Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 8, Rev 0, ITS Section 3.3 Instrumentation, Pages 427-818
	ML041200367
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP:NRC:4901
	Download: ML041200367 (392)
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Attachment 1, Volume 8, Rev. 0, Page 427 of 818 ATTACHMENT 3 ITS 3.3.3, Post Accident Monitoring (PAM) Instrumentation Attachment 1, Volume 8, Rev. 0, Page 427 of 818

, Volume 8, Rev. 0, Page 428 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 8, Rev. 0, Page 428 of 818

Attachment 1, Volume 8, Rev. 0, Page 429 of 818 ITS 3.3.3 A.1 ITS LCO 3.3.3 Add proposed ACTIONS Note 2 A.2 M.1 ACTIONS A and C L.1 L.2 ACTIONS B, E, F and G Add proposed Required Action F.1 M.2 ACTION A 30 days L.3 ACTION B L.1 Add proposed Required Action B.1 L.4 Add proposed ACTIONS C and F L.5 ACTIONS Note 1 SR Table Note Page 1 of 16 Attachment 1, Volume 8, Rev. 0, Page 429 of 818

ITS ITS Table 3.3.3-1 8

3 4

5 12 2

2 M.3 22 24 R.1 19 25 LA.1 R.1 A.1 15, 16, 17, 18 6 LA.1 2 M.3 7

R.1 Footnote (d)

LA.1 R.1 Add proposed Functions 1, 9, 13, 14, 20, 21, 23, 26, 27, and 28 M.4 , Volume 8, Rev. 0, Page 430 of 818 Attachment 1, Volume 8, Rev. 0, Page 430 of 818 Page 2 of 16 ITS 3.3.3

Attachment 1, Volume 8, Rev. 0, Page 431 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 SR 3.3.3.1 SR 3.3.3.3 8

3 4

24 months L.6 5

12 2

22 R.1 24 19 24 months L.6 25 R.1 24 months L.6 15, 16, 17, 18 M.5 6

LA.2 7 R.1 24 months L.6 Add proposed Functions 1, 9, 13, 14, 20, 21, 23, 26, 27, and 28 M.4 M.5 LA.2 M.5 Page 3 of 16 Attachment 1, Volume 8, Rev. 0, Page 431 of 818

Attachment 1, Volume 8, Rev. 0, Page 432 of 818 ITS 3.3.3 A.1 ITS LCO 3.3.3 L.7 Add proposed ACTIONS Note 2 A.2 L.7 ACTION A, B, C, E, and G ACTIONS Note 1 M.6 SR Table Note L.8 Page 4 of 16 Attachment 1, Volume 8, Rev. 0, Page 432 of 818

Attachment 1, Volume 8, Rev. 0, Page 433 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 L.7 L.9 See ITS 3.3.6 and CTS 3/4.3.3.1 L.7 10 L.14 See ITS 3.3.6 and ITS 3.4.15 See CTS 3/4.3.3.1 Page 5 of 16 Attachment 1, Volume 8, Rev. 0, Page 433 of 818

Attachment 1, Volume 8, Rev. 0, Page 434 of 818 ITS 3.3.3 A.1 ITS See ITS 3.4.15 See CTS 3/4.3.3.1 See ITS 3.3.6 ACTIONS A and C L.11 ACTIONS B, E, and G See ITS 5.6 ACTIONS Note 1 M.6 See CTS 3/4.3.3.1 Page 6 of 16 Attachment 1, Volume 8, Rev. 0, Page 434 of 818

Attachment 1, Volume 8, Rev. 0, Page 435 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 SR 3.3.3.1 SR 3.3.3.3 L.9 See CTS 3/4.3.3.1 L.8 L.9 10 31 days 24 months L.6 L.12 L.14 See ITS 3.4.15 See CTS 3/4.3.3.1 Page 7 of 16 Attachment 1, Volume 8, Rev. 0, Page 435 of 818

Attachment 1, Volume 8, Rev. 0, Page 436 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 M.7 Function 11 3

Add proposed ACTIONS Note 1 L.10 Add proposed ACTIONS Note 2 A.2 ACTION A ACTION B Add proposed Required Action B.1 L.1 ACTION D ACTIONS E and F and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months M.7 SR 3.3.3.2 L.13 LA.3 Page 8 of 16 Attachment 1, Volume 8, Rev. 0, Page 436 of 818

Attachment 1, Volume 8, Rev. 0, Page 437 of 818 ITS 3.3.3 A.1 ITS LCO 3.3.3 Add proposed ACTIONS Note 2 A.2 M.1 ACTIONS A and C L.1 ACTIONS B, E, F, and G L.2 Add proposed Required Actions F.1 M.2 ACTION A 30 days L.3 ACTION B Add proposed Required Action B.1 L.1 L.4 Add proposed ACTIONS C and F L.5 ACTIONS Note 1 SR Table Note Page 9 of 16 Attachment 1, Volume 8, Rev. 0, Page 437 of 818

ITS ITS Table 3.3.3-1 8

3 4

5 12 2 2 M.3 22 24 R.1 19 25 LA.1 R.1 15, 16, 17, 18 2 M.3 6

A.1 LA.1 7

R.1 Footnote (d)

LA.1 R.1 Add proposed Functions 1, 9, 13, 14, 20, 21, 23, 26, 27, and 28 , Volume 8, Rev. 0, Page 438 of 818 Attachment 1, Volume 8, Rev. 0, Page 438 of 818 M.4 Page 10 of 16 ITS 3.3.3

Attachment 1, Volume 8, Rev. 0, Page 439 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 SR 3.3.3.1 SR 3.3.3.3 8

3 4

5 12 24 months L.6 2

22 R.1 24 19 24 months L.6 25 R.1 24 months L.6 15, 16, 17, 18 M.5 6

LA.2 R.1 7

24 months L.6 Add proposed Functions 1, 9, 13, 14, 20, 21, 23, 26, 27, and 28 M.4 M.5 LA.2 M.5 Page 11 of 16 Attachment 1, Volume 8, Rev. 0, Page 439 of 818

Attachment 1, Volume 8, Rev. 0, Page 440 of 818 ITS 3.3.3 A.1 ITS LCO 3.3.3 L.7 Add proposed ACTIONS Note 2 A.2 L.7 ACTION A, B, C, E and G ACTIONS Note 1 M.6 SR Table Note L.8 Page 12 of 16 Attachment 1, Volume 8, Rev. 0, Page 440 of 818

Attachment 1, Volume 8, Rev. 0, Page 441 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 L.7 L.9 See ITS 3.3.6 and CTS 3/4.3.3.1 10 L.7 L.14 See ITS 3.3.6 and ITS 3.4.15 See CTS 3/4.3.3.1 Page 13 of 16 Attachment 1, Volume 8, Rev. 0, Page 441 of 818

Attachment 1, Volume 8, Rev. 0, Page 442 of 818 ITS 3.3.3 A.1 ITS See ITS 3.4.15 See CTS 3/4.3.3.1 See ITS 3.3.6 ACTIONS A and C L.11 See ITS ACTIONS B, E, and G 5.6 ACTIONS Note 1 M.6 See CTS 3/4.3.3.1 Page 14 of 16 Attachment 1, Volume 8, Rev. 0, Page 442 of 818

Attachment 1, Volume 8, Rev. 0, Page 443 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 SR 3.3.3.1 SR 3.3.3.3 L.9 See CTS 3/4.3.3.1 L.8 L.9 10 24 months L.6 31 days L.12 L.14 See ITS 3.4.15 See CTS 3/4.3.3.1 Page 15 of 16 Attachment 1, Volume 8, Rev. 0, Page 443 of 818

Attachment 1, Volume 8, Rev. 0, Page 444 of 818 ITS 3.3.3 A.1 ITS Table 3.3.3-1 M.7 Function 11 3

Add proposed ACTIONS Note 1 L.10 Add proposed ACTIONS Note 2 A.2 ACTION A ACTION B Add proposed Required Action B.1 L.1 ACTION D ACTIONS E and F and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months M.7 SR 3.3.3.2 L.13 LA.3 Page 16 of 16 Attachment 1, Volume 8, Rev. 0, Page 444 of 818

Attachment 1, Volume 8, Rev. 0, Page 445 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) 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 Unit 1 CTS 3.3.3.8 Actions a and b, Unit 2 CTS 3.3.3.6 Actions a and b, CTS 3.3.3.1 Actions b and c, CTS Table 3.3-6 Action 22A, and CTS 3.6.4.1 Actions a and b provide the compensatory actions to take when PAM instrumentation is inoperable. ITS 3.3.3 ACTIONS provide the compensatory actions for inoperable PAM Instrumentation. The ITS 3.3.3 ACTIONS include a Note (Note 2) that allows separate Condition entry for each Function. In addition, separate Condition entry is allowed within a Function on a steam generator basis for Functions 2 (Steam Generator Pressure), 19 (Auxiliary Feedwater Flow), and 22 (Steam Generator Water Level (Narrow Range)). This modifies the CTS by providing a specific allowance to enter the Action for each inoperable PAM instrumentation Function and for certain Functions on a steam generator basis.

This change is acceptable because it clearly states the current requirement. The CTS considers each PAM instrumentation Function to be separate and independent from the others. In addition, the channels associated with Functions 2, 19, and 22 are allowed separate Condition entry on a steam generator basis, which is consistent with the intent of the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 Unit 1 CTS 3.3.3.8 Action a and Unit 2 CTS 3.3.3.6 Action a require, with the number of OPERABLE post accident monitoring instrumentation channels less than the minimum channels OPERABLE requirements of Table 3.3-11 (Unit 1) and Table 3.3-10 (Unit 2), that the inoperable channel be restored to OPERABLE status within 30 days. ITS 3.3.3 ACTION C requires, with one or more Functions with two required channels inoperable, restoration of one channel to OPERABLE status within 7 days. This changes the CTS requirement by reducing the allowed outage time when two required channels of a PAM instrumentation Function are inoperable from 30 days to 7 days.

This change is acceptable because it provides appropriate requirements for when two required channels of a PAM instrumentation Function are inoperable.

The PAM instrumentation are required to be OPERABLE to provide the control room operators with sufficient information on selected unit parameters to monitor and assess unit status following an accident. This change is designated as more restrictive because it requires restoration of the inoperable PAM instrumentation channels is less time than is required in the CTS.

CNP Units 1 and 2 Page 1 of 20 Attachment 1, Volume 8, Rev. 0, Page 445 of 818

Attachment 1, Volume 8, Rev. 0, Page 446 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION M.2 Unit 1 CTS 3.3.3.8 Action a and Unit 2 CTS 3.3.3.6 Action a require, when required channels are not restored within the allowed outage time, that the unit be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.3.3 ACTION F requires the unit to be placed in MODE 3 (HOT STANDBY) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action F.1) and MODE 4 (HOT SHUTDOWN) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action F.2). This changes the CTS requirement by requiring 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 change is acceptable because 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is a reasonable period of time for the operator to safely decrease power from full power to MODE 3 without challenging unit systems. This Completion Time is consistent with other ITS requirements that specify a unit power reduction to MODE 3. The change is designated as more restrictive because it adds a requirement to place the unit in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to the CTS.

M.3 Unit 1 CTS Table 3.3-11 and Unit 2 CTS Table 3.3-10, Instruments 7 and 16, require one channel per steam generator for the Steam Generator Water Level-Narrow Range Instrument and one train (equivalent to one channel in ITS nomenclature) for the Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) Instrument to be OPERABLE. ITS Table 3.3.3-1 Functions 22 and 6 require two channels per steam generator for Steam Generator Water Level (Narrow Range) Function and two channels for the Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) to be OPERABLE. This changes the CTS requirements for the parameters from one to two required channels.

This change is acceptable because the ITS reflects the requirements for diversity and redundancy stated in Regulatory Guide 1.97, Revision 3, and NRC Generic Letter 82-33. Additionally, the unit specific evaluation requires that a minimum of two channels be available for these parameters. This provides the operator an unambiguous source of information for decisions needed following design basis events. The change is designated as a more restrictive because the number of required channels for the indicated parameters is increased from one to two.

M.4 Unit 1 CTS Table 3.3-11 and Unit 2 CTS Table 3.3-10 do not require OPERABLE indication channels for Neutron Flux, Penetration Flow Path Containment Isolation Valve Position, Steam Generator Water Level (Wide Range),

Condensate Storage Tank Level, Centrifugal Charging Pump Flow, Safety Injection Pump Flow, Containment Pressure (Wide Range), Component Cooling Water Pump Circuit Breaker Status, Centrifugal Charging Pump Circuit Breaker Status, and Safety Injection Pump Circuit Breaker Status. These are added to the CTS and shown in ITS Table 3.3.3-1, Functions 1, 9, 13, 14, 20, 21, 23, 26, 27, and 28. Two channels are provided for Neutron Flux (Function 1). Two channels per penetration flow path are provided for Penetration Flow Path Containment Isolation Valve Position (Function 9). This requirement is modified by two footnotes, footnotes (a) and (b). Footnote (a) does not require position indication for isolation valves whose penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange or check valve with flow through the valve secured. Footnote (b) requires only one position indication channel per penetration flow path with one installed channel located in the control room. One channel per steam generator is provided for CNP Units 1 and 2 Page 2 of 20 Attachment 1, Volume 8, Rev. 0, Page 446 of 818

Attachment 1, Volume 8, Rev. 0, Page 447 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Steam Generator Water Level (Wide Range) (Function 13). One channel is provided for Condensate Storage Tank Level (Function 14). One channel per cold leg injection is provided for Centrifugal Charging Pump Flow (Function 20).

Two channels are provided for Safety Injection Pump Flow (Function 21). Two channels are provided for Containment Pressure (Wide Range) (Function 23).

One channel per pump is provided for Component Cooling Water Pump Circuit Breaker Status (Function 26). One channel per pump is provided for Centrifugal Charging Pump Circuit Breaker Status (Function 27). One Channel per pump is provided for Safety Injection Pump Circuit Breaker Status (Function 28).

ITS 3.3.3 ACTION A has been added to cover the Condition when one or more Functions have one required channel inoperable. ITS 3.3.3 Required Action A.1 allows 30 days to restore the required channel to OPERABLE status. If this Required Action and associated Completion Time of Condition A is not met, then ITS Required Action B.1 requires the immediate initiation of the actions specified in Specification 5.6.6. ITS 3.3.3 ACTION C has been added to cover the Condition when one or more Functions have two required channels inoperable.

ITS 3.3.3 Required Action C.1 requires restoration of one channel to OPERABLE status within 7 days. If this cannot be met, then ITS 3.3.3 Condition E must be entered, which will then require entry into Condition F where ITS 3.3.3 Required Action F.1 will require 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 . A Note has been added to the ACTIONS to allow Separate Condition entry for each Function. In addition, separate Condition entry is allowed within a Function as follows: (a) for Function 13 on a steam generator basis; (b) for Function 20 on a cold leg injection line basis; and (c) for Functions 26, 27, and 28 on a pump basis. In addition, SRs are added for each Function. These SRs are a CHANNEL CHECK for each required instrumentation channel that is normally energized (SR 3.3.3.1) and a CHANNEL CALIBRATION (SR 3.3.3.3). For the CHANNEL CALIBRATION of the Neutron Flux Function channels, SR 3.3.3.3 is modified by a note that states "Neutron detectors are excluded from CHANNEL CALIBRATION." This changes the CTS by adding new Functions, Footnotes, a Note, applicable ACTIONS, and SRs.

This change is acceptable because a plant specific evaluation has concluded that these instrumentation channels are required to provide the primary, unambiguous information to the operator necessary in order to perform manual actions for which no automatic controls exist and that are required for safety systems to accomplish their safety functions for design basis accident (DBA) events. The change is designated as more restrictive because 10 new instrumentation functions are added to the Technical Specifications.

M.5 Unit 1 CTS Table 4.3-7 and Unit 2 CTS Table 4.3-10 Instrument 15, Incore Thermocouples (Core Exit Thermocouples), and Instrument 16, Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) CHANNEL CALIBRATION requirements are modified by Notes (1) and (3), respectively.

Note (1) states "Partial range channel calibration for sensor to be performed below P-12 in MODE 3." Note (3) states "Completion of channel calibration for sensors to be performed below P-12 in MODE 3." The ITS SR 3.3.3.3 requires the performance of a CHANNEL CALIBRATION for ITS Table 3.3.3-1 Functions 15, 16, 17, and 18 (Core Exit Temperature - Quadrants 1, 2, 3, and 4) and ITS Table 3.3.3-1 Function 6 (Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication)). This changes the CTS by deleting the CNP Units 1 and 2 Page 3 of 20 Attachment 1, Volume 8, Rev. 0, Page 447 of 818

Attachment 1, Volume 8, Rev. 0, Page 448 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION allowances of Unit 1 CTS Table 4.3-7 and Unit 2 CTS Table 4.3-10 Notes (1) and (3).

The purpose of the CTS Notes is to allow the unit to enter the MODE of Applicability of the instrumentation without calibrating the associated sensors.

These allowances are no longer used for performing the CHANNEL CALIBRATIONS of these Functions. The CHANNEL CALIBRATIONS of these Functions are performed prior to entering the MODE of Applicability. Therefore, deletion of these Notes is acceptable. This change is designated as more restrictive as it eliminates allowances from the CTS.

M.6 CTS 3.3.3.1 Action c states, in part, that the provisions of Specification 3.0.3 is not applicable. CTS Table 3.3-6 Action 22A.3 states, in part, that Specification 3.0.3 is not applicable. ITS 3.3.3 does not include a LCO 3.0.3 exception. This changes the CTS by eliminating the CTS 3.0.3 exception.

CTS 3.0.3 requires the unit to be shutdown when the requirements of LCOs and associated Actions are not satisfied. This change is acceptable because the ISTS does not provide exceptions to ITS LCO 3.0.3 in the PAM Instrumentation Specification. Eliminating the CTS 3.0.3 exception ensures that the operators are provided guidance regarding actions to take in the event the required PAM instrumentation is inoperable and associated Actions are not satisfied within the required time periods. This change is designated as more restrictive because an explicit exception provided in the CTS is eliminated.

M.7 CTS 3.6.4.1, Hydrogen Analyzers, is applicable in MODES 1 and 2. CTS 3.6.4.1 Action b requires, if both hydrogen analyzers are inoperable for more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , that the unit is to be placed in HOT STANDBY (MODE 3) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.3.3 is applicable in MODES 1, 2, and 3. ITS 3.3.3 ACTION F requires, if two hydrogen analyzers are inoperable for greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , that the unit is to be placed 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 Applicability requirements for the hydrogen analyzers from MODES 1 and 2 to MODES 1, 2, and 3, and the Required Actions from being in MODE 3 to being in MODE 4.

This change is acceptable because the potential for hydrogen generation in the Reactor Coolant System in MODE 3 can be the same as MODES 1 and 2. The only effect on hydrogen concentration as assumed in the accident analyses that changes for MODE 3 is the potential amount of hydrogen generated from fuel clad damage. Therefore, the expansion of the Applicability to MODE 3 and the requirement to place the unit in MODE 4 (outside the expanded MODES of Applicability) if inoperable hydrogen analyzers are inoperable and not restored within the required Completion Time, are appropriate. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time provided to reach MODE 4 is consistent with the time provided in similar actions in both the CTS and ITS. The change is designated as more restrictive because the hydrogen analyzers are required to be OPERABLE in more conditions than required in the CTS.

CNP Units 1 and 2 Page 4 of 20 Attachment 1, Volume 8, Rev. 0, Page 448 of 818

Attachment 1, Volume 8, Rev. 0, Page 449 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION RELOCATED SPECIFICATIONS R.1 Unit 1 CTS Tables 3.3-11 and 4.3-7 and Unit 2 CTS Tables 3.3-10 and 4.3-10 provide requirements for Post-Accident Monitoring Instrumentation channels. Each individual post accident monitoring parameter has a specific purpose, however, the general purpose for all accident monitoring instrumentation is to ensure sufficient information is available following an accident to allow an operator to verify the response of automatic safety systems, and to take preplanned manual actions to accomplish a safe shutdown of the plant.

The NRC position on application of the screening criteria to post-accident monitoring instrumentation is documented in a letter dated May 9, 1988 from T.E.

Murley (NRC) to W.S. Wilgus (B&W Owners Group). The screening criteria are now incorporated into 10 CFR 50.36(c)(2)(ii). The NRC position taken was that the post-accident monitoring instrumentation table list should contain, on a plant specific basis, all Regulatory Guide 1.97 Type A instruments specified in the plant's Safety Evaluation Report (SER) on Regulatory Guide 1.97, and all Regulatory Guide 1.97 Category 1 instruments. Accordingly, this position has been applied to the CNP Units 1 and 2 Regulatory Guide 1.97 instruments. Those instruments meeting these criteria have remained in Technical Specifications. The instruments not meeting this criteria will be relocated from the Technical Specifications to the Technical Requirements Manual (TRM).

A review of the CNP Units 1 and 2 UFSAR and the NRC Regulatory Guide 1.97 Safety Evaluation for CNP Units 1 and 2 shows that the following Unit 1 CTS Tables 3.3-11 and 4.3-7 and Unit 2 CTS Tables 3.3-10 and 4.3-10 Instruments do not meet Category 1 or Type A requirements.

Instrument 9 Boric Acid Tank Solution Level Instrument 12 PORV Position Indicator - Limit Switches Instrument 13 PORV Block Valve Position Indicator - Limit Switches Instrument 14 Safety Valve Position Indicator - Acoustic Monitor Instrument 17 Containment Sump Level 10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1. These instruments are not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a design basis accident (DBA). These instruments do not meet criterion 1.

2. The monitored parameters are not process variables, design features, or operating restrictions that are initial conditions of a DBA or transient. These instruments do not meet criterion 2.

3. These instruments are not part of a primary success path in the mitigation of a DBA or transient. These instruments do not meet criterion 3.

4. These instruments are not structures, systems, or components which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. As discussed in Section 4.0 (Appendix A, page A-25) and summarized in Table 1 of WCAP-11618, the CNP Units 1 and 2 Page 5 of 20 Attachment 1, Volume 8, Rev. 0, Page 449 of 818

Attachment 1, Volume 8, Rev. 0, Page 450 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION loss of the above listed instruments were found to be non-significant risk contributors to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. These instruments do not meet criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met for instruments which do not meet Regulatory Guide 1.97 Type A variable requirements or non-Type A, Category 1, variable requirements, their associated LCO and Surveillances may be relocated out of the Technical Specifications. The Technical Specification requirements for these instruments will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as a relocation because the LCO requirements for these instruments did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and have been relocated to the TRM.

REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) Unit 1 CTS Table 3.3-11 and Unit 2 CTS Table 3.3-10, Instrument 11, Reactor Coolant System Subcooling Margin Monitor channel OPERABILITY requirements are modified by footnote **, that states "PPC subcooling margin readout can be used as a substitute for the subcooling monitor instrument." Unit 1 CTS Table 3.3-11 and Unit 2 CTS Table 3.3-10, Instrument 16, Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication), states that the required train (equivalent to one channel in ITS nomenclature) includes three channels. ITS Table 3.3.3-1 Function 25 requires one channel of the RCS Subcooling Margin Monitor to be OPERABLE and Function 6 requires two channels of the Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) to be OPERABLE, but the details of what constitutes an OPERABLE channel are moved to the Bases. This changes the CTS by moving the details of what constitutes an OPERABLE channel to the Bases. The change to the number of required CTS Function 16 channels is discussed in DOC M.3.

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 one channel of the RCS Subcooling Margin Monitor and two channels of the Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) to be OPERABLE and to perform CHANNEL CHECKS and CHANNEL CALIBRATIONS of the channels. 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 of the ITS. 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.

CNP Units 1 and 2 Page 6 of 20 Attachment 1, Volume 8, Rev. 0, Page 450 of 818

Attachment 1, Volume 8, Rev. 0, Page 451 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) Unit 1 CTS Table 4.3-7 and Unit 2 CTS Table 4.3-10, Instrument 16, Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication), CHANNEL CHECK requirements are modified by Note (2).

Note (2) allows, with one train of Reactor Vessel Level Indication inoperable, subcooling margin indication and core exit thermocouples to be used to perform a CHANNEL CHECK to verify the remaining Reactor Vessel Level Indication train is OPERABLE. ITS SR 3.3.3.1 requires the performance of a CHANNEL CHECK of the Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) channels. This changes the CTS by moving the descriptive wording of the method for performing the CHANNEL CHECK to the ITS 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 the CHANNEL CHECK. 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.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.4.1 requires that each hydrogen analyzer be demonstrated OPERABLE by performing a CHANNEL CALIBRATION using calibration gas containing a four percent and fifteen percent nominal hydrogen gas, balance nitrogen. ITS SR 3.3.3.2 requires the hydrogen monitors to be subjected to a CHANNEL CALIBRATION. This change moves the CTS calibration gas requirements to the ITS 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 for the hydrogen monitors to be OPERABLE in the required MODES. The details of composition of the calibration gas used to perform the CHANNEL CALIBRATION is not required to be in the Technical Specifications, because regardless of the calibration gas composition, the hydrogen monitors are required to be OPERABLE (i.e., capable of performing their safety function). 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.

CNP Units 1 and 2 Page 7 of 20 Attachment 1, Volume 8, Rev. 0, Page 451 of 818

Attachment 1, Volume 8, Rev. 0, Page 452 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) Unit 1 CTS 3.3.3.8 Actions a and b and Unit 2 CTS 3.3.3.6 Actions a and b require placing the unit in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if an inoperable PAM instrumentation channel has not been restored within the allowed outage time. CTS 3.6.4.1 Action a requires placing the unit in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if an inoperable hydrogen analyzer has not been restored within the allowed outage time. ITS 3.3.3 ACTION B requires the initiation of a report to the NRC if one inoperable PAM instrumentation channel has not been restored within the associated Completion Time. This changes the CTS by deleting the requirements for the unit to be in HOT STANDBY or HOT SHUTDOWN with one required channel inoperable and not restored within the allowed outage time, and instead requiring a report to be made in accordance with ITS 5.6.6.

The purpose of these shutdown requirements is to limit unit operation in the MODES of Applicability when required equipment is inoperable. This change is acceptable due to the passive function of these instruments and the operator's ability to respond to an accident utilizing redundant or alternate instruments and methods for monitoring. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to respond to the event is low. The addition of a report is acceptable because it advises the NRC of the cause of the inoperability and the plans and schedule for restoring the instrumentation channel to OPERABLE status. This change is designated as less restrictive because additional time is allowed to restore instrument channels to OPERABLE status than was allowed in the CTS.

L.2 (Category 3 - Relaxation of Completion Time) Unit 1 CTS 3.3.3.8 Action a and Unit 2 CTS 3.3.3.6 Action a require placing the unit in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if both Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) channels are inoperable and have not been restored within the allowed outage time. ITS 3.3.3 ACTION G requires initiation of a report to the NRC if one of the two inoperable channels of the Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication) Function has not been restored within the associated Completion Time. This changes the CTS by deleting the requirements for the unit to be in HOT SHUTDOWN with two Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication)

Function channels inoperable and not restored within the allowed outage time, and instead requiring a report to be made in accordance with ITS 5.6.6.

The purpose of these shutdown requirements is to limit unit operation in the MODES of Applicability when required equipment is inoperable. This change is acceptable due to the passive function of these instruments and the operator's ability to respond to an accident utilizing alternate instruments and methods for monitoring. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to respond to the event is low. The addition of a report is acceptable because it advises the NRC of the cause of the inoperability and the plans and schedule for restoring the instrumentation channel to OPERABLE status. This change is designated as less restrictive because additional time is allowed to restore instrument channels to OPERABLE status than was allowed in the CTS.

CNP Units 1 and 2 Page 8 of 20 Attachment 1, Volume 8, Rev. 0, Page 452 of 818

Attachment 1, Volume 8, Rev. 0, Page 453 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION L.3 (Category 3 - Relaxation of Completion Time) Unit 1 CTS 3.3.3.8 Action b and Unit 2 CTS 3.3.3.6 Action b require, whenever one required channel is inoperable, restoration of one Refueling Water Storage Tank Water Level PAM instrumentation channel to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.3.3 ACTION A requires the restoration of the inoperable Refueling Water Storage Tank Water Level PAM instrumentation channel within 30 days. This changes the CTS by extending the restoration time for an inoperable Refueling Water Storage Tank Water Level PAM instrumentation channel from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 30 days.

The purpose of the current 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed outage time for restoration of an inoperable Refueling Water Storage Tank Water Level PAM instrumentation channel, as a opposed to the current 30 day allowed outage time for restoration of other inoperable PAM instrumentation channels, is to ensure that the allowed outage times for the Refueling Water Storage Tank Water Level PAM instrumentation channel was consistent with allowed outage times for the Emergency Core Cooling System (ECCS). The Refueling Water Storage Tank Water Level PAM instrumentation provides level indication in the control room for the operators to determine when to manually transfer suction of the ECCS pumps from the depleted refueling water storage tank to cold leg recirculation from the containment recirculation sump following an accident. This level instrumentation also provides a bistable input to trip the Residual Heat Removal (RHR) pump when Refueling Water Storage Tank level falls below a preset level to protect the RHR pump. However, this bistable function is not part of the PAM Instrumentation Function, and the bistable Function is not necessary for the OPERABILITY of the PAM Instrumentation Function. The definition of OPERABLE-OPERABILITY and the requirements in ITS 3.5.2, "ECCS -

Operating," are adequate to ensure that, if this bistable results in RHR pump inoperability, then the applicable actions of ITS 3.5.2 will be taken. Therefore, this change is acceptable due to the passive function of these PAM instruments and the operator's ability to respond to an accident utilizing redundant instruments. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to respond to the event is low. This change is designated as less restrictive because additional time is allowed to restore instrument channels to OPERABLE status than was allowed in the CTS.

