Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 9, Rev 0, ITS Section 3.4 Reactor Coolant System.
	ML041200368
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Issue date:	04/06/2004
From:	; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
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Attachment 1, Volume 9, Rev. 0, Page 1 of 624 VOLUME 9 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.4 REACTOR COOLANT SYSTEM Revision 0 Attachment 1, Volume 9, Rev. 0, Page 1 of 624

Attachment 1, Volume 9, Rev. 0, Page 2 of 624 LIST OF ATTACHMENTS

1. ITS 3.4.1

2. ITS 3.4.2

3. ITS 3.4.3

4. ITS 3.4.4

5. ITS 3.4.5

6. ITS 3.4.6

7. ITS 3.4.7

8. ITS 3.4.8

9. ITS 3.4.9

10. ITS 3.4.10

11. ITS 3.4.11

12. ITS 3.4.12

13. ITS 3.4.13

14. ITS 3.4.14

15. ITS 3.4.15

16. ITS 3.4.16

17. Relocated/Deleted Current Technical Specifications (CTS)

18. Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 9, Rev. 0, Page 2 of 624

Attachment 1, Volume 9, Rev. 0, Page 3 of 624 ATTACHMENT 1 ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DEPARTURE FROM NUCLEATE BOILING LIMITS Attachment 1, Volume 9, Rev. 0, Page 3 of 624

, Volume 9, Rev. 0, Page 4 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 4 of 624

Attachment 1, Volume 9, Rev. 0, Page 5 of 624 ITS 3.4.1 A.1 ITS LCO 3.4.1 ACTION A ACTION B 6 L.1 or equal to SR 3.4.1.1, A.2 SR 3.4.1.2, SR 3.4.1.3 LA.1 Add proposed SR 3.4.1.4 Note SR 3.4.1.4 M.1 24 precision heat balance LA.2 L.2 M.1 Page 1 of 6 Attachment 1, Volume 9, Rev. 0, Page 5 of 624

Attachment 1, Volume 9, Rev. 0, Page 6 of 624 ITS 3.4.1 A.1 ITS A.3 as specified in COLR LA.3 LCO 3.4.1 Add limit specified LA.3 in COLR LA.4 Applicability Note LA.4 Page 2 of 6 Attachment 1, Volume 9, Rev. 0, Page 6 of 624

Attachment 1, Volume 9, Rev. 0, Page 7 of 624 ITS 3.4.1 A.1 ITS LCO 3.4.1 as specified in the COLR LA.3 Add limit specified in COLR LA.3 A.2 ACTION A or equal to ACTION B L.1 6

SR 3.4.1.1, LA.1 SR 3.4.1.2, SR 3.4.1.3 Add proposed M.1 SR 3.4.1.4 Note precision heat balance LA.2 SR 3.4.1.4 24 L.2 M.1 Applicability Note LA.4 Page 3 of 6 Attachment 1, Volume 9, Rev. 0, Page 7 of 624

, Volume 9, Rev. 0, Page 8 of 624 ITS 3.4.1 A.1 Page 4 of 6 , Volume 9, Rev. 0, Page 8 of 624

, Volume 9, Rev. 0, Page 9 of 624 ITS 3.4.1 A.1 Page 5 of 6 , Volume 9, Rev. 0, Page 9 of 624

, Volume 9, Rev. 0, Page 10 of 624 ITS 3.4.1 A.1 Page 6 of 6 , Volume 9, Rev. 0, Page 10 of 624

Attachment 1, Volume 9, Rev. 0, Page 11 of 624 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.2.5 Action requires the unit to reduce THERMAL POWER to "less than" 5% of RATED THERMAL POWER (RTP) within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if the DNB parameters are not restored to within limit in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.4.1 ACTION B requires the power reduction to "less than or equal to" 5% RTP (MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the DNB parameters are not restored to within limit in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

This changes the CTS by allowing the unit be at 5% RTP instead of < 5% RTP.

The change in the time period to reach 5% RTP is discussed in DOC L.1.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.2.5 is applicable in MODE 1, which is greater than 5% RTP. CTS 3.0.1 states that Actions are applicable during the MODES or other conditions specified for the Specification. Therefore, the CTS 3.2.5 Action to be less than 5% RTP ceases to be applicable once the unit enters MODE 2, i.e., at 5% RTP, and the Action is exited. As a result, changing the ACTION to "be in MODE 2" results in no operational difference from the CTS Action. This change is designated as administrative as it results in no technical change to the CTS.

A.3 (Unit 1 only) CTS 3.2.5 Table 3.2-1 contains a column for DNB limits during four loop operation at RATED THERMAL POWER. The ITS does not contain this detail. This changes the Unit 1 CTS by eliminating the detail that the DNB limits apply to four loop operation at RATED THERMAL POWER.

This change is acceptable because the requirements have not changed. Both the ITS and the CTS require all four loops in operation in the applicable MODE (MODE 1). This change is designated as administrative because it eliminates an option in the CTS which cannot be used.

MORE RESTRICTIVE CHANGES M.1 CTS 4.2.5.3 states that the Reactor Coolant System (RCS) total flow rate shall be determined. CTS 4.2.5.4 states that the provisions of CTS 4.0.4 shall not apply to primary flow surveillances. ITS SR 3.4.1.4 requires measurement of the RCS total flow rate and is modified by a Note which states, "Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after > 90% RTP." This changes the CTS by explicitly specifying the time required to perform the Surveillance after entering MODE 1 conditions.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 9, Rev. 0, Page 11 of 624

Attachment 1, Volume 9, Rev. 0, Page 12 of 624 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS The purpose of CTS 4.2.5.3 is to accurately determine the RCS total flow rate.

This change is acceptable because the new Surveillance has been evaluated to ensure that it provides an acceptable level of equipment reliability. An accurate measurement of the RCS total flow rate must be performed at full power under stable operating conditions. The Note also applies a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period after reaching 90% RTP to perform the test. This is a reasonable period to establish stable operating conditions, install the test equipment, perform the test, and analyze the results. This change is designated as more restrictive as it specifies an explicit time period to perform the test.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms) CTS 4.2.5.2 requires that the indicators which are used to determine RCS flow rate be subjected to a CHANNEL CALIBRATION at least once per 18 months. ITS 3.4.1 does not include this requirement. This changes the CTS by relocating the Surveillance Requirement 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. This RCS flow rate indicators are not required to be OPERABLE to determine whether the RCS total flow rate is within limit. The requirement to determine RCS total flow rate remains in the ITS. In addition, the majority of the instrumentation (e.g., sensor) remains in the ITS as part of ITS 3.3.1 (Table 3.3.1-1 Function 10). 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 is being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.5.3 requires the RCS total flow rate to be determined by a power balance around the steam generators. ITS SR 3.4.1.4 requires the verification by precision heat balance that RCS total flow rate is greater than the limits. This changes the CTS by relocation of the procedural details on how to perform the heat balance (power balance around the steam generators) to the Bases and replacing it with "by a precision heat balance."

The removal of these details for performing Surveillance Requirements from the CTS is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 9, Rev. 0, Page 12 of 624

Attachment 1, Volume 9, Rev. 0, Page 13 of 624 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS health and safety. The ITS still retains requirement to verify RCS total flow rate by using a precision heat balance. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

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

LA.3 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS Table 3.2-1 (Unit 1) and CTS 3.2.5 (Unit 2) place limits on DNB RCS Tavg, pressurizer pressure, and RCS total flow rate. ITS 3.4.1 states that the limits on RCS Tavg and pressurizer pressure shall not exceed the limits specified in the COLR. ITS 3.4.1 also requires RCS total flow rate to be greater than or equal to the limit specified in the COLR and that the minimum RCS total flow rate to be > 341,100 gpm (Unit 1) and > 366,400 gpm (Unit 2). This changes the CTS by relocating the specific values of RCS Tavg, pressurizer pressure, and RCS total flow rate, which must be confirmed on a cycle-specific basis, to the COLR.

The removal of these cycle-specific parameter limits from the Technical Specifications and their relocation into the COLR is acceptable because these limits are developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications," that this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirements and Surveillances that verify that the cycle-specific parameter limits are being met.

NRC-approved Topical Report WCAP-14483, "Generic Methodology for Expanded Core Operating Limits Report," determined that the specific values for the DNB parameters may be relocated to the COLR as long as the limiting RCS total flow limit is retained in the LCO. The LCO continues to require that the core be operated within the DNB limits. The methodologies used to develop the DNB parameters in the COLR have obtained prior approval by the NRC in accordance with Generic Letter 88-16. Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.5, "CORE OPERATING LIMITS REPORT." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the Technical Specifications.

LA.4 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.2-1 Footnote * (Unit 1) and CTS 3.2.5 Footnote * (Unit 2) require the Tavg to be evaluated with the use of the indicated average of at least three OPERABLE instrument loops. CTS Table 3.2-1 Footnote *** (Unit 1) and CTS 3.2.5 Footnote *** (Unit 2) state that the limit specified for RCS total flow rate is the indicated value. ITS 3.4.1 does not CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 9, Rev. 0, Page 13 of 624

Attachment 1, Volume 9, Rev. 0, Page 14 of 624 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS provide these details. This changes the CTS by relocating the procedural details on how to perform the parameter comparison to the Bases.

The removal of these details for performing Surveillance Requirements from the CTS is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the parameters should be met and requires them to be verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.2.5 Action requires the unit to reduce THERMAL POWER to < 5% of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if the DNB parameters are not restored to within limit in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.4.1 ACTION B requires the power reduction to < 5% RTP (MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the DNB parameters are not restored to within limit in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by extending the time for the unit to be placed outside the MODE of Applicability. The change which allows the THERMAL POWER reduction to be only to 5% RTP is discussed in DOC A.2.

The purpose of the CTS 3.2.5 Action is to limit the time the unit can be outside of the DNB parameter limits and remain within the Applicability of the Specification.

This change is acceptable because the Completion Time is 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 allowed Completion Time. The change extends the time the unit is allowed to be outside the DNB parameter limits and be in the Applicability of the Specification. The time extension is from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L.2 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.2.5.3 requires the RCS total flow rate to be determined by a power balance around the steam generators every 18 months. ITS SR 3.4.1.4 requires the verification by precision heat balance that RCS total flow rate is greater than the limits to be performed 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 CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 9, Rev. 0, Page 14 of 624

Attachment 1, Volume 9, Rev. 0, Page 15 of 624 DISCUSSION OF CHANGES ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS ITS SR 3.0.2). The change to the procedural details on how to perform the test (power balance around the steam generators) is discussed in DOC LA.2.

The purpose of CTS 4.2.5.3 is to allow the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is within limit. 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 precision heat balance is acceptable because during the operating cycle reactor flow is indicated and alarmed, and instruments are channel checked for confirmation of flow conditions. The instruments that support the indication and trip functions have been evaluated for calibration extension using failure analysis and drift verification. There is a high confidence that these instruments will remain functional and accurate for the full 24-month interval. Therefore any changes to indicated flow would be readily detected. Since elbow taps are used for flow differential pressure, there are few conditions which could disrupt flow without the significant change causing a low flow trip. Based on the inherent system and component reliability and the testing performed during the operating cycle, including CHANNEL CHECKS and CHANNEL OPERATIONAL TESTS (COTs) associated with the reactor coolant flow instrumentation, 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.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 9, Rev. 0, Page 15 of 624

Attachment 1, Volume 9, Rev. 0, Page 16 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 21 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS

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

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

3. Editorial/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 21 of 624

Attachment 1, Volume 9, Rev. 0, Page 22 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 31 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.1 BASES, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS

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

2. These changes are made for consistency with similar phrases in other parts of the ITS Bases and/or consistency with the ITS.

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

4. The Bases are revised to reflect changes made to the ITS.

5. This statement in the Applicability Bases is discussing a Safety Limit, includes requirements that are not found in this Specification, and is unrelated to why the Applicability of this Specification is what it is. Therefore, it is not appropriate information to be included in this Bases and has been deleted.

6. The reason for the Frequency is not accurate and does not reflect the requirements in the actual Surveillance Requirement. The actual Surveillance Requirement does not require performance after a refueling outage when the core has been altered; it is required every 24 months (18 months in the ISTS). Therefore, the reason has been modified to be consistent with other Surveillance Requirements with a similar Frequency.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 31 of 624

Attachment 1, Volume 9, Rev. 0, Page 32 of 624 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 9, Rev. 0, Page 33 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.1, RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 33 of 624

Attachment 1, Volume 9, Rev. 0, Page 34 of 624 ATTACHMENT 2 ITS 3.4.2, RCS Minimum Temperature for Criticality Attachment 1, Volume 9, Rev. 0, Page 34 of 624

, Volume 9, Rev. 0, Page 35 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 35 of 624

Attachment 1, Volume 9, Rev. 0, Page 36 of 624 ITS 3.4.2 A.1 ITS LCO 3.4.2 ACTION A A.2 30 MODE 2 with keff < 1.0 A.3 SR 3.4.2.1 L.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A.4 Applicability Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 36 of 624

Attachment 1, Volume 9, Rev. 0, Page 37 of 624 ITS 3.4.2 A.1 ITS LCO 3.4.2 ACTION A A.2 30 MODE 2 with keff < 1.0 A.3 SR 3.4.2.1 L.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Applicability Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 37 of 624

Attachment 1, Volume 9, Rev. 0, Page 38 of 624 DISCUSSION OF CHANGES ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.1.1.5 Action states that with a Reactor Coolant System operating loop temperature (Tavg) < 541°F, to "restore (Tavg) to within its limit within 15 minutes or be in HOT STANDBY within the next 15 minutes." ITS 3.4.2, ACTION A, states that with Tavg in one or more RCS loops not within limit, be in MODE 2 with keff < 1.0 within 30 minutes. This changes the CTS by eliminating the requirement to restore Tavg to within its limit within 15 minutes. The change associated with entering MODE 2 with keff < 1.0 instead of HOT STANDBY is discussed in DOC A.3.

This change is acceptable because it results in no technical change to the Technical Specifications. Restoration of compliance with the LCO is always an option in an Action, so eliminating the restoration Action from the CTS has no effect. In both the CTS and the ITS, if Tavg is not within limits, the unit must be placed in a MODE in which the LCO does not apply. This change is designated as administrative as it results in no technical change to the CTS.

A.3 CTS 3.1.1.5 Action states that with a Reactor Coolant System operating loop temperature (Tavg) < 541°F, to restore Tavg to within its limit within 15 minutes or "be in HOT STANDBY within the next 15 minutes." ITS 3.4.2, ACTION A, states that with Tavg in one or more RCS loops not within limit, be in MODE 2 with keff < 1.0 within 30 minutes. This changes the CTS requirement to enter HOT STANDBY to enter MODE 2 with keff < 1.0. Other changes to this CTS Action are discussed in DOC A.2.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.1.1.5 is applicable in MODE 1 and MODE 2 with keff 1.0. CTS 3.0.1 states that Actions are applicable during the MODES or other conditions specified for the Specification. Therefore, the CTS 3.1.1.5 Action to enter MODE 3 ceases to be applicable once the unit enters MODE 2 with keff < 1.0, and the Action is exited. As a result, changing the ACTION to "be in MODE 2 with keff < 1.0" results in no operational difference from the CTS Action. This change is designated as administrative as it results in no technical change to the CTS.

A.4 The Applicability of CTS 3.1.1.5 (Unit 1 only) is modified by Footnote *, which states "See Special Test Exception 3.10.3." The ITS 3.4.2 Applicability does not contain the footnote or a reference to the Special Test Exception.

CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 9, Rev. 0, Page 38 of 624

Attachment 1, Volume 9, Rev. 0, Page 39 of 624 DISCUSSION OF CHANGES ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY The purpose of the footnote reference is to alert the user that a Special Test Exception exists that may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.1.1.5 states that the RCS Tavg shall be determined to be > 541°F within 15 minutes prior to achieving reactor criticality, and every 30 minutes when the reactor is critical and the RCS Tavg < 545°F (Unit 1) and < 551°F (Unit 2) or when the low Tavg alarm is inoperable (Unit 1) or with the Tavg - Tref deviation alarm not reset (Unit 2). ITS SR 3.4.2.1 requires RCS Tavg in each loop to be verified > 541°F every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by deleting the within 15 minutes prior to achieving criticality Frequency and the Surveillance Frequencies based on the condition of the reactor (critical), the reactor coolant temperature, and when the low Tavg alarm is inoperable (Unit 1) or the Tavg-Tref deviation alarm not reset (Unit 2), and replacing them with a periodic 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency.

The purpose of CTS 4.1.1.5 is to ensure RCS Tavg is within limit when the reactor is critical. The requirement is that RCS Tavg be > 541°F, and is required to be met when the unit is operating in MODE 2 with keff > 1.0 and MODE 1. Based on ITS SR 3.0.4, this would require the SR to be met within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to entry into MODE 2 with keff > 1.0 or before the reactor is critical. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of assurance. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered frequent enough to prevent inadvertent violation of the LCO. In the approach to criticality, the reactor coolant pumps are adding heat to the RCS, so the conditions before and after criticality are similar. The approach to criticality is a carefully controlled evolution during which RCS temperature is closely monitored. Therefore, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is frequent enough for the Technical Specifications to require recording of Tavg prior to criticality given that it is being CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 9, Rev. 0, Page 39 of 624

Attachment 1, Volume 9, Rev. 0, Page 40 of 624 DISCUSSION OF CHANGES ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY carefully watched. The inoperability of an alarm or an alarm not reset does not increase the probability of RCS temperature (Tavg) being outside its limit. The alarms are for indication only and are not credited in any safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 9, Rev. 0, Page 40 of 624

Attachment 1, Volume 9, Rev. 0, Page 41 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 41 of 624

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Attachment 1, Volume 9, Rev. 0, Page 43 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY

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

2. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 43 of 624

Attachment 1, Volume 9, Rev. 0, Page 44 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 49 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.2 BASES, RCS MINIMUM TEMPERATURE FOR CRITICALITY

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 discussion in the Applicability Section is deleted since the special test exception LCOs are not normally discussed in the Bases of other LCOs.

3. Editorial/grammatical error corrected.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 49 of 624

Attachment 1, Volume 9, Rev. 0, Page 50 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 50 of 624

Attachment 1, Volume 9, Rev. 0, Page 51 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.2, RCS MINIMUM TEMPERATURE FOR CRITICALITY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 51 of 624

Attachment 1, Volume 9, Rev. 0, Page 52 of 624 ATTACHMENT 3 ITS 3.4.3, RCS PRESSURE AND TEMPERATURE LIMITS Attachment 1, Volume 9, Rev. 0, Page 52 of 624

, Volume 9, Rev. 0, Page 53 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 53 of 624

Attachment 1, Volume 9, Rev. 0, Page 54 of 624 ITS 3.4.3 A.1 ITS LCO 3.4.3 LA.1 A.2 Add proposed Conditions A and C Notes A.3 A.4 ACTIONS A and C LA.2 Add proposed Required ACTION B Actions A.2 and M.1 C.2 Completion Times A.5 Page 1 of 9 Attachment 1, Volume 9, Rev. 0, Page 54 of 624

Attachment 1, Volume 9, Rev. 0, Page 55 of 624 ITS 3.4.3 A.1 ITS SR 3.4.3.1 L.1 A.6 Page 2 of 9 Attachment 1, Volume 9, Rev. 0, Page 55 of 624

Attachment 1, Volume 9, Rev. 0, Page 56 of 624 ITS 3.4.3 A.1 ITS L.2 Figure 3.4.3-1 L.2 Page 3 of 9 Attachment 1, Volume 9, Rev. 0, Page 56 of 624

Attachment 1, Volume 9, Rev. 0, Page 57 of 624 ITS 3.4.3 A.1 ITS L.2 Figure 3.4.3-2 Page 4 of 9 Attachment 1, Volume 9, Rev. 0, Page 57 of 624

, Volume 9, Rev. 0, Page 58 of 624 ITS 3.4.3 A.1 A.6 Page 5 of 9 , Volume 9, Rev. 0, Page 58 of 624

Attachment 1, Volume 9, Rev. 0, Page 59 of 624 ITS 3.4.3 A.1 ITS LCO 3.4.3 LA.1 A.2 Add proposed Conditions A and C Notes A.3 ACTIONS A A.4 and C LA.2 Add proposed Required ACTION B Actions A.2 M.1 and C.2 Completion Times SR 3.4.3.1 A.6 Page 6 of 9 Attachment 1, Volume 9, Rev. 0, Page 59 of 624

Attachment 1, Volume 9, Rev. 0, Page 60 of 624 ITS 3.4.3 A.1 ITS L.2 Figure 3.4.3-1 L.2 Page 7 of 9 Attachment 1, Volume 9, Rev. 0, Page 60 of 624

Attachment 1, Volume 9, Rev. 0, Page 61 of 624 ITS 3.4.3 A.1 ITS L.2 Figure 3.4.3-2 Page 8 of 9 Attachment 1, Volume 9, Rev. 0, Page 61 of 624

, Volume 9, Rev. 0, Page 62 of 624 ITS 3.4.3 A.1 A.6 Page 9 of 9 , Volume 9, Rev. 0, Page 62 of 624

Attachment 1, Volume 9, Rev. 0, Page 63 of 624 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.4.9.1 states that the RCS temperature and pressure shall be limited "during heatup, cooldown, criticality, and inservice leak and hydrostatic testing."

CTS 3.4.9.1 is applicable at all times. ITS 3.4.3 states that the RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained.

ITS 3.4.3 is applicable at all times. This changes the CTS by eliminating the LCO requirement that the limits must be met during heatup, cooldown, criticality, and inservice leak and hydrostatic testing.

This change is acceptable because the CTS and ITS limits are applicable at all times, including during heatup, cooldown, criticality, and inservice leak and hydrostatic testing. Stating that the limits are applicable during heatup, cooldown, and inservice leak and hydrostatic testing in the LCO presents an apparent conflict with the Applicability which states that the limits apply at all times. This change is designated as administrative as it is an editorial change to eliminate an apparent conflict in the CTS.

A.3 CTS 3.4.9.1 Action states that with any of the P/T limits exceeded, restore the temperature and/or pressure to within the limit within 30 minutes; perform an analysis to determine the effects of the out-of limit condition on the fracture toughness properties of the RCS; and determine that the RCS remains acceptable for continued operations. ITS 3.4.3, Conditions A and C state that when the requirements of the LCO are not met, the parameters must be restored to within limits and it must be determined that the RCS is acceptable for continued operation. ITS 3.4.3, Conditions A and C are modified by a Note which requires the determination that the RCS is acceptable for continued operation to be performed whenever the Condition is entered. This changes the CTS by explicitly stating that a determination that the RCS is acceptable for continued operation must be performed whenever the condition is entered.

Other changes to the Actions are described in other DOCs.

This change is acceptable because it is the current understanding and application of the CTS Action. The CTS 3.4.9.1 Action is currently interpreted as requiring a determination that the RCS is acceptable for continued operation whenever the LCO is not met. This change is designated as editorial as it clarifies the current understanding of the CTS requirement.

A.4 CTS 3.4.9.1 Action states that with any of the P/T limits exceeded, restore the temperature and/or pressure to within the limit within 30 minutes; perform an analysis to determine the effects of the out-of-limit condition on the fracture toughness properties of the RCS; determine that the RCS remains acceptable for CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 9, Rev. 0, Page 63 of 624

Attachment 1, Volume 9, Rev. 0, Page 64 of 624 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS continued operations or be in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce the RCS Tavg and pressure to less than 200°F and 500 psig, respectively, within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ITS 3.4.3, ACTION C, states that with the requirements of the LCO not met any time in other than MODE 1, 2, 3, or 4, to initiate immediate action to restore the parameter(s) to within limits and determine the RCS is acceptable for continued operation prior to entering MODE 4.

This change is acceptable because this change reflects an enhanced presentation of the existing intent. The CTS 3.4.9.1 Action to "restorewithin 30 minutes" is proposed to be revised to "initiate action to restore Immediately" for conditions other than MODES 1, 2, 3, and 4. The existing Action would appear to provide a half hour in which pressure and temperature requirements could exceed the limits, even if capable of being returned to within limits. Also, if the parameters are incapable of being restored to within the limits within 30 minutes, the existing Action would appear to result in the requirement of a Licensee Event Report. The intent of the Action is believed to be more appropriately presented in ITS 3.4.3 Required Action C.1. This interpretation of the intent is supported by the Westinghouse Standard Technical Specifications, NUREG-1431, Rev. 2. This change is designated as administrative as it reflects an enhanced presentation of the existing intent.

A.5 (Unit 1 only) The Applicability of CTS 3.4.9.1 is modified by Footnote *, which states "See Special Test Exception 3.10.3." The ITS 3.4.3 Applicability does not contain the footnote or a reference to the Special Test Exception. This changes the Unit 1 CTS by deleting a cross-reference to the Special Test Exception.

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

A.6 CTS 4.4.9.1.c (Unit 1) and CTS 4.4.9.1.2 (Unit 2) state that the reactor vessel material irradiation surveillance specimens shall be removed and examined to determine changes in material properties at the intervals shown in Table 4.4-5.

The results of these examinations shall be used to update the P/T limit curves.

ITS 3.4.3 does not contain this Surveillance nor the Table. This changes the CTS by deleting the reactor vessel material irradiation Surveillance Requirement.

This change is acceptable because the Surveillance is unnecessary and repetitive. The unit is required by applicable regulations to remove material irradiation surveillance specimens and generate P/T curves in accordance with 10 CFR 50, Appendix H. Therefore, the Surveillance serves no purpose and is removed. This change is designated as administrative as it eliminates a requirement that is duplicative of a regulatory requirement in the CFR.

CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 9, Rev. 0, Page 64 of 624

Attachment 1, Volume 9, Rev. 0, Page 65 of 624 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS MORE RESTRICTIVE CHANGES M.1 CTS 3.4.9.1 Action states that if the P/T limits are exceeded, an analysis must be performed to determine if the RCS remains acceptable for continued operation.

No time limit is given for the performance of this analysis. ITS 3.4.3 Required Action A.2 states that when the LCO is not met in MODES 1, 2, 3, or 4, an evaluation is required to be performed to determine if the RCS is acceptable for continued operation within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.4.3 Required Action C.2 states that when the LCO is not met any time in other than MODE 1, 2, 3, or 4, an evaluation is required to be performed to determine if the RCS is acceptable for continued operation prior to entering MODE 4. This changes the CTS by specifying a finite time to complete the analysis.

This change is acceptable because it provides adequate time to evaluate exceeding the LCO requirements. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is considered reasonable for operation in MODES 1, 2, 3, and 4 because P/T limits are based on very conservative flaw assumptions and large factors of safety.

The Completion Time of "prior to entering MODE 4" during operations other than MODE 1, 2, 3, or 4 is considered reasonable since it would prevent entry into the operating MODES, and is consistent with current LCO 3.0.4. This change is designated as more restrictive as it provides a limited time to perform an action for which the CTS provides no time limit.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.4.9.1 states that the RCS (except the pressurizer) temperature and pressure shall be limited. The LCO also contains limits on RCS heatup and cooldown rates. ITS 3.4.3 states that the RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within limits. This changes the CTS by moving the exclusion of the pressurizer from the LCO 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 P/T limits on the RCS.

Neither the CTS or the ITS P/T limits apply to the pressurizer. It is the ITS convention to state this detail of the LCO in the ITS Bases. This detail of the LCO is not required to be in the Technical Specifications in order to provide adequate protection of the public health and safety. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. 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 3 of 5 Attachment 1, Volume 9, Rev. 0, Page 65 of 624

Attachment 1, Volume 9, Rev. 0, Page 66 of 624 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting Problems) CTS 3.4.9.1 Action states that with any of the P/T limits exceeded, to perform an analysis to determine the effects of the out-of-limit condition on the fracture toughness properties of the RCS and to determine that the RCS remains acceptable for continued operations. ITS 3.4.3, ACTIONS A and C state that with the requirements of the LCO not met, restore the parameter(s) to within limit(s) and determine the RCS is acceptable for continued operation. This changes the CTS by moving the requirement to perform an analysis to determine the effects of the out-of-limit condition on the fracture toughness properties of the RCS 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 to determine that the RCS remains acceptable for continued operation and this detail of how the determination is made is not required to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The requirement to perform an analysis to determine the effects of the out-of-limit condition on the fracture toughness properties of the RCS is a step in determining that the RCS remains acceptable for continued operation.

Therefore, this detail on how the determination is made is moved to the Bases, which provides additional detail on how the determination should be made. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. 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 5 - Deletion of Surveillance Requirement) (Unit 1 only) CTS 4.4.9.1.b requires the RCS temperature and pressure conditions to be determined to be to the right of the criticality limit line within 15 minutes prior to achieving reactor criticality. ITS 3.4.3 does not include this requirement. This changes the Unit 1 CTS by deleting the Surveillance.

The purpose of CTS 4.4.9.1.b is to ensure the criticality limit curve is met. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the criticality limit curve is met to meet the LCO requirements on P/T limits. Thus, appropriate Technical Specification Surveillances continue to be performed in a manner and at a Frequency necessary to give confidence that the criticality limit curve is met. The CTS 4.4.9.1.b Surveillance has been deleted since ITS SR 3.4.2.1 will continue to ensure the criticality limit is met. ITS SR 3.4.2.1 requires the verification of RCS Tavg every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The requirement is that RCS Tavg in each loop be

> 541°F and is required to be met when the unit is operating in MODE 2 with keff > 1.0 and MODE 1. Based on ITS SR 3.0.4, this would require the SR to be met within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to entry into a MODE 2 with keff > 1.0 or before the reactor is critical. The criteria for RCS Tavg is acceptable since it bounds the CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 9, Rev. 0, Page 66 of 624

Attachment 1, Volume 9, Rev. 0, Page 67 of 624 DISCUSSION OF CHANGES ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS criticality limit curve throughout the operating pressure range of the RCS.

Although CTS 4.4.9.1.b requires the Surveillance to be performed within 15 minutes of criticality, the Surveillance Frequency of ITS SR 3.4.2.1 is considered acceptable. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered frequent enough to prevent inadvertent violation of the LCO. In the approach to criticality, the reactor coolant pumps are adding heat to the RCS, so the conditions before and after criticality are similar. The approach to criticality is a carefully controlled evolution during which RCS temperature is closely monitored. Therefore, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is frequent enough for the Technical Specifications to require recording of Tavg prior to criticality given that it is being carefully watched. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.2 (Category 1 - Relaxation of LCO Requirements) CTS Figures 3.4-2 and 3.4-3 describe in the Header that the P/T curves are generated without margins for instrument error, and describe the limiting material, initial ART value, and the limiting ART value that are used to determine the P/T limits. CTS Figure 3.4-2 also states (in the figure portion) that the criticality limit is based on inservice hydrostatic test temperature of 259°F (Unit 1) and 260°F (Unit 2). The ITS Figures 3.4.3-1 and 3.4.3-2 do not include this information. This changes the CTS by deleting this information from the CTS.

The purpose of this information is to provide additional detail as to how the P/T curves were generated. However, deleting this information is acceptable because it is not necessary to be listed in the Figures in order to properly use the Figures. ITS 3.4.3 requires the Figure limits to be met. The details as to how the Figures are generated is not needed to comply with the LCO. The ITS 3.4.3 Bases describes that the Figures were generated to comply with the applicable regulatory requirements of 10 CFR 50, Appendix G and ASME Section III, Appendix G. Therefore, since CNP is required to comply with 10 CFR 50, Appendix G and ASME Section III, Appendix G, this additional information is not required. This change is designated as less restrictive because certain details related to how the LCO was generated are being deleted.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 9, Rev. 0, Page 67 of 624

Attachment 1, Volume 9, Rev. 0, Page 68 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 68 of 624

, Volume 9, Rev. 0, Page 69 of 624 , Volume 9, Rev. 0, Page 69 of 624

Attachment 1, Volume 9, Rev. 0, Page 70 of 624 3.4.3 1 INSERT 1 Figures 3.4.3-1 and 3.4.3-2 with:

a. A maximum heatup of 60°F in any one hour period;

b. A maximum cooldown of 100°F in any one hour period; and

c. A maximum temperature change of < 5°F in any one hour period, during hydrostatic testing operations above system design pressure.

Insert Page 3.4.3-1 Attachment 1, Volume 9, Rev. 0, Page 70 of 624

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Attachment 1, Volume 9, Rev. 0, Page 72 of 624 3.4.3 1 INSERT 2a 2500 Leak Test Limit 2250 Unacceptable Acceptable 2000 Operation Operation Reactor Coolant System Pressure (psig)

Heatup Limit Criticality 1750 60ºF/hr Limit 1500 1250 1000 750 500 Boltup Temp.

250 0

0 50 100 150 200 250 300 350 400 450 500 550 Average Reactor Coolant System Temperature (ºF)

Figure 3.4.3-1 Reactor Coolant System Pressure versus Temperature Limits -

Heatup Limit, Criticality Limit, and Leak Test Limit (Applicable for service period up to 32 EFPY)

Insert Page 3.4.3-2a Attachment 1, Volume 9, Rev. 0, Page 72 of 624

Attachment 1, Volume 9, Rev. 0, Page 73 of 624 3.4.3 1 INSERT 2b 2500 2250 Unacceptable 2000 Acceptable Operation Operation Reactor Coolant System Pressure (psig) 1750 1500 1250 1000 Cooldown Rate 750 (ºF/hr) 0 20 40 500 60 100 Boltup 250 Temp.

0 0 50 100 150 200 250 300 350 400 450 500 550 Average Reactor Coolant System Temperature (ºF)

Figure 3.4.3-2 Reactor Coolant System Pressure versus Temperature Limits -

Various Cooldown Rates Limits (Applicable for service period up to 32 EFPY)

Insert Page 3.4.3-2b Attachment 1, Volume 9, Rev. 0, Page 73 of 624

Attachment 1, Volume 9, Rev. 0, Page 74 of 624 3.4.3 1 INSERT 2c 2500 Leak Test Limit 2250 Unacceptable Acceptable 2000 Operation Operation Reactor Coolant System Pressure (psig) 1750 Heatup Limit 1500 60ºF/hr Criticality 1250 Limit 1000 750 500 250 Boltup Temp.

0 0 50 100 150 200 250 300 350 400 450 500 550 Average Reactor Coolant System Temperature (ºF)

Figure 3.4.3-1 Reactor Coolant System Pressure versus Temperature Limits -

Heatup Limit, Criticality Limit, and Leak Test Limit (Applicable for service period up to 32 EFPY)

Insert Page 3.4.3-2c Attachment 1, Volume 9, Rev. 0, Page 74 of 624

Attachment 1, Volume 9, Rev. 0, Page 75 of 624 3.4.3 1 INSERT 2d 2500 2250 Unacceptabl Unacceptable 2000 Operation Operation Acceptabl Acceptable Reactor Coolant System Pressure (psig)

Operation Operation 1750 1500 1250 Cooldown Rate (ºF/hr) 1000 0 20 40 60 750 100 500 Boltup 250 Temp.

0 0 50 100 150 200 250 300 350 400 450 500 550 Average Reactor Coolant System Temperature (ºF)

Figure 3.4.3-2 Reactor Coolant System Pressure versus Temperature Limits -

Various Cooldown Rates Limits (Applicable for service period up to 32 EFPY)

Insert Page 3.4.3-2d Attachment 1, Volume 9, Rev. 0, Page 75 of 624

Attachment 1, Volume 9, Rev. 0, Page 76 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS

1. CNP is not adopting a Pressure Temperature Limits Report (PTLR) and is retaining in the ITS the limits on heatup, cooldown, and inservice leak and hydrostatic testing, and data for maximum rate of change of reactor coolant temperature.

2. 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 9, Rev. 0, Page 76 of 624

Attachment 1, Volume 9, Rev. 0, Page 77 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 77 of 624

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Attachment 1, Volume 9, Rev. 0, Page 86 of 624 B 3.4.3 2

INSERT 2 The evaluation must include an analysis to determine the effects of the out-of-limit condition on the fracture toughness properties of the RCS.

2 INSERT 3 WCAP-15878, Rev. 0, dated December 2002 (Unit 1) and WCAP-15047, Rev. 2, dated May 2002 (Unit 2)

Insert Page 3.4.3-6 Attachment 1, Volume 9, Rev. 0, Page 86 of 624

, Volume 9, Rev. 0, Page 87 of 624 , Volume 9, Rev. 0, Page 87 of 624

Attachment 1, Volume 9, Rev. 0, Page 88 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.3 BASES, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS

1. Changes are made to reflect those 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. Changes are made to reflect the ISTS.

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

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 88 of 624

Attachment 1, Volume 9, Rev. 0, Page 89 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 89 of 624

Attachment 1, Volume 9, Rev. 0, Page 90 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 90 of 624

, Volume 9, Rev. 0, Page 91 of 624 ATTACHMENT 4 ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 , Volume 9, Rev. 0, Page 91 of 624

, Volume 9, Rev. 0, Page 92 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 92 of 624

Attachment 1, Volume 9, Rev. 0, Page 93 of 624 ITS 3.4.4 A.1 ITS OPERABLE and A.2 LCO 3.4.4 A.3 ACTION A 6 L.1 SR 3.4.4.1 LA.1 A.3 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 93 of 624

Attachment 1, Volume 9, Rev. 0, Page 94 of 624 ITS 3.4.4 A.1 ITS OPERABLE and A.2 LCO 3.4.4 A.3 ACTION A 6 L.1 SR 3.4.4.1 LA.1 A.3 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 94 of 624

Attachment 1, Volume 9, Rev. 0, Page 95 of 624 DISCUSSION OF CHANGES ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.4.1.1 states that all reactor coolant loops shall be in operation. ITS 3.4.4 states that four RCS loops shall be OPERABLE and in operation. This changes the CTS by requiring the RCS loops to be OPERABLE.

