ML041200373

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 10, Rev 0, ITS Section 3.5 Emergency Core Cooling Systems (Eccs)

ML041200373
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:4901
Download: ML041200373 (164)

Text

VOLUME 10 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

Revision 0, Volume 10, Rev. 0, Page 1 of 164, Volume 10, Rev. 0, Page 1 of 164

LIST OF ATTACHMENTS

1.

ITS 3.5.1

2.

ITS 3.5.2

3.

ITS 3.5.3

4.

ITS 3.5.4

5.

ITS 3.5.5

6.

Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS, Volume 10, Rev. 0, Page 2 of 164, Volume 10, Rev. 0, Page 2 of 164

ATTACHMENT 1 ITS 3.5.1, ACCUMULATORS, Volume 10, Rev. 0, Page 3 of 164, Volume 10, Rev. 0, Page 3 of 164

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 10, Rev. 0, Page 4 of 164, Volume 10, Rev. 0, Page 4 of 164

ITS 3.5.1 ITS Page 1 of 4 A.1 LCO 3.5.1 SR 3.5.1.1 SR 3.5.1.2 SR 3.5.1.4 SR 3.5.1.3 Four A.2 SR 3.5.1.2 SR 3.5.1.3 SR 3.5.1.1 Applicability ACTION A ACTION C ACTION B ACTION C Add proposed ACTION D A.3 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> L.1, Volume 10, Rev. 0, Page 5 of 164, Volume 10, Rev. 0, Page 5 of 164

ITS 3.5.1 ITS Page 2 of 4 A.1 A.4 13 ft3 SR 3.5.1.4 SR 3.5.1.5, Volume 10, Rev. 0, Page 6 of 164, Volume 10, Rev. 0, Page 6 of 164

ITS 3.5.1 ITS Page 3 of 4 A.1 LCO 3.5.1 SR 3.5.1.1 SR 3.5.1.2 SR 3.5.1.4 SR 3.5.1.3 Four A.2 ACTION A ACTION C ACTION B ACTION C Add proposed ACTION D A.3 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> L.1 SR 3.5.1.2 SR 3.5.1.3 SR 3.5.1.1 Applicability, Volume 10, Rev. 0, Page 7 of 164, Volume 10, Rev. 0, Page 7 of 164

ITS 3.5.1 ITS Page 4 of 4 A.1 13 ft3 SR 3.5.1.4 SR 3.5.1.5 A.4, Volume 10, Rev. 0, Page 8 of 164, Volume 10, Rev. 0, Page 8 of 164

DISCUSSION OF CHANGES ITS 3.5.1, ACCUMULATORS CNP Units 1 and 2 Page 1 of 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 3.5.1 requires "each" reactor coolant system accumulator to be OPERABLE. ITS LCO 3.5.1 requires "four" ECCS accumulators to be OPERABLE. This changes the CTS by specifying the exact number of ECCS accumulators required to be OPERABLE.

This change is acceptable because the total number of ECCS accumulators installed in each unit at CNP is four. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.3 CTS 3.5.1 does not contain a specific ACTION for two or more accumulators inoperable. With two or more accumulators inoperable, CTS 3.0.3 would be entered. ITS 3.5.1 ACTION D directs entry into LCO 3.0.3 when two or more accumulators are inoperable. This changes the CTS by specifically stating to enter LCO 3.0.3 in this System Specification.

This change is acceptable because the actions taken when two or more accumulators are inoperable are unchanged. Adding this ACTION is consistent with the ITS convention of directing entry into LCO 3.0.3 when multiple ACTIONS are presented in the ITS, and entry into these multiple ACTIONS could result in a loss of safety function. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.4 CTS 4.5.1.b requires each affected accumulator be demonstrated OPERABLE within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase that is not the result of addition from the refueling water storage tank (RWST) of > 1% of tank volume by verifying the boron concentration of the accumulator solution. ITS SR 3.5.1.4 requires verifying boron concentration once within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase that is not the result of addition from the RWST of 13 ft3. This changes CTS by changing the parameter value of solution volume increase of >

1% of tank volume to solution volume increase of 13 ft3.

This change is acceptable because a solution volume increase of 1% of tank volume correlates to a solution volume increase of 13 ft3. This change is designated as administrative because it does not result in any technical changes to the CTS., Volume 10, Rev. 0, Page 9 of 164, Volume 10, Rev. 0, Page 9 of 164

DISCUSSION OF CHANGES ITS 3.5.1, ACCUMULATORS CNP Units 1 and 2 Page 2 of 2 MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.5.1 Action b requires an accumulator inoperable for reasons other than boron concentration not within limits be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. ITS 3.5.1 ACTION B specifies a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under the same condition. This changes the CTS by relaxing the Completion Time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The purpose of CTS 3.5.1 Action b is to provide the appropriate compensatory actions for one accumulator inoperable for reasons other than boron concentration not within limits. The current Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is an insufficient amount of time to correct accumulator mechanical problems or restore parameters to within limits. This change is acceptable because an evaluation was performed to assess the risk of the proposed accumulator Completion Time extension. The risk evaluation was performed in accordance with RG 1.174 and RG 1.177 and approved by the staff and documented in WCAP-15049-A, Rev. 1, April 1999. I&M has reviewed WCAP-15049, Rev. 1 and the CNP PRA, and has determined that the WCAP-15049 analysis is applicable to CNP and is consistent and bounding with respect to the CNP PRA model. In addition, the extended allowed outage time has no impact on the safety analyses. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits in the ITS than was allowed in the CTS., Volume 10, Rev. 0, Page 10 of 164, Volume 10, Rev. 0, Page 10 of 164

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 11 of 164, Volume 10, Rev. 0, Page 11 of 164

, Volume 10, Rev. 0, Page 12 of 164, Volume 10, Rev. 0, Page 12 of 164

, Volume 10, Rev. 0, Page 13 of 164, Volume 10, Rev. 0, Page 13 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1, ACCUMULATORS CNP Units 1 and 2 Page 1 of 1

1. The brackets are removed and the proper plant specific information/value is provided., Volume 10, Rev. 0, Page 14 of 164, Volume 10, Rev. 0, Page 14 of 164

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 15 of 164, Volume 10, Rev. 0, Page 15 of 164

, Volume 10, Rev. 0, Page 16 of 164, Volume 10, Rev. 0, Page 16 of 164

B 3.5.1 Insert Page B 3.5.1-1 INSERT 1 Reactor Coolant System (RCS), contributing to the filling of the INSERT 1A through the beginning of the reflood phase during a large break 1

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B 3.5.1 Insert Page B 3.5.1-5 INSERT 6 time the unit is exposed INSERT 7 The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed to restore an inoperable accumulator to OPERABLE status is justified in WCAP-15049-A, Rev. 1 (Ref. 5).

INSERT 8 or other specified condition 4

TSTF-370 5

3 1, Volume 10, Rev. 0, Page 24 of 164, Volume 10, Rev. 0, Page 24 of 164

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B 3.5.1 Insert Page B 3.5.1-7 INSERT 9 3.

WCAP-15049-A, Rev. 1, April 1999.

TSTF-370 "Risk-Informed Evaluation of an Extension to Accumulator Completion Times,"

1, Volume 10, Rev. 0, Page 27 of 164, Volume 10, Rev. 0, Page 27 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.1 BASES, ACCUMULATORS CNP Units 1 and 2 Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that 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. Typographical/grammatical error corrected.

4. The ISTS ACTION B.1 Bases state that the Completion Time minimizes the potential for exposure of the plant to a LOCA under these conditions. In actuality, the Completion Time minimizes the time the unit is exposed to a LOCA under these conditions, not the potential for exposure. Therefore, the ISTS is revised to more accurately reflect the role of the Completion Time.

