required Channels, Conditions, and Surveillance Requirements for the SI Input from ESFAS Function consistent with the CTS. The CTS implies that the requirement only includes an input from SI since there is only a CHANNEL FUNCTIONAL TEST (a TADOT in the ITS) associated with these Functions. ITS Table 3.3.2-1 Function 5.c (Turbine Trip and Feedwater Isolation SI Input from ESFAS) also receives an input from SI, however there was no explicit Function for it in the CTS. It was added in accordance with the Discussion of Changes for ITS 3.3.2.

19. The bracketed requirement "and de-activated" has been deleted, consistent with a change made in ITS 3.7.2, "Steam Generator Stop Valves (SGSVs)."

20. ITS Table 3.3.2-1 Function 7 (Containment Air Recirculation/Hydrogen Skimmer (CEQ) System) has been added consistent with the CTS.

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INSTRUMENTATION

21. ISTS Table 3.3.2-1 (ITS Table 3.3.2-1) Function 8 (ESFAS Interlocks) has been revised to reflect the CNP specific design and nomenclature.

22. The Reviewers Note has been deleted since it is not intended to be included in the ITS.

23. When an ISTS Table 3.3.2-1 Function 8.c (ITS Table 3.3.2-1 Function 8.c) P-12 interlock channel is inoperable, ISTS 3.3.2 ACTION L must be taken, and requires verification that the interlock is in the required state for the existing unit condition.

However, at CNP the P-12 interlock also prevents a steam line isolation from occurring on a high steam line flow when Tavg is above the Tavg - Low Low reset point. Thus, placing the P-12 interlock train in the required state for the existing unit condition is not always a conservative action, since if a steam line break were to occur, the reactor coolant temperature would decrease to below the Tavg - Low Low reset point. Since compliance with ISTS 3.3.2 ACTION L would result in placing the P-12 interlock in a condition that prevents the steam line isolation, the ACTION is not conservative. Therefore, ITS Table 3.3.2-1 will require ISTS 3.3.2 ACTION D (ITS 3.3.2 ACTION D) to be entered when one train of the P-12 interlock Function is inoperable, and this ACTION requires placing the channel in trip, which is conservative for the steam line break event (i.e., the steam line isolation will not be blocked).

24. The Note to ISTS SR 3.3.2.10 (ITS SR 3.3.2.13) has been changed to be consistent with similar Notes in ITS 3.7.5 (ITS SRs 3.7.5.2 and 3.7.5.4).

25. Changes are made to reflect plant specific nomenclature or design.

26. The Note to ISTS SR 3.3.2.7 (ITS SR 3.3.2.6) has been changed to be consistent with a similar Note in ITS 3.3.1 (ITS SR 3.3.1.12).

27. A Note has been added to ISTS SR 3.3.2.5 (ITS SR 3.3.2.5) consistent with the CTS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 8, Rev. 0, Page 329 of 818

Attachment 1, Volume 8, Rev. 0, Page 330 of 818 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 335 of 818 B 3.3.2 4

INSERT 2 As described in Reference 2, where a unit condition that requires protective action can be brought on by a failure or malfunction of the control system, and the same failure or malfunction prevents proper action of a protection system channel or channels designed to protect against the resultant unsafe condition, the remaining portions of the protection system shall be independently capable of withstanding a single failure and automatically initiating appropriate protective action. For CNP, the protection system is designed to be independent of the status of the control system. However, the control system does derive signals from the protection systems through isolation amplifiers, which are part of the protection system. The isolation amplifiers prevent perturbation of the protection signal (input) due to disturbances of the isolated signal (output) which could occur near any termination of the output wiring external to the protection and safeguards racks. As such, other acceptable logic designs (e.g., two-out-of-three logic) exist for parameters that are used as inputs to SSPS and a control function. Also, additional redundancy is warranted for those Functions whose channels energize to trip, even if they are not used as a control function.