This change is acceptable because it is consistent with the current use and understanding of the LCO. It is not sufficient for a RCS loop to be in operation if it is not capable of performing its safety function (i.e., OPERABLE). This change is designated as administrative as it clarifies the current understanding of a requirement.

A.3 The Applicability of CTS 3.4.1.1 (Unit 1) is modified by footnote

that states "See Special Test Exception 3.10.5." The Applicability of CTS 3.4.1.1 (Unit 2) is modified by footnote

that states "See Special Test Exception 3.10.4." The ITS 3.4.4 Applicability does not contain the footnotes or a reference to the Special Test Exceptions.

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

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.4.1.1 states that the required reactor coolant loops shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.4.1 states that each RCS loop shall be verified to be in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by moving the CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 95 of 624

Attachment 1, Volume 9, Rev. 0, Page 96 of 624 DISCUSSION OF CHANGES ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 Surveillance requirement to verify that the reactor coolant loops are circulating reactor coolant to the Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement that a RCS loop be in operation. This will require recirculation of reactor coolant since the ITS Bases specify that verification that a reactor coolant loop is in operation includes flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.4.1.1 Action states that when the reactor coolant loop requirements are not met, the unit must be in HOT STANDBY within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.4.4 ACTION A states that when the RCS loop requirements are not met, the unit must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by relaxing the Completion Time 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 purpose of CTS 3.4.1.1 Action is to require a unit shutdown if the necessary reactor coolant flow is not available. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. Operating experience has shown that 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is a reasonable time to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. It is likely that failure to meet the LCO requirements will lead to a reactor trip on low flow. However, if the LCO is not met for a reason that does not lead to a reactor trip, then 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to transition from full power operation to MODE 3 is consistent with the Completion Time provided for a loss of safety function for other systems and with LCO 3.0.3.

This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 96 of 624

Attachment 1, Volume 9, Rev. 0, Page 97 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 97 of 624

, Volume 9, Rev. 0, Page 98 of 624 , Volume 9, Rev. 0, Page 98 of 624

Attachment 1, Volume 9, Rev. 0, Page 99 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.4, RCS LOOPS - MODES 1 AND 2

1. 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 9, Rev. 0, Page 99 of 624

Attachment 1, Volume 9, Rev. 0, Page 100 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 100 of 624

, Volume 9, Rev. 0, Page 101 of 624 , Volume 9, Rev. 0, Page 101 of 624

, Volume 9, Rev. 0, Page 102 of 624 , Volume 9, Rev. 0, Page 102 of 624

Attachment 1, Volume 9, Rev. 0, Page 103 of 624 B 3.4.4 2

INSERT 1 These analyses establish allowable RCS loop average temperature and T for the minimum measured flow and power distribution as a function of RCS pressure. These analyses also establish a locus of power, pressure, and temperature conditions for which the departure from nucleate boiling ratio (DNBR) is equal to its Safety Limit value. The area of permissible operation is bounded by the combination of assumed reactor trips for Power Range Neutron Flux - High, Overtemperature T, Overpower T, Pressurizer Pressure - Low, and Pressurizer Pressure - High Functions. The difference between the reactor trip values assumed in the safety analyses and the nominal reactor trip setpoints provides an allowance for instrumentation channel error and setpoint error.

Insert Page 3.4.4-2 Attachment 1, Volume 9, Rev. 0, Page 103 of 624

, Volume 9, Rev. 0, Page 104 of 624 , Volume 9, Rev. 0, Page 104 of 624

Attachment 1, Volume 9, Rev. 0, Page 105 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.4 BASES, RCS LOOPS - MODES 1 AND 2

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

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

3. Typographical/grammatical error corrected.

4. Changes have been made to be consistent with changes made to the Specification.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 105 of 624

Attachment 1, Volume 9, Rev. 0, Page 106 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 106 of 624

Attachment 1, Volume 9, Rev. 0, Page 107 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.4, RCS LOOPS - MODES 1 AND 2 There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 107 of 624

, Volume 9, Rev. 0, Page 108 of 624 ATTACHMENT 5 ITS 3.4.5, RCS LOOPS - MODE 3 , Volume 9, Rev. 0, Page 108 of 624

, Volume 9, Rev. 0, Page 109 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 109 of 624

Attachment 1, Volume 9, Rev. 0, Page 110 of 624 ITS 3.4.5 A.1 ITS LCO 3.4.5 LA.1 LA.2 two L.1 LA.2 L.2 A.2 M.1 removed from operation per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period LCO 3.4.5 L.3 Note Add proposed LCO Note part c A.2 L.3 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 110 of 624

Attachment 1, Volume 9, Rev. 0, Page 111 of 624 ITS 3.4.5 A.1 ITS one M.2 ACTION A ACTION B one A.3 ACTION C LA.2 Required Add proposed Required Actions C.1 and D.1 immediately Action D.1 M.2 L.2 M.2 OR Two required RCS loops inoperable ACTION D L.3 M.2 Add proposed Required Action D.1 Add proposed SR 3.4.5.3 NOTE L.4 SR 3.4.5.3 SR 3.4.5.1 LA.3 Add proposed SR 3.4.5.2 M.3 L.3 Page 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 111 of 624

Attachment 1, Volume 9, Rev. 0, Page 112 of 624 ITS 3.4.5 A.1 ITS LCO 3.4.5 LA.1 LA.2 two L.1 LA.2 L.2 A.2 M.1 removed from operation per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period LCO 3.4.5 L.3 Note Add proposed LCO Note part c A.2 L.3 Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 112 of 624

Attachment 1, Volume 9, Rev. 0, Page 113 of 624 ITS 3.4.5 A.1 ITS one M.2 ACTION A ACTION B one A.3 ACTION C LA.2 Required Add proposed Required Actions C.1 and D.1 immediately Action D.1 M.2 L.2 OR Two required RCS M.2 ACTION D loops inoperable L.3 M.2 Add proposed Required Action D.1 Add proposed SR 3.4.5.3 NOTE L.4 SR 3.4.5.3 SR 3.4.5.1 LA.3 Add proposed SR 3.4.5.2 M.3 L.3 Page 4 of 4 Attachment 1, Volume 9, Rev. 0, Page 113 of 624

Attachment 1, Volume 9, Rev. 0, Page 114 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 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 3.4.1.2 Footnote

allows all reactor coolant pumps to be de-energized. ITS LCO 3.4.5 Note allows all reactor coolant pumps to be removed from operation.

This changes the word "de-energized" to "removed from operation." In addition, CTS 3.4.1.2 Footnote

only modifies the LCO portion dealing with the requirements when the Control Rod Drive System is not capable of rod withdrawal; the allowance is not applicable when the Control Rod Drive System is capable of rod withdrawal. In the ITS LCO 3.4.5 Note, this is specifically stated as part c of the Note. This changes the CTS by clearly stating when the allowance can be used, with respect to the condition of the Rod Control System.

The purpose of CTS 3.4.1.2 Footnote

is to allow the pumps to not meet the requirement of CTS LCO 3.4.1.2.b to be in operation. The change better reflects the deviation to the LCO. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.4.1.2 Action b requires the restoration of the required number of coolant loops within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or to open the reactor trip breakers. ITS 3.4.5 Required Actions C.1 and D.1 require the Rod Control System to be placed in a condition incapable of rod withdrawal. This changes the CTS by not explicitly stating the requirement to restore the RCS loop to an operating condition. The change from open the reactor trip breakers to place the Rod Control System in a condition incapable of rod withdrawal is covered by DOC LA.2.

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

MORE RESTRICTIVE CHANGES M.1 CTS LCO 3.4.1.2.b states that at least two reactor coolant loops shall be OPERABLE and at least one must be in operation. This requirement is modified by Footnote

that states that all reactor coolant pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.4.5 contains the same allowance, but limits the use of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 9, Rev. 0, Page 114 of 624

Attachment 1, Volume 9, Rev. 0, Page 115 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 The purpose of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is to allow a reactor coolant loop to be removed from operation in order to place another loop in service. This change is acceptable because it helps ensure that boron stratification and inadequate decay heat removal do not occur should multiple 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periods be required.

This change is designated as more restrictive because it limits the allowance to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, and that restriction does not currently exist.

M.2 CTS 3.4.1.2 Action a states that when less than the required reactor coolant loops are OPERABLE, the required loops must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS 3.4.1.2 Action b states that with less than the number of operating coolant loops required by item c (of the LCO statement), restore the required number of coolant loops within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or open the reactor trip breakers.

CTS 3.4.1.2 Action d states that when no reactor coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loop to operation.

ITS 3.4.5 ACTION A specifies the Required Action for one required RCS loop inoperable. The Required Action is to restore the RCS loop to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.4.5 ACTION C specifies the Required Action for one required RCS loop not in operation with Rod Control System capable of rod withdrawal. The Required Action is to place the Rod Control System in a condition incapable of rod withdrawal within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.4.5 ACTION D specifies the Required Actions for two required RCS loops inoperable, two required RCS loops not in operation with Rod Control System capable of rod withdrawal, or the required RCS loop not in operation with Rod Control System not capable of rod withdrawal. The Required Actions are to immediately place the Rod Control System in a condition incapable of rod withdrawal, immediately suspend operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1, and to immediately initiate action to restore one RCS loop to OPERABLE status and operation. This changes the CTS by revising the Actions to immediately require actions to be taken when two required RCS loops are inoperable or two RCS loops are not in operation when the Rod Control System is capable of rod withdrawal.

This change is acceptable because it provides appropriate actions for a loss of all OPERABLE RCS loops. If both required RCS loops are inoperable, allowing 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an RCS loop to OPERABLE status is inappropriate because the loops may not be able to remove the decay heat generated by the reactor.

Immediate action is necessary. Also, the inadvertent rod withdrawal accident assumes two cooling loops are in operation. With no loops in operation, inadvertent rod withdrawal must be prevented. This change is designated as more restrictive because it requires immediate action instead of allowing time for restoration.

M.3 CTS 3.4.1.2 specifies requirements for reactor coolant loops to be OPERABLE with each loop consisting of an RCS loop, its associated steam generator, and its reactor coolant pump. However, CTS 3/4.1.2 does not define the OPERABILITY requirements for the steam generator or provide any associated Surveillance Requirements. ITS SR 3.4.5.2 requires verification that each required steam generator has a secondary side water level above the top of the U-tubes every CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 9, Rev. 0, Page 115 of 624

Attachment 1, Volume 9, Rev. 0, Page 116 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by defining the OPERABILITY requirements for a steam generator, with respect to this Specification.

This change is acceptable because the reactor coolant system loops cannot remove decay heat from the reactor without a heat sink in the steam generators.

The ITS Bases also state that the SR is met if the narrow range instrument is on scale or if the wide range instrument indicates > 76%. This change is designated as more restrictive because it applies new requirements to the steam generators.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.4.1.2 contains a description of what constitutes an OPERABLE RCS loop. ITS 3.4.5 does not include this description of what constitutes an OPERABLE RCS loop. This changes the CTS by moving the details of what constitutes an OPERABLE RCS loop 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 a requirement for the RCS loops 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 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.4.1.2.b specifies requirements for RCS loops when the reactor trip breakers are in the open position or the control rod drive system is not capable of rod withdrawal. CTS 3.4.1.2.c specifies requirements for RCS loops when the reactor trip breakers are in the closed position and the control rod drive system is capable of rod withdrawal. With less than the number of operating RCS loops required by CTS LCO 3.4.1.2.c, CTS 3.4.1.2 Action b requires the restoration of the required RCS loops within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or to open the reactor trip breakers. ITS LCO 3.4.5.a specifies requirements for the RCS loops when the Rod Control System is capable of rod withdrawal. ITS LCO 3.4.5.b specifies requirements for the RCS loops when the Rod Control System is not capable of rod withdrawal. ITS 3.4.5 ACTION C requires the Rod Control System to be placed in a condition incapable of rod withdrawal when one required RCS loop is not in operation with the Rod Control System capable of rod withdrawal. ITS 3.4.5 ACTION D specifies the same Required Action (Required Action D.1). This changes the CTS by moving the details on how to place the CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 9, Rev. 0, Page 116 of 624

Attachment 1, Volume 9, Rev. 0, Page 117 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 Rod Control System in a state capable or incapable of rod withdrawal (i.e., by using the reactor trip breakers) 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 continues to specify requirements on the RCS depending on the status of the Rod Control System's capability to withdraw rods. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.4.1.2.2 states that at least one required reactor coolant loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.5.1 states that the required reactor coolant loops shall be verified to be in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by moving the requirement to verify that the reactor coolant loops are circulating reactor coolant to the Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement that a reactor coolant loop be in operation, and a loop that is in operation will be circulating reactor coolant. As described in the ITS Bases, verification that a reactor coolant loop is in operation includes flow rate, temperature, or pump status monitoring. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS 3.4.1.2.c requires at least three RCS loops to be OPERABLE and in operation when the reactor trip breakers are in the closed position and the control rod drive system is capable of rod withdrawal. ITS LCO 3.4.5 requires two RCS loops to be OPERABLE and ITS LCO 3.4.5.a requires two RCS loops to be in operation when the Rod Control System is capable of rod withdrawal. This changes the CTS by reducing the required number of RCS loops to be OPERABLE and in operation when the Rod Control System is capable of rod withdrawal from three to two.

CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 9, Rev. 0, Page 117 of 624

Attachment 1, Volume 9, Rev. 0, Page 118 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 The purpose of CTS 3.4.1.2 is to ensure the appropriate number of RCS loops are OPERABLE and in operation to support the safety analysis associated with the uncontrolled rod cluster control assembly bank withdrawal event from a subcritical condition. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This change reduces the required number of RCS loops to be OPERABLE and in operation when the Rod Control System is capable of rod withdrawal from three to two and modifies the Required Actions accordingly. The original licensing basis for both Unit 1 and Unit 2 required only two loops to be OPERABLE and in operation. The Unit 2 Technical Specifications were amended (Amendment No. 82) to reflect accident analysis assumptions used in fuel cycle 6. The cycle 6 reactor core represented a transition from Westinghouse Electric Company manufactured fuel to Exxon Nuclear Company manufactured fuel. The analysis for control rod withdrawal events assumed a minimum of three reactor coolant pumps in operation. As such, the Unit 2 Technical Specifications were revised to reflect the analysis. To establish consistency between the Unit 1 Technical Specifications and the Unit 2 Technical Specifications, the Unit 1 Technical Specifications were amended (Amendment No. 120) to require a minimum of three reactor coolant loops in operation when the reactor trip system breakers are in the closed position and the control rod drive system is capable of rod withdrawal. Although the Unit 1 analysis only required two coolant loops, three coolant loops in operation was considered conservative with respect to the safety analysis. Prior to cycle 8 for Unit 2, fresh reload fuel was again furnished by Westinghouse using the Vantage 5 fuel assembly design. The safety analysis for the Vantage 5 reactor core only assumed two coolant loops in operation for the uncontrolled rod cluster control assembly bank withdrawal event. However, neither the Technical Specifications for Unit 2, nor the Technical Specifications for Unit 1, were revised to reflect the latest analysis. Therefore, the proposed change presented is consistent with current analysis and consistent with NUREG-1431. 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.2 (Category 1 - Relaxation of LCO Requirements) CTS 3.4.1.2.d requires at least three RCS loops to be OPERABLE and in operation above P-12. CTS 3.4.1.2 Action c requires the restoration of the required number of coolant loops within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or lower the RCS temperature below P-12. ITS LCO 3.4.5 does not include these requirements. This changes the CTS by deleting the requirements for three RCS loops when the unit is operating above P-12.

According to License Amendment No. 120 for Unit 1 and Amendment No. 107 for Unit 2, the purpose of CTS 3.4.1.2.d is to assure that the requirements of CTS Table 3.3-3, Engineered Safety Features Actuation System, may be met.

This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The requirements to have at least three RCS Loops OPERABLE and in operation above P-12 has been deleted.

CTS Table 3.3-3 requires the Steam Flow in Two Steam Lines - High and the Steam Line Pressure - Low Functions to be OPERABLE in MODES 1, 2, and 3 at and above the P-12 interlock. Both of these Functions provide requirements for only three and four RCS loop operation. These requirements have been CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 9, Rev. 0, Page 118 of 624

Attachment 1, Volume 9, Rev. 0, Page 119 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 changed in ITS 3.3.2 as indicated in the Discussion of Changes for ITS 3.3.2.

These Functions will be applicable with any configuration of the RCS loops.

Therefore reference to the instrumentation Specifications is not necessary. 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.3 (Category 4 - Relaxation of Required Action) CTS 3.4.1.2 Footnote

states that all reactor coolant pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided no operations are permitted that would cause dilution of the reactor coolant system boron concentration. However, CTS LCO 3.4.1.2 Footnote ** clarifies that for purpose of this Specification, addition of water from the refueling water storage tank (RWST) does not constitute a dilution activity provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.8.b.2. CTS 3.4.1.2 Action d states that when no reactor coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended. CTS 3.4.1.2 Action d, Footnote **, also provides the same clarification as is in CTS LCO 3.4.1.2 Footnote **. The ITS LCO 3.4.5 Note states that all reactor coolant pumps may be removed from operation provided no operations are permitted that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1," SHUTDOWN MARGIN (SDM)."

ITS 3.4.5 Required Action D.2 states that operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1 must be suspended. This relaxes the CTS Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1. The detail concerning the RWST boron concentration is also deleted.

The purpose of CTS 3.4.1.2 Footnote

and of CTS 3.4.1.2, including Action d Footnote **, is to ensure that "pockets" of coolant with boron concentration less than that required to maintain the SDM are not created when there is no forced flow through the reactor. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering 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. As long as coolant with boron concentration less than that required to meet the SDM requirement in LCO 3.1.1 is not introduced into the RCS, there is no possibility of creating "pockets" of coolant with less than the required boron concentration. 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.4.1.2.1 states that the required reactor coolant pumps, if not in operation, shall be determined to be OPERABLE by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.5.3 requires verification of CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 9, Rev. 0, Page 119 of 624

Attachment 1, Volume 9, Rev. 0, Page 120 of 624 DISCUSSION OF CHANGES ITS 3.4.5, RCS LOOPS - MODE 3 correct breaker alignment and indicated power availability to each required pump. It is modified by a Note that states "Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation." This changes the CTS by not requiring the SR to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a pump is taken out of operation.

The purpose of CTS 4.4.1.2.1 is to ensure that the standby reactor coolant pump is ready to operate. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The Note provides time to perform the Surveillance to verify correct breaker alignment and indicated power availability. Without the Note, the Surveillance would not be met immediately after taking a pump out of operation. 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 7 of 7 Attachment 1, Volume 9, Rev. 0, Page 120 of 624

Attachment 1, Volume 9, Rev. 0, Page 121 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 127 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.5, RCS LOOPS - MODE 3

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

2. Typographical/grammatical error corrected and editorial change made for enhanced clarity.

3. A provision has been added to the ISTS LCO 3.4.5 Note to require the Rod Control System not to be capable of rod withdrawal. This change is consistent with the current licensing basis.

4. ISTS 3.4.5 Required Action C.1 requires restoration of the required RCS loop to operation or the placement of the Rod Control System in a condition incapable of rod withdrawal. The Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 4.1.6.g, states "A Required Action which requires restoration, such that the Condition is no longer met, is considered superfluous. It is only included if it would be the only Required Action for the Condition or it is needed for presentation clarity." Neither exception applies in this case. Therefore, Required Action C.1 is deleted and the subsequent Required Action renumbered.

5. ISTS 3.4.5 ACTION D has been revised to clearly cover the Conditions of the LCO it is intended to cover. ISTS 3.4.5 ACTION C covers the situation for one required RCS loop not in operation with Rod Control System capable of rod withdrawal. ISTS 3.4.5 Condition D (second condition) is intended to cover the remaining situations when the required RCS loops are not in operation. The appropriate Conditions to cover this situation are Two required RCS loops not in operation with the Rod Control System capable of rod withdrawal and Required RCS loop not in operation with Rod Control System not capable of rod withdrawal. As such, ISTS 3.4.5 Condition D has been revised accordingly.

6. The SG water level value has been changed from referencing a specific instrument to referencing the top of the U-tubes. This will allow the wide range or narrow range instrument (or other qualified indicator) to be used to ensure proper SG water level.

This proposed water level will ensure the U-tubes are covered, which is the intent of the current wide range instrument value.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 127 of 624

Attachment 1, Volume 9, Rev. 0, Page 128 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 134 of 624 B 3.4.5 4

INSERT 3

c. The Rod Control System is not capable of rod withdrawal to avoid an accidental control rod bank withdrawal.

7 INSERT 3A

. A SG is OPERABLE if it meets the requirements of Insert Page B 3.4.5-3 Attachment 1, Volume 9, Rev. 0, Page 134 of 624

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Attachment 1, Volume 9, Rev. 0, Page 140 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.5 BASES, RCS LOOPS - MODE 3

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

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

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

4. Changes are made to reflect those changes made to the ISTS.

5. The Bases of ISTS SR 3.4.5.3 state that "Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability." The Note to SR 3.4.5.3 clearly states that the SR is only required to be performed after a required pump is not in operation. Therefore, the SR does not need to be performed for operating pumps and the statement that there is an alternative method of verification is not necessary. The statement is essentially justifying why the Note to the SR is allowed. As such, a similar statement has been added to the paragraph describing the Note allowance.

6. Typographical/grammatical error corrected.

7. Editorial change made for enhanced clarity.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 140 of 624

Attachment 1, Volume 9, Rev. 0, Page 141 of 624 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 9, Rev. 0, Page 142 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.5, RCS LOOPS - MODE 3 There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 142 of 624

, Volume 9, Rev. 0, Page 143 of 624 ATTACHMENT 6 ITS 3.4.6, RCS LOOPS - MODE 4 , Volume 9, Rev. 0, Page 143 of 624

, Volume 9, Rev. 0, Page 144 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 144 of 624

Attachment 1, Volume 9, Rev. 0, Page 145 of 624 ITS 3.4.6 A.1 ITS LCO 3.4.6 LA.1 L.1 A.2 LCO 3.4.6 per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months M.1 removed from Note period operation A.3 L.2 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 145 of 624

Attachment 1, Volume 9, Rev. 0, Page 146 of 624 ITS 3.4.6 A.1 ITS M.2 Add proposed Required Action A.2 Note one ACTIONS A and B L.3 24 Add proposed Required Actions B.2 and B.2 L.1 ACTION B L.2 A.4 or RHR M.3 SR 3.4.6.3 L.4 Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation SR 3.4.6.2 L.5 above the top of the U-tubes SR 3.4.6.1 LA.2 L.2 Page 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 146 of 624

Attachment 1, Volume 9, Rev. 0, Page 147 of 624 ITS 3.4.6 A.1 ITS LCO 3.4.6 LA.1 L.1 A.2 per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months M.1 LCO 3.4.6 removed from period operation A.3 Note L.2 Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 147 of 624

Attachment 1, Volume 9, Rev. 0, Page 148 of 624 ITS 3.4.6 A.1 ITS M.2 Add proposed Required Action A.2 Note L.3 one ACTIONS A and B Add proposed Required Actions B.1 and B.2 24 L.3 L.1 ACTION B L.2 A.4 or RHR M.3 SR 3.4.6.3 Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation L.4 SR 3.4.6.2 L.5 above the top of the U-tubes SR 3.4.6.1 LA.2 L.2 Page 4 of 4 Attachment 1, Volume 9, Rev. 0, Page 148 of 624

Attachment 1, Volume 9, Rev. 0, Page 149 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 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 3.4.1.3 Footnote

states that the OPERABILITY of a reactor coolant loop does not require an OPERABLE Auxiliary Feedwater System. ITS LCO 3.4.6 does not include this detail. This changes the CTS by deleting the detail that OPERABILITY of the reactor coolant loops do not require an OPERABLE auxiliary feedwater system.

The purpose of the CTS 3.4.1.3 is to provide requirements for the RCS loops.

However, the Auxiliary Feedwater (AFW) System is not normally part of the OPERABILITY requirements for an RCS loop. The AFW System requirements are covered in ITS 3.7.5. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.4.1.3 Footnote ** allows all reactor coolant pumps to be de-energized.

ITS LCO 3.4.6 Note 1 allows all reactor coolant pumps and RHR pumps to be removed from operation. This changes the word "de-energized" to "removed from operation."

The purpose of CTS 3.4.1.3 Footnote ** is to allow the pumps to not meet the requirement of CTS LCO 3.4.1.3 to be in operation. The change better reflects the deviation to the LCO. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.4.1.3.1 states that the required residual heat removal loop(s) shall be determined OPERABLE per Specification 4.0.5, the inservice testing Surveillance Requirements for ASME Code Class 1, 2, and 3 components. ITS 3.4.6 does not contain this explicit Surveillance Requirement. This changes the CTS by deleting the explicit requirement to perform the inservice testing Surveillance Requirements for ASME Code Class 1, 2, and 3 component.

The purpose of CTS 4.4.1.3.1 is to ensure the appropriate inservice testing Surveillance Requirements for ASME Code Class 1, 2, and 3 components are performed for the required residual heat removal loops. The inservice testing requirements of CTS 4.0.5 are retained in ITS 5.5.6, "Inservice Testing Program."

See the Discussion of Changes for ITS 5.5 for any changes to the requirements of CTS 4.0.5. The explicit cross reference is not necessary because when the system is determined to be inoperable when tested in accordance with the inservice testing program, the plant procedures will require the RHR System to be declared inoperable and the appropriate ITS 3.4.6 ACTIONS will be entered when applicable. This change is designated as administrative because it does not result in technical changes to the CTS.

CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 9, Rev. 0, Page 149 of 624

Attachment 1, Volume 9, Rev. 0, Page 150 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 MORE RESTRICTIVE CHANGES M.1 CTS LCO 3.4.1.3.b states that at least two coolant loops shall be OPERABLE and at least one must be in operation. This requirement is modified by Footnote ** that states that all reactor coolant pumps and residual heat removal pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.4.6 contains the same allowance, but limits the use of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

The purpose of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is to allow a coolant loop to be removed from operation in order to place another loop in service. This change is acceptable because it helps ensure that boron stratification and inadequate decay heat removal do not occur should multiple 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periods be required.

This change is designated as more restrictive because it limits an allowance to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, and that restriction does not currently exist.

M.2 CTS 3.4.1.3 Action a states that with less than the above required coolant loops OPERABLE, immediately initiate corrective action to return the required loops to OPERABLE status. ITS 3.4.6 ACTION A specifies the Required Action for one required loop inoperable. The Required Action is to immediately initiate action to restore a second loop to OPERABLE status. ITS 3.4.6 ACTION B specifies the Required Actions for when two required loops are inoperable. The Required Actions are to immediately suspend operations that would cause introduction into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1, and to initiate action to restore one loop to OPERABLE status and operation. This changes the CTS by revising the actions to immediately require actions to be taken when two required loops are inoperable.

This change is acceptable because it provides appropriate actions for two required cooling loops inoperable. Under these conditions, immediate action is necessary to ensure certain unit transients do not occur, and action is taken immediately to restore one loop to OPERABLE status to be able to remove the decay heat generated by the reactor. This change is designated as more restrictive because it requires immediate action in conditions for which the CTS does not require these actions.

M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined OPERABLE by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.6.3 requires verification that correct breaker alignment and indicated power are available to the required pump not in operation. ITS LCO 3.4.6 allows a combination of reactor coolant pumps and RHR pumps. This changes the CTS by requiring verification of correct breaker alignment and indicated power availability on required RHR pumps that are not in operation.

The purpose of the CTS is to ensure a standby pump is available to provide RCS cooling should the operating pump fail. This change is acceptable because the verification of proper breaker alignment and power availability ensures that an additional reactor coolant pump or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. This CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 9, Rev. 0, Page 150 of 624

Attachment 1, Volume 9, Rev. 0, Page 151 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 change is designated as more restrictive because it requires performance of the Surveillance on RHR pumps in addition to reactor coolant pumps.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.4.1.3 contains a description of what constitutes an OPERABLE reactor coolant loop and RHR loop. ITS 3.4.6 does not include this description of what constitutes an OPERABLE reactor coolant or RHR loop. This changes the CTS by moving the details of what constitutes an OPERABLE reactor coolant or RHR loop 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 that the coolant loops 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 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.4.1.3.4 states that at least one coolant loop shall be verified to be in operation and "circulating reactor coolant" at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.6.1 states that an RHR or RCS loop shall be verified to be in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by moving the requirement to verify that the coolant loop is circulating reactor coolant to the Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement that a reactor coolant loop be in operation. As described in the ITS Bases, verification that a reactor coolant loop is in operation includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. 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 CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 9, Rev. 0, Page 151 of 624

Attachment 1, Volume 9, Rev. 0, Page 152 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 CTS LCO 3.4.1.3.c requires at least three reactor coolant loops to be in operation when the reactor trip breakers are in the closed position and the control rod drive system is capable of rod withdrawal. CTS 3.4.1.3 Action b specifies the compensatory actions for less than the number of required OPERABLE or operating coolant loops specified in CTS LCO 3.4.1.3.c. ITS LCO 3.4.6 requires two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops to be OPERABLE, and one loop to be in operation. This changes the CTS by deleting more restrictive coolant loop requirements based on the status of the Rod Control System. In addition, due to this change, the CTS LCO 3.4.1.3.b reference to the position of the reactor trip breakers or the capability of the control rod drive system is deleted.

The purpose of CTS 3.4.1.3, as described in the CTS Bases, is to ensure that sufficient RCS flow and cooling are provided for decay heat removal. In addition, the purpose of the CTS LCO 3.4.1.3.c requirement is to ensure the appropriate number of coolant loops are OPERABLE and in operation to support the safety analysis associated with the uncontrolled rod cluster control assembly bank withdrawal event from a subcritical condition. The original licensing basis for both Unit 1 and Unit 2 required two coolant loops to be OPERABLE and one loop to be in operation in MODE 4. The second reactor coolant pump (RCP) was included for single failure considerations. Requirements to ensure the assumptions for an uncontrolled rod cluster control assembly bank withdrawal event were only included in CTS 3.4.1.2, the MODE 3 RCS loops Technical Specification. This was consistent with the initial RCS temperature and pressure assumptions for the uncontrolled rod cluster control assembly bank withdrawal event, which corresponded to MODE 3. The Unit 2 Technical Specifications were amended (Amendment No. 82) in cycle 6 to reflect a transition from fuel manufactured by Westinghouse Electric Company to fuel manufactured by Exxon Nuclear Company. As a part of this Amendment, requirements related to the number of RCPs required to be in operation were included in both the MODE 3 and MODE 4 RCS loop Technical Specifications (CTS 3.4.1.2 and CTS 3.4.1.3) to correspond to the initial condition of the Exxon Nuclear Company uncontrolled rod cluster control assembly bank withdrawal event. For consistency, the Unit 1 Technical Specifications were revised (Amendment No. 120) in a like manner, even though fuel manufactured by Exxon Nuclear Company was never used in Unit 1. Prior to cycle 8 for Unit 2, fresh reload fuel was again furnished by Westinghouse Electric Company using the Vantage 5 fuel assembly design.

However, the CNP Technical Specifications were not amended to reflect the less restrictive assumptions of the Westinghouse uncontrolled rod cluster control assembly bank withdrawal event analysis. This change was not made because the requirements in the CTS were conservative relative to the initial conditions assumed in the Westinghouse analysis (i.e., the Exxon Nuclear Company uncontrolled rod cluster control assembly bank withdrawal event analysis assumed 3 RCPs in operation while the Westinghouse analysis for the same event assumes only 2 RCPs are in operation). CNP is now revising the CTS to CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 9, Rev. 0, Page 152 of 624

Attachment 1, Volume 9, Rev. 0, Page 153 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 be consistent with the current analysis, including only requiring Technical Specifications to control an uncontrolled rod cluster control assembly bank withdrawal event from a shutdown condition in MODE 3. This change is acceptable for the following reasons: a) It ensures alignment between the CNP Technical Specifications and the initial conditions assumed in the current uncontrolled rod cluster control assembly bank withdrawal event analysis; and b)

It establishes consistency between the CNP Technical Specifications and the ISTS (NUREG-1431, ISTS LCO 3.4.6) and associated ISTS Bases, which do not assume an uncontrolled rod cluster control assembly bank withdrawal event in MODE 4. This is also consistent with the initial accident assumptions required by NUREG-0800, Section 15.4.1 (which discusses the review requirements for an uncontrolled rod cluster control assembly bank withdrawal event), and is consistent with the original CNP licensing basis prior to the transition to fuel manufactured by Exxon Nuclear Company (which did not require Technical Specifications to cover an uncontrolled rod cluster control assembly bank withdrawal event in MODE 4). 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.2 (Category 4 - Relaxation of Required Action) CTS LCO 3.4.1.3 Footnote **

states that all reactor coolant pumps and RHR pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration. However, CTS LCO 3.4.1.3 Footnote *** clarifies that for purposes of this Specification, addition of water from the refueling water storage tank (RWST) does not constitute a dilution activity provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.8.b.2. CTS 3.4.1.3 Action c states that when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended. CTS 3.4.1.3 Action c Footnote *** also provides the same clarification as is in CTS LCO 3.4.1.3 Footnote ***. The ITS LCO 3.4.6 Note states that all reactor coolant pumps and RHR pumps may be removed from operation provided no operations are permitted that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1, "SHUTDOWN MARGIN (SDM)." ITS 3.4.6 Required Action B.1 states that operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1 must be suspended. This relaxes the CTS Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1.

The purpose of the CTS LCO 3.4.1.3 Footnote *** and CTS 3.4.1.3 Action c is to ensure that "pockets" of coolant with boron concentration less than that required to maintain the SDM are not created when there is no forced flow through the reactor. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering 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 CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 9, Rev. 0, Page 153 of 624

Attachment 1, Volume 9, Rev. 0, Page 154 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 replacement, and the low probability of a DBA occurring during the repair period.

As long as coolant with boron concentration less than that required to meet the SDM requirement in LCO 3.1.1 is not introduced into the RCS, there is no possibility of creating "pockets" of coolant with less than the required boron concentration. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 4 - Relaxation of Required Action) CTS 3.4.1.3 Action a states that with less than the required coolant loops OPERABLE, the unit must be placed in COLD SHUTDOWN within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . ITS 3.4.6 Required Action A.2 states that when one required loop is inoperable, the unit must be placed in MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , but only if an RHR loop is OPERABLE. This changes the CTS by providing an exception to the requirement to be in MODE 5 and allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months instead of 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months to reach MODE 5.

The purpose of CTS 3.4.1.3 Action a is to require the unit to be brought to a MODE in which the LCO does not apply. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. The revised actions provide appropriate compensatory measures for an inoperable loop. The CTS requires a cooldown to MODE 5 even if no RHR loops are OPERABLE (i.e., the only OPERABLE loop is an RCS loop.) With only an RCS loop OPERABLE, it is safer to stay in MODE 4 so that the steam generators can be used to remove decay heat. If a cooldown to MODE 5 is required, allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months instead of 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months is consistent with the times provided in other Specifications, including ITS LCO 3.0.3, to transition from MODE 4 to MODE 5 and is a reasonable time to reach MODE 5 from MODE 4 in an orderly manner and without challenging unit systems. 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined to be OPERABLE once per 7 days by verifying correct breaker alignments and indicated power availability. ITS SR 3.4.6.3 requires verification of correct breaker alignment and indicated power availability to the required pump that is not in operation every 7 days. It is modified by a Note that states "Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation." This changes the CTS by not requiring the SR to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a pump is taken out of operation.

The purpose of CTS 4.4.1.3.2 is to ensure that the standby pump is ready to operate. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The Note provides time to perform the Surveillance to verify correct CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 9, Rev. 0, Page 154 of 624

Attachment 1, Volume 9, Rev. 0, Page 155 of 624 DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 breaker alignment and indicated power availability. Without the Note, the Surveillance would not be met immediately after taking a pump out of operation.

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

L.5 CTS 4.4.1.3.3 states that the required steam generator(s) shall be determined OPERABLE by verifying secondary side water level is greater than or equal to 76% of wide range instrument span. ITS SR 3.4.6.2 requires verification that the steam generator (SG) secondary side water levels are above the top of the U-tubes for the required RCS loops steam generators. This changes the CTS by changing the requirement to specifically state the required water level as referenced to a specific point inside the steam generators instead of using a specific indication from one instrument.

The purpose of CTS 4.4.1.3.3 is to provide assurance that the SG water level is above the top of the U-tubes. The change is acceptable since the proposed SG level will continue to ensure that the SG water level is above the top of the U-tubes, ensuring that an adequate secondary side heat sink is maintained. This requirement is also consistent with the NRC Safety Evaluation Report (SER) for License Amendments 224 (Unit 1) and 208 (Unit 2), dated November 27, 1998, which stated that the requirement is to ensure the U-tubes are covered. Also, as stated in the NRC SER, the current value, based on the wide range instrument, is a conservative value. The ITS will continue to require a periodic check to ensure proper SG levels are maintained, and the Bases states that one method for verifying the SG water level is within the limit is to verify the SG water level is

> 76% wide range instrument span (a second method using the narrow range instrument is also being included in the Bases). This change is defined as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 7 of 7 Attachment 1, Volume 9, Rev. 0, Page 155 of 624

Attachment 1, Volume 9, Rev. 0, Page 156 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 156 of 624

, Volume 9, Rev. 0, Page 157 of 624 , Volume 9, Rev. 0, Page 157 of 624

, Volume 9, Rev. 0, Page 158 of 624 , Volume 9, Rev. 0, Page 158 of 624

Attachment 1, Volume 9, Rev. 0, Page 159 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.6, RCS LOOPS - MODE 4

1. ISTS LCO 3.4.6 Note 2 concerning the startup of an RCP has been deleted. The purpose of the LCO Note Section is to provide exceptions to the applicable LCO.