5. Changes are made to be consistent with the Specification.

6. ISTS SR 3.5.1.5 Bases state that verifying that power is removed from each accumulator isolation valve operator ensures that an active failure could not result in the "undetected" closure of an accumulator motor operated isolation valve. The word undetected was not included in the ITS because verification that power is removed only ensures that the valve does not have power. The requirements of ITS SR 3.5.1.1 and other administrative controls help to ensure that a valve closure does not remain undetected.

7. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI-03, Section 5.1.3., Volume 10, Rev. 0, Page 28 of 164, Volume 10, Rev. 0, Page 28 of 164

Specific No Significant Hazards Considerations (NSHCs), Volume 10, Rev. 0, Page 29 of 164, Volume 10, Rev. 0, Page 29 of 164

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.1, ACCUMULATORS CNP Units 1 and 2 Page 1 of 1 There are no specific NSHC discussions for this Specification., Volume 10, Rev. 0, Page 30 of 164, Volume 10, Rev. 0, Page 30 of 164

ATTACHMENT 2 ITS 3.5.2, ECCS - OPERATING, Volume 10, Rev. 0, Page 31 of 164, Volume 10, Rev. 0, Page 31 of 164

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 10, Rev. 0, Page 32 of 164, Volume 10, Rev. 0, Page 32 of 164

ITS 3.5.2 ITS Page 1 of 8 A.1 LCO 3.5.2 LA.1 or more L.1 ACTION A ACTION B Add proposed Required Action B.1 M.1 L.2 Add proposed ACTION C L.1, Volume 10, Rev. 0, Page 33 of 164, Volume 10, Rev. 0, Page 33 of 164

ITS 3.5.2 ITS Page 2 of 8 A.1 SR 3.5.2.1 LA.2 SR 3.5.2.2 LA.2 LA.3, Volume 10, Rev. 0, Page 34 of 164, Volume 10, Rev. 0, Page 34 of 164

ITS 3.5.2 ITS Page 3 of 8 A.1 actuation See ITS 3.4.14 SR 3.5.2.7 24 L.3 L.3 L.4 SR 3.5.2.4 SR 3.5.2.5 LA.4 LA.1 SR 3.5.2.3 L.5 SR 3.5.2.6 ECCS LA.1 LA.4 that is not locked, sealed, or otherwise secured in position L.6 24 actual or actuation ECCS LA.1 LA.1 L.6 actual or test, Volume 10, Rev. 0, Page 35 of 164, Volume 10, Rev. 0, Page 35 of 164

ITS 3.5.2 ITS Page 4 of 8 A.1 SR 3.5.2.6 LA.5 L.5 24 L.3, Volume 10, Rev. 0, Page 36 of 164, Volume 10, Rev. 0, Page 36 of 164

ITS 3.5.2 ITS Page 5 of 8 A.1 LA.1 or more L.1 Add proposed Required Action B.1 A.3 L.2 A.2 Add proposed ACTION C LCO 3.5.2 ACTION A ACTION B ACTION D M.1 L.1, Volume 10, Rev. 0, Page 37 of 164, Volume 10, Rev. 0, Page 37 of 164

ITS 3.5.2 ITS Page 6 of 8 A.1 SR 3.5.2.1 LA.2 SR 3.5.2.2 LA.2 LA.3, Volume 10, Rev. 0, Page 38 of 164, Volume 10, Rev. 0, Page 38 of 164

ITS 3.5.2 ITS Page 7 of 8 A.1 See ITS 3.4.14 SR 3.5.2.7 24 SR 3.5.2.4 SR 3.5.2.5 LA.1 SR 3.5.2.3 L.5 SR 3.5.2.6 ECCS LA.4 actuation L.3 actuation ECCS that is not locked, sealed, or otherwise secured in position L.6 L.6 actual or test 24 L.4 L.3 actual or LA.1 LA.1 LA.4 LA.1, Volume 10, Rev. 0, Page 39 of 164, Volume 10, Rev. 0, Page 39 of 164

ITS 3.5.2 ITS Page 8 of 8 A.1 SR 3.5.2.6 LA.5 L.5 24 L.3, Volume 10, Rev. 0, Page 40 of 164, Volume 10, Rev. 0, Page 40 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 1 of 8 ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

A.2 (Unit 2 only) CTS 3.5.2 Action b requires, with a safety injection cross tie valve closed, either restoring the cross tie valve to the open position or reducing core power to < 3304 MWt within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Unit 2 ITS 3.5.2 ACTION D does not state the requirement to restore a closed safety injection cross tie valve to the open position, but includes the other compensatory Required Action to reduce power within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This changes the Unit 2 CTS by not explicitly stating the requirement to restore a closed safety injection cross tie valve to the open position.

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

A.3 (Unit 2 only) CTS 3.5.2 Action b states "Specification 3.0.4 does not apply." CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted." Unit 2 ITS 3.5.2 ACTION D does not contain the exception to ITS LCO 3.0.4, since ITS LCO 3.0.4 states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability may be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This changes the Unit 2 CTS by deleting an allowance since it is incorporated into ITS LCO 3.0.4.

This change is considered acceptable because ITS LCO 3.0.4 has been changed such that the CTS allowance is not required in order to retain the same CTS requirement. Unit 2 ITS 3.5.2 ACTION D allows continued operation for an unlimited period of time, which together with ITS LCO 3.0.4 results in the same technical requirements as the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.5.2 Action a requires that when one inoperable ECCS subsystem is not restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the unit must be in HOT, Volume 10, Rev. 0, Page 41 of 164, Volume 10, Rev. 0, Page 41 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 2 of 8 SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In addition to requiring the unit to be in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (ITS 3.5.2 Required Action B.2) if the ECCS is not restored within the allowed Completion Time, ITS 3.5.2 Required Action B.1 also requires the unit to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This changes the CTS by requiring entry into MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when a shutdown is required.

This change is acceptable because the requirement to place the unit in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is based on operating experience and the need to reach the required conditions from full power in an orderly manner and without challenging unit systems. This change is designated as more restrictive because it imposes a time requirement on when the unit must be in MODE 3.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.5.2 states that two independent ECCS subsystems shall be OPERABLE and contains a description of what constitutes an OPERABLE subsystem. CTS 4.5.2.e.2 and 4.5.2.f also list the pumps that are included in an OPERABLE subsystem and are required to be tested. ITS 3.5.2 requires two ECCS trains to be OPERABLE, but the details of what constitutes an OPERABLE train are moved to the Bases. ITS SR 3.5.2.3 and SR 3.5.2.5 also do not list the pumps that comprise an ECCS train since this information has been moved to the Bases, but require only that each ECCS pump be tested.

This changes the CTS by moving the details of what constitutes an OPERABLE subsystem to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for two ECCS trains to be OPERABLE, to verify each ECCS pump starts on an actual or simulated actuation signal, and to verify each ECCS pump develops acceptable head. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.2 (Type 2 - Removing Descriptions of System Operation) CTS 4.5.2.a, which requires verification of the position of certain ECCS valves, includes a footnote (footnote *) that states that positions of certain ECCS valves must be changed during the switchover from injection to recirculation flow following a LOCA. ITS SR 3.5.2.1, which requires the same valve position verification, does not include, Volume 10, Rev. 0, Page 42 of 164, Volume 10, Rev. 0, Page 42 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 3 of 8 this extra information. This changes the CTS by removing the description that certain valves must change position to the UFSAR.

The removal of these details, which are related to system operation, 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 verify the valves are secured in the listed position. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Changes to the UFSAR are controlled by 10 CFR 50.59 or 10 CFR 50.71(e), which ensures that any changes to the UFSAR are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to system operation is being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting Problems) CTS 4.5.2.c requires a visual inspection for loose debris in containment prior to establishing containment integrity and within affected areas of the containment at the completion of each containment entry when containment integrity is established. The ITS does not include this requirement. This changes the CTS by moving this requirement to the Technical Requirements Manual (TRM).

