Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 11, Rev 0, ITS Section 3.6 Containment Systems.
	ML041200376
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: ML041200376 (494)
	v • d • e

Attachment 1, Volume 11, Rev. 0, Page 1 of 494 VOLUME 11 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.6 CONTAINMENT SYSTEMS Revision 0 Attachment 1, Volume 11, Rev. 0, Page 1 of 494

Attachment 1, Volume 11, Rev. 0, Page 2 of 494 LIST OF ATTACHMENTS

1. ITS 3.6.1

2. ITS 3.6.2

3. ITS 3.6.3

4. ITS 3.6.4

5. ITS 3.6.5

6. ITS 3.6.6

7. ITS 3.6.7

8. ITS 3.6.8

9. ITS 3.6.9

10. ITS 3.6.10

11. ITS 3.6.11

12. ITS 3.6.12

13. ITS 3.6.13

14. ITS 3.6.14

15. Relocated/Deleted Current Technical Specifications (CTS)

16. Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 11, Rev. 0, Page 2 of 494

, Volume 11, Rev. 0, Page 3 of 494 ATTACHMENT 1 ITS 3.6.1, Containment , Volume 11, Rev. 0, Page 3 of 494

, Volume 11, Rev. 0, Page 4 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 4 of 494

Attachment 1, Volume 11, Rev. 0, Page 5 of 494 ITS 3.6.1 A.1 ITS OPERABILITY A.2 LCO 3.6.1 OPERABILITY A.2 ACTION A ACTION B OPERABILITY A.2 L.1 See ITS 3.6.3 L.1 L.2 A.3 See ITS 3.6.3 Page 1 of 10 Attachment 1, Volume 11, Rev. 0, Page 5 of 494

Attachment 1, Volume 11, Rev. 0, Page 6 of 494 ITS 3.6.1 A.1 ITS See ITS Chapter 1.0 LA.1 L.2 See ITS 3.6.2 SR 3.6.1.1 See ITS Chapter 1.0 Page 2 of 10 Attachment 1, Volume 11, Rev. 0, Page 6 of 494

Attachment 1, Volume 11, Rev. 0, Page 7 of 494 ITS 3.6.1 A.1 ITS LCO 3.6.1 A.2 See ITS 5.5 Add proposed ACTIONS A and B A.4 the Containment Leakage Rate Testing Program A.5 SR 3.6.1.1 See ITS 5.5 A.5 See ITS 5.5 A.5 See ITS 5.5 Page 3 of 10 Attachment 1, Volume 11, Rev. 0, Page 7 of 494

Attachment 1, Volume 11, Rev. 0, Page 8 of 494 ITS 3.6.1 A.1 ITS Page 4 of 10 Attachment 1, Volume 11, Rev. 0, Page 8 of 494

Attachment 1, Volume 11, Rev. 0, Page 9 of 494 ITS 3.6.1 A.1 ITS LCO 3.6.1 A.2 Add proposed ACTIONS A and B A.4 SR 3.6.1.1 the Containment Leakage Rate Testing Program A.5 Page 5 of 10 Attachment 1, Volume 11, Rev. 0, Page 9 of 494

Attachment 1, Volume 11, Rev. 0, Page 10 of 494 ITS 3.6.1 A.1 ITS OPERABILITY A.2 LCO 3.6.1 OPERABILITY A.2 ACTION A ACTION B OPERABILITY A.2 L.1 See ITS 3.6.3 L.1 L.2 A.3 See ITS 3.6.3 Page 6 of 10 Attachment 1, Volume 11, Rev. 0, Page 10 of 494

Attachment 1, Volume 11, Rev. 0, Page 11 of 494 ITS 3.6.1 A.1 ITS See ITS Chapter 1.0 LA.1 L.2 See ITS 3.6.2 SR 3.6.1.1 LA.1 See ITS Chapter 1.0 Page 7 of 10 Attachment 1, Volume 11, Rev. 0, Page 11 of 494

Attachment 1, Volume 11, Rev. 0, Page 12 of 494 ITS 3.6.1 A.1 ITS LCO 3.6.1 A.2 See ITS 5.5 Add proposed ACTIONS A and B A.4 the Containment Leakage Rate Testing Program A.5 SR 3.6.1.1 See ITS 5.5 A.5 See ITS 5.5 A.5 See ITS 5.5 Page 8 of 10 Attachment 1, Volume 11, Rev. 0, Page 12 of 494