This specific Note provides a restriction for starting up an RCP; however, the restriction is a low temperature overpressure protection (LTOP) concern. ISTS LCO 3.4.6 does not cover LTOP issues; it is related to coolant circulation only. The ISTS limitations for LTOP are covered in ISTS 3.4.12, "Low Temperature Overpressure Protection (LTOP) System." As such, this specific requirement (ISTS LCO 3.4.6 Note 2) will be covered by the LTOP System LCO and a specific cross reference to this requirement is not necessary in this Specification. This is also consistent with the current licensing basis, which does not include this note in the RCS Loops - Hot Shutdown Specification.

2. Editorial change made for enhanced clarity.

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

4. The SG water level value has been changed from referencing a specific instrument to referencing the top of the U-tubes. This will allow the wide range or narrow range instrument (or other qualified indicator) to be used to ensure proper SG water level.

This proposed water level will ensure the U-tubes are covered, which is the intent of the current wide range instrument value.

5. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 159 of 624

Attachment 1, Volume 9, Rev. 0, Page 160 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 160 of 624

, Volume 9, Rev. 0, Page 161 of 624 , Volume 9, Rev. 0, Page 161 of 624

, Volume 9, Rev. 0, Page 162 of 624 , Volume 9, Rev. 0, Page 162 of 624

, Volume 9, Rev. 0, Page 163 of 624 , Volume 9, Rev. 0, Page 163 of 624

Attachment 1, Volume 9, Rev. 0, Page 164 of 624 B 3.4.6 2

INSERT 2 "Shutdown Margin (SDM),"

5 INSERT 3

. A SG is OPERABLE if it meets the requirements of 2

INSERT 4 (either the east or west)

Insert Page B 3.4.6-2 Attachment 1, Volume 9, Rev. 0, Page 164 of 624

, Volume 9, Rev. 0, Page 165 of 624 , Volume 9, Rev. 0, Page 165 of 624

, Volume 9, Rev. 0, Page 166 of 624 , Volume 9, Rev. 0, Page 166 of 624

, Volume 9, Rev. 0, Page 167 of 624 , Volume 9, Rev. 0, Page 167 of 624

, Volume 9, Rev. 0, Page 168 of 624 , Volume 9, Rev. 0, Page 168 of 624

, Volume 9, Rev. 0, Page 169 of 624 , Volume 9, Rev. 0, Page 169 of 624

Attachment 1, Volume 9, Rev. 0, Page 170 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.6 BASES, RCS LOOPS - MODE 4

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

2. Changes are made to reflect those changes made to the ISTS.

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

4. 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.

5. Editorial change made for enhanced clarity.

6. The Bases of ISTS SR 3.4.6.3 state that "Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability." The Note to SR 3.4.6.3 clearly states that the SR is only required to be performed after a required pump is not in operation. Therefore, the SR does not need to be performed for operating pumps and the statement that there is an alternative method of verification is not necessary. The statement is essentially justifying why the Note to the SR is allowed. As such, a similar statement has been added to the paragraph describing the Note allowance.

7. Grammatical error correcteed.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 170 of 624

Attachment 1, Volume 9, Rev. 0, Page 171 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 171 of 624

Attachment 1, Volume 9, Rev. 0, Page 172 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.6, RCS LOOPS - MODE 4 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.1 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS LCO 3.4.1.3.c requires at least three reactor coolant loops to be in operation when the reactor trip breakers are in the closed position and the control rod drive system is capable of rod withdrawal. CTS 3.4.1.3 Action b specifies the compensatory actions for less than the number of required OPERABLE or operating coolant loops specified in CTS LCO 3.4.1.3.c. ITS LCO 3.4.6 requires two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops to be OPERABLE, and one loop to be in operation. This changes the CTS by deleting more restrictive coolant loop requirements based on the status of the Rod Control System. In addition, due to this change, the CTS LCO 3.4.1.3.b reference to the position of the reactor trip breakers or the capability of the control rod drive system is deleted.

The purpose of CTS 3.4.1.3, as described in the CTS Bases, is to ensure that sufficient RCS flow and cooling are provided for decay heat removal. In addition, the purpose of the CTS LCO 3.4.1.3.c requirement is to ensure the appropriate number of coolant loops are OPERABLE and in operation to support the safety analysis associated with the uncontrolled rod cluster control assembly bank withdrawal event from a subcritical condition. The original licensing basis for both Unit 1 and Unit 2 required two coolant loops to be OPERABLE and one loop to be in operation in MODE 4. The second reactor coolant pump (RCP) was included for single failure considerations. Requirements to ensure the assumptions for an uncontrolled rod cluster control assembly bank withdrawal event were only included in CTS 3.4.1.2, the MODE 3 RCS loops Technical Specification. This was consistent with the initial RCS temperature and pressure assumptions for the uncontrolled rod cluster control assembly bank withdrawal event, which corresponded to MODE 3. The Unit 2 Technical Specifications were amended (Amendment No. 82) in cycle 6 to reflect a transition from fuel manufactured by Westinghouse Electric Company to fuel manufactured by Exxon Nuclear Company. As a part of this Amendment, requirements related to the number of RCPs required to be in operation were included in both the MODE 3 and MODE 4 RCS loop Technical Specifications (CTS 3.4.1.2 and CTS 3.4.1.3) to correspond to the initial condition of the Exxon Nuclear Company uncontrolled rod cluster control assembly bank withdrawal event. For consistency, the Unit 1 Technical Specifications were revised (Amendment No. 120) in a like manner, even though fuel manufactured by Exxon Nuclear Company was never used in Unit 1. Prior to cycle 8 for Unit 2, fresh reload fuel was again furnished by Westinghouse Electric Company using the Vantage 5 fuel assembly design.

However, the CNP Technical Specifications were not amended to reflect the less restrictive assumptions of the Westinghouse uncontrolled rod cluster control assembly bank withdrawal event analysis. This change was not made because the requirements in the CTS were conservative relative to the initial conditions assumed in the Westinghouse analysis (i.e., the Exxon Nuclear Company uncontrolled rod cluster control assembly bank withdrawal event analysis assumed 3 RCPs in operation while the Westinghouse analysis for the same event assumes only 2 RCPs are in operation).

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 9, Rev. 0, Page 172 of 624

Attachment 1, Volume 9, Rev. 0, Page 173 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.6, RCS LOOPS - MODE 4 CNP is now revising the CTS to be consistent with the current analysis, including only requiring Technical Specifications to control an uncontrolled rod cluster control assembly bank withdrawal event from a shutdown condition in MODE 3. This change is acceptable for the following reasons: a) It ensures alignment between the CNP Technical Specifications and the initial conditions assumed in the current uncontrolled rod cluster control assembly bank withdrawal event analysis; and b) It establishes consistency between the CNP Technical Specifications and the ISTS (NUREG-1431, ISTS LCO 3.4.6) and associated ISTS Bases, which do not assume an uncontrolled rod cluster control assembly bank withdrawal event in MODE 4. This is also consistent with the initial accident assumptions required by NUREG-0800, Section 15.4.1 (which discusses the review requirements for an uncontrolled rod cluster control assembly bank withdrawal event), and is consistent with the original CNP licensing basis prior to the transition to fuel manufactured by Exxon Nuclear Company (which did not require Technical Specifications to cover an uncontrolled rod cluster control assembly bank withdrawal event in MODE 4). This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

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

as discussed below:

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

Response: No.

The proposed change deletes the dependence of coolant loop requirements on the capability of Rod Control System to be able to withdraw control rods and revises the LCO and actions consistent with the initial licensing basis and also consistent with the ISTS. This change will not affect the probability of an accident, since the OPERABILITY or operation of coolant loops is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident will be bounded by the UFSAR analysis. 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 deletes the dependence of coolant loop requirements on the capability of Rod Control System to be able to withdraw control rods, and revises the LCO and actions consistent with the initial licensing basis and consistent with the ISTS. This change will not physically alter the plant (no new or different type of equipment will be installed), and no new or revised operator actions are proposed. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 9, Rev. 0, Page 173 of 624

Attachment 1, Volume 9, Rev. 0, Page 174 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.6, RCS LOOPS - MODE 4

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change deletes the dependence of coolant loop requirements on the capability of Rod Control System to be able to withdraw control rods, and revises the LCO and actions consistent with the initial licensing basis and consistent with the ISTS. The margin of safety is not affected by this change because the safety analysis assumptions are not affected. The UFSAR analysis will bound the consequences of an uncontrolled rod cluster control assembly bank withdrawal event. 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 3 of 5 Attachment 1, Volume 9, Rev. 0, Page 174 of 624

Attachment 1, Volume 9, Rev. 0, Page 175 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.6, RCS LOOPS - MODE 4 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.5 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS 4.4.1.3.3 states that the required steam generator(s) shall be determined OPERABLE by verifying secondary side water level is greater than or equal to 76% of wide range instrument span. ITS SR 3.4.6.2 requires verification that the steam generator (SG) secondary side water levels are above the top of the U-tubes for the required RCS loops. This changes the CTS by changing the requirement to specifically state the required water level as referenced to a specific point inside the steam generators in lieu of using a specific indication from one instrument.

The purpose of CTS 4.4.1.3.3 is to provide assurance that the SG water level is above the top of the U-tubes. The change is acceptable since the proposed SG level will continue to ensure that the SG water level is above the top of the U-tubes, ensuring that an adequate secondary side heat sink is maintained. This requirement is also consistent with the NRC Safety Evaluation Report (SER) for Amendments 224 (Unit 1) and 208 (Unit 2), dated November 27, 1998, which stated that the requirement is to ensure the U-tubes are covered. Also, as stated in the NRC SER, the current value, based on the wide range instrument, is a conservative value. The ITS will continue to require a periodic check to ensure proper SG levels are maintained, and the Bases states that one method for verifying the SG water level is within the limit is to verify the SG water level is

> 76% wide range instrument span (a second method, using the narrow range instrument, is also being included in the Bases). This change is defined as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

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

as discussed below:

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

Response: No.

The proposed change deletes the requirement that the steam generator secondary side water level limit be referenced to a wide range instrument level, and allows the limit to be referenced to a specific point inside the steam generator. This change will not affect the probability of an accident, since the steam generator wide range instrument is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident are not affected by this change since the steam generator water level is still required to be maintained above the top of the U-tubes, consistent with the purpose of CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 9, Rev. 0, Page 175 of 624

Attachment 1, Volume 9, Rev. 0, Page 176 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.6, RCS LOOPS - MODE 4 maintaining a specific wide range water level. 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 deletes the requirement that the steam generator secondary side water level limit be referenced to a wide range instrument level, and allows the limit to be referenced to a specific point inside the steam generator. This change will not physically alter the plant (no new or different type of equipment will be installed), and no new or revised operator actions are proposed. The changes in the method to verify steam generator water level is above the top of the U-tubes is consistent with plant design and capability.

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 that the steam generator secondary side water level limit be referenced to a wide range instrument level, and allows the limit to be referenced to a specific point inside the steam generator. The margin of safety is not affected by this change because the safety analysis assumptions are not affected. The SG water level is still required to be maintained above the top of the U-tubes, ensuring that an adequate secondary side heat sink is maintained. This requirement is also consistent with the NRC SER for License Amendments 224 (Unit 1) and 208 (Unit 2), dated November 27, 1998, which stated that the requirement is to ensure the U-tubes are covered. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 9, Rev. 0, Page 176 of 624

, Volume 9, Rev. 0, Page 177 of 624 ATTACHMENT 7 ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED , Volume 9, Rev. 0, Page 177 of 624

, Volume 9, Rev. 0, Page 178 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 178 of 624

Attachment 1, Volume 9, Rev. 0, Page 179 of 624 ITS 3.4.7 A.1 ITS LCO 3.4.7 above the top of the U-tubes L.3 ACTIONS A and B Add proposed Condition C first part M.1 ACTION C L.1 OPERABLE status and one M.1 SR 3.4.7.2 LA.1 M.2 SR 3.4.7.1 Add proposed SR 3.4.7.3 M.3 per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period LCO 3.4.7 L.1 Note 1 LCO 3.4.7 Note 2 See ITS 3.4.12 A.2 L.1 Add proposed LCO 3.4.7 Note 3 L.2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 179 of 624

Attachment 1, Volume 9, Rev. 0, Page 180 of 624 ITS 3.4.7 A.1 ITS LCO 3.4.7 above the top of the U-tubes L.3 ACTIONS A and B Add proposed Condition C first part M.1 ACTION C L.1 OPERABLE status and one M.1 SR 3.4.7.2 LA.1 SR 3.4.7.1 M.2 Add proposed SR 3.4.7.3 M.3 per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period LCO 3.4.7 L.1 Note 1 LCO 3.4.7 Note 2 See ITS 3.4.12 A.2 L.1 Add proposed LCO 3.4.7 Note 3 L.2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 180 of 624

Attachment 1, Volume 9, Rev. 0, Page 181 of 624 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED 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 3.4.1.4 states that residual heat removal (RHR) loops shall be OPERABLE.

Footnote to the LCO states that the OPERABLE RHR loops may have inoperable offsite or emergency power sources. ITS 3.4.7 does not contain a specific allowance for an OPERABLE RHR loop to have an offsite or emergency power source inoperable.

This change is acceptable because the ITS definition of OPERABLE -

OPERABILITY requires an OPERABLE component to have only a normal or an emergency power source. This change to the CTS definition of OPERABLE -

OPERABILITY is discussed in the ITS Section 1.0 Discussion of Changes.

Given this change to the definition of OPERABLE - OPERABILITY, a specific allowance for the RHR loops is not required. This change is designated as editorial as it replaces a specific exception with an ITS change in the definition of OPERABLE - OPERABILITY.

MORE RESTRICTIVE CHANGES M.1 CTS 3.4.1.4 Actions do not include Actions for when there are no required RHR loops OPERABLE. ITS 3.4.7 ACTION C includes this Condition and requires the immediate suspension of operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1, and to immediately initiate action to restore one RHR loop to OPERABLE status and operation. This changes the CTS by adding the explicit requirements to ITS 3.4.7.

The purpose of ITS 3.4.7 ACTION C is to provide the appropriate compensatory action for inoperable RHR loops. This change is acceptable because it provides additional assurance that the appropriate compensatory actions will be taken with no RHR loops OPERABLE. This change is designated as more restrictive, because it adds an explicit ACTION for which there is no CTS Action.

M.2 CTS 3/4.4.1.4 does not contain an explicit Surveillance Requirement to verify correct breaker alignment and indicated power for the required RHR pump that is not in operation. ITS SR 3.4.7.3 requires this SR to be conducted every 7 days, however the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. This changes the CTS by adding the ITS requirement of SR 3.4.7.3.

CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 181 of 624

Attachment 1, Volume 9, Rev. 0, Page 182 of 624 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED The purpose of ITS SR 3.4.7.3 is to ensure the RHR pump can start, if necessary. This change is acceptable because it provides additional assurance that the RHR pump will have power for immediate startup, if necessary. This change is designated as more restrictive, because it adds a SR to the CTS.

M.3 CTS 3.4.1.4 states the number of coolant loops that shall be OPERABLE, and states that at least one RHR loop must be in operation. This requirement is modified by a note that states that the RHR pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.4.7 contains the same allowance, but limits the use of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

The purpose of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is to allow the RHR pump to be removed from operation in order to place the other RHR pump in service. This change is acceptable because it helps ensure that boron stratification and inadequate decay heat removal do not occur should multiple 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periods be required.

This change is designated as more restrictive because it limits an allowance to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, and that restriction does not currently exist.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.4.1.4.2 states that at least one RHR loop shall be determined to be in operation and "circulating reactor coolant" at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.7.1 states that an RHR loop shall be verified to be in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by moving the requirement to verify that the RHR loop is circulating reactor coolant to the Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement that a reactor coolant loop be in operation. As described in the ITS Bases, verification that a reactor coolant loop is in operation includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. 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 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 182 of 624

Attachment 1, Volume 9, Rev. 0, Page 183 of 624 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.4.1.4 Footnote

states that the RHR pump may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration. However, CTS 3.4.1.4 Footnote clarifies that for purposes of this Specification, addition of water from the refueling water storage tank (RWST) does not constitute a dilution activity provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.7.b.2. CTS 3.4.1.4 Action b states that when no RHR loop is in operation, all operations involving a reduction in boron concentration of the RCS must be suspended. ITS LCO 3.4.7 Note 1 states that the RHR pump of the loop in operation may be removed from operation provided no operations are permitted that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1, "SHUTDOWN MARGIN (SDM)." ITS 3.4.7 Required Action C.1 states that operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1 must be suspended. This relaxes the CTS Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1.

The purpose of the CTS 3.4.1.4 LCO Footnote and Action b is to ensure that "pockets" of coolant with boron concentration less than that required to maintain the SDM are not created when there is no forced flow through the reactor. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering 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. As long as coolant with boron concentration less than that required to meet the SDM requirement in LCO 3.1.1 is not introduced into the RCS, there is no possibility of creating "pockets" of coolant with less than the required boron concentration.

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 1 - Relaxation of LCO Requirements) CTS 3.4.1.4 places OPERABILITY requirements for the RHR loops to be OPERABLE and operating.

ITS 3.4.7 specifies the same requirements; however, ITS LCO 3.4.7 Note 3 allows all RHR loops to be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation. This changes the CTS by adding this allowance during planned heatup operations to MODE 4.

The purpose of CTS LCO 3.4.1.4 is to ensure there is sufficient forced circulation to prevent boric acid stratification and to provide forced flow for decay heat removal and transport. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 183 of 624

Attachment 1, Volume 9, Rev. 0, Page 184 of 624 DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED change allows an RCS loop to be in operation instead of an RHR loop. The RCS loop simply replaces the function of the RHR loop. 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.3 CTS 3.4.1.4.b states that the secondary side water level of at least two steam generators shall be greater than or equal to 76% of wide range instrument span.

ITS LCO 3.4.7.b requires the secondary side water level of at least two steam generators to be above the top of the U-tubes. This changes the CTS by changing the requirement to specifically state the required water level as referenced to a specific point inside the steam generators instead of using a specific indication from one instrument.

The purpose of CTS 3.4.1.4.b is to provide assurance that the SG water level is above the top of the U-tubes. The change is acceptable since the proposed SG level will continue to ensure that the SG water level is above the top of the U-tubes, ensuring that an adequate secondary side heat sink is maintained. This requirement is also consistent with the NRC Safety Evaluation Report (SER) for License Amendments 224 (Unit 1) and 208 (Unit 2), dated November 27, 1998, which stated that the requirement is to ensure the U-tubes are covered. Also, as stated in the NRC SER, the current value, based on the wide range instrument, is a conservative value. The ITS will continue to require a periodic check to ensure proper SG levels are maintained, and the Bases states that one method for verifying the SG water level is within the limit is to verify the SG water level is

> 76% wide range instrument span (a second method, using the narrow range instrument, is also being included in the Bases). This change is defined as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 9, Rev. 0, Page 184 of 624

Attachment 1, Volume 9, Rev. 0, Page 185 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 185 of 624

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Attachment 1, Volume 9, Rev. 0, Page 189 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED

1. Editorial/grammatical change made for enhanced clarity.

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

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

4. ISTS LCO 3.4.7 Note 3 concerning the startup of an RCP has been deleted. The purpose of an LCO Note is to provide exceptions to the applicable LCO. The Note provides a restriction for starting an RCP because there may be a low temperature overpressure concern. The ISTS limitations on low temperature overpressure concerns have been included in ITS 3.4.12, "Low Temperature Overpressure Protection (LTOP) System." The requirements in ITS 3.4.12 provide sufficient limitations on low temperature overpressure concerns and a cross reference is not necessary. The subsequent Note has been renumbered.

5. The SG water level value has been changed from referencing a specific instrument to referencing the top of the U-tubes. This will allow the wide range or narrow range instrument (or other qualified indicator) to be used to ensure proper SG water level.

This proposed water level will ensure the U-tubes are covered, which is the intent of the current wide range instrument value.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 189 of 624

Attachment 1, Volume 9, Rev. 0, Page 190 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 190 of 624

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Attachment 1, Volume 9, Rev. 0, Page 200 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.7 BASES, RCS LOOPS - MODE 5, LOOPS FILLED

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

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

3. Changes are made to reflect those changes made to the ISTS.

4. The Bases has been revised to reflect the ISTS.

5. The Bases of ISTS SR 3.4.7.3 state that "Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability." The Note to SR 3.4.7.3 clearly states that the SR is only required to be performed after a required pump is not in operation. Therefore, the SR does not need to be performed for operating pumps and the statement that there is an alternative method of verification is not necessary. The statement is essentially justifying why the Note to the SR is allowed. As such, a similar statement has been added to the paragraph describing the Note allowance.

6. Editorial change made to be consistent with the rest of the paragraph.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 200 of 624

Attachment 1, Volume 9, Rev. 0, Page 201 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 201 of 624

Attachment 1, Volume 9, Rev. 0, Page 202 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.3 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS 3.4.1.4.b states that the secondary side water level of at least two steam generators shall be greater than or equal to 76% of wide range instrument span. ITS LCO 3.4.7.b requires the secondary side water level of at least two steam generators to be above the top of the U-tubes. This changes the CTS by changing the requirement to specifically state the required water level as referenced to a specific point inside the steam generators in lieu of using a specific indication from one instrument.

The purpose of CTS 3.4.1.4.b is to provide assurance that the SG water level is above the top of the U-tubes. The change is acceptable since the proposed SG level will continue to ensure that the SG water level is above the top of the U-tubes, ensuring that an adequate secondary side heat sink is maintained. This requirement is also consistent with the NRC Safety Evaluation Report (SER) for License Amendments 224 (Unit 1) and 208 (Unit 2), dated November 27, 1998, which stated that the requirement is to ensure the U-tubes are covered. Also, as stated in the NRC SER, the current value, based on the wide range instrument, is a conservative value. The ITS will continue to require a periodic check to ensure proper SG levels are maintained, and the Bases states that one method for verifying the SG water level is within the limit is to verify the SG water level is

> 76% wide range instrument span (a second method, using the narrow range instrument, is also being included in the Bases). This change is defined as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

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

as discussed below:

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

Response: No.

The proposed change deletes the requirement that the steam generator secondary side water level limit be referenced to a wide range instrument level, and allows the limit to be referenced to a specific point inside the steam generator. This change will not affect the probability of an accident, since the steam generator wide range instrument is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident are not affected by this change since the steam generator water level is still required to be maintained above the top of the U-tubes, consistent with the purpose of CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 202 of 624

Attachment 1, Volume 9, Rev. 0, Page 203 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED maintaining a specific wide range water level. 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 deletes the requirement that the steam generator secondary side water level limit be referenced to a wide range instrument level, and allows the limit to be referenced to a specific point inside the steam generator. This change will not physically alter the plant (no new or different type of equipment will be installed), and no new or revised operator actions are proposed. The changes in the method to verify steam generator water level is above the top of the U-tubes is consistent with plant design and capability.

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 that the steam generator secondary side water level limit be referenced to a wide range instrument level, and allows the limit to be referenced to a specific point inside the steam generator. The margin of safety is not affected by this change because the safety analysis assumptions are not affected. The SG water level is still required to be maintained above the top of the U-tubes, ensuring that an adequate secondary side heat sink is maintained. This requirement is also consistent with the NRC SER for License Amendments 224 (Unit 1) and 208 (Unit 2), dated November 27, 1998, which stated that the requirement is to ensure the U-tubes are covered. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 203 of 624

Attachment 1, Volume 9, Rev. 0, Page 204 of 624 ATTACHMENT 8 ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED Attachment 1, Volume 9, Rev. 0, Page 204 of 624

, Volume 9, Rev. 0, Page 205 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 205 of 624

Attachment 1, Volume 9, Rev. 0, Page 206 of 624 ITS 3.4.8 A.1 ITS LCO 3.4.8 ACTION A M.1 Add proposed Condition B first part ACTION B L.1 one OPERABLE status and M.1 SR 3.4.8.1 LA.1 Add proposed SR 3.4.8.2 M.2 M.3 LCO 3.4.8 L.1 Note 1 Add proposed LCO 3.4.8 Note 1 part c M.3 LCO 3.4.8 Note 2 A.2 L.1 Page 1 of 3 Attachment 1, Volume 9, Rev. 0, Page 206 of 624

Attachment 1, Volume 9, Rev. 0, Page 207 of 624 ITS 3.4.8 A.1 ITS LCO 3.4.8 ACTION A M.1 Add proposed Condition B first part ACTION B L.1 one OPERABLE status and M.1 SR 3.4.8.1 LA.1 Add proposed SR 3.4.8.2 M.2 M.3 LCO 3.4.8 L.1 Note 1 Add proposed LCO 3.4.8 Note 1 part c M.3 LCO 3.4.8 Note 2 A.2 L.1 Page 2 of 3 Attachment 1, Volume 9, Rev. 0, Page 207 of 624

, Volume 9, Rev. 0, Page 208 of 624 ITS 3.4.8 A.1 Page 3 of 3 , Volume 9, Rev. 0, Page 208 of 624

Attachment 1, Volume 9, Rev. 0, Page 209 of 624 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOP - MODE 5, LOOPS NOT FILLED 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 3.4.1.5 states that at least two RHR loops shall be OPERABLE. Footnote to the LCO states that the OPERABLE RHR loops may have inoperable offsite or emergency power sources. ITS 3.4.8 does not contain a specific allowance for an OPERABLE RHR loop to have an offsite or emergency power source inoperable.

This change is acceptable because the ITS definition of OPERABLE -

OPERABILITY requires an OPERABLE component to have only a normal or emergency power source. This change to the CTS definition of OPERABLE -

OPERABILITY is discussed in the ITS Section 1.0 Discussion of Change. Given this change to the definition of OPERABLE - OPERABILITY, a specific allowance for the RHR loops is not required. This change is designated as editorial as it replaces a specific exception with an ITS change in the definition of OPERABLE

- OPERABILITY.

MORE RESTRICTIVE CHANGES M.1 CTS 3.4.1.5 Actions do not include actions for when there is no required RHR loops OPERABLE. ITS 3.4.8 ACTION B includes this Condition and requires the immediate suspension of operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1 and to immediately initiate action to restore one RHR loop to OPERABLE status and operation. This changes the CTS by adding the explicit Condition for no required RHR loop OPERABLE and provides the appropriate compensatory actions.

The purpose of ITS 3.4.8 ACTION B is to provide the appropriate compensatory action for no OPERABLE RHR loops. This change is acceptable because it provides additional assurance that the appropriate compensatory actions will be taken with no RHR loops OPERABLE. This change is designated as more restrictive, because it adds an explicit ACTION for which there is no CTS Action.

M.2 CTS 4.4.1.5 does not contain an explicit requirement to verify correct breaker alignment and indicated power for the required RHR pump that is not in operation. ITS SR 3.4.8.2 requires this SR to be conducted every 7 days, however the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. This changes the CTS by adding the ITS requirement of SR 3.4.8.2.

CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 9, Rev. 0, Page 209 of 624

Attachment 1, Volume 9, Rev. 0, Page 210 of 624 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOP - MODE 5, LOOPS NOT FILLED The purpose of ITS SR 3.4.8.2 is to ensure the RHR pump can start, if necessary. This change is acceptable because it provides additional assurance that the RHR pump will have power for immediate startup, if necessary. This change is designated as more restrictive, because it adds a SR to the Technical Specifications.

M.3 CTS 3.4.1.5 Footnote

contains an allowance for the RHR pump to be de-energized for up to one hour. ITS LCO 3.4.8 Note 1 allows all RHR pumps to be removed from operation for 30 minutes only when switching from one loop to the other, and also requires that no draining operations to further reduce the RCS water volume are permitted (part c). This changes the CTS by reducing the time allowed for the RHR pump to be de-energized from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 30 minutes, restricts the allowance to only pump switching operations, and adds a restriction that no draining operations are permitted to further reduce the RCS water volume.

The purpose of the CTS 3.4.1.5 Footnote

is to allow the RCS loops to be switched from one to the other. This change is acceptable because ITS LCO 3.4.8 Note 1 provides sufficient time to perform loop switching operations and provide adequate controls. Stopping all operating RHR loops when the RCS is not filled should be limited to short periods of time because of the reduced inventory of water available to absorb decay heat. Stopping all RHR pumps during loop swapping operations is necessary, because pump vortexing may occur if both pumps are run simultaneously. Thirty minutes is sufficient time to perform the loop swapping operation without excessive increases in RCS average temperature due to lack of decay heat removal. Adding the additional condition that no draining operations be performed when the pumps are stopped is reasonable given the low RCS water level and the unavailability of the RHR pumps to add inventory to the RCS, if needed. This change is more restrictive because it reduces the time an RHR loop may be out of service and adds an additional restriction.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.4.1.5 states that at least one RHR loop shall be determined to be in operation and "circulating reactor coolant" at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.8.1 states that the required RHR loop shall be verified to be in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by moving the requirement to verify that the RHR loop is circulating reactor coolant to the Bases.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 9, Rev. 0, Page 210 of 624

Attachment 1, Volume 9, Rev. 0, Page 211 of 624 DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOP - MODE 5, LOOPS NOT FILLED protection of the public health and safety. The ITS retains the requirement that a reactor coolant loop be in operation. As described in the ITS Bases, verification that a reactor coolant loop is in operation includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.4.1.5 Footnote

states that the RHR pump may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided no operations are permitted that would cause dilution of the reactor coolant system boron concentration. However, CTS 3.4.1.5 Footnote clarifies that for purposes of this Specification, addition of water from the refueling water storage tank (RWST) does not constitute a dilution activity provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.7.b.2. CTS 3.4.1.5 Action b states that when no coolant loop is in operation, all operations involving a reduction in boron concentration of the RCS must be suspended. ITS LCO 3.4.8 Note 1 states that all RHR pumps may be removed from operation provided no operations are permitted that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1, "SHUTDOWN MARGIN (SDM)."

ITS 3.4.8 Required Action B.1 states that operations that would cause introduction, into the RCS, of coolant with boron concentration less than required to meet the requirements of LCO 3.1.1 must be suspended. This relaxes the CTS Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1.

The purpose of the CTS 3.4.1.5 LCO Footnote and Action b is to ensure that "pockets" of coolant with boron concentration less than that required to maintain the SDM are not created when there is no forced flow through the reactor. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering 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. As long as coolant with boron concentration less than that required to meet the SDM requirement in LCO 3.1.1 is not introduced into the RCS, there is no possibility of creating "pockets" of coolant with less than the required boron concentration.

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

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 9, Rev. 0, Page 211 of 624

Attachment 1, Volume 9, Rev. 0, Page 212 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 214 of 624 3.4.8 1

INSERT 1

, "SHUTDOWN MARGIN (SDM)"

Insert Page 3.4.8-1 Attachment 1, Volume 9, Rev. 0, Page 214 of 624

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Attachment 1, Volume 9, Rev. 0, Page 216 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.8, RCS LOOP - MODE 5, LOOPS NOT FILLED

1. Editorial change made for enhanced clarity or to be consistent with other places in the Specifications.

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

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

4. The time provided to allow all RHR pumps to be removed from service has been changed from 15 minutes to 30 minutes. In the CTS, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is currently provided.

This current 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time is sufficient time to allow the operators to swap the pumps in a controlled manner without rushing through the evolution, and provides some additional time in case difficulties arise during the pump swap evolution. Reducing the time to 30 minutes will still allow the operators the time to swap the pumps in a controlled manner without rushing through the evolution, yet removes most of the additional time currently provided.

5. The limit has been changed to be consistent with the same limit provided in Notes to ISTS 3.4.6 and ISTS 3.4.7, and with the current licensing basis.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 216 of 624

Attachment 1, Volume 9, Rev. 0, Page 217 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 223 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.8 BASES, RCS LOOP - MODE 5, LOOPS NOT FILLED

1. In the Bases Background section, the sentence, The number of pumps in operation can vary to suit operational needs, is not adopted. Only one RHR pump is used at a time in MODE 5.

2. The LCO Bases state, An additional RHR loop is required to be OPERABLE to meet single failure considerations. In the Background section of the Bases for this Specification, the need for a second RHR loop is stated as, The other intent of this LCO is to require that a second path be available to provide redundancy for heat removal. This is a more accurate statement of the requirement. The term single failure is typically used to describe an accident analysis assumption and the accident analyses performed for MODE 5 do not assume the single failure of an RHR loop. The LCO Bases have been revised to describe the LCO requirement using the wording from the Bases Background section.

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

4. Changes are made to reflect those changes made to the ISTS.

5. Editorial change for enhanced clarity.

6. Changes have been made to reflect the ISTS.

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. 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.

9. The Bases of ISTS SR 3.4.8.3 state that "Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability." The Note to SR 3.4.8.3 clearly states that the SR is only required to be performed after a required pump is not in operation. Therefore, the SR does not need to be performed for operating pumps, and the statement that there is an alternative method of verification is not necessary. The statement is essentially justifying why the Note to the SR is allowed. As such, a similar statement has been added to the paragraph describing the Note allowance.

10. Grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 223 of 624

Attachment 1, Volume 9, Rev. 0, Page 224 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 224 of 624

Attachment 1, Volume 9, Rev. 0, Page 225 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.8, RCS LOOP - MODE 5, LOOPS NOT FILLED There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 225 of 624

, Volume 9, Rev. 0, Page 226 of 624 ATTACHMENT 9 ITS 3.4.9, PRESSURIZER , Volume 9, Rev. 0, Page 226 of 624

, Volume 9, Rev. 0, Page 227 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 227 of 624

Attachment 1, Volume 9, Rev. 0, Page 228 of 624 ITS 3.4.9 A.1 ITS level A.2 LCO 3.4.9 backup A.3 M.1 ACTION B ACTION C water level not within limit A.4 ACTION A Add proposed Required Actions A.1, A.2, and A.3 M.2 level A.2 SR 3.4.9.1 backup A.3 SR 3.4.9.2 24 L.1 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 228 of 624

Attachment 1, Volume 9, Rev. 0, Page 229 of 624 ITS 3.4.9 A.1 ITS level A.2 LCO 3.4.9 backup A.3 M.1 ACTION B ACTION C water level not within limit A.4 ACTION A Add proposed Required Actions A.1, A.2, and A.3 M.2 level A.2 SR 3.4.9.1 backup A.3 SR 3.4.9.2 24 L.1 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 229 of 624

Attachment 1, Volume 9, Rev. 0, Page 230 of 624 DISCUSSION OF CHANGES ITS 3.4.9, PRESSURIZER 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 LCO 3.4.4 requires the pressurizer water volume to be < 92% of span and CTS 4.4.4.1 requires a verification of the pressurizer water volume. ITS LCO 3.4.9 requires the pressurizer water level to be < 92% and ITS SR 3.4.9.1 requires verification of the pressurizer water level. This changes the CTS by changing "pressurizer water volume" to "pressurizer water level."

The purpose of CTS LCO 3.4.4 and CTS 4.4.4.1 is to ensure the pressurizer water level is at or below the trip setpoint specified in CTS Table 2.2-1. This change is acceptable since the current value corresponds to pressurizer water level. The value of 92% of span corresponds to the Pressurizer Water Level -

High trip setpoint in CTS Table 2.2-1. Since the value corresponds to the actual water level in the pressurizer, the change from "volume" to "level" is appropriate.

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

A.3 CTS LCO 3.4.4 requires two trains of pressurizer heaters with the capacity of each train to be > 150 kW and CTS 4.4.4.2 requires a verification of the pressurizer heaters. ITS LCO 3.4.9 requires two trains of pressurizer backup heaters with the capacity of each train to be greater than or equal to 150 kW and ITS SR 3.4.9.2 requires a verification of the pressurizer backup heaters. This changes the CTS by changing the words "pressurizer heaters" to "pressurizer backup heaters."

The purpose of the subject CTS phrase is to ensure the appropriate heaters are available with the appropriate capacity. This change is acceptable because the CTS 3/4.4.4 Bases state that the requirements for pressurizer heaters applies to the pressurizer backup heaters. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.4.4 Action b applies when the pressurizer is otherwise inoperable (i.e., for reasons other than an inoperable train of pressurizer heaters as described in Action a). ITS 3.4.9 Condition A applies when the pressurizer water level is not within limit. This changes the CTS to specifically state the reason the pressurizer is inoperable.

The purpose of CTS 3.4.4 is to require the pressurizer to be OPERABLE and two conditions of OPERABILITY are supplied. The conditions are pressurizer water level and pressurizer backup heater OPERABILITY. CTS 3.4.4 Action b only applies when water level is not within limit. This is the same condition for which ITS 3.4.9 Condition A applies. This change is acceptable because the condition CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 9, Rev. 0, Page 230 of 624

Attachment 1, Volume 9, Rev. 0, Page 231 of 624 DISCUSSION OF CHANGES ITS 3.4.9, PRESSURIZER under which CTS 3.4.4 Action b applies has not changed. This change is designated as administrative as it results in no technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.4.4 Action a states, in part, to be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the "following" 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Under the same condition, ITS 3.4.9 Required Action C.2 requires the unit to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

This changes the CTS by reducing the time the unit must be in MODE 4 from 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in MODE 3 and the "following" 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to be in MODE 4) to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The purpose of the shutdown actions of CTS 3.4.4 Action a is to place the unit outside of the Applicability of the Specification. ITS 3.4.9 ACTION C continues to accomplish this purpose but the time to be in MODE 4 has decreased from 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in MODE 3 and the "following" 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to be in MODE 4) to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change is acceptable because the time required to be in MODE 4 is consistent with the time allowed in other Specifications. This change is designated as more restrictive because it reduces the amount of time provided to complete a Required Action.