The removal of these details for performing a Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.5.2.7 still retains the requirement for an inspection of the containment sump for debris every 24 months. The purpose of CTS 4.5.2.c is to ensure that following a containment entry for maintenance or inspection, any debris is removed that could clog the containment sump following a LOCA. This is a good housekeeping practice that should be part of any containment entry and is a detail not necessary to be included in the ITS 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 Technical Requirements Manual (TRM). Any changes to the TRM are made under 10 CFR 50.59, which ensures changes to the TRM are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to meeting a TS requirement is being removed from the Technical Specifications.

LA.4 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.5.2.e.1 and 4.5.2.e.2 require verification of the automatic actuation of ECCS components on a "Safety Injection" signal. ITS SR 3.5.2.4 and SR 3.5.2.5 do not state the specific type of signal, but only specify an "actuation" signal. This changes CTS by moving the actual actuation signal 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 to, Volume 10, Rev. 0, Page 43 of 164, Volume 10, Rev. 0, Page 43 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 4 of 8 verify that appropriate equipment actuates upon receipt of an actuation signal.

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

LA.5 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.5.2.g.2, which requires verification of the position of certain ECCS throttle valves, includes information concerning the flow path they throttle (i.e., boron injection or safety injection). ITS SR 3.5.2.6, which requires the same valve position verification, does not include this extra information. This changes the CTS by moving the flow path description to the UFSAR.

The removal of these details, which are related to system design and system description, 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 verify the valves are secured in the listed position, and the specific valve number is still listed in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR.

Changes to the UFSAR are controlled by 10 CFR 50.59 or 10 CFR 50.71(e),

which ensure that any changes to the UFSAR are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to system design and system description is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.5.2 Action a states that when one ECCS train is inoperable, it must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ITS 3.5.2 ACTION A states that when one or more trains are inoperable (for reasons other than Condition D - Unit 2 only), restore the trains to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ITS 3.5.2 ACTION C states that with less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available (for reasons other than Condition D - Unit 2 only), enter LCO 3.0.3 immediately. This changes the CTS by allowing combinations of equipment from both trains to be credited as meeting the ECCS safety function provided 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available. For example, under the CTS, an inoperable safety injection pump in one train and an inoperable charging pump in the other train would require a CTS 3.0.3 entry.

Under the ITS, the same condition would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before requiring a shutdown because the remaining OPERABLE safety injection pump and charging pump are capable of producing the flow equivalent to a single OPERABLE train.

The purpose of CTS 3.5.2 Action a is to limit the period of time the plant can operate without redundant ECCS trains. This change is acceptable because the, Volume 10, Rev. 0, Page 44 of 164, Volume 10, Rev. 0, Page 44 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 5 of 8 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. ITS 3.5.2 ACTIONS A and C continue to require ECCS components equivalent to a complete ECCS train, and limit the time only one equivalent train is OPERABLE to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The ECCS can still perform its safety function, assuming no single failure occurs. 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 8 - Deletion of Reporting Requirements) CTS 3.5.2 Action b (Unit 1) and CTS 3.5.2 Action c (Unit 2) require that a Special Report be prepared and submitted to the NRC within 90 days following an ECCS actuation that results in water being injected into the Reactor Coolant System. The report is to include the description of the circumstances of the event and the total accumulated actuation cycles to date. ITS 3.5.2 does not include this requirement.

The purpose of CTS 3.5.2 Action b (Unit 1) and CTS 3.5.2 Action c (Unit 2) is to provide information about the event to the NRC. This change is acceptable because the regulations provide adequate reporting requirements, and the reports do not affect continued plant operation. A Licensee Event Report is required to be submitted by 10 CFR 50.73(a)(2)(iv) describing any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF). Therefore, a report to the NRC is still required. However, 10 CFR 50.73 does not require that the report include the total accumulated actuation cycles to date. ITS 5.5.4, "Component Cyclic or Transient Limits,"

requires that controls are in place to track the cyclic and transient occurrences to ensure that components are maintained within the design limits. 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 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.5.2.d.2 requires a visual inspection of the containment sump and verifying subsystem suction inlets are not restricted by debris and the sump components show no evidence of structural distress or abnormal corrosion every 18 months. CTS 4.5.2.e.1 requires a verification that each ECCS automatic valve in the flow path actuates to its correct position on a Safety Injection signal every 18 months. CTS 4.5.2.e.2 requires a verification that each ECCS pump starts on a Safety Injection signal every 18 months. CTS 4.5.2.g.2 requires a verification that the mechanical stops for certain boron injection and safety injection throttle valves are in the correct position every 18 months. ITS SR 3.5.2.7, SR 3.5.2.4, SR 3.5.2.5, and SR 3.5.2.6, respectively, require performance of similar tests 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)., Volume 10, Rev. 0, Page 45 of 164, Volume 10, Rev. 0, Page 45 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 6 of 8 The purpose of CTS 4.5.2.d.2 is to ensure the containment sump condition does not prevent the ECCS pumps from performing their required function. The purpose of CTS 4.5.2.e.1 and 4.5.2.e.2 is to ensure that the ECCS automatic valves in the flow path and pumps function properly on receipt of an automatic actuation signal. The purpose of CTS 4.5.2.g.2 is to ensure the throttle valves are in their correct position to ensure proper flow during an accident. These changes were 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.

For CTS 4.5.2.d.2, while several buckets of dirt and debris were removed from the sump locations during the 1995, 1996, and 1997 sump inspections performed to meet the CTS 4.5.2.d.2 requirement, there did not appear to be any substantial loss of capability and these discoveries do not appear to be the result of time elapsed between inspections. Subsequent to these inspections, a new plant procedure was issued to provide containment cleanliness requirements with respect to loose debris. Also, CTS 4.5.2.c, which requires a visual inspection for loose debris in containment prior to establishing containment integrity and within affected areas of the containment at the completion of each containment entry when containment integrity is required, is being maintained in the Technical Requirements Manual. This requirement, as well as ITS SR 3.6.14.1 and SR 3.6.14.2, which require visual inspections for debris of the refueling canal drains, will assist in ensuring the containment sumps remain free of debris that could affect ECCS OPERABILITY.

For CTS 4.5.2.e.1 and 4.5.2.e.2, extending the Surveillance Frequency for the ECCS automatic valves and pump tests is acceptable because the automatic valves are cycled and the pumps operated, during the operating cycle, in accordance with the Inservice Testing (IST) Program, or justifications exist to document less frequent testing. 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.

For CTS 4.5.2.g.2, extending the Surveillance Frequency to verify that mechanical stops for certain boron injection and safety injection throttle valves are in the correct position is acceptable because the stops are mechanical devices and simple devices that require direct operator action to move. The stops are only adjusted by procedure after testing to confirm proper operation.

There are no time-based events that would result in the change of the mechanical stops. Based on the device simplicity and component reliability, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrates that there are no failures that would invalidate this conclusion., Volume 10, Rev. 0, Page 46 of 164, Volume 10, Rev. 0, Page 46 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 7 of 8 For each of these Surveillances, 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 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.5.2.e.1 requires verification that each ECCS automatic valve actuates to its correct position. ITS SR 3.5.2.4 requires verification that each ECCS automatic valve in the flow path "that is not locked, sealed, or otherwise secured in position" actuates to the correct position. This changes the CTS by excluding those ECCS automatic valves that are locked, sealed, or otherwise secured in position from the verification.