L.4 (Category 4 - Relaxation of Required Action) Unit 1 CTS 3.3.3.8 Action b.2 and Unit 2 CTS 3.3.3.6 Action b.2, in the event of an inoperable Refueling Water Storage Tank Water Level PAM instrumentation channel, require action to be taken within one hour to bypass the Residual Heat Removal (RHR) pump trip function from the Refueling Water Storage Tank Water Level instrumentation for the pump associated with the out-of-service instrument. ITS 3.3.3 does not include this requirement. This changes the CTS by eliminating the Action requirement to bypass the RHR trip function when the Refueling Water Storage Tank Water Level PAM instrumentation channel is inoperable.

The purpose of the action to bypass the RHR pump trip function is to maintain RHR pump availability in the event of Refueling Water Storage Tank Water Level instrumentation inoperability. The Refueling Water Storage Tank Water Level PAM instrumentation provides level indication in the control room for the CNP Units 1 and 2 Page 9 of 20 Attachment 1, Volume 8, Rev. 0, Page 453 of 818

Attachment 1, Volume 8, Rev. 0, Page 454 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION operators to determine when to manually transfer suction of the ECCS pumps from the depleted refueling water storage tank to cold leg recirculation from the containment recirculation sump following an accident. This level instrumentation also provides a bistable input to trip the Residual Heat Removal (RHR) pump when Refueling Water Storage Tank level falls below a preset level to protect the RHR pump. However, this bistable function is not part of the PAM Instrumentation Function, and the bistable Function is not necessary for the OPERABILITY of the PAM Instrumentation Function. The definition of OPERABLE-OPERABILITY and the requirements in ITS 3.5.2 are adequate to ensure that, if this bistable results in RHR pump inoperability, then the applicable actions of ITS 3.5.2 will be taken. In addition, the requirements of the ITS 3.5.2 ACTIONS and the requirements of 10 CFR 50.65 ensure that RHR pump availability is adequately maintained. Therefore, the CTS action to bypass the bistable trip of the associated RHR pump when a Refueling Water Storage Tank Water Level PAM instrument is inoperable is unnecessary. 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 3 - Relaxation of Completion Time) Unit 1 CTS 3.3.3.8 Action b and Unit 2 CTS 3.3.3.6 Action b provide actions for the condition of one Refueling Water Storage Tank Water Level PAM instrumentation channel. When both Refueling Water Storage Tank Water Level PAM instrumentation channels are inoperable, no actions are provided and unit shutdown in accordance with CTS 3.0.3 is required. ITS 3.3.3 ACTION C, when two channels of Refueling Water Storage Tank Water Level PAM instrumentation are inoperable, requires the restoration of one of the two inoperable Refueling Water Storage Tank Water Level PAM instrumentation channels to OPERABLE status within 7 days. If not restored, then ITS 3.3.3 ACTION F requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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 a restoration time when two Refueling Water Storage Tank Water Level PAM instrumentation channels are inoperable, prior to requiring a unit shutdown.

The purpose of requiring entry into CTS 3.0.3 when two Refueling Water Storage Tank Water Level PAM instrumentation channels are inoperable, as opposed to the current 30 day allowed outage time for other inoperable PAM instrumentation channels, is to ensure that the allowed outage time for the Refueling Water Storage Tank Water Level PAM instrumentation channels was consistent with allowed outage times for Emergency Core Cooling System (ECCS). The Refueling Water Storage Tank Water Level PAM instrumentation provides level indication in the control room for the operators to determine when to manually transfer suction of the ECCS pumps from the depleted refueling water storage tank to cold leg recirculation from the containment recirculation sump following an accident. This level instrumentation also provides a bistable input to trip the Residual Heat Removal (RHR) pump when Refueling Water Storage Tank level falls below a preset level to protect the RHR pump. However, this bistable function is not part of the PAM Instrumentation Function, and the bistable Function is not necessary for the OPERABILITY of the PAM Instrumentation Function. The definition of OPERABLE-OPERABILITY and the requirements in ITS 3.5.2 are adequate to ensure that, if this bistable results in RHR pump inoperability, then the applicable actions of ITS 3.5.2 will be taken. Therefore, this change is acceptable due to the passive function of these PAM instruments CNP Units 1 and 2 Page 10 of 20 Attachment 1, Volume 8, Rev. 0, Page 454 of 818

Attachment 1, Volume 8, Rev. 0, Page 455 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION and the operator's ability to respond to an accident utilizing redundant instruments. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to respond to the event is low. This change is designated as less restrictive because additional time is allowed to restore instrument channels to OPERABLE status than was allowed in the CTS.

L.6 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) Unit 1 CTS Table 4.3-7 and Unit 2 CTS Table 4.3-10 requires a CHANNEL CALIBRATION of the identified PAM instruments every 18 months.

CTS Table 4.3-3 requires a CHANNEL CALIBRATION of the Containment High Range Area Monitors every 18 months. ITS Table 3.3.3-1 Functions 2 through 8, 10, 12, 15 through 19, 22, 24, and 25 require the performance of SR 3.3.3.3, a CHANNEL CALIBRATION, 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 Unit 1 CTS Table 4.3-7, Unit 2 CTS Table 4.3-10, and CTS Table 4.3-3 is to ensure PAM instruments will function as designed during an analyzed event. Extending the SR Frequency is acceptable because the PAM instruments are designed to be highly reliable. Furthermore, a CHANNEL CHECK is performed on a more frequent basis (ITS SR 3.3.3.1). The CHANNEL CHECK provides a qualitative demonstration of the OPERABILITY of the instrument.

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. The impacted PAM instruments listed below were evaluated through a failure analysis as well as a quantitative and qualitative analysis for drift to verify the instrument drift did not adversely impact instrument performance or availability.

Unit 1 CTS Table 4.3-7 and Unit 2 CTS Table 4.3-10 Instrument 1, Containment Pressure For narrow range containment pressure, the function is performed using Foxboro E11 Series Transmitters, Foxboro N-2AI-H2V Input Cards, Foxboro N-N-2AO-V2H+P Series Converters, Weschler VX-252 Indicators, and Yokogawa µR100 Recorders. A separate drift evaluation was not performed for the accident monitoring instrumentation based upon the design of the accident monitoring instruments, accuracy requirements, and equipment history. The following discussion supports this conclusion.

The accident monitoring function is supported by a combination of process transmitters, indicators and recorders. These components differ from other TS instruments in that they are not associated with a single action point but may be required to function anywhere within their range capability. An additional difference, based upon the time of function, is the process and environmental CNP Units 1 and 2 Page 11 of 20 Attachment 1, Volume 8, Rev. 0, Page 455 of 818

Attachment 1, Volume 8, Rev. 0, Page 456 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION conditions that may be present when the instruments are required. Trip devices function during the first several seconds of an accident (normally prior to any significant environment changes) to prevent or mitigate the consequences of an accident. The detailed setpoint analysis for these devices considers the environmental conditions as well as the specific process conditions associated with the protective trip. The accident monitoring instrumentation devices must maintain their function after the accident has occurred and track the progress of the event and event mitigation over a long period of time. Accident monitoring instrumentation is designed to operate in a wide variety of environments (ranging from normal to high temperature, high radiation, and high humidity) and to maintain functionality. Accident instrumentation may also be expected to monitor the process over a wide range of process conditions. However, these instruments are not expected to function with the same high degree of accuracy demanded of accident detection and mitigation trip devices. The accident monitoring instrumentation devices are expected to maintain sufficient accuracy to detect trends or the existence or non-existence of a condition within wider boundaries (e.g., is there water in the steam generator).

The accident monitoring instrumentation is designed with a high degree of reliability and redundancy. Where possible, the indicators and recorders used for accident monitoring are compared with other channels of instruments measuring the same variable or other variables with know relationships, to verify OPERABILITY during normal operating conditions. Additionally, a CHANNEL CHECK is required every 31 days. These tests verify that the indication and recording instruments are acceptable and operating within established tolerances. For the transmitters, the primary error contributor for normal operations is drift. However, for accident monitoring conditions the major errors are associated with the changes in process conditions and in environmental conditions. These changes in process and environmental conditions are in most cases orders of magnitude larger than the errors associated with drift. Therefore, a drift analysis will not verify that these devices will maintain acceptable accuracy for the accident monitoring conditions. Additionally, no specific accuracy requirements are noted within Technical Specifications and the accident analyses have adequate margin to account for instrumentation errors.

Therefore, for the reasons cited above, a drift calculation for these instruments is not necessary and a review of the surveillance test history provides an acceptable method to determine if the instrument calibration interval can be extended to a 24 month operating cycle. For the Narrow Range Containment Pressure instrumentation, the Foxboro E11 Series Transmitters and the Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 2, Reactor Coolant Outlet Temperature - THOT (Wide Range)

This function is performed using 200 Platinum RTDs as the sensing elements, Foxboro N-2AI-P2V Input Card and N-2AO-V2H+P Series Converter, and Leeds and Northrup 125 Series Recorders. The RTDs are not calibrated, and as such, instrument drift does not apply to these devices. Response of the RTDs to CNP Units 1 and 2 Page 12 of 20 Attachment 1, Volume 8, Rev. 0, Page 456 of 818

Attachment 1, Volume 8, Rev. 0, Page 457 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION temperature variations during normal plant operation verifies proper operation of the input signal. The Foxboro N-2AO-V2H+P Series Converter and N-2AI-P2V Input Card and Leeds and Northrup 125 series Recorders were not evaluated for drift based on the generic discussion for Instrument 1 above. The results of these analyses will support a 24 month Surveillance interval.

Instrument 3, Reactor Coolant Inlet Temperature - TCOLD (Wide Range)

This function is performed using 200 Platinum RTDs as the sensing element, Foxboro N-2AI-P2V Input Card and N-2AO-V2H+P Series Converter, and Leeds and Northrup 125 series Recorders. 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 verifies proper operation of the input signal. The Foxboro N-2AI-P2V Input Card and N-2AO-V2H+P Series Converter and Leeds and Northrup 125 Series Recorders were not evaluated for drift based on the generic discussion for Instrument 1 above. The results of these analyses will support a 24 month Surveillance interval.

Instrument 4, Reactor Coolant Pressure - Wide Range This function is performed using a Foxboro N-E11 Series Transmitter, Foxboro N-2AI-H2V Input Card and N-2AO-V2H+P Series Converter, a Weschler VX-252 Indicator, and a Yokogawa µR100 Recorder. The Foxboro N-2AO-V2H+P Series Converter, Weschler VX-252 Indicator, and Yokogawa

µR100 Recorder were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E11 Series Transmitters and Foxboro N-2AI-H2V Input Card were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 5, Pressurizer Water Level This function is performed using a Foxboro N-E13 Series Differential Pressure Transmitter, a Foxboro N-2AI-H2V Input Card and N-2AO-V2H+P Series Converter, a Weschler VX-252 Indicator, and a Yokogawa µR100 Recorder. The Foxboro N-2AO-V2H+P Series Converter, Weschler VX-252 Indicator, and the Yokogawa µR100 Recorder were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E13 Series Differential Pressure Transmitters and Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 6, Steam Line Pressure This function is performed using Foxboro N-E11 Series Transmitters, Foxboro N-2AI-H2V Input Cards, Foxboro N-2AO-V2H+P Series Converters, a Weschler VX-252 Indicator, and a Taylor 1334JA18100 Indicator. The Foxboro N-2AO-V2H+P Series Converters, Weschler VX-252 Indicator, and Taylor CNP Units 1 and 2 Page 13 of 20 Attachment 1, Volume 8, Rev. 0, Page 457 of 818

Attachment 1, Volume 8, Rev. 0, Page 458 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION 1334JA18100 Indicator were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E11 Series Transmitters and Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 7, Steam Generator Water Level - Narrow Range This function is performed using Foxboro N-E13 Series Differential Pressure Transmitters, Foxboro N-2AI-H2V Input Cards, Foxboro N-2AO-V2H+P Series Converters, and a Weschler VX-252 Indicator. The Foxboro N-2AO-V2H+P Series Converters and the Weschler VX-252 Indicator were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E13 Series Differential Pressure Transmitters and Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 8, Refueling Water Storage Tank Water Level This function is performed using a Foxboro E13 Series Differential Pressure Transmitters, Foxboro N-2AI-H2V Input Cards, Foxboro N-2AO-V2H+P Series Converters, Devar 18-119 Series Isolators, a Leeds & Northrup 124 Series Recorder, and a Weschler VX-252 Indicator. The Foxboro N-2AO-V2H+P Series Converters, Devar 18-119 Series Isolators, Leeds & Northrup 124 Series Recorder, and Weschler VX-252 Indicator were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro E13 Series Differential Pressure Transmitters and Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 10, Auxiliary Feedwater Flow Rate This function is performed using Foxboro N-E13 Series Differential Pressure Transmitters, Foxboro N-2AI-H2V and N-2CCA-SC & -DC Input Cards, Foxboro N-2AO-V2H+P Series Converters, and a Weschler VX-252 Indicator. The Foxboro N-2CCA-SC & -DC Input Cards, Foxboro N-2AO-V2H+P Series Converters, and the Weschler VX-252 Indicator were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E13 Series Differential Pressure Transmitters and Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

CNP Units 1 and 2 Page 14 of 20 Attachment 1, Volume 8, Rev. 0, Page 458 of 818

Attachment 1, Volume 8, Rev. 0, Page 459 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Instrument 11, Reactor Coolant System Subcooling Margin Monitor This function is performed by using various instrument loop inputs to the Subcooling Margin Monitor indication. Inputs from the Core Exit Thermocouples are provided by Whittaker Type K thermocouples as the sensing elements, Foxboro N 2AI-T2V+K+K, 2AO-V3I, 2AO-VAI, and 2AO-V2H Input Cards, and Foxboro N-2AO-V2H+P Series Converters. Inputs for Reactor Coolant System Wide Range Temperature are provided by 200 Platinum RTDs as the sensing elements, Foxboro 66 Special and 66-BC-OH Input Cards, and Foxboro N-2AO-V2H+P and N-2AI-H2V+P Series Converters. Inputs for the Reactor Coolant System Wide Range Pressure are provided by Foxboro N-E11 Series Pressure Transmitters, Foxboro N-2AI-H2V Input Cards, and Foxboro N-2AO-V2H+P and N-2AI-H2V+P Series Converters. Foxboro N-2CCA-SC Spec 200 Micro Control Cards provide the Subcooling Margin computation and provide output to the Subcooling Margin Monitor Indicators via Foxboro N-2AO-V2I+P Series Converters. The Indicators are Wavetek Model 500D Indicators. The RTDs and thermocouples are not calibrated, and as such, instrument drift does not apply to these devices. Response of the RTDs and thermocouples to temperature variations during normal plant operation verifies proper operation of the input signal. With the exception of the Foxboro N-2AI-H2V Input Cards, the Input Cards, Converters, and Indicators were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E11 Pressure Transmitters and Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

Instrument 15, Incore Thermocouples (Core Exit Thermocouples)

This function is performed using Whittaker Type K thermocouples as the sensing elements, Foxboro 2AO-V3I and 2AO-VAI Input Cards, a Foxboro N-2AI-T2V+K+K Series Converter, and a Yokogawa DR 240 Recorder.

The thermocouples are not calibrated, and as such, instrument drift does not apply to these devices. Response of the thermocouples to temperature variations during normal plant operation verifies proper operation of the input signal. The Foxboro 2AO-V3I and 2AO-VAI Input Cards, Foxboro N-2AI-2V+K+K Series Converter, and Yokogawa DR 240 Indicators were not evaluated for drift based on the generic discussion for Instrument 1 above. The results of these analyses will support a 24 month Surveillance interval.

Instrument 16, Reactor Coolant Inventory Tracking System (Reactor Vessel Level Indication)

This function is performed by a loop consisting of sensing elements, signal processing equipment, and indicators. The sensing elements include Foxboro N-E11 Series Transmitters and Barton 764 Differential Pressure Transmitters providing pressure and level signals and Conax RTDs providing Wide Range RCS Temperature signals. The Barton 764 Differential Pressure Transmitter (level) sensing lines are temperature (sensing line and RCS) and pressure (RCS) compensated, with the sensing line temperature compensation CNP Units 1 and 2 Page 15 of 20 Attachment 1, Volume 8, Rev. 0, Page 459 of 818

Attachment 1, Volume 8, Rev. 0, Page 460 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION signal provided by Minco RTDs. The signal processing equipment is contained not only within the various sensing element loops, but also in a Westinghouse 7300 Rack that generates the actual level signal for output to the Level Indicators. The Foxboro rack equipment for signal processing includes Model N-2AI-H2V and N-2AI-P2V Input Cards and N-2AO-V2H+P Converters.

The Westinghouse 7300 rack signal processing equipment consists of Model NRA2 and NLP2 Input Cards, Model NCT4 and NTC4 test Input Cards, and Model NCH9, NCH10, NCH11, NCH12, NCH13, NCI1, NLL1, NLP3, NMD1, NPC1, NSA, NSA2, NSA3, NSA4 and NSC7 Converters and signal processing cards. The Level Indicators are Weschler VX-252 Indicators. 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 verifies proper operation of the input signal. The signal processing equipment and Indicators (with the exception of the Foxboro N-2AI-H2V and Foxboro N-2AI-P2V Input Cards) were not evaluated for drift based on the generic discussion for Instrument 1 above. The Foxboro N-E11 Series Transmitters, Barton 764 Differential Pressure Transmitters, Foxboro N-2AI-H2V Input Cards for the RCS Pressure input, and the Foxboro N-2AI-P2V Input Cards for the RCS Temperature input were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions with the extended calibration interval was consistent with drift for normal operating conditions at the current calibration interval. The results of these analyses will support a 24 month Surveillance interval.

Instrument 18, Containment Water Level This function is performed using a FCI CL-86 Level Transmitter, Foxboro N-2AI-H2V Input Cards, Foxboro N-2AO-V2H+P Series Converters, and a Weschler VX-252 Indicator. The Foxboro N-2AO-V2H+P Converter and the Weschler VX-252 Indicator were not evaluated for drift based on the generic discussion for Instrument 1 above. The FCI CL-86 Level Transmitters and the Foxboro N-2AI-H2V Input Cards were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of these analyses will support a 24 month Surveillance interval.

CTS Table 4.3-3 Instrument 1.A.ii, Containment High Range Area Monitors This function is performed using Victoreen 877-1 Hi Range Radiation Monitoring Element as the sensing element and Victoreen 876-A-1 and 879-1 Hi Range Radiation Monitoring Readout Modules and Eberline SPING-4 Hi Range Radiation Monitoring Readout Modules for the output indication. These components were not evaluated for drift because, for radiation monitors, the major error contributor is the accuracy of the detector and the calibration sources. In the case of the calibration sources, normally multiple readings are required and an average reading is used to confirm operation. The accuracy of the decay curves and detector sensitivity may be from 12% to 30%. This accuracy far overshadows the accuracy of the electronic signal conditioning circuit. Therefore, drift of the electronic circuit does not provide a measure of CNP Units 1 and 2 Page 16 of 20 Attachment 1, Volume 8, Rev. 0, Page 460 of 818

Attachment 1, Volume 8, Rev. 0, Page 461 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION functional performance over time between calibrations. This is substantiated by the ANSI N42.18 acceptance criteria of + 20%, which also recognizes that + 30%

for alarm points satisfies the accuracy needed for Emergency Plan decisions and license requirements. The results of these analyses will support a 24 month Surveillance interval or the interval.

Based on the design of the instrumentation and the drift evaluations (where applicable), 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 unit licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.7 (Category 1 - Relaxation of LCO Requirements) CTS 3.3.3.1 and CTS Table 3.3-6, Instrument 1.A.ii provides alarm setpoint requirements for the Containment High Range Area Monitors. CTS 3.3.3.1 Action a provides actions to take when the Containment High Range Area Monitors alarm setpoint exceeds the specified value. ITS 3.3.3 does not include alarm setpoint for the Containment Area Radiation (High Range) instrumentation. This changes the CTS by eliminating the alarm setpoint requirements for the Containment High Range Area Monitors.

The purpose of the Containment High Range Area Monitors PAM instrumentation is to provide the control room operator with indication of adverse conditions in containment. This change is acceptable because the alarm setpoint is not necessary for the Containment High Range Area Monitors PAM instrumentation to perform its specified function of providing indication to the control room operators. ITS 3.3.3 requires the Containment Area Radiation (High Range) instrumentation to be OPERABLE. The ITS 3.3.3 requirement and the definition of OPERABLE-OPERABILITY are adequate to ensure that the Containment Area Radiation (High Range) PAM instrumentation remain capable of providing indication to the control room operators. 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.8 (Category 5 - Deletion of Surveillance Requirement) CTS 4.3.3.1 and CTS Table 4.3-3 require the performance of a CHANNEL FUNCTIONAL TEST of Containment High Range Area Monitors. ITS 3.3.3 does not require a CHANNEL FUNCTIONAL TEST be performed for Containment Area Radiation (High Range) PAM instrumentation. This changes the CTS by eliminating the CHANNEL FUNCTIONAL TEST for the Containment Area Radiation (High Range) PAM instrumentation.

The purpose of CTS Table 4.3-3 Surveillances is to ensure the Containment Area Radiation (High Range) PAM instrumentation will function as designed during an analyzed event. This change is acceptable because the deleted CNP Units 1 and 2 Page 17 of 20 Attachment 1, Volume 8, Rev. 0, Page 461 of 818

Attachment 1, Volume 8, Rev. 0, Page 462 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION Surveillance Requirement is not necessary to verify that the capability of equipment used to meet the LCO is consistent with assumption in the safety analysis. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are satisfied. The ITS SRs for the instruments continue to provide sufficient test requirements to ensure the OPERABILITY of the Containment Area Radiation (High Range) PAM instrumentation. The elimination of the CTS SR does not affect reactor protection or accident mitigation. The ITS SRs are consistent with other PAM instrumentation channels and ensure the functions remain OPERABLE. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.9 (Category 2 - Relaxation of Applicability) CTS Tables 3.3-6 and 4.3-3 require the Containment High Range Area Monitors to be OPERABLE in MODES 1, 2, 3, and 4. ITS 3.3.3 requires the Containment Area Radiation (High Range) PAM Function to be OPERABLE in MODES 1, 2, and 3. This changes the CTS by deleting the requirements for the Function in MODE 4.

The purpose of the Containment Area Radiation (High Range) PAM instrumentation requirements is to ensure that the control room operators are provided with information regarding adverse conditions in containment following a design basis event. This change is acceptable because the requirements continue to ensure that the instruments are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis.

Containment Area Radiation (High Range) PAM instrumentation is required to be OPERABLE in MODES 1, 2, and 3. This is acceptable because in MODES 4, 5, and 6, accidents of the type that would require these instruments are less likely to occur because of reduced temperature and pressure in the RCS and secondary system. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.10 (Category 13 - Addition of LCO 3.0.4 Exception) CTS 3.6.4.1 provides requirements for containment hydrogen analyzers, but does not include an exception to CTS 3.0.4. Thus, CTS 3.0.4 would preclude changing MODES when one or both hydrogen analyzers are inoperable. ITS 3.3.3 ACTION Note 1 states "LCO 3.0.4 is not applicable." This changes the CTS by allowing entry into the MODE of Applicability with one or both hydrogen analyzers inoperable.

The purpose of CTS 3.6.4.1 is to provide the capability to detect high hydrogen concentration levels in containment that represent a potential for containment breach from a hydrogen uncontrolled burn following a Design Basis Accident.

The change allows entry into the MODE of Applicability with one or both hydrogen analyzers inoperable. The hydrogen analyzers do not impact normal unit operation and would not provide additional initiators for unit transients during MODE changes. 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 passive function of these PAM instruments and the operator's ability to respond to an accident utilizing redundant instruments or alternative CNP Units 1 and 2 Page 18 of 20 Attachment 1, Volume 8, Rev. 0, Page 462 of 818

Attachment 1, Volume 8, Rev. 0, Page 463 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION monitoring means for monitoring hydrogen concentration in containment.

Therefore, the capability to detect high hydrogen concentration levels in containment that represent a potential for containment breach from a hydrogen uncontrolled burn following a Design Basis Accident is maintained. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to respond to the event is low. This change is designated as less restrictive because the ACTIONS Note allows entry into the MODE of Applicability with one or two inoperable containment hydrogen monitors.

L.11 (Category 3 - Relaxation of Completion Time) CTS Table 3.3-6 Action 22A requires, when one or both Containment High Range Area Monitor channels become inoperable, the inoperable channels to be restored to OPERABLE status within 7 days. ITS 3.3.3 ACTION A allows 30 days to restore one inoperable channel of the Containment Area Radiation (High Range) Function to OPERABLE status. This changes the CTS by allowing one channel of the Containment Area Radiation (High Range) Function to be inoperable for a period of 30 days.

The purpose of the CTS allowed outage times is to limit unit operation in the MODES of Applicability when required equipment is inoperable. This change is acceptable due to the passive function of these PAM instruments and the operator's ability to respond to an accident utilizing redundant instruments. The change is also considered acceptable since the probability of an event requiring the operator to utilize this instrumentation to respond to the event is low. This change is designated as less restrictive because additional time is allowed to restore instrument channels to OPERABLE status than was allowed in the CTS.

L.12 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.3-3 requires the performance of a CHANNEL CHECK of the Containment High Range Area Monitors once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.3.3.1 requires the performance of a CHANNEL CHECK of the Containment Area Radiation (High Range) Function instrumentation once per 31 days. This changes the CTS by extending the Surveillance interval for performance of a CHANNEL CHECK of the Containment Area Radiation (High Range) Function instrumentation from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 31 days.

The purpose of the CHANNEL CHECK is to perform a qualitative assessment to ensure that gross instrumentation failure has not occurred. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change extends the Surveillance Frequency for performance of a CHANNEL CHECK of the Containment Area Radiation (High Range) Function instrumentation from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 31 days. This change is acceptable since a Frequency of 31 days for the CHANNEL CHECK of this instrumentation provides adequate assurance that a gross failure will be detected since operating experience demonstrates that channel failure is rare. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

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Attachment 1, Volume 8, Rev. 0, Page 464 of 818 DISCUSSION OF CHANGES ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION L.13 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.4.1 requires each hydrogen analyzer to be demonstrated OPERABLE at least once per 92 days "on a STAGGERED TEST BASIS" by performing a CHANNEL CALIBRATION. ITS SR 3.3.3.2 requires a CHANNEL CALIBRATION of the hydrogen monitors to be performed at a Frequency of every 92 days, but does not include the "STAGGERED TEST BASIS" requirement. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of the CHANNEL CALIBRATION surveillance is to demonstrate the OPERABILITY of the hydrogen monitors. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change deletes the requirement to perform the CHANNEL CALIBRATION on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested. A number of studies have been performed that have demonstrated that staggered testing has negligible impact on component reliability. These analytical and subjective analyses have determined that staggered testing 1) is operationally difficult, 2) has negligible impact on component reliability, 3) is not as significant as initially thought, 4) has no impact on failure frequency, 5) introduces additional stress on components potentially causing increased component failures rates and component wearout, 6) results in reduced redundancy testing, and 7) increases likelihood of human error by increasing testing intervals. Therefore, the hydrogen monitors CHANNEL CALIBRATION staggered testing requirements have been deleted. This change is designated as less restrictive because the intervals between performances of the Surveillances for the two hydrogen monitors can be larger or smaller under the ITS than under the CTS.

L.14 (Category 1 - Relaxation of LCO Requirements) CTS Table 3.3-6, Instrument 1.A.ii specifies the Containment High Range Area Monitor channel instrument numbers to be VRA 1310/1410 (Unit 1) and VRA 2310/2410 (Unit 2).

ITS Table 3.3.3-1 Function 10 does not specify the instrument numbers. This changes the CTS by deleting the Containment High Range Area Monitor channel instrument numbers from the Technical Specifications.

The purpose of CTS Table 3.3-6, Instrument 1.A.ii is to ensure the appropriate instrument channels are OPERABLE. This change is acceptable because the LCO and associated Surveillance Requirements continue to ensure that the instrumentation is maintained consistent with the safety analyses and licensing basis. The Containment High Range Area Monitor instrument channel numbers have been deleted from the Technical Specifications. The instrument numbers are not necessary to ensure the equipment is OPERABLE. The requirements to maintain the instrumentation (Containment Area Radiation (High Range) channels) OPERABLE is sufficient to ensure the appropriate equipment is maintained OPERABLE. The use of a description of the instrument channel in the Technical Specifications has been proven to be sufficient. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

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Attachment 1, Volume 8, Rev. 0, Page 472 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION

1. An additional CHANNEL CALIBRATION (ITS SR 3.3.3.2) has been added consistent with the current licensing basis for performing CHANNEL CALIBRATION of the hydrogen analyzers. The Note to the Surveillance Requirements has been modified and the subsequent Surveillance has been modified and renumbered due to the addition.

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

3. The PAM Instrumentation Functions and number of required channels have been revised in ISTS Table 3.3.3-1 to reflect the CNP nomenclature, design, and licensing basis with respect to the plant-specific Regulatory Guide 1.97 Type A instruments and Category 1, non-Type A, instruments.

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

5. A new footnote (d) is added to ISTS Table 3.3.3-1, Function 19, Auxiliary Feedwater Flow to allow ITS Table 3.3.3-1, Function 22, Steam Generator Water Level (Narrow Range) channel(s) to be credited with satisfying the corresponding Auxiliary Feedwater Flow channel(s) OPERABILITY requirements. This change is consistent with the allowances of the

footnote in Unit 1 CTS Table 3.3-11 and Unit 2 CTS Table 3.3-10.

6. Changes have been made due to changes in other Specifications.

7. The ISTS ACTIONS NOTE has been revised to allow separate Condition entry for certain Functions specified on a steam generator, a cold leg injection line, and a pump basis. The allowance is also consistent with the current allowances in the CTS for Functions 2, 19, and 22. There are no requirements in the CTS for Functions 13, 20, 26, 27, and 28. The requirements for these Functions have been added in accordance with ITS 3.3.3 DOC M.4. 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 the ITS 3.3.2.

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INSERT 1 The PAM Instrumentation LCO also ensures the OPERABILITY of Category 1, non-Type A, variables so the control room staff can:

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Attachment 1, Volume 8, Rev. 0, Page 479 of 818 B 3.3.3 1 INSERT 1A

, except for approved deviations, as described in References 1 and 2.