M.2 CTS 3.4.4 Action b requires the unit to be in at least MODE 4 with the reactor trip breakers open within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the pressurizer water level limit is not met.

Under the same condition, ITS 3.4.9 ACTION A also requires the unit to be in MODE 3, to fully insert all rods, and place the Rod Control System in a condition incapable of rod withdrawal within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . In addition, the unit is required to be in MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by replacing the requirement to open the reactor trip breakers within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to requiring the unit to be in MODE 3, to fully insert all rods, and place the Rod Control System in a condition incapable of rod withdrawal within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The purpose of CTS 3.4.4 Action b is to place the unit outside of the Applicability of the Specification. ITS 3.4.9 ACTION A continues to require the unit to be in MODE 4 but adds three additional requirements intended to minimize the core reactivity and any pressure transient which may result from any inadvertent withdrawal of control rods. This change is acceptable because it provides additional assurance that certain events will not occur during the transition out of the MODE of Applicability of the Specification. This change is designated as more restrictive, because additional Required Actions are now required.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 9, Rev. 0, Page 231 of 624

Attachment 1, Volume 9, Rev. 0, Page 232 of 624 DISCUSSION OF CHANGES ITS 3.4.9, PRESSURIZER LESS RESTRICTIVE CHANGES L.1 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.4.4.2 states that the pressurizer heaters shall be demonstrated OPERABLE at least once per 18 months by energizing the required capacity of heaters in each train. ITS SR 3.4.9.2 requires the same test to be performed at a 24 month Frequency. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.4.4.2 is to ensure the pressurizer backup heaters perform as designed. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for the pressurizer backup heater capacity test is acceptable because during the cycle the heaters automatically start when necessary to maintain the appropriate pressurizer pressure and temperature. This operational characteristic will help identify any operational problems during the cycle.

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

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 9, Rev. 0, Page 232 of 624

Attachment 1, Volume 9, Rev. 0, Page 233 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 233 of 624

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Attachment 1, Volume 9, Rev. 0, Page 236 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.9, PRESSURIZER

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

2. The CNP design includes backup and proportional heaters. The backup heaters are required to be OPERABLE in accordance with this Specification. Therefore, "pressurizer heaters" has been changed to "pressurizer backup heaters" and the word "required" has been deleted, as applicable.

3. The bracketed phrase has been deleted. The backup heaters are always powered from an emergency power supply.

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

5. CNP is equipped with two groups (trains) of pressurizer backup heaters that are permanently powered by Class 1E power supplies. Therefore, ITS SR 3.4.9.3, which verifies that pressurizer heaters can be manually swapped from normal power to emergency power, is not applicable to CNP. In addition, the Reviewer's Note has been deleted in ISTS SR 3.4.9.2.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 236 of 624

Attachment 1, Volume 9, Rev. 0, Page 237 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 237 of 624

, Volume 9, Rev. 0, Page 238 of 624 , Volume 9, Rev. 0, Page 238 of 624

, Volume 9, Rev. 0, Page 239 of 624 , Volume 9, Rev. 0, Page 239 of 624

, Volume 9, Rev. 0, Page 240 of 624 , Volume 9, Rev. 0, Page 240 of 624

Attachment 1, Volume 9, Rev. 0, Page 241 of 624 B 3.4.9 1

INSERT 2 provide assurance that the heaters can be energized during a loss of offsite power condition to provide adequate subcooling margin in the RCS to maintain natural circulation conditions in MODE 3. Seven heaters (each rated at 23.08 kW) per train are required to meet the 150 kW capacity requirement.

Insert Page B 3.4.9-2 Attachment 1, Volume 9, Rev. 0, Page 241 of 624

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, Volume 9, Rev. 0, Page 243 of 624 , Volume 9, Rev. 0, Page 243 of 624

, Volume 9, Rev. 0, Page 244 of 624 , Volume 9, Rev. 0, Page 244 of 624

Attachment 1, Volume 9, Rev. 0, Page 245 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.9 BASES, PRESSURIZER

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 Reviewer's Note has been deleted since it is not intended to remain in a plant specific ITS.

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

4. Changes are made to reflect those changes made to the ISTS. The subsequent requirements are renumbered or revised, where applicable, to reflect the changes.

5. Changes have been made to be consistent with the ISTS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 245 of 624

Attachment 1, Volume 9, Rev. 0, Page 246 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 246 of 624

Attachment 1, Volume 9, Rev. 0, Page 247 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.9, PRESSURIZER There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 247 of 624

, Volume 9, Rev. 0, Page 248 of 624 ATTACHMENT 10 ITS 3.4.10, PRESSURIZER SAFETY VALVES , Volume 9, Rev. 0, Page 248 of 624

, Volume 9, Rev. 0, Page 249 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 249 of 624

Attachment 1, Volume 9, Rev. 0, Page 250 of 624 ITS 3.4.10 A.1 ITS M.1 three LCO 3.4.10 L.1 with all RCS cold leg temperatures > 266°F Add proposed L.2 Applicability Note ACTIONS M.1 A and B Add proposed ACTION A L.3 Add proposed ACTION B M.1 SR 3.4.10.1 Add proposed SR 3.4.10.1 A.2 LA.1 SR 3.4.10.1 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 250 of 624

Attachment 1, Volume 9, Rev. 0, Page 251 of 624 ITS 3.4.10 A.1 ITS LCO 3.4.10 Add proposed L.2 Applicability Note ACTION A 24 ACTION B MODE 4 with any RCS cold loop temperature < 266° F L.4 Add proposed Required Action B.1 Add second part of Condition B SR 3.4.10.1 Add proposed SR 3.4.10.1 A.2 LA.1 SR 3.4.10.1 Page 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 251 of 624

Attachment 1, Volume 9, Rev. 0, Page 252 of 624 ITS 3.4.10 A.1 ITS M.1 three LCO 3.4.10 L.1 with all RCS cold leg temperatures > 299°F Add proposed L.2 Applicability Note Add proposed ACTIONS A and B ACTION A M.1 Add proposed L.3 ACTION B M.1 SR 3.4.10.1 Add proposed SR 3.4.10.1 A.2 LA.1 SR 3.4.10.1 Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 252 of 624

Attachment 1, Volume 9, Rev. 0, Page 253 of 624 ITS 3.4.10 A.1 ITS LCO 3.4.10 Add proposed L.2 Applicability Note ACTION A 24 MODE 4 with any RCS cold ACTION B loop temperature < 299°F L.4 Add proposed Required Action B.1 Add second part of Condition B SR 3.4.10.1 Add proposed SR 3.4.10.1 A.2 LA.1 SR 3.4.10.1 Page 4 of 4 Attachment 1, Volume 9, Rev. 0, Page 253 of 624

Attachment 1, Volume 9, Rev. 0, Page 254 of 624 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 4.4.3 states that there are no Surveillance Requirements on the pressurizer safety valves other than those required by Specification 4.0.5. CTS 4.4.2 states that the pressurizer safety valves shall be demonstrated OPERABLE per CTS 4.4.3. Specification 4.0.5 describes the Inservice Test requirements.

CTS LCO 3.4.2 Footnote # and CTS LCO 3.4.3 Footnote # state that the valves shall be reset to the nominal value + 1% when found outside the + 1% band. ITS SR 3.4.10.1 states that it must be verified that each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program and, following testing, lift settings shall be within +/- 1%.

This change is acceptable because the requirements have not changed. Both the CTS and the ITS state that the safety valves must be tested in accordance with the Inservice Testing Program. The ITS requirement that the as-left lift settings must be within +/- 1% is moved from CTS LCO 3.4.3 and 3.4.2. This change is designated as administrative as the technical requirements are not changed.

MORE RESTRICTIVE CHANGES M.1 CTS 3.4.2 requires a minimum of one pressurizer safety valve to be OPERABLE during MODES 4 and 5. Thus, one or two of the three safety valves are allowed to be inoperable indefinitely in MODES 4 and 5. ITS LCO 3.4.10 requires three pressurizer safety valves to be OPERABLE during MODE 4 with all RCS cold leg temperatures > 266°F (Unit 1) and > 299°F (Unit 2). With one of the three pressurizer safety valves inoperable, ITS 3.4.10 ACTION A states that the valve must be restored to OPERABLE status within 15 minutes. If this cannot be met, ITS 3.4.10 ACTION B 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 with any RCS cold leg temperature < 266°F (Unit 1) and < 299°F (Unit 2) in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In addition, ITS 3.4.10 ACTION B requires these same actions to place the unit outside of the Applicability of the Specification when two of the three pressurizer safety valves are inoperable. This changes the CTS by requiring three safety valves to be OPERABLE and by specifying new Required Actions for when one or two of the three valves are inoperable. The change to the Applicability is discussed in DOC L.1. The change to the remainder of the CTS 3.4.2 Actions is discussed in DOC L.3.

The purpose of CTS 3.4.2 is to provide requirements on pressurizer safety valves during shutdown conditions. In the ITS, the requirements for pressurizer safety CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 9, Rev. 0, Page 254 of 624

Attachment 1, Volume 9, Rev. 0, Page 255 of 624 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES valves are included in one Specification (ITS 3.4.10). The new requirement is acceptable since it is more conservative and helps to ensure the combined capacity of the three valves will keep the reactor coolant pressure below 110% of its design value during postulated transients. Along with this change, the ITS 3.4.10 ACTIONS provide a minimal time for restoration when one of the three safety valves is inoperable and provides a shutdown requirement for when this minimal time has expired or when two of the three pressurizer safety valves are inoperable. This change is designated as more restrictive as it increases the required number of pressurizer safety valves from one to three and provides explicit Required Actions for when one or two of the three safety valves are inoperable.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.4.2 and CTS LCO 3.4.3 are modified by a note that states that the pressurizer lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure.

This information is not provided in ITS 3.4.10. This changes the CTS by moving this information to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.4.10 still retains a requirement for the valves to be OPERABLE. Under the definition of OPERABILITY, the safety valves must be capable of lifting at the assumed conditions, which includes the ambient operating conditions of the safety valves themselves. 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 moved from the Technical Specifications to the ITS Bases.

LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.4.2 requires a safety valve to be OPERABLE in MODES 4 and 5. ITS 3.4.10 requires three safety valves to be OPERABLE in MODE 4 with all RCS cold leg temperatures > 266°F (Unit 1) and

> 299°F (Unit 2). This changes the operating conditions in which pressurizer CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 9, Rev. 0, Page 255 of 624

Attachment 1, Volume 9, Rev. 0, Page 256 of 624 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES safety valves are required to be OPERABLE. The change in the number of required safety valves is discussed in DOC M.1.

The purpose of CTS 3.4.2 is to ensure the appropriate number of safety valves are available to mitigate an overpressurization event. This change is acceptable because the requirements continue to ensure that the systems are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. Below the low temperature overpressurization protection (LTOP) arming temperature of 266°F (Unit 1) and 299°F (Unit 2), the LTOP System provides overpressure protection. The LTOP System provides pressure relief at a lower pressure than the pressurizer safety valves and, therefore, the pressurizer safety valves are not needed. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions in the ITS than in the CTS.

L.2 (Category 2 - Relaxation of Applicability) CTS LCO 3.4.2 and CTS LCO 3.4.3 provide requirements for the pressurizer code safety valves. The ITS LCO 3.4.10 Applicability is modified by a Note which allows the lift settings to not be within the LCO limits during MODES 3 and 4 for the purpose of in-situ setting of the pressurizer safety valves under ambient (hot) conditions. The exception is allowed for 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months following entry into MODE 3 provided a preliminary cold setting was made prior to heatup. This changes the CTS by allowing entry into MODES 3 and 4 without verifying that the pressurizer code safety valve lift settings are within the LCO limits.

The purpose of the Applicability Note is to allow entry into MODES 3 and 4 to perform testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. This change is acceptable because the requirements continue to ensure that the components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The cold lift settings give assurance that the valves are OPERABLE near their design condition during the short period of time allowed to verify the settings at the hot condition. While CNP does not set pressurizer safety valves while installed at this time, this Applicability Note provides the flexibility to utilize this method in the future. 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) The CTS 3.4.2 Action states that with no pressurizer safety valve OPERABLE to immediately suspend all operations involving reactivity changes except addition of water from the refueling water storage tank (RWST), provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.8.b.2 (MODE 4) or 3.1.2.7.b.2 (MODE 5), and to place an OPERABLE RHR loop into operation in the shutdown cooling mode, and to immediately render all Safety Injection pumps and all but one charging pump inoperable by removing the applicable motor circuit breakers from the electric power circuit within one hour.

With no pressurizer safety valves OPERABLE (i.e., all three safety valves are inoperable), ITS 3.4.10 ACTION B 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 CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 9, Rev. 0, Page 256 of 624

Attachment 1, Volume 9, Rev. 0, Page 257 of 624 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES and MODE 4 with any RCS cold leg temperature < 266°F (Unit 1) and < 299°F (Unit 2) in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This places the unit outside of the Applicability of the Specification. This changes the CTS by replacing the CTS 3.4.2 Actions with new ACTIONS designed to place the unit outside of the Applicability of the Specification when no pressurizer safety valves are OPERABLE. The change to the Applicability is discussed in DOC L.1. The change to the number of pressurizer safety valves required for OPERABILITY is discussed in DOC M.1.

The purpose of the CTS 3.4.2 Action is to ensure a reactivity excursion does not occur. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

This change replaces the CTS 3.4.2 Actions with new ACTIONS designed to place the unit outside of the Applicability of the Specification when no pressurizer safety valves are OPERABLE. The explicit Actions to immediately suspend all operations involving positive reactivity changes, to place an OPERABLE RHR loop into operation in the shutdown cooling mode, and to immediately render all Safety Injection pumps and all but one charging pump inoperable by removing the applicable motor circuit breakers from the electric power circuit within one hour have been deleted. The explicit action to stop operations involving positive reactivity changes is not needed since the new Required Actions require the unit to proceed to a MODE outside of the Applicability which will require the unit to cool down and to add boron to maintain the required SHUTDOWN MARGIN.

The explicit Action to place an OPERABLE RHR loop into operation in the shutdown cooling mode is not necessary since the requirements for RHR shutdown cooling and the reactor coolant loops are prescribed in ITS LCO 3.4.6, "Reactor Coolant Loops - MODE 4." This Specification requires at least one RHR or RCS loop to be in operation. This will ensure sufficient mixing of the borated water in the reactor coolant. The requirement to immediately render all Safety Injection pumps and all but one charging pump inoperable by removing the applicable motor circuit breakers from the electric power circuit within one hour is not necessary, since ITS LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP) System," prescribes the requirements for low temperature overpressure protection. This Specification continues to limit the number of pumps allowed to be capable of injecting into the RCS during periods when low temperature overpressurization is a concern. 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) The CTS 3.4.3 Action states that with one of the three pressurizer safety valves inoperable either restore the inoperable valve to OPERABLE status within 15 minutes or be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Currently, no Actions are specified when two or three safety valves are inoperable. Thus CTS 3.0.3 must be entered. ITS 3.4.10 ACTION A continues to allow 15 minutes to restore the inoperable pressurizer safety valve to OPERABLE status. ITS 3.4.10 ACTION B requires the unit to be in MODE 3 in CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 9, Rev. 0, Page 257 of 624

Attachment 1, Volume 9, Rev. 0, Page 258 of 624 DISCUSSION OF CHANGES ITS 3.4.10, PRESSURIZER SAFETY VALVES 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 with any RCS cold leg temperature < 266°F (Unit 1) and

< 299°F (Unit 2) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if the valve is not restored within the 15 minutes or if two or more pressurizer safety valves are inoperable. This changes the CTS by extending the time to place the unit outside of the Applicability and allows the unit not to enter LCO 3.0.3 when two or more pressurizer safety valves are found to be inoperable.

The purpose of the CTS 3.4.3 Action is to place the unit in a condition in which the pressurizer safety valves are not needed if one safety valve is inoperable and cannot be restored to OPERABLE status within the specified Completion Time.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. The time to place the unit outside of the Applicability has been extended. In addition, the change allows the unit not to enter LCO 3.0.3 when two or more pressurizer safety valves are found to be inoperable. The time to place the unit outside of the Applicability has been extended (from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 4 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reach MODE 4 with any RCS cold leg temperature < 266°F (Unit 1) and < 299°F (Unit 2)). Because the LTOP entry conditions (266°F (Unit 1) and 299°F (Unit 2))

are below the 350°F entry conditions for entry into MODE 4, additional time is provided beyond the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months given to enter MODE 4 in CTS 3.0.3 and ITS LCO 3.0.3. In addition, this extension in time is acceptable since a new Required Action has been added to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This will require the unit to reduce power in a more controlled manner. The allowance not to enter LCO 3.0.3 when two or more pressurizer safety valves are found to be inoperable is acceptable since overpressure protection may still be maintained by the pressurizer power operated relief valves. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 9, Rev. 0, Page 258 of 624

Attachment 1, Volume 9, Rev. 0, Page 259 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 259 of 624

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Attachment 1, Volume 9, Rev. 0, Page 263 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.10, PRESSURIZER SAFETY VALVES

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

2. The actual temperature has been provided, consistent with the allowance in the Applicability.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 263 of 624

Attachment 1, Volume 9, Rev. 0, Page 264 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 273 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.10 BASES, PRESSURIZER SAFETY VALVES

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

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

4. Changes are made to be consistent with similar phrases in other ISTS Bases.

5. Changes have been made to be consistent with the ISTS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 273 of 624

Attachment 1, Volume 9, Rev. 0, Page 274 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 274 of 624

Attachment 1, Volume 9, Rev. 0, Page 275 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.10, PRESSURIZER SAFETY VALVES There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 275 of 624

Attachment 1, Volume 9, Rev. 0, Page 276 of 624 ATTACHMENT 11 ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES Attachment 1, Volume 9, Rev. 0, Page 276 of 624

, Volume 9, Rev. 0, Page 277 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 277 of 624

Attachment 1, Volume 9, Rev. 0, Page 278 of 624 ITS 3.4.11 A.1 ITS LCO 3.4.11 M.1 Add proposed ACTIONS Note 1 and capable of being manually cycled A.2 ACTION A A.3 ACTION H A.2 and not capable of being manually cycled A.3 ACTION B ACTION H A.2 and not capable of being manually cycled ACTION D A.3 Required Actions B.1 and B.2 M.1 Required Action D.1 ACTION H A.2 and not capable of being manually cycled ACTION H A.3 Required Actions B.1 and B.2 M.1 ACTION H A.3 A.4 Add Required Action C.1 Note ACTION C M.2 ACTION H A.4 Add Required Action E.1 and F.1 Note ACTIONS E and G Required Action C.1 A.3 Required Action C.1 Required Action G.1 Required Action E.1 M.1 ACTION H Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 278 of 624

Attachment 1, Volume 9, Rev. 0, Page 279 of 624 ITS 3.4.11 A.1 ITS and not capable of being manually cycled A.2 ACTIONS F and H Required Actions B.1 and B.2 A.3 Required Action C.1 L.1 ACTIONS F and H ACTIONS Note 2 A.5 L.2 24 L.3 SR 3.4.11.2 24 L.3 SR 3.4.11.3 L.2 SR 3.4.11.1 L.4 Page 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 279 of 624

Attachment 1, Volume 9, Rev. 0, Page 280 of 624 ITS 3.4.11 A.1 ITS LCO 3.4.11 M.1 Add proposed ACTIONS Note 1 A.2 and capable of being manually cycled A.3 ACTION A ACTION H A.2 and not capable of being manually cycled ACTION B A.3 ACTION H and not capable of being manually cycled A.2 ACTION D A.3 Required Actions B.1 and B.2 M.1 Required Action D.1 ACTION H and not capable of being manually cycled A.2 ACTION H A.3 Required Actions B.1 and B.2 M.1 ACTION H Add Required Action C.1 Note A.4 ACTION C A.3 M.2 ACTION H Add Required Action E.1 and F.1 Note A.4 ACTIONS E and G Required Action C.1 A.3 Required Action C.1 Required Action G.1 M.1 Required Action E.1 ACTION H Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 280 of 624

Attachment 1, Volume 9, Rev. 0, Page 281 of 624 ITS 3.4.11 A.1 ITS and not capable of being A.2 manually cycled ACTIONS F and H A.3 Required Actions B.1 and B.2 Required Action C.1 ACTIONS F and H L.1 ACTIONS Note 2 A.5 L.2 24 L.3 SR 3.4.11.2 24 L.3 SR 3.4.11.3 L.2 SR 3.4.11.1 L.4 Page 4 of 4 Attachment 1, Volume 9, Rev. 0, Page 281 of 624

Attachment 1, Volume 9, Rev. 0, Page 282 of 624 DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

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 3.4.11 Action a applies to one or more PORVs inoperable solely due to excessive seat leakage. CTS 3.4.11 Actions b, c, and d apply to one, two, or three PORVs inoperable, respectively, due to causes other than excessive seat leakage. CTS 3.4.11 Action g applies to PORVs and block valves not in the same line inoperable due to causes other than excessive seat leakage.

ITS 3.4.11 ACTIONS divide the conditions of PORV inoperability into those in which the PORV is capable of being manually cycled and those which the PORV is not capable of being manually cycled. ITS 3.4.11 ACTION A applies to one or more PORVs inoperable and capable of being manually cycled. ITS 3.4.11 ACTION B applies to one or more PORVs inoperable and not capable of being manually cycled. ITS 3.4.11 ACTION D applies to two PORVs inoperable and not capable of being manually cycled. ITS ACTION F applies to one PORV inoperable and not capable of being manually cycled and one block valve inoperable in a different line than the inoperable PORV. ITS ACTION H applies to three PORVs inoperable and not capable of being manually cycled. ITS ACTION H also applies to: a) two PORVs inoperable and not capable of being manually cycled and one block valve inoperable in a different line than the inoperable PORVs; or b) one PORV inoperable and not capable of being manually cycled and two block valves inoperable and in different lines than the inoperable PORV. This changes the CTS by dividing the existing conditions into those in which the PORV can, and cannot, be manually cycled.

This change is acceptable because the requirements have not changed. A PORV inoperable due to excessive seat leakage can still be manually cycled.

PORVs inoperable for other reasons cannot be manually cycled. Therefore, the conditions under which the Required Actions are applied have not changed. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 3.4.11 Actions a, b, c, and d provide an option to restore inoperable PORV(s) to OPERABLE status. CTS 3.4.11 Actions e and f provide an option to restore inoperable block valve(s) to OPERABLE status. CTS 3.4.11 Action g provides an option to restore either the inoperable PORV(s) or the inoperable block valve(s) to OPERABLE status. ITS 3.4.11 does not include the explicit option to restore the valves to OPERABLE status. This changes the CTS by eliminating the option to restore the valves to OPERABLE status.

The purpose of the CTS Actions are to provide all of the acceptable options for inoperable PORVs and block valves. This change is acceptable because the requirements have not changed. LCO 3.0.3 states that upon discovery of a CNP Units 1 and 2 Page 1 of 6 Attachment 1, Volume 9, Rev. 0, Page 282 of 624

Attachment 1, Volume 9, Rev. 0, Page 283 of 624 DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) failure to meet an LCO, the Required Actions of the associated Conditions shall be met. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. Therefore, it is not necessary to provide the option to restore the inoperable valves to OPERABLE status. When they are restored, LCO 3.0.2 allows exiting from the Condition. This change is designated as administrative as it is a change required by the ITS usage rules that does not result in a technical change to the CTS.

A.4 CTS 3.4.11 Action e specifies the compensatory actions for one inoperable block valve. CTS 3.4.11 Action f specifies the compensatory actions for two or three inoperable block valves. ITS 3.4.11 ACTION C specifies the Required Actions for one inoperable block valve, ITS 3.4.11 ACTION E specifies the Required Actions for two inoperable block valves, and ITS 3.4.11 ACTION G specifies the Required Actions for three inoperable block valves. The ITS 3.4.11 ACTIONS C, E, and G Required Actions are preceded by a Note that states that the specified Required Action (C.1, E.1, or G.1) does not apply when the block valve is inoperable solely as a result of complying with Required Action B.2. ITS 3.4.11 Required Action B.2 requires the removal of power from the applicable block valve when a PORV is inoperable. This changes the CTS by adding the clarification Note that the Required Action to place the PORV in manual control is not applicable when the block valve is inoperable solely due to complying with the ACTIONS for an inoperable PORV.

The purpose of the CTS 3.4.11 Actions is to ensure the appropriate compensatory measures are taken with inoperable PORVs or inoperable block valves. The Note clarifies that the applicable Required Action is not necessary when entry into the Condition is made as a result of application of the Required Actions for inoperable PORVs that are not capable of being manually cycled.

This clarification is acceptable since these actions (place associated PORV in manual control or restore one block valve to OPERABLE status) are not appropriate for the block valve inoperability. This change is designated as administrative since the change does not result in a technical change to the CTS.

A.5 CTS 4.4.11.1 states that the PORVs must be tested in accordance with Specification 4.0.5, the Inservice Testing Program requirements for ASME Code Class 1, 2, and 3 components. ITS 3.4.11 does not contain this explicit Surveillance Requirement. This changes the CTS by deleting the explicit requirement to perform the inservice testing Surveillance Requirements for ASME Code Class 1, 2, and 3 components.

The purpose of CTS 4.4.11.1 is to ensure the appropriate inservice testing Surveillance Requirements for ASME Code Class 1, 2, and 3 components are performed for the required PORVs. The inservice testing requirements of CTS 4.0.5 are retain in ITS 5.5.6, "Inservice Testing Program." See the Discussion of Changes for ITS 5.5 for any changes to the requirements of CTS 4.0.5. The explicit cross reference is not necessary since when the system is determined to be inoperable when tested in accordance with the Inservice Testing Program, the plant procedures will require the PORVs to be declared inoperable and the appropriate ITS 3.4.11 ACTIONS will be entered when CNP Units 1 and 2 Page 2 of 6 Attachment 1, Volume 9, Rev. 0, Page 283 of 624

Attachment 1, Volume 9, Rev. 0, Page 284 of 624 DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) applicable. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.4.11 describes the Actions to be taken when PORV(s) and/or block valve(s) are inoperable. ITS 3.4.11 also describes Actions to be taken when PORV(s) and/or block valve(s) are inoperable and contains a statement (ITS 3.4.11 ACTION Note 1) that separate condition entry is allowed for each PORV and each block valve. This changes the CTS by adding a Note stating that separate condition entry is allowed for each PORV.

The purpose of the CTS 3.4.11 Actions are to provide the appropriate compensatory actions for inoperable PORV(s) and/or block valves. This proposed change will allow separate condition entry for each PORV and each block valve. CTS 3.4.11 Action a allows separate condition entry for one or more inoperable PORVs because of excessive seat leakage, but for all other inoperabilities a specific condition exists in CTS 3.4.11. That is, an Action exists for one PORV inoperable due to causes other than excessive seat leakage (Action b), two PORVs inoperable due to causes other than excessive seat leakage (Action c), three PORVs inoperable due to causes other than excessive seat leakage (Action d), one block valve inoperable (Action e), two or three block valves inoperable (Action f), and PORVs and block valves not in the same line inoperable due to causes other than excessive seat leakage (Action g). This change will result in more restrictive Completion Times for those Conditions where more than one valve is inoperable. CTS 3.4.11 Action c and Action d require restoration of one valve in the "following" 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for two inoperable valves). The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months time starts after the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time allowed to close block valves and remove power to the block valves, or to restore the PORVs to OPERABLE status. ITS 3.4.11 Required Action D.1 and Required Action E.1 will not allow the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time to follow the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period since separate condition entry is allowed. If three PORVs are found to be inoperable due to causes other than excessive seat leakage, CTS 3.4.11 Action d requires the unit to close block valves and remove power from the block valves within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in HOT STANDBY (MODE 3) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN (MODE 4) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.4.11 ACTION H will require immediate entry into the shutdown actions when three PORVs are inoperable. These changes are acceptable since the proposed Required Actions provide sufficient time to satisfy the Required Actions. Valve inoperabilities are normally found one at a time, not concurrently. Therefore, the action to close a block valve or place a PORV in manual control will apply as each valve is found to be inoperable and not at the same time. This change is designated as more restrictive as it reduces the Completion Times for multiple valve failures.

M.2 CTS 3.4.11 Action e provides an option to place the associated PORV in manual control or to close the block valve and remove power from the block valve when it is found that one block valve is inoperable. ITS 3.4.11 ACTION C specifies to place the PORVs in manual control. This changes the CTS by deleting the option to close the block valve and remove power from the block valve when the block valve is found to be inoperable.

CNP Units 1 and 2 Page 3 of 6 Attachment 1, Volume 9, Rev. 0, Page 284 of 624

Attachment 1, Volume 9, Rev. 0, Page 285 of 624 DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

The purpose of CTS 3.4.11 Action e is to provide the appropriate compensatory actions for when a block valve is inoperable. A block valve is inoperable when it is not open or when it is not capable of isolating the associated PORV from the pressure of the reactor coolant system. In most cases, the option to close the valve will not be available if the valve is inoperable such that it cannot be closed.

Therefore, the action to place the PORV in manual control is acceptable. This precludes its automatic opening for an overpressure event and avoids the potential for a stuck open PORV at a time when its associated block valve is inoperable. This change is designated as more restrictive as it deletes an optional compensatory action.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.4.11 Action g specifies compensatory measures for inoperable PORVs and block valves not in the same line due to causes other than excessive seat leakage. The actions are to restore the valves to OPERABLE status or close and de-energize the associated block valve and place the associated PORV in manual control in each respective line within one hour. In addition, the applicable portions of CTS 3.4.11 Action c or d must be applied, relating to the OPERATIONAL MODE, as appropriate for two or three lines unavailable. ITS 3.4.11 ACTION B covers the condition associated with one or more PORVs inoperable and not capable of being manually cycled.

Required Actions B.1 and B.2 are to close the associated block valve and to remove power from associated block valve. ITS 3.4.11 ACTION C covers the condition associated with one or more inoperable block valves. ITS 3.4.11 Required Action C.1 requires the PORVs to be placed in manual control.

ITS 3.4.11 ACTION F covers the condition associated with one PORV inoperable and not capable of being manually cycled and one block valve inoperable in a different line than the inoperable PORV. ITS 3.4.11 ACTION H covers the conditions associated with: a) two PORVs inoperable and not capable of being manually cycled and one block valve inoperable in a different line than the inoperable PORVs; and b) one PORV inoperable and not capable of being manually cycled and two block valves inoperable in different lines than the inoperable PORV. This changes the CTS by only requiring the block valves to be closed and de-energized when its associated PORV is inoperable and only requires the PORVs to be placed in manual when its associated block valve is inoperable.

The purpose of the CTS 3.4.11 Actions is to provide the appropriate compensatory actions for inoperable PORVs and inoperable block valves. This CNP Units 1 and 2 Page 4 of 6 Attachment 1, Volume 9, Rev. 0, Page 285 of 624

Attachment 1, Volume 9, Rev. 0, Page 286 of 624 DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. When a block valve is inoperable the associated PORV is placed in manual control. The primary purpose of a block valve is to isolate a stuck open PORV. If the PORV is placed in manual control it cannot be opened inadvertently; therefore, the primary purpose of the block valve is being met. The PORV still has the capability to be manually opened. When a PORV is inoperable, isolation is required by closing the block valve and removing power from the associated block valve. This ensures that the inadvertent opening of the PORV will not depressurize the Reactor Coolant System. Therefore, it is not necessary to close and deenergize the block valve in addition to placing the PORV in manual control for each type of inoperability. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 5 - Deletion of Surveillance Requirement) CTS 4.4.11.1.a requires performance of a Channel Functional Test for each PORV, excluding valve operation, every 31 days and CTS 4.4.11.1.d requires performance of a Channel Calibration of the PORV actuation instrumentation every 18 months. ITS 3.4.11 does not require the PORV automatic control system for OPERABILITY. This changes the CTS by eliminating the LCO requirement and SRs for the PORV automatic control system.

The purpose of CTS 3.4.11 is to ensure the PORVs are available to perform their accident mitigation function. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. In the applicable MODES for ITS 3.4.11, the PORVs are only credited for manual operator action in the event of a steam generator tube rupture. The PORV automatic control system is not needed to perform this function and, therefore, is not required for PORV OPERABILITY. This change is designated as less restrictive because less stringent LCO requirements and SRs are being applied in the ITS than were applied in the CTS.

L.3 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.4.11.1.b requires each PORV to be cycled through one complete cycle of full travel every 18 months. CTS 4.4.11.1.c requires each solenoid air control valve and check valve in the PORV control systems to be operated through one complete cycle of full travel every 18 months. ITS SR 3.4.11.2 and SR 3.4.11.3 include these same tests to be performed at a Frequency of 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 5 of 6 Attachment 1, Volume 9, Rev. 0, Page 286 of 624

Attachment 1, Volume 9, Rev. 0, Page 287 of 624 DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

The purpose of CTS 4.4.11.1.b and 4.4.11.1.c is to ensure the PORVs can be opened. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for the full cycle tests of the PORVs and the associated solenoid air control valves and check valves is acceptable because the accident analysis only assumes the manual actuation of one PORV. Additionally, there are no time-based failure mechanisms identified in the PORVs, the solenoid air control valves, or the check valves. Based on the inherent system and component reliability, system redundancy, the quarterly stroke testing and the mid cycle stroke time testing performed under the IST Program, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.4 (Category 7 - Relaxation of Surveillance Frequency, Non-24 Month Type Change) CTS 4.4.11.2 states that each block valve shall be cycled unless the block valve is closed in order to meet the requirements of CTS 3.4.11 Action b, c, or d. CTS 3.4.11 Actions b, c, and d require the block valve to be closed for reasons other than excessive PORV seat leakage. ITS SR 3.4.11.1 states that each block valve shall be cycled, but it is modified by a Note stating that the SR is not required to be performed with the block valve closed in accordance with the Required Actions. This changes the CTS by not requiring a cycle of the block valve when the block valve is also closed due to excessive PORV seat leakage.

The purpose of CTS 4.4.11.2 is to verify the block valve can be cycled, if needed.

This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

With the block valve closed in order to isolate a PORV with excessive seat leakage, opening the block valve increases the risk of an unisolable RCS leak as the PORV is already inoperable. 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 9, Rev. 0, Page 287 of 624

Attachment 1, Volume 9, Rev. 0, Page 288 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 288 of 624

, Volume 9, Rev. 0, Page 289 of 624 , Volume 9, Rev. 0, Page 289 of 624

, Volume 9, Rev. 0, Page 290 of 624 , Volume 9, Rev. 0, Page 290 of 624

, Volume 9, Rev. 0, Page 291 of 624 , Volume 9, Rev. 0, Page 291 of 624

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Attachment 1, Volume 9, Rev. 0, Page 295 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

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

2. ISTS 3.4.11 Condition B includes a bracketed requirement for entry when one [or two] PORV[s] are inoperable and not capable of being manually cycled. ISTS 3.4.11 Required Action B.3 requires restoration of the two PORVs within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The CTS does not require restoration when only one PORV is inoperable. Therefore, the bracketed requirement has been changed to require entry when one or more PORVs are inoperable and the requirement to restore the PORV within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months has been deleted. ITS 3.4.11 ACTION D has been added (consistent with the CTS) and covers the condition associated with two inoperable PORVs that are not capable of being manually cycled. The Required Action is to restore the inoperable PORV to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Completion Time is also consistent with the Completion Time for ISTS 3.4.11 Required Action B.3.

3. The ISTS 3.4.11 ACTIONS Note 1 has been revised to allow separate Condition entry for each block valve. TSTF-247, Rev. 0, approved this change on September 24, 1998, but it was not properly adopted in NUREG-1431, Rev.2.

4. ISTS 3.4.11 Condition C includes a requirement for entry when one block valve is inoperable. ISTS 3.4.11 Required Action C.2 requires restoration of the block valve within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The CTS does not require restoration of one inoperable block valve.

Therefore, ISTS 3.4.11 Required Action C.2 has been deleted and ISTS 3.4.11 Condition C has been changed to "one or more block valves inoperable," since ISTS 3.4.11 Required Action C.1 is appropriate for any number of inoperable block valves.

In addition, the ISTS 3.4.11 Required Action C Note has been modified to reflect the deletion of Required Action C.2. ISTS 3.4.11 Condition F covers the inoperabilities associated with "more than one block valve inoperable." This Condition (ITS 3.4.11 Condition E) has been revised to cover the condition for when two block valves are inoperable. In addition, ISTS 3.4.11 Required Actions F.1 and F.2 have been deleted. ISTS 3.4.11 Required Action F.1 is covered by ISTS 3.4.11 Required Action C.1 and does not have to be repeated in this Condition since, as noted in the ACTIONS Note 1, separate Condition entry is allowed for each block valve and since Condition C has been revised to cover the Condition of "one or more block valves inoperable." ISTS 3.4.11 Required Action F.2 has been deleted since the action (Restore one block valve to OPERABLE status if three block valves are inoperable) is covered by proposed ITS 3.4.11 ACTION G, three block valves inoperable.