The purpose of CTS 4.5.2.e.1 is to provide assurance that if an event occurred requiring the ECCS valves to be in their correct position, those requiring automatic actuation would actuate to their correct position. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Those automatic valves that are locked, sealed, or otherwise secured in position are not required to actuate on an ECCS actuation signal in order to perform their safety function because they are already in the required position. Testing such valves would not provide any additional assurance of OPERABILITY. Valves that are required to actuate will continue to be tested. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.5 (Category 5 - Deletion of Surveillance Requirement) CTS 4.5.2.g.1 and 4.5.2.h describe tests that must be performed following repositioning of valves, maintenance, or modification to the ECCS. The ITS does not include these testing requirements. This changes the CTS by deleting a conditional Surveillance Requirement.

The purpose of 4.5.2.g.1 and 4.5.2.h is to verify OPERABILITY of ECCS subsystems following repositioning or maintenance on a valve and following completion of modifications to the ECCS subsystems that alter subsystem flow characteristics. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and required under ITS SR 3.0.1. The OPERABILITY requirements for the ECCS trains are described in the Bases for ITS 3.5.2. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B is required under the unit operating license. As a result, post-, Volume 10, Rev. 0, Page 47 of 164, Volume 10, Rev. 0, Page 47 of 164

DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 8 of 8 maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.6 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria) CTS 4.5.2.e.1 and 4.5.2.e.2 require verification of the automatic actuation of ECCS components on a "Safety Injection" signal. ITS SR 3.5.2.4 and SR 3.5.2.5 do not state the specific type of signal, but only specify that the signal may be from either an actual or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.5.2.e.1 and 4.5.2.e.2 is to ensure that the ECCS components operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment can not discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS., Volume 10, Rev. 0, Page 48 of 164, Volume 10, Rev. 0, Page 48 of 164

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JUSTIFICATION FOR DEVIATIONS ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 1 of 1

1. ISTS SR 3.4.14.1 is not normally performed in MODE 3 at CNP, and it cannot currently be performed in < 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Therefore, the Note 1 allowance is not needed and has been deleted. The CNP LTOP system enable temperatures are 266°F for Unit 1 and 299°F for Unit 2. These temperatures are outside of the ECCS Applicability of MODES 1 through 3. Note 2 provides an exception for ECCS pumps inoperable pursuant to LTOP controls. Therefore, Note 2 is not needed and has been removed.

2. A new ACTION (ACTION D) has been added, for Unit 2 only, to be consistent with the current licensing basis. The Unit 2 small break LOCA analysis assumes the Safety Injection System cross tie valves are open, and if not, power must be restricted to < 3304 MWt. In addition, Unit 2 Conditions A and C have been modified to reflect the addition of ACTION D.

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

4. ISTS SR 3.5.2.3, a bracketed Surveillance Requirement, has not been included in the CNP ITS. This is consistent with current licensing basis. In addition, a review of plant records indicate that water hammers in the ECCS trains are not a concern at CNP. The remaining SRs have been renumbered due to this deletion., Volume 10, Rev. 0, Page 55 of 164, Volume 10, Rev. 0, Page 55 of 164

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B 3.5.2 Insert Page B 3.5.2-8 INSERT 12A This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves.

INSERT 12B Verifying that each ECCS pump's developed head at the flow test point is greater than or equal to the required developed head ensures that ECCS pump performance has not degraded to an unacceptable level during the cycle. Flow and differential head are normal tests of ECCS pump performance required by the ASME OM Code (Ref. 10).

Since the ECCS pumps cannot be tested with flow through the normal ECCS flow paths, they are tested on recirculation flow (RHR and SI pumps) or normal charging flow path (centrifugal charging pumps). This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

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B 3.5.2 Insert Page B 3.5.2-10 INSERT 18 10.

ASME, Operations and Maintenance Standards and Guides (OM Codes).

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JUSTIFICATION FOR DEVIATIONS ITS 3.5.2 BASES, ECCS - OPERATING CNP Units 1 and 2 Page 1 of 1

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

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that 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 Specification. The following requirements are renumbered or revised, where applicable, to reflect the changes.

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

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

5. Editorial change made for consistency with similar phrases in other ITS Bases.

6. Statements regarding specific accidents representing the design basis of ECCS pumps have been corrected. The ECCS pumps design characteristics are inputs to the accident analysis, not outputs.

7. The listed LCOs concern the shutdown cooling function of the RHR System, not the ECCS function. The Applicability Section has adequately described why ECCS is not needed in MODES 5 and 6, and it is not necessary to describe why normal shutdown cooling is required. Therefore, this inappropriate information has been deleted.

8. The first sentence of this Bases paragraph describes how a single component can result in the inoperability of both ECCS trains. This description is adequately covered in the LCO Section (in the description that each flow path must maintain its designed independence) and is not appropriate for the Bases of this ACTION (one or more ECCS trains inoperable but 100% capability maintained). In addition, the second and third sentences are covered by the Bases of ACTION C.1, and, consistent with the content of the ISTS Bases for many other ACTIONS, is not necessary to be included in the Bases for this ACTION.

9. Change made to be consistent with the actual Specification.

10. The statement that the instrumentation is tested as part of the ESF Actuation System Testing and that equipment performance is monitored as part of the Inservice Testing Program is not necessary. This cross reference type information is included in the appropriate Specifications and is not needed to be referenced in this SR Bases.

11. Changes are made to be consistent with similar statements in the Bases (e.g.,

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DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.2, ECCS - OPERATING CNP Units 1 and 2 Page 1 of 1 There are no specific NSHC discussions for this Specification., Volume 10, Rev. 0, Page 78 of 164, Volume 10, Rev. 0, Page 78 of 164

ATTACHMENT 3 ITS 3.5.3, ECCS - SHUTDOWN, Volume 10, Rev. 0, Page 79 of 164, Volume 10, Rev. 0, Page 79 of 164

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 10, Rev. 0, Page 80 of 164, Volume 10, Rev. 0, Page 80 of 164

ITS 3.5.3 ITS Page 1 of 4 A.1 LA.1 LCO 3.5.3 LA.1 See ITS 3.4.12 See ITS 3.4.12 See ITS 3.4.12 L.2 ACTION C 24 L.1 centrifugal charging ACTION A M.1 RHR LA.1 ACTION B, Volume 10, Rev. 0, Page 81 of 164, Volume 10, Rev. 0, Page 81 of 164

ITS 3.5.3 ITS Page 2 of 4 A.1 SR 3.5.2.2 (as modified by the Note),

SR 3.5.2.3, SR 3.5.2.6, and SR 3.5.2.7 A.2 SR 3.5.3.1 See ITS 3.4.12, Volume 10, Rev. 0, Page 82 of 164, Volume 10, Rev. 0, Page 82 of 164

ITS 3.5.3 ITS Page 3 of 4 A.1 LCO 3.5.3 LA.1 See ITS 3.4.12 ACTION C 24 L.1 centrifugal charging ACTION B LA.1 ACTION A M.1 RHR LA.1 See ITS 3.4.12 See ITS 3.4.12 L.2, Volume 10, Rev. 0, Page 83 of 164, Volume 10, Rev. 0, Page 83 of 164

ITS 3.5.3 ITS Page 4 of 4 A.1 224 SR 3.5.2.2 (as modified by the Note),

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DISCUSSION OF CHANGES ITS 3.5.3, ECCS - SHUTDOWN CNP Units 1 and 2 Page 1 of 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 4.5.3.1 states that the ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2. ITS SR 3.5.3.1 states the specific Surveillances of ITS 3.5.2 that must be performed.

This change is acceptable because the change is editorial. The Surveillances listed in ITS SR 3.5.3.1 are those that are considered applicable under the CTS. All ITS 3.5.2 Surveillances are included in SR 3.5.3.1 except those that are not applicable in MODE 4. ITS SR 3.5.2.1 verifies certain ECCS valves, whose alignment could render both ECCS trains inoperable, are secured in the correct position. It is excluded since only one ECCS train is required in MODE 4. SRs 3.5.2.4 and 3.5.2.5 are excluded since the automatic starting of ECCS is not required in MODE 4. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.5.3 Action b requires that when the required RHR subsystem is inoperable, the RHR subsystem must be restored to OPERABLE status or the RCS Tavg must be maintained < 350°F by use of alternate heat removal methods.