1 INSERT 1B of each of the two neutron flux instruments (10E-8 to 200% power) 1 INSERT 2

2. Steam Generator Pressure Steam Generator Pressure is a Type A, Category 1 variable provided for determination of required core exit temperature. Three steam generator pressure channels per steam generator are provided. Each channel has a range of 0 psig to 1200 psig. However, only two steam generator pressure channels per steam generator are required to satisfy the guidance in Reference 3.

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INSERT 6 The Reactor Coolant Inventory Tracking System consists of two channels of instrumentation. Each channel is capable of measuring upper plenum level, narrow range level, and dynamic head (i.e., wide range level).

1 INSERT 7 Containment Water Level is a Type A, Category 1 variable provided for determination of adverse containment conditions. Two containment water level channels are provided.

Each channel is capable of measuring from 599' 3" elevation to 614' elevation (containment floor level to maximum flood level). Additionally, each channel is supplemented by two level switches. Each level switch will provide indication in the control room when the containment water level has exceeded its associated setpoint.

One level switch actuates at a containment level of 602' 2 3/4" while the other level switch actuates when the containment level reaches 613' 0." The low switch provides a decision point associated with Type A use (switch the ECCS suction source from the refueling water storage tank to the containment recirculation sump) while the high switch confirms whether or not the containment water level has exceeded its design basis value.

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INSERT 8 Containment Pressure (Narrow Range) is a Type A, Category 1 variable used as criteria to manually establish or trip containment spray. Four containment pressure (narrow range) channels are provided. Each channel has a range of -5 psig to +12 psig.

However, only two of containment pressure (narrow range) channels are required to satisfy the guidance in Reference 3.

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Attachment 1, Volume 8, Rev. 0, Page 487 of 818 B 3.3.3 1 INSERT 9 Two containment area radiation channels are provided. Each channel is capable of monitoring from 1 R/hr to 1 X 10E7 R/hr.

1 INSERT 10 Two hydrogen monitors are provided. Each hydrogen monitor is capable of determining hydrogen concentration in the range of 0 to 30% hydrogen by volume. Each analyzer must be capable of sampling the containment.

1 INSERT 11 Three pressurizer level channels are provided. Each channel has a range of 0 to 100%

(96% of indicated volume). However, only two pressurizer level channels are required to satisfy the guidance in Reference 3.

1 INSERT 12 One steam generator level (wide range) channel per steam generator is provided. Each channel is capable of monitoring from 12 above the steam generator tube sheet to the separators.

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Attachment 1, Volume 8, Rev. 0, Page 489 of 818 B 3.3.3 1 INSERT 13 from essentially the top of the CST to the bottom of the CST (95% total volume) by a single channel provided to satisfy the guidance of Reference 3, as described in Reference 1.

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INSERT 14 a Type A, Category 1 variable used to determine whether to manually reduce Emergency Core Cooling System (ECCS) flow. This variable is also 1

INSERT 15 In addition, core exit temperature is used for determining RCS subcooling margin.

1 INSERT 16 Each core exit temperature channel has a range of 200°F to 2300°F.

1 INSERT 17 a Type A, Category 1 variable used to determine whether to manually reduce ECCS flow. This variable is also Insert Page B 3.3.3-10 Attachment 1, Volume 8, Rev. 0, Page 491 of 818

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Attachment 1, Volume 8, Rev. 0, Page 493 of 818 B 3.3.3 1 INSERT 18 One auxiliary feedwater flow channel per steam generator is provided. Each channel is capable of measuring from 0 lbm/hr to 250,000 lbm/hr. Due to the similarity of the Steam Generator Water Level (Narrow Range) Function (Table 3.3.3-1 Function 22) and the Auxiliary Feedwater Flow Function (Table 3.3.3-1, Function 19), Note (d) to Table 3.3.3-1 provides the allowance to credit OPERABLE Steam Generator Water Level (Narrow Range) channel(s) to satisfy the corresponding Auxiliary Feedwater Flow channel(s) OPERABILITY requirements of Table 3.3.3-1.

1 INSERT 19

20. Centrifugal Charging Pump Flow Centrifugal Charging Pump Flow is a Type A, Category 1 variable provided for verification that pressurizer level is maintained during a Steam Generator Tube Rupture. Four charging pump flow channels (one channel per cold leg injection line) are provided. Each channel is capable of measuring from 0 gpm to 200 gpm.

21. Safety Injection Pump Flow Safety Injection Pump Flow is a Type A, Category 1 variable used as criteria to manually trip the reactor coolant pumps. Two safety injection pump flow channels (one channel per safety injection line) are provided. Each channel is capable of measuring from 0 gpm to 500 gpm.

22. Steam Generator Water Level (Narrow Range)

Steam Generator Water Level (Narrow Range) is a Type A, Category 1 variable used to determine whether to manually reduce ECCS flow. This variable is also provided to monitor operation of decay heat removal via the SGs. Three steam generator water level (narrow range) channels per steam generator are provided. Each channel is capable of measuring from below the first stage separator to the second stage separator. However, only two steam generator water level (narrow range) channels per steam generator are required to satisfy the guidance in Reference 3.

23. Containment Pressure (Wide Range)

Containment Pressure (Wide Range) is a Category 1 variable provided for verification of RCS and containment OPERABILITY. Two containment pressure (wide range) channels are provided. Each channel is capable of monitoring from

-5 psig to +36 psig.

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INSERT 19 (continued)

24. Refueling Water Storage Tank Level Refueling Water Storage Tank Level is a Type A, Category 1 variable provided for determination of when the manual transfer to cold leg recirculation is required, based on low Refueling Water Storage Tank level. Two refueling water storage tank water level channels are provided. Each channel is capable of monitoring from essentially the top of the tank (bottom of the tank overflow) to the bottom of the tank (bottom of the safety injection suction pipe).

25. RCS Subcooling Margin Monitor RCS Subcooling Margin Monitor is a Type A variable provided for the determination of when to manually trip or when to reduce pressurizer spray and ECCS flow. This variable is also provided for verification of core cooling. The RCS Subcooling Margin Monitor calculates the margin to saturation for the RCS from inputs for RCS Pressure (Wide Range), Core Exit Temperature, RCS Hot Leg Temperature (Wide Range) and RCS Cold Leg Temperature (Wide Range). The RCS Subcooling Margin Monitor is capable of measuring from 425°F subcooling to 75°F superheat.

The output of the RCS Subcooling Margin Monitor is indicated in the control room.

The plant process computer subcooling margin readout can also be used in place of the RCS Subcooling Margin Monitor indicator in the control room.

26. Component Cooling Water Pump Circuit Breaker Status Component Cooling Water Pump Circuit Breaker Status is a Type A, Category 1 variable provided for verification of component cooling water flow to Engineered Safety Feature Systems. Two component cooling water pump circuit breaker status channels (one channel per component cooling water pump) are provided. Each channel is capable of indicating circuit breaker position (open or closed).

27. Centrifugal Charging Pump Circuit Breaker Status Centrifugal Charging Pump Circuit Breaker Status is a Type A, Category 1 variable used as criteria to manually trip the reactor coolant pumps (RCPs). Two centrifugal charging pump circuit breaker status channels (one channel per centrifugal charging pump) are provided. Each channel is capable of indicating circuit breaker position (open or closed).

28. Safety Injection Pump Circuit Breaker Status Safety Injection Pump Circuit Breaker Status is a Type A, Category 1 variable used as criteria to manually trip the RCPs. Two safety injection pump circuit breaker status channels (one channel per safety injection pump) are provided. Each channel is capable of indicating circuit breaker position (open or closed).

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INSERT 19A In addition, separate Condition entry is allowed within a Function as follows: (a) for Functions 2, 13, 19, and 22 on a steam generator basis; (b) for Function 20 on a cold leg injection line basis; and (c) for Functions 26, 27, and 28 on a pump basis.

4 INSERT 19B or steam generator basis for Functions 2, 13, 19, and 22, cold leg injection line basis for Function 20, and pump basis for Functions 26, 27, and 28 1 INSERT 20 or remaining isolation barrier in the case of containment penetrations with only one CIV Insert Page B 3.3.3-12 Attachment 1, Volume 8, Rev. 0, Page 496 of 818

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INSERT 22 For Function 9, the CHANNEL CALIBRATION shall consist of verifying that the position indication conforms to actual valve position. For Function 11, the CHANNEL CALIBRATION shall be performed using a 4% and 15% nominal hydrogen gas, balance nitrogen. For Functions 15, 16, 17, and 18, whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the Core Exit Temperature thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing elements. For Functions 26, 27, and 28, the CHANNEL CALIBRATION shall consist of verifying that the position indication conforms to actual circuit breaker position.

6 INSERT 23 Both the 92 day and 24 month Frequencies are 1

INSERT 24

1. NRC letter, T. G. Colburn (NRC) to M. P. Alexich (Indiana Michigan Power Company), "Emergency Response Capability - Conformance to Regulatory Guide 1.97 Revision 3 for the D. C. Cook Nuclear Plant, Units 1 and 2," dated December 14, 1990.

2. UFSAR, Table 7.8-1.

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Attachment 1, Volume 8, Rev. 0, Page 502 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.3 BASES, POST ACCIDENT MONITORING (PAM) 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. The Background section of the ISTS 3.3.3 Bases contains information that describes the Type A variables and Category 1 variables. This same descriptive information is effectively duplicated in the Applicable Safety Analyses section of the ISTS 3.3.3 Bases. Therefore, the duplicate descriptive information in the Background section of the Bases is deleted. In addition, the description of these variables in the Applicable Safety Analyses section of the ISTS 3.3.3 Bases has been modified to clearly identify which functions are provided by Type A variables and which functions are provided by Category 1, non-Type A, variables.

3. The ISTS Reviewers Note is deleted because it is not intended to be included in the plant specific ITS submittal.

4. Changes are made to reflect the Specifications.

5. Grammatical/editorial error corrected.

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

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

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

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Attachment 1, Volume 8, Rev. 0, Page 503 of 818 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 8, Rev. 0, Page 504 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.3, POST ACCIDENT MONITORING (PAM) INSTRUMENTATION There are no specific NSHC discussions for this Specification.

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Attachment 1, Volume 8, Rev. 0, Page 505 of 818 ATTACHMENT 4 ITS 3.3.4, Remote Shutdown Monitoring Instrumentation Attachment 1, Volume 8, Rev. 0, Page 505 of 818

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Attachment 1, Volume 8, Rev. 0, Page 507 of 818 ITS 3.3.4 A.1 ITS LA.1 LCO 3.3.4 LA.2 Add proposed ACTIONS Note 2 A.2 ACTIONS A and B Add proposed Required Action B.1 M.1 ACTIONS Note 1 SR 3.3.4.1, SR 3.3.4.2 Page 1 of 6 Attachment 1, Volume 8, Rev. 0, Page 507 of 818

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Attachment 1, Volume 8, Rev. 0, Page 509 of 818 ITS 3.3.4 A.1 ITS LA.1 SR 3.3.4.1 SR 3.3.4.2 24 months M.2 24 months L.1 Page 3 of 6 Attachment 1, Volume 8, Rev. 0, Page 509 of 818

Attachment 1, Volume 8, Rev. 0, Page 510 of 818 ITS 3.3.4 A.1 ITS LA.1 LCO 3.3.4 LA.2 Add proposed ACTIONS Note 2 A.2 ACTIONS A and B Add proposed Required Action B.1 M.1 ACTIONS Note 1 SR 3.3.4.1, SR 3.3.4.2 Page 4 of 6 Attachment 1, Volume 8, Rev. 0, Page 510 of 818

Attachment 1, Volume 8, Rev. 0, Page 511 of 818 ITS 3.3.4 A.1 ITS LA.1 Page 5 of 6 Attachment 1, Volume 8, Rev. 0, Page 511 of 818

Attachment 1, Volume 8, Rev. 0, Page 512 of 818 ITS 3.3.4 A.1 ITS LA.1 M.2 L.1 24 months 24 months SR 3.3.4.2 SR 3.3.4.1 Page 6 of 6 Attachment 1, Volume 8, Rev. 0, Page 512 of 818

Attachment 1, Volume 8, Rev. 0, Page 513 of 818 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING 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 3.3.3.5 Action a provides the compensatory actions to take when remote shutdown monitoring instrumentation is inoperable. ITS 3.3.4 ACTIONS provide the compensatory actions for inoperable remote shutdown monitoring instrumentation. The ITS 3.3.4 ACTIONS include a Note (Note 2) that allows separate Condition entry for each Function. This modifies the CTS by providing a specific allowance to enter the Action for each inoperable remote shutdown monitoring instrumentation Function.

This change is acceptable because it clearly states the current requirement. The CTS considers each remote shutdown monitoring instrumentation Function to be separate and independent from the others. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.3.3.5 Action a requires, if an inoperable channel cannot be returned to OPERABLE status within the allowed outage time, then the unit shall be placed in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.3.4 ACTION B requires, if a required channel cannot be returned to OPERABLE status within the associated Completion Time, then the unit shall be in MODE 3 (HOT STANDBY) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 (HOT SHUTDOWN) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS requirements by specifying that MODE 3 must be achieved within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The purpose of ITS 3.3.4 Required Action B.1 is to specify consistent Completion Times to shutdown the unit from full power to MODE 3. This change is acceptable because the proposed Completion Time is sufficient to allow an operator to reduce power from full power to MODE 3 in a controlled manner without challenging unit safety systems. The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time provided to reach MODE 3 is also consistent with the time provided in similar actions in both the CTS and ITS. The change has been designated as more restrictive because it specifies the amount of time within which the unit must be placed in MODE 3.

M.2 CTS Table 4.3-6 provides Surveillance Requirements for the remote shutdown monitoring instrumentation. For the Reactor Trip Breaker Indication Function, CTS Table 4.3-6 does not require Surveillances to be performed. ITS SR 3.3.4.2 requires a CHANNEL CALIBRATION for each required instrumentation channel be performed every 24 months, including the Reactor Trip Breaker Indication Function. This changes the CTS by requiring a CHANNEL CALIBRATION of the CNP Units 1 and 2 Page 1 of 6 Attachment 1, Volume 8, Rev. 0, Page 513 of 818

Attachment 1, Volume 8, Rev. 0, Page 514 of 818 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Reactor Trip Breaker Indication Function of the remote shutdown monitoring instrumentation.

The purpose of the CHANNEL CALIBRATION is to ensure that the remote shutdown monitoring instrumentation is capable of performing its intended monitoring function should the control room become inaccessible. This change is acceptable because it provides additional assurance that the operator will be capable of monitoring reactor trip breaker status on the hot shutdown panel should the control room become inaccessible. The change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.3.3.5 requires the remote shutdown monitoring instrumentation in Table 3.3-9 to be OPERABLE. CTS Table 3.3-9 lists each of the required remote shutdown monitoring instruments, the measurement range of each instrument, the location of the remote shutdown monitoring instrumentation readout, and the minimum number of channels required for each instrument.

CTS Table 4.3-6 lists the required remote shutdown monitoring instruments and their associated Surveillance Requirements. ITS LCO 3.3.4 states that the remote shutdown monitoring instrumentation Functions shall be OPERABLE.

This changes the CTS by moving the details in Tables 3.3-9 and 4.3-6, with the exception of the Surveillance Requirements, from the Technical Specifications to the ITS 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 remote shutdown monitoring instrumentation 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.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.3.3.5 states that the remote shutdown monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE "with readouts displayed external to the control room." ITS LCO 3.3.4 states that the remote shutdown monitoring instrumentation Functions shall be OPERABLE.

CNP Units 1 and 2 Page 2 of 6 Attachment 1, Volume 8, Rev. 0, Page 514 of 818

Attachment 1, Volume 8, Rev. 0, Page 515 of 818 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION This changes the CTS by moving the requirement for readouts displayed external to the control room from the Technical Specifications to the ITS 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 remote shutdown monitoring instrumentation 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.

LESS RESTRICTIVE CHANGES L.1 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS Table 4.3-6 requires a CHANNEL CALIBRATION of the remote shutdown monitoring pressurizer pressure, pressurizer level, steam generator pressure, and steam generator level instruments every 18 months.

ITS SR 3.3.4.2 requires the performance of a CHANNEL CALIBRATION for these instruments 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 Table 4.3-6 is to ensure remote shutdown monitoring instruments will function as designed during an analyzed event. Extending the SR Frequency is acceptable because the remote shutdown monitoring instruments are designed to be highly reliable. Furthermore, a CHANNEL CHECK for the remote shutdown monitoring pressurizer pressure, pressurizer level, steam generator pressure, and steam generator level instruments is performed on a more frequent basis (ITS SR 3.3.4.1). The CHANNEL CHECK provides a qualitative demonstration of the OPERABILITY of the instrument.

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. The impacted remote shutdown monitoring instrumentation has been evaluated through a failure analysis as well as a quantitative and qualitative analysis for drift to verify the instrument drift did not adversely impact instrument performance or availability.

CNP Units 1 and 2 Page 3 of 6 Attachment 1, Volume 8, Rev. 0, Page 515 of 818

Attachment 1, Volume 8, Rev. 0, Page 516 of 818 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION CTS Table 4.3-6 Instrument 2, Pressurizer Pressure This function is performed using a Foxboro N-E11 Series Pressure Transmitter, Foxboro N-2AI-H2V Input Cards, Foxboro N-2AO-V2H+P Series Converters, and a Weschler VX-252 Indicator. The Foxboro N-E11 Pressure Transmitter and Foxboro N-2AI-H2V Input Card were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of the quantitative drift analysis demonstrate that the Transmitter and Input Card will provide acceptable accuracy for the Remote Shutdown Monitoring indication in the event an evacuation of the control room is required. The Foxboro N-2AO-V2H+P Series Converters and Weschler VX-252 Indicator were not evaluated for drift because mirror Indicators exist in the control room for the same variables, in many cases with signals provided by the same Transmitters.

Monthly CHANNEL CHECKS are required to compare the control room reading with the remote panel reading. Thus the periodic CHANNEL CHECKS provide an excellent indication that the Remote Shutdown Monitoring indication loop is properly functioning. The Transmitter and its associated Input Card are analyzed because a single Transmitter may provide the signal for both control room and remote shutdown panel indications. Therefore, the specific accuracy of the Transmitter is verified by analysis and the accuracy of the Indicators and Converter are verified by the CHANNEL CHECKS. The results of these analyses will support a 24 month Surveillance interval.

Instrument 3, Pressurizer Level This function is performed using a Foxboro N-E13 Series Differential Pressure Transmitter, Foxboro N-2AI-H2V Input Card, Foxboro N-2AO-V2H+P Series Converter, and a Hughes VX-252 Indicator. The Foxboro N-E13 Series Differential Pressure Transmitter and Foxboro N-2AI-H2V Input Card were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of the quantitative drift analysis demonstrate that the Transmitter and Input Card will provide acceptable accuracy for the Remote Shutdown Monitoring indication in the event an evacuation of the control room is required. The Foxboro N-2AO-V2H+P Series Converter and Hughes VX-252 Indicator were not evaluated for drift because mirror indicators exist in the control room for the same variables, in many cases with signals provided by the same Transmitters. Monthly CHANNEL CHECKS are required to compare the control room reading with the remote panel reading. Thus the periodic CHANNEL CHECKS provide an excellent indication that the Remote Shutdown Monitoring indication loop is properly functioning. The Transmitter and its associated Input Card are analyzed because a single Transmitter may provide the signal for both control room and remote shutdown panel indications.

Therefore, the specific accuracy of the Transmitter is verified by analysis and the accuracy of the Indicators and Converter are verified by the CHANNEL CHECKS. The results of these analyses will support a 24 month Surveillance interval.

CNP Units 1 and 2 Page 4 of 6 Attachment 1, Volume 8, Rev. 0, Page 516 of 818

Attachment 1, Volume 8, Rev. 0, Page 517 of 818 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION Instrument 4, Steam Generator Pressure This function is performed using a Foxboro N-E11 Series Pressure Transmitter, Foxboro N-2AI-H2V Input Card, Foxboro N-2AO-V2H+P Series Converter, and a Weschler VX-252 Indicator. The Foxboro N-E11 Pressure Transmitter and Foxboro N-2AI-H2V Input Card were evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of the quantitative drift analysis demonstrate that the Transmitter will provide acceptable accuracy for the Remote Shutdown Monitoring indication in the event an evacuation of the control room is required. The Foxboro N-2AO-V2H+P Series Converter and Weschler VX-252 Indicator were not evaluated for drift because mirror indicators exist in the control room for the same variables, in many cases with signals provided by the same Transmitters. Monthly CHANNEL CHECKS are required to compare the control room reading with the remote panel reading. Thus the periodic CHANNEL CHECKS provide an excellent indication that the Remote Shutdown Monitoring indication loop is properly functioning. The Transmitter and its associated Input Card are analyzed because a single Transmitter may provide the signal for both control room and remote shutdown panel indications. Therefore, the specific accuracy of the Transmitter is verified by analysis and the accuracy of the Indicators and Converter are verified by the CHANNEL CHECKS. The results of these analyses will support a 24 month Surveillance interval.

Instrument 5, Steam Generator Level This function is performed using a Foxboro N-E13 Series Differential Pressure Transmitter and a Weschler VX-252 Indicator. The Foxboro N-E13 Series Differential Pressure Transmitter was evaluated quantitatively through a drift analysis to verify that drift for normal operating conditions is consistent with similar plant instruments used for protective functions. The results of the quantitative drift analysis demonstrate that the Transmitter will provide acceptable accuracy for the Remote Shutdown Monitoring indication in the event an evacuation of the control room is required. The Remote Shutdown Monitoring Indicators were not evaluated for drift because mirror indicators exist in the control room for the same variables, in many cases with signals provided by the same Transmitters. Monthly CHANNEL CHECKS are required to compare the control room reading with the remote panel reading. Thus the periodic CHANNEL CHECKS provide an excellent indication that the Remote Shutdown Monitoring indication loop is properly functioning. The Transmitter and its associated Input Card are analyzed because a single Transmitter may provide the signal for both control room and remote shutdown panel indications.

Therefore, the specific accuracy of the Transmitter is verified by analysis and the accuracy of the Indicators and Converter are verified by the CHANNEL CHECKS. The results of these analyses will support a 24 month Surveillance interval.

Based on the design of the instrumentation and the drift evaluations (where applicable), 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 CNP Units 1 and 2 Page 5 of 6 Attachment 1, Volume 8, Rev. 0, Page 517 of 818

Attachment 1, Volume 8, Rev. 0, Page 518 of 818 DISCUSSION OF CHANGES ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION 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 unit licensing basis. 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 6 of 6 Attachment 1, Volume 8, Rev. 0, Page 518 of 818

Attachment 1, Volume 8, Rev. 0, Page 519 of 818 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 8, Rev. 0, Page 519 of 818

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Attachment 1, Volume 8, Rev. 0, Page 522 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.4, REMOTE SHUTDOWN MONITORING INSTRUMENTATION

1. ISTS 3.3.4 requires Remote Shutdown System Functions to be OPERABLE. As stated in the Bases, these Functions include not only instrumentation to monitor plant parameters, but also control switches and circuits to operate equipment necessary to shut down and maintain the unit in MODE 3. The requirements of ITS 3.3.4 only include the instrumentation necessary to monitor the prompt shutdown to MODE 3, including the necessary instrumentation to support maintaining the unit in a safe condition in MODE 3. This change is consistent with the current licensing basis for the Remote Shutdown Instrumentation in CTS 3/4.3.3.5. As a result of this change, the Specification's title and LCO statement have been changed from "Protection System" to "Monitoring Instrumentation," and ISTS SR 3.3.4.2, which verifies control circuit and transfer switch capability, has not been included in the ITS.

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

3. ISTS SR 3.3.4.4 requires performance of a TADOT of the reactor trip breaker open/closed indication. This requirement has not been included in the CNP Unit 1 and Unit 2 ITS. CTS 3/4.3.3.5 does not contain this requirement. Thus, this deviation from the ISTS has been made to retain the current licensing basis.

OPERABILITY of the Reactor Trip Breaker Indication will be adequately verified by the performance of a CHANNEL CALIBRATION (ITS SR 3.3.4.2).

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 522 of 818

Attachment 1, Volume 8, Rev. 0, Page 523 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 534 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.4 BASES, REMOTE SHUTDOWN MONITORING INSTRUMENTATION

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

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

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

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

4. The ISTS Reviewers Notes have been deleted since they are not intended to be included in the ITS.

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

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

7. These instruments are not normally monitored during normal operations. Thus, this sentence has been deleted.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 534 of 818

Attachment 1, Volume 8, Rev. 0, Page 535 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 535 of 818

Attachment 1, Volume 8, Rev. 0, Page 536 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.4, REMOTE SHUTDOWN MONITORING 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 536 of 818

Attachment 1, Volume 8, Rev. 0, Page 537 of 818 ATTACHMENT 5 ITS 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation Attachment 1, Volume 8, Rev. 0, Page 537 of 818

, Volume 8, Rev. 0, Page 538 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 8, Rev. 0, Page 538 of 818

Attachment 1, Volume 8, Rev. 0, Page 539 of 818 ITS 3.3.5 A.1 ITS A.2 LCO 3.3.5 See ITS 3.3.2 LA.1 Add proposed ACTIONS Note A.3 ACTION A LA.1 ACTION A SR 3.3.5.1, A.4 SR 3.3.5.2, SR 3.3.5.3, SR 3.3.5.4, SR 3.3.5.5 See ITS 3.3.2 A.5 Page 1 of 10 Attachment 1, Volume 8, Rev. 0, Page 539 of 818

Attachment 1, Volume 8, Rev. 0, Page 540 of 818 ITS 3.3.5 A.1 ITS See ITS 3.3.2 LCO 3.3.5, 3 A.6 APPLICABILITY, and ACTION A when associated DG is required to 3 M.1 be OPERABLE train by LCO 3.8.2 A.7 LA.2 243 Page 2 of 10 Attachment 1, Volume 8, Rev. 0, Page 540 of 818

Attachment 1, Volume 8, Rev. 0, Page 541 of 818 ITS 3.3.5 A.1 ITS See ITS 3.3.2 L.1 ACTION A L.2 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Add proposed ACTION B L.3 Add proposed ACTION C L.4 See ITS 3.3.2 Page 3 of 10 Attachment 1, Volume 8, Rev. 0, Page 541 of 818

Attachment 1, Volume 8, Rev. 0, Page 542 of 818 ITS 3.3.5 A.1 ITS See ITS 3.3.2 SR 3.3.5.5 SR 3.3.5.3 LA.1 202 Page 4 of 10 Attachment 1, Volume 8, Rev. 0, Page 542 of 818

Attachment 1, Volume 8, Rev. 0, Page 543 of 818 ITS 3.3.5 A.1 ITS SR 3.3.5.2, SR 3.3.5.4 SR 3.3.5.3, SR 3.3.5.1 SR 3.3.5.5 A.4 See ITS 3.3.2 A.4 LCO 3.3.5 and

-5 -4 APPLICABILITY

-3 -2 184 days Add proposed Note to SR 3.3.5.2 and SR 3.3.5.4 31 days when associated DG is required M.1 to be OPERABLE by LCO 3.8.2 184 days L.5 M.2 A.8 Page 5 of 10 Attachment 1, Volume 8, Rev. 0, Page 543 of 818

Attachment 1, Volume 8, Rev. 0, Page 544 of 818 ITS 3.3.5 A.1 ITS A.2 See ITS LCO 3.3.5 3.3.2 LA.1 Add proposed ACTIONS Note A.3 ACTION A LA.1 ACTION A SR 3.3.5.1, A.4 SR 3.3.5.2, SR 3.3.5.3, SR 3.3.5.4, SR 3.3.5.5 See ITS 3.3.2 A.5 Page 6 of 10 Attachment 1, Volume 8, Rev. 0, Page 544 of 818

Attachment 1, Volume 8, Rev. 0, Page 545 of 818 ITS 3.3.5 A.1 ITS See ITS 3.3.2 A.6 3

LCO 3.3.5, when associated APPLICABILITY, DG is required to and ACTION A 3 be OPERABLE M.1 train by LCO 3.8.2 A.7 LA.2 See ITS 3.3.6 See ITS 3.3.2 See ITS 3.3.2 and ITS 3.3.6 See ITS 3.3.2 Page 7 of 10 Attachment 1, Volume 8, Rev. 0, Page 545 of 818

Attachment 1, Volume 8, Rev. 0, Page 546 of 818 ITS 3.3.5 A.1 ITS See ITS 3.3.2 L.1 L.2 ACTION A 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Add proposed ACTION B L.3 Add proposed ACTION C L.4 See ITS 3.3.2 Page 8 of 10 Attachment 1, Volume 8, Rev. 0, Page 546 of 818

Attachment 1, Volume 8, Rev. 0, Page 547 of 818 ITS 3.3.5 A.1 ITS See ITS 3.3.2 SR 3.3.5.5 LA.1 SR 3.3.5.3 Page 9 of 10 Attachment 1, Volume 8, Rev. 0, Page 547 of 818

Attachment 1, Volume 8, Rev. 0, Page 548 of 818 ITS 3.3.5 A.1 ITS A.4 SR 3.3.5.2, SR 3.3.5.4 SR 3.3.5.3, SR 3.3.5.1 SR 3.3.5.5 See ITS 3.3.2 Add proposed Note to SR 3.3.5.2 and A.8 SR 3.3.5.4 184 days 184 days LCO 3.3.5 and -5 -4 when associated DG A.4 APPLICABILITY is required to be

-2 OPERABLE by

-3 31 days LCO 3.8.2 M.1 L.5 M.2 See ITS 3.3.2 See ITS 3.3.6 See ITS 3.3.2 See ITS 3.3.2 Page 10 of 10 Attachment 1, Volume 8, Rev. 0, Page 548 of 818

Attachment 1, Volume 8, Rev. 0, Page 549 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START 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, "Engineered Safety Feature Actuation System Instrumentation,"

requires the Engineered Safety Feature Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 to be OPERABLE.