Attachment 1, Volume 11, Rev. 0, Page 13 of 494 ITS 3.6.1 A.1 ITS Page 9 of 10 Attachment 1, Volume 11, Rev. 0, Page 13 of 494

Attachment 1, Volume 11, Rev. 0, Page 14 of 494 ITS 3.6.1 A.1 ITS LCO 3.6.1 A.2 Add proposed ACTIONS A and B A.4 SR 3.6.1.1 the Containment Leakage Rate Testing Program A.5 Page 10 of 10 Attachment 1, Volume 11, Rev. 0, Page 14 of 494

Attachment 1, Volume 11, Rev. 0, Page 15 of 494 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT 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 3.6.1.1 states "Primary CONTAINMENT INTEGRITY shall be maintained."

CTS 3.6.1.2 requires containment leakage rates be within specified parameters.

CTS 3.6.1.6 requires that the structural integrity of the containment be maintained within specified parameters. ITS 3.6.1 states "Containment shall be OPERABLE." This changes the CTS by deleting the specific CONTAINMENT INTEGRITY definition and all references to it, as well as combining the containment requirements of CTS 3.6.1.1, CTS 3.6.1.2, and CTS 3.6.1.6 into one LCO statement.

The purpose of CTS 3.6.1.1, CTS 3.6.1.2, and CTS 3.6.1.6 is to provide requirements pertaining for containment OPERABILITY. This portion of the change (combining the LCOs) is acceptable because moving these requirements to one LCO, ITS 3.6.1, centralizes the requirements. The purpose of CTS 1.8 is to clearly describe all aspects of CONTAINMENT INTEGRITY. The CTS 3/4.6.1 references to CONTAINMENT INTEGRITY have been deleted since the CTS definition of CONTAINMENT INTEGRITY in CTS 1.8 is incorporated into ITS 3.6.1, 3.6.2 and 3.6.3 and is no longer maintained as a separate definition in the ITS. ITS 3.6.1 requires that the containment shall be OPERABLE. The definition of OPERABLE and the subsequent ITS 3.6.1 LCO, ACTIONS, and Surveillance Requirements are sufficient to encompass the applicable requirements of the CTS definition. This change removes any confusion that may exist between the definition and the specific requirements of the LCO and is a presentation preference consistent with NUREG-1431, Rev. 2. Since all aspects of the CONTAINMENT INTEGRITY definition requirements, along with the remainder of the LCOs in the Containment Systems Primary Containment section (i.e., air locks and containment isolation valves), are maintained in subsequent Specifications of ITS, this change is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 4.6.1.1.b requires that Primary CONTAINMENT INTEGRITY shall be demonstrated by verifying that each containment air lock is in compliance with the requirements of Specification 3.6.1.3. The ITS does not include the reference to CTS 3.6.1.3 (which has changed to ITS 3.6.2). This changes the CTS by not including a reference to another LCO that is required in the same MODES.

The purpose of the CTS 4.6.1.1.b is to provide assurance that each containment air lock is performing its function in support of CONTAINMENT INTEGRITY.

This cross reference to another Specification is not necessary and this change is CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 15 of 494

Attachment 1, Volume 11, Rev. 0, Page 16 of 494 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT acceptable because ITS 3.6.2 provides assurance that containment air locks are OPERABLE without the reference in ITS 3.6.1. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.6.1.2 Action does not state what action to take if specific leakage rate limits are not met while in MODE 1, 2, 3, or 4; it only includes a requirement that the limits be restored prior to increasing Reactor Coolant System temperature above 200°F (i.e., MODE 4). CTS 3.6.1.6 Action does not state what action to take if the structural integrity limits are not met while in MODE 1, 2, 3, or 4; it only includes a requirement that the limits be restored prior to increasing Reactor Coolant System temperature above 200°F (i.e., MODE 4). Thus, entry into CTS 3.0.3 is required if CTS 3.6.1.2 or CTS 3.6.1.6 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 a shutdown 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 3.6.1 ACTION A requires that if the containment is inoperable, it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.6.1 ACTION B requires that if the Required Action and associated Completion Time are not met (i.e., the containment is not restored to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), the unit must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes 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 4.