The CTS does not provide any finite start time or completion time to perform the Action. ITS 3.5.3 ACTION A requires the immediate initiation of action to restore the required RHR train to OPERABLE status. This changes the CTS by specifically stating that action to restore the RHR train to OPERABLE status must be initiated immediately, and does not allow alternate decay heat methods to be used.

The purpose of CTS Action b is to provide compensatory measures for when the required RHR train is inoperable. While the CTS Action compensates for the decay heat removal aspect of the inoperable RHR train, it does not address the ECCS function of the RHR train. Therefore, this new ACTION is acceptable because it ensures that action is immediately initiated to restore the RHR train to OPERABLE status, which compensates for both functions that the RHR train performs. This change is designated as more restrictive because it provides a finite start time for the action and it ensures that action is taken to restore the ECCS function of the RHR train to OPERABLE status., Volume 10, Rev. 0, Page 85 of 164, Volume 10, Rev. 0, Page 85 of 164

DISCUSSION OF CHANGES ITS 3.5.3, ECCS - SHUTDOWN CNP Units 1 and 2 Page 2 of 3 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.5.3 states that an ECCS subsystem shall be OPERABLE and contains a description of what constitutes an OPERABLE subsystem. ITS 3.5.3 requires an ECCS train be OPERABLE, but the details of what constitutes an OPERABLE train are moved to the Bases. CTS 3.5.3 Action a provides an action for when a ECCS subsystem is inoperable "because of the inoperability of either the centrifugal charging pump or the flow path from the refueling water storage tank" and CTS 3.5.3 Action b provides an action for when an ECCS subsystem is inoperable "because of the inoperability of either the residual heat removal heat exchanger or residual heat removal pump." ITS 3.5.3 ACTION A uses the term "residual heat removal (RHR) subsystem" and ITS 3.5.3 ACTION B uses the term "centrifugal charging subsystem" instead of stating the reasons the subsystem is inoperable, and the reasons listed in the CTS are moved to the Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.5.3 Action a allows 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to reach MODE 5 when a centrifugal charging pump or its flow path from the refueling water storage tank is inoperable and is not restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery. ITS 3.5.3 ACTION C allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to reach MODE 5. This changes the CTS by extending the Completion Time from 20 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the centrifugal charging subsystem is not restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery.

The purpose of CTS 3.5.3 is to ensure the unit is capable of being cooled down by whatever means available when no high head ECCS subsystem is OPERABLE. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the capacity and capability of remaining features, a reasonable time for repairs or, Volume 10, Rev. 0, Page 86 of 164, Volume 10, Rev. 0, Page 86 of 164

DISCUSSION OF CHANGES ITS 3.5.3, ECCS - SHUTDOWN CNP Units 1 and 2 Page 3 of 3 replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on operating experience to reach MODE 5 in an orderly manner and without challenging plant systems or operators. This is consistent with LCO 3.0.3, which allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to transition from MODE 4 to MODE 5.

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 8 - Deletion of Reporting Requirements) CTS 3.5.3 Action d requires that a Special Report be prepared and submitted to the NRC within 90 days following an ECCS actuation that results in water being injected into the Reactor Coolant System. The report is to include the description of the circumstances of the actuation and the total accumulated actuation cycles to date. ITS 3.5.3 does not include this requirement.

The purpose of CTS 3.5.3 Action d is to provide information about the event to the NRC. This change is acceptable because the regulations provide adequate reporting requirements, and the reports do not affect continued plant operation.

A Licensee Event Report is required to be submitted by 10 CFR 50.73(a)(2)(iv) describing any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF). Therefore, a report to the NRC is still required. However, 10 CFR 50.73 does not require that the report include the total accumulated actuation cycles to date. ITS 5.5.4, "Component Cyclic or Transient Limits," requires that controls are in place to track the cyclic and transient occurrences to ensure that components are maintained within the design limits. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS., Volume 10, Rev. 0, Page 87 of 164, Volume 10, Rev. 0, Page 87 of 164

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JUSTIFICATION FOR DEVIATIONS ITS 3.5.3, ECCS - SHUTDOWN CNP Units 1 and 2 Page 1 of 1

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

2. Changes have been made to SR 3.5.3.1 due to changes made to the SRs of ITS 3.5.2.

3. ISTS SR 3.5.3.1 has been modified to include a requirement for ITS SR 3.5.2.2 to be met. ITS SR 3.5.2.2, which verifies proper valve position, is required for the associated ECCS train to be OPERABLE. In conjunction with this addition, a Note to ISTS SR 3.5.3.1 has been added to allow ITS SR 3.5.2.2 to be met provided the valves "can be aligned to the correct position." The words in ITS SR 3.5.2.2 states that the valves must be "in the correct position." In the ITS, this means that the valves are in the accident position or can be automatically aligned to the accident position within the assumed time. Since the automatic feature of the valves is not required in MODE 4, the Note allows ITS SR 3.5.2.2 to be met as long as the valves can be manually realigned to their accident position. In addition, since the valves are not required to reposition automatically, the Note to the LCO is not necessary and has been deleted., Volume 10, Rev. 0, Page 92 of 164, Volume 10, Rev. 0, Page 92 of 164

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 93 of 164, Volume 10, Rev. 0, Page 93 of 164

, Volume 10, Rev. 0, Page 94 of 164, Volume 10, Rev. 0, Page 94 of 164

, Volume 10, Rev. 0, Page 95 of 164, Volume 10, Rev. 0, Page 95 of 164

, Volume 10, Rev. 0, Page 96 of 164, Volume 10, Rev. 0, Page 96 of 164

, Volume 10, Rev. 0, Page 97 of 164, Volume 10, Rev. 0, Page 97 of 164

, Volume 10, Rev. 0, Page 98 of 164, Volume 10, Rev. 0, Page 98 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.3 BASES, ECCS - SHUTDOWN CNP Units 1 and 2 Page 1 of 1

1. Editorial change made for consistency with similar phrases in other ITS Bases.

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

3. The listed LCOs concern the shutdown cooling function of the RHR System, not the ECCS function. The Applicability Section has adequately described why ECCS is not needed in MODES 5 and 6, and it is not necessary to describe why normal shutdown cooling is required. Therefore, this inappropriate information has been deleted.

4. The statement in ACTION A.1 Bases concerning how decay heat is removed is not appropriate for this Specification. ITS 3.5.3 concerns ECCS, not normal decay heat removal. Normal decay heat removal in MODE 4 is covered by ITS LCO 3.4.6. In addition, the actual ITS Required Action A.1 does not discuss normal decay heat removal requirements; it only requires the ECCS train to be restored. Therefore, the statement has been deleted.

5. The statement in ACTION B.1 Bases concerning why a centrifugal charging subsystem is inoperable has been deleted, since there may be other reasons the centrifugal charging subsystem is inoperable. The statement that the centrifugal charging subsystem is inoperable is sufficient and is consistent with the actual wording of ITS Required Action B.1.

6. The statement in ACTION B.1 Bases concerning initiation of actions to place the plant in MODE 5 has been deleted, since it is not consistent with the actual wording of ITS Required Action B.1. ITS Required Action B.1 does not address a plant cooldown to MODE 5; it only address restoring the subsystem to OPERABLE status.

ITS Required Action C.1 provides the requirements to place the unit in MODE 5.

7. Typographical/grammatical error corrected.

8. The Bases of the action to take when Required Action B.1 cannot be completed is changed to state that the unit must be brought to MODE 5. This is a more accurate description than the ISTS Bases statement that a controlled shutdown should be initiated since the LCO only applies during shutdown.