ITS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation,"

requires specific channels per bus for the Loss of Voltage and specific channels per train for the Degraded Voltage Functions to be OPERABLE. This changes the CTS by having a separate Specification for the LOP DG Start Instrumentation in lieu of including it with the ESFAS Instrumentation Specification.

This change is acceptable because the technical requirements for the LOP DG start instrumentation are maintained with the change in format. The LOP DG Start Instrumentation Specification continues to require the start of the DGs on Loss of Voltage and Degraded Voltage signals. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 3.3.2.1 Actions provide the compensatory actions to take when Loss of Power instrumentation is inoperable. ITS 3.3.5 ACTIONS provide the compensatory actions for inoperable LOP DG start instrumentation. The ITS 3.3.5 ACTIONS include a Note that allows separate Condition entry for each Function. This modifies the CTS by providing a specific allowance to enter the Action for each inoperable LOP DG Start Instrumentation Function.

This change is acceptable because it clearly states the current requirement. The CTS considers each Loss of Power Function to be separate and independent from the other. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.3.2.1.1 and CTS Table 4.3-2 require that Loss of Power Function channels be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST once per 31 days. ITS SR 3.3.5.2 and SR 3.3.5.4 require the performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) once per 31 days and 184 days, respectively. This changes the CTS by changing the CHANNEL FUNCTIONAL TEST requirements to a TADOT. The change to the Frequency for ITS SR 3.3.5.4 is discussed in DOC L.5.

This change is acceptable because the TADOT continues to perform a test similar to the current CHANNEL FUNCTIONAL TEST. The change is one of format only. In addition, the change to the CHANNEL FUNCTIONAL TEST definition is described in Discussion of Changes for ITS Chapter 1.0. This CNP Units 1 and 2 Page 1 of 8 Attachment 1, Volume 8, Rev. 0, Page 549 of 818

Attachment 1, Volume 8, Rev. 0, Page 550 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 4.3.2.1.3 requires ENGINEERED SAFETY FEATURES RESPONSE TIME testing of "each" ESFAS function. ITS 3.3.5 does not include response time testing for the LOP DG Start Instrumentation Functions. This changes the CTS by clearly identifying that the ENGINEERED SAFETY FEATURES RESPONSE TIME testing does not apply to the LOP DG Start Instrumentation Functions.

The purpose of the CTS 4.3.2.1.3 requirements is to ensure that the actuation response time is less than or equal to the maximum value 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. CTS Table 3.3-5 did not include response times for the CTS 3.3.2 Loss of Power Functions. Therefore, this change is acceptable since ENGINEERED SAFETY FEATURES RESPONSE TIME testing of the Loss of Power Functions was not required. These response times were removed from CTS 3.3.2 and placed under CNP control as documented in the NRC Safety Evaluation for License Amendments 202 (Unit 1) and 187 (Unit 2). In addition, UFSAR Table 7.2-7 currently does not require response time testing of the CTS 3.3.2 Loss of Power Functions. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS Table 3.3-3 specifies the "TOTAL NO. OF CHANNELS" as 3/Bus and the "MINIMUM CHANNELS OPERABLE" as 2/Bus for the Loss of Voltage and Degraded Voltage Functions. CTS Table 3.3-3 Action 14 specifies the actions to take with the number of Loss of Voltage or Degraded Voltage channels OPERABLE one less than required by the "TOTAL NO. OF CHANNELS" column. ITS LCO 3.3.5 requires the LOP DG Start Instrumentation Functions to be OPERABLE and specifies the required number of channels. The required number of channels specified in ITS LCO 3.3.5 is consistent with the TOTAL NO.

OF CHANNELS specified in CTS Table 3.3-3. The ITS 3.3.5 ACTIONS require entry when the OPERABLE channels are less than required by the LCO. This changes the CTS by effectively changing the "MINIMUM CHANNELS OPERABLE" column to the required number of channels in the LCO and changes the number of channels to reflect when actions must be taken when a required channel becomes inoperable.

This change is acceptable because the requirements for when actions must be taken remain unchanged. The required channels specified in ITS LCO 3.3.5 reflect the current requirements in the CTS Table 3.3-3 Actions for when actions are required to be taken. The "MINIMUM CHANNELS OPERABLE" column for CTS Table 3.3-3 Functional Units 8.a and 8.b have effectively been changed to correspond to the number of channels in the "TOTAL NO. OF CHANNELS" column as reflected in ITS LCO 3.3.5. This change is designated as administrative because it does not result in technical changes to the CTS.

A.7 CTS Table 3.3-3 requires 3 channels/bus (T11D - Train A and T11A - Train B (Unit 1) and T21D - Train A and T21A - Train B (Unit 2)) to be OPERABLE for the Degraded Voltage Function (Functional Unit 8.b). ITS LCO 3.3.5, for the Degraded Voltage Function, requires 3 channels per train to be OPERABLE.

CNP Units 1 and 2 Page 2 of 8 Attachment 1, Volume 8, Rev. 0, Page 550 of 818

Attachment 1, Volume 8, Rev. 0, Page 551 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION This changes the CTS by specifying, for the Degraded Voltage Function, the required number of channels on a "per train" basis instead of on a "per bus" basis.

This change is acceptable because the number of channels of the Degraded Voltage Function required to be OPERABLE remains unchanged. The CNP design includes two 4.16 kV emergency buses for each of two trains (Train "A" and Train "B"). Only one of these 4.16 kV emergency buses in each train has Degraded Voltage Function channels. As described for the Degraded Voltage Function in CTS Table 3.3-3, there are 3 channels per bus, on one bus in each of two trains, required to be OPERABLE (i.e., 3 channels per train as reflected in ITS LCO 3.3.5). This change is designated as administrative because it does not result in technical changes to the CTS.

A.8 CTS Table 4.3-2 requires a CHANNEL FUNCTIONAL TEST be performed for Functions 8.a (Loss of Power, 4 kv Bus Loss of Voltage) and 8.b (Loss of Power, 4 kv Bus Degraded Voltage). ITS 3.3.5 requires performance of SR 3.3.5.4 and SR 3.3.5.2 (respectively), a TADOT, for these Functions. 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.4.

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.

MORE RESTRICTIVE CHANGES M.1 CTS Tables 3.3-3 and 4.3-2 requirements for the Loss of Voltage Function are applicable in MODES 1, 2, 3, and 4. ITS 3.3.5 requires the Loss of Voltage Function to be OPERABLE in MODES 1, 2, 3, and 4 and when the associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown." This changes the CTS by expanding the conditions under which the Loss of Voltage Function must be OPERABLE.

This change is acceptable because requiring the Loss of Voltage Function to be OPERABLE when LCO 3.8.2 requires a DG to be OPERABLE ensures that the automatic loss of power start of the DG is available when needed. This change is designated as more restrictive because the ITS expands MODES in which equipment is required to be OPERABLE.

M.2 CTS Table 4.3-2 requires a CHANNEL CALIBRATION of the Loss of Voltage and Degraded Voltage instrumentation every 18 months, however the Surveillances are currently being performed more frequently. ITS SR 3.3.5.3 requires the performance of a CHANNEL CALIBRATION for the Degraded Voltage Function CNP Units 1 and 2 Page 3 of 8 Attachment 1, Volume 8, Rev. 0, Page 551 of 818

Attachment 1, Volume 8, Rev. 0, Page 552 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION every 31 days and ITS SR 3.3.5.5 requires the performance of a CHANNEL CALIBRATION for the Loss of Voltage Function every 184 days. This changes the CTS by changing the Frequency of the Surveillance from 18 months to either 31 days or 184 days.

The purpose of CTS Table 4.3-2 is to ensure LOP DG start instrumentation will function as designed during an analyzed event. Changing the SR Frequency is acceptable because a 31 day and 184 day calibration interval (as applicable) 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.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.3.2.1 requires the ESFAS instrumentation and interlocks 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 Functions. ITS 3.3.5 requires the LOP DG Start Instrumentation Functions to be OPERABLE. ITS SR 3.3.5.3 and SR 3.3.5.5 specify the Allowable Values for the LOP DG Start 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 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 LOP DG Start 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 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 the Loss of Voltage and Degraded Voltage Functions. These columns are labeled, "TOTAL NO. OF CHANNELS,"

"CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." In addition, CTS Table 3.3-3 also specifies the tag numbers of the emergency buses in each CNP Units 1 and 2 Page 4 of 8 Attachment 1, Volume 8, Rev. 0, Page 552 of 818

Attachment 1, Volume 8, Rev. 0, Page 553 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION train that include the Degraded Voltage Function instrumentation. ITS LCO 3.3.5 does not retain the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns and does not include the tag numbers of the emergency buses that include the Degraded Voltage Function instrumentation. This changes the CTS by moving the information of the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns and emergency bus tag numbers 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.

LESS RESTRICTIVE CHANGES L.1 (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, "operation may proceed until performance of the next required CHANNEL FUNCTIONAL TEST." This CTS Action applies to the Loss of Voltage and Degraded Voltage Functions of CTS Table 3.3-3. ITS 3.3.5 ACTION A is the applicable action for the Loss of Voltage and Degraded Voltage 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 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 3.3.5 ACTION A 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 CNP Units 1 and 2 Page 5 of 8 Attachment 1, Volume 8, Rev. 0, Page 553 of 818

Attachment 1, Volume 8, Rev. 0, Page 554 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION 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.2 (Category 3 - Relaxation of Completion Time) CTS Table 3.3-3 Action 14 requires, with the number of OPERABLE channels one less than the total number of channels, that the inoperable channel be placed in trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This CTS Action applies to the Loss of Voltage and Degraded Voltage Functions of CTS Table 3.3-3. ITS 3.3.5 ACTION A allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the channel in trip when one Loss of Voltage or Degraded Voltage channel is inoperable. This changes the CTS by extending the time for placing a channel in trip, when a Loss of Voltage Function of Degraded Voltage channel is inoperable, 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 .

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. This change is acceptable because the Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant instrumentation channels. This includes the capacity and capability of remaining channels, a reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the repair period. The ITS Action will allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to trip the channel when one channel is inoperable. This is a reasonable period of time because of the low probability of an event occurring that would require a LOP DG start, and because of the LOP start actuation capability provided by the remaining OPERABLE channels of the associated 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.3 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 14 provides requirements for when one Loss of Voltage or Degraded Voltage channel per bus is inoperable. With more than one channel per bus of these channels inoperable, the shutdown requirements of CTS 3.0.3 would apply since the applicable CTS Table 3.3-3 Actions do not address this condition. ITS 3.3.5 ACTION B requires, with one or more Functions with two or more channels per bus or train inoperable, restoration of all but one channel per bus or train to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This changes the CTS to allow more than one channel per bus or train of the Loss of Voltage and Degraded Voltage Functions to be inoperable. The change to the presentation of the required number of channels (i.e., on a "per train" basis instead of a "per bus" basis for the Degraded Voltage Function) is addressed in DOC A.7.

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. This change is acceptable because the Required Actions are consistent with safe operation under the specified Condition, considering a reasonable time for repairs or replacement of most failures and the low probability of a DBA occurring during the repair period. The ITS ACTION will allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore all but one CNP Units 1 and 2 Page 6 of 8 Attachment 1, Volume 8, Rev. 0, Page 554 of 818

Attachment 1, Volume 8, Rev. 0, Page 555 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION channel per bus or train to OPERABLE status. This is a reasonable period of time because of the low probability of an event occurring that would require a LOP DG start. In addition, the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time is consistent with the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time to initiate a unit shutdown provided in CTS 3.0.3. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.4 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 14 requires, with the number of OPERABLE channels one less than the total number of channels, that the inoperable channel be placed in trip within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

If this action is not accomplished, the shutdown requirements of CTS 3.0.3 would apply. ITS 3.3.5 ACTION C requires, when the Required Action and associated Completion Time are not met, that the applicable Condition(s) and Required Action(s) for the associated DG made inoperable by LOP DG start instrumentation be immediately entered. This changes the CTS by allowing the associated DG to be declared inoperable instead of entering CTS 3.0.3 and shutting down the unit.

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. This change is acceptable because 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 instrumentation provides a start signal for the DGs (i.e., it supports DG OPERABILITY) and the appropriate action in this condition is to declare the DG inoperable. The current requirements are overly restrictive. For example, if a DG were inoperable for other reasons, then a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed outage time is provided. However, if an instrument is inoperable but the DG is otherwise fully OPERABLE, then an immediate shutdown is required. 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 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 Loss of Voltage instrumentation every 31 days. ITS SR 3.3.5.4 requires the performance of a TADOT for the Loss of Voltage Function 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.4.

The purpose of the CHANNEL FUNCTIONAL TEST requirement in CTS Table 4.3-2 is to ensure the channels of the Loss of Voltage Function will function as designed during an analyzed event (i.e., a total loss of offsite power). An evaluation of the surveillance interval extension was performed, based on the same approach described in NRC Generic Letter No. 91-04, "Changes in CNP Units 1 and 2 Page 7 of 8 Attachment 1, Volume 8, Rev. 0, Page 555 of 818

Attachment 1, Volume 8, Rev. 0, Page 556 of 818 DISCUSSION OF CHANGES ITS 3.3.5, LOP DG START INSTRUMENTATION 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 TADOT is acceptable because the reliability and conservative settings of the plant protective equipment, combined with the low probability of a total loss of offsite power, provide a high confidence in proper system operation. 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.

ITS than were applied in the CTS.

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Attachment 1, Volume 8, Rev. 0, Page 560 of 818 CTS 3.3.5 6 4 INSERT 1 4.3.2.1.1, Table SR 3.3.5.2 ----------------------------------------------------------------------------

4.3-2 Functional -NOTE-Unit 8.b Verification of setpoint not required.

Perform TADOT for the Degraded Voltage Function. 31 days 4.3.2.1.1, Tables SR 3.3.5.3 Perform CHANNEL CALIBRATION for the Degraded 31 days 3.3-4 and 4.3-2 Voltage Function. The Allowable Value shall be > 3910 V Functional Unit 8.b and < 4000 V with a time delay of 9 + 0.25 seconds when a Steam Generator Water Level - Low Low signal or Safety Injection signal is present.

6 INSERT 2

-NOTE-Verification of setpoint not required.

4 INSERT 3 4.3.2.1.1, Tables SR 3.3.5.5 Perform CHANNEL CALIBRATION for the Loss of 184 days 3.3-4 and 4.3-2 Voltage Function. The Allowable Value shall be > 3245 V Functional Unit 8.a and < 3328 V with a time delay of 2 + 0.2 seconds (Unit 1) and > 3195 V and < 3280 V with a time delay of 2 + 0.2 seconds (Unit 2).

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Attachment 1, Volume 8, Rev. 0, Page 561 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.5, LOP DG START INSTRUMENTATION

1. Grammatical/editorial change made for consistency.

2. ISTS LCO 3.3.5 requires [three] channels per bus of the loss of voltage Function and

[three] channels per bus of the degraded voltage Function to be OPERABLE. ISTS LCO 3.3.5 is revised in ITS LCO 3.3.5 to reflect the design of the CNP Units 1 and 2 Degraded Voltage Function. The CNP Units 1 and 2 design includes two 4.16 kV emergency buses for each of two trains (Train "A" and Train "B"). Only one of these 4.16 kV emergency buses in each train has Degraded Voltage Function channels.

Therefore, ITS LCO 3.3.5 requires three channels per bus of the Loss of Voltage Function and three channels per train of the Degraded Voltage Function to be OPERABLE. Commensurate changes to ISTS 3.3.5 ACTIONS A and B to address the "per train" design of the Degraded Voltage Function are made by adding the phrase "or train" to the references to "channels per bus."

3. ISTS 3.3.5 Required Action A.1 is modified by a Note that allows an inoperable channel to be bypassed 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.

The ISTS 3.3.5 Bases states the Note is provided where bypassing the channel does not cause an actuation and where two other channels are monitoring the parameter.

For the CNP Units 1 and 2, the design of each of the LOP DG Start Instrumentation Functions includes 3 channels per bus or train monitoring the parameters. As such, when one channel of a Function on a bus or train is inoperable and another channel of the same Function on the same bus or train is made inoperable for Surveillance testing, only one channel of the Function on that bus or train is available for monitoring the parameter. Therefore, the ISTS 3.3.5 Required Action A.1 Note is not included in the CNP Units 1 and 2 ITS 3.3.5.

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

5. The second part of the ISTS LCO 3.3.5 Applicability has been modified so that it only applies to the Loss of Voltage Function. The Degraded Voltage Function is only required to be OPERABLE during MODES 1, 2, 3, and 4. This proposed Applicability for the Degraded Voltage Function is consistent with the current licensing basis.

6. A Note has been added consistent with the Note in ITS SR 3.3.2.6, which performs a TADOT on the actual or similar instruments. This is also consistent with the current licensing basis.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 561 of 818

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Attachment 1, Volume 8, Rev. 0, Page 564 of 818 B 3.3.5 1

INSERT 1 (i.e., the required number of channels required to trip to generate an LOP signal is 2 per bus) 1 INSERT 2 Undervoltage relays and time delays are also provided for detecting a sustained degraded voltage condition. Three undervoltage relays with time delays are provided for one Train "A" 4.16 kV emergency bus (T11D (Unit 1) and T21D (Unit 2)). Three undervoltage relays with time delays are provided for one Train "B" 4.16 kV emergency bus (T11A (Unit 1) and T21A (Unit 2)). The relays are combined in a two-out-of-three logic to generate an LOP signal (i.e., the required number of channels required to trip to generate an LOP signal is 2 per train) if the voltage is below approximately 93% for a specified delay time. If an accident signal (i.e., Steam Generator Water Level - Low Low signal or a Safety Injection signal) is present coincident with a degraded voltage condition, the delay time is approximately 9 seconds. If no accident signal is present coincident with a degraded voltage condition, the delay time is approximately 2 minutes.

The LOP start actuation for the Degraded Voltage Function is discussed in UFSAR, Section 8.5 (Ref. 2).

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INSERT 2A or other specified conditions other than MODES 1, 2, 3, and 4 Insert Page B 3.3.5-3 Attachment 1, Volume 8, Rev. 0, Page 567 of 818

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INSERT 3 maintains LOP start actuation capability on each associated 4.16 kV emergency bus.

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Attachment 1, Volume 8, Rev. 0, Page 571 of 818 B 3.3.5 3 INSERT 3A The SRs are modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION.

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4. EG-IC-004, "Instrument Setpoint Uncertainty," Revision 4.

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Attachment 1, Volume 8, Rev. 0, Page 574 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.5 BASES, LOP DG START 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. The ISTS Reviewers Note has been deleted since it is not intended to be included in the ITS.

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

4. Grammatical/editorial change made for consistency.

5. Changes are made to reflect the Specification.

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

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Attachment 1, Volume 8, Rev. 0, Page 575 of 818 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 8, Rev. 0, Page 576 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.5, LOP DG START INSTRUMENTATION There are no specific NSHC discussions for this Specification.

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Attachment 1, Volume 8, Rev. 0, Page 577 of 818 ATTACHMENT 6 ITS 3.3.6, Containment Purge Supply and Exhaust System Isolation Instrumentation Attachment 1, Volume 8, Rev. 0, Page 577 of 818

, Volume 8, Rev. 0, Page 578 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 8, Rev. 0, Page 578 of 818

Attachment 1, Volume 8, Rev. 0, Page 579 of 818 A.1 ITS 3.3.6 ITS A.2 LCO 3.3.6 See ITS 3.3.2 LA.3 Add proposed ACTIONS Note A.3 ACTIONS B and C LA.3 ACTIONS B and C SR Table COT A.4 Note See ITS 3.3.2 A.5 Page 1 of 29 Attachment 1, Volume 8, Rev. 0, Page 579 of 818

Attachment 1, Volume 8, Rev. 0, Page 580 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.1 REQUIRED A.6 See ITS 3.3.2 Function 1 Function 3 C Function 3 C A.6 2 per train LA.1 L.4 M.2 Add proposed Function 2 Add proposed Function 4 M.3 M.1 Page 2 of 29 Attachment 1, Volume 8, Rev. 0, Page 580 of 818

Attachment 1, Volume 8, Rev. 0, Page 581 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.1 REQUIRED A.6 See ITS Function 4 3.3.2 B

Function 1 1 per train L.10 B

LA.1 Function 1 LA.2 See ITS 3.3.2 Page 3 of 29 Attachment 1, Volume 8, Rev. 0, Page 581 of 818

Attachment 1, Volume 8, Rev. 0, Page 582 of 818 A.1 ITS 3.3.6 ITS two or more L.1 Add proposed ACTION A ACTION C ACTION B L.3 ACTION C See ITS 3.3.2 Page 4 of 29 Attachment 1, Volume 8, Rev. 0, Page 582 of 818

Attachment 1, Volume 8, Rev. 0, Page 583 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.3 See ITS 3.3.2 Function 1 Page 5 of 29 Attachment 1, Volume 8, Rev. 0, Page 583 of 818

Attachment 1, Volume 8, Rev. 0, Page 584 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.3 A.7 Function 3 Function 3 A.7 L.4 See ITS 3.3.2 Page 6 of 29 Attachment 1, Volume 8, Rev. 0, Page 584 of 818

Attachment 1, Volume 8, Rev. 0, Page 585 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.3 See ITS 3.3.2 Function 4 LA.3 See ITS 3.3.2 LA.3 Function 1 Function 1 LA.2 See ITS 3.3.2 Page 7 of 29 Attachment 1, Volume 8, Rev. 0, Page 585 of 818

Attachment 1, Volume 8, Rev. 0, Page 586 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 COT A.4 SR 3.3.6.1 SR 3.3.6.8 SR 3.3.6.6 See ITS 3.3.2 M.1 Function 1 Function 3 -1 -8 -6 L.9 184 days 24 months L.5 Add proposed SRs 3.3.6.2, 3.3.6.3, and 3.3.6.4 for Function 2 M.2 Add proposed SR 3.3.6.5 for Function 4 M.3 Page 8 of 29 Attachment 1, Volume 8, Rev. 0, Page 586 of 818

Attachment 1, Volume 8, Rev. 0, Page 587 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 SR 3.3.6.7 See ITS 3.3.2 Function 4

-7 Function 1 24 months L.6

-7 Function 1 LA.2 See ITS 3.3.2 Page 9 of 29 Attachment 1, Volume 8, Rev. 0, Page 587 of 818

Attachment 1, Volume 8, Rev. 0, Page 588 of 818 A.1 ITS 3.3.6 ITS A.2 LCO 3.3.6 LA.3 A.3 Add proposed ACTIONS Note inoperable, restore the channel L.1 ACTION A ACTION C A.8 SR Table Note COT A.4 Page 10 of 29 Attachment 1, Volume 8, Rev. 0, Page 588 of 818

Attachment 1, Volume 8, Rev. 0, Page 589 of 818 A.1 ITS 3.3.6 ITS See ITS Table 3.3.6-1 3.3.3 ALLOWABLE VALUE A.7 M.1 See CTS Function 3.c 3/4.3.3.1 L.4 See ITS 3.3.3 M.1 Function 3.b See ITS 3.4.15 Function 3.a L.4 See CTS 3/4.3.3.1 Page 11 of 29 Attachment 1, Volume 8, Rev. 0, Page 589 of 818

Attachment 1, Volume 8, Rev. 0, Page 590 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 L.7 ALLOWABLE VALUE A.7 During movement of irradiated fuel Footnote (a) assemblies within containment See CTS 3/4.3.3.1 C

Function 3.c Footnote (b)

Function 3.b Function 3.a C

Function 3.c Footnote (b)

Function 3.b Function 3.a L.7 L.4 See CTS 3/4.3.3.1 L.7 See CTS 3/4.3.3.1 Page 12 of 29 Attachment 1, Volume 8, Rev. 0, Page 590 of 818

Attachment 1, Volume 8, Rev. 0, Page 591 of 818 A.1 ITS 3.3.6 ITS See ITS 3.4.15 See CTS 3/4.3.3.1 two or more L.1 ACTION C M.4 See ITS 3.3.3 See ITS 5.6 See ITS 3.3.3 See CTS 3/4.3.3.1 Page 13 of 29 Attachment 1, Volume 8, Rev. 0, Page 591 of 818

Attachment 1, Volume 8, Rev. 0, Page 592 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 A.4 SR 3.3.6.6 COT SR 3.3.6.1 SR 3.3.6.8 L.11 L.5 184 days 24 months Footnote (a)

L.9 Function 3.c 1- 8- 6-During movement of irradiated 1- 8- 6- fuel assemblies within L.7 Function 3.b containment Function 3.a 1- 8- 6-Footnote (a) 1- 8- 6-Function 3.c Function 3.b 1- 8- 6-Function 3.a 1- 8- 6-L.4 See CTS 3/4.3.3.1 L.11 See CTS 3/4.3.3.1 Page 14 of 29 Attachment 1, Volume 8, Rev. 0, Page 592 of 818

Attachment 1, Volume 8, Rev. 0, Page 593 of 818 A.1 ITS 3.3.6 ITS A.2 instrumentation LCO 3.3.6 L.2 Table 3.3.6-1 Footnote (a)

ACTION C A.8 184 days for (containment radiation monitors) L.9 24 months (for manual initiation) L.6 L.2 SR 3.3.6.6, L.8 SR 3.3.6.7 See ITS 3.9.3 Page 15 of 29 Attachment 1, Volume 8, Rev. 0, Page 593 of 818

Attachment 1, Volume 8, Rev. 0, Page 594 of 818 A.1 ITS 3.3.6 ITS A.2 LCO 3.3.6 See ITS 3.3.2 LA.3 Add proposed ACTIONS Note A.3 ACTIONS B and C LA.3 ACTIONS B and C SR Table Note COT A.4 See ITS 3.3.2 A.5 Page 16 of 29 Attachment 1, Volume 8, Rev. 0, Page 594 of 818

Attachment 1, Volume 8, Rev. 0, Page 595 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.1 REQUIRED A.6 See ITS 3.3.2 Function 1 Function 3 C Function 3 C 2 per train A.6 LA.1 L.4 Add proposed Function 2 M.2 Add proposed Function 4 M.3 M.1 Page 17 of 29 Attachment 1, Volume 8, Rev. 0, Page 595 of 818

Attachment 1, Volume 8, Rev. 0, Page 596 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.1 REQUIRED A.6 See ITS 3.3.2 See ITS 3.3.5 See ITS 3.3.2 Function 4 B

1 per train L.10 Function 1 B LA.1 Function 1 LA.2 See ITS 3.3.2 Page 18 of 29 Attachment 1, Volume 8, Rev. 0, Page 596 of 818

Attachment 1, Volume 8, Rev. 0, Page 597 of 818 A.1 ITS 3.3.6 ITS two or more L.1 Add proposed ACTION A ACTION C ACTION B L.3 ACTION C See ITS 3.3.2 Page 19 of 29 Attachment 1, Volume 8, Rev. 0, Page 597 of 818

Attachment 1, Volume 8, Rev. 0, Page 598 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.3 A.7 See ITS 3.3.2 Function 1 Function 3 Function 3 A.7 L.4 Page 20 of 29 Attachment 1, Volume 8, Rev. 0, Page 598 of 818

Attachment 1, Volume 8, Rev. 0, Page 599 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 LA.3 See ITS 3.3.2 Function 4 LA.3 See ITS 3.3.2 LA.3 Function 1 Function 1 LA.2 See ITS 3.3.2 Page 21 of 29 Attachment 1, Volume 8, Rev. 0, Page 599 of 818

Attachment 1, Volume 8, Rev. 0, Page 600 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 COT A.4 SR 3.3.6.1 SR 3.3.6.8 SR 3.3.6.6 L.9 184 days M.1 Function 1 Function 3 -1 8- 6-24 months L.5 See ITS 3.3.2 Add proposed SRs 3.3.6.2, 3.3.6.3, and 3.3.6.4 for Function 2 M.2 Add proposed SR 3.3.6.5 for Function 4 M.3 Page 22 of 29 Attachment 1, Volume 8, Rev. 0, Page 600 of 818

Attachment 1, Volume 8, Rev. 0, Page 601 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 SR 3.3.6.7 See ITS 3.3.2 See ITS 3.3.5 See ITS 3.3.2 Function 4

-7 24 months L.6 Function 1

-7 LA.2 Function 1 See ITS 3.3.2 Page 23 of 29 Attachment 1, Volume 8, Rev. 0, Page 601 of 818

Attachment 1, Volume 8, Rev. 0, Page 602 of 818 A.1 ITS 3.3.6 ITS A.2 LCO 3.3.6 LA.3 A.3 Add proposed ACTIONS Note inoperable, restore the channel ACTION A L.1 ACTION C A.8 SR Table Note COT A.4 Page 24 of 29 Attachment 1, Volume 8, Rev. 0, Page 602 of 818

Attachment 1, Volume 8, Rev. 0, Page 603 of 818 A.1 ITS 3.3.6 ITS See ITS Table 3.3.6-1 3.3.3 ALLOWABLE VALUE A.7 M.1 See CTS 3/4.3.3.1 Function 3.c L.4 See ITS 3.3.3 M.1 Function 3.b See ITS 3.4.15 Function 3.a L.4 See CTS 3/4.3.3.1 Page 25 of 29 Attachment 1, Volume 8, Rev. 0, Page 603 of 818

Attachment 1, Volume 8, Rev. 0, Page 604 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 L.7 ALLOWABLE VALUE A.7 During movement of irradiated fuel Footnote (a) assemblies within containment See CTS 3/4.3.3.1 C

Function 3.c Footnote (b)

Function 3.b Function 3.a C

Function 3.c Footnote (b)

Function 3.b Function 3.a L.7 L.4 See CTS 3/4.3.3.1 See CTS 3/4.3.3.1 L.7 Page 26 of 29 Attachment 1, Volume 8, Rev. 0, Page 604 of 818

Attachment 1, Volume 8, Rev. 0, Page 605 of 818 A.1 ITS 3.3.6 ITS See ITS 3.4.15 See CTS 3/4.3.3.1 two or more L.1 ACTION C M.4 See ITS 3.3.3 See ITS 5.6 See ITS 3.3.3 See CTS 3/4.3.3.1 Page 27 of 29 Attachment 1, Volume 8, Rev. 0, Page 605 of 818

Attachment 1, Volume 8, Rev. 0, Page 606 of 818 A.1 ITS 3.3.6 ITS Table 3.3.6-1 A.4 SR 3.3.6.6 COT SR 3.3.6.1 SR 3.3.6.8 L.11 184 days L.5 24 months Footnote (a)

L.9 Function 3.c 1- 8- 6-During movement of irradiated fuel L.7 Function 3.b 1- 8- 6-assemblies within containment Function 3.a 1- 8- 6-Footnote (a)

Function 3.c 1- 8- 6-Function 3.b 1- 8- 6-Function 3.a 1- 8- 6-L.4 See CTS 3/4.3.3.1 L.11 See CTS 3/4.3.3.1 Page 28 of 29 Attachment 1, Volume 8, Rev. 0, Page 606 of 818

Attachment 1, Volume 8, Rev. 0, Page 607 of 818 A.1 ITS 3.3.6 ITS A.2 instrumentation LCO 3.3.6 L.2 Table 3.3.6-1 Footnote (a)

ACTION C A.8 L.9 184 days for containment radiation monitors 24 months for manual initiation L.6 SR 3.3.6.6, SR 3.3.6.7 L.2 L.8 See ITS 3.9.3 Page 29 of 29 Attachment 1, Volume 8, Rev. 0, Page 607 of 818

Attachment 1, Volume 8, Rev. 0, Page 608 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION 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, "Engineered Safety Feature Actuation System Instrumentation,"

requires the Engineered Safety Feature Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 to be OPERABLE.