Similarly, the ISTS 3.4.11 Required Action F Note (ITS 3.4.11 Required Action E Note) has been modified to reflect the deletion of ISTS 3.4.11 Required Actions F.1 and F.2.

5. ITS ACTION F has been added to cover inoperabilities associated with one PORV inoperable and not capable of being manually cycled and one block valve inoperable in a different line for reasons other than to comply with Required Action B.2. This ACTION is consistent with the CTS Actions. The Required Action is to restore one PORV to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or restore the block valve to OPERABLE status.

6. The default Conditions covered by ISTS 3.4.11 ACTIONS D and G have been deleted since they are adequately covered by ISTS 3.4.11 ACTION E (ITS 3.4.11 ACTION H).

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 295 of 624

Attachment 1, Volume 9, Rev. 0, Page 296 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

7. ISTS 3.4.11 ACTION E (ITS 3.4.11 ACTION H) has been revised to cover any Required Action and associated Completion Time not met, three PORVs inoperable and not capable of being manually cycled, two PORVs inoperable and not capable of being manually cycled and one block valve inoperable in a different line than the inoperable PORVs, and two block valves inoperable and one PORVs inoperable and not capable of being manually cycled in a different line than the inoperable block valve. These Conditions, Required Actions, and Completion Times are consistent with the CTS. In addition, ISTS 3.4.11 Required Actions E.1 and E.2 have been deleted since they are covered by the Required Actions in ITS 3.4.11 ACTION B.

Subsequent Required Actions have been renumbered as applicable.

8. This allowance has not been adopted, consistent with current licensing basis. The remaining Note has been renumbered due to this deletion.

9. The bracketed requirement is deleted because it is not applicable to CNP. The PORVs and block valves are not configured such that they can be powered from a non-safety related power source.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 296 of 624

Attachment 1, Volume 9, Rev. 0, Page 297 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 311 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.11 BASES, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

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 the ISTS.

3. This portion of the LCO Bases description implies that the LCO is satisfied with leaking PORVs and the associated block valve closed. This Condition is reflected in ACTION A therefore the discussion is not appropriate in the LCO description. In addition, the previous sentence in the Bases already states that the block valves are OPERABLE if closed but with power maintained.

4. Editorial change made for clarity.

5. This statement has been deleted since the statement is not valid. The Required Action does not preclude the unit from starting up without performing the maintenance on the valve(s).

6. Changes are made to reflect those changes made to the ISTS. The subsequent requirements are renumbered or revised, where applicable, to reflect the changes.

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

8. This cross reference to another Specification has been deleted. This type of cross reference is not used in the ITS Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 311 of 624

Attachment 1, Volume 9, Rev. 0, Page 312 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 312 of 624

Attachment 1, Volume 9, Rev. 0, Page 313 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 313 of 624

Attachment 1, Volume 9, Rev. 0, Page 314 of 624 ATTACHMENT 12 ITS 3.4.12, LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM Attachment 1, Volume 9, Rev. 0, Page 314 of 624

, Volume 9, Rev. 0, Page 315 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 315 of 624

Attachment 1, Volume 9, Rev. 0, Page 316 of 624 ITS 3.4.12 A.1 ITS LCO 3.4.12.d Add LCO 3.4.12.b accumulator isolation requirements M.1 LCO 3.4.12.d.1 LCO 3.4.12.d.2 M.2 MODE 4 when any RCS cold leg temperature < 266ºF M.3 LCO 3.4.12.d.3 LA.1 M.1 Add proposed LCO Note 2 M.2 Add proposed ACTION E ACTION F ACTION G LA.1 12 L.1 A.2 LA.1 ACTION G L.1 12 A.2 SR 3.4.12.5 L.2 M.4 Add proposed ACTIONS C and D M.1 Page 1 of 14 Attachment 1, Volume 9, Rev. 0, Page 316 of 624

Attachment 1, Volume 9, Rev. 0, Page 317 of 624 ITS 3.4.12 A.1 ITS Add proposed SR 3.4.12.8 Note SR 3.4.12.8 M.4 SR 3.4.12.9 L.3 24 SR 3.4.12.6 A.3 SR 3.4.12.7 LA.2 SR 3.4.12.4 A.3 Add proposed SR 3.4.12.3 M.1 Page 2 of 14 Attachment 1, Volume 9, Rev. 0, Page 317 of 624

Attachment 1, Volume 9, Rev. 0, Page 318 of 624 ITS 3.4.12 A.1 ITS See CTS 3/4.1.2.3 M.6 266 ACTION A, LA.3 ACTION B Applicability immediately M.7 See CTS 3/4.1.2.3 M.6 LCO 3.4.12 Applicability 266 Add proposed LCO 3.4.12 Note 3 M.6 Page 3 of 14 Attachment 1, Volume 9, Rev. 0, Page 318 of 624

Attachment 1, Volume 9, Rev. 0, Page 319 of 624 ITS 3.4.12 A.1 ITS not capable of injection into the RCS LA.3 SR 3.4.12.1, M.6 SR 3.4.12.2 266 Applicability See CTS 3/4.1.2.3 Page 4 of 14 Attachment 1, Volume 9, Rev. 0, Page 319 of 624

Attachment 1, Volume 9, Rev. 0, Page 320 of 624 ITS 3.4.12 A.1 ITS See ITS 3.4.7 LCO 3.4.12.c A.4 See ITS 3.4.7 Add proposed third Condition of Condition G M.5 Page 5 of 14 Attachment 1, Volume 9, Rev. 0, Page 320 of 624

Attachment 1, Volume 9, Rev. 0, Page 321 of 624 ITS 3.4.12 A.1 ITS See ITS 3.5.3 M.6 See ITS 3.5.3 ACTION A, ACTION B M.6 LA.3 266 Applicability immediately M.7 See ITS 3.5.3 LCO 3.4.12.a Applicability 266 M.6 Add proposed LCO 3.4.12 Note 1 L.4 Add proposed LCO 3.4.12 Note 3 M.6 Page 6 of 14 Attachment 1, Volume 9, Rev. 0, Page 321 of 624

Attachment 1, Volume 9, Rev. 0, Page 322 of 624 ITS 3.4.12 A.1 ITS See ITS 3.5.3 not capable of injecting into LA.3 the RCS SR 3.4.12.1, SR 3.4.12.2 Applicability L.5 266 M.6 Page 7 of 14 Attachment 1, Volume 9, Rev. 0, Page 322 of 624

Attachment 1, Volume 9, Rev. 0, Page 323 of 624 ITS 3.4.12 A.1 ITS Add LCO 3.4.12.b accumulator isolation requirements M.1 LCO 3.4.12.d LCO 3.4.12.d.1 LCO 3.4.12.d.2 MODE 4 when any RCS cold M.2 leg temperature < 299ºF M.3 LCO 3.4.12.d.3 Add proposed LCO Note 2 M.1 LA.1 Add proposed ACTION E M.2 ACTION F LA.1 ACTION G 12 L.1 A.2 LA.1 ACTION G L.1 12 A.2 SR 3.4.12.5 L.2 M.4 Add proposed ACTIONS C and D M.1 Page 8 of 14 Attachment 1, Volume 9, Rev. 0, Page 323 of 624

Attachment 1, Volume 9, Rev. 0, Page 324 of 624 ITS 3.4.12 A.1 ITS Add proposed SR 3.4.12.8 Note SR 3.4.12.8 M.4 SR 3.4.12.9 L.3 24 SR 3.4.12.6 SR 3.4.12.7 LA.2 SR 3.4.12.4 A.3 Add proposed SR 3.4.12.3 M.1 Page 9 of 14 Attachment 1, Volume 9, Rev. 0, Page 324 of 624

Attachment 1, Volume 9, Rev. 0, Page 325 of 624 ITS 3.4.12 A.1 ITS See CTS 3/4.1.2.3 M.6 299 ACTION A, LA.3 ACTION B Applicability immediately M.7 See CTS 3/4.1.2.3 M.6 LCO 3.4.12 Applicability 299 Add proposed LCO 3.4.12 Note 3 M.6 Page 10 of 14 Attachment 1, Volume 9, Rev. 0, Page 325 of 624

Attachment 1, Volume 9, Rev. 0, Page 326 of 624 ITS 3.4.12 A.1 ITS not capable of injection into the RCS LA.3 SR 3.4.12.1, M.6 SR 3.4.12.2 299 Applicability See CTS 3/4.1.2.3 Page 11 of 14 Attachment 1, Volume 9, Rev. 0, Page 326 of 624

Attachment 1, Volume 9, Rev. 0, Page 327 of 624 ITS 3.4.12 A.1 ITS See ITS 3.4.7 LCO 3.4.12.c A.4 See ITS 3.4.7 Add proposed third Condition of Condition G M.5 Page 12 of 14 Attachment 1, Volume 9, Rev. 0, Page 327 of 624

Attachment 1, Volume 9, Rev. 0, Page 328 of 624 ITS 3.4.12 A.1 ITS See ITS 3.5.3 M.6 See ITS 3.5.3 M.6 ACTION A, ACTION B 299 LA.3 Applicability immediately M.7 See ITS 3.5.3 LCO 3.4.12.a Applicability M.6 299 Add proposed LCO 3.4.12 Note 1 L.4 Add proposed LCO 3.4.12 Note 3 M.6 Page 13 of 14 Attachment 1, Volume 9, Rev. 0, Page 328 of 624

Attachment 1, Volume 9, Rev. 0, Page 329 of 624 ITS 3.4.12 A.1 ITS See ITS 3.5.3 not capable LA.3 of injecting SR 3.4.12.1, into the RCS SR 3.4.12.2 Applicability L.5 299 A.2 Page 14 of 14 Attachment 1, Volume 9, Rev. 0, Page 329 of 624

Attachment 1, Volume 9, Rev. 0, Page 330 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM 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 3.4.9.3 Action a states that the RCS must be maintained in the vented condition until the inoperable PORV or RHR safety valve has been restored to OPERABLE status. CTS 3.4.9.3 Action b states that the RCS must be maintained in the vented condition until both PORVs or one PORV and the RHR safety valve have been restored to OPERABLE status. ITS 3.4.12 does not include the explicit requirement to maintain the RCS vented until the required valves are restored to OPERABLE status. This changes the CTS by eliminating the requirement to restore the valves to OPERABLE status.

The purpose of the CTS Actions are to provide all of the acceptable options for inoperable PORVs and RHR safety valves. This change is acceptable because the requirements have not changed. ITS LCO 3.0.2 states that upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. Therefore, it is not necessary to provide the requirement to maintain the RCS vented until the required valves are restored to OPERABLE status. When they are restored, LCO 3.0.2 allows exiting from the Condition. This change is designated as administrative as it is a change required by the ITS usage rules that does not result in a technical change to the CTS.

A.3 (Unit 1 only) CTS 4.4.9.3.1.d states that each PORV shall be demonstrated OPERABLE by testing in accordance with the inservice test requirements for ASME Category B valves pursuant to Specification 4.0.5. CTS 4.4.9.3.2.b states that each RHR safety valve shall be demonstrated OPERABLE by testing in accordance with the inservice test requirements for ASME Category C valves pursuant to Specification 4.0.5. ITS 3.4.12 does not contain these requirements.

This change is acceptable because Specification 4.0.5 applies whether or not it is specifically invoked in a particular Specification. A requirement to follow Specification 4.0.5 in CTS 4.4.9.3.1.d and 4.4.9.3.2.b is repetitious and adds no new requirements. Therefore, it is deleted. Changes to Specification 4.0.5 are discussed in the ITS Section 5.5 DOCs. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the the Unit 1 CTS.

A.4 CTS 3.4.1.4 Applicability Footnote *** specifies restrictions for reactor coolant pump startups with one or more of the RCS cold leg temperatures less than or equal to 152ºF. In addition, the footnote states that the OPERABILITY of the reactor coolant loop(s) does not require an OPERABLE Auxiliary Feedwater CNP Units 1 and 2 Page 1 of 11 Attachment 1, Volume 9, Rev. 0, Page 330 of 624

Attachment 1, Volume 9, Rev. 0, Page 331 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM System. ITS LCO 3.4.12.c contains the requirements of this CTS Footnote, however the detail of the OPERABILITY requirements for the reactor coolant loops is not retained. This changes the CTS by deleting the detail of the OPERABILITY requirements for the reactor coolant loops.

The purpose of the detail is to clarify that the Auxiliary Feedwater System is not required to support the reactor coolant loop. The requirements for reactor coolant loops during MODE 5 with the reactor coolant loops filled is retained in ITS 3.4.7. This Specification includes the appropriate OPERABILITY requirements for the reactor coolant loops. Since the Auxiliary Feedwater System is not listed in the Surveillance Requirements for this Specification (LCO 3.4.7) and is not mentioned in the Bases, it is clear that it is not required to support the reactor coolant loops. This change is designated as an administrative change and is acceptable because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 The CTS LTOP Specifications provide no limitations on the accumulators. ITS LCO 3.4.12.b states that the accumulators shall be isolated. The ITS LCO contains a Note (Note 2) that states, "An accumulator may be unisolated when the accumulator is depressurized and vented." ITS 3.4.12 ACTION C states that if an accumulator is not isolated when the accumulator is not depressurized and vented, then the affected accumulator must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If this isolation is not accomplished, ITS 3.4.12 ACTION D states that the RCS cold leg temperature must be increased to > 266°F (Unit 1) and > 299°F (Unit 2) or the affected accumulator must be depressurized and vented within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.4.12.3 requires verification that each accumulator is isolated every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

These changes are acceptable because the LTOP analyses assume that the accumulators are isolated and therefore not capable of initiating a mass addition transient. The Completion Times are reasonable for the ACTIONS to be performed and minimize the time in which the design assumptions for the LTOP System are not being met. The Surveillance Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is the same as the Frequency of ITS SR 3.5.1.1, which verifies that the accumulator isolation valves are open when the accumulators are required to be OPERABLE to perform ECCS functions. This change is designated as more restrictive because it adds additional requirements to the CTS.

M.2 CTS 3.4.9.3 is applicable in MODE 5 when the temperature of any RCS cold leg is < 152ºF, and MODE 6 when the head is on and fastened to the reactor vessel and the RCS is not vented through a 2-square-inch or larger vent, or through any single blocked open PORV. ITS LCO 3.4.12 is applicable in MODE 4 when any RCS cold leg temperature is < 266ºF (Unit 1) and < 299ºF (Unit 2), MODE 5, and MODE 6 when the reactor vessel head is on. This change expands the Applicability to require the low temperature overpressure protection systems to be OPERABLE in MODE 4 when any RCS cold leg temperature is < 266ºF (Unit 1) and < 299ºF (Unit 2), and at all times in MODE 5. Along with this change, proposed ITS 3.4.12 ACTION E has been added to cover the CNP Units 1 and 2 Page 2 of 11 Attachment 1, Volume 9, Rev. 0, Page 331 of 624

Attachment 1, Volume 9, Rev. 0, Page 332 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM inoperabilities associated with one required RCS relief valve in MODE 4.

ITS 3.4.12 Required Action E.1 states to restore required RCS relief valve to OPERABLE status within 7 days.

These changes are acceptable because the LTOP analyses require the LTOP Systems to be OPERABLE during the specified MODE 4 conditions. This change is designated as more restrictive because it adds additional requirements to the CTS.

M.3 CTS 3.4.9.3 Applicability states that the requirement of CTS LCO 3.4.9.3 are applicable when in MODE 6 when the head is on and fastened to the reactor vessel and the RCS is not vented through a 2-square-inch or larger vent. ITS LCO 3.4.12 states that one of the pressure relief capabilities allowed is the RCS depressurized and an RCS vent of > 2.0 square inches. The ITS 3.4.12 Applicability states the LCO is applicable in MODE 6 when the reactor vessel head is on. This changes the CTS by requiring the MODE 6 Applicability to include the situation when all reactor vessel head closure bolts are removed and the head is still on. Other changes to this Applicability statement are discussed in DOC LA.1.

The purpose of CTS 3.4.9.3 is to ensure there is sufficient low temperature overpressurization protection in all conditions. The definition of MODE 5 and MODE 6 included in ITS Table 1.1-1 clearly states that in MODE 5 all reactor vessel head closure bolts are fully tensioned and MODE 6 is when one or more reactor vessel head closure bolts are less that fully tensioned. The ITS 3.4.12 Applicability states that the LCO is applicable in MODE 6 when the reactor vessel head is on. This change therefore will require the MODE 6 Applicability to include the situation when all reactor vessel head closure bolts are removed and the vessel head is still on. This change is necessary since a low temperature overpressurization event may occur in this situation and a vent path is still necessary until the head is physically removed. This change is designated as more restrictive because it adds additional requirements to the CTS.

M.4 CTS 3.4.9.3 Action e states that the provisions of Specification 3.0.4 are not applicable. CTS 4.4.9.3.1.a requires the performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel (excluding valve operation) within 31 days prior to entering a condition in which the PORV is required OPERABLE and at least once per 31 days thereafter when the PORV is required OPERABLE. ITS 3.4.12 does not contain an equivalent Action, but ITS SR 3.4.12.8 states that a CHANNEL OPERATIONAL TEST (COT) must be performed on each required PORV, excluding actuation, every 31 days.

However the SR is modified by a Note that states that the test is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to 266°F (Unit 1) and < 299°F (Unit 2). This changes the CTS by deleting the CTS 3.0.4 exception and provides an explicit Note which allows testing of the PORV instrumentation after entering the MODE of Applicability of the Specification.

The purpose of the CTS 3.0.4 exception is to allow testing of the PORV LTOP actuation circuitry, which cannot be performed until the PORVs can be placed in the LTOP protection MODE. The CTS 3.0.4 exception allows entry into the CNP Units 1 and 2 Page 3 of 11 Attachment 1, Volume 9, Rev. 0, Page 332 of 624

Attachment 1, Volume 9, Rev. 0, Page 333 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM LTOP region prior to performing the test. The ITS uses a specific exception for the test that must be performed in the LTOP region. This change is acceptable because it continues to allow the necessary PORV actuation logic testing to be performed. This change is designated as more restrictive because is replaces a broad CTS 3.0.4 exception that applies to the entire LTOP Specification with a specific exception applied to a single test and it places a limit on the length of time that the exception can be used.

M.5 CTS 3.4.1.4 Applicability Footnote *** specifies restrictions for reactor coolant pump startups with one or more of the RCS cold leg temperatures < 152ºF. The Specification does not provide compensatory actions for when this requirement is not met. ITS LCO 3.4.12.c contains the requirements of this CTS Footnote. In addition, a new ACTION has been added to cover the situation when the requirements are not met. ITS 3.4.12 ACTION G requires a depressurization of the RCS and the establishment of an RCS vent > 2.0 square inches when the LTOP System is inoperable for any reason other than ITS 3.4.12 Condition A, B, C, D, E, or F. This changes the CTS by ensuring the appropriate Condition and Required Actions are taken.

The purpose of CTS 3.4.1.4 Applicability Footnote *** is to ensure the startup of a reactor coolant pump will not cause a low temperature overpressurization transient. A more explicit action has been added consistent with the compensatory action in CTS 3.4.9.3 for all required RCS pressure relief valves inoperable. The proposed action is appropriate if this condition exists. This change is designated as more restrictive since an explicit action is provided.

M.6 CTS LCO 3.5.3 requires one ECCS subsystem to be OPERABLE in MODE 4.

CTS LCO 3.5.3.a requires one centrifugal charging pump to be OPERABLE; however this requirement is modified by Footnote #, which specifies that a maximum of one centrifugal charging pump shall be OPERABLE and both safety injection pumps shall be inoperable whenever the temperature of one or more of the RCS cold legs is < 152ºF. CTS 4.5.3.2 requires all charging pumps and safety injection pumps, except the above required OPERABLE charging pump to be demonstrated inoperable by verifying that the motor circuit breakers have been removed from their electrical power supply circuits whenever the temperature of one or more of the RCS cold legs is < 152ºF. CTS 3.5.3 Action c provides the compensatory actions to be taken when more than one charging pump is OPERABLE or with one or more safety injection pumps OPERABLE when the temperature of any RCS cold leg is < 152ºF. CTS LCO 3.1.2.3.a requires one charging pump in the boron injection flow path required by Specification 3.1.2.1 to be OPERABLE and CTS LCO 3.1.2.3.b requires one charging flow path associated with support of Unit 2 shutdown functions to be available. LCO 3.1.2.3.b is modified by a footnote that states that a maximum of one centrifugal charging pump shall be OPERABLE whenever the temperature of one or more of the RCS cold legs is < 152ºF. LCO 3.1.2.3.a is applicable in MODES 5 and 6, and CTS LCO 3.1.2.3.b is applicable at all times when Unit 2 (Unit 1) and Unit 1 (Unit 2) is in MODES 1, 2, 3, or 4. CTS 4.1.2.3.2 requires all charging pumps and safety injection pumps, except the above required OPERABLE charging pump, to be demonstrated inoperable by verifying that the motor circuit breakers have been removed from their electrical power supply circuits except when the reactor vessel head is removed or the temperature of CNP Units 1 and 2 Page 4 of 11 Attachment 1, Volume 9, Rev. 0, Page 333 of 624

Attachment 1, Volume 9, Rev. 0, Page 334 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM one or more of the RCS cold legs is > 152ºF. CTS 3.1.2.3 Action b provides the compensatory actions to be taken when more than one charging pump is OPERABLE or with one or more safety injection pumps OPERABLE when the temperature of any RCS cold leg is < 152ºF unless the reactor vessel head is removed. ITS LCO 3.4.12.a requires a maximum of one charging pump and no safety injection (SI) pump capable of injecting into the RCS. The LCO is modified by a Note (Note 3) that allows both charging pumps to be capable of injecting into the RCS, provided all RCS cold leg temperatures are > 175°F, pressurizer water level is < 50%, and all three RCS relief valves are OPERABLE.

The Applicability of the Specification has been changed to be consistent with CTS 3.4.9.3 as modified by DOCs M.2, M.3, and L.1. The new Applicability is MODE 4 when any RCS cold leg temperature is < 266ºF (Unit 1) and < 299ºF (Unit 2), MODE 5, and MODE 6 when the reactor vessel head is on. ITS 3.4.12 ACTION A covers the situation when one or more SI pumps capable of injecting into the RCS. ITS 3.4.12 ACTION B covers the situation when two charging pumps are capable of injecting into the RCS and only one charging pump is allowed to be capable of injecting into the RCS. This changes the CTS by aligning the Applicability with the LTOP Specification. The pumps must not be capable of injecting into the RCS over a wider RCS cold leg temperature band.

This change also allows two charging pumps to be capable of injecting into the RCS when all RCS cold leg temperatures are > 175°F and other conditions are met.

The purpose of the CTS 3.5.3 Footnote #, CTS 4.5.3.2, CTS 3.1.2.3 Footnote #,

and CTS 4.1.2.3.2 is to ensure the mass addition capacity assumed in the LTOP analysis is not exceeded. This ensures the low temperature overpressure analysis assumptions will be met. Low temperature overpressurization concerns have been extended to MODE 4 with any RCS cold leg temperature < 266ºF (Unit 1) and < 299ºF (Unit 2). These changes are consistent with the analysis.

Since the limitations on charging and SI pumps in CTS 3.5.3 Footnote #,

CTS 3.5.3 Action c, CTS 3.1.2.3 Footnote #, and CTS 4.1.2.3.2 are to cover the low temperature overpressurization concerns, the extension of this Applicability is considered appropriate and necessary. This change is designated as more restrictive because it will require entry into the ACTIONS whenever any SI pump or an additional charging pump is capable of injection into the RCS in the proposed expanded Applicability. In addition, when all RCS cold leg temperatures are > 175°F and other conditions are met, two charging pumps are allowed to be capable of injecting into the RCS. This is also consistent with the analysis assumptions. Since the CTS Applicability is < 152°F and this new allowance is only applicable when all RCS cold leg temperatures are > 175°F, this change is also more restrictive.

M.7 CTS 3.5.3 Action c and CTS 3.1.2.3 Action b provides the compensatory actions to be taken when more than one charging pump OPERABLE or with a safety injection pump(s) OPERABLE. The requirement is to remove the additional charging pump(s) and the safety injection pump(s) motor circuit breakers from the electrical power circuit with 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.4.12 ACTION A covers the situation when one or more SI pumps are capable of injecting into the RCS.

ITS 3.4.12 Required Action A.1 is to immediately initiate action to verify all SI pumps are not capable of injecting into the RCS. ITS 3.4.12 ACTION B covers the situation when two charging pumps are capable of injecting into the RCS and CNP Units 1 and 2 Page 5 of 11 Attachment 1, Volume 9, Rev. 0, Page 334 of 624

Attachment 1, Volume 9, Rev. 0, Page 335 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM only one charging pump is allowed to be capable of injecting into the RCS.

ITS 3.4.12 Required Action B.1 is to immediately initiate action to verify a maximum of one charging pump is capable of injecting into the RCS. The changes CTS 3.5.3 Action c to require "immediate" response instead of a response "within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ."

The purpose of CTS 3.5.3 Action c and CTS 3.1.2.3 Action b is to minimize the time the unit is operating with more than one charging pump or one or more SI pumps. The proposed Required Action requires action to be taken immediately.

This change reflects the urgency of removing the RCS from this condition. In this condition, the low temperature overpressure protection analysis may not be met.

Therefore, immediate action is necessary. This change is designated as more restrictive because the required response was change from "within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months " to "immediate."

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.4.9.3 Applicability states that the requirements of CTS LCO 3.4.9.3 are applicable when in MODE 6 when the head is on and fastened to the reactor vessel and the RCS is not vented through a 2-square-inch or larger vent or through any blocked open PORV. CTS 3.4.9.3 Actions a and b require a depressurization of the RCS through a 2 square inch vent or through any single blocked open PORV. ITS LCO 3.4.12 states that one of the pressure relief capabilities may be when the RCS is depressurized and an RCS vent of

> 2.0 square inches is available. The ITS 3.4.12 Applicability states the LCO is applicable in MODE 6 when the reactor vessel head is on. ITS 3.4.12 ACTION G requires a depressurization of the RCS and to establish an RCS vent of

> 2.0 square inches. This changes the CTS by relocating the detail that a blocked open PORV is an acceptable vent pathway to the Bases. Other changes to this Applicability statement are 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 that the RCS vent must be > 2.0 square inches. 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.

CNP Units 1 and 2 Page 6 of 11 Attachment 1, Volume 9, Rev. 0, Page 335 of 624

Attachment 1, Volume 9, Rev. 0, Page 336 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM LA.2 (Type 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms) CTS 4.4.9.3.1.e.2 (Unit 1) and 4.4.9.3.1.d.2 (Unit 2) require the performance of a CHANNEL FUNCTIONAL TEST and a CHANNEL CALIBRATION of the PORV emergency air tank pressure instrumentation.

ITS 3.4.12 does not include this requirement. This changes the CTS by relocating these Surveillances 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. This indication and alarm instrumentation is not required to be OPERABLE to support OPERABILITY of the LTOP actuation logic. The ITS continues to verify that the emergency air tank banks pressure is sufficient to operate the required PORVs. Also, this change is acceptable because the removed information will be adequately controlled in 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 the alarm is being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.5.3.a requires one centrifugal charging pump to be OPERABLE. However this requirement is modified by Footnote #,

which specifies that a maximum of one centrifugal charging pump shall be OPERABLE and both safety injection pumps shall be inoperable. CTS 3.5.3 Action c provides the compensatory actions to be taken with more than one charging pump OPERABLE or with safety injection pump(s) OPERABLE. The requirement is to remove the additional charging pump(s) and the safety injection pump(s) motor circuit breakers from the electrical power circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

CTS 4.5.3.2 requires all charging pumps and safety injection pumps, except the above required OPERABLE charging pump, to be demonstrated inoperable by verifying that the motor circuit breakers have been removed from their electrical power supply circuits. CTS LCO 3.1.2.3.a requires one charging pump in the boron injection flow path required by Specification 3.1.2.1 to be OPERABLE and CTS LCO 3.1.2.3.b requires one charging flow path associated with support of Unit 2 (Unit 1) and Unit 1 (Unit 2) shutdown functions to be available.

LCO 3.1.2.3.b is modified by a footnote that states that a maximum of one centrifugal charging pump shall be OPERABLE whenever the temperature of one or more of the RCS cold legs is < 152ºF. CTS 4.1.2.3.2 requires all charging pumps and safety injection pumps, except the above required OPERABLE charging pump, to be demonstrated inoperable by verifying that the motor circuit breakers have been removed from their electrical power supply circuits.

CTS 3.1.2.3 Action b provides the compensatory actions to be taken when more than one charging pump is OPERABLE or with one or more safety injection pumps OPERABLE. The requirement is to remove the additional charging pump(s) and the safety injection pump(s) motor circuit breakers from the electrical power circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS LCO 3.4.12.a requires a maximum of one charging pump capable of injecting into the RCS and both safety injection pumps not capable of injecting into the RCS. ITS 3.4.12 ACTION A covers the situation when one or more SI pumps are capable of injecting into the RCS.

CNP Units 1 and 2 Page 7 of 11 Attachment 1, Volume 9, Rev. 0, Page 336 of 624

Attachment 1, Volume 9, Rev. 0, Page 337 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM ITS 3.4.12 Required Action A.1 is to initiate action to verify all SI pumps are not capable of injecting into the RCS. ITS 3.4.12 ACTION B covers the situation when two charging pumps are capable of injecting into the RCS and only one charging pump is allowed to be capable of injecting into the RCS. ITS 3.4.12 Required Action B.1 is to initiate action to verify a maximum of one charging pump is capable of injecting into the RCS. ITS SR 3.4.12.1 requires the verification that all SI pumps are not capable of injecting into the RCS while SR 3.4.12.2 requires verification that no more than the maximum allowed number of charging pumps are capable of injecting into the RCS. This changes the CTS by relocating the detail on how to remove the safety injection and charging pumps from service (remove motor circuit breakers from the electrical power circuit) to the Bases and replacing them with the words "in a condition not capable of injecting into the RCS."

The removal of these details for performing Actions and Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements in the LCO, Required Actions, and Surveillances that the specified pumps are not capable of injection into the RCS. Also, this change is acceptable because these types of procedural details will be adequately controlled the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) When an inoperable RCS vent path has not been restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , CTS 3.4.9.3 Action a essentially allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (for a total of 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months ) to depressurize the RCS and establish an RCS vent. CTS 3.4.9.3 Action b allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to depressurize the RCS and establish an RCS vent when both PORVs and the RHR safety valve are inoperable. ITS 3.4.12 ACTION G requires the RCS to be depressurized and to establish an RCS vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months under the same conditions. This changes the CTS by allowing 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to depressurize and vent the RCS when one of the PORVs is inoperable or when both the PORVs and the RHR safety valve are inoperable.

The purpose of CTS 3.4.9.3 Actions a and b is to place the unit in a condition in which the PORVs and RHR safety valve are not needed. This change is acceptable because the Completion Time is 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 allowed Completion Time. Twelve hours is a sufficient amount of time to allow to cool and depressurize the RCS (following the unit cooldown rate limits), change MODES, and plan and execute CNP Units 1 and 2 Page 8 of 11 Attachment 1, Volume 9, Rev. 0, Page 337 of 624

Attachment 1, Volume 9, Rev. 0, Page 338 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM the maintenance activity of opening an RCS vent. This change allows the necessary activities to be performed in a controlled manner. This change is designated as less restrictive because additional time is allowed to complete Required Actions than was allowed in the CTS.

L.2 (Category 8 - Deletion of Reporting Requirements) CTS 3.4.9.3 Action d states that in the event either the PORVs, the RHR safety valve, or the RCS vent(s) are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.

The report shall describe the circumstances initiating the transient, the effect of the PORVs or RCS vent(s) on the transient, and any corrective action necessary to prevent recurrence. The ITS does not have a similar requirement. This changes the CTS by eliminating a Special Report.

The purpose of CTS 3.4.9.3 Action d is to inform the NRC of challenges to the RCS pressure relief capabilities. This change is acceptable because the regulations provide adequate reporting requirements, or the reports do not affect continued plant operation. The regulatory reporting requirements in 10 CFR 50 are adequate to inform the NRC of challenges to the PORVs, the RHR safety valve, or RCS vents, when necessary. Neither the safety analysis assumptions or conditions for continued operation are dependent on the NRC review of the provided information. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

L.3 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS 4.4.9.3.1.b requires the performance of a CHANNEL CALIBRATION on the PORV actuation channel at least once per 18 months. ITS SR 3.4.12.9 requires this same test at a 24 month Frequency. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.4.9.3.1.b is to ensure the PORV actuation channel will function correctly when required to mitigate a low temperature overpressurization event. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. This change is acceptable because the PORV actuation and actuation logic, is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one of the channel components. Furthermore, the impacted PORV actuation channel has been evaluated based on make, manufacturer, and model number to determine that the instrumentation's actual drift falls within the design allowance in the associated setpoint calculation.

For CTS 4.4.9.3.1.b, this Function (PORV actuation on RCS Pressure - High) is performed by Foxboro N-E11 Series Pressure Transmitters, Foxboro N-2AI-H2V Input Cards, and Foxboro N-2CCA-DC Control Cards. The signal conditioners and Control Cards are a part of the Foxboro Spec 200 rack. The Control Cards CNP Units 1 and 2 Page 9 of 11 Attachment 1, Volume 9, Rev. 0, Page 338 of 624

Attachment 1, Volume 9, Rev. 0, Page 339 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM are to be functionally checked and setpoint verified by a COT every 31 days in the required MODES, and if necessary, recalibrated. These more frequent testing requirements remain unchanged. Therefore, an increase in the calibration Surveillance interval does not affect the Foxboro rack components with respect to drift. The Foxboro N-E11 Series Transmitters 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 drift value determined has been used in the development of, confirmation of, or revision to the current plant setpoint and the Technical Specification Allowable Value. Based on the design of the instrumentation and the drift evaluation, it is concluded that the impact, if any, from this change on system availability is minimal. A review of the Surveillance test history was performed to validate the above conclusion. This review demonstrates that there are no failures that would invalidate the conclusion that the impact, if any, on system availability from this change is minimal. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.4 (Category 1 - Relaxation of LCO Requirements) CTS LCO 3.5.3 requires one ECCS subsystem to be OPERABLE in MODE 4. CTS LCO 3.5.3.a requires one centrifugal charging pump to be OPERABLE, however this requirement is modified by Footnote #, which specifies that a maximum of one centrifugal charging pump shall be OPERABLE when the temperature of one or more of the RCS cold legs is < 152ºF. ITS LCO 3.4.12.a requires a maximum of one charging pump capable of injecting into the RCS. In addition, ITS 3.4.12 LCO Note 1 allows two charging pumps to be capable of injecting into the RCS for

< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for pump swap operations. This changes the CTS by allowing an additional charging pump to be capable of injecting into the RCS for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during pump swap operations only.

The purpose of CTS 3.5.3.a Footnote # is to ensure that appropriate limitations are placed on Emergency Core Cooling Systems, which helps ensure a low temperature overpressurization event is avoided. This change is acceptable because it is a short time period and the probability of an LTOP event is low.

This changes the CTS by allowing an additional charging pump to be capable of injecting into the RCS. The one hour time period for the pump swap operation provides sufficient time to safely complete the actual transfer and to complete administrative controls and Surveillance Requirements associated with the swap.

The intent is to minimize the actual time that more than one charging pump is physically capable of injection. 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.5.3.2 requires all charging pumps and safety injection pumps, except the required OPERABLE charging pump, to be demonstrated inoperable.

The Surveillance is required to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the temperature of one or more RCS cold legs is < 152°F as determined at least CNP Units 1 and 2 Page 10 of 11 Attachment 1, Volume 9, Rev. 0, Page 339 of 624

Attachment 1, Volume 9, Rev. 0, Page 340 of 624 DISCUSSION OF CHANGES ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM once per hour when any RCS cold leg temperature is between 152°F and 200°F.

ITS SR 3.4.12.1 and SR 3.4.12.2 require the same tests to be performed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by deleting the requirement to evaluate the RCS cold legs temperature at least once per hour when any cold leg temperature is between 152°F and 200°F.

The purpose of CTS 4.5.3.2 is to ensure the pumps are not capable of injection into the RCS when low temperature overpressurization is a concern. This change is acceptable because the proposed Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

This changes the CTS by deleting the requirement to evaluate the RCS cold legs temperature at least once per hour when any cold leg temperature is between 152°F and 200°F. RCS cold leg temperature indication is readily available in the control room and therefore, an explicit frequency for monitoring or determining the Applicability is not necessary. The RCS cold leg temperature of 152°F is consistent with the Applicability in CTS 3/4.4.9.3 (Overpressure Protection Systems). CTS 3/4.4.9.3 contains a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Surveillance requirement (CTS 4.4.9.3.2) that does not include the determination of the Applicability at least once per hour when any cold leg temperature is between 152°F and 200°F.

Since the RCS cold leg temperature is included in the Applicability of ITS 3.4.12, it is considered not necessary to retain this requirement in any 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 11 of 11 Attachment 1, Volume 9, Rev. 0, Page 340 of 624

Attachment 1, Volume 9, Rev. 0, Page 341 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 341 of 624

, Volume 9, Rev. 0, Page 342 of 624 , Volume 9, Rev. 0, Page 342 of 624

Attachment 1, Volume 9, Rev. 0, Page 343 of 624 3.4.12 2

INSERT 1 and no safety injection (SI) pump 3

INSERT 2

c. Reactor coolant pumps shall not be started with one or more RCS cold leg temperatures < 152ºF unless the pressurizer water level is < 62% or the secondary water temperature of each steam generator is < 50ºF above each of the RCS cold leg temperatures; and d.