The purpose of CTS 3.0.3 is to place the unit outside the MODE of Applicability within a reasonable amount of time in a controlled manner. CTS 3.6.1.2 and CTS 3.6.1.6 are silent on these actions, deferring to CTS 3.0.3 for the actions to accomplish this. This change is acceptable because the ACTIONS specified in ITS 3.6.1 adopt ISTS structure for placing the unit outside the MODE of Applicability without changing the time specified to enter MODE 3 and MODE 5.

In addition, deletion of the current Actions of CTS 3.6.1.2 and CTS 3.6.1.6 is acceptable, because CTS 3.0.4 (ITS 3.0.4) already precludes entering the MODE of Applicability when the LCO is not met. Therefore, it is not necessary to include these requirements as specific actions in ITS 3.6.1. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 4.6.1.2 and CTS 4.6.1.6 reference specific 10 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria. CTS 4.6.1.2 also states "The provisions of Specification 4.0.2 are not applicable." ITS SR 3.6.1.1 requires performance of visual examinations and leakage rate testing, except for containment air lock testing, in accordance with the Containment Leakage Rate Testing Program. This changes CTS by referencing the appropriate Containment Leakage Rate Testing Program.

The purpose of ITS 3.6.1 is to ensure that the structural integrity of the containment will be maintained comparable to the original design standards for the life of the facility. This change is acceptable because the appropriate 10 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria are retained in the Technical Specifications as part of ITS 5.5.14, "Containment Leakage Rate Testing Program." This change is designated as administrative because it does not result in technical changes to the CTS.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 16 of 494

Attachment 1, Volume 11, Rev. 0, Page 17 of 494 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 2 - Removing Descriptions of System Operation) CTS 1.8 states "CONTAINMENT INTEGRITY shall exist when: 1.8.1 All penetrations required to be closed during accident conditions are either: a. Capable of being closed by an OPERABLE containment automatic isolation valve system, or b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1; 1.8.2 All equipment hatches are closed and sealed; and (Unit 2 only) 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE." ITS 3.6.1 states "Containment shall be OPERABLE." This changes the CTS by moving the reference to penetration and equipment hatch requirements to the Bases. The change deleting the phrase "and sealed" in CTS 1.8.2 is addressed by DOC L.2.

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 for the containment to be OPERABLE and the relocated material describes aspects of OPERABILITY. The ITS also still retains the requirement to perform required visual inspections and leakage rate testing in accordance with the Containment Leakage Rate Testing Program in accordance with 10 CFR 50 Appendix J, Part B, which would provide verification that the equipment hatch is closed and the sealing mechanisms are 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 operation is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.1.1.a.2 requires the primary containment equipment hatches to be verified closed and sealed every 31 days. The ITS does not include this requirement. This changes the CTS by deleting the specific Surveillance Requirement to verify primary containment equipment hatches are closed. The deletion of the sealed requirement is addressed in DOC L.2.

CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 17 of 494

Attachment 1, Volume 11, Rev. 0, Page 18 of 494 DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT The purpose of CTS 4.6.1.1.a.2 is to help ensure primary CONTAINMENT INTEGRITY is maintained. However, the ITS still maintains the requirement for the Containment to be OPERABLE, and maintaining the hatches closed is part of this requirement (as described in the Bases). The ITS also continues to require the leakage rate testing in accordance with the Containment Leakage Rate Testing Program. This leakage testing would confirm that the equipment hatch is sealed, since if it was not sealed, then the measured leakage rate would be affected. In addition, opening of the equipment hatch is not a routine evolution, and it is strictly controlled by plant procedures. The appropriate procedure requires proper verification that the opened equipment hatch is resealed when the equipment hatch is closed. Therefore, this specific Surveillance Requirement is not necessary to be included in the ITS. 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 1.8 states "CONTAINMENT INTEGRITY shall exist when:1.8.2 All equipment hatches are closed and sealed." ITS 3.6.1 states that the Containment shall be OPERABLE. This changes the CTS by not including an explicit reference to sealing the equipment hatch. The change associated with moving the reference to the equipment hatch into the Bases is addressed by DOC LA.1.