9. There are no References in the ITS 3.5.3 Bases, therefore, the statement referring to the ITS 3.5.2 Bases has been deleted and the word "none" has been added.

10. Changes are made to be consistent with changes made to the ISTS., Volume 10, Rev. 0, Page 99 of 164, Volume 10, Rev. 0, Page 99 of 164

Specific No Significant Hazards Considerations (NSHCs), Volume 10, Rev. 0, Page 100 of 164, Volume 10, Rev. 0, Page 100 of 164

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.3, ECCS - SHUTDOWN CNP Units 1 and 2 Page 1 of 1 There are no specific NSHC discussions for this Specification., Volume 10, Rev. 0, Page 101 of 164, Volume 10, Rev. 0, Page 101 of 164

ATTACHMENT 4 ITS 3.5.4, REFUELING WATER STORAGE TANK, Volume 10, Rev. 0, Page 102 of 164, Volume 10, Rev. 0, Page 102 of 164

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 10, Rev. 0, Page 103 of 164, Volume 10, Rev. 0, Page 103 of 164

ITS 3.5.4 ITS Page 1 of 2 A.1 Add proposed ACTION A L.1 for reasons other than concentration or temperature not within limits LCO 3.5.4 SR 3.5.4.2 SR 3.5.4.3 SR 3.5.4.1 ACTION B ACTION C SR 3.5.4.2 SR 3.5.4.3 SR 3.5.4.1, Volume 10, Rev. 0, Page 104 of 164, Volume 10, Rev. 0, Page 104 of 164

ITS 3.5.4 ITS Page 2 of 2 A.1 LCO 3.5.4 SR 3.5.4.2 SR 3.5.4.3 SR 3.5.4.1 ACTION B ACTION C SR 3.5.4.2 SR 3.5.4.3 SR 3.5.4.1 Add proposed ACTION A L.1 for reasons other than concentration or temperature not within limits, Volume 10, Rev. 0, Page 105 of 164, Volume 10, Rev. 0, Page 105 of 164

DISCUSSION OF CHANGES ITS 3.5.4, REFUELING WATER STORAGE TANK CNP Units 1 and 2 Page 1 of 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.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) The CTS 3.5.5 Action allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore an inoperable RWST. ITS 3.5.4 ACTION A allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the RWST to OPERABLE status if the inoperability is due to the RWST boron concentration or temperature not within limits. This changes the CTS by increasing the Completion Time for the specified Conditions from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The purpose of CTS 3.5.5 Action is to require rapid correction of conditions that affect both trains of ECCS. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. The primary function of the RWST is to provide large volumes of water to the RCS following a Loss of Coolant Accident.

This large volume of water continues to be available while in this Condition. As a result, the most important safety function of the RWST can still be provided.

Because of the volume of the RWST, changes to the boron concentration or temperature occur slowly, and consequently would not go far out of limit. If one of these parameters was out of limit, more than one hour would likely be required to restore the parameter. Given the remaining abilities of the RWST, requiring a plant shutdown after one hour is not warranted. This change is designated as, Volume 10, Rev. 0, Page 106 of 164, Volume 10, Rev. 0, Page 106 of 164

DISCUSSION OF CHANGES ITS 3.5.4, REFUELING WATER STORAGE TANK CNP Units 1 and 2 Page 2 of 2 less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS., Volume 10, Rev. 0, Page 107 of 164, Volume 10, Rev. 0, Page 107 of 164

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 108 of 164, Volume 10, Rev. 0, Page 108 of 164

, Volume 10, Rev. 0, Page 109 of 164, Volume 10, Rev. 0, Page 109 of 164

, Volume 10, Rev. 0, Page 110 of 164, Volume 10, Rev. 0, Page 110 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.4, REFUELING WATER STORAGE TANK CNP Units 1 and 2 Page 1 of 1

1. A bracketed Note for ISTS SR 3.5.4.1 associated with the effect of ambient air temperature on RWST temperature is not adopted. CNP RWST borated water is heated and not maintained at ambient temperature, and the current temperature band is not very large.

2. The brackets are removed and the proper plant specific information/value is provided., Volume 10, Rev. 0, Page 111 of 164, Volume 10, Rev. 0, Page 111 of 164

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 112 of 164, Volume 10, Rev. 0, Page 112 of 164

, Volume 10, Rev. 0, Page 113 of 164, Volume 10, Rev. 0, Page 113 of 164

, Volume 10, Rev. 0, Page 114 of 164, Volume 10, Rev. 0, Page 114 of 164

, Volume 10, Rev. 0, Page 115 of 164, Volume 10, Rev. 0, Page 115 of 164

, Volume 10, Rev. 0, Page 116 of 164, Volume 10, Rev. 0, Page 116 of 164

, Volume 10, Rev. 0, Page 117 of 164, Volume 10, Rev. 0, Page 117 of 164

, Volume 10, Rev. 0, Page 118 of 164, Volume 10, Rev. 0, Page 118 of 164

B 3.5.4 Insert Page B 3.5.4-4 INSERT 7A a conservative value with respect to INSERT 8 In MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is extremely low.

5 1, Volume 10, Rev. 0, Page 119 of 164, Volume 10, Rev. 0, Page 119 of 164

, Volume 10, Rev. 0, Page 120 of 164, Volume 10, Rev. 0, Page 120 of 164

, Volume 10, Rev. 0, Page 121 of 164, Volume 10, Rev. 0, Page 121 of 164

, Volume 10, Rev. 0, Page 122 of 164, Volume 10, Rev. 0, Page 122 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.4 BASES, REFUELING WATER STORAGE TANK CNP Units 1 and 2 Page 1 of 1

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

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

3. Changes are made to reflect those changes made to the Specification. Subsequent requirements are renumbered or revised, where applicable, to reflect the changes.

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

5. The listed LCOs concern the shutdown cooling function of the RHR System, not the ECCS function. The Applicability Section should describe why ECCS is not needed in MODES 5 and 6, similar to that in the ITS 3.5.2 Bases, and it is not necessary to describe why normal shutdown cooling is required. Therefore, this inappropriate information has been deleted and wording about MODES 5 and 6, consistent with the ITS 3.5.2 Bases, has been added.

6. Change made to be consistent with the actual Specification.

7. Typographical/grammatical error corrected.

8. The paragraph is not appropriate for this Specification. It is discussing how the ECCS and Containment Spray System pumps maintain minimum flow requirements.

A description concerning ECCS pump minimum flow requirements has been added to the ITS 3.5.2 Bases, Background Section (this issue is already discussed in the ITS 3.6.6 Bases)., Volume 10, Rev. 0, Page 123 of 164, Volume 10, Rev. 0, Page 123 of 164

Specific No Significant Hazards Considerations (NSHCs), Volume 10, Rev. 0, Page 124 of 164, Volume 10, Rev. 0, Page 124 of 164

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.4, REFUELING WATER STORAGE TANK CNP Units 1 and 2 Page 1 of 1 There are no specific NSHC discussions for this Specification., Volume 10, Rev. 0, Page 125 of 164, Volume 10, Rev. 0, Page 125 of 164

ATTACHMENT 5 ITS 3.5.5, SEAL INJECTION FLOW, Volume 10, Rev. 0, Page 126 of 164, Volume 10, Rev. 0, Page 126 of 164

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 10, Rev. 0, Page 127 of 164, Volume 10, Rev. 0, Page 127 of 164

ITS 3.5.5 ITS Page 1 of 4 A.1 See ITS 3.4.14 ACTION A ACTION B See ITS 3.4.13 See ITS 3.4.14 L.1 See ITS 3.4.13 SR 3.5.5.1 Note A.3 LA.1 A.2 MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> L.1 10 M.1 Seal line resistance not within, Volume 10, Rev. 0, Page 128 of 164, Volume 10, Rev. 0, Page 128 of 164