1 7

INSERT 3 2

into the RCS

-NOTES-

1. [Two charging pumps] may be made capable of injecting for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for pump swap operations.

6 INSERT 3A

3. Two charging pumps may be capable of injecting into the RCS provided: a) all RCS cold leg temperatures are > 175°F; b) pressurizer water level is < 50%; c) two PORVs are OPERABLE with lift settings < 435 psig; and d) the RHR suction relief valve is OPERABLE with a setpoint < 450 psig.

2 INSERT 4 266ºF (Unit 1) and < 299ºF (Unit 2)

Insert Page 3.4.12-1 Attachment 1, Volume 9, Rev. 0, Page 343 of 624

, Volume 9, Rev. 0, Page 344 of 624 , Volume 9, Rev. 0, Page 344 of 624

Attachment 1, Volume 9, Rev. 0, Page 345 of 624 3.4.12 6

INSERT 4A

, when only one is allowed to be capable of injecting into the RCS 2

INSERT 5 266ºF (Unit 1) and > 299ºF (Unit 2)

Insert Page 3.4.12-2 Attachment 1, Volume 9, Rev. 0, Page 345 of 624

, Volume 9, Rev. 0, Page 346 of 624 , Volume 9, Rev. 0, Page 346 of 624

Attachment 1, Volume 9, Rev. 0, Page 347 of 624 3.4.12 9

INSERT 5A

-NOTE-Valve position may be verified by use of administrative means.

Insert Page 3.4.12-3 Attachment 1, Volume 9, Rev. 0, Page 347 of 624

, Volume 9, Rev. 0, Page 348 of 624 , Volume 9, Rev. 0, Page 348 of 624

Attachment 1, Volume 9, Rev. 0, Page 349 of 624 3.4.12 2

INSERT 6 266ºF (Unit 1) and < 299ºF (Unit 2) 8 INSERT 7 SR 3.4.12.7 Verify pressure in each 31 days required emergency air tank bank is > 900 psig.

Insert Page 3.4.12-4 Attachment 1, Volume 9, Rev. 0, Page 349 of 624

Attachment 1, Volume 9, Rev. 0, Page 350 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM

1. Editorial change made for enhanced clarity.

2. The brackets are removed and the proper plant specific information/value is provided. Subsequent SRs have been renumbered as applicable.

3. The limitations on the reactor coolant pump startups have been added to ITS LCO 3.4.12 consistent with the requirements in the CTS. In addition, limitations are currently in ISTS 3.4.6 Note 2 and ISTS 3.4.7 Note 3, but are actually LTOP limitations, not RCS loop limitations; thus they are more appropriate to be in this Specification.

4. CNP does not propose to use a PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) and therefore, will not relocate the power operated relief valve lift settings or the LTOP arming point to the PTLR. The current limits will be retained in the ITS.

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

6. The Residual Heat Removal System only includes one suction relief valve. The Specification has been revised consistent with the current design. The current licensing basis also does not allow any safety injection pumps to be capable of injecting into the RCS. Therefore, the ISTS has been modified accordingly. In addition, current analysis only allows the accumulators to be unisolated when they are depressurized and vented. Furthermore, under certain conditions, the current analysis allows two charging pumps to be capable of injecting into the RCS. Thus, the ISTS has been modified accordingly.

7. TSTF-243 (Rev. 0), TSTF-280 (Rev. 1), and TSTF-285 (Rev. 1) have been approved on September 24, 1998, July 26, 1999, and May 12, 1999, respectively. However, some of the changes have not been properly incorporated into NUREG-1431, Rev. 2. These changes reflect the appropriate changes resulting from these Travelers.

8. SR 3.4.12.7, the PORV emergency air tank bank pressure verification test, has been added consistent with the current licensing basis.

9. ISTS SR 3.4.12.3 requires verification that each accumulator is isolated. The ISTS Bases states that this is accomplished by closing and locking out the accumulator discharge isolation valves. At CNP, locking out the valve is accomplished by racking out the valve motor breaker. The CNP design does not include a method for remotely verifying that the accumulator discharge isolation valve is closed when power is removed from the valve motor. Thus, a containment entry would now be required every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to locally verify the valve is still closed, since this Surveillance Requirement is not in the CTS. In lieu of this requirement, a Note has been added that allows the valve position to be verified by administrative means.

This allowance is similar to those found in other Specifications where valves are required to be deactivated in a closed position (e.g., ISTS 3.6.3 Required Action A.2). Allowing verification by administrative means is considered acceptable, since the valve position is verified prior to deactivating the valve, access to the CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 350 of 624

Attachment 1, Volume 9, Rev. 0, Page 351 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.12, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP) SYSTEM containment is restricted, and valves are only operated under strict procedural control.

10. ISTS SR 3.4.12.5, first Frequency, states that the SR must be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for "unlocked" open vent valve(s). The ISTS Bases states that the term "locked" includes valves that are sealed or secured in the open position. However, in other places in the ISTS, the term "locked" does not include "sealed or otherwise secured in position." The ISTS, in these cases, specifically lists in the appropriate Required Action or Surveillance Requirement all three terms: "locked," "sealed," and "or otherwise secured in position." Therefore, for clarity, consistency, and to ensure the Bases does not change the intent of the Specification, the words ", unsealed, and unsecured" have been added to the Frequency.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 351 of 624

Attachment 1, Volume 9, Rev. 0, Page 352 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 352 of 624

, Volume 9, Rev. 0, Page 353 of 624 , Volume 9, Rev. 0, Page 353 of 624

Attachment 1, Volume 9, Rev. 0, Page 354 of 624 B 3.4.12 1

INSERT 1

, limiting reactor coolant pump (RCP) startup transients, 1

INSERT 2 RCPs shall not be started when RCS cold leg temperature is < 152ºF unless certain requirements are met.

1 INSERT 2A When all RCS cold leg temperatures are > 175°F and pressurizer water level is < 50%,

the coolant input capability is allowed to be increased by allowing both charging pumps to be capable of injecting into the RCS. This is acceptable since requiring three RCS relief valves provides adequate pressure relief capacity under these conditions (two of the three RCS valves are the overpressure protection devices that are available to terminate an increasing pressure event).

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Attachment 1, Volume 9, Rev. 0, Page 356 of 624 B 3.4.12 3

INSERT 3 power operated relief valves 1

INSERT 3A When all RCS cold leg temperatures are > 175°F, pressurizer water level is < 50%, and two charging pumps are capable of injecting into the RCS, the LTOP System for pressure relief includes all three RCS relief valves (two PORVs and the RHR suction relief valve). Three RCS relief valves are required for redundancy, since two RCS relief valves have adequate relieving capability to prevent overpressurization at this coolant input capability.

4 INSERT 4 When the RCS temperature is below the LTOP enable temperature, a safeguards circuit is manually armed which allows the PORVs to open in the event of a low temperature overpressurization transient. RCS pressure is monitored by two wide range pressure instruments with each instrument providing an opening signal to one PORV.

4 INSERT 5 for both PORVs are the same Insert Page B 3.4.12-2 Attachment 1, Volume 9, Rev. 0, Page 356 of 624

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Attachment 1, Volume 9, Rev. 0, Page 366 of 624 B 3.4.12 1 INSERT 14A However, LCO Note 3 allows two charging pumps to be capable of injecting into the RCS under certain conditions.

2 INSERT 15 In addition to the coolant input limit capability, restrictions are placed on RCP startups.

This is necessary to ensure the limiting heat input transient is maintained within the analyses. Therefore, an RCP shall not be started with one or more RCS cold leg temperatures < 152ºF unless the pressurizer water level is < 62% or the secondary water temperature of each steam generator is < 50ºF above each of the RCS cold leg temperatures.

1 INSERT 15A Note 3 allows two charging pumps to be capable of injecting into the RCS, provided all RCS cold leg temperatures are > 175°F, pressurizer water level is < 50%, and all three RCS relief valves are OPERABLE and their setpoints within the specified limits. This allowance is consistent with the analyses assumptions.

2 INSERT 16 Motive power for the PORVs is through the use of air. Normally this air is supplied by the plant control air source. To assure OPERABILITY of the PORVs in the event of a loss of control air, a backup air supply is provided. The backup air supply consists of compressed air bottles (the emergency air tank bank), piping, and valves. The backup air supply contains enough air to support PORV operation for 10 minutes with no operator action upon a loss of control air. Only two of the three PORVs have a backup air supply, therefore they are the only PORVs that can be used to meet the LCO requirements.

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Attachment 1, Volume 9, Rev. 0, Page 376 of 624 B 3.4.12 1

INSERT 22 Verification every 31 days that each required emergency air tank banks pressure is

> 900 psig assures adequate air pressure for reliable PORV operation. With the emergency air supply at > 900 psig, there will be enough air to support PORV operation for 10 minutes with no operator action upon a loss of control air. The 31 day Frequency takes into consideration administrative control over operation of the emergency air tank banks and alarms for low air pressure.

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Attachment 1, Volume 9, Rev. 0, Page 378 of 624 B 3.4.12 1 2 INSERT 23 266ºF (Unit 1) and < 299ºF (Unit 2) 4 INSERT 24 ECP 12-N1-05, Low Temperature Overpressure Protection - LTOP Setpoint Calculation, and ECP 12-N1-24, Low Temperature Overpressure Protection (LTOP)

Administrative Controls.

Insert Page B 3.4.12-13 Attachment 1, Volume 9, Rev. 0, Page 378 of 624

Attachment 1, Volume 9, Rev. 0, Page 379 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.12 BASES, LOW TEMPERATURE OVERPRESURE PROTECTION (LTOP)

SYSTEM

1. Changes are made to reflect those changes made to the ISTS. The following requirements are renumbered or revised, where applicable, to reflect the changes.

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

3. Editorial change made for enhanced clarity or to be consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03.

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

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

6. Changes are made to reflect the ISTS.

7. An additional method to isolate a pump has been provided.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 379 of 624

Attachment 1, Volume 9, Rev. 0, Page 380 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 380 of 624

Attachment 1, Volume 9, Rev. 0, Page 381 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.12, LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 381 of 624

, Volume 9, Rev. 0, Page 382 of 624 ATTACHMENT 13 ITS 3.4.13, RCS OPERATIONAL LEAKAGE , Volume 9, Rev. 0, Page 382 of 624

, Volume 9, Rev. 0, Page 383 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 383 of 624

Attachment 1, Volume 9, Rev. 0, Page 384 of 624 ITS 3.4.13 ITS A.1 LCO 3.4.13 0.8 M.1 See ITS 3.5.5 See ITS 3.4.14 ACTION D Add proposed ACTIONS A and B M.1 ACTION C ACTION D See ITS 3.4.14 See ITS 3.5.5 Page 1 of 10 Attachment 1, Volume 9, Rev. 0, Page 384 of 624

Attachment 1, Volume 9, Rev. 0, Page 385 of 624 ITS 3.4.13 ITS A.1 L.1 See ITS 3.5.5 Add proposed SR 3.4.13.1 Note L.2 SR 3.4.13.1 L.1 See ITS 3.4.14 Page 2 of 10 Attachment 1, Volume 9, Rev. 0, Page 385 of 624

Attachment 1, Volume 9, Rev. 0, Page 386 of 624 ITS 3.4.13 ITS A.1 See ITS 3.4.14 See ITS 3.4.14 Page 3 of 10 Attachment 1, Volume 9, Rev. 0, Page 386 of 624

Attachment 1, Volume 9, Rev. 0, Page 387 of 624 ITS 3.4.13 ITS A.1 Page 4 of 10 Attachment 1, Volume 9, Rev. 0, Page 387 of 624

Attachment 1, Volume 9, Rev. 0, Page 388 of 624 ITS 3.4.13 ITS A.1 A.2 A.3 Add proposed ACTION B (Condition third part)

M.2 SR 3.4.13.2 A.2 See ITS 5.5 A.3 Page 5 of 10 Attachment 1, Volume 9, Rev. 0, Page 388 of 624

Attachment 1, Volume 9, Rev. 0, Page 389 of 624 ITS 3.4.13 ITS A.1 LCO 3.4.13 See ITS 3.5.5 See ITS 3.4.14 ACTION B ACTION A ACTION B See ITS 3.4.14 See ITS 3.5.5 Page 6 of 10 Attachment 1, Volume 9, Rev. 0, Page 389 of 624

Attachment 1, Volume 9, Rev. 0, Page 390 of 624 ITS 3.4.13 ITS A.1 L.1 See ITS 3.5.5 Add proposed SR 3.4.13.1 Note L.2 SR 3.4.13.1 L.1 See ITS 3.4.14 Page 7 of 10 Attachment 1, Volume 9, Rev. 0, Page 390 of 624

Attachment 1, Volume 9, Rev. 0, Page 391 of 624 ITS 3.4.13 ITS A.1 See ITS 3.4.14 See ITS 3.4.14 Page 8 of 10 Attachment 1, Volume 9, Rev. 0, Page 391 of 624

Attachment 1, Volume 9, Rev. 0, Page 392 of 624 ITS 3.4.13 ITS A.1 Page 9 of 10 Attachment 1, Volume 9, Rev. 0, Page 392 of 624

Attachment 1, Volume 9, Rev. 0, Page 393 of 624 ITS 3.4.13 ITS A.1 A.2 A.3 Add proposed ACTION B (Condition third part)

M.2 SR 3.4.13.2 A.2 See ITS 5.5 A.3 Page 10 of 10 Attachment 1, Volume 9, Rev. 0, Page 393 of 624

Attachment 1, Volume 9, Rev. 0, Page 394 of 624 DISCUSSION OF CHANGES ITS 3.4.13, RCS OPERATIONAL LEAKAGE 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 3.4.5 requires each steam generator to be OPERABLE. CTS 4.4.5.0 requires each steam generator to be demonstrated OPERABLE by performance of the augmented inservice inspection program (CTS 4.4.5.1, 4.4.5.2, 4.4.5.3, 4.4.5.4, and 4.4.5.5) and the requirement of Specification 4.0.5. ITS LCO 3.4.13 specifies the RCS operational LEAKAGE limits and SR 3.4.13.2 requires the steam generator tube integrity to be performed in accordance with the Steam Generator Program. The augmented inservice inspection program has been moved to ITS 5.5.7, "Steam Generator (SG) Program," and the inspection requirements of Specification 4.0.5 have been moved outside of the Technical Specifications to the Inservice Inspection Program. This changes the CTS by deleting the explicit LCO to maintain the steam generator OPERABLE, however the testing requirements are still retained in SR 3.4.13.2 and the inservice inspection program.

The purpose of CTS 3.4.5 and 4.4.5 are to ensure the appropriate Steam Generator integrity testing is performed to help ensure the leakage limits are met.

The ITS moves the Steam Generator tube inspection from CTS 3.4.5 to a program in the Administrative Controls section. SR 3.4.13.2 provide a link to the Steam Generator Program. The Inservice Inspection requirements of CTS 4.0.5 are still required by 10 CFR 50.55a and the cross reference is not needed in the Technical Specifications. This change is designated as administrative because it does not result in a technical change to the Specifications.

A.3 The Applicability of CTS 3.4.5 is MODES 1, 2, 3, and 4. CTS 3.4.5 Applicability Footnote

states that the Specification does not apply in MODE 4 while performing crevice flushing as long as the requirements of LCO 3.4.1.3, Reactor Coolant Loops and Coolant Circulation - Hot Shutdown, are maintained.

CTS 3.4.1.3 specifies the requirements for circulation and heat removal capability of the reactor coolant loops during MODE 4 operations. The operational LEAKAGE limits are specified in ITS 3.4.13 and the Surveillance Requirements of CTS 4.4.5 have been included as ITS SR 3.4.13.2 as discussed in DOC A.2.

The Applicability is MODES 1, 2, 3, and 4. There is no allowance for steam generator integrity not to be met in MODE 4. This changes the CTS by deleting the explicit Note concerning crevice flushing.

The purpose of CTS 3/4.4.5 is to ensure the integrity of the steam generators is maintained in MODES 1, 2, 3, and 4. The purpose of CTS 3/4.4.1.3 is to ensure the appropriate systems and components are available to ensure reactor coolant circulation and decay heat removal capability during MODE 4 operations.

ITS 3.4.13 continues to help ensure the integrity of the steam generators and CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 394 of 624

Attachment 1, Volume 9, Rev. 0, Page 395 of 624 DISCUSSION OF CHANGES ITS 3.4.13, RCS OPERATIONAL LEAKAGE ITS 3.4.6 continues to ensure the appropriate systems and components are available to ensure reactor coolant circulation and decay heat removal. The Note is not included since the allowance for steam generator integrity not being met is not used and needed. Steam generator integrity is always necessary during MODES 1, 2, 3, and 4 even during crevice flushing. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 (Unit 1 only) CTS 3.4.6.2.b states that the Reactor Coolant System leakage shall be limited to 1 gpm UNIDENTIFIED LEAKAGE. CTS 3.4.6.2 Action b allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to reduce leakage to within limits with any RCS leakage greater than any one of the limits, excluding pressure boundary leakage. Unit 1 ITS LCO 3.4.13.b states that the RCS unidentified LEAKAGE limit is 0.8 gpm. Unit 1 ITS 3.4.13 ACTION A states that if the unidentified leakage is > 0.8 gpm, to verify the source of unidentified LEAKAGE is not the pressurizer surge line or to reduce unidentified LEAKAGE to within limit in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Unit 1 ITS 3.4.13 ACTION B states that if unidentified LEAKAGE is > 1.0 gpm, to reduce unidentified LEAKAGE to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This changes the Unit 1 CTS by decreasing the unidentified LEAKAGE limit from 1 gpm to 0.8 gpm and provides additional Actions if the unidentified LEAKAGE is not within the new 0.8 gpm limit but < 1.0 gpm.

The purpose of CTS 3.4.6.2.b is to provide requirements for unidentified LEAKAGE. The change is acceptable because it is consistent with the condition for application of leak-before-break methodology to the pressurizer surge line for Unit 1 as documented in a Letter from Indiana Michigan Power Company (M.W. Rencheck) to the NRC dated October 26, 2000 (Letter C1000-20). The change is designated as more restrictive because it reduces the unidentified LEAKAGE limit for Unit 1 and provides additional ACTIONS if the new unidentified LEAKAGE limit is not met for Unit 1.

M.2 CTS 4.4.5.0 requires the demonstration that each steam generator is OPERABLE. CTS 3.4.5 Action requires the restoration of the inoperable steam generator prior to increasing Tavg above 200°F. CTS 3.4.5 Action does not state what action to take if the steam generator testing is not met while in MODE 1, 2, 3, or 4; it only includes a requirement that the testing be performed prior to entering MODE 1, 2, 3, or 4 (i.e., increasing Reactor Coolant System temperature above 200°F). Thus, entry into CTS 3.0.3 is required if CTS 4.4.5.0 is not met while in MODE 1, 2, 3, or 4. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to prepare for shutdown of the unit, and requires the unit to be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . ITS SR 3.4.13.2 requires the demonstration that each steam generator is OPERABLE. ITS 3.4.13 ACTION B requires the unit to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months whenever SR 3.4.13.2 is not met in the applicable MODES. This changes the CTS by stating the ACTIONS rather than deferring to CTS 3.0.3. In addition, it deletes the CTS Actions to restore the limits prior to entering MODE 1, 2, 3, or 4.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 395 of 624

Attachment 1, Volume 9, Rev. 0, Page 396 of 624 DISCUSSION OF CHANGES ITS 3.4.13, RCS OPERATIONAL LEAKAGE The purpose of CTS 3.0.3 is to place the plant in a condition in which the Surveillance Requirement is not required to be met. The change is acceptable because 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to reach MODE 3 and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach MODE 5 are reasonable times to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems. The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months time is consistent with the majority of similar Required Action Completion Times.

The change is designated as more restrictive because it reduces a Required Action time.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 5 - Deletion of Surveillance Requirement) CTS 4.4.6.2.1.a requires monitoring of the containment atmosphere particulate radioactivity monitor at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS 4.4.6.2.1.b requires monitoring the containment sump inventory and discharge at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS 4.4.6.2.1.e requires monitoring the reactor head flange leakoff system at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS does not contain these Surveillance Requirements. This changes the CTS by eliminating these Surveillance Requirements.

This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the LCO is being met. Thus, appropriate Surveillance Requirements continue to be performed in a manner and at a Frequency necessary to give confidence that the LCO is being met. The indications in the deleted Surveillance Requirements are not necessarily indications of failure to meet the LCO on RCS operational leakage. These items do provide useful information and the containment atmosphere particulate monitor and the containment sump monitors are required to be OPERABLE by ITS 3.4.15, "RCS Leakage Detection Instrumentation." However, under ITS SR 3.0.1, failure to meet the Surveillance results in failure to meet the LCO. As these indications do not necessarily indicate a failure to meet the LCO, it is not appropriate to retain these indications in this Specification. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.4.6.2.1.d requires the performance of a Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months during steady state operation.

ITS SR 3.4.13.1 also requires that RCS operational leakage be verified to be within its limits by performance of an RCS water inventory balance every CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 396 of 624

Attachment 1, Volume 9, Rev. 0, Page 397 of 624 DISCUSSION OF CHANGES ITS 3.4.13, RCS OPERATIONAL LEAKAGE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months during steady state operation. In addition, ITS SR 3.4.13.1 contains a Note that states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation. This changes the CTS by providing an exception to the Surveillance Frequency.

The purpose of this change is to allow establishment of steady state conditions before the Surveillance is required. Performance of the water inventory balance requires approximately one hour of steady state operation and it is not desired to stop required testing or escalation to a higher MODE solely for the performance of this test. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Other means of monitoring RCS operational leakage are available prior to establishment of steady state conditions, such as containment sump monitors, containment atmosphere particulate monitor, and visual inspection of the RCS.

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

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 9, Rev. 0, Page 397 of 624

Attachment 1, Volume 9, Rev. 0, Page 398 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 398 of 624

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Attachment 1, Volume 9, Rev. 0, Page 404 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.13, RCS OPERATIONAL LEAKAGE

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

2. The 1 gpm unidentified LEAKAGE limit for Unit 1 only has been reduced to 0.8 gpm.

In addition, two new ACTIONS have been added for Unit 1 only for when the unidentified LEAKAGE is > 0.8 gpm and when it is > 1.0 gpm. This change is consistent with the condition for application of leak-before-break methodology to the pressurizer surge line as documented in a Letter from Indiana Michigan Power Company (M.W. Rencheck) to the NRC dated October 26, 2000 (Letter C1000-20).

Subsequent ACTIONS (Unit 1 only) have been modified and renumbered as applicable.

3. The CNP Unit 1 total primary to secondary LEAKAGE through all steam generators limit (in gallons per day versus gallons per minute) has been included, consistent with the current licensing basis.

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

5. A third Condition has been added (SR 3.4.13.2 not met) to ISTS 3.4.13 Condition B to clarify the appropriate Condition to enter when the requirements of SR 3.4.13.2 are not met. Without this new Condition, entry into LCO 3.0.3 would be required, since the Steam Generator Program is not covered by any of the current ISTS Conditions.

6. The ISTS SR 3.4.13.1 Note reference to "in MODE 3 or 4" has been deleted and the words "after establishment" have been added. TSTF-116, Rev. 2, approved these changes on September 24, 1998, but they were not properly adopted in NUREG-1431, Rev. 2.

7. Changes have been made to reflect changes made to the Program title in ITS 5.5.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 404 of 624

Attachment 1, Volume 9, Rev. 0, Page 405 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 405 of 624

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Attachment 1, Volume 9, Rev. 0, Page 410 of 624 B 3.4.13 2 1 INSERT 5 Unit 1 only For the SLB accident, the amount of primary to secondary LEAKAGE in the three intact SGs is assumed to be 1 gpm minus a faulted SG tube LEAKAGE of 500 gallons per day.

The LCO limit of 600 gallons per day is more conservative than the 1 gpm value assumed in the offsite dose calculations. This limit is imposed to help minimize the potential for excessive leakage or tube burst in the event of a MSLB or LOCA consistent with the LCO limit on primary to secondary LEAKAGE through any one SG. In addition, the conservative limit is appropriate due to the increased steam release as a result of the replacement SGs.

1 INSERT 6 Unit 2 only For the SLB accident, the amount of primary to secondary LEAKAGE in the three intact SGs is assumed to be 1 gpm minus a faulted SG tube LEAKAGE of 500 gallons per day.

Insert Page B 3.4.13-3 Attachment 1, Volume 9, Rev. 0, Page 410 of 624

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Attachment 1, Volume 9, Rev. 0, Page 415 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.13 BASES, RCS OPERATIONAL LEAKAGE

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 made to be consistent with changes made to the ISTS.

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

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

5. The steady state definition used in ISTS SR 3.4.13.1 Bases has been modified to delete the pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows. The pressurizer and makeup tank levels change over the duration of the water inventory measurement. This change is the primary measure of RCS LEAKAGE, therefore, they are not normally stable. Any changes in makeup and letdown flows, as well as RCP seal injection and return flows, are reflected in corresponding changes in pressurizer and makeup tank levels. In addition, a new parenthetical statement, which also describes the term steady state, is being added to ISTS SR 3.4.13.1 Bases. TSTF-116, Rev. 2, approved these changes on September 24, 1998, but they were not properly adopted in NUREG-1431, Rev. 2.

The statement is modified consistent with the changes described above.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 415 of 624

Attachment 1, Volume 9, Rev. 0, Page 416 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 416 of 624

Attachment 1, Volume 9, Rev. 0, Page 417 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.13, RCS OPERATIONAL LEAKAGE There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 417 of 624

Attachment 1, Volume 9, Rev. 0, Page 418 of 624 ATTACHMENT 14 ITS 3.4.14, RCS PRESSURE ISOLATION VALVE LEAKAGE Attachment 1, Volume 9, Rev. 0, Page 418 of 624

, Volume 9, Rev. 0, Page 419 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 419 of 624

Attachment 1, Volume 9, Rev. 0, Page 420 of 624 ITS 3.4.14 ITS A.1 See ITS 3.4.13 See ITS 3.5.5 LCO 3.4.14 LA.1 SR 3.4.14.1 A.2 L.1 See ITS 3.5.5 Add proposed ACTIONS Note 1 A.3 Add proposed ACTIONS Note 2 A.4 See ITS 3.4.13 M.1 Add proposed Required Actions A.1 and A.2 Note ACTION A L.2 ACTION B See ITS 3.5.5 Page 1 of 8 Attachment 1, Volume 9, Rev. 0, Page 420 of 624

Attachment 1, Volume 9, Rev. 0, Page 421 of 624 ITS 3.4.14 ITS A.1 See ITS 3.4.13 See ITS 3.5.5 See ITS 3.4.13 Add proposed SR 3.4.14.1 SR 3.4.14.1 L.3 Note LA.1 Page 2 of 8 Attachment 1, Volume 9, Rev. 0, Page 421 of 624

Attachment 1, Volume 9, Rev. 0, Page 422 of 624 ITS 3.4.14 ITS A.1 LA.2 LA.1 A.5 LA.2 Page 3 of 8 Attachment 1, Volume 9, Rev. 0, Page 422 of 624

Attachment 1, Volume 9, Rev. 0, Page 423 of 624 ITS 3.4.14 ITS A.1 Add proposed LCO 3.4.14 part 2 A.6 24 months L.4 SR 3.4.14.2 See ITS 3.5.2 Add proposed ACTION C L.5 Page 4 of 8 Attachment 1, Volume 9, Rev. 0, Page 423 of 624

Attachment 1, Volume 9, Rev. 0, Page 424 of 624 ITS 3.4.14 ITS A.1 See ITS 3.4.13 See ITS 3.5.5 LCO 3.4.14 LA.1 SR 3.4.14.1 A.2 L.1 See ITS 3.5.5 Add proposed ACTIONS Note 1 A.3 Add proposed ACTIONS Note 2 A.4 See ITS 3.4.13 Add proposed Required M.1 Actions A.1 ACTION A and A.2 Note L.2 ACTION B See ITS 3.5.5 Page 5 of 8 Attachment 1, Volume 9, Rev. 0, Page 424 of 624

Attachment 1, Volume 9, Rev. 0, Page 425 of 624 ITS 3.4.14 ITS A.1 See ITS 3.4.13 See ITS 3.5.5 See ITS 3.4.13 Add proposed SR 3.4.14.1 SR 3.4.14.1 L.3 Note LA.1 Page 6 of 8 Attachment 1, Volume 9, Rev. 0, Page 425 of 624

Attachment 1, Volume 9, Rev. 0, Page 426 of 624 ITS 3.4.14 ITS A.1 LA.2 LA.1 A.5 LA.2 Page 7 of 8 Attachment 1, Volume 9, Rev. 0, Page 426 of 624

Attachment 1, Volume 9, Rev. 0, Page 427 of 624 ITS 3.4.14 ITS A.1 A.6 Add proposed LCO 3.4.14 part 2 24 months L.4 SR 3.4.14.2 See ITS 3.5.2 Add proposed ACTION C L.5 Page 8 of 8 Attachment 1, Volume 9, Rev. 0, Page 427 of 624

Attachment 1, Volume 9, Rev. 0, Page 428 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE 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 3.4.6.2.f specifies the leakage limits for the Reactor Coolant System pressure isolation valves at a Reactor Coolant System average pressure within 20 psi of the nominal full pressure value. ITS SR 3.4.14.1 also specifies the leakage limit, but specifies it for the allowed Reactor Coolant System pressure range > 2065 psig and < 2105 psig (Unit 1) and > 2215 psig and < 2255 psig (Unit 2). This changes the CTS by providing the actual pressure limits.

The purpose of specifying the Reactor Coolant System pressure range is to ensure the PIV leakage tests are performed within 20 psi of the RCS normal operating pressure. The proposed values continue to ensure the test is performed within 20 psi of the RCS normal operating pressure. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.4.6.2 Action c specifies the compensatory actions to take when the leakage by any RCS PIV(s) is greater than the specified limit. ITS ACTIONS A and B also state the appropriate compensatory actions under the same condition, however, ITS 3.4.14 ACTIONS Note 1 has been added. ITS 3.4.14 ACTIONS Note 1 allows separate entry condition for each RCS PIV flow path. This changes the CTS by explicitly stating that the Action is to be taken separately for each inoperable RCS PIV flow path.

The purpose of the Note is to provide explicit instructions for proper application of the ACTION for Technical Specification compliance. In conjunction with proposed Specification 1.3, "Completion Times," this Note provides direction consistent with the intent of the existing Action for inoperable PIVs. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.4.6.2 Action c specifies the compensatory actions to take when the leakage through any RCS PIV(s) is greater than the specified limit. ITS 3.4.14 ACTIONS A and B also state the appropriate compensatory actions under the same condition, however, ITS 3.4.14 ACTIONS Note 2 has been added.

ITS 3.4.14 ACTIONS Note 2 states "Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable RCS PIV." This changes the CTS by explicitly stating that the Conditions and Required Actions for systems made inoperable by an inoperable RCS PIV must be entered.

The purpose of the Note is to provide explicit instructions for proper application of the ACTION for Technical Specification compliance. This Note facilitates the use CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 9, Rev. 0, Page 428 of 624

Attachment 1, Volume 9, Rev. 0, Page 429 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE and understanding of the intent to consider any system affected by inoperable PIVs, which is to have its ACTIONS also apply if it is determined to be inoperable. With the addition of ITS LCO 3.0.6, this intent would not necessarily apply. This clarification is consistent with the intent and interpretation of the existing Technical Specifications, and is therefore considered an administrative presentation preference. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS Table 3.4-0 contains the maximum allowable leakage value for each RCS PIV. ITS SR 3.4.14.1 specifies the limit to be < 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm. This changes the CTS by deleting the explicit value for each valve.

The purpose of CTS Table 3.4-0 is to provide the maximum allowable leakage value for each valve. Since the maximum allowable leakage value for each valve is based on the < 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm this information in the Table is redundant. This change is acceptable since the limits for each valve continue to be controlled by the Technical Specifications (SR 3.4.14.1). This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS 4.5.2.d.1 requires verification, when the Reactor Coolant System pressure is above 600 psig, that the automatic interlock action to prevent opening of the suction of the RHR System from the Reactor Coolant System is OPERABLE. In the ITS, this Surveillance has been included as ITS SR 3.4.14.2. In addition, a new LCO has been added which requires the Residual Heat Removal System interlock to be OPERABLE. This changes the CTS by including the Residual Heat Removal System interlock Surveillance Requirement with the RCS PIV leakage limits and adding a new LCO for the interlock.

The purpose of CTS 4.5.2.d.1 is to ensure the RHR low pressure piping is not overpressurized. This Surveillance is not directly related to the OPERABLITY of the RHR System. The Operability of the RHR System is affected when this valve is open, not when the interlock is inoperable. Therefore, the transfer of this requirement to the RCS PIV Specification is appropriate. A discussion of a change to the Required Actions when the interlock is found to be inoperable is discussed in DOC L.5. This change is acceptable since the RHR interlock is retained in the Technical Specifications. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.4.6.2 Action c specifies the compensatory actions to take when the leakage by any RCS PIV(s) is greater than the specified limit. The compensatory action is to isolate the high pressure portion of the affected system from the low pressure portion by the use of a combination of at least two closed valves, one of which may be the OPERABLE check valve and the other a closed de-energized motor operated valve. The CTS does not include any leakage restrictions concerning the valves that may be used to satisfy the isolation requirement of this action. ITS 3.4.14 ACTION A is consistent with the requirement in CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 9, Rev. 0, Page 429 of 624

Attachment 1, Volume 9, Rev. 0, Page 430 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE CTS 3.4.6.2 Action c, however, a Note has been added to the Required Actions (ITS 3.4.14 Required Actions A.1 and A.2 Note) which specifies that each valve used to satisfy ITS 3.4.14 Required Actions A.1 and A.2 must have been verified to meet SR 3.4.14.1, the RCS PIV leakage limit Surveillance Requirement, and either be in the reactor coolant pressure boundary or the high pressure portion of the system. This changes the CTS by providing a Note which explicitly states that the valves used to satisfy Required Action must satisfy the same requirements of the RCS PIVs.

The purpose of CTS 3.4.6.2 Action c is to isolate the flow path in order to minimize the leakage from the high pressure portion of the RCS to the low pressure piping. The Note requires the valves used to provide isolation between the high pressure and low pressure portions of the affected system to have been verified to meet the PIV leakage limits within the required Surveillance Frequency. The addition of the Note represents an additional restriction on unit operation necessary to help ensure the valves used to isolate the high pressure portion from the low pressure portion of the affected system are capable of preventing the overpressurization of the low pressure portion of the system. This change is designated as more restrictive because it adds a new 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 3.4.6.2.f requires the leakage from each RCS PIV specified in Table 3.4-0 to be limited and CTS 4.4.6.2.2 requires the RCS PIVs in Table 3.4-0 to be periodically tested. CTS Table 3.4-0 contains a list of the RCS PIVs, their associated size, and their associated leakage limits. ITS 3.4.14 does not contain a list of the RCS PIVs or their size, and the leakage limits are located in SR 3.4.14.1. This changes the CTS by relocating the list of PIVs, including their associated size, to the Technical Requirements Manual (TRM).

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still requires the RCS PIVs to be OPERABLE. It is not necessary for the list of RCS PIVs to be in the Technical Specifications in order to ensure that the RCS PIVs are OPERABLE. Other lists of components, such as containment isolation valves and equipment response times, have been relocated from the Technical Specifications to licensee-controlled documents while retaining the requirements on these components in the Technical Specifications. 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 ensure changes are properly evaluated. This CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 9, Rev. 0, Page 430 of 624

Attachment 1, Volume 9, Rev. 0, Page 431 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE 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 3.4-0 specifies the minimum test differential pressure for the RCS PIVs to not be below 150 psid. ITS 3.4.14 does not specify this limit. This changes the CTS by relocating the minimum test differential pressure to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.4.14 still retains the requirement that the RCS PIV leakage must be within limit and provides the appropriate Surveillance that includes the leakage limit. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.4.6.2.f is applicable in MODES 1, 2, 3, and 4. ITS 3.4.14 is applicable in MODES 1, 2, and 3, and in MODE 4, except valves in the residual heat removal (RHR) flow path when in, or during the transition to or from, the RHR mode of operation. This changes CTS by exempting the RHR isolation PIVs from the leakage requirements when in or during the transition to or from the RHR mode of operation.

The purpose of CTS 3.4.6.2.f is to ensure the RCS PIVs are within leakage limits.

This change is acceptable because the LCO requirements continue to ensure that the components are maintained consistent with the safety analyses and licensing basis. It is not necessary for the RHR PIVs to meet the leakage limits when in or during transition to or from the RHR mode of operation. These valves are not opened until RCS pressure is less than the design pressure of the RHR system, so overpressurization of the RHR system is not a concern. In addition, an automatic interlock prevents opening the RHR suction valve when > 600 psig.