CTS 3.3.3.1, "Radiation Monitoring Instrumentation," requires the radiation monitoring instrumentation channels shown in Table 3.3-6 to be OPERABLE.

CTS 3.9.9 requires the Containment Purge and Exhaust Isolation System to be OPERABLE. ITS 3.3.6, "Containment Purge Supply and Exhaust System Isolation Instrumentation," requires specific channels for the Manual Initiation, Containment Radiation, and Safety Injection Functions to be OPERABLE. This changes the CTS by having a separate Specification for the Containment Purge Supply and Exhaust System isolation instrumentation in lieu of including it with the ESFAS Instrumentation Specification.

This change is acceptable because the technical requirements for the Containment Purge Supply and Exhaust System isolation instrumentation are maintained with the change in format. The Containment Purge Supply and Exhaust System Isolation Instrumentation Specification continues to require the isolation of the Containment Purge Supply and Exhaust System on Manual Initiation, Containment Radiation, and Safety Injection Input from ESFAS signals.

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

A.3 CTS 3.3.2.1 Actions and CTS 3.3.3.1 Actions provide the compensatory actions to take when Containment Purge Supply and Exhaust System isolation instrumentation is inoperable. ITS 3.3.6 ACTIONS provide the compensatory actions for inoperable Containment Purge Supply and Exhaust System isolation instrumentation. The ITS 3.3.6 ACTIONS include a Note that allows separate Condition entry for each Function. This modifies the CTS by providing a specific allowance to enter the Action for each inoperable Containment Purge Supply and Exhaust System Isolation Instrumentation Function.

This change is acceptable because it clearly states the current requirement. The CTS considers each Containment Purge Supply and Exhaust System Isolation Instrumentation Function to be separate and independent from the other. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.3.2.1.1, Table 4.3-2, 4.3.3.1, and Table 4.3-3 require that Containment Radiation Function channels be demonstrated OPERABLE by performance of a CNP Units 1 and 2 Page 1 of 15 Attachment 1, Volume 8, Rev. 0, Page 608 of 818

Attachment 1, Volume 8, Rev. 0, Page 609 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION CHANNEL FUNCTIONAL TEST once per 92 days. ITS SR 3.3.6.6 requires the performance of a CHANNEL OPERATIONAL TEST (COT) of the Containment Radiation Function channels once per 184 days. This changes the CTS by changing the CHANNEL FUNCTIONAL TEST requirements to a COT. The change to the Frequency is discussed in DOC L.9.

This change is acceptable because the COT continues to perform a test similar to the current CHANNEL FUNCTIONAL TEST. The change is one of format only. In addition, the change to the CHANNEL FUNCTIONAL TEST definition is described in 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.5 CTS 4.3.2.1.3 requires ENGINEERED SAFETY FEATURES RESPONSE TIME testing of "each" ESFAS function. ITS 3.3.6 does not include response time testing for the Containment Purge Supply and Exhaust System Isolation Instrumentation Functions. This changes the CTS by clearly identifying that the ENGINEERED SAFETY FEATURES RESPONSE TIME testing does not apply to the Containment Purge Supply and Exhaust System Isolation Instrumentation Functions.

The purpose of the CTS 4.3.2.1.3 requirements 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. CTS Table 3.3-5 did not include response times for the CTS 3.3.2 Purge and Exhaust Isolation Functions. Therefore, this change is acceptable since ENGINEERED SAFETY FEATURES RESPONSE TIME testing of the Purge and Exhaust Isolation Functions was not required. These response times were removed from CTS 3.3.2 and placed under CNP control as documented in the NRC Safety Evaluation for License Amendments 202 (Unit 1) and 187 (Unit 2). In addition, UFSAR Table 7.2-7 currently does not require response time testing of the CTS 3.3.2 Purge and Exhaust Isolation Functions.

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

A.6 CTS Table 3.3-3 requires two channels to be OPERABLE for Functional Unit 3.c.2) (Containment Radioactivity - High Train A) and two channels to be OPERABLE for Functional Unit 3.c.3) (Containment Radioactivity - High Train B).

ITS Table 3.3.6-1 requires two channels per train of the Containment Radiation Function (Function 3) to be OPERABLE. This changes the CTS by combining the requirements for Containment Radioactivity - High Train A and Train B Functional Units into one Containment Radiation Function and designating the channel requirements on a "per train" basis and by changing the title of the "MINIMUM CHANNELS OPERABLE" column to "REQUIRED CHANNELS."

This change is acceptable because the channel requirements for the Containment Radiation Function remains unchanged. The "REQUIRED CHANNELS" specified for ITS Table 3.3.6-1 Function 3 (two per train for a total of four channels) reflect the current requirements for CTS Table 3.3-3 Functional Units 3.c.2) and 3.c.3) (two channels in each of two trains for a total of four CNP Units 1 and 2 Page 2 of 15 Attachment 1, Volume 8, Rev. 0, Page 609 of 818

Attachment 1, Volume 8, Rev. 0, Page 610 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION channels). The "MINIMUM CHANNELS OPERABLE" column for CTS Table 3.3-3 Functional Units 3.c.2) and 3.c.3), which are presented for each train, have been changed to correspond to the number of channels on a "per train" basis as reflected in ITS Table 3.3.6-1 Function 3. This change is designated as administrative because it does not result in technical changes to the CTS.

A.7 CTS 3.3.2.1 Action a requires action to be taken if the channel's trip setpoint is less conservative than the value shown in the Allowable Value column of Table 3.3-4. However, no Allowable Value is provided for Functional Units 3.c.2 and 3.c.3 (the Containment Radioactivity - High monitors); only a Trip Setpoint is provided. CTS 3.3.3.1 requires the radiation monitoring instrumentation channels shown in Table 3.3-6 to be OPERABLE with their alarm/trip setpoints within specified limits. CTS 3.3.3.1 Action a requires the channel to be declared inoperable when the setpoint exceeds the Trip Setpoint value shown in CTS Table 3.3-6 and not restored to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS Table 3.3.6-1 specifies this value as an "Allowable Value" consistent with other ISTS Section 3.3 Tables. This changes the CTS by specifying an Allowable Value in ITS Table 3.3.6-1 instead of a "Trip Setpoint."

This change is acceptable because, in accordance with current plant procedures and practices, the Trip Setpoints specified in CTS Table 3.3-6 are applied as the OPERABILITY limits for the associated instruments. Therefore, the use of the term "Trip Setpoint" in the CTS is the same as the use of the term "Allowable Value" in the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.8 CTS 3.3.3.1 Action c applies, in part, to the MODE 6 requirements for CTS Table 3.3-6 Functional Units 2.A (Train A Containment Area Radiation, Particulate, and Noble Gas Channels) and 2.B (Train B Containment Area Radiation, Particulate, and Noble Gas Channels), and states that the provisions of Specifications 3.0.3 and 3.0.4 are not applicable. The CTS 3.9.9 Action, which applies when the above channels are inoperable, also states that the provisions of Specification 3.0.3 are not applicable. ITS 3.3.6 does not contain equivalent statements. This changes the CTS by deleting the Specifications 3.0.3 and 3.0.4 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 and LCO 3.0.4 are not applicable in MODE 6.

Therefore, the LCO 3.0.3 and LCO 3.0.4 exception are not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 The Applicability for CTS Table 3.3-3 Functional Units 3.c.2) (Containment Radioactivity - High Train A) and 3.c.3) (Containment Radioactivity - High Train B) is MODES 1, 2, 3, and 4. This requirement is modified by Note

that states that the Specification only applies during PURGE. ITS 3.3.6 requires the Containment Radiation Function of the Containment Purge Supply and Exhaust CNP Units 1 and 2 Page 3 of 15 Attachment 1, Volume 8, Rev. 0, Page 610 of 818

Attachment 1, Volume 8, Rev. 0, Page 611 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION System isolation instrumentation to be OPERABLE in MODES 1, 2, 3, and 4 when any Containment Purge Supply and Exhaust System isolation valve is open. This changes the CTS by requiring the Containment Radiation Function of the Containment Purge Supply and Exhaust System isolation instrumentation to be OPERABLE in MODES 1, 2, 3, and 4 when any Containment Purge Supply and Exhaust System isolation valve is open, in lieu of just when PURGING. In addition, the Applicability for CTS Table 4.3-2 Functional Unit 3.c.2)

(Containment Radioactivity - High) Surveillance Requirements is MODES 1, 2, 3, and 4, and the CTS footnote concerning PURGING is not included. This change also administratively corrects the Applicability of the CTS Surveillances to match the actual Specification Applicability.

This change is acceptable because requiring the Containment Radiation Function of the Containment Purge Supply and Exhaust System isolation instrumentation to be OPERABLE during MODES 1, 2, 3, and 4 when any Containment Purge Supply and Exhaust System isolation valve is open ensures that automatic isolation of the containment purge supply and exhaust isolation valves is available when needed (i.e., whenever the containment purge supply and exhaust valves are open, not just during purging operations). This change is designated as more restrictive because the ITS expands the MODES and other specified conditions in which equipment is required to be OPERABLE.

M.2 CTS Table 3.3-3 Functional Unit 3.c provides requirements for Purge and Exhaust Isolation Functions, but does not explicitly provide requirements for the Automatic Actuation Logic and Actuation Relays Function that results in closure of the containment purge supply and exhaust isolation valves. ITS 3.3.6, "Containment Purge Supply and Exhaust System Isolation Instrumentation,"

provides requirements for the Automatic Actuation Logic and Actuation Relays Function (Function 2) to be OPERABLE and provides Surveillance Requirements (ITS SR 3.3.6.2, SR 3.3.6.3, and SR 3.3.6.4) to ensure the proper functioning of the associated actuation logic and relays. This changes the CTS by explicitly requiring the Automatic Actuation Logic and Actuation Relays Function for the Containment Purge Supply and Exhaust System isolation instrumentation to be OPERABLE.

This change is acceptable because the Automatic Actuation Logic and Actuation Relays Function is required to support the OPERABILITY of the containment purge supply and exhaust isolation valves. 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 Containment Purge Supply and Exhaust System isolation instrumentation will be maintained. The change provides explicit requirements for the Automatic Actuation Logic and Actuation Relays Function (ITS Table 3.3.6-1 Function 2) to be OPERABLE. The addition of SR 3.3.6.2 (an ACTUATION LOGIC TEST), SR 3.3.6.3 (a MASTER RELAY TEST), and SR 3.3.6.4 (a SLAVE RELAY TEST) is acceptable since currently the requirements of these tests are satisfied during the 92 day performance of the CHANNEL FUNCTIONAL TEST for the containment radiation monitoring channels. The requirements for the Containment Purge Supply and Exhaust System isolation instrumentation continue to require the isolation of the CNP Units 1 and 2 Page 4 of 15 Attachment 1, Volume 8, Rev. 0, Page 611 of 818

Attachment 1, Volume 8, Rev. 0, Page 612 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION Containment Purge Supply and Exhaust System on Manual Initiation, Containment Radiation, and Safety Injection Input from ESFAS signals. This change is designated as more restrictive because it adds explicit OPERABILITY requirements and SRs for the Automatic Actuation Logic and Actuation Relays Function to the CTS.

M.3 CTS Table 3.3-3 Functional Unit 3.c provides requirements for Purge and Exhaust Isolation Functions, but does not explicitly provide requirements for the Safety Injection signal that results in closure of the containment purge supply and exhaust isolation valves, with the exception of the manual Safety Injection signal.

ITS 3.3.6, "Containment Purge Supply and Exhaust System Isolation Instrumentation," provides requirements for the Safety Injection Input from ESFAS Function (Function 4) to be OPERABLE and provides a Surveillance Requirement (ITS SR 3.3.6.5) to ensure the proper functioning of the Safety Injection Input from ESFAS Function. This changes the CTS by explicitly requiring the Safety Injection from ESFAS Function for the Containment Purge Supply and Exhaust System isolation instrumentation and by adding the requirement to periodically perform a TADOT.

This change is acceptable because the Safety Injection Input from ESFAS Function is required to support the OPERABILITY of the containment purge supply and exhaust isolation valves. As such, explicitly including requirements for the Safety Injection Input from ESFAS Function in the Technical Specifications provides additional assurance that the OPERABILITY of the Containment Purge Supply and Exhaust System isolation instrumentation will be maintained. The addition of SR 3.3.6.5 (a TADOT) is acceptable since is consistent with current practice and the CTS requirements for other instrumentation that receive input for safety injection. The requirements for the Containment Purge Supply and Exhaust System isolation instrumentation continue to require the isolation of the Containment Purge Supply and Exhaust System on Manual Initiation, Containment Radiation, and Safety Injection Input from ESFAS signals. This change is designated as more restrictive because it adds OPERABILITY requirements and an SR for the Safety Injection Input from ESFAS Function to the CTS.

M.4 When one or more required channels of CTS Table 3.3-6 Instrument 2.A (Train A Containment Area Radiation, Particulate, and Noble Gas) or 2.B (Train B Containment Area Radiation, Particulate, and Noble Gas) inoperable, CTS Table 3.3-6 Action 22 requires compliance with the CTS 3.9.9 Action (i.e., close each containment purge and exhaust penetration). However, CTS Table 3.3-6 Action 22 includes an exception that states, "This ACTION is not required during the performance of containment integrated leak rate test." ITS 3.3.6 does not include this exception to CTS Table 3.3-6 Action 22. This changes the CTS by eliminating an exception to Action requirements.

The purpose of the exception to the actions when one or more required containment radiation monitoring channels is inoperable was to eliminate to need to obtain grab samples from containment during a containment integrated leak rate test. Prior to License Amendments 60 (Unit 1) and 43 (Unit 2), when one or more required containment radiation monitoring channels were inoperable, a CNP Units 1 and 2 Page 5 of 15 Attachment 1, Volume 8, Rev. 0, Page 612 of 818

Attachment 1, Volume 8, Rev. 0, Page 613 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION grab sample was required. The action requirement to obtain a grab sample in the event of inoperability of one or more required containment radiation monitoring channels was eliminated from the Technical Specifications and replaced with the requirement to comply with the action requirements of CTS 3.9.9 (i.e., close each containment purge and exhaust penetration) in License Amendments 60 (Unit 1) and 43 (Unit 2) dated September 9, 1982. This change is acceptable since the exception to compliance with CTS Table 3.3-6 Action 22 is no longer needed. This change is designated as more restrictive because it eliminates an allowance from the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (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 the Purge and Exhaust Isolation Functions.

These columns are labeled, "TOTAL NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." ITS Table 3.3.6-1 does not retain the "TOTAL NO. OF CHANNELS" and "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.2 (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 provide requirements for Functions 9.b (Manual Containment Spray Containment Isolation - Phase "B" Containment Purge and Exhaust Isolation) and 9.c (Manual Containment Isolation - Phase "A" Containment Purge and Exhaust Isolation Function). ITS Table 3.3.6-1 provides requirements for Function 1 (Manual Initiation). This changes the CTS by moving the details of the Manual Initiation Function for Containment Purge Supply and Exhaust System isolation from the Technical Specifications to the Bases.

CNP Units 1 and 2 Page 6 of 15 Attachment 1, Volume 8, Rev. 0, Page 613 of 818

Attachment 1, Volume 8, Rev. 0, Page 614 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION 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 requirement for the Manual Initiation Function of the Containment Purge Supply and Exhaust System isolation instrumentation 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.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.3.2.1 requires the ESFAS instrumentation and interlocks setpoints to be set consistent with the Trip Setpoint values shown in Table 3.3-4 and the Trip Setpoint column in CTS Table 3.3-4 references CTS Table 3.3-6. CTS 3.3.3.1 requires the radiation monitoring instrumentation channels shown in Table 3.3-6 to be set consistent with the Trip Setpoint values shown in Table 3.3-6. The radiation monitoring channels in question are the same for both CTS 3.3.2.1 and CTS 3.3.3.1. In addition, 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. ITS 3.3.6 requires the Containment Purge Supply and Exhaust System Isolation Instrumentation Functions to be OPERABLE.

ITS Table 3.3.6-1 specifies the Allowable Values for the Containment Purge Supply and Exhaust System Isolation 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 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 Containment Purge Supply and Exhaust System Isolation 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 Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS Table 3.3-3 Action 17 allows operation to continue with the number of OPERABLE channels of the Containment Radioactivity - High Function less than the minimum number of channels, provided the containment purge and exhaust valves are maintained closed. CTS 3.3.3.1 Action a requires that if a radiation monitoring channel CNP Units 1 and 2 Page 7 of 15 Attachment 1, Volume 8, Rev. 0, Page 614 of 818

Attachment 1, Volume 8, Rev. 0, Page 615 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION alarm/trip setpoint exceeds specified limits (effectively inoperable), then the setpoint is to be adjusted to within the limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (i.e., restore the channel to OPERABLE status) or the channel declared inoperable. CTS Table 3.3-6 Action 22 requires, with the number of OPERABLE containment area radiation, particulate, and noble gas channels less than the minimum number of channels, compliance with the Action requirements of CTS 3.9.9. The CTS 3.9.9 Action requires the containment purge and exhaust penetrations to be closed.

ITS 3.3.6 ACTION A is the applicable action for the Containment Radiation Functions when one required channel is inoperable, and allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the channel to OPERABLE status. This changes the CTS by providing a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time to restore a channel to OPERABLE status when one required Containment Radiation Function channel is inoperable. As a result, a corresponding change is also made to CTS Table 3.3-3 Action 17 and CTS Table 3.3-6 Action 22 such that these actions address the condition of two or more required Containment Radiation Function channels inoperable.

The purpose of the Required Actions is 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. This change is acceptable because the Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant instrumentation channels. This includes the capacity and capability of remaining channels, a reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the repair period. The ITS ACTION will allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the channel to OPERABLE status when one channel is inoperable. This is a reasonable period of time because of the low probability of an event occurring that would require a Containment Purge Supply and Exhaust System isolation and the Containment Purge Supply and Exhaust System isolation capability provided by the remaining OPERABLE channels of the associated Containment Radiation 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.2 (Category 2 - Relaxation of Applicability) CTS 3.9.9 is applicable during CORE ALTERATIONS and during movement of irradiated fuel assemblies within containment. The ITS Table 3.3.6-1 requirements for the Manual Initiation and Containment Radiation Functions are applicable, in part, during movement of irradiated fuel assemblies within containment. This changes the CTS by eliminating requirements for the Containment Purge and Exhaust Isolation System during CORE ALTERATIONS.

The purpose of CTS 3.9.9 is to ensure the containment purge supply and exhaust isolation valves are capable of being closed as assumed in the fuel handling accident inside containment analysis. 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. There are no accidents postulated to occur during CORE ALTERATIONS that result in significant radioactive release except a fuel handling accident. The analysis for a fuel handling accident assumes the event occurs only during movement of irradiated CNP Units 1 and 2 Page 8 of 15 Attachment 1, Volume 8, Rev. 0, Page 615 of 818

Attachment 1, Volume 8, Rev. 0, Page 616 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION fuel. No CORE ALTERATIONS except the movement of irradiated fuel are assumed to be in progress when a fuel handling accident occurs. Therefore, imposing requirements during CORE ALTERATIONS in addition to during movement of irradiated fuel is unnecessary. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.3 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 Action 18 requires, with the number of OPERABLE channels of the Manual Containment Purge and Exhaust Isolation Functions less than the total number of channels, that the channels be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or that the unit be placed in MODE 3 in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ITS 3.3.6 ACTION C is the applicable action for the Manual Initiation Functions when inoperable channels are not restored to OPERABLE status within the associated Completion Time, and allows the containment purge supply and exhaust isolation valves to be placed in the closed position immediately.

This changes the CTS by allowing the containment purge supply and exhaust isolation valves to be closed, in lieu of requiring a unit shutdown.

The purpose of the requirements for the Manual Initiation Function is to ensure the associated containment purge supply and exhaust isolation valves are capable of being manually closed. The proposed Required Action ensures that the function of the inoperable channels is satisfied by requiring the containment purge supply and exhaust isolation valves to be placed in the closed position.

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. This change is acceptable because the Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the automatic Containment Purge Supply and Exhaust System isolation instrumentation channels, a reasonable time to accomplish the closure of the containment purge supply and exhaust isolation valves, and the low probability of a DBA occurring during the time period. The ITS ACTION will allow the containment purge supply and exhaust isolation valves to be placed in the closed position immediately. This is a reasonable period of time because of the low probability of an event occurring that would require a Containment Purge Supply and Exhaust System isolation and the isolation capability provided by the remaining OPERABLE automatic channels of the Containment Purge Supply and Exhaust System Isolation Instrumentation Functions. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.4 (Category 1 - Relaxation of LCO Requirements) CTS Table 3.3-3 specifies the Functional Unit 3.c.2) (Purge and Exhaust Isolation, Containment Radioactivity -

High Train A) channel instrument numbers to be VRS-1101, ERS-1301, and ERS-1305 (Unit 1) and VRS-2101, ERS-2301, and ERS-2305 (Unit 2) and the Functional Unit 3.c.3) (Purge and Exhaust Isolation, Containment Radioactivity -

High Train B) channel instrument numbers to be VRS-1201, ERS-1401, and ERS-1405 (Unit 1) and VRS-2201, ERS-2401, and ERS-2405 (Unit 2).

CTS Table 3.3-4 specifies the Functional Unit 3.c.2 (Purge and Exhaust Isolation, Containment Radioactivity - High Train A) channel instrument numbers to be CNP Units 1 and 2 Page 9 of 15 Attachment 1, Volume 8, Rev. 0, Page 616 of 818

Attachment 1, Volume 8, Rev. 0, Page 617 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION VRS-1101, ERS-1301, and ERS-1305 (Unit 1) and VRS-2101, ERS-2301, and ERS-2305 (Unit 2) and the Functional Unit 3.c.3 (Purge and Exhaust Isolation, Containment Radioactivity - High Train B) channel instrument numbers to be VRS-1201, ERS-1401, and ERS-1405 (Unit 1) and VRS-2201, ERS-2401, and ERS-2405 (Unit 2). CTS Table 3.3-6 specifies the Instruments 1.A.i (Area Monitor, Upper Containment), 1.B.i (Process Monitors, Particulate Channel), and 1.B.ii (Process Monitors, Noble Gas Channel) channel instrument numbers to be VRS-1101, VRS-1201, ERS-1301, ERS-1401, ERS-1305, and ERS-1405 (Unit 1) and VRS-2101, VRS-2201, ERS-2301, ERS-2401, ERS-2305, and ERS-2405 (Unit 2). CTS Tables 3.3-6 and 4.3-3 specify the Instruments 2.A.i, 2.A.ii, and 2.A.iii (Containment Area Radiation, Particulate, and Noble Gas Train A )

channel instrument numbers to be VRS-1101, ERS-1301, and ERS-1305 (Unit 1) and VRS-2101, ERS-2301, and ERS-2305 (Unit 2) and the Instruments 2.B.i, 2.B.ii, and 2.B.iii (Containment Area Radiation, Particulate, and Noble Gas Train B) channel instrument numbers to be VRS-1201, ERS-1401, and ERS-1405 (Unit 1) and VRS-2201, ERS-2401, and ERS-2405 (Unit 2). ITS Table 3.3.6-1 Functions 3.a, 3.b, and 3.c (Containment Radiation - Gaseous, - Particulate, and

- Area Radiation) do not specify the instrument numbers for these instruments.

This changes the CTS by deleting the instrument numbers for the channels of the Containment Radioactivity - High Functions from the Technical Specifications.

The purpose of the requirements of CTS Tables 3.3-3, 3.3-4, 3.3-6, and 4.3-3 are to ensure the appropriate Containment Radioactivity - High Functions channels are OPERABLE for isolation of the containment purge supply and exhaust isolation valves. This change is acceptable because ITS LCO 3.3.6 and associated Surveillance Requirements continue to ensure that the instrumentation is maintained consistent with the safety analyses and licensing basis. The channel instrument numbers of the Containment Radioactivity - High Function have been deleted from the Technical Specifications. The instrument numbers are not necessary to ensure the equipment is OPERABLE. The requirements to maintain the Containment Radiation Functions instrumentation OPERABLE is sufficient to ensure the appropriate equipment is maintained OPERABLE. The use of a description of the instrument channel in the Technical Specifications has been proven to be sufficient. 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.5 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS Table 4.3-2 requires a CHANNEL CALIBRATION of the Containment Radioactivity - High Functional Unit instrumentation every 18 months and CTS Table 4.3-3 requires a CHANNEL CALIBRATION of the containment area radiation, particulate, and noble gas channels every 18 months. ITS SR 3.3.6.8 requires the performance of a CHANNEL CALIBRATION for the Containment Radiation Function instrumentation 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).

CNP Units 1 and 2 Page 10 of 15 Attachment 1, Volume 8, Rev. 0, Page 617 of 818

Attachment 1, Volume 8, Rev. 0, Page 618 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION The purpose of the CHANNEL CALIBRATION requirement of CTS Tables 4.3-2 and 4.3-3 is to ensure channels of the Containment Radiation Function will function as designed during an analyzed event. Extending the SR Frequency is acceptable because the Containment Radiation Function instruments are designed to be single failure proof, therefore ensuring system availability in the event of a failure of one of the channel components. Furthermore, a CHANNEL CHECK is performed on a more frequent basis (ITS SR 3.3.6.1). The CHANNEL CHECK provides a qualitative demonstration of the OPERABILITY of the instruments.

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. The following impacted Containment Radiation Function instrumentation were evaluated:

CTS Table 4.3-2, Functional Unit 3.c.2, Containment Radioactivity - High and CTS Table 4.3-3, Instruments 2.A.i and 2.B.i, Containment Area Radiation CTS Table 4.3-2, Functional Unit 3.c.2, Containment Radioactivity - High and CTS Table 4.3-3, Instruments 2.A.ii and 2.B.ii, Particulate CTS Table 4.3-2, Functional Unit 3.c.2, Containment Radioactivity - High and CTS Table 4.3-3, Instruments 2.A.iii and 2.B.iii, Noble Gas These functions are performed using Eberline Radiation Monitoring Systems including Eberline SPING Radiation Monitoring Systems. These components were not evaluated for drift because, for radiation monitors, the major error contributor is the accuracy of the detector and the calibration sources. In the case of the calibration sources, normally multiple readings are required and an average reading is used to confirm operation. The accuracy of the decay curves and detector sensitivity may be from 12% to 30%. This accuracy far overshadows the accuracy of the electronic signal conditioning circuit.

Therefore, drift of the electronic circuit does not provide a measure of functional performance over time between calibrations. This is substantiated by the ANSI N42.18 acceptance criteria of + 20%. CHANNEL CHECKS and source checks (where internal source check is possible) verify that the instruments are performing within expected conditions. In addition, there was a failure analysis evaluation performed. This failure analysis did not reveal any time based failure mechanisms or any failure types that would invalidate the conclusion that the system availability and reliability would be impacted by an increased Surveillance interval.

Based on the design of the instrumentation, as well as the qualitative drift analysis and the failure results analysis, 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 CNP Units 1 and 2 Page 11 of 15 Attachment 1, Volume 8, Rev. 0, Page 618 of 818

Attachment 1, Volume 8, Rev. 0, Page 619 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the unit licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.6 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS Table 4.3-2 requires the performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) of the Manual Purge and Exhaust Isolation Functional Unit at least once per 18 months. CTS 4.9.9 requires the verification of containment purge and exhaust isolation on a manual initiation signal once per 7 days during CORE ALTERATIONS. ITS SR 3.3.6.7 requires the performance of a TADOT of the Manual Initiation Function every 24 months. This changes the CTS by extending the Frequency of the Surveillance 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 requirements of CTS Table 4.3-2 for the Manual Purge and Exhaust Isolation Function is to ensure the proper operation of the associated instrumentation. 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 TADOT is acceptable because the Manual Initiation of the Containment Purge Supply and Exhaust System isolation is not credited in any safety analyses and manual isolation of the Containment Purge Supply and Exhaust System may be accomplished using the individual valve controls.

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.7 (Category 2 - Relaxation of Applicability) CTS Tables 3.3-6 and 4.3-3 require the Functional Units 2.A and 2.B (Containment Area Radiation, Particulate, and Noble Gas) channels to be OPERABLE in MODE 6. ITS Table 3.3.6-1 Footnote (a) requires the Function 3 (Containment Radiation) channels to be OPERABLE during movement of irradiated fuel assemblies within containment.