The purpose of CTS 1.8.2 is to help provide assurance that the equipment hatch can perform its safety 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. The Containment Leakage Rate Testing Program requires testing be performed in accordance with 10 CFR 50 Appendix J, Part B, requiring the containment isolation valves, including the equipment hatch, to be OPERABLE, but there is no specific mention of sealing the equipment hatches. This change is designated 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 11, Rev. 0, Page 18 of 494

Attachment 1, Volume 11, Rev. 0, Page 19 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 19 of 494

, Volume 11, Rev. 0, Page 20 of 494 , Volume 11, Rev. 0, Page 20 of 494

Attachment 1, Volume 11, Rev. 0, Page 21 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.1, CONTAINMENT

1. The headings for ISTS 3.6.1 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation.

2. Typographical/grammatical error corrected.

3. This bracketed requirement regarding Containment Tendon Surveillance Program is deleted because it is not applicable to CNP. The CNP containment does not utilize containment tendons.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 21 of 494

Attachment 1, Volume 11, Rev. 0, Page 22 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 22 of 494

, Volume 11, Rev. 0, Page 23 of 494 , Volume 11, Rev. 0, Page 23 of 494

, Volume 11, Rev. 0, Page 24 of 494 , Volume 11, Rev. 0, Page 24 of 494

, Volume 11, Rev. 0, Page 25 of 494 , Volume 11, Rev. 0, Page 25 of 494

, Volume 11, Rev. 0, Page 26 of 494 , Volume 11, Rev. 0, Page 26 of 494

, Volume 11, Rev. 0, Page 27 of 494 , Volume 11, Rev. 0, Page 27 of 494

, Volume 11, Rev. 0, Page 28 of 494 , Volume 11, Rev. 0, Page 28 of 494

Attachment 1, Volume 11, Rev. 0, Page 29 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.1 BASES, CONTAINMENT

1. The type of Containment (Ice Condenser) and the Specification designator "C" are deleted since they are unnecessary (only one Containment Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Atmospheric, Subatmospheric, and Dual Containment Specification Bases (ISTS B 3.6.1A, ISTS B 3.6.1B, and ISTS B 3.6.1D) are not used and are not shown.

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

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

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 or to be consistent with the ISTS Writers Guide (NEI 01-03).

6. This bracketed requirement is deleted since it is not applicable to CNP.

7. Reviewers Note not retained.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 29 of 494

Attachment 1, Volume 11, Rev. 0, Page 30 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 30 of 494

Attachment 1, Volume 11, Rev. 0, Page 31 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.1, CONTAINMENT There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 31 of 494

, Volume 11, Rev. 0, Page 32 of 494 ATTACHMENT 2 ITS 3.6.2, Containment Air Locks , Volume 11, Rev. 0, Page 32 of 494

, Volume 11, Rev. 0, Page 33 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 33 of 494

Attachment 1, Volume 11, Rev. 0, Page 34 of 494 ITS 3.6.2 A.1 ITS LCO 3.6.2 LA.1 See ITS 5.5 L.1 Add proposed ACTIONS Note 1 Add proposed ACTIONS Note 2 Add proposed ACTIONS A A.2 A.3 and B Add proposed ACTIONS Note 3 ACTION C ACTION D L.1 Add proposed Required Actions C.1 and C.2 M.1 SR 3.6.2.1 See ITS 5.5 the Containment Leakage Rate Testing Program A.4 SR 3.6.2.2 24 L.2 A.5 Add proposed SR 3.6.2.1 Note 1 Add proposed SR 3.6.2.1 Note 2 A.6 Page 1 of 6 Attachment 1, Volume 11, Rev. 0, Page 34 of 494

Attachment 1, Volume 11, Rev. 0, Page 35 of 494 ITS 3.6.2 A.1 ITS Page 2 of 6 Attachment 1, Volume 11, Rev. 0, Page 35 of 494

Attachment 1, Volume 11, Rev. 0, Page 36 of 494 ITS 3.6.2 A.1 ITS See ITS Chapter 1.0 See ITS 3.6.1 See ITS LCO 3.6.2 3.6.1 See ITS Chapter 1.0 Page 3 of 6 Attachment 1, Volume 11, Rev. 0, Page 36 of 494