This interlock is maintained in the ITS. 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.2 (Category 3 - Relaxation of Completion Time) CTS 3.4.6.2 Action c requires verification that the isolated condition of the closed valves be verified "once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." ITS 3.4.14 Required Actions A.1 and A.2 require the valves to be closed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , respectively. This changes the CTS by CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 9, Rev. 0, Page 431 of 624

Attachment 1, Volume 9, Rev. 0, Page 432 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE eliminating the "once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " verification of closure and extends the requirement to close the second valve from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The purpose of CTS 3.4.6.2 Action c is to allow time to reduce leakage before isolating the pathway. This change is acceptable because the Completion Time is 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 allowed Completion Time. The time to close the first valve remains the same and the time to close the second valve has been changed from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The requirement to verify the closure of the valves every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been deleted. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time to close the first valve provides time to reduce leakage in excess of the allowable limit and to isolate the flow path if leakage cannot be reduced while corrective actions to reseat the leaking PIVs are taken. The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is consistent with the NRC Order dated April 20, 1981. The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allows time for these actions and restricts the time of operation with leaking valves. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time to close the second valve considers the time required to complete the Required Action and the low probability of the first valve failing during this period. Verification every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not necessary because the closed valves are normally tagged in accordance with procedures. Therefore, permission to open or cycle these closed valves will require shift management approval. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L.3 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.4.6.2.2 requires the performance of the RCS PIV leakage test pursuant to Specification 4.0.5. ITS SR 3.4.14.1 requires the same testing, however, a Note has been included that requires the performance of the leakage test only in MODES 1 and 2. This changes the CTS by adding a Note that requires RCS PIV testing only in certain MODES.

The purpose of CTS 4.4.6.2.2 is to perform the RCS PIV leakage test in accordance with the Frequency of the Inservice Test Program (CTS 4.0.5). This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

The SR is modified by a Note that states the leakage Surveillance is only required to be performed in MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in MODES with lower pressures. Entry into MODE 3 and 4 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.4 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.5.2.d.1 requires verification, when the Reactor Coolant System pressure is above 600 psig, that the automatic interlock action to prevent opening of the suction of the RHR System from the Reactor Coolant System is OPERABLE. This test is required to be performed every 18 months. ITS SR 3.4.14.2 requires this test to be performed every 24 months. This changes CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 9, Rev. 0, Page 432 of 624

Attachment 1, Volume 9, Rev. 0, Page 433 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.5.2.d.1 is to test the automatic interlock action to prevent opening of the suction of the RHR System from the RCS when the RCS pressure is above 600 psig. This interlock is provided only for equipment protection to prevent an intersystem LOCA scenario, and credit for the interlock is not assumed in the accident or transient analysis in the UFSAR. 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. The motor operated valves associated with the RHR suction from the RCS, have the circuit breaker for the valve motor racked out during normal operation, and it is not possible to operate the valve without specific controls and direction. The multi-channel design for these protective circuits ensures no single failure or out-of-tolerance condition can prevent the proper operation of the protective function. Extending the Surveillance test interval for the RHR interlock is acceptable because the valve is normally closed, with the breaker for the valve operator racked out, and is only opened when the RHR System is being used to cooldown the unit under direct supervision of the control room. When the unit is being cooled precautions are taken to ensure the RCS pressure is below the interlock setpoint, therefore the interlock is not challenged.

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

L.5 (Category 4 - Relaxation of Required Action) CTS 4.5.2.d.1 requires verification, when the Reactor Coolant System pressure is above 600 psig, that the automatic interlock action to prevent opening of the suction of the RHR System from the Reactor Coolant System is OPERABLE. When the interlock is inoperable, LCO 3.0.3 entry is required since this inoperability affects both RHR trains.

ITS 3.4.14 ACTION C has been added which requires the isolation of the penetration by use of one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This changes the CTS by allowing the penetration to be isolated and to continue operation of the unit for an unlimited amount of time without entry into LCO 3.0.3.

The purpose of ITS 3.4.14 ACTION C is to isolate the penetration to ensure RHR System is not overpressurized by the RCS. This change is acceptable because CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 9, Rev. 0, Page 433 of 624

Attachment 1, Volume 9, Rev. 0, Page 434 of 624 DISCUSSION OF CHANGES ITS 3.4.14, RCS PIV LEAKAGE the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. ITS 3.4.14 ACTION C has been added that requires the isolation of the penetration by use of one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This change allows the unit to continue to operate and avoids an unnecessary entry into LCO 3.0.3.

Deactivating the automatic valve or closing a manual valve will ensure the function of the interlock is met. Therefore, since the penetration is isolated by closing and deactivating an automatic valve or by closing a manual valve, the function of the interlock is satisfied and this change is acceptable. In addition, the added ACTION avoids an unnecessary reduction in unit power to enter MODE 5. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 7 of 7 Attachment 1, Volume 9, Rev. 0, Page 434 of 624

Attachment 1, Volume 9, Rev. 0, Page 435 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 442 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.14, RCS PIV LEAKAGE

1. The second part of the LCO has been added to ensure consistency between the LCO, ACTIONS, and Surveillance Requirements. The ISTS LCO, Actions, and Surveillances do not match up since there is no explicit statement in the LCO requiring the RHR System interlock function to be OPERABLE. LCO 3.0.1 requires LCOs to be met during the MODES or other specified conditions in the Applicability.

LCO 3.0.2 states that upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met. Currently, if the RHR System interlock function is inoperable, the LCO is still met. Thus, ACTION C is not required to be entered since the LCO is still met. Therefore, the inclusion of the second portion of the LCO ensures consistency between the LCO, ACTIONS, and Surveillance Requirements. In addition, due to the addition of the term "RHR" into the LCO statement, the use of the term "residual heat removal (RHR)" in the Applicability has been changed to "RHR."

2. Change made to be consistent with usage of the term in all other places in this Specification.

3. The ISTS 3.4.14 Required Action A.1 Completion Time has been extended from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is consistent with the current licensing basis and with the NRC Order dated April 20, 1981.

4. The requirements of ISTS SR 3.4.14.3 have been deleted consistent with the changes approved in License Amendment 219 (Unit 1) and 203 (Unit 2). In addition, the Note to ISTS SR 3.4.14.2 has been deleted since ISTS SR 3.4.12.7 is not included in the ITS.

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

6. Editorial changes have been made to be consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 4.1.7.g.

7. Note 2 to ISTS SR 3.4.14.1 has been deleted since it is not necessary. The ISTS 3.4.14 Applicability does not require leakage to be met for RHR valves in the flow path when in MODE 4 and when in, or during the transition to or from, the RHR mode of operation.

8. The 18 month Frequency, the third Frequency, the fourth Frequency, and Note 3 to ISTS SR 3.4.14.1 have been deleted since they are not required by the current licensing basis. The Inservice Testing Program Frequency is adequate to ensure the valves are OPERABLE.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 442 of 624

Attachment 1, Volume 9, Rev. 0, Page 443 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 447 of 624 B 3.4.14 1 2 INSERT 2 Two motor operated valves are included in series in the suction piping of the RHR System to isolate the high pressure RCS from the low pressure piping of the RHR System when the RCS pressure is above the design pressure of the RHR System piping and components. Ensuring the RHR interlock that prevents the valves from being opened is OPERABLE ensures that RCS pressure will not pressurize the RHR System beyond its design pressure of 600 psig.

1 INSERT 3 at an RCS pressure > 2065 psig and < 2105 psig (Unit 1) and > 2215 psig and < 2255 psig (Unit 2). This criteria is based on a study by the Idaho National Engineering Laboratory (Ref. 7).

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Attachment 1, Volume 9, Rev. 0, Page 449 of 624 B 3.4.14 1

INSERT 4 However, in all cases, the minimum test differential pressure shall be > 150 psid.

1 INSERT 5 Ensuring the RHR interlock that prevents the valves from being opened is OPERABLE ensures that RCS pressure will not pressurize the RHR System beyond its design pressure of 600 psig.

3 INSERT 6 If leakage from one or more RCS PIVs is not within limit, Insert Page B 3.4.14-3 Attachment 1, Volume 9, Rev. 0, Page 449 of 624

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Attachment 1, Volume 9, Rev. 0, Page 455 of 624 B 3.4.14 1

INSERT 9A that prevents the valves from being opened is 1

INSERT 10

4. Letter from D.G. Eisenhut, NRC, to all LWR licensees, LWR Primary Coolant System Pressure Isolation Valves, February 23, 1980.

5. Letter from S.A. Varga, NRC, to J. Dolan, Order for Modification of Licenses Concerning Primary Coolant System Pressure Isolation Valves, April 20, 1981.

6. Technical Requirements Manual.

7. EGG-NTAP-6175, Inservice Testing of Primary Pressure Isolation Valves, Idaho National Engineering Laboratory, February 1983.

8. NRC Safety Evaluation for License Amendment 188 (Unit 1) and 174 (Unit 2).

1 INSERT 11 Operation and Maintenance Standards and Guides (OM Codes)

Insert Page B 3.4.14-6 Attachment 1, Volume 9, Rev. 0, Page 455 of 624

Attachment 1, Volume 9, Rev. 0, Page 456 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.14 BASES, RCS PIV LEAKAGE

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 Bases are modified to reflect changes made to the ISTS.

3. The Bases are changed to reflect the requirements of the ISTS.

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

5. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 456 of 624

Attachment 1, Volume 9, Rev. 0, Page 457 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 457 of 624

Attachment 1, Volume 9, Rev. 0, Page 458 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.14, RCS PIV LEAKAGE There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 458 of 624

Attachment 1, Volume 9, Rev. 0, Page 459 of 624 ATTACHMENT 15 ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION Attachment 1, Volume 9, Rev. 0, Page 459 of 624

, Volume 9, Rev. 0, Page 460 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 460 of 624

Attachment 1, Volume 9, Rev. 0, Page 461 of 624 ITS 3.4.15 A.1 ITS LCO 3.4.15 LCO 3.4.15.b L.1 LCO 3.4.15.a A.2 LCO 3.4.15.c L.1 L.3 Add proposed ACTIONS Note L.5 M.1 Add proposed Required Action A.1 ACTIONS A, B, Add proposed Required C, and D L.4 Actions B.1.2 and C.2 Required Actions B.1.1 and C.1 L.5 ACTION E Add proposed ACTION F M.2 L.5 COT A.3 SR 3.4.15.1, SR 3.4.15.2, SR 3.4.15.4 A.2 SR 3.4.15.3 24 L.6 SR 3.4.15.5 24 L.6 Page 1 of 10 Attachment 1, Volume 9, Rev. 0, Page 461 of 624

Attachment 1, Volume 9, Rev. 0, Page 462 of 624 ITS 3.4.15 A.1 ITS See ITS 3.3.3 See ITS 3.3.6 and CTS 3/4.3.3.1 See ITS 3.3.6 and CTS 3/4.3.3.1 See ITS 3.3.3 See ITS 3.3.6 B, C, D, E LCO 3.4.15.b L.1 LCO 3.4.15.c B, C, D, E See CTS 3/4.3.3.1 Page 2 of 10 Attachment 1, Volume 9, Rev. 0, Page 462 of 624

Attachment 1, Volume 9, Rev. 0, Page 463 of 624 ITS 3.4.15 A.1 ITS ACTIONS B, C, D, E See CTS 3/4.3.3.1 See ITS 3.3.6 See ITS 3.3.3 See ITS 5.6 See ITS 3.3.3 See CTS 3/4.3.3.1 Page 3 of 10 Attachment 1, Volume 9, Rev. 0, Page 463 of 624

Attachment 1, Volume 9, Rev. 0, Page 464 of 624 ITS 3.4.15 A.1 ITS A.3 COT SR 3.4.15.2 SR 3.4.15.1 SR 3.4.15.4 See CTS 3/4.3.3.1 See ITS 3.3.3 LCO 3.4.15.b 24 months L.6 184 days L.8 L.1 See CTS 3/4.3.3.1 Page 4 of 10 Attachment 1, Volume 9, Rev. 0, Page 464 of 624

Attachment 1, Volume 9, Rev. 0, Page 465 of 624 ITS 3.4.15 A.1 ITS A.3 COT SR 3.4.15.2 SR 3.4.15.1 SR 3.4.15.4 See ITS 3.3.6 L.8 LCO 3.4.15.b 184 days 24 months LCO 3.4.15.c L.6 L.1 See ITS 3.3.6 L.8 LCO 3.4.15.b 184 days 24 months LCO 3.4.15.c L.6 L.1 See CTS 3/4.3.3.1 L.7 See CTS 3/4.3.3.1 Page 5 of 10 Attachment 1, Volume 9, Rev. 0, Page 465 of 624

Attachment 1, Volume 9, Rev. 0, Page 466 of 624 ITS 3.4.15 A.1 ITS L.2 LCO 3.4.15 LCO 3.4.15.b L.1 A.2 LCO 3.4.15.a One L.2 LCO 3.4.15.c LCO 3.4.15.b L.1 Add proposed ACTIONS Note L.3 L.5 Add proposed Required Action A.1 M.1 ACTIONS A, B, C, and D L.5 Required Actions Add proposed L.4 B.1.1 and C.1 Required Actions ACTION E Add proposed ACTION F B.1.2 and C.2 L.5 L.2 SR 3.4.15.1, SR 3.4.15.2, COT A.3 SR 3.4.15.4 A.2 SR 3.4.15.3 L.6 24 L.2 SR 3.4.15.5 L.6 24 4

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Attachment 1, Volume 9, Rev. 0, Page 467 of 624 ITS 3.4.15 A.1 ITS See ITS 3.3.3 See ITS 3.3.6 and CTS 3/4.3.3.1 See ITS 3.3.6 and CTS 3/4.3.3.1 See ITS 3.3.3 See ITS LCO 3.4.15.b 3.3.6 B, D, E LCO 3.4.15.c B, D, E L.1 See CTS 3/4.3.3.1 Page 7 of 10 Attachment 1, Volume 9, Rev. 0, Page 467 of 624

Attachment 1, Volume 9, Rev. 0, Page 468 of 624 ITS 3.4.15 A.1 ITS ACTIONS B, D, E See CTS 3/4.3.3.1 See ITS 3.3.6 See ITS 3.3.3 See ITS 5.6 See ITS 3.3.3 See CTS 3/4.3.3.1 Page 8 of 10 Attachment 1, Volume 9, Rev. 0, Page 468 of 624

Attachment 1, Volume 9, Rev. 0, Page 469 of 624 ITS 3.4.15 A.1 ITS COT A.3 SR 3.4.15.1 SR 3.4.15.4 SR 3.4.15.2 See CTS 3/4.3.3.1 See ITS 3.3.3 24 months LCO 3.4.15.b L.6 184 days L.8 L.1 See CTS 3/4.3.3.1 Page 9 of 10 Attachment 1, Volume 9, Rev. 0, Page 469 of 624

Attachment 1, Volume 9, Rev. 0, Page 470 of 624 ITS 3.4.15 A.1 ITS A.3 COT SR 3.4.15.2 SR 3.4.15.1 SR 3.4.15.4 See ITS 3.3.6 L.8 LCO 3.4.15.b 184 days 24 months L.6 LCO 3.4.15.c L.1 See ITS 3.3.6 L.8 LCO 3.4.15.b 184 days 24 months L.6 LCO 3.4.15.c L.1 See CTS 3/4.3.3.1 L.7 See CTS 3/4.3.3.1 Page 10 of 10 Attachment 1, Volume 9, Rev. 0, Page 470 of 624

Attachment 1, Volume 9, Rev. 0, Page 471 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION 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 LCO 3.4.6.1.b requires the containment sump "level and flow" monitoring "system" to be OPERABLE. CTS 4.4.6.1.b requires the containment sump "level and flow" monitoring "system" to be calibrated. ITS LCO 3.4.15.a requires one containment sump monitor in each sump to be OPERABLE and ITS SR 3.4.15.3 requires the performance of CHANNEL CALIBRATION of the required containment sump monitors. This changes the CTS by explicitly writing the LCO statement and SR to match the CNP design.

The purpose of CTS 3.4.6.1 is to ensure diverse RCS leakage detection system channels are OPERABLE. At CNP, there are actually three distinct containment sumps, each collecting leakage from a different area. The only monitoring instruments that can be used to monitor actual leakage rates are the containment sump pump run times, which provide flow monitoring. The CTS requirements are met by ensuring one of the two flow monitors for each of the three sumps is OPERABLE. Therefore, the ITS has been explicitly written to be consistent with the actual design of CNP. This design and its relationship to CTS 3.4.6.1 was reviewed by the NRC during the closeout of Generic Letter 84-04, as documented in the NRC Safety Evaluation Report for Unit 2 Amendment 76 (Letter from the NRC to (S.A. Varga) to Indiana and Michigan Electric Company (J. Dolan) dated 11/22/85). Therefore, since this change is consistent with the current requirements and is only providing clarification, it is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 4.4.6.1.a and Table 4.3-3 require that the Leakage Detection System particulate and noble gas channels be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST. ITS SR 3.4.15.2 requires the performance of a CHANNEL OPERATIONAL TEST (COT) of the required containment atmosphere radioactivity monitors. This changes the CTS by changing the CHANNEL FUNCTIONAL TEST requirements to a COT.

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 Chapter 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

CNP Units 1 and 2 Page 1 of 9 Attachment 1, Volume 9, Rev. 0, Page 471 of 624

Attachment 1, Volume 9, Rev. 0, Page 472 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION MORE RESTRICTIVE CHANGES M.1 CTS 3.4.6.1 does not contain an explicit requirement to perform a Reactor Coolant System (RCS) water inventory balance (CTS 3.3.3.3, ITS SR 3.4.13.1) when the required RCS containment sump monitoring system is found to be inoperable. ITS 3.4.15 Required Action A.1 requires the performance of ITS SR 3.4.13.1, the RCS water inventory balance Surveillance, once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when it is discovered that the required containment sump monitor is inoperable.

This changes the CTS by adding the requirement to perform ITS SR 3.4.13.1 when the specified RCS leakage detection instrumentation is found to be inoperable.

The purpose of performing ITS SR 3.4.13.1 is to provide additional assurance that the existing RCS LEAKAGE is within the prescribed limits of ITS LCO 3.4.13.

This change is acceptable because the added Required Actions provides additional assurance that the RCS LEAKAGE is within the prescribed limits of ITS LCO 3.4.13 prior to the performance of the normally scheduled Surveillance (once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ). This change is designated as more restrictive, because it adds Required Actions to the CTS.

M.2 (Unit 1 only) CTS 3.4.6.1 Action requires a grab sample of the containment atmosphere to be obtained and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the required gaseous and/or particulate radioactivity monitoring channels are inoperable. Unit 1 ITS 3.4.15 Required Action B.1.1 requires the same requirement at a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency when no containment atmosphere particulate radioactivity monitoring channels are OPERABLE. This changes the Unit 1 CTS by adding the requirement to analyze grab samples of the containment atmosphere every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The purpose of analyzing the grab samples of the containment atmosphere is to help ensure the RCS leakage has not increased since the last performance of the Surveillance. This change is consistent with a condition of approval for application of leak-before-beak methodology to the pressurizer surge line for Unit 1 when no containment atmosphere particulate radioactivity monitoring channels are OPERABLE (Letter from Indiana Michigan Power Company (M.W.

Rencheck) to the NRC dated October 26, 2000). This change is acceptable because the increased Frequency of the Required Action provides additional assurance that the RCS leakage has not increased significantly since the previous performance of the Surveillance. This change is designated as more restrictive, because it adds Required Actions to the Unit 1 CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None CNP Units 1 and 2 Page 2 of 9 Attachment 1, Volume 9, Rev. 0, Page 472 of 624

Attachment 1, Volume 9, Rev. 0, Page 473 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS LCO 3.4.6.1.a, CTS Table 3.3-6 Instrument 1.B.i, and Table 4.3-3 Instruments 1.B.i, 2.A.ii, and 2.B.ii specify the containment atmosphere particulate radioactivity monitoring channel instrument numbers to be ERS-1301 and ERS-1401 (Unit 1) and ERS-2301 and ERS-2401 (Unit 2). CTS LCO 3.4.6.1.c, CTS Table 3.3-6 Instrument 1.B.ii, and CTS Table 4.3-3 Instruments 2.A.iii and 2.B.iii specify the containment atmosphere gaseous (noble gas) radioactivity monitoring channel instrument numbers to be ERS-1305 and ERS-1405 (Unit 1) and ERS-2305 and ERS-2405 (Unit 2). ITS LCO 3.4.15 and the associated Surveillances do not specify the instrument numbers. This changes the CTS by deleting the containment atmosphere particulate and gaseous radioactivity monitoring channels instrument numbers from the Technical Specifications.

The purpose of CTS 3.4.6.1, CTS Table 3.3-6, and CTS Table 4.3-3 are to ensure the appropriate RCS leakage detection system 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 atmosphere particulate and gaseous radioactivity monitoring channel instrument 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 atmosphere radioactivity monitor) 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.2 (Category 1 - Relaxation of LCO Requirements) (Unit 2 only) CTS LCO 3.4.6.1.a requires one of the containment atmosphere particulate radioactivity channels to be OPERABLE while CTS LCO 3.4.6.1.c requires either the containment humidity monitor or one of the containment atmosphere gaseous radioactivity monitoring channels to be OPERABLE. CTS 4.4.6.1.a requires the containment atmosphere particulate and gaseous (if being used) monitoring system to be tested (CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST) at the Frequencies specified in Table 4.3-3.

CTS 4.4.6.1.c requires a CHANNEL CALIBRATION of the containment humidity monitor (if being used). Unit 2 ITS LCO 3.4.15.b requires one containment atmosphere radioactivity monitor (gaseous or particulate) and Unit 2 ITS LCO 3.4.15.c requires one containment humidity monitor to be OPERABLE.

Unit 2 ITS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. Unit 2 ITS SR 3.4.15.2 requires the performance of a COT of the required containment atmosphere radioactivity monitor. Unit 2 ITS SR 3.4.15.4 requires the performance of a CHANNEL CALIBRATION of the required containment atmosphere radioactivity monitor. Unit 2 ITS SR 3.4.15.5 requires the performance of a CHANNEL CALIBRATION of the required containment humidity monitor. This changes the CTS by allowing all of the containment atmosphere particulate radioactivity channels to be inoperable without requiring any compensatory actions to be CNP Units 1 and 2 Page 3 of 9 Attachment 1, Volume 9, Rev. 0, Page 473 of 624

Attachment 1, Volume 9, Rev. 0, Page 474 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION taken. That is, the containment atmosphere gaseous radioactivity monitoring channel can replace a particulate channel. It also revises the Surveillances as necessary to clarify that only the required channels must be tested.

The purpose of CTS 3.4.6.1 is to ensure diverse RCS leakage detection system channels are OPERABLE. This change is acceptable because the LCO requirements continue to ensure that the instrumentation is maintained consistent with the safety analyses and licensing basis. The CTS LCO 3.4.6.1 has been changed by allowing all of the containment atmosphere particulate radioactivity channels to be inoperable without any requiring any compensatory actions to be taken. However, at the same time the containment humidity monitor is required to be OPERABLE without any alternate channel. This change is acceptable because ITS LCO 3.4.15 continues to require diverse methods to monitor RCS LEAKAGE. ITS LCO 3.4.15 requires one containment atmosphere radioactivity monitor, a containment sump monitoring method, and a containment humidity channel to be OPERABLE. The changes to the Surveillances are made to align the proposed LCO with the Surveillances. This change is designated as less restrictive because less stringent LCO requirements are being applied in the Unit 2 ITS than were applied in the Unit 2 CTS.

L.3 (Category 13 - Addition of LCO 3.0.4 Exception) CTS 3.4.6.1 Action states, in part, that with one RCS leakage detection system inoperable, the inoperable system must be restored to OPERABLE status within 30 days or a shutdown is required. Thus, CTS 3.0.4 would preclude changing MODES with an RCS leakage detection system inoperable. The ITS 3.4.15 ACTIONS includes a Note that LCO 3.0.4 is not applicable. This changes the CTS by allowing entry into the MODE of Applicability with one or two RCS leakage detection systems inoperable.

The purpose of CTS 3.4.6.1 is to provide the capability for detecting RCS LEAKAGE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

The change allows entry into the MODE of Applicability with one or two required leakage detection systems inoperable. If the required leakage detection systems are not restored to OPERABLE status within 30 days, the unit must be shutdown.

During this time period one other RCS leakage detection system must be OPERABLE. In addition, other Required Actions are included, such as performance of an RCS inventory balance or analysis of containment atmosphere grab samples, at an established Frequency (once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months depending on the inoperable equipment and unit) to help ensure the RCS LEAKAGE is within limit during the 30 day time period. Therefore, the capability for monitoring RCS LEAKAGE is retained to some extent by requiring at least one monitor to be OPERABLE and by performing other Required Actions to monitor RCS LEAKAGE. This change is designated as less restrictive CNP Units 1 and 2 Page 4 of 9 Attachment 1, Volume 9, Rev. 0, Page 474 of 624

Attachment 1, Volume 9, Rev. 0, Page 475 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION because the Required Action Note allows entry into the MODE of Applicability with one or two RCS leakage detection systems monitors inoperable.

L.4 (Category 4 - Relaxation of Required Action) CTS 3.4.6.1 Action requires a grab sample of the containment atmosphere to be obtained and analyzed at a specified frequency when the required gaseous and/or particulate radioactivity monitoring channels are inoperable. ITS 3.4.15 Required Actions B.1.1 and C.1 also include this requirement, however ITS 3.4.15 Required Actions B.1.2 and C.2 provide an option to perform an RCS water inventory balance under the same conditions. This changes the CTS by providing an option to perform an RCS water inventory balance instead of analyzing a grab sample of the containment atmosphere under the same conditions.

The purpose of the CTS 3.4.6.1 Action is to provide periodic information that is adequate to detect RCS LEAKAGE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. Performing an RCS water inventory balance quantifies the actual RCS LEAKAGE therefore the method provides adequate periodic information on the RCS integrity. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.5 (Category 4 - Relaxation of Required Action) CTS 3.4.6.1 Action states the actions to take when only two of the above required Reactor Coolant System (RCS) leakage detection systems are OPERABLE (one required leakage detection system inoperable). With more than one required RCS leakage detection system inoperable entry into CTS LCO 3.0.3 would be required.

ITS 3.4.15 ACTION C covers the situation when a) Unit 1 only - the required containment humidity or containment atmosphere gaseous radioactivity monitor is inoperable; and b) Unit 2 only - the required containment humidity monitor is inoperable. The ITS 3.4.15 Required Actions are to analyze grab samples of the containment atmosphere every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or to perform SR 3.4.13.1 once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.4.15 ACTION D covers the situation when the required containment atmosphere (particulate - Unit 1 only) radioactivity monitor is inoperable and when a) Unit 1 only - the required containment humidity or containment atmosphere gaseous radioactivity monitor is inoperable; and b)

Unit 2 only - the required containment humidity monitor is inoperable. The ITS 3.4.15 Required Actions are to restore of least one of the associated required monitors to OPERABLE status within 30 days. ITS 3.4.15 ACTION F requires the immediate entry into ITS LCO 3.0.3 when all three types of required leakage detection instrumentation are found to be inoperable (i.e., LCO 3.4.15.a, b, and c are not met). This changes the CTS 3.4.6.1 Actions by allowing more than one leakage detection system channel to be inoperable at the same time without requiring entry into LCO 3.0.3.

CNP Units 1 and 2 Page 5 of 9 Attachment 1, Volume 9, Rev. 0, Page 475 of 624

Attachment 1, Volume 9, Rev. 0, Page 476 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION The purpose of the CTS 3.4.6.1 Action is to provide appropriate compensatory measures when Reactor Coolant System leakage detection instrumentation is found to be inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows more than one required RCS leakage detection system channel to be inoperable at the same time without requiring entry into LCO 3.0.3. This change is acceptable because if a required RCS leakage detection instrumentation monitor is inoperable, then entry into the appropriate Conditions is necessary. If more than one RCS leakage detection instrumentation monitor is inoperable, then entry into at least two Conditions will be required. The proposed compensatory actions either require the determination of RCS leakage by requiring the performance of SR 3.4.13.1 (RCS water inventory balance), or in some cases an option is to analyze grab samples of the containment atmosphere once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . These Required Actions ensure with sufficient Frequency that RCS LEAKAGE is within limit thus performing the function of the instrumentation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.6 (Category 11 - 18 to 24 Month Surveillance Frequency Change, Channel Calibration Type) CTS 4.4.6.1.b requires the performance of a CHANNEL CALIBRATION of the containment sump level and flow monitoring system at least once per 18 months. CTS 4.4.6.1.c requires the performance of a CHANNEL CALIBRATION of the containment humidity monitor at least once per 18 months. CTS 4.4.6.1.a and Table 4.3-3 for the Process Monitors requires the CHANNEL CALIBRATION of the particulate and gaseous channels to be performed every 18 months. ITS SR 3.4.15.3 requires a CHANNEL CALIBRATION of the required containment sump monitors every 24 months.

ITS SR 3.4.15.4 requires a CHANNEL CALIBRATION of the required containment atmospheric radioactivity monitors and ITS SR 3.4.15.5 requires a CHANNEL CALIBRATION of the required containment humidity monitor every 24 months. This changes the CTS by extending the Frequency of the Surveillances from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.4.6.1 is to ensure the RCS leakage detection system instrumentation is OPERABLE. 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. A separate drift evaluation has not been performed for the leakage detection instrumentation for the following reasons:

CNP Units 1 and 2 Page 6 of 9 Attachment 1, Volume 9, Rev. 0, Page 476 of 624

Attachment 1, Volume 9, Rev. 0, Page 477 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION a) The containment sump monitoring instrumentation is used as the primary method for evaluation of RCS Operational LEAKAGE. The process variable being monitored is a change in LEAKAGE over a relatively short time interval (i.e., hours, not refueling outage to refueling outage).

Instrument drift is considered a long-term affect, and the drift that occurs during the short duration between readings on the leakage instruments is insignificant and will not affect the conclusions drawn relative to RCS LEAKAGE. Therefore, the short-term LEAKAGE change measurement is unaffected by long term drift of the instrumentation. Normal operation of all leakage detection instrumentation is also confirmed at the end of the day by totaling the LEAKAGE and confirming that no abnormal conditions exist. This verification would identify any significant changes in the leakage detection instruments and therefore confirms proper operation.

Since drift of the detector is not a consideration, the projected performance is based on the historical performance of the monitoring circuits.

b) The containment atmospheric radioactivity instruments monitor only for a sudden increase of radioactivity, which could be due to steam or water leakage. The containment atmospheric radioactivity monitoring instruments are not capable of quantifying LEAKAGE rates, but are sensitive enough to indicate increased LEAKAGE rates. Additionally, 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 decay curves and the detector sensitivity may be from 12% to 30% accurate. 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% which also recognizes +/- 30% for alarm points. Since drift of the detector is not a consideration, the projected performance is based on the historical performance of the monitoring circuits.

c) The containment humidity monitoring instruments only monitor for short-term increases in area humidity and are not assumed to detect small humidity changes over long periods of time. This short-term LEAKAGE change measurement is unaffected by long-term drift of the instrumentation. Since drift of the instrument is not a consideration, the projected performance is based on the historical performance of the monitoring circuits. The ability to detect LEAKAGE is not degraded due to any long-term drift considerations.

The Reactor Coolant Leakage Detection instrumentation provides a monitoring function only to alert the operator to a potential unit problem. The alarm setpoints of these devices are not an assumption in any safety analyses. ITS SR 3.4.15.1 and SR 3.4.15.2 require that a CHANNEL CHECK and CHANNEL OPERATIONAL TEST, respectively, be performed on a more frequent basis on the required containment atmosphere (particulate and gaseous radioactivity)

CNP Units 1 and 2 Page 7 of 9 Attachment 1, Volume 9, Rev. 0, Page 477 of 624

Attachment 1, Volume 9, Rev. 0, Page 478 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION channels. Based on the redundant detection methods, the other functional tests performed on the required containment atmosphere (particulate and gaseous radioactivity) channels, the historical calibration records, and the design of the instrumentation and the drift evaluations, it is concluded that the impact, if any, from this change on system availability is minimal. A review of the Surveillance test history was performed to validate the above conclusion. This review demonstrates that there are no failures that would invalidate the conclusion that the impact, if any, on system availability from this change is minimal. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.7 (Category 5 - Deletion of Surveillance Requirement) CTS Table 4.3-3 requires a CHANNEL CHECK of the particulate and gaseous channels every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In addition, per Table 4.3-3 Note *, this CHANNEL CHECK includes a SOURCE CHECK. ITS SR 3.4.15.1 requires a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. This changes the CTS by deleting the SOURCE CHECK of the particulate and gaseous channels.

The purpose of CTS Table 4.3-3 is to provide the appropriate Surveillance schedule for the associated monitors. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, the equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. The requirement to perform a SOURCE CHECK on the particulate and gaseous channels has been deleted. The CHANNEL CHECK gives reasonable confidence that the channel is operating properly every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . A verification that the channel will respond to a source will be performed during a CHANNEL CALIBRATION every 24 months since the CHANNEL CALIBRATION is a test of the entire channel. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.8 (Category 9 - Surveillance Frequency Change Using GL 91-04 Guidelines, Non-24 Month Type Change) CTS Table 4.3-3 requires a CHANNEL FUNCTIONAL TEST of the particulate and noble gas channels every 92 days. ITS SR 3.4.15.2 requires the performance of a COT of the required containment atmosphere radioactivity monitors every 184 days. This changes the CTS by extending the Frequency of the Surveillance from 92 days (i.e., 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 a COT is discussed in DOC A.3.

The purpose of the CHANNEL FUNCTIONAL TEST requirement in CTS Table 4.3-3 is to ensure the channels of the required containment atmosphere radioactivity monitors will function as designed to detect a change in RCS leakage. An evaluation of the surveillance interval extension was performed, based on the same approach described in NRC Generic Letter No. 91-04, CNP Units 1 and 2 Page 8 of 9 Attachment 1, Volume 9, Rev. 0, Page 478 of 624

Attachment 1, Volume 9, Rev. 0, Page 479 of 624 DISCUSSION OF CHANGES ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal.

Extending the Surveillance test interval for this COT is acceptable because the accuracy of the indication of leakage is not changed due to the extended surveillance interval. Based on the inherent system accuracy 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.

CNP Units 1 and 2 Page 9 of 9 Attachment 1, Volume 9, Rev. 0, Page 479 of 624

Attachment 1, Volume 9, Rev. 0, Page 480 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 487 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION

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

2. ISTS LCO 3.4.15.b and LCO 3.4.15.c for Unit 1 have been revised to be consistent with the current licensing basis. ITS 3.4.15 ACTIONS B, C, and D for Unit 1 have also been revised to be consistent with the equipment reflected in the LCO. In addition, the Completion Times for Unit 1 of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in ISTS 3.4.15 Required Actions B.1.1 and B.1.2 have been changed to Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

These changes have been made to be consistent with the condition for application of leak-before-break methodology to the pressurizer surge line as documented in a Letter from Indiana Michigan Power Company (M.W. Rencheck) to the NRC dated October 26, 2000 (Letter C1000-20) for Unit 1.

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

4. ISTS 3.4.15 Required Action C.1 has been changed from Perform SR 3.4.15.1 to Analyze grab samples of the containment atmosphere. The Completion Time of this Required Action is Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . SR 3.4.15.1 is the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitors.

The Surveillance Frequency for SR 3.4.15.1 is every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ISTS 3.4.15 Required Action C.1 does not add any additional requirements since SR 3.4.15.1 is normally performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.4.15 Required Action C.1 is consistent with the current licensing basis and is considered appropriate. In addition, the Completion Time of ISTS 3.4.15 Required Action C.2 has been changed from 30 days to Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The normal Frequency of SR 3.4.13.1 is every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The ISTS 3.4.15 Required Action C.2 Completion Time of 30 days does not add any additional requirements since SR 3.4.13.1 is normally performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Completion Time of ITS 3.4.15 Required Action C.2 of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is consistent with the Completion Time of ITS 3.4.15 Required Action C.1.

These changes are necessary since when ITS 3.4.15 Condition C is entered either Required Actions C.1 or Required Action C.2 are required to be met.

5. At CNP, there are actually three distinct containment sumps, each collecting leakage from a different area. The only monitoring instruments that can be used to monitor leakage are the pump runout timers, which provide flow monitoring. Therefore, ISTS LCO 3.4.15, ACTION A, Condition F, and SR 3.4.15.3 are modified to reflect this design.

6. The Frequency has been changed to 184 days. The technical justification for this change is provided in the Discussion of Changes.

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Attachment 1, Volume 9, Rev. 0, Page 500 of 624 B 3.4.15 1 INSERT 11

3. AEP Letter to NRC, AEP:NRC:0137D, "NRC Generic Letter 84-04; Elimination Of Postulated Pipe Breaks In Primary Main Loops Generic Issue A-2, Asymmetric Blowdown Loads On PWR Primary Systems Request For License Condition Deletion," dated 9/10/84.

4. NRC Letter to AEP, "Generic Letter 84-04, Safety Evaluation of Westinghouse Topical Reports Dealing With Elimination of Postulated Pipe Breaks in PWR Primary Main Loops," dated 11/22/85.

1 (Unit 1 only)

INSERT 12

6. WCAP-15435, Rev. 1, Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2 Nuclear Power Plant, August 2000.

Insert Page B 3.4.15-6 Attachment 1, Volume 9, Rev. 0, Page 500 of 624

Attachment 1, Volume 9, Rev. 0, Page 501 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.15 BASES, RCS LEAKAGE DETECTION 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 brackets are removed and the proper plant specific information/value is provided.

3. Changes are made to reflect changes made to the ISTS. The subsequent requirements are renumbered or revised, where applicable, to reflect the changes.