This changes the CTS by deleting the requirement that the Containment Radiation Functions be OPERABLE in MODE 6 when irradiated fuel assemblies are not being moved in containment.

The purpose of CTS Tables 3.3-6 and 4.3-3 MODE 6 requirements for containment area radiation, particulate, and noble gas channels is to ensure the CNP Units 1 and 2 Page 12 of 15 Attachment 1, Volume 8, Rev. 0, Page 619 of 818

Attachment 1, Volume 8, Rev. 0, Page 620 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION containment purge supply and exhaust isolation valves are capable of closing to mitigate the consequences of a fuel handling accident as assumed in the safety analyses. This change is acceptable because the ITS 3.3.6 requirements continue to ensure that the instrumentation is maintained OPERABLE in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The fuel handling accident is assumed to occur only during movement of an irradiated fuel assembly. This change is designated as less restrictive because LCO requirements are applicable in fewer conditions than in the CTS.

L.8 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.9 states that the Containment Purge and Exhaust Isolation System shall be demonstrated OPERABLE, in part, "within 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to the start of" the specified conditions. ITS SR 3.3.6.6 and ITS SR 3.3.6.7 do not include the "within 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to the start of" Frequency. ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions in the Applicability for the individual LCOs, unless otherwise stated in the SR."

Therefore, under the ITS, the Surveillances must be met prior to the initiation of movement of irradiated fuel within containment. This changes the CTS by eliminating the stipulation that the Surveillances be met within 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to entering the MODE of Applicability.

The purpose of CTS 4.9.9 is to verify the Containment Purge and Exhaust Isolation System is OPERABLE. This change is acceptable because the periodic Surveillance Frequencies have been evaluated to ensure that they provide an acceptable level of equipment reliability. For CTS 4.9.9, the periodic Surveillance Frequencies for verifying Containment Purge and Exhaust Isolation Instrumentation OPERABILITY are acceptable during the MODE of Applicability, and are also acceptable during the period prior to entering the MODE of Applicability. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.9 (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 Containment Radioactivity - High Functional Unit instrumentation every 92 days and CTS Table 4.3-3 requires a CHANNEL FUNCTIONAL TEST of the containment area radiation, particulate, and noble gas channels every 92 days. CTS 4.9.9 states that the Containment Purge and Exhaust Isolation System shall be demonstrated OPERABLE, in part, once per 7 days during the specified conditions. ITS SR 3.3.6.6 requires, for the Containment Radiation Functions of the Containment Purge Supply and Exhaust System isolation instrumentation, the performance of a CHANNEL OPERATIONAL TEST once per 184 days. This changes the CTS by extending the Frequency of the Surveillance from 7 days or 92 days (i.e., for the 92 day Frequency, a maximum of 115 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 CHANNEL OPERATIONAL TEST is addressed in DOC A.4.

CNP Units 1 and 2 Page 13 of 15 Attachment 1, Volume 8, Rev. 0, Page 620 of 818

Attachment 1, Volume 8, Rev. 0, Page 621 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION The purpose of the CHANNEL FUNCTIONAL TEST requirement in CTS Tables 4.3-2 and 4.3-3 is to ensure the channels of the Containment Radiation Function 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. 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.

The purpose of CTS 4.9.9 is to verify the Containment Purge and Exhaust Isolation System is OPERABLE. The Containment Purge and Exhaust Isolation System includes the instrumentation that provides a containment high radiation isolation signal to the containment purge supply and exhaust isolation valves.

During MODES 1, 2, 3, 4, and during MODE 6, CTS Tables 4.3-2 and 4.3-3 require the performance of a CHANNEL FUNCTIONAL TEST for this containment radiation instrumentation once per 92 days (changed to 184 days as described above). This change is acceptable because the periodic Surveillance Frequency for MODES 1, 2, 3, 4 and 6 has been evaluated to ensure that it provides an acceptable level of equipment reliability. For CTS 4.9.9, the same periodic Surveillance Frequency (once per 184 days) for verifying Containment Purge and Exhaust Isolation System OPERABILITY is acceptable during the MODE of Applicability, and is also acceptable during the period prior to entering the MODE of Applicability.

These changes are designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.10 CTS Table 3.3-3, Functional Units 9.b and 9.c (Manual Containment Purge and Exhaust Isolation) require a total of 2 channels per train to be OPERABLE (1 channel per train for Functional Unit 9.b and 1 channel per train for Functional Unit 9.c). ITS Table 3.3.6-1, Function 1 (Manual Initiation) requires only one channel per train to be OPERABLE. This changes the CTS be decreasing the number of manual channels required OPERABLE from two per train to one per train.

The purpose of the Containment Purge Supply and Exhaust Manual Initiation Function is to ensure the capability exists to manually isolate the Containment Purge Supply and Exhaust System isolation valves. The Containment Purge Supply and Exhaust System Manual Initiation Function at CNP is provided by four switches, two per train. Each switch will actuate all Containment Purge Supply and Exhaust System isolation valves in its associated train (i.e., the two CNP Units 1 and 2 Page 14 of 15 Attachment 1, Volume 8, Rev. 0, Page 621 of 818

Attachment 1, Volume 8, Rev. 0, Page 622 of 818 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION train A switches are fully redundant to each other and the two train B switches are fully redundant to each other). The differences between the two switches within a train are their location within the control room, and one of the two switches also actuates Containment Isolation Phase A while the other switch also actuates the Containment Spray subsystem and Containment Isolation Phase B.

There is no manual switch that only initiates a Containment Purge Supply and Exhaust System isolation at CNP. One train A switch and one train B switch are located on the Containment Spray System panel, while one train A switch and one train B switch are located on the Ventilation System panel. The CTS requires both channels per train OPERABLE because the CTS groups the Containment Purge Supply and Exhaust manual initiation function by switch function. Therefore, it is listed twice in CTS Table 3.3-3, Functional Unit 9: once for the Containment Spray subsystem and Containment Isolation Phase B switch (Functional Unit 9.b) and once for the Containment Isolation Phase A switch (Functional Unit 9.c). 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 Containment Purge Supply and Exhaust System 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, then the associated Containment Purge Supply and Exhaust System valves can still be closed using individual valve 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.11 CTS Table 4.3-3 footnote

requires performance of a SOURCE CHECK as part of the shiftly CHANNEL CHECK requirements for Containment Radiation instrumentation (Instruments 2.A.i, 2.A.ii, 2.A.iii, 2.B.i, 2.B.ii, and 2.B.iii).

ITS 3.3.6 does not include this requirement. This changes the CTS by deleting the shiftly SOURCE CHECK requirement on the Containment Radiation instrumentation.

A SOURCE CHECK is a qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. The purpose for performing the SOURCE CHECK on these instruments is to ensure on-scale reading of the instruments. However, the background radiation levels in the vicinity of these instruments is sufficiently high enough to provide an on-scale reading for the instruments. Thus, the required routine (every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) CHANNEL CHECK (ITS SR 3.3.6.1) will ensure the on-scale reading of the instruments (i.e., the instruments are not "pegged-low"). In addition, the Containment Radiation instruments have a low failure alarm to alert the operators of a failed-low radiation detector. Therefore, the deletion of this specific requirement is acceptable. This change is designated as less restrictive because a Surveillance Requirement is being deleted.

CNP Units 1 and 2 Page 15 of 15 Attachment 1, Volume 8, Rev. 0, Page 622 of 818

Attachment 1, Volume 8, Rev. 0, Page 623 of 818 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 625 of 818 3.3.6 4

INSERT 1 Restore required channels to OPERABLE status.

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Attachment 1, Volume 8, Rev. 0, Page 628 of 818 3.3.6 10 CTS INSERT 2 DOC SR 3.3.6.5 Perform TADOT. 92 days on a M.3 STAGGERED TEST BASIS Insert Page 3.3.6-3 Attachment 1, Volume 8, Rev. 0, Page 628 of 818

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Attachment 1, Volume 8, Rev. 0, Page 630 of 818 3.3.6 CTS 10 INSERT 3

3. Containment 1(c), 2(c), 3 (c), 2 per train(b) SR 3.3.6.1 See 2 below Radiation 4(c), (a) SR 3.3.6.6 SR 3.3.6.8

a. Gaseous < 4.4 E-3 µCi/cc

b. Particulate < 2.52 µCi

c. Area Radiation < 54 mR/hr 10 INSERT 4

4. Safety Injection 1, 2, 3, 4 2 trains SR 3.3.6.5 NA DOC (SI) Input from M.3 Engineered Safety Features Actuation System (ESFAS) 2 INSERT 5 See 3 (b) Only 2 of the 3 Containment Radiation Function channels (Gaseous, Particulate, below and Area Radiation) per train are required to be OPERABLE.

10 INSERT 6 DOC (c) When any Containment Purge Supply and Exhaust System isolation valve is open.

M.1 2 CTS Table 3.3-3 Functions 3.c.2) and 3.c.3)

CTS Table 3.3-4 Functions 3.c.2 and 3.c.3 CTS Table 4.3-2 Function 3.c.2)

CTS Table 3.3-6 Functions 2.A and 2.B CTS Table 4.3-3 Functions 2.A and 2.B 3 CTS Table 3.3-3 Functions 3.c.2) and 3.c.3)

CTS Table 3.3-6 Functions 2.A and 2.B Insert Page 3.3.6-4 Attachment 1, Volume 8, Rev. 0, Page 630 of 818

Attachment 1, Volume 8, Rev. 0, Page 631 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION

1. The title of ISTS 3.3.6, Containment Purge and Exhaust Isolation Instrumentation, has been revised in ITS 3.3.6 to reflect the plant specific nomenclature (i.e.,

Containment Purge Supply and Exhaust System Isolation Instrumentation).

Corresponding changes have also been made to the ISTS 3.3.6 Header, LCO, Surveillance Requirements Note and Table 3.3.6-1.

2. The plant specific design of the containment radiation monitoring instrumentation that functions to isolate the containment purge supply and exhaust isolation valves includes three radiation monitoring channels in each of two trains. These radiation monitors are arranged such that any one of the three radiation monitor channels in a train will initiate a Containment Purge Supply and Exhaust System isolation of the associated train of containment isolation valves in the Containment Purge Supply and Exhaust System. However, current licensing basis, reflected in the Technical Specifications, only requires two of the three radiation monitors in each train to be OPERABLE. This allowance is reflected in ITS Table 3.3.6-1 Footnote (b), which states "Only 2 of the 3 Containment Radiation Function channels (Gaseous, Particulate, and Area Radiation) per train are required to be OPERABLE." As a result, the word "required" is added to ISTS 3.3.6 Conditions A and C to reflect that not all of the radiation monitors are required to be OPERABLE to meet the LCO.

3. ISTS 3.3.6 Required Action A.1 states, "Restore the affected channel to OPERABLE status." ITS 3.3.6 Required Action A.1 is revised to state "Restore channel to OPERABLE status." This changes ISTS 3.3.6 Required Action A.1 to be consistent with other Required Actions in ISTS Section 3.3.

4. ISTS 3.3.6 ACTION B is revised to be consistent with CNP Units 1 and 2 CTS requirements for the manual initiation channels for the Containment Purge Supply and Exhaust System isolation. When one or more of the required manual initiation channels are inoperable, the CTS allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the channels to OPERABLE status (ITS 3.3.6 ACTION B). ISTS 3.3.6 ACTION B requirements related to inoperable automatic actuation trains, multiple inoperable radiation monitoring channels, and default actions when ISTS 3.3.6 ACTION A requirements are not met are addressed in ITS 3.3.6 ACTION C. Due to these revised actions, the Note to ISTS 3.3.6 Condition B, which states "Only applicable in MODES 1, 2, 3, and 4, is unnecessary and is deleted.

5. ISTS 3.3.6 ACTION C is revised to be consistent with CNP Units 1 and 2 CTS requirements for the instrumentation channels for the Containment Purge Supply and Exhaust System isolation. When multiple required radiation channels are inoperable, the CTS require the containment purge supply and exhaust isolation valves to be placed in the closed position. This action accomplishes the safety function of the inoperable channels. The function of each of the Containment Purge Supply and Exhaust System Isolation Instrumentation Functions is to close or support closure of the containment purge supply and exhaust isolation valves. Therefore, ITS 3.3.6 Required Action C.1 has also been provided when one or more automatic actuation logic and actuation relay trains are inoperable, when one or more SI Input to ESFAS trains are inoperable, or when any Required Action and associated Completion Time of ITS 3.3.6 Condition A or B is not met (i.e., when one inoperable required radiation monitoring channel is not restored within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or when one or more inoperable manual initiation channels are not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ). Due to the changes to CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 8, Rev. 0, Page 631 of 818

Attachment 1, Volume 8, Rev. 0, Page 632 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION ISTS 3.3.6 ACTIONS B and C, the Note to ISTS 3.3.6 Condition C and ISTS 3.3.6 Required Action C.2 are unnecessary and are deleted.

6. The ISTS 3.3.6 Surveillance Requirements are revised to reflect the CNP Units 1 and 2 current licensing basis and testing practices. ISTS SR 3.3.6.2 (ITS SR 3.3.6.2) requires the performance of an ACTUATION LOGIC TEST and ISTS SR 3.3.6.3 (ITS SR 3.3.6.3) requires performance of a MASTER RELAY TEST.

The ISTS 3.3.6 Frequencies for these SRs are revised from "31 days on a STAGGERED TEST BASIS" to "92 days" to reflect the Frequency that these tests are performed at CNP Units 1 and 2. Currently, the requirements of ITS SR 3.3.6.2 and ITS SR 3.3.6.3 are satisfied during the 92 day performance of the CHANNEL FUNCTIONAL TEST for the radiation monitoring channels.

7. ISTS SR 3.3.6.6 (ITS SR 3.3.6.7) requires the performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) for the manual initiation channels. ISTS SR 3.3.6.6 is modified by a Note that states "Verification of setpoint is not required."

The manual initiation channels 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 the manual initiation channels, the TADOT definition does not require verification of setpoints. Therefore, the Note to ISTS SR 3.3.6.6 is unnecessary and has been deleted.

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

9. The Frequency of ISTS SR 3.3.6.4 (ITS SR 3.3.6.6) has been changed from 92 days to 184 days. The technical justification for this change is consistent with the guidelines of Generic Letter 91-04, and is discussed in ITS 3.3.6 DOC L.9. SRs have been renumbered to reflect their Frequencies, as required.

10. ISTS Table 3.3.6-1 is revised to reflect the plant specific nomenclature, design, and licensing basis for ITS Table 3.3.6-1 Function 1 (Manual Initiation) (as modified by a Discussion of Change), Function 3 (Containment Radiation) (as modified by a Discussion of Change), and Function 4 (Safety Injection Input from Engineered Safety Features Actuation System). In addition, a new Surveillance Requirement (ITS SR 3.3.6.5), which requires the performance of a TADOT once per 92 days on a STAGGERED TEST BASIS, is added for ITS Table 3.3.6-1 Function 4 consistent with current practice and the CTS requirements for other instrumentation that receive input for safety injection.

11. The words "and maintain" in ISTS 3.3.6 Required Action C.1 are unnecessary and have been deleted. In the ISTS, when a Required Action states to place a component in a given condition, it is implicit that the condition specified in the Required Action is to be maintained. Therefore, for consistency with similar Required Actions and to alleviate any confusion, the words have been deleted.

12. Typographical error corrected.

CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 8, Rev. 0, Page 632 of 818

Attachment 1, Volume 8, Rev. 0, Page 633 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION

13. ISTS Table 3.3.6-1 includes requirements for Trip Setpoints for the Containment Radiation Functions of the Containment Purge Supply and Exhaust System isolation instrumentation. The term "TRIP SETPOINT" is revised to "ALLOWABLE VALUE" in ITS Table 3.3.6-1 to reflect the OPERABILITY limit for the channels of the Containment Radiation Functions. This change achieves consistency with the OPERABILITY requirements for other actuation instrumentation channels in ISTS Section 3.3.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 8, Rev. 0, Page 633 of 818

Attachment 1, Volume 8, Rev. 0, Page 634 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 636 of 818 B 3.3.6 1

INSERT 1 purge supply and exhaust 1

INSERT 1A containment instrumentation room purge supply and exhaust valves, and containment pressure relief isolation valves 1

INSERT 1B

, or manual actuation of Phase B isolation 1

INSERT 1C Three radiation monitoring channels in each of two trains are also provided as input to the Containment Purge Supply and Exhaust System isolation. The channels in each train measure containment radiation at two locations. One channel in each train is an upper containment area radiation monitor, and the other two channels in each train measure radiation in lower containment samples. The radiation detectors that measure radiation in the lower containment samples are of two different types: gaseous and particulate. For the purpose of this LCO, the three radiation monitors in each train are considered redundant even though they measure radiation in different locations of the containment. The radiation monitors are arranged such that any one of the three radiation monitor channels in a train will initiate a Containment Purge Supply and Exhaust System isolation of the associated train of containment isolation valves in the Containment Purge Supply and Exhaust System. Therefore, only two of the three radiation monitors in each train are required to be OPERABLE. Since the radiation monitors that measure the radiation in lower containment constitute a sampling system, various components such as sample line valves and sample pumps are required to support the OPERABILITY of these monitors.

Containment Purge Supply and Exhaust System has inner and outer containment isolation valves. A Train A Containment Purge Supply and Exhaust System Isolation signal closes the inner containment isolation valves in the Containment Purge Supply and Exhaust System. A Train B Containment Purge Supply and Exhaust System Isolation signal closes the outer containment isolation valves in the Containment Purge Supply and Exhaust System. The Containment Purge Supply and Exhaust System is described in UFSAR, Section 5.5.3 (Ref. 1).

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Attachment 1, Volume 8, Rev. 0, Page 638 of 818 B 3.3.6 1 INSERT 1D isolated by this instrumentation 1 INSERT 2 (manual Containment Isolation - Phase A actuation or manual Containment Spray, Containment Isolation - Phase B actuation) in either Train A or Train B 1 INSERT 2A These switches are common to ESFAS Containment Isolation, Phase A and B Manual Initiation switches.

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Attachment 1, Volume 8, Rev. 0, Page 640 of 818 B 3.3.6 1

INSERT 3

, and ESFAS Function 3.b, Containment Phase B Isolation 2 INSERT 4 Safety Injection (SI) Input to Engineered Safety Features Actuation System (ESFAS)

The SI Input from ESFAS ensures that the ESFAS automatic actuation logic will actuate the Containment Purge Supply and Exhaust System isolation upon any signal that initiates SI. Actuation of the Containment Purge Supply and Exhaust System on an SI signal ensures that, in the event of conditions that may result in a radiological release, the Containment Purge Supply and Exhaust will be isolated. The SI Input from ESFAS signal directly inputs to Containment Purge Supply and Exhaust Isolation Instrumentation actuation logic. There are two trains of SI Input from ESFAS arranged in a one-out-of-two logic.

1 INSERT 5 The Containment Radiation Function is required to be OPERABLE in MODES 1, 2, 3, and 4 when any Containment Purge Supply and Exhaust System isolation valve is open and during movement of irradiated fuel assemblies within containment. The SI Input from ESFAS Function is required to be OPERABLE in MODES 1, 2, 3, and 4.

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Attachment 1, Volume 8, Rev. 0, Page 643 of 818 B 3.3.6 2

INSERT 6 Condition B applies to the manual initiation channels. If one or more required manual initiation channels are inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore the required channels to OPERABLE status. The specified Completion Time is reasonable considering that there are two automatic actuation trains OPERABLE for each Function, and the low probability of an event occurring during this interval.

2 INSERT 7 If one or more Automatic Actuation Logic and Actuation Relay trains are inoperable, one or more SI Input to ESFAS trains are inoperable, two or more required radiation monitoring channels are inoperable, or the Required Action and associated Completion Time of Condition A or B are not met, operation may continue provided the containment purge supply and exhaust isolation valves are placed in the closed position immediately.

Placing the containment purge supply and exhaust isolation valves in the closed position accomplishes the safety function of the inoperable trains or channels.

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Attachment 1, Volume 8, Rev. 0, Page 646 of 818 B 3.3.6 2 INSERT 8 The TADOT of the SI Input from ESFAS Function is performed every 92 days on a STAGGERED TEST BASIS. The TADOT of the Manual Initiation Function is performed every 24 months.

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Attachment 1, Volume 8, Rev. 0, Page 648 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.6 BASES, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION 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. Changes are made to reflect changes made to the Specification.

3. Grammatical/typographical error corrected.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 648 of 818

Attachment 1, Volume 8, Rev. 0, Page 649 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 649 of 818

Attachment 1, Volume 8, Rev. 0, Page 650 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.10 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 Units 9.b and 9.c (Manual Containment Purge and Exhaust Isolation) require a total of 2 channels per train to be OPERABLE (1 channel per train for Functional Unit 9.b and 1 channel per train for Functional Unit 9.c). ITS Table 3.3.6-1, Function 1 (Manual Initiation) requires only one channel per train to be OPERABLE.

This changes the CTS be decreasing the number of manual channels required OPERABLE from two per train to one per train.

The purpose of the Containment Purge Supply and Exhaust Manual Initiation Function is to ensure the capability exists to manually isolate the Containment Purge Supply and Exhaust System isolation valves. The Containment Purge Supply and Exhaust System Manual Initiation Function at CNP is provided by four switches, two per train. Each switch will actuate all Containment Purge Supply and Exhaust System isolation valves in its associated 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 differences between the two switches within a train are their location within the control room, and one of the two switches also actuates Containment Isolation Phase A while the other switch also actuates the Containment Spray subsystem and Containment Isolation Phase B. There is no manual switch that only initiates a Containment Purge Supply and Exhaust System isolation at CNP. One train A switch and one train B switch are located on the Containment Spray System panel, while one train A switch and one train B switch are located on the Ventilation System panel. The CTS requires both channels per train OPERABLE because the CTS groups the Containment Purge Supply and Exhaust manual initiation function by switch function. Therefore, it is listed twice in CTS Table 3.3-3, Functional Unit 9: once for the Containment Spray subsystem and Containment Isolation Phase B switch (Functional Unit 9.b) and once for the Containment Isolation Phase A switch (Functional Unit 9.c). NUREG-1431 only requires two Manual Initiation channel 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 Containment Purge Supply and Exhaust System 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, then the associated Containment Purge Supply and Exhaust System valves can still be closed using individual valve 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:

CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 8, Rev. 0, Page 650 of 818

Attachment 1, Volume 8, Rev. 0, Page 651 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION

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 initiation 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.

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 initiation 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 Containment Purge Supply and Exhaust System isolation valves. No new or revised operator actions are required as a result of this change. 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 initiation 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 Containment Purge Supply and Exhaust System valves can still be closed using individual valve 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 4 Attachment 1, Volume 8, Rev. 0, Page 651 of 818

Attachment 1, Volume 8, Rev. 0, Page 652 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION INSTRUMENTATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.11 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 4.3-3 footnote

requires performance of a SOURCE CHECK as part of the shiftly CHANNEL CHECK requirements for Containment Radiation instrumentation (Instruments 2.A.i, 2.A.ii, 2.A.iii, 2.B.i, 2.B.ii, and 2.B.iii). ITS 3.3.6 does not include this requirement. This changes the CTS by deleting the shiftly SOURCE CHECK requirement on the Containment Radiation instrumentation.

A SOURCE CHECK is a qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. The purpose for performing the SOURCE CHECK on these instruments is to ensure on-scale reading of the instruments.

However, the background radiation levels in the vicinity of these instruments is sufficiently high enough to provide an on-scale reading for the instruments. Thus, the required routine (every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) CHANNEL CHECK (ITS SR 3.3.6.1) will ensure the on-scale reading of the instruments (i.e., the instruments are not "pegged-low"). In addition, the Containment Radiation instruments have a low failure alarm to alert the operators of a failed-low radiation detector. Therefore, the deletion of this specific requirement is acceptable. This change is designated as less restrictive because a Surveillance Requirement is being deleted.

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 deletes the requirement to perform a shiftly SOURCE CHECK of the Containment Radiation instrumentation. This change will not affect the probability of an accident, since the Containment Radiation instrumentation is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident are not affected by this change since Containment Radiation instrumentation are assumed to be the backup signal to the SI Input from ESFAS signal for actuating Containment Purge Supply and Exhaust System isolation; it 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 3 of 4 Attachment 1, Volume 8, Rev. 0, Page 652 of 818

Attachment 1, Volume 8, Rev. 0, Page 653 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.6, CONTAINMENT PURGE SUPPLY AND EXHAUST SYSTEM ISOLATION 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 deletes the requirement to perform a shiftly SOURCE CHECK of the Containment Radiation instrumentation. This change will not physically alter the plant (no new or different type of equipment will be installed).

Two channels per train will remain required OPERABLE and will normally be available to actuate the Containment Purge Supply and Exhaust System isolation valves. No new or revised operator actions are required as a result of this change. 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 deletes the requirement to perform a shiftly SOURCE CHECK of the Containment Radiation instrumentation. The margin of safety is not affected by this change because the safety analyses assumptions are not affected. In addition, if the Containment Radiation instrumentation does not function, the associated Containment Purge Supply and Exhaust System valves can still be automatically closed using the SI Input from ESFAS signal.

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

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

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 8, Rev. 0, Page 653 of 818

Attachment 1, Volume 8, Rev. 0, Page 654 of 818 ATTACHMENT 7 ITS 3.3.7, Control Room Emergency Ventilation (CREV) System Actuation Instrumentation Attachment 1, Volume 8, Rev. 0, Page 654 of 818

, Volume 8, Rev. 0, Page 655 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 8, Rev. 0, Page 655 of 818

Attachment 1, Volume 8, Rev. 0, Page 656 of 818 ITS 3.3.7 A.1 ITS LCO 3.3.7 See ITS 3.7.10 Add proposed ACTIONS Note place in pressurization/cleanup mode L.1 ACTION A ACTION C Add proposed ACTION B See ITS 3.7.10 Page 1 of 4 Attachment 1, Volume 8, Rev. 0, Page 656 of 818

Attachment 1, Volume 8, Rev. 0, Page 657 of 818 ITS 3.3.7 A.1 ITS 24 L.2 SR 3.3.7.1 See ITS 5.5 Table 3.3.7.1 Function 1 SR 3.3.7.1 See ITS 3.7.10 Table 3.3.7.1 Function 2 SR 3.3.7.1 See ITS 3.7.10 See ITS 5.5 Page 2 of 4 Attachment 1, Volume 8, Rev. 0, Page 657 of 818

Attachment 1, Volume 8, Rev. 0, Page 658 of 818 ITS 3.3.7 A.1 ITS LCO 3.3.7 See ITS 3.7.10 Add proposed ACTIONS Note place in pressurization/cleanup mode L.1 ACTION A ACTION C Add proposed ACTION B See ITS 3.7.10 Page 3 of 4 Attachment 1, Volume 8, Rev. 0, Page 658 of 818

Attachment 1, Volume 8, Rev. 0, Page 659 of 818 ITS 3.3.7 A.1 ITS 24 L.2 SR 3.3.7.1 See ITS 5.5 Table 3.3.7.1 Function 2 SR 3.3.7.1 See ITS 3.7.10 Table 3.3.7.1 Function 1 SR 3.3.7.1 See ITS 3.7.10 See ITS 5.5 Page 4 of 4 Attachment 1, Volume 8, Rev. 0, Page 659 of 818

Attachment 1, Volume 8, Rev. 0, Page 660 of 818 DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION 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.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.7.5.1 Action a requires, with one train of the SI Input from ESFAS actuation instrumentation inoperable (i.e.,

the associated CREV pressurization train is inoperable), to either restore the pressurization train to OPERABLE status (i.e., by restoring the SI Input from ESFAS actuation instrumentation train to OPERABLE status) within 7 days or the unit must be placed in MODE 3 in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . In addition, the CTS does not provide any Actions when both trains of the SI Input for ESFAS actuation instrumentation are inoperable (i.e.,

both CREV trains are inoperable) in MODES 1, 2, 3, and 4. Thus a CTS 3.0.3 entry is required, which requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . ITS 3.3.7 ACTION A allows 7 days to place the associated CREV train in the pressurization/cleanup mode when one SI Input from ESFAS actuation instrumentation train is inoperable. When both SI Input from ESFAS actuation instrumentation trains are inoperable, ITS 3.3.7 ACTION B allows either immediately placing one CREV train in the pressurization/cleanup mode and declaring the other CREV train inoperable (and taking the actions of the ITS 3.7.10 for an inoperable CREV train) or immediately placing both CREV trains in the pressurization/cleanup mode. Alternately, if the CREV trains are not placed in the pressurization/cleanup mode, ITS 3.3.7 ACTION C requires shutting down the unit to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 8, Rev. 0, Page 660 of 818

Attachment 1, Volume 8, Rev. 0, Page 661 of 818 DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION INSTRUMENTATION In addition, since there are two SI Input from ESFAS Functions required (one from each unit), and each of them affect both CREV trains, a Note is included that allows separate Condition entry for each Function. This changes the CTS by allowing the associated CREV System trains to be placed in the pressurization/cleanup mode, in lieu of requiring a unit shutdown. In addition, separate Condition entry is allowed for each of the two SI Input from ESFAS Functions.

The purpose of the requirements for the SI Input from ESFAS Functions is to ensure the associated CREV trains are capable of being automatically placed in the pressurization/cleanup mode. The proposed ACTIONS ensure that the function of each inoperable SI Input from ESFAS actuation instrumentation train is satisfied by requiring the associated CREV train to be placed in the pressurization/cleanup mode, since this places the associated CREV train in the post accident operating condition. The 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. This change is acceptable because the ACTIONS are consistent with safe operation under the specified Condition, considering the status of the associated CREV System train(s) (i.e.,

the associated train(s) are in the post accident operating condition), and the low probability of a DBA occurring during the time period. If the associated train(s) are not placed in the pressurization/cleanup mode, the ITS ACTIONS will require the unit to be shut down, consistent with current requirements. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.7.5.1.e.2.a requires the verification that on a Safety Injection Signal from the associated unit, the system automatically operates.