Attachment 1, Volume 11, Rev. 0, Page 37 of 494 ITS 3.6.2 A.1 ITS LCO 3.6.2 LA.1 See ITS 5.5 Add proposed ACTIONS Note 1 L.1 Add proposed ACTIONS Note 2 Add proposed ACTIONS A A.2 and B Add proposed ACTIONS Note 3 A.3 ACTION C L.1 ACTION D Add proposed Required ACTIONS M.1 C.1 and C.2 See ITS SR 3.6.2.1 5.5 the Containment Leakage Rate Testing Program A.4 SR 3.6.2.2 24 L.2 A.5 Add proposed SR 3.6.2.1 Note 1 Add proposed SR 3.6.2.1 Note 2 A.6 Page 4 of 6 Attachment 1, Volume 11, Rev. 0, Page 37 of 494

Attachment 1, Volume 11, Rev. 0, Page 38 of 494 ITS 3.6.2 A.1 ITS Page 5 of 6 Attachment 1, Volume 11, Rev. 0, Page 38 of 494

Attachment 1, Volume 11, Rev. 0, Page 39 of 494 ITS 3.6.2 A.1 ITS See ITS Chapter 1.0 See ITS 3.6.1 LCO 3.6.2 See ITS Chapter 1.0 Page 6 of 6 Attachment 1, Volume 11, Rev. 0, Page 39 of 494

Attachment 1, Volume 11, Rev. 0, Page 40 of 494 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS 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 because they do not result in technical changes to the CTS.

A.2 CTS 3.6.1.3 states "Each containment air lock shall be OPERABLE" CTS 3.6.1.3 Action a states "With an air lock inoperable" and specifies Actions to be taken. ITS 3.6.2 ACTIONS Note 2 states "Separate Condition entry is allowed for each air lock." ITS 3.6.2 Condition C states "One or more containment air locks inoperable for reasons other than Condition A or B." This changes the CTS by clarifying the current intent of applying the CTS Actions to each air lock separately.

The purpose of CTS 3.6.1.3 is to ensure containment air locks meet their requirements for CONTAINMENT INTEGRITY (changed to containment OPERABILITY in the ITS). One OPERABLE air lock door in each containment air lock provides a pressure boundary, and applying the CTS Actions for an inoperable air lock to each of the air locks separately is appropriate. ITS 3.6.2 ACTIONS Note 2 clearly states this. The Required Actions for each Condition provide appropriate compensatory action for each inoperable air lock. This change is acceptable because it clarifies existing requirements and better describes how the requirements are currently used. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.6.1.3 does not include a reference to entering applicable Conditions and Required Actions of the CONTAINMENT INTEGRITY LCO (CTS 3.6.1.1)

(changed to containment OPERABILITY in the ITS). ITS 3.6.2 ACTIONS Note 3 states "Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when air lock leakage results in exceeding the overall containment leakage rate." This changes the CTS by explicitly requiring the Containment Actions be entered when the Containment LCO is not met as a result of air lock leakage exceeding limits.

This change is acceptable because it reinforces the requirement in ITS 3.6.1 to meet overall containment leakage limits. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.6.1.3.a references specific 10 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria. ITS SR 3.6.2.1 requires performance of containment air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program. This changes CTS by referencing the appropriate Containment Leakage Rate Testing Program.

The purpose of CTS 4.6.1.3.a is to ensure that the structural integrity of the containment air locks will be maintained comparable to the original design CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 11, Rev. 0, Page 40 of 494

Attachment 1, Volume 11, Rev. 0, Page 41 of 494 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS standards for the life of the facility. This change is acceptable because the appropriate 10 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria are retained in the Technical Specifications as part of ITS 5.5.14, "Containment Leakage Rate Testing Program." This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 4.6.1.3.a references specific 10 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria. ITS SR 3.6.2.1 requires performance of containment air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program. ITS SR 3.6.2.1 Note 1 states "An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test." This changes the CTS by adding a Note as a reminder that either air lock door is capable of providing a fission product barrier in the event of a DBA.