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Attachment 1, Volume 8, Rev. 0, Page 340 of 818 B 3.3.2 4

1 INSERT 3

Trip main feedwater pumps;

Actuate Essential Service Water (ESW) System for Units 1 and Unit 2;

Actuate Component Cooling Water (CCW) System; and

Actuate Engineered Safety Features (ESF) Ventilation System.

4 INSERT 4 The Safety Injection Manual Initiation Function is designed with two manual panel switches in each train. One switch (channel) in a train must be placed in the actuate position for the associated components in the train to receive an SI initiation signal.

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INSERT 16 component cooling water (CCW) to the reactor coolant pumps and non-essential service water (NESW) to the ventilation units 4 INSERT 16A The NESW System supplies cooling water to the containment ventilation units. Since the NESW System is normally available to support containment cooling, not isolating NESW on the low pressure Phase A signal enhances unit safety by allowing operators to use the containment ventilation units to remove heat from the containment instead of using the Containment Spray System.

4 INSERT 17 CCW to the reactor coolant pumps and NESW to the ventilation units 4

INSERT 17A The NESW System is not isolated at this time to permit continued operation of the containment ventilation units.

4 INSERT 18 one train while the other switch isolates the other train 4

INSERT 18A In addition, containment cooling via the containment ventilation units is no longer desirable.

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INSERT 22 High Steam Flow in Two Steam Lines Function design includes two steam flow channels per steam line arranged in a one-out-of-two logic configuration per steam line. Tavg -

Low Low Function design includes one channel per loop for a total of four channels arranged in a two-out-of-four logic configuration. Logic actuation will occur when two steam lines indicate high flow coincident with Tavg - Low Low exceeding its trip setpoint (two of the four channels). Two steam line flow channels per steam line and one Tavg -

Low Low channel per loop are required to be OPERABLE to ensure no single failure will disable this Function.

The one-out-of-two logic configuration allows online testing because trip of one high steam flow channel is not sufficient to cause initiation. High steam flow in two steam lines is acceptable in the case of a single steam line fault due to the fact that the remaining intact steam lines will pick up the full turbine load. The increased steam flow in the remaining intact lines will actuate the required second high steam flow trip.

The Allowable Value for high steam flow is a linear function that varies with power level.

The high steam flow and Tavg transmitters are located inside containment thus, it is not possible for them to experience adverse environmental conditions during a rupture of a steam line. Therefore, the trip setpoint only reflects steady state environmental instrument uncertainties.

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Attachment 1, Volume 8, Rev. 0, Page 381 of 818 B 3.3.2 4 INSERT 32 Three undervoltage relays with time delays are provided for each 4.16 kV emergency bus to detect a loss of bus voltage. The relays are combined in a two-out-of-three logic to generate a loss of voltage signal (i.e., the required number of channels required to trip to generate a loss of voltage signal is two per bus). A Loss of Voltage signal on T11A (Unit 1) and T21A (Unit 2) (Train B) or T11D (Unit 1) and T21D (Unit 2) (Train A) will start the associated motor driven feedwater pump. A Loss of Voltage signal on T11A and T11B (Unit 1) and T21A and T21B (Unit 2) (Train B) or T11C and T11D (Unit 1) and T21C and T21D (Unit 2) (Train A) will actuate the valves associated with the motor driven feedwater pumps on both trains.

4 INSERT 33 A bus undervoltage signal is generated by one out of two undervoltage relays (channels) per reactor coolant pump bus, however the LCO requires only one per bus to be OPERABLE. While not assumed in the accident analysis, 4

INSERT 34 (Unit 1 only)

Each turbine driven MFW pump is equipped with a low and high pressure steam stop valve. Each stop valve contains a limit switch, which actuates when the associated stop valve is closed. Both of the stop valve limit switches associated with a turbine driven MFW provide input into one of the two channels and both limit switches must actuate for the channel to indicate a turbine driven MFW pump has tripped. Since the unit includes two turbine driven MFW pumps, both channels must trip to start the motor driven auxiliary feedwater pumps (i.e., a two-out-of-two logic configuration). The LCO requires both channels to be OPERABLE. This Function does not meet the single failure criteria, however this is acceptable since the SG Water Level - Low Low Function is credited to start the AFW System in the design basis accidents and transients that result in a loss of MFW.