4. Editorial change made for consistency with other places in the Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 501 of 624

Attachment 1, Volume 9, Rev. 0, Page 502 of 624 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 9, Rev. 0, Page 503 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 503 of 624

, Volume 9, Rev. 0, Page 504 of 624 ATTACHMENT 16 ITS 3.4.16, SPECIFIC ACTIVITY , Volume 9, Rev. 0, Page 504 of 624

, Volume 9, Rev. 0, Page 505 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 505 of 624

Attachment 1, Volume 9, Rev. 0, Page 506 of 624 ITS 3.4.16 A.1 ITS LCO 3.4.16 SR 3.4.16.2 SR 3.4.16.1 L.1 Add proposed Condition A Note L.2 ACTION A ACTION B ACTION B L.1 ACTION A L.3 A.2 SR 3.4.16.1, SR 3.4.16.2, SR 3.4.16.3 APPLICABILITY Page 1 of 8 Attachment 1, Volume 9, Rev. 0, Page 506 of 624

Attachment 1, Volume 9, Rev. 0, Page 507 of 624 ITS 3.4.16 A.1 ITS Page 2 of 8 Attachment 1, Volume 9, Rev. 0, Page 507 of 624

ITS L.1 SR 3.4.16.1 L.4 SR 3.4.16.2 LA.1 Add proposed Note to SR 3.4.16.3 A.1 SR 3.4.16.3 L.5 Required Action A.1 L.1 LA.1 L.3 SR 3.4.16.2 L.1 , Volume 9, Rev. 0, Page 508 of 624 Attachment 1, Volume 9, Rev. 0, Page 508 of 624 Page 3 of 8 A.2 SR 3.4.16.3 ITS 3.4.16

Attachment 1, Volume 9, Rev. 0, Page 509 of 624 ITS 3.4.16 A.1 ITS Figure 3.4.16-1 Page 4 of 8 Attachment 1, Volume 9, Rev. 0, Page 509 of 624

Attachment 1, Volume 9, Rev. 0, Page 510 of 624 ITS 3.4.16 A.1 ITS LCO 3.4.16 SR 3.4.16.2 SR 3.4.16.1 L.1 Add proposed Condition A Note L.2 ACTION A ACTION B ACTION B L.1 ACTION A L.3 A.2 SR 3.4.16.1, SR 3.4.16.2, SR 3.4.16.3 APPLICABILITY Page 5 of 8 Attachment 1, Volume 9, Rev. 0, Page 510 of 624

Attachment 1, Volume 9, Rev. 0, Page 511 of 624 ITS 3.4.16 A.1 ITS Page 6 of 8 Attachment 1, Volume 9, Rev. 0, Page 511 of 624

ITS L.1 SR 3.4.16.1 7 days L.4 SR 3.4.16.2 LA.1 SR 3.4.16.3 Add proposed Note to SR 3.4.16.3 L.5 L.1 Required Action A.1 LA.1 L.3 A.1 L.1 SR 3.4.16.2 A.2 SR 3.4.16.3 , Volume 9, Rev. 0, Page 512 of 624 Attachment 1, Volume 9, Rev. 0, Page 512 of 624 Page 7 of 8 ITS 3.4.16

Attachment 1, Volume 9, Rev. 0, Page 513 of 624 ITS 3.4.16 A.1 Figure 3.4.16-1 Page 8 of 8 Attachment 1, Volume 9, Rev. 0, Page 513 of 624

Attachment 1, Volume 9, Rev. 0, Page 514 of 624 DISCUSSION OF CHANGES ITS 3.4.16, RCS SPECIFIC ACTIVITY 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 3.4.8 Action a (MODES 1, 2, 3, 4, and 5) and CTS Table 4.4-4, Footnote #,

require the isotopic analysis for iodine to be performed until the specific activity of the primary coolant system is restored to within limits. ITS 3.4.16 Required Action A.1 requires this same analysis, however the explicit statement to perform the isotopic analysis for iodine until the limits are met has been deleted. This changes the CTS by deleting the explicit statement to perform the isotopic analysis for iodine until the limits are met.

The purpose of the CTS 3.4.8 Action a (MODES 1, 2, 3, 4, and 5) and CTS Table 4.4-4 is to ensure the Surveillance is performed to determine whether the specific activity is met. This statement is not necessary in the ITS, because ITS LCO 3.0.2 requires the Required Actions of the associated Conditions to be met upon discovery of failure to meet an LCO. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. This change is acceptable since ITS LCO 3.0.4 will require the Required Action to be performed until the LCO is met. 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 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 4.4-4, Item 2 requires an isotopic analysis to determine whether DOSE EQUIVALENT I-131 concentration is within limit.

CTS Table 4.4-4, Item 4 requires an isotopic analysis for iodine including I-131, I-133, and I-135. ITS SR 3.4.16.2 requires the verification that reactor coolant DOES EQUIVALENT I-131 specific activity is within limit. ITS 3.4.16 Required Action A.1 requires the verification that DOSE EQUIVALENT I-131 is within the acceptable region. This changes the CTS by moving the detail that an isotopic CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 9, Rev. 0, Page 514 of 624

Attachment 1, Volume 9, Rev. 0, Page 515 of 624 DISCUSSION OF CHANGES ITS 3.4.16, RCS SPECIFIC ACTIVITY analysis must be performed to satisfy the requirements of the Surveillances to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.4.16.2 and ITS 3.4.16 Required Action A.1 still retain the requirements to verify reactor coolant DOSE EQUIVALENT I-131 is within limit. Also, this change is acceptable because these types of procedural details will be adequately controlled 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 2 - Relaxation of Applicability) CTS 3.4.8 is applicable in MODES 1, 2, 3, 4, and 5. In addition, the testing for gross activity determination in CTS Table 4.4-4 is required in MODES 1, 2, 3, and 4 and the isotopic analysis for iodine requirement in CTS Table 4.4-4 is required periodically in MODES 1, 2, 3, 4, and 5 and after a 15% RTP change in MODES 1, 2, and 3. ITS 3.4.16, including the Surveillances, is applicable in MODES 1 and 2, and MODE 3 with RCS Tavg > 500°F. This changes the CTS by reducing the MODES in which the LCO is applicable, including the Surveillances, to only MODES 1 and 2, and MODES 3 with RCS Tavg > 500°F.

The purpose of CTS 3.4.8 is to ensure that the specific activity of the RCS is within the assumptions of the Steam Generator Tube Rupture (SGTR) analysis.

This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. During operation in MODE 3 with RCS Tavg < 500°F, and in MODES 4 and 5, the release of radioactivity in the event of a SGTR is unlikely because the saturation pressure of the reactor coolant is below the lift pressure settings of the main steam safety valves. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.2 (Category 13 - Addition of LCO 3.0.4 Exception) CTS 3.4.8 does not allow the unit to change MODES when the RCS specific activity is not within limits.

ITS 3.4.16 Condition A Note specifies that LCO 3.0.4 is not applicable. This changes the CTS by allowing the unit to change MODES or other specified Conditions in the Applicability when the specific activity for DOSE EQUIVALENT I-131 is > 1.0 µCi/gm.

The purpose of CTS 3/4.4.8 is to ensure appropriate limitations are placed on reactor coolant activity. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 9, Rev. 0, Page 515 of 624

Attachment 1, Volume 9, Rev. 0, Page 516 of 624 DISCUSSION OF CHANGES ITS 3.4.16, RCS SPECIFIC ACTIVITY degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change allows the unit to change MODES or other specified Conditions in the Applicability when the specific activity for DOSE EQUIVALENT I-131 is > 1.0 µCi/gm. However, after entering the Applicability the unit must enter ACTION A and verify DOSE EQUIVALENT I-131 is within the acceptable region of Figure 3.4.16-1 every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This verification will ensure that a steam generator tube rupture will not lead to a site boundary dose that exceeds the 10 CFR 100 dose guideline limits. Therefore, this change is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the unit remains at, or proceeds to power operation. In addition, ITS 3.4.16 ACTION A requires DOSE EQUIVALENT I-131 to be within limit in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

This change is designated as less restrictive because the Required Action Note allows entry into the MODE of Applicability when the specific activity for DOSE EQUIVALENT I-131 is > 1.0 µCi/gm.

L.3 (Category 4 - Relaxation of Required Action) CTS 3.4.8 Action a (MODES 1, 2, 3, 4, and 5) and CTS Table 4.4-4, Item 4, part a, require isotopic analysis for iodine once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when the specific activity exceeds 100/ E µCi/gm. The ITS does not contain this Action. This changes the CTS by eliminating a conditionally performed Surveillance when gross activity exceeds 100/ E µCi/gm.

The purpose of CTS 3.4.8 Action a (MODES 1, 2, 3, 4, and 5) and CTS Table 4.4-4, Item 4, part a is to monitor iodine activity when the specific activity limits are exceeded. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. When specific activity exceeds 100/ E µCi/gm, ITS 3.4.16 Required Action B.1 and CTS 3.4.8 Action b (MODES 1 and 2, and MODE 3 with Tavg > 500°F) require the plant to be in MODE 3 with Tavg < 500°F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Monitoring of E is required in order to determine if the LCO is met and the ACTION can be exited. Furthermore, if the Condition is entered and the unit is in MODE 2 in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or less, the Required Action is in conflict with the Note of ITS SR 3.4.16.2, which states that this SR is only required in MODE 1.

Finally, this action is an unnecessary burden as the unit is required to be in MODE 3 with Tavg < 500°F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , exiting the Applicability. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 9, Rev. 0, Page 516 of 624

Attachment 1, Volume 9, Rev. 0, Page 517 of 624 DISCUSSION OF CHANGES ITS 3.4.16, RCS SPECIFIC ACTIVITY L.4 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.4-4, Item 1, requires gross activity to be determined three times per 7 days with a maximum time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months between samples (Unit 1) and at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Unit 2). ITS SR 3.4.16.1 requires verification that the reactor coolant gross specific activity is < 100/ E µCi/gm every 7 days. This changes the CTS by reducing the Frequency from three times per 7 days with a maximum time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months between samples (Unit 1) and at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Unit 2) to 7 days for both units.

The purpose of CTS Table 4.4-4, Item 1, is to obtain a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding iodines, which provides an indication of increases in gross specific activity. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of monitoring. A Frequency of 7 days provides sufficient information to trend the results in order to detect gross fuel failure, while considering the low probability of a gross fuel failure between performances. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.5 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS Table 4.4-4, Item 3, requires radiochemical determination of E once per 6 months. Footnote

states that the sample is to be taken after a minimum of 2 EFPD and 20 days of POWER OPERATION have elapsed since the reactor was last subcritical for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or longer. ITS SR 3.4.16.3 requires E to be determined from a sample taken in MODE 1 after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS SR 3.4.16.3 is modified by a Note which states, "Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ." This changes the CTS by putting a limit, 31 days, on when the Surveillance must be performed after the requisite conditions are met.

The purpose of CTS Table 4.4-4, Item 3, is to determine the value of E when the isotopic concentrations in the core are stable. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of monitoring. Circumstances could arise in which the 6 month Frequency for performance of the SR has passed but the operating conditions for performance of the test have not been met. In this circumstance, the Surveillance would be immediately past due as soon as the operating conditions are met. The ITS Note allows 31 days to perform the Surveillance after the operating conditions are met. 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 9, Rev. 0, Page 518 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 524 of 624 3.4.16 2

INSERT 2 (275, 26) 275 250 225 200 DOSE EQUIVALENT I-131 Limit (µCi/gm)

UNACCEPTABLE OPERATION 175 150 125 100 ACCEPTABLE OPERATION 75 (60, 100)

(60, 80) 50 25 0

20 30 40 50 60 70 80 90 100 RTP (%)

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Attachment 1, Volume 9, Rev. 0, Page 525 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.16, RCS SPECIFIC ACTIVITY

1. ISTS 3.4.16 ACTION B has been deleted and incorporated in ISTS 3.4.16 ACTION C (ITS 3.4.16 ACTION B) because the Required Actions are identical (be in MODE 3 with Tavg < 500°F). In NUREG-1431, Rev. 1, ISTS 3.4.16 ACTION B contained an additional Required Action. This Required Action was deleted in NUREG-1431, Rev. 2, as a result of approved TSTF-28. ACTION B should have been deleted as a result of the application of TSTF-28, but was not. This changes the ISTS to be consistent with other Specifications where ACTION Conditions are combined when the same Required Actions apply.

2. The CNP reactor coolant DOSE EQUIVALENT I-131 specific power limit verses percent of RATED THERMAL POWER curve is substituted for the curve provided for illustration in the ISTS.

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Attachment 1, Volume 9, Rev. 0, Page 526 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 9, Rev. 0, Page 529 of 624 B 3.4.16 1

INSERT 1 based on an evolution rate that is 500 times normal equilibrium rate for a spike duration of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 1

INSERT 1A and, for the concurrent iodine spike case, has a linear increasing DOSE EQUIVALENT I-131 level beginning immediately after the accident and reaching a maximum level in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (when fuel cladding gap iodine inventory has been depleted).

Insert Page B 3.4.16-2 Attachment 1, Volume 9, Rev. 0, Page 529 of 624

, Volume 9, Rev. 0, Page 530 of 624 , Volume 9, Rev. 0, Page 530 of 624

Attachment 1, Volume 9, Rev. 0, Page 531 of 624 B 3.4.16 1

INSERT 1B An isotopic analysis of a reactor coolant sample must be performed for at least I-131, I-133, and I-135.

Insert Page B 3.4.16-3 Attachment 1, Volume 9, Rev. 0, Page 531 of 624

, Volume 9, Rev. 0, Page 532 of 624 , Volume 9, Rev. 0, Page 532 of 624

, Volume 9, Rev. 0, Page 533 of 624 , Volume 9, Rev. 0, Page 533 of 624

, Volume 9, Rev. 0, Page 534 of 624 , Volume 9, Rev. 0, Page 534 of 624

, Volume 9, Rev. 0, Page 535 of 624 , Volume 9, Rev. 0, Page 535 of 624

Attachment 1, Volume 9, Rev. 0, Page 536 of 624 JUSTIFICATION FOR DEVIATIONS ITS 3.4.16 BASES, RCS SPECIFIC ACTIVITY

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 be consistent with the ISTS.

3. Changes are made to be consistent with changes made to the ISTS.

4. The Reference to 10 CFR 100.11 is revised to eliminate the referenced year. The most recent version of the Code of Federal Regulations is applicable and referencing a year is unnecessary.

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

6. This statement is redundant and has been deleted. Any time the unit is modified, appropriate safety analyses must be reviewed.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 536 of 624

Attachment 1, Volume 9, Rev. 0, Page 537 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 537 of 624

Attachment 1, Volume 9, Rev. 0, Page 538 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.4.16, RCS SPECIFIC ACTIVITY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 538 of 624

Attachment 1, Volume 9, Rev. 0, Page 539 of 624 ATTACHMENT 17 Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 9, Rev. 0, Page 539 of 624

, Volume 9, Rev. 0, Page 540 of 624 CTS 3/4.4.7, CHEMISTRY , Volume 9, Rev. 0, Page 540 of 624

, Volume 9, Rev. 0, Page 541 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 541 of 624

, Volume 9, Rev. 0, Page 542 of 624 CTS 3/4.4.7 R.1 Page 1 of 6 , Volume 9, Rev. 0, Page 542 of 624

, Volume 9, Rev. 0, Page 543 of 624 CTS 3/4.4.7 R.1 Page 2 of 6 , Volume 9, Rev. 0, Page 543 of 624

, Volume 9, Rev. 0, Page 544 of 624 CTS 3/4.4.7 R.1 Page 3 of 6 , Volume 9, Rev. 0, Page 544 of 624

, Volume 9, Rev. 0, Page 545 of 624 CTS 3/4.4.7 R.1 Page 4 of 6 , Volume 9, Rev. 0, Page 545 of 624

, Volume 9, Rev. 0, Page 546 of 624 CTS 3/4.4.7 R.1 Page 5 of 6 , Volume 9, Rev. 0, Page 546 of 624

, Volume 9, Rev. 0, Page 547 of 624 CTS 3/4.4.7 R.1 Page 6 of 6 , Volume 9, Rev. 0, Page 547 of 624

Attachment 1, Volume 9, Rev. 0, Page 548 of 624 DISCUSSION OF CHANGES CTS 3/4.4.7, CHEMISTRY ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.4.7 provides limits on the oxygen, chloride and fluoride content in the RCS. Poor coolant water chemistry contributes to the long term degradation of system materials of construction, and thus is not of immediate importance to the unit operator. Reactor coolant water chemistry is monitored for a variety of reasons. One reason is to reduce the possibility of failures in the Reactor Coolant System pressure boundary caused by corrosion. However, the chemistry monitoring activity is of a long term preventative purpose rather than mitigative. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.4.7 does not meet the 10 CFR 50.92(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The RCS chemistry limits are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. The RCS Chemistry Specification does not satisfy criterion 1.

2. The RCS chemistry limits are not a process variable that is an initial condition of a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The RCS Chemistry Specification does not satisfy criterion 2.

3. The RCS chemistry limits are not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The RCS Chemistry Specification does not satisfy criterion 3.

4. The RCS chemistry limits are not a structure, system, or component 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-40) and summarized in Table 1 of WCAP-11618, the RCS chemistry limits were 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, CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 548 of 624

Attachment 1, Volume 9, Rev. 0, Page 549 of 624 DISCUSSION OF CHANGES CTS 3/4.4.7, CHEMISTRY and concurs with this assessment. The RCS Chemistry Specification does not meet criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the RCS Chemistry LCO and associated Surveillances may be relocated out of the Technical Specifications. The RCS Chemistry Specification will be relocated to the TRM.

Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the LCO 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 9, Rev. 0, Page 549 of 624

Attachment 1, Volume 9, Rev. 0, Page 550 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 550 of 624

Attachment 1, Volume 9, Rev. 0, Page 551 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.4.7, CHEMISTRY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 551 of 624

, Volume 9, Rev. 0, Page 552 of 624 CTS 3/4.4.9.2, PRESSURIZER , Volume 9, Rev. 0, Page 552 of 624

, Volume 9, Rev. 0, Page 553 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 553 of 624

, Volume 9, Rev. 0, Page 554 of 624 CTS 3/4.4.9.2 R.1 Page 1 of 2 , Volume 9, Rev. 0, Page 554 of 624

, Volume 9, Rev. 0, Page 555 of 624 CTS 3/4.4.9.2 R.1 Page 2 of 2 , Volume 9, Rev. 0, Page 555 of 624

Attachment 1, Volume 9, Rev. 0, Page 556 of 624 DISCUSSION OF CHANGES CTS 3/4.4.9.2, PRESSURIZER ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.4.9.2 states that the pressurizer temperature shall be limited to a maximum heatup of 100°F or cooldown of 200°F in any one hour period and a maximum spray water temperature differential of 320°F. The limits meet the requirements given in the ASME Boiler and Pressure Vessel Code,Section III, Appendix G. These limitations are consistent with structural analysis results.

However, these limits are not initial condition assumptions of a DBA or transient.

These limits represent operating restrictions and Criterion 2 includes operating restrictions. However, it should be noted that in the Final Policy Statement the Criterion 2 discussion specified only those operating restrictions required to preclude unanalyzed accidents and transients be included in Technical Specifications. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.4.9.2 does not meet the 10 CFR 50.92(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The pressurizer temperature limits are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The Pressurizer Specification does not satisfy criterion 1.

2. The pressurizer temperature limits are not a process variable that is an initial condition of a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Pressurizer Specification does not satisfy criterion 2.

3. The pressurizer temperature limits are not a structure, system or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Pressurizer Specification does not satisfy criterion 3.

4. The pressurizer temperature limits are not a structure, system, or component 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-41) and summarized in Table 1 of CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 556 of 624

Attachment 1, Volume 9, Rev. 0, Page 557 of 624 DISCUSSION OF CHANGES CTS 3/4.4.9.2, PRESSURIZER WCAP-11618, the pressurizer temperature limits were 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 this assessment. The Pressurizer Specification does not meet criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Pressurizer LCO and associated Surveillances may be relocated out of the Technical Specifications. The Pressurizer Specification will be relocated to the TRM.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 557 of 624

Attachment 1, Volume 9, Rev. 0, Page 558 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 558 of 624

Attachment 1, Volume 9, Rev. 0, Page 559 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.4.9.2, PRESSURIZER There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 559 of 624

Attachment 1, Volume 9, Rev. 0, Page 560 of 624 CTS 3/4.4.10.1, ASME CODE CLASS 1, 2 AND 3 COMPONENTS Attachment 1, Volume 9, Rev. 0, Page 560 of 624

, Volume 9, Rev. 0, Page 561 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 561 of 624

, Volume 9, Rev. 0, Page 562 of 624 CTS 3/4.4.10.1 R.1 See ITS 5.5 Page 1 of 3 , Volume 9, Rev. 0, Page 562 of 624

, Volume 9, Rev. 0, Page 563 of 624 CTS 3/4.4.10.1 Page 2 of 3 , Volume 9, Rev. 0, Page 563 of 624

, Volume 9, Rev. 0, Page 564 of 624 CTS 3/4.4.10.1 R.1 See ITS 5.5 Page 3 of 3 , Volume 9, Rev. 0, Page 564 of 624

Attachment 1, Volume 9, Rev. 0, Page 565 of 624 DISCUSSION OF CHANGES CTS 3/4.4.10.1, ASME CODE CLASS 1, 2 AND 3 COMPONENTS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.4.10.1 provides requirements for the ASME Code Class 1, 2 and 3 components to ensure their structural integrity. The inspection programs for ASME Code Class 1, 2 and 3 components ensure that the structural integrity of these components will be maintained throughout the life of the components.

ASME Code Class 1, 2, and 3 components are monitored so that the possibility of component structural failure does not degrade the safety function of the system. The monitoring activity is of a preventive nature rather than a mitigative action. Other Technical Specifications require important systems to be OPERABLE (for example, Emergency Core Cooling Systems) and in a ready state for mitigative action. This Technical Specification is more directed toward prevention of component degradation and continued long term maintenance of acceptable structural conditions. Hence, it is not necessary to retain this Specification to ensure immediate OPERABILITY of safety systems. Further, this Technical Specification prescribes inspection requirements that are performed during plant shutdown. It is, therefore, not directly important for responding to design basis accidents. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.4.10.1 does not meet the 10 CFR 50.92(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The inspections stipulated by this Specification are not installed instrumentation used for detecting, and indicating in the control room, a significant abnormal degradation of the reactor coolant pressure boundary during operations prior to a DBA. The ASME Code Class 1, 2 and 3 Components Specification does not satisfy criterion 1.

2. The inspections stipulated by this Specification are not a process variable, design feature, or operating restriction that is an initial assumption in a DBA or transient. The ASME Code Class 1, 2 and 3 Components Specification does not satisfy criterion 2.

3. The ASME Code Class 1, 2 and 3 Components inspected per this Specification are assumed to function to mitigate a DBA. Their capability to perform this function is addressed by other Technical Specifications.

This Technical Specification only specifies inspection requirements for CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 565 of 624

Attachment 1, Volume 9, Rev. 0, Page 566 of 624 DISCUSSION OF CHANGES CTS 3/4.4.10.1, ASME CODE CLASS 1, 2 AND 3 COMPONENTS these components, and these inspections can only be performed when the plant is shutdown. Therefore, criterion 3 is not satisfied.

4. The ASME Code Class 1, 2 and 3 Components are not a structure, system, or component 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-43) and summarized in Table 1 of WCAP-11618, the assurance of OPERABILITY of the entire system as verified in the system OPERABILITY Specification dominates the risk contribution of the system. The lack of a long term assurance of structural integrity as stipulated by this Specification 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 this assessment. The ASME Code Class 1, 2 and 3 Components Specification does not meet criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the ASME Code Class 1, 2 and 3 Components LCO and associated Surveillances may be relocated out of the Technical Specifications. The ASME Code Class 1, 2 and 3 Components Specification will be relocated to the TRM. Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. In addition, Surveillances, except for the reactor coolant pump (RCP) flywheel inspection, are already required by regulations in 10 CFR 50.55a to be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda. The RCP flywheel inspection requirement is not covered by other regulatory requirements and is needed for safe operation of the plant; therefore, this requirement will be maintained in the CNP Units 1 and 2 Improved Technical Specifications. Chapter 5.0 of the CNP Units 1 and 2 Improved Technical Specifications will contain a section which provides a programmatic approach to the requirements relating to the structural integrity of ASME Code Class 1, 2, and 3 components. This change is designated as relocation because the Specification did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 566 of 624

Attachment 1, Volume 9, Rev. 0, Page 567 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 567 of 624

Attachment 1, Volume 9, Rev. 0, Page 568 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.4.10.1, ASME CODE CLASS 1, 2 AND 3 COMPONENTS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 568 of 624

, Volume 9, Rev. 0, Page 569 of 624 CTS 3/4.4.12.1, REACTOR VESSEL HEAD VENTS , Volume 9, Rev. 0, Page 569 of 624

, Volume 9, Rev. 0, Page 570 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 570 of 624

, Volume 9, Rev. 0, Page 571 of 624 CTS 3/4.4.12.1 R.1 Page 1 of 4 , Volume 9, Rev. 0, Page 571 of 624

, Volume 9, Rev. 0, Page 572 of 624 CTS 3/4.4.12.1 R.1 Page 2 of 4 , Volume 9, Rev. 0, Page 572 of 624

, Volume 9, Rev. 0, Page 573 of 624 CTS 3/4.4.12.1 R.1 Page 3 of 4 , Volume 9, Rev. 0, Page 573 of 624

, Volume 9, Rev. 0, Page 574 of 624 CTS 3/4.4.12.1 R.1 Page 4 of 4 , Volume 9, Rev. 0, Page 574 of 624

Attachment 1, Volume 9, Rev. 0, Page 575 of 624 DISCUSSION OF CHANGES CTS 3/4.4.12.1, REACTOR VESSEL HEAD VENTS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.4.12.1 provides requirements for the reactor vessel head vents. The reactor vessel head vents are provided to exhaust noncondensible gases and/or steam from the RCS which could inhibit natural circulation core cooling following any event involving a loss of offsite power and requiring long term cooling, such as a loss-of-coolant accident (LOCA). Their function, capabilities, and testing requirements are consistent with the requirements of Item II.B.1 of NUREG-0737, "Clarification of TMI Action Plan Requirements," however, the operation of reactor vessel head vents is not part of the primary success path. The operation of these vents is an operator action after the event has occurred, and is only required when there is indication that natural circulation is not occurring. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.4.12.1 does not meet the 10 CFR 50.92(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The reactor vessel head vents are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The Reactor Vessel Head Vents Specification does not satisfy criterion 1.

2. The reactor vessel head vents are not a process variable that is an initial condition of a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Reactor Vessel Head Vents Specification does not satisfy criterion 2.

3. The reactor vessel head vents are not a structure, system or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Reactor Vessel Head Vents Specification does not satisfy criterion 3.

4. The reactor vessel head vents are not a structure, system, or component 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-44) and summarized in Table 1 of WCAP-11618, the reactor vessel head vents were found to be a non-significant risk CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 575 of 624

Attachment 1, Volume 9, Rev. 0, Page 576 of 624 DISCUSSION OF CHANGES CTS 3/4.4.12.1, REACTOR VESSEL HEAD VENTS 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 this assessment. The Reactor Vessel Head Vents Specification does not meet criterion 4.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 576 of 624

Attachment 1, Volume 9, Rev. 0, Page 577 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 577 of 624

Attachment 1, Volume 9, Rev. 0, Page 578 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.4.12.1, REACTOR VESSEL HEAD VENTS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 578 of 624

Attachment 1, Volume 9, Rev. 0, Page 579 of 624 CTS 3/4.4.12.2, PRESSURIZER STEAM SPACE VENTS Attachment 1, Volume 9, Rev. 0, Page 579 of 624

, Volume 9, Rev. 0, Page 580 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 580 of 624

, Volume 9, Rev. 0, Page 581 of 624 CTS 3/4.4.12.2 R.1 Page 1 of 4 , Volume 9, Rev. 0, Page 581 of 624

, Volume 9, Rev. 0, Page 582 of 624 CTS 3/4.4.12.2 R.1 Page 2 of 4 , Volume 9, Rev. 0, Page 582 of 624

, Volume 9, Rev. 0, Page 583 of 624 CTS 3/4.4.12.2 R.1 Page 3 of 4 , Volume 9, Rev. 0, Page 583 of 624

, Volume 9, Rev. 0, Page 584 of 624 CTS 3/4.4.12.2 R.1 Page 4 of 4 , Volume 9, Rev. 0, Page 584 of 624

Attachment 1, Volume 9, Rev. 0, Page 585 of 624 DISCUSSION OF CHANGES CTS 3/4.4.12.2, PRESSURIZER STEAM SPACE VENTS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.4.12.2 provides requirements for the pressurizer steam space vents.

The pressurizer steam space vents are provided to exhaust noncondensible gases and/or steam from the RCS which could inhibit natural circulation core cooling following any event involving a loss of offsite power and requiring long term cooling, such as a loss-of-coolant accident (LOCA). Their function, capabilities, and testing requirements are consistent with the requirements of Item II.B.1 of NUREG-0737, "Clarification of TMI Action Plan Requirements,"

however, the operation of pressurizer steam space vents is not part of the primary success path. The operation of these vents is an operator action after the event has occurred, and is only required when there is indication that natural circulation is not occurring. This Specification does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3/4.4.12.2 does not meet the 10 CFR 50.92(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The pressurizer steam space vents are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The Pressurizer Steam Space Vents Specification does not satisfy criterion 1.

2. The pressurizer steam space vents are not a process variable that is an initial condition of a DBA or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Pressurizer Steam Space Vents Specification does not satisfy criterion 2.

3. The pressurizer steam space vents are not a structure, system, or component that is part of a primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Pressurizer Steam Space Vents Specification does not satisfy criterion 3.

4. The pressurizer steam space vents are not a structure, system, or component which operating experience or probabilistic risk assessment CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 9, Rev. 0, Page 585 of 624

Attachment 1, Volume 9, Rev. 0, Page 586 of 624 DISCUSSION OF CHANGES CTS 3/4.4.12.2, PRESSURIZER STEAM SPACE VENTS has shown to be significant to public health and safety. As discussed in Section 4.0 (Appendix A, page A-44) and summarized in Table 1 of WCAP-11618, the pressurizer steam space vents were 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 Pressurizer Steam Space Vents Specification does not satisfy criterion 4.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 9, Rev. 0, Page 586 of 624

Attachment 1, Volume 9, Rev. 0, Page 587 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 587 of 624

Attachment 1, Volume 9, Rev. 0, Page 588 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.4.12.2, PRESSURIZER STEAM SPACE VENTS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 588 of 624

, Volume 9, Rev. 0, Page 589 of 624 CTS 3/4.10.5 (UNIT 1) AND 3/4.10.4 (UNIT 2),

NATURAL CIRCULATION TESTS , Volume 9, Rev. 0, Page 589 of 624

, Volume 9, Rev. 0, Page 590 of 624 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 9, Rev. 0, Page 590 of 624

, Volume 9, Rev. 0, Page 591 of 624 CTS 3/4.10.5 M.1 Page 1 of 2 , Volume 9, Rev. 0, Page 591 of 624

, Volume 9, Rev. 0, Page 592 of 624 CTS 3/4.10.4 M.1 Page 2 of 2 , Volume 9, Rev. 0, Page 592 of 624

Attachment 1, Volume 9, Rev. 0, Page 593 of 624 DISCUSSION OF CHANGES CTS 3/4.10.5 (Unit 1) and CTS 3/4.10.4 (Unit 2), NATURAL CIRCULATION TESTS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M.1 CTS 3/4.10.5 (Unit 1) and CTS 3/4.10.4 (Unit 2) provide an exception to the Reactor Coolant Loops and Coolant Circulation requirements in CTS 3/4.4.1.1 for the purpose of performance of PHYSICS TESTS and Thermal-Hydraulic Tests, provided the THERMAL POWER does not exceed the P-7 Interlock Setpoint, and the Reactor Trip Setpoints for the OPERABLE Intermediate Range, Neutron Flux and the Power Range, Neutron Flux, Low Setpoint are set at less than or equal to 25% of RATED THERMAL POWER. The ITS does not contain this special test exception. This changes the CTS by eliminating a special test exception.

This change is acceptable because this exception is not needed any longer for the performance of these tests. As a result, the CTS test exception is not needed. This change is designated as more restrictive because an exception to the CTS is being deleted.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 593 of 624

Attachment 1, Volume 9, Rev. 0, Page 594 of 624 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 9, Rev. 0, Page 594 of 624

Attachment 1, Volume 9, Rev. 0, Page 595 of 624 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.10.5 (Unit 1) and CTS 3/4.10.4 (Unit 2), NATURAL CIRCULATION TESTS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 595 of 624

Attachment 1, Volume 9, Rev. 0, Page 596 of 624 ATTACHMENT 18 Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 9, Rev. 0, Page 596 of 624

, Volume 9, Rev. 0, Page 597 of 624 ISTS 3.4.17, RCS LOOP ISOLATION VALVES , Volume 9, Rev. 0, Page 597 of 624

Attachment 1, Volume 9, Rev. 0, Page 598 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 598 of 624

, Volume 9, Rev. 0, Page 599 of 624 , Volume 9, Rev. 0, Page 599 of 624

Attachment 1, Volume 9, Rev. 0, Page 600 of 624 JUSTIFICATION FOR DEVIATIONS ISTS 3.4.17, REACTOR COOLANT SYSTEM LOOP ISOLATION VALVES

1. This Reactor Coolant System Loop Isolation Valves Specification is not included in the CNP Units 1 and 2 ITS because the Reactor Coolant System hot and cold leg loops do not include isolation valves.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 600 of 624

Attachment 1, Volume 9, Rev. 0, Page 601 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 601 of 624

, Volume 9, Rev. 0, Page 602 of 624 , Volume 9, Rev. 0, Page 602 of 624

, Volume 9, Rev. 0, Page 603 of 624 , Volume 9, Rev. 0, Page 603 of 624

, Volume 9, Rev. 0, Page 604 of 624 , Volume 9, Rev. 0, Page 604 of 624

Attachment 1, Volume 9, Rev. 0, Page 605 of 624 JUSTIFICATION FOR DEVIATIONS ISTS 3.4.17 BASES, REACTOR COOLANT SYSTEM LOOP ISOLATION VALVES

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 605 of 624

, Volume 9, Rev. 0, Page 606 of 624 ISTS 3.4.18, RCS ISOLATED LOOP STARTUP , Volume 9, Rev. 0, Page 606 of 624

Attachment 1, Volume 9, Rev. 0, Page 607 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 607 of 624

, Volume 9, Rev. 0, Page 608 of 624 , Volume 9, Rev. 0, Page 608 of 624

, Volume 9, Rev. 0, Page 609 of 624 , Volume 9, Rev. 0, Page 609 of 624

Attachment 1, Volume 9, Rev. 0, Page 610 of 624 JUSTIFICATION FOR DEVIATIONS ISTS 3.4.18, REACTOR COOLANT SYSTEM ISOLATED LOOP STARTUP

1. This Reactor Coolant System Isolated Loop Startup Specification is not included in the CNP Units 1 and 2 ITS because the Reactor Coolant System hot and cold leg loops do not include isolation valves.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 610 of 624

Attachment 1, Volume 9, Rev. 0, Page 611 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 611 of 624

, Volume 9, Rev. 0, Page 612 of 624 , Volume 9, Rev. 0, Page 612 of 624

, Volume 9, Rev. 0, Page 613 of 624 , Volume 9, Rev. 0, Page 613 of 624

, Volume 9, Rev. 0, Page 614 of 624 , Volume 9, Rev. 0, Page 614 of 624

Attachment 1, Volume 9, Rev. 0, Page 615 of 624 JUSTIFICATION FOR DEVIATIONS ISTS 3.4.18 BASES, REACTOR COOLANT SYSTEM ISOLATED LOOP STARTUP

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 615 of 624

, Volume 9, Rev. 0, Page 616 of 624 ISTS 3.4.19, RCS LOOPS - TEST EXCEPTIONS , Volume 9, Rev. 0, Page 616 of 624

Attachment 1, Volume 9, Rev. 0, Page 617 of 624 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 617 of 624

, Volume 9, Rev. 0, Page 618 of 624 , Volume 9, Rev. 0, Page 618 of 624

Attachment 1, Volume 9, Rev. 0, Page 619 of 624 JUSTIFICATION FOR DEVIATIONS ISTS 3.4.19, REACTOR COOLANT SYSTEM LOOPS - TEST EXCEPTIONS

1. This Reactor Coolant System Loops - Test Exceptions Specification is not included in the CNP Units 1 and 2 ITS because the exception is not needed to perform any required startup or PHYSICS TESTS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 619 of 624

Attachment 1, Volume 9, Rev. 0, Page 620 of 624 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 9, Rev. 0, Page 620 of 624

, Volume 9, Rev. 0, Page 621 of 624 , Volume 9, Rev. 0, Page 621 of 624

, Volume 9, Rev. 0, Page 622 of 624 , Volume 9, Rev. 0, Page 622 of 624

, Volume 9, Rev. 0, Page 623 of 624 , Volume 9, Rev. 0, Page 623 of 624

Attachment 1, Volume 9, Rev. 0, Page 624 of 624 JUSTIFICATION FOR DEVIATIONS ISTS 3.4.19 BASES, REACTOR COOLANT SYSTEM LOOPS - TEST EXCEPTIONS

1. Changes have been made to be consistent with changes made to the ISTS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 9, Rev. 0, Page 624 of 624

ML041200368

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