ITS 3.5.5 ITS Page 2 of 4 A.1 See ITS 3.4.13 See ITS 3.4.14 A.3 See ITS 3.4.13 M.2 Note to SR 3.5.5.1 LA.2 SR 3.5.5.1 LA.1 10 M.1 2138 2290 M.1, Volume 10, Rev. 0, Page 129 of 164, Volume 10, Rev. 0, Page 129 of 164

ITS 3.5.5 ITS Page 3 of 4 A.1 See ITS 3.4.13 LCO 3.5.5 See ITS 3.4.13 See ITS 3.4.14 L.1 SR 3.5.5.1 Note A.3 LA.1 L.1 MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ACTION A ACTION B See ITS 3.4.14 10 M.1 Seal line resistance not within A.2, Volume 10, Rev. 0, Page 130 of 164, Volume 10, Rev. 0, Page 130 of 164

ITS 3.5.5 ITS Page 4 of 4 A.1 See ITS 3.4.13 M.2 Note to SR 3.5.5.1 LA.2 SR 3.5.5.1 LA.1 A.3 See ITS 3.4.13 See ITS 3.4.14 10 M.1 2290 M.1, Volume 10, Rev. 0, Page 131 of 164, Volume 10, Rev. 0, Page 131 of 164

DISCUSSION OF CHANGES ITS 3.5.5, SEAL INJECTION FLOW CNP Units 1 and 2 Page 1 of 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 3.4.6.2 Action b provides the actions for when any Reactor Coolant System (RCS) leakage is greater than any one of the above limits, excluding PRESSURE BOUNDARY LEAKAGE. The Condition for ITS 3.5.5 ACTION A is specific as to which of the RCS leakage limits is not met, specifically, the seal injection flow resistance not within limits. This changes the CTS by replacing "Reactor Coolant System leakage greater than any one of the above limits, excluding PRESSURE BOUNDARY LEAKAGE" with "seal injection flow resistance not within limit."

The purpose of CTS 3.4.6.2 Action b is to provide a specific action to restore the RCS leakage to within the specified limits of CTS LCO 3.4.6.2. The RCS leakage limits for CTS LCO 3.4.6.2.a through CTS LCO 3.4.6.2.d are covered in ITS 3.4.13. The RCS leakage limit for CTS LCO 3.4.6.2.f is covered in ITS LCO 3.4.14. Changes to the CTS Actions are discussed in the Discussion of Changes for these Technical Specifications. ITS 3.5.5 only covers seal injection flow resistance (CTS LCO 3.4.6.2.e). Therefore, replacing the name "RCS leakage" with the explicit "seal injection flow resistance" limit does not change the action.

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

A.3 CTS 3.4.6.2.e Applicability Footnote

• states that Specification 3.4.6.2.e is applicable with average pressure within 20 psi "of the nominal full pressure value." CTS 4.4.6.2.1.c states that the seal line resistance shall be determined when the average pressurizer pressure is within 20 psi "of its nominal full pressure value." The ITS SR 3.5.5.1 Note states that the Surveillance is not required to be performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the pressurizer pressure stabilizes at

> 2075 psig and < 2095 psig (Unit 1) and > 2225 psig and < 2245 psig (Unit 2).

This changes the CTS by including the explicit pressure limits. Changes to the detail that the pressurizer pressure must be an average pressure are discussed in DOC LA.1 and changes to the pressure band are discussed in DOC M.1.

The purpose of CTS 3.4.6.2.e Applicability Footnote

• and CTS 4.4.6.2.1.c is to perform the test at the appropriate pressurizer pressure. The appropriate nominal range has been proposed. This change is acceptable because the proposed values are consistent with the current application of the requirements, as modified by DOC M.1. This change is designated as administrative because it does not result in technical changes to the CTS., Volume 10, Rev. 0, Page 132 of 164, Volume 10, Rev. 0, Page 132 of 164

DISCUSSION OF CHANGES ITS 3.5.5, SEAL INJECTION FLOW CNP Units 1 and 2 Page 2 of 4 MORE RESTRICTIVE CHANGES M.1 CTS 3.4.6.2.e Applicability Footnote

• states that Specification 3.4.6.2.e is applicable with average pressure within "20" psi of the nominal full pressure value. CTS 4.4.6.2.1.c states that the seal line resistance shall be determined when the average pressurizer pressure is within "20" psi of its nominal full pressure value. The ITS SR 3.5.5.1 Note states that the Surveillance is not required to be performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the pressurizer pressure stabilizes at

> 2075 psig and < 2095 psig (Unit 1) and > 2225 psig and < 2245 psig (Unit 2).

This changes the CTS by decreasing the pressure band from + 20 psi to + 10 psi. Other changes related to Footnote

• are described in DOC A.3. In addition, CTS 4.4.6.2.1.c provides a pressure constant, PSI, to be used in the calculation of seal line resistance. The values for this constant (two values for Unit 1 and one value for Unit 2), which are moved to the Bases as described in DOC LA.2, have been increased and results in a decrease in the calculated seal line resistance at any given charging pump pressure. This changes the CTS by increasing the pressure constant value, resulting in a decrease in the calculated seal line resistance flow.

The purpose of CTS 3.4.6.2.e and 4.4.6.2.1.c is to ensure seal line resistance is high enough to ensure the appropriate ECCS flows assumed in the LOCA analysis. This change effectively increases the seal line flow resistance limit due to the increase in the pressure constant. It also narrows the test pressure band that is required to be maintained. This change is based on the most recent seal line resistance calculation and is acceptable because it will slightly increase the overall ECCS borated water pumped into the RCS such that there would be an insignificant impact as a result. The change has been designated as more restrictive because it effectively increases the seal line flow resistance limit.

M.2 CTS 4.4.6.2.1.c states that the seal line resistance must be determined at least once per 31 days when the average pressurizer pressure is within 20 psi of its nominal full pressure value. CTS 4.4.6.2.1.c also states that the provisions of CTS 4.0.4 are not applicable for entry into MODES 3 and 4. ITS SR 3.5.5.1 requires verification that the seal injection flow resistance is > 0.227 ft/gpm2 and is modified by a Note that states the Surveillance is not required to be performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the pressurizer pressure stabilizes at the specified pressure band. This changes the CTS by explicitly specifying the time required to perform the Surveillance after entering the specified pressure band.

The purpose of CTS 4.4.6.2.1.c is to accurately determine the seal line injection flow resistance. 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 seal line injection flow resistance must be performed at stable pressurizer pressure conditions. The Note applies a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period after reaching the specified pressurizer pressure band 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., Volume 10, Rev. 0, Page 133 of 164, Volume 10, Rev. 0, Page 133 of 164

DISCUSSION OF CHANGES ITS 3.5.5, SEAL INJECTION FLOW CNP Units 1 and 2 Page 3 of 4 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.4.6.2.e Applicability Footnote

• states that Specification 3.4.6.2.e is applicable with "average" pressure within 20 psi of the nominal full pressure value. CTS 4.4.6.2.1.c states that the seal line resistance shall be determined when the "average" pressurizer pressure is within 20 psi of its nominal full pressure value. ITS SR 3.5.5.1 Note states that the Surveillance is not required to be performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the pressurizer pressure stabilizes at > 2075 psig and < 2095 psig (Unit 1) and > 2225 psig and

< 2245 psig (Unit 2). This changes the CTS by relocating the detail that the pressurizer pressure is an averaged value to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform the seal line injection flow resistance evaluation at a pressurizer pressure of > 2075 psig and < 2095 psig (Unit 1) and > 2225 psig and < 2245 psig (Unit 2). Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