CTS 4.7.5.1.e.2.b requires the verification that on a Safety Injection Signal from the other unit, the system automatically operates. ITS SR 3.3.7.1 requires a TADOT to be performed every 24 months. The TADOT is performed on each of the trains for the Unit 1 and Unit 2 SI Input from ESFAS Function. 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). It also changes the CTS by defining this test as a TADOT.

The purpose of CTS 4.7.5.1.e.2 is to ensure the CREV System trains start automatically. 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 not revealed any time-based failure mechanisms.

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 CREV trains is acceptable because the CREV trains are verified to be operating properly throughout the operating cycle by requiring each CREV train to be operated for CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 8, Rev. 0, Page 661 of 818

Attachment 1, Volume 8, Rev. 0, Page 662 of 818 DISCUSSION OF CHANGES ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION INSTRUMENTATION

> 15 minutes every 184 days. This testing ensures that a significant portion of the CREV circuitry is operating properly and will detect significant failures of this circuitry. Additional justification for extending the Surveillance test interval is that the CREV trains, including the actuating logic, is designed to be single failure, therefore ensuring system availability in the event of a failure of one CREV train.

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. The change defining the test as a TADOT is acceptable because it is essentially the same requirement; it is ensuring the CREV System receives the applicable automatic start signals. The actual actuation of the CREV System components (e.g., fans) is verified in an ITS 3.7.10 Surveillance. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 8, Rev. 0, Page 662 of 818

Attachment 1, Volume 8, Rev. 0, Page 663 of 818 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 668 of 818 3.3.7 6

INSERT 1 (Unit 1 only)

1. Safety Injection (SI) Input from 1, 2, 3, 4 2 trains NA Engineered Safety Features Actuation System (ESFAS)

2. Unit 2 SI Input from ESFAS (a) 2 trains NA 6 INSERT 1 (Unit 2 only)

1. Safety Injection (SI) Input from 1, 2, 3, 4 2 trains NA Engineered Safety Features Actuation System (ESFAS)

2. Unit 1 SI Input from ESFAS (a) 2 trains NA 6 INSERT 2 (Unit 1 only)

(a) When Unit 2 is in MODE 1, 2, 3, or 4 and Unit 1 is in MODE 1, 2, 3, or 4.

6 INSERT 2 (Unit 2 only)

(a) When Unit 1 is in MODE 1, 2, 3, or 4 and Unit 2 is in MODE 1, 2, 3, or 4.

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Attachment 1, Volume 8, Rev. 0, Page 669 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION INSTRUMENTATION

1. The title of ISTS 3.3.7, Control Room Emergency Filtration System (CREFS)

Actuation Instrumentation, has been revised in ITS 3.3.7 to reflect the plant specific nomenclature (i.e., Control Room Emergency Ventilation (CREV) System Actuation Instrumentation). Corresponding changes have also been made to the ISTS 3.3.7 Header, LCO, Required Actions, Surveillance Requirements Note and Table 3.3.7-1.

2. The plant specific design of the CREV System actuation instrumentation includes two trains of Safety Injection (SI) Input from Engineered Safety Features Actuation System (ESFAS) Function and two trains of SI Input from ESFAS Function from the opposite unit. These Functions are arranged such that any one of the four trains will initiate actuation of an associated CREV train. However, the opposite unit SI Input from ESFAS Function is only required to be OPERABLE when the opposite unit is in MODE 1, 2, 3, or 4. Therefore, the opposite unit SI Input from ESFAS will not always be required to be OPERABLE. As a result, the word "required" is added to ISTS 3.3.7 Conditions A and B to reflect that each of the Functions may not always be required to be OPERABLE to meet the LCO and ISTS 3.3.7 Required Action A.1 is revised to reflect placing the "associated" CREV train in pressurization/cleanup mode of operation. In addition, the references to "channels" in ISTS 3.3.7 Conditions A and B are deleted since the requirements for each of the Functions are presented on a "train" basis, not a "channel" basis.

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

4. The references to the "emergency [radiation protection] mode" in ISTS 3.3.7 ACTIONS A and B are revised to "pressurization/cleanup mode" in ITS 3.3.7 ACTIONS A and B. This change reflects the CNP Units 1 and 2 specific nomenclature.

5. ISTS 3.3.7 ACTIONS D and E provide requirements that are applicable during movement of [recently] irradiated fuel assemblies and in MODE 5 or 6, respectively.

These ACTIONS are not included in ITS 3.3.7, consistent with CNP Unit 1 and Unit 2 specific design, analysis, and licensing basis for CREV System actuation. During movement of irradiated fuel assemblies, the fuel handling accident analysis assumes manual actuation of the CREV trains. Individual component controls are used for manually isolating the normal fresh-air intake and manually starting the emergency pressurization/cleanup filter unit of the CREV System. During other times in MODE 5 or 6, the CREV System is not required OPERABLE; thus, the Functions are not required. Therefore, ITS 3.3.7 does not include requirements that are applicable during these MODES or specified conditions. As a result of the deletion of ISTS 3.3.7 ACTIONS D and E (which reference MODES or conditions other than MODES 1, 2, 3, and 4), the reference to "MODE 1, 2, 3, or 4" in ISTS 3.3.7 Condition C is unnecessary and is deleted.

6. ISTS Table 3.3.7-1 is revised to reflect the plant specific nomenclature, design, analysis, and licensing basis for Functions in ITS Table 3.3.7-1, CREV System Actuation Instrumentation. This includes the deletion of ISTS Table 3.3.7-1 Functions 1 (Manual Initiation), 2 (Automatic Actuation Logic and Actuation Relays),

and 3 (Control Room Radiation). ISTS Table 3.3.7-1 Function 4 (ITS Table 3.3.7-1 Functions 1 and 2) is revised to reflect that the SI Input from ESFAS Functions from CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 669 of 818

Attachment 1, Volume 8, Rev. 0, Page 670 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION INSTRUMENTATION both units provide the CREV System actuation. In addition, ISTS Table 3.3.7-1 Footnote (a) is revised to reflect the plant specific design and analysis basis for the SI Input from ESFAS Functions.

7. The ISTS 3.3.7 Surveillance Requirements are revised to reflect the CNP Units 1 and 2 current licensing basis and testing practices for the CREV System Actuation Instrumentation Functions. The Functions included in ITS Table 3.3.7-1 are the SI Input from ESFAS Functions. For these Functions, the applicable Surveillance Requirement is the performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT), ISTS SR 3.3.7.6. The other ISTS 3.3.7 Surveillance Requirements (ISTS SRs 3.3.7.1, 3.3.7.2, 3.3.7.3, 3.3.7.4, 3.3.7.5, and 3.3.7.7) are not applicable to the SI Input to ESFAS Functions and are deleted. In addition, ISTS SR 3.3.7.6 is renumbered (ITS SR 3.3.7.1). Due to the deletion of all but one of the SRs, the Note to the SRs is not necessary. Thus, the Note has been deleted, as well as the Surveillance Requirements column in Table 3.3.7-1, and ISTS SR 3.3.7.6 has been revised to state it is applicable to all required Functions, similar to the SRs in ISTS 3.3.3.

8. ISTS SR 3.3.7.6 (ITS SR 3.3.7.1) requires the performance of a TADOT for the SI Input from ESFAS Functions. ISTS SR 3.3.7.6 is modified by a note, which states "Verification of setpoint is not required." The SI Input from ESFAS Functions 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 the SI Input from ESFAS Functions, the TADOT definition does not require verification of setpoints. Therefore, the Note to ISTS SR 3.3.7.6 is unnecessary and is deleted.

9. ISTS Table 3.3.7-1 includes requirements for Trip Setpoints for the CREV System actuation instrumentation. The term "TRIP SETPOINT" is revised to "ALLOWABLE VALUE" in ITS Table 3.3.7-1 to reflect OPERABILITY limits for the channels of the CREV System Actuation Instrumentation Functions. This change achieves consistency with the OPERABILITY requirements for other actuation instrumentation channels in ISTS Section 3.3.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 670 of 818

Attachment 1, Volume 8, Rev. 0, Page 671 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 673 of 818 B 3.3.7 1

INSERT 1 the Control Room Air Conditioning (CRAC) System portion of the Control Room Ventilation System is operated in the air conditioning mode, which is further described in the Bases of LCO 3.7.11, Control Room Air Conditioning (CRAC) System.

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Attachment 1, Volume 8, Rev. 0, Page 675 of 818 B 3.3.7 2 INSERT 2

1. Safety Injection (SI) Input from Engineered Safety Features Actuation System (ESFAS)

The SI Input from ESFAS ensures that the ESFAS automatic actuation logic will actuate the CREV System upon any signal that initiates SI. Actuation of the CREV System on an SI signal ensures that, in the event of conditions that may result in a radiological release, the control room will be maintained habitable.

Allowable Values are not applicable to this Function. The SI Input from ESFAS signal directly inputs to CREV System actuation logic. There are two trains of SI Input from ESFAS, with each train inputting to the associated CREV train (i.e.,

one SI Input from ESFAS signal starts one CREV train while the other SI Input from ESFAS signal starts the other CREV train). The LCO requires two trains of SI Input from ESFAS to be OPERABLE in MODE 1, 2, 3, or 4.

2. Unit 2 (Unit 1) and Unit 1 (Unit 2) SI Input from ESFAS Unit 2 (Unit 1) and Unit 1 (Unit 2) SI Input from ESFAS ensures the Unit 2 (Unit

1) and Unit 1 (Unit 2) ESFAS automatic actuation logic will actuate the CREV System upon any signal that initiates Unit 2 (Unit 1) and Unit 1 (Unit 2) SI.

Actuation of the CREV System on a Unit 2 (Unit 1) and Unit 1 (Unit 2) SI signal ensures that, in the event of conditions that may result in a radiological release from Unit 2 (Unit 1) and Unit 1 (Unit 2), the control room will be maintained habitable. Allowable Values are not applicable to this Function. The Unit 2 (Unit

1) and Unit 1 (Unit 2) SI Input from ESFAS signal directly inputs to CREV System actuation logic. There are two trains of Unit 2 (Unit 1) and Unit 1 (Unit 2) SI Input from ESFAS, with each train inputting to the associated CREV train (i.e., one SI Input from ESFAS signal starts one CREV train while the other SI Input from ESFAS signal starts the other CREV train). The LCO requires two trains of Unit 2 (Unit 1) and Unit 1 (Unit 2) SI Input from ESFAS to be OPERABLE when Unit 2 (Unit 1) and Unit 1 (Unit 2) is in MODE 1, 2, 3, or 4 and Unit 1 (Unit 1) and Unit 2 (Unit 2) is in MODE 1, 2, 3, or 4.

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Attachment 1, Volume 8, Rev. 0, Page 677 of 818 B 3.3.7 2 INSERT 3 and when Unit 2 (Unit 1) and Unit 1 (Unit 2) is in MODE 1, 2, 3, or 4 1 2 INSERT 4 The CREV System Actuation Instrumentation is not required in MODES 5 and 6 since the CREV System is not required OPERABLE in these MODES. During movement of irradiated fuel assemblies, CREV System Actuation Instrumentation Functions are not required to be OPERABLE since the fuel handling accident analysis assumes manual actuation of the CREV trains. The controls for manually isolating the normal fresh-air intake and manually starting the emergency pressurization/cleanup filter unit of the CREV System are located in the control room and the air conditioning equipment room and can be manually actuated from either room.

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Attachment 1, Volume 8, Rev. 0, Page 683 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.7 BASES, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION 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. Changes are made to reflect changes made to the Specification.

3. Changes are made to reflect the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 683 of 818

Attachment 1, Volume 8, Rev. 0, Page 684 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 684 of 818

Attachment 1, Volume 8, Rev. 0, Page 685 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.7, CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ACTUATION 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 685 of 818

Attachment 1, Volume 8, Rev. 0, Page 686 of 818 ATTACHMENT 8 ITS 3.3.8, Boron Dilution Monitoring Instrumentation (BDMI)

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Attachment 1, Volume 8, Rev. 0, Page 688 of 818 ITS 3.3.8 A.1 ITS LCO 3.3.8 A.2 See ITS 3.3.1 SR 3.3.8.1, SR 3.3.8.2 A.3 See ITS 3.3.1 A.4 A.4 Page 1 of 10 Attachment 1, Volume 8, Rev. 0, Page 688 of 818

Attachment 1, Volume 8, Rev. 0, Page 689 of 818 ITS 3.3.8 A.1 See ITS See ITS See ITS LA.1 LA.1 3.3.1 3.3.1 3.3.1 LCO 3.3.8, ITS Applicability, and ACTION A Page 2 of 10 Attachment 1, Volume 8, Rev. 0, Page 689 of 818

Attachment 1, Volume 8, Rev. 0, Page 690 of 818 ITS 3.3.8 A.1 ITS See ITS 3.3.1 L.1 ACTION A Add proposed Note 1 to Required Action A.1 L.2 or equal to required limit LA.2 SR 3.1.1.1 A.1 LA.3 required limit LA.2 LA.3 See ITS 3.3.1 Page 3 of 10 Attachment 1, Volume 8, Rev. 0, Page 690 of 818

Attachment 1, Volume 8, Rev. 0, Page 691 of 818 ITS 3.3.8 A.1 ITS A.3 SR 3.3.8.1 SR 3.3.8.2 See ITS 3.3.1 See ITS SR 3.3.8.1, 3.3.1

-1 2-SR 3.3.8.2, Applicability 24 months L.3 See ITS 3.3.1 Page 4 of 10 Attachment 1, Volume 8, Rev. 0, Page 691 of 818

Attachment 1, Volume 8, Rev. 0, Page 692 of 818 ITS 3.3.8 A.1 ITS See ITS 3.3.1 Note to SR 3.3.8.2 See ITS 3.3.1 Page 5 of 10 Attachment 1, Volume 8, Rev. 0, Page 692 of 818

Attachment 1, Volume 8, Rev. 0, Page 693 of 818 ITS 3.3.8 A.1 ITS LCO 3.3.8 A.2 See ITS 3.3.1 SR 3.3.8.1, SR 3.3.8.2 A.3 See ITS 3.3.1 A.4 A.4 Page 6 of 10 Attachment 1, Volume 8, Rev. 0, Page 693 of 818

Attachment 1, Volume 8, Rev. 0, Page 694 of 818 ITS 3.3.8 A.1 See ITS See ITS See ITS LA.1 LA.1 3.3.1 3.3.1 3.3.1 ITS LCO 3.3.8, Applicability, and ACTION A Page 7 of 10 Attachment 1, Volume 8, Rev. 0, Page 694 of 818

Attachment 1, Volume 8, Rev. 0, Page 695 of 818 ITS 3.3.8 A.1 ITS See ITS 3.3.1 L.1 ACTION A Add proposed Note 1 to Required Action A.1 L.2 or equal to required limit LA.2 SR 3.1.1.1 A.1 LA.3 required limit LA.2 LA.3 See ITS 3.3.1 Page 8 of 10 Attachment 1, Volume 8, Rev. 0, Page 695 of 818

Attachment 1, Volume 8, Rev. 0, Page 696 of 818 ITS 3.3.8 A.1 See ITS A.3 See ITS See ITS 24 months 3.3.1 L.3 3.3.1 3.3.1 SR 3.3.8.2 2-SR 3.3.8.1

-1 SR 3.3.8.1, SR 3.3.8.2, ITS Applicability Page 9 of 10 Attachment 1, Volume 8, Rev. 0, Page 696 of 818

Attachment 1, Volume 8, Rev. 0, Page 697 of 818 ITS 3.3.8 A.1 ITS See ITS 3.3.1 Note to SR 3.3.8.2 See ITS 3.3.1 Page 10 of 10 Attachment 1, Volume 8, Rev. 0, Page 697 of 818

Attachment 1, Volume 8, Rev. 0, Page 698 of 818 DISCUSSION OF CHANGES ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

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, "Reactor Trip System Instrumentation," requires the Reactor Trip System instrumentation channels and interlocks shown in Table 3.3-1 to be OPERABLE. ITS 3.3.8, "Boron Dilution Monitoring Instrumentation (BDMI),"

requires one source range neutron flux monitoring channel to be OPERABLE.

This changes the CTS by having a separate Specification for the Boron Dilution Monitoring Instrumentation, in lieu of including it with the Reactor Trip System Instrumentation Specification.

This change is acceptable because the technical requirements for the source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation are maintained with the change in format. The Boron Dilution Monitoring Instrumentation Specification continues to require the OPERABILITY of the source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 4.3.1.1.1 and Table 4.3-1 require that the source range neutron flux monitoring channel be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST once per 31 days and each unit startup, if not performed in the previous 7 days. ITS 3.3.8 does not include this Surveillance Requirement. This changes the CTS by deleting the CHANNEL FUNCTIONAL TEST requirement for the source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation.

The CTS requirement to perform a CHANNEL FUNCTIONAL TEST only applies to the Reactor Trip System function of the source range neutron flux monitor channels. For the Boron Dilution Monitoring Instrumentation requirements, the source range neutron flux channel only provides indication; there is no trip or alarm feature assumed. Thus, to meet the Boron Dilution Monitoring Instrumentation requirements, a CHANNEL FUNCTIONAL TEST is not required.

This is also consistent with the MODE 6 source range neutron flux monitoring requirements in ITS 3.9.2. ITS 3.9.2 does not require a CHANNEL FUNCTIONAL TEST, since the source range neutron flux monitors safety function requirements in MODE 6 do not require any trip or alarm features. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.3.1.1.3 and the

footnote require REACTOR TRIP SYSTEM RESPONSE TIME testing of "each" reactor trip function. ITS 3.3.8 does not include response time testing for the source range neutron flux monitoring channel of the Boron CNP Units 1 and 2 Page 1 of 6 Attachment 1, Volume 8, Rev. 0, Page 698 of 818

Attachment 1, Volume 8, Rev. 0, Page 699 of 818 DISCUSSION OF CHANGES ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

Dilution Monitoring Instrumentation. This changes the CTS by clearly identifying that the REACTOR TRIP SYSTEM RESPONSE TIME testing does not apply to the source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation.

The purpose of the CTS 4.3.1.1.3 requirements is to ensure that the actuation response times are less than or equal to the maximum values assumed in the accident analysis. UFSAR Table 7.2-6, which was previously in CTS 3.3.1 as Table 3.3-2, only specifies response times for those Reactor Trip System Functions assumed in the CNP safety analysis. CTS Table 3.3-2 did not include response times for any of the CTS 3.3.1 Source Range Neutron Flux Functions.

Therefore, this change is acceptable since REACTOR TRIP SYSTEM RESPONSE TIME testing of the Source Range Neutron Flux Functions was not required. These response times were removed from CTS 3.3.1 and placed under CNP control as documented in the NRC Safety Evaluation for License Amendments 202 (Unit 1) and 187 (Unit 2). In addition, UFSAR Table 7.2-6 currently does not require response time testing of any of the CTS 3.3.1 Source Range Neutron Flux Functions. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-1 for Reactor Trip System instrumentation has three columns stating various requirements for the Source Range Neutron Flux Functions. These columns are labeled, "TOTAL NO. OF CHANNELS,"

"CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." For CTS Table 3.3-1 Function 6.b, the "CHANNELS TO TRIP" column entry is "0" (i.e., the Function is required to provide an indication only function and is not required to have a trip function). ITS 3.3.8 does not retain the "TOTAL NO. OF CHANNELS" and "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 "CHANNELS TO TRIP" information is presented in the form of a description of the indication requirements for the source range neutron flux channel of the Boron Dilution Monitoring 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 requirement for CNP Units 1 and 2 Page 2 of 6 Attachment 1, Volume 8, Rev. 0, Page 699 of 818

Attachment 1, Volume 8, Rev. 0, Page 700 of 818 DISCUSSION OF CHANGES ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI) 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.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.3-1 Action 5.a provides the allowance to continue to add water from the Refueling Water Storage Tank (RWST) provided the RWST boron concentration is greater than the minimum required by other Technical Specifications. CTS Table 3.3-1 Action 5.c provides the allowance to not isolate the RWST in MODE 5 provided RWST boron concentration is greater than or equal to Reactor Coolant System (RCS) boron concentration or greater than or equal to the minimum required by another Technical Specification.

Note 2 to ITS 3.3.8 Required Action A.1 and ITS 3.3.8 Required Action A.4.1 provide these same allowances, but require that RWST boron concentration be greater than or equal to required limit. This changes the CTS by moving the details of the required RWST boron concentration limits from the Technical Specifications to the Bases.

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 retains the requirement for the RWST boron concentration to be within required limits in order to utilize the allowances to continue to add water from the RWST and to not require isolation of the RWST in MODE 5. 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 procedural details for meeting Technical Specification requirements are 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 Action 5.c requires closure of the isolation valves for unborated sources "to the Chemical and Volume Control System." CTS Table 3.3-1 Action 5.c also requires the RWST to be isolated "from the Reactor Coolant System" if RWST boron concentration is not within the required limit in MODE 5. ITS 3.3.8 Required Action A.2 requires the unborated water source valves to be closed and ITS 3.3.8 Required Action A.4.2 requires the RWST to be isolated. This changes the CTS by moving the details of which unborated water source isolation valves and RWST valves to close from the Technical Specifications to the Bases.

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 CNP Units 1 and 2 Page 3 of 6 Attachment 1, Volume 8, Rev. 0, Page 700 of 818

Attachment 1, Volume 8, Rev. 0, Page 701 of 818 DISCUSSION OF CHANGES ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI) public health and safety. The ITS still retains the requirements for closure of the unborated water source isolation valves and isolation of the RWST. 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 procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 Action 5.a specifies the compensatory action for an inoperable required source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation.

One of the compensatory actions is the immediate suspension of positive reactivity changes. ITS 3.3.8 Required Action A.1 requires the immediate suspension of operations involving positive reactivity additions. ITS 3.3.8 Required Action A.1 is modified by Note 1, which states that unit temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN (SDM). This changes the CTS compensatory actions by allowing a positive reactivity change due to unit temperature changes, as long as SDM limitations are met.

The purpose of this CTS Table 3.3-1 Action 5.a is to suspend any positive reactivity additions that could affect the SDM of the reactor core. 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. Note 1 to ITS 3.3.8 Required Action A.1 will allow positive reactivity changes that are associated with temperature changes, provided the change is accounted for in the SDM calculation. The applicable requirements for SDM are specified in ITS LCO 3.1.1, "SHUTDOWN MARGIN (SDM)." The current and proposed actions may result in an overall reduction in SDM, but continue to ensure the required SDM is maintained and provides acceptable margin to maintaining subcritical operation. Therefore, these limitations are considered acceptable. The ITS Bases also indicate that introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient must also be evaluated to ensure they do not result in a loss of required SDM. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS Table 3.3-1 Action 5.a provides the allowance to add water from the Refueling Water Storage Tank (RWST) provided the RWST boron concentration is "greater than" the minimum required by other Technical Specifications. Note 2 to ITS 3.3.8 Required Action A.1 allows water to be added from the RWST provided the RWST boron concentration is "greater than or equal to" the required limit. This changes the CNP Units 1 and 2 Page 4 of 6 Attachment 1, Volume 8, Rev. 0, Page 701 of 818

Attachment 1, Volume 8, Rev. 0, Page 702 of 818 DISCUSSION OF CHANGES ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

CTS by allowing water to be added from the RWST provided the RWST boron concentration is "greater than or equal to" the required limit, instead of "greater than" the required limit.

The purpose of this CTS Table 3.3-1 Action 5.a is to suspend any positive reactivity additions that could affect the SDM of the reactor core. 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. Note 2 to ITS 3.3.8 Required Action A.1 will allow water to be added from the RWST provided the RWST boron concentration is greater than or equal to the required limit. These required RWST boron concentration limits are established to ensure that SDM is maintained. This change is acceptable since the addition of water from the RWST, with RWST concentration equal to the required limit, ensures the required SDM is maintained and provides acceptable margin to maintaining subcritical operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS Table 4.3-1 requires a CHANNEL CALIBRATION of the Source Range Neutron Flux instrumentation every 18 months. ITS SR 3.3.8.2 requires the performance of a CHANNEL CALIBRATION for the required source range neutron flux monitoring channel 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 the CHANNEL CALIBRATION requirement of CTS Table 4.3-1 is to ensure the required source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation will function as designed during an analyzed event. Extending the SR Frequency is acceptable because the source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation is designed to be highly reliable. Furthermore, a CHANNEL CHECK for the required source range neutron flux monitoring channel of the Boron Dilution Monitoring Instrumentation is performed on a more frequent basis (ITS SR 3.3.8.1). The CHANNEL CHECK provides a qualitative demonstration of the OPERABILITY of the instrument.

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. The impacted source range neutron flux monitoring instrumentation was evaluated through a failure analysis and a qualitative drift analysis:

CTS Table 4.3-1, Functional Unit 6, Source Range, Neutron Flux This function is performed by SRM Neutron Flux Detectors (Westinghouse Model WL-23706), SRM Neutron Flux Drawers (Westinghouse Model 6051D50G01), a CNP Units 1 and 2 Page 5 of 6 Attachment 1, Volume 8, Rev. 0, Page 702 of 818

Attachment 1, Volume 8, Rev. 0, Page 703 of 818 DISCUSSION OF CHANGES ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

Weschler HX-252 Indicator, and a Tracor Westronics Recorders (Model 4200 (Unit 1) and Model 4220 (Unit 2)). 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.

Based on the design of the instrumentation and the qualitative 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. Those tests that were classified as failures were evaluated and primarily 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 unit licensing basis. 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 6 of 6 Attachment 1, Volume 8, Rev. 0, Page 703 of 818

Attachment 1, Volume 8, Rev. 0, Page 704 of 818 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 8, Rev. 0, Page 704 of 818

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Attachment 1, Volume 8, Rev. 0, Page 706 of 818 3.3.8 CTS 2 INSERT 1 LCO 3.3.1.1, One source range neutron flux monitoring channel Table 3.3-1 Function 6.B 5

INSERT 2 Table 3.3-1 2. Addition of water from the refueling water storage tank (RWST) is allowed provided Action 5 RWST boron concentration is greater than or equal to required limit.

Insert Page 3.3.9-1 Attachment 1, Volume 8, Rev. 0, Page 706 of 818

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Attachment 1, Volume 8, Rev. 0, Page 708 of 818 3.3.8 CTS 9 INSERT 3 AND Table -------------------------------------

3.3-1 - NOTE -

Action 5 Required Actions A.4.1 and A.4.2 are only applicable in MODE 5.

A.4.1 Verify RWST boron 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months concentration is greater than or equal to required limit.

OR A.4.2 Isolate RWST. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Insert Page 3.3.9-2 Attachment 1, Volume 8, Rev. 0, Page 708 of 818

Attachment 1, Volume 8, Rev. 0, Page 709 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

1. The numbering of ISTS 3.3.9, Boron Dilution Protection System (BDPS), has been revised to reflect the plant specific numbering (i.e., ITS 3.3.8). Corresponding changes have also been made to the ISTS 3.3.9 Header, LCO, Surveillance Requirements and page numbers. Also, the title of the Specification has been changed since an actual "Protection System" does not exist at CNP.

2. ISTS LCO 3.3.9 requires two trains of the BDPS to be OPERABLE. At CNP Units 1 and 2, mitigation of boron dilution accidents is provided by operator action in response to source range neutron flux monitor indication. Therefore, to achieve consistency with the CNP Units 1 and 2 design, analysis, and licensing basis, the ISTS 3.3.9 requirements are revised, in ITS LCO 3.3.8, to require one source range neutron flux monitoring channel to be OPERABLE. At CNP Units 1 and 2 there are two source range neutron flux monitoring channels. However, only one is required to be OPERABLE to meet the requirements of the CTS LCO. As a result, ISTS 3.3.9 ACTION A and the second Condition of ISTS 3.3.9 ACTION B, which address one of the two BDPS trains inoperable are deleted. In addition, ISTS 3.3.9 ACTION B requirements are renumbered as ITS 3.3.8 ACTION A and have been applied to the condition of one required channel inoperable. Furthermore, since the source range neutron flux monitor provides indication only, ISTS SR 3.3.9.2, the COT, has been deleted and the subsequent SR has been renumbered.

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

4. The ISTS 3.3.9 Applicability Note allows the boron dilution flux doubling signal to be blocked in MODES 2 and 3 during reactor startup. This Note is not included in ITS 3.3.8 since the CNP Units 1 and 2 design does not include a boron dilution flux doubling signal.

5. A second Note is added to ISTS 3.3.9 Required Action B.1 (ITS 3.3.8 Required Action A.1) to allow the addition of water from the Refueling Water Storage Tank (RWST) provided RWST boron concentration is greater than or equal to required limits. This change is made to reflect the allowances of the CNP Units 1 and 2 CTS.

As a result of this addition, the existing ISTS 3.3.9 Required Action A.1 Note is renumbered as Note 1.

6. ISTS 3.3.9 Required Action B.2.1 specifies, as an optional requirement, to restore one train to OPERABLE status. ITS 3.3.8 ACTION A does not include this requirement consistent with the CNP Units 1 and 2 CTS. In addition, the option to restore inoperable equipment within the specified Completion Times for Required Actions is always available. As stated in LCO 3.0.2, if the LCO is met or is no longer applicable prior to expiration of Completion Time(s), completion of Required Actions is not required unless otherwise stated. As a result of this change, the subsequent Required Actions are renumbered.