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Attachment 1, Volume 8, Rev. 0, Page 415 of 818 B 3.3.2 7 INSERT 50 SR 3.3.2.7 SR 3.3.2.7 is the performance of a CHANNEL CALIBRATION. A CHANNEL CALIBRATION is performed every 184 days. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Frequency of 184 days is based on the assumption of an 184 day calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

7 INSERT 50A

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Attachment 1, Volume 8, Rev. 0, Page 422 of 818 B 3.3.2 4

INSERT 52A "Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System," including Supplement 1, May 1986, and 4

INSERT 53 10

6. WCAP-15376, "Risk-Informed Assessment of the RTS and ESFAS Surveillance TSTF-411 Intervals and Reactor Trip Breaker Test and Completion Times," October 2000.

11. UFSAR, Table 7.2-7.

Insert Page B 3.3.2-53 Attachment 1, Volume 8, Rev. 0, Page 422 of 818

Attachment 1, Volume 8, Rev. 0, Page 423 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2 BASES, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION

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. Editorial change to be consistent with other places in the Bases.

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

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

5. The Reviewers Notes are deleted because they are not intended to be included in the plant specific ITS submittal.

6. Changes are made to reflect the Specifications.

7. Changes are made to reflect changes made to the Specification.

8. Grammatical error corrected.

9. This information is describing how to perform Surveillances and is more appropriate to be located in the applicable Surveillance Requirements Bases.

10. This statement has been deleted since it is not relevant to the discussion.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 423 of 818

Attachment 1, Volume 8, Rev. 0, Page 424 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 424 of 818

Attachment 1, Volume 8, Rev. 0, Page 425 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.20 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS Table 3.3-3, Functional Unit 9.a (Safety Injection, Manual Initiation) requires a total of two channels per train to be OPERABLE. ITS Table 3.3.2-1, Function 1.a requires only one channel per train to be OPERABLE. This changes the CTS by decreasing the number of manual channels required OPERABLE from two per train to one per train.

The purpose of Safety Injection (SI) manual initiation function is to ensure the capability exists to manually initiate the Safety Injection trains. The SI Manual Initiation Function at CNP is provided by four switches, two per train. Each switch will actuate the associated SI train (i.e., the two train A switches are fully redundant to each other and the two train B switches are fully redundant to each other). The only difference between the two switches within a train are their location within the control room. NUREG-1431 only requires two Manual Initiation channels to be OPERABLE, since a typical Westinghouse plant only has two channels installed. This change is acceptable since each channel within a train is fully redundant to the other channel in that train for the SI Manual Initiation Function, and the fact that it is consistent with the NUREG-1431 requirements.

In addition, if the single required manual initiation switch does not function, the associated SI train can still be initiated using the individual component control switches that exist in the control room. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

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

as discussed below:

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

Response: No.

The proposed change decreases the number of manual channels required OPERABLE from two per train to one per train. This change will not affect the probability of an accident, since the manual initiation instrumentation is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident are not affected by this change since manual initiation instrumentation is not assumed to mitigate the consequences of an accident previously evaluated. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 425 of 818

Attachment 1, Volume 8, Rev. 0, Page 426 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION

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

Response: No.

The proposed change decreases the number of manual channels required OPERABLE from two per train to one per train. This change will not physically alter the plant (no new or different type of equipment will be installed). Both channels per train will remain installed in the plant and will normally be available to manually actuate the associated Safety Injection train. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change decreases the number of manual channels required OPERABLE from two per train to one per train. The margin of safety is not affected by this change because the safety analysis assumptions are not affected. In addition, if the single required manual initiation switch does not function, the associated SI train can still be initiated using the individual component control switches that exist in the control room. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 426 of 818

ML041200365

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