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

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.4.6.2.1.c provides a detailed formula to determine the actual seal line resistance. ITS SR 3.5.5.1 does not include this detailed formula. This changes the CTS by relocating the detailed formula of how to determine seal line resistance to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the seal line resistance limit and the requirement to determine the actual seal line resistance is within the limit every 31 days. Also, this change is acceptable because these types of procedural details will be adequately controlled in 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., Volume 10, Rev. 0, Page 134 of 164, Volume 10, Rev. 0, Page 134 of 164

DISCUSSION OF CHANGES ITS 3.5.5, SEAL INJECTION FLOW CNP Units 1 and 2 Page 4 of 4 LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.4.6.2.e is applicable in MODES 1, 2, 3, and 4. If the requirement of the LCO (seal line resistance) is not met, CTS 3.4.6.2 Action b allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore the seal line resistance to within limit or be in HOT STANDBY (MODE 3) within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN (MODE 5) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.5.5 is applicable only in MODES 1, 2, and 3. If the requirement of ITS 3.5.5 is not met, ITS 3.5.5 ACTIONS A and B require similar Required Actions as the CTS. However, the requirement to be in MODE 5 is replaced with a requirement to be in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by deleting MODE 4 from the Applicability and making corresponding changes to the Action.

The purpose of CTS 3.4.6.2.e is to maintain proper ECCS injection flow in the event of an accident. 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.

Seal injection flow resistance is less critical in MODE 4 than in MODES 1, 2, and

3. Should an accident occur in MODE 4, it would be less severe due to the lower RCS pressure and decreased decay heat generation. Therefore, it is not necessary to limit seal injection flow in MODE 4 due to the lesser requirements of safety injection flow needed for long term cooling. Requiring the unit be in MODE 4, which is outside the Applicability of the Specification, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> corresponds with similar Completion Times in the ITS. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS., Volume 10, Rev. 0, Page 135 of 164, Volume 10, Rev. 0, Page 135 of 164

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 136 of 164, Volume 10, Rev. 0, Page 136 of 164

, Volume 10, Rev. 0, Page 137 of 164, Volume 10, Rev. 0, Page 137 of 164

, Volume 10, Rev. 0, Page 138 of 164, Volume 10, Rev. 0, Page 138 of 164

, Volume 10, Rev. 0, Page 139 of 164, Volume 10, Rev. 0, Page 139 of 164

, Volume 10, Rev. 0, Page 140 of 164, Volume 10, Rev. 0, Page 140 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.5, SEAL INJECTION FLOW CNP Units 1 and 2 Page 1 of 1

1. The brackets are removed and the proper plant specific information/value is 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. ISTS 3.5.5 Required Action A.1 requires the manual seal injection throttle valves to be adjusted to give a flow resistance within limit. This is essentially describing "how" to restore the LCO to within the required limit. In the ISTS, the manner in which the LCO limit is restored is normally relegated to the Bases. In this case, there may be other correct ways to restore the LCO limit without having to adjust a manual seal injection throttle valve. For example, the actual calculation that determined the seal injection flow resistance may be in error. Therefore, consistent with most other Required Actions that simply state to restore the variable to within limit, ISTS 3.5.5 Required Action A.1 has been changed to require restoration of the seal injection flow resistance to within limit. In addition, ISTS SR 3.5.5.1, the Surveillance that verifies the LCO limit is met, has also been changed to require verification that the seal injection flow resistance is within limit., Volume 10, Rev. 0, Page 141 of 164, Volume 10, Rev. 0, Page 141 of 164

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 142 of 164, Volume 10, Rev. 0, Page 142 of 164

, Volume 10, Rev. 0, Page 143 of 164, Volume 10, Rev. 0, Page 143 of 164

, Volume 10, Rev. 0, Page 144 of 164, Volume 10, Rev. 0, Page 144 of 164

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, Volume 10, Rev. 0, Page 146 of 164, Volume 10, Rev. 0, Page 146 of 164

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, Volume 10, Rev. 0, Page 148 of 164, Volume 10, Rev. 0, Page 148 of 164

JUSTIFICATION FOR DEVIATIONS ITS 3.5.5 BASES, SEAL INJECTION FLOW CNP Units 1 and 2 Page 1 of 1

1. Editorial change made for enhanced clarity or to be consistent with the ISTS Writers Guide.

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

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

4. Typographical/grammatical error corrected.

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

6. The detail in the ISTS SR 3.5.5.1 Bases, added in accordance with approved TSTF-337, specifying that the control valves in the flow path between the charging header and the RCS pressure sensing points must be in their post accident position during this Surveillance to correlate with the acceptance criteria has been deleted.

Seal line resistance (RSL) is calculated based on the equation in the CTS and is included in the ITS SR 3.5.5.1 Bases. The only measured variables in this equation are charging pump header pressure (PCHP) and total seal injection flow (Q). PCHP is measured downstream of the charging system flow control valves. Therefore, the indicated pressure drop and system resistance calculated will not reflect the pressure drop across the charging system flow control valves. Changes in PCHP that are as a result of changes in charging system control valve position will result in a corresponding change in Q. Therefore, the calculated RSL will not change outside of the accuracy of the measurement instrumentation. None of the components within the RSL calculation boundary are adjustable from the control room., Volume 10, Rev. 0, Page 149 of 164, Volume 10, Rev. 0, Page 149 of 164

Specific No Significant Hazards Considerations (NSHCs), Volume 10, Rev. 0, Page 150 of 164, Volume 10, Rev. 0, Page 150 of 164

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.5, SEAL INJECTION FLOW CNP Units 1 and 2 Page 1 of 1 There are no specific NSHC discussions for this Specification., Volume 10, Rev. 0, Page 151 of 164, Volume 10, Rev. 0, Page 151 of 164

ATTACHMENT 6 Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS, Volume 10, Rev. 0, Page 152 of 164, Volume 10, Rev. 0, Page 152 of 164

ISTS 3.5.6, BORON INJECTION TANK, Volume 10, Rev. 0, Page 153 of 164, Volume 10, Rev. 0, Page 153 of 164

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 154 of 164, Volume 10, Rev. 0, Page 154 of 164

, Volume 10, Rev. 0, Page 155 of 164, Volume 10, Rev. 0, Page 155 of 164

, Volume 10, Rev. 0, Page 156 of 164, Volume 10, Rev. 0, Page 156 of 164

JUSTIFICATION FOR DEVIATIONS ISTS 3.5.6, BORON INJECTION TANK CNP Units 1 and 2 Page 1 of 1

1. This Boron Injection Tank Specification is not included in the CNP Units 1 and 2 ITS.

The requirements for the Boron Injection Tank have been deleted from the CTS in License Amendments 158 (Unit 1) and 142 (Unit 2) dated November 20, 1991., Volume 10, Rev. 0, Page 157 of 164, Volume 10, Rev. 0, Page 157 of 164

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs), Volume 10, Rev. 0, Page 158 of 164, Volume 10, Rev. 0, Page 158 of 164

, Volume 10, Rev. 0, Page 159 of 164, Volume 10, Rev. 0, Page 159 of 164

, Volume 10, Rev. 0, Page 160 of 164, Volume 10, Rev. 0, Page 160 of 164

, Volume 10, Rev. 0, Page 161 of 164, Volume 10, Rev. 0, Page 161 of 164

, Volume 10, Rev. 0, Page 162 of 164, Volume 10, Rev. 0, Page 162 of 164

, Volume 10, Rev. 0, Page 163 of 164, Volume 10, Rev. 0, Page 163 of 164

JUSTIFICATION FOR DEVIATIONS ISTS 3.5.6 BASES, BORON INJECTION TANK CNP Units 1 and 2 Page 1 of 1

1. Changes are made to be consistent with changes made to the ISTS., Volume 10, Rev. 0, Page 164 of 164, Volume 10, Rev. 0, Page 164 of 164