7. The ISTS 3.3.9 Required Action B.2.2.1 (ITS 3.3.8 Required Action A.2) is revised to reflect the CNP Units 1 and 2 current licensing basis and CTS Actions for closure of unborated water source isolation valves, which do not require RWST isolation valves to be closed in MODES 3 or 4. The Technical Specification Change Request (dated May 21, 1999) that provided these actions also added the requirement to isolate the RWST if minimum RWST boron concentration was not met in MODE 5. ITS 3.3.8 CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 709 of 818

Attachment 1, Volume 8, Rev. 0, Page 710 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

Required Action A.4.1 requires verification that RWST boron concentration is greater than or equal to the required limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If RWST boron concentration is less than the required limit, the RWST is considered a dilution source and is required to be isolated in accordance with ITS 3.3.8 Required Action A.4.2. ITS 3.3.8 Required Actions A.4.1 and A.4.2 are modified by a Note which states these Required Actions are only applicable in MODE 5. This Technical Specification Change Request stated that the requirement to isolate the RWST was not included for MODES 3 and 4 since, with RWST boron concentration not within limits, the Actions for CTS 3/4.1.2.8 (which are included in the ACTIONS of ITS LCO 3.5.4) would require a shutdown to MODE 5 if RWST boron concentration was not restored to within limits in the required allowed outage time. After the shutdown is complete, the MODE 5 requirement to isolate the RWST from the RCS would apply. These allowances were approved in License Amendments 230 (Unit 1) and 213 (Unit 2), dated October 21, 1999.

8. This format correction has been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03.

9. The reference to "Plant" in the Note to ISTS 3.3.9 Required Action B.1 is changed to "Unit" in Note 1 to ITS 3.3.8 Required Action A.1 to reflect CNP Units 1 and 2 specific nomenclature.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 710 of 818

Attachment 1, Volume 8, Rev. 0, Page 711 of 818 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 8, Rev. 0, Page 711 of 818

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Attachment 1, Volume 8, Rev. 0, Page 713 of 818 B 3.3.8 2 INSERT 1 provide indication of inadvertent positive reactivity changes when the reactor is in a shutdown condition (i.e., MODES 3, 4, and 5). Based on this indication, operator action can be taken to 2 INSERT 2 The source range neutron flux monitors are used to monitor the core reactivity condition.

The installed source range neutron flux monitors are part of the Nuclear Instrumentation System. These detectors are located external to the reactor vessel and detect neutrons leaking from the core.

The installed source range neutron flux monitors are BF3 detectors operating in the proportional region of the gas filled detector characteristic curve. The detectors monitor the neutron flux in counts per second. The instrument range covers six decades of neutron flux (1E+6 cps). The detectors also provide continuous visual indication in the control room and an audible count rate (selectable between the source range neutron flux monitor channels) to alert operators to a possible dilution accident.

2 INSERT 3 The source range neutron flux monitor channel of the BDMI is credited in the boron dilution accident analysis in the UFSAR (Ref. 1) to alert the operators of an event that could lead to an inadvertent criticality.

1 2 INSERT 4 one source range neutron flux monitor channel. To be considered OPERABLE, the source range neutron flux monitor channel must provide visual neutron flux indication in the control room.

Insert Page B 3.3.9-1 Attachment 1, Volume 8, Rev. 0, Page 713 of 818

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Attachment 1, Volume 8, Rev. 0, Page 715 of 818 B 3.3.8 2 INSERT 5 to indicate the need for operator action 1 INSERT 6 the requirements of LCO 3.9.2, "Nuclear Instrumentation," ensure that adequate instrumentation is available to indicate the need for operator action to mitigate an inadvertent dilution of the RCS.

Insert Page B 3.3.9-2 Attachment 1, Volume 8, Rev. 0, Page 715 of 818

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Attachment 1, Volume 8, Rev. 0, Page 717 of 818 B 3.3.8 1 INSERT 7 With the required source range neutron flux monitor channel of BDMI 2

INSERT 8 isolation valves for unborated water sources to the Chemical and Volume Control System, except refueling water storage tank (RWST) isolation valves, 1 INSERT 9 the required source range neutron flux monitor channel 2

INSERT 9A 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action is intended to confirm that the required SDM has been maintained and the periodic 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 1 INSERT 10 Required Action A.4.1 requires verification that RWST boron concentration is greater than or equal to the required limit. The required limit is the minimum boron concentration limit specified in LCO 3.5.4, "Refueling Water Storage Tank (RWST),"

(when the unit is in MODE 3 or 4) or the minimum RWST boron concentration limit specified in the TRM (when the unit is in MODE 5). If RWST boron concentration is not within the required limit, the RWST is considered a dilution source and is required to be isolated from the RCS in accordance with Required Action A.4.2. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Times are adequate to complete the requirements of Required Actions A.4.1 and A.4.2.

Insert Page B 3.3.9-3a Attachment 1, Volume 8, Rev. 0, Page 717 of 818

Attachment 1, Volume 8, Rev. 0, Page 718 of 818 B 3.3.8 1 INSERT 11 Note 2 permits addition of water from the RWST provided the RWST boron concentration is greater than or equal to required limit. The required limit is the minimum boron concentration limit specified in LCO 3.5.4, "Refueling Water Storage Tank (RWST)," (when the unit is in MODE 3 or 4) or the minimum RWST boron concentration limit specified in the TRM (when the unit is in MODE 5). These boron concentration limits are established to meet SDM requirements. Therefore, SDM is maintained when water is added to the RCS from the RWST provided RWST boron concentration is greater than or equal to the required limit.

Required Actions A.4.1 and A.4.2 are modified by a Note stating that these actions are only applicable in MODE 5. In MODES 3 and 4, these actions are not applicable since, with RWST boron concentration not within limits, the ACTIONS of LCO 3.5.4 would require a shutdown to MODE 5 if RWST boron concentration cannot be restored to within limits in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . After the shutdown to MODE 5 is complete, Required Actions A.4.1 and A.4.2 would apply.

Insert Page B 3.3.9-3b Attachment 1, Volume 8, Rev. 0, Page 718 of 818

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Attachment 1, Volume 8, Rev. 0, Page 721 of 818 B 3.3.8 4 INSERT 12 The CHANNEL CALIBRATION also includes obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturers data. This SR is modified by a Note that states that neutron detectors are excluded from the CHANNEL CALIBRATION.

Insert Page B 3.3.9-5 Attachment 1, Volume 8, Rev. 0, Page 721 of 818

Attachment 1, Volume 8, Rev. 0, Page 722 of 818 JUSTIFICATION FOR DEVIATIONS ITS 3.3.8 BASES, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

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

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

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

4. Changes are made to reflect the Specification and for consistency with similar Bases for the source range monitors.

5. Grammatical/typographical error corrected.

6. The paragraph has been moved since it is discussing modifications to Required Action A.1.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 722 of 818

Attachment 1, Volume 8, Rev. 0, Page 723 of 818 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 8, Rev. 0, Page 724 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.3.8, BORON DILUTION MONITORING INSTRUMENTATION (BDMI)

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 724 of 818

Attachment 1, Volume 8, Rev. 0, Page 725 of 818 ATTACHMENT 9 Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 8, Rev. 0, Page 725 of 818

Attachment 1, Volume 8, Rev. 0, Page 726 of 818 CTS 3/4.3.3.1, RADIATION MONITORING INSTRUMENTATION Attachment 1, Volume 8, Rev. 0, Page 726 of 818

Attachment 1, Volume 8, Rev. 0, Page 727 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

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, Volume 8, Rev. 0, Page 728 of 818 CTS 3/4.3.3.1 LA.1 LA.2 Page 1 of 12 , Volume 8, Rev. 0, Page 728 of 818

, Volume 8, Rev. 0, Page 729 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.3 See ITS 3.3.6 and ITS 3.4.15 LA.1 LA.2 LA.2 LA.1 LA.2 LA.1 LA.2 LA.2 LA.1 Page 2 of 12 , Volume 8, Rev. 0, Page 729 of 818

, Volume 8, Rev. 0, Page 730 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.6 LA.1 LA.1 Page 3 of 12 , Volume 8, Rev. 0, Page 730 of 818

, Volume 8, Rev. 0, Page 731 of 818 CTS 3/4.3.3.1 See ITS 3.4.15 LA.1 See ITS 3.3.6 See ITS 3.3.3 See ITS 5.6 See ITS 3.3.3 LA.1 Page 4 of 12 , Volume 8, Rev. 0, Page 731 of 818

, Volume 8, Rev. 0, Page 732 of 818 CTS 3/4.3.3.1 LA.2 See ITS 3.3.3 See ITS 3.4.15 LA.1 LA.2 LA.2 LA.1 LA.2 LA.1 LA.2 LA.2 LA.1 Page 5 of 12 , Volume 8, Rev. 0, Page 732 of 818

, Volume 8, Rev. 0, Page 733 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.6 See ITS 3.3.6 and ITS 3.4.15 See ITS 3.3.6 See ITS 3.3.6 and ITS 3.4.15 LA.1 See ITS 3.3.6 and ITS 3.4.15 LA.1 Page 6 of 12 , Volume 8, Rev. 0, Page 733 of 818

, Volume 8, Rev. 0, Page 734 of 818 CTS 3/4.3.3.1 LA.1 LA.2 Page 7 of 12 , Volume 8, Rev. 0, Page 734 of 818

, Volume 8, Rev. 0, Page 735 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.3 See ITS 3.3.6 and ITS 3.4.15 LA.1 LA.2 LA.2 LA.1 LA.2 LA.1 LA.2 LA.2 LA.1 Page 8 of 12 , Volume 8, Rev. 0, Page 735 of 818

, Volume 8, Rev. 0, Page 736 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.6 LA.1 LA.1 Page 9 of 12 , Volume 8, Rev. 0, Page 736 of 818

, Volume 8, Rev. 0, Page 737 of 818 CTS 3/4.3.3.1 See ITS 3.4.15 LA.1 See ITS 3.3.6 See ITS 3.3.3 See ITS 5.6 See ITS 3.3.3 LA.1 Page 10 of 12 , Volume 8, Rev. 0, Page 737 of 818

, Volume 8, Rev. 0, Page 738 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.3 See ITS 3.4.15 LA.1 LA.2 LA.2 LA.1 LA.2 LA.1 LA.2 LA.2 LA.1 Page 11 of 12 , Volume 8, Rev. 0, Page 738 of 818

, Volume 8, Rev. 0, Page 739 of 818 CTS 3/4.3.3.1 LA.1 See ITS 3.3.6 See ITS 3.3.6 and ITS 3.4.15 See ITS 3.3.6 See ITS 3.3.6 and ITS 3.4.15 LA.1 See ITS 3.3.6 and ITS 3.4.15 LA.1 Page 12 of 12 , Volume 8, Rev. 0, Page 739 of 818

Attachment 1, Volume 8, Rev. 0, Page 740 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.1, RADIATION MONITORING INSTRUMENTATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms) CTS 3/4.3.3.1 provides requirements for the radiation monitoring instrumentation in CTS Tables 3.3-6 and 4.3-3. CTS Table 3.3-6 and Table 4.3-3 provide requirements for the following radiation monitoring instruments: Upper Containment Area Monitor (Instrument 1.A.i); Noble Gas Effluent Monitors (Instruments 1.C.i.b, 1.C.i.c, 1C.ii.a, 1C.ii.b, 1C.ii.c, 1C.ii.d, 1.C.iv.b, and 1.C.iv.c); and Spent Fuel Storage Radiation Monitor (Instrument 3.A). The ITS does not include requirements for these radiation monitoring instruments. The Technical Specification function of these radiation monitoring instruments is only to provide indication and alarms. This changes the CTS by relocating the requirements for these radiation monitoring instruments to the Technical Requirements Manual (TRM).

The removal of requirements for indication-only instrumentation and alarms 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. These instruments and alarms are not required to be OPERABLE to support OPERABILITY of the Technical Specification systems or components. Therefore, the availability of this instrumentation and alarms is more appropriately specified in the plant procedures that are required by ITS 5.4.1. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is incorporated by reference into the UFSAR and 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 performance requirements for indication-only instrumentation and alarms are being removed from the Technical Specifications.

LA.2 (Type 6 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 3/4.3.3.1 provides requirements for the radiation monitoring instrumentation in CTS Tables 3.3-6 and 4.3-3. CTS Table 3.3-6 and Table 4.3-3 provide requirements for the following radiation monitoring instruments: Noble Gas Effluent Monitors (Instruments 1.C.i.a, 1.C.iii.a, and 1.C.iv.a). These instruments ensure 10 CFR 20 limits are met. The ITS does not CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 740 of 818

Attachment 1, Volume 8, Rev. 0, Page 741 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.1, RADIATION MONITORING INSTRUMENTATION include requirements for these radiation monitoring instruments. This changes the CTS by moving the requirements for these radiation monitoring instrumentation to the Offsite Dose Calculation Manual (ODCM).

The purpose of the radiation monitoring channels is to ensure the 10 CFR 20 limits are met. The removal of these requirements for radiation monitoring instrumentation 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. This change is acceptable because these types of requirements will be adequately controlled in the ODCM. Changes to the ODCM are controlled by the ODCM change control process in ITS Section 5.5, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because the requirements for a program are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 741 of 818

Attachment 1, Volume 8, Rev. 0, Page 742 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 742 of 818

Attachment 1, Volume 8, Rev. 0, Page 743 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.3.3.1, RADIATION MONITORING 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 743 of 818

, Volume 8, Rev. 0, Page 744 of 818 CTS 3/4.3.3.2, MOVABLE INCORE DETECTORS , Volume 8, Rev. 0, Page 744 of 818

Attachment 1, Volume 8, Rev. 0, Page 745 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 8, Rev. 0, Page 745 of 818

, Volume 8, Rev. 0, Page 746 of 818 CTS 3/4.3.3.2 R.1 Page 1 of 2 , Volume 8, Rev. 0, Page 746 of 818

, Volume 8, Rev. 0, Page 747 of 818 CTS 3/4.3.3.2 R.1 Page 2 of 2 , Volume 8, Rev. 0, Page 747 of 818

Attachment 1, Volume 8, Rev. 0, Page 748 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.2, MOVABLE INCORE DETECTORS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.3.3.2 ensures the OPERABILITY of movable incore detector instrumentation when required to monitor the flux distribution within the core.

The instrumentation is used for periodic Surveillance of the reactor core power distribution, and calibration of the excore neutron flux detectors, but is not assumed in any design basis accident (DBA) analysis and does not mitigate an accident. This Specification does not meet the criteria for retention in the Improved Technical Specifications (ITS); therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.3.3.2 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The movable incore detectors are not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Movable Incore Detectors Specification does not satisfy criterion 1.

2. The movable incore detectors are not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Movable Incore Detectors Specification does not satisfy criterion 2.

3. The movable incore detectors are not part of a primary success path in the mitigation of a DBA or transient. The Movable Incore Detectors Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-12) and summarized in Table 1 of WCAP-11618, the loss of movable incore detectors was found to be a non-significant risk contributor to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Movable Incore Detectors Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Movable Incore Detectors LCO and Surveillances may be relocated out of the Technical Specifications. The Movable Incore Detectors Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 748 of 818

Attachment 1, Volume 8, Rev. 0, Page 749 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.2, MOVABLE INCORE DETECTORS 10 CFR 50.59. This change is designated as a relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 749 of 818

Attachment 1, Volume 8, Rev. 0, Page 750 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 750 of 818

Attachment 1, Volume 8, Rev. 0, Page 751 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.3.3.2, MOVABLE INCORE DETECTORS 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 751 of 818

, Volume 8, Rev. 0, Page 752 of 818 CTS 3/4.3.3.3, SEISMIC INSTRUMENTATION , Volume 8, Rev. 0, Page 752 of 818

Attachment 1, Volume 8, Rev. 0, Page 753 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 8, Rev. 0, Page 753 of 818

, Volume 8, Rev. 0, Page 754 of 818 CTS 3/4.3.3.3 R.1 Page 1 of 6 , Volume 8, Rev. 0, Page 754 of 818

, Volume 8, Rev. 0, Page 755 of 818 CTS 3/4.3.3.3 R.1 Page 2 of 6 , Volume 8, Rev. 0, Page 755 of 818

, Volume 8, Rev. 0, Page 756 of 818 CTS 3/4.3.3.3 R.1 Page 3 of 6 , Volume 8, Rev. 0, Page 756 of 818

, Volume 8, Rev. 0, Page 757 of 818 CTS 3/4.3.3.3 R.1 Page 4 of 6 , Volume 8, Rev. 0, Page 757 of 818

, Volume 8, Rev. 0, Page 758 of 818 CTS 3/4.3.3.3 R.1 Page 5 of 6 , Volume 8, Rev. 0, Page 758 of 818

, Volume 8, Rev. 0, Page 759 of 818 CTS 3/4.3.3.3 R.1 Page 6 of 6 , Volume 8, Rev. 0, Page 759 of 818

Attachment 1, Volume 8, Rev. 0, Page 760 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.3, SEISMIC INSTRUMENTATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.3.3.3 provides requirements for seismic instrumentation. In the event of an earthquake, seismic instrumentation is required to permit comparison of the measured response to that used in the design basis of the facility to determine if plant shutdown is required pursuant to Appendix A of 10 CFR 100. Since this is determined after the event has occurred, it has no bearing on the mitigation of any design basis accident (DBA). This Specification does not meet the criteria for retention in the Improved Technical Specifications (ITS); therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.3.3.3 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. Seismic instrumentation is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Seismic Instrumentation Specification does not satisfy criterion 1.

2. Seismic instrumentation is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Seismic Instrumentation Specification does not satisfy criterion 2.

3. Seismic instrumentation is not part of a primary success path in the mitigation of a DBA or transient. The Seismic Instrumentation Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-22), and summarized in Table 1 of WCAP-11618, the loss of seismic instrumentation was found to be a non-significant risk contributor to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Seismic Instrumentation Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Seismic Instrumentation LCO and Surveillances may be relocated out of the Technical Specifications. The Seismic Instrumentation Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 760 of 818

Attachment 1, Volume 8, Rev. 0, Page 761 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.3, SEISMIC INSTRUMENTATION This change is designated as a relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 761 of 818

Attachment 1, Volume 8, Rev. 0, Page 762 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 762 of 818

Attachment 1, Volume 8, Rev. 0, Page 763 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.3.3.3, SEISMIC 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 763 of 818

Attachment 1, Volume 8, Rev. 0, Page 764 of 818 CTS 3/4.3.3.4, METEOROLOGICAL INSTRUMENTATION Attachment 1, Volume 8, Rev. 0, Page 764 of 818

Attachment 1, Volume 8, Rev. 0, Page 765 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 8, Rev. 0, Page 765 of 818

, Volume 8, Rev. 0, Page 766 of 818 CTS 3/4.3.3.4 R.1 Page 1 of 6 , Volume 8, Rev. 0, Page 766 of 818

, Volume 8, Rev. 0, Page 767 of 818 CTS 3/4.3.3.4 R.1 Page 2 of 6 , Volume 8, Rev. 0, Page 767 of 818

, Volume 8, Rev. 0, Page 768 of 818 CTS 3/4.3.3.4 R.1 Page 3 of 6 , Volume 8, Rev. 0, Page 768 of 818

, Volume 8, Rev. 0, Page 769 of 818 CTS 3/4.3.3.4 R.1 Page 4 of 6 , Volume 8, Rev. 0, Page 769 of 818

, Volume 8, Rev. 0, Page 770 of 818 CTS 3/4.3.3.4 R.1 Page 5 of 6 , Volume 8, Rev. 0, Page 770 of 818

, Volume 8, Rev. 0, Page 771 of 818 CTS 3/4.3.3.4 R.1 Page 6 of 6 , Volume 8, Rev. 0, Page 771 of 818

Attachment 1, Volume 8, Rev. 0, Page 772 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.4, METEOROLOGICAL INSTRUMENTATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.3.3.4 provides requirements for meteorological instrumentation.

Meteorological instrumentation is used to measure environmental parameters that may affect distribution of fission products and gases following a design basis accident (DBA), but it is not an input assumption for any DBA analysis and does not mitigate the accident. Meteorological information is required to evaluate the need for initiating protective measures to protect the health and safety of the public. This Specification does not meet the criteria for retention in the Improved Technical Specifications (ITS); therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.3.3.4 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. Meteorological instrumentation is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Meteorological Instrumentation Specification does not satisfy criterion 1.

2. Meteorological instrumentation is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Meteorological Instrumentation Specification does not satisfy criterion 2.

3. Meteorological instrumentation is not part of a primary success path in the mitigation of a DBA or transient. The Meteorological Instrumentation Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-23), and summarized in Table 1 of WCAP-11618, the loss of meteorological monitoring instrumentation was found to be a non-significant risk contributor to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Meteorological Instrumentation Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, Meteorological Instrumentation LCO and Surveillances may be relocated out of the Technical CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 772 of 818

Attachment 1, Volume 8, Rev. 0, Page 773 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.4, METEOROLOGICAL INSTRUMENTATION Specifications. The Meteorological Instrumentation Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as a relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 773 of 818

Attachment 1, Volume 8, Rev. 0, Page 774 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 774 of 818

Attachment 1, Volume 8, Rev. 0, Page 775 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.3.3.4, METEOROLOGICAL 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 775 of 818

Attachment 1, Volume 8, Rev. 0, Page 776 of 818 CTS 3/4.3.3.5.1, APPENDIX R REMOTE SHUTDOWN INSTRUMENTATION Attachment 1, Volume 8, Rev. 0, Page 776 of 818

Attachment 1, Volume 8, Rev. 0, Page 777 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 8, Rev. 0, Page 777 of 818

, Volume 8, Rev. 0, Page 778 of 818 CTS 3/4.3.3.5.1 R.1 Page 1 of 8 , Volume 8, Rev. 0, Page 778 of 818

, Volume 8, Rev. 0, Page 779 of 818 CTS 3/4.3.3.5.1 R.1 Page 2 of 8 , Volume 8, Rev. 0, Page 779 of 818

, Volume 8, Rev. 0, Page 780 of 818 CTS 3/4.3.3.5.1 R.1 Page 3 of 8 , Volume 8, Rev. 0, Page 780 of 818

, Volume 8, Rev. 0, Page 781 of 818 CTS 3/4.3.3.5.1 131 R.1 Page 4 of 8 , Volume 8, Rev. 0, Page 781 of 818

, Volume 8, Rev. 0, Page 782 of 818 CTS 3/4.3.3.5.1 R.1 Page 5 of 8 , Volume 8, Rev. 0, Page 782 of 818

, Volume 8, Rev. 0, Page 783 of 818 CTS 3/4.3.3.5.1 R.1 Page 6 of 8 , Volume 8, Rev. 0, Page 783 of 818

, Volume 8, Rev. 0, Page 784 of 818 CTS 3/4.3.3.5.1 R.1 Page 7 of 8 , Volume 8, Rev. 0, Page 784 of 818

, Volume 8, Rev. 0, Page 785 of 818 CTS 3/4.3.3.5.1 R.1 224 Page 8 of 8 , Volume 8, Rev. 0, Page 785 of 818

Attachment 1, Volume 8, Rev. 0, Page 786 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.5.1, APPENDIX R REMOTE SHUTDOWN INSTRUMENTATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.3.3.5.1 provides requirements for Appendix R remote shutdown instrumentation. The Appendix R remote shutdown instrumentation is used to ensure that a fire will not preclude achieving safe shutdown. This instrumentation is independent of areas where a fire could damage systems normally used to shutdown the reactor. However, the instrumentation is not used to detect a degradation of the reactor coolant pressure boundary, and is not assumed to mitigate a design basis accident (DBA) or transient event. The Appendix R remote shutdown instrumentation capability is consistent with the requirements of 10 CFR 50, Appendix R. The acceptability of the relocation of the Appendix R Technical Specification requirements from the plant Technical Specifications has already been endorsed by the NRC as indicated in Generic Letter 86-10. This Specification does not meet the criteria for retention in the Improved Technical Specifications (ITS); therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.3.3.5.1 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. Appendix R remote shutdown instrumentation is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Appendix R Remote Shutdown Instrumentation Specification does not satisfy criterion 1.

2. Appendix R remote shutdown instrumentation is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. The Appendix R Remote Shutdown Instrumentation Specification does not satisfy criterion 2.

3. Appendix R remote shutdown instrumentation is not part of a primary success path in the mitigation of a DBA or transient. The Appendix R Remote Shutdown Instrumentation Specification does not satisfy criterion 3.

4. Although the Appendix R remote shutdown instrumentation has not been specifically evaluated for risk significance either generically or on a plant specific basis, insight based on a review of CNP Units 1 and 2 licensing CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 786 of 818

Attachment 1, Volume 8, Rev. 0, Page 787 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.5.1, APPENDIX R REMOTE SHUTDOWN INSTRUMENTATION basis documentation (including the CNP Probabilistic Risk Assessment Final Report) indicates that the instrumentation is not risk dominant with regards to core damage frequency or off-site health effects. The Appendix R Remote Shutdown Instrumentation Specification does not satisfy criterion 4.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 787 of 818

Attachment 1, Volume 8, Rev. 0, Page 788 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 788 of 818

Attachment 1, Volume 8, Rev. 0, Page 789 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.3.3.5.1, APPENDIX R REMOTE SHUTDOWN 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 789 of 818

, Volume 8, Rev. 0, Page 790 of 818 CTS 3/4.3.3.9, EXPLOSIVE GAS MONITORING INSTRUMENTATION , Volume 8, Rev. 0, Page 790 of 818

Attachment 1, Volume 8, Rev. 0, Page 791 of 818 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 8, Rev. 0, Page 791 of 818

, Volume 8, Rev. 0, Page 792 of 818 CTS 3/4.3.3.9 R.1 Page 1 of 6 , Volume 8, Rev. 0, Page 792 of 818

, Volume 8, Rev. 0, Page 793 of 818 CTS 3/4.3.3.9 R.1 Page 2 of 6 , Volume 8, Rev. 0, Page 793 of 818

, Volume 8, Rev. 0, Page 794 of 818 CTS 3/4.3.3.9 R.1 Page 3 of 6 , Volume 8, Rev. 0, Page 794 of 818

, Volume 8, Rev. 0, Page 795 of 818 CTS 3/4.3.3.9 R.1 Page 4 of 6 , Volume 8, Rev. 0, Page 795 of 818

, Volume 8, Rev. 0, Page 796 of 818 CTS 3/4.3.3.9 R.1 Page 5 of 6 , Volume 8, Rev. 0, Page 796 of 818

, Volume 8, Rev. 0, Page 797 of 818 CTS 3/4.3.3.9 R.1 Page 6 of 6 , Volume 8, Rev. 0, Page 797 of 818

Attachment 1, Volume 8, Rev. 0, Page 798 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.9, EXPLOSIVE GAS MONITORING INSTRUMENTATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.3.3.9 provides requirements for explosive gas monitoring instrumentation. The Explosive Gas Monitoring Instrumentation Specification is provided to ensure that the concentration of potentially explosive gas mixtures contained in the gaseous waste processing system is adequately monitored, which will help ensure that the concentration is maintained below the flammability limit. However, the system is designed to contain detonations, and detonations would not affect the function of any safety related equipment. The concentration of oxygen in the gaseous Waste Processing System is not an initial assumption of any design basis accident (DBA) or transient analysis. This Specification does not meet the criteria for retention in the Improved Technical Specifications (ITS);

therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.3.3.9 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. Explosive gas monitoring instrumentation is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The Explosive Gas Monitoring Instrumentation Specification does not satisfy criterion 1.

2. Explosive gas monitoring instrumentation is not used to indicate status of, or monitor a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient. In addition, excessive system oxygen is not an indication of a DBA or transient. The Explosive Gas Monitoring Instrumentation Specification does not satisfy criterion 2.

3. Explosive gas monitoring instrumentation is not part of a primary success path in the mitigation of a DBA or transient. In addition, excessive oxygen discharge is not part of a primary success path in mitigating a DBA or transient. The Explosive Gas Monitoring Instrumentation Specification does not satisfy criterion 3.

4. As discussed in Section 4.0 (Appendix A, page A-69) and summarized in Table 1 of WCAP-11618, the loss of the explosive gas monitoring instrumentation was found to be a non-significant risk contributor to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 8, Rev. 0, Page 798 of 818

Attachment 1, Volume 8, Rev. 0, Page 799 of 818 DISCUSSION OF CHANGES CTS 3/4.3.3.9, EXPLOSIVE GAS MONITORING INSTRUMENTATION the assessment. The Explosive Gas Monitoring Instrumentation Specification does not satisfy criterion 4.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 8, Rev. 0, Page 799 of 818

Attachment 1, Volume 8, Rev. 0, Page 800 of 818 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 8, Rev. 0, Page 800 of 818

Attachment 1, Volume 8, Rev. 0, Page 801 of 818 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.3.3.9, EXPLOSIVE GAS MONITORING 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 801 of 818

Attachment 1, Volume 8, Rev. 0, Page 802 of 818 ATTACHMENT 10 Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 8, Rev. 0, Page 802 of 818

Attachment 1, Volume 8, Rev. 0, Page 803 of 818 ISTS 3.3.8, FUEL BUILDING AIR CLEANUP SYSTEM (FBACS)

ACTUATION SYSTEM Attachment 1, Volume 8, Rev. 0, Page 803 of 818

Attachment 1, Volume 8, Rev. 0, Page 804 of 818 ISTS 3.3.8 Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 809 of 818 JUSTIFICATION FOR DEVIATIONS ISTS 3.3.8, FUEL BUILDING AIR CLEANUP SYSTEM (FBACS) ACTUATION INSTRUMENTATION

1. ISTS 3.3.8, "FBACS Actuation Instrumentation," is not being adopted at CNP Units 1 and 2 because it does not meet any of the 10 CFR 50.36(c)(2)(ii) criteria for retention in the ITS. ITS 3.7.13, "Fuel Handling Area Exhaust Ventilation (FHAEV) System,"

requires the FHAEV System to be in operation during movement of irradiated fuel assemblies in the auxiliary building, and no automatic actuation is required. The CNP Units 1 and 2 safety analyses assume that the FHAEV System is operating when a Fuel Handling Accident occurs. For this reason, FBACS Actuation Instrumentation is not required for accident mitigation, and does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for inclusion in the Technical Specifications.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 8, Rev. 0, Page 809 of 818

Attachment 1, Volume 8, Rev. 0, Page 810 of 818 ISTS 3.3.8 Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 8, Rev. 0, Page 818 of 818 JUSTIFICATION FOR DEVIATIONS ISTS 3.3.8 BASES, FUEL BUILDING AIR CLEANUP SYSTEM (FBACS) ACTUATION INSTRUMENTATION

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

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

ML041200367

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