The purpose of CTS 4.6.1.3.a is to ensure that the structural integrity of the containment air locks will be maintained comparable to the original design standards for the life of the facility. This change is acceptable because it provides clarification that the previous overall containment air lock leakage test remains valid when one air lock door is found inoperable, consistent with current requirements and practices. One inoperable door does not invalidate the test for the overall air lock leakage test because the second door is still capable of performing the safety function. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS 4.6.1.3.a references specific 10 CFR 50, Appendix J, Option B requirements, and other specific leakage rate criteria. ITS SR 3.6.2.1 requires performance of containment air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program. ITS SR 3.6.2.1 Note 2 states "Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1."

This changes the CTS by adding a Note as a reminder that the air lock leakage must be accounted for in determining the combined Type B and C containment leakage rate.

The purpose of CTS 4.6.1.3.a is to ensure that the structural integrity of the containment air locks will be maintained comparable to the original design standards for the life of the facility. This change is acceptable because it provides clarification that the containment air lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate, consistent with current requirements and practices. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 The CTS 3.6.1.3 Action requires restoration of an inoperable air lock within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The ITS requires two additional Required Actions. When one or more containment air locks are inoperable for reasons other than Condition A or B, ITS 3.6.2 Required Action C.1 requires initiation of action to evaluate overall containment leakage rate per LCO 3.6.1 immediately and ITS 3.6.2 Required CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 11, Rev. 0, Page 41 of 494

Attachment 1, Volume 11, Rev. 0, Page 42 of 494 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS Action C.2 requires a door in the inoperable air lock to be closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This changes the CTS by adding new Required Actions.

The purpose of ITS 3.6.2 Required Action C.1 is to verify that the overall leakage rate aspect of containment OPERABILITY is met in the event an airlock is inoperable for a reason other than one door or an interlock mechanism being inoperable. The purpose of ITS 3.6.2 Required Action C.2 is to minimize, to the extent possible, the leakage through the inoperable air lock. This change is acceptable because if the inoperability is something that could cause the overall containment leakage rate limits to be exceeded, this should be evaluated immediately, commensurate with the importance of the limits. This change is considered more restrictive because it provides new Required Actions.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.6.1.3.a states (in part) what constitutes an OPERABLE containment air lock. ITS LCO 3.6.2 does not include this level of detail. This changes the CTS by moving details concerning what constitutes an OPERABLE containment air lock to the Bases.

The removal of these details, which are related to system design, 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 to have two OPERABLE containment air locks. 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 CTS.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) The CTS 3.6.1.3 Action states that with an air lock inoperable (for any reason), restore the air lock to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and if not restored, the unit must be shutdown within a certain time limit. The ITS provides separate ACTIONS for different inoperabilities of the air lock. With an airlock inoperable due to a single inoperable door, ITS 3.6.2 ACTION A allows unlimited operation, provided the OPERABLE air lock door is closed in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and locked closed in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and a verification is performed every 31 days that the OPERABLE air lock door remains locked closed. For air lock doors in high radiation areas, this 31 day CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 11, Rev. 0, Page 42 of 494

Attachment 1, Volume 11, Rev. 0, Page 43 of 494 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS verification can be performed by administrative means. In addition, if both air locks have inoperable doors, the ACTION allows containment entry and exit for up to 7 days. With an air lock interlock mechanism inoperable, ITS 3.6.2 ACTION B allows unlimited operation, provided an OPERABLE door in the air lock is closed in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and locked closed in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and a verification is performed every 31 days that an OPERABLE air lock door in the air lock remains locked closed. For air lock doors in high radiation areas, this 31 day verification can be performed by administrative means. In addition, containment entry and exit through the air lock is permissible (i.e., the closed and locked OPERABLE door can be opened) under the control of a dedicated individual. Finally, due to these new ACTIONS, ITS 3.6.2 ACTION C, which requires the air lock to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , only applies to an air lock that is inoperable for reasons other than an inoperable door or an inoperable interlock mechanism. For both of these new ACTIONS as well as ACTION C, as stated in ITS ACTIONS Note 1, entry and exit (i.e., the closed and locked OPERABLE air lock doors can be opened) is also permissible to perform repairs on the affected air lock components. This changes the CTS by allowing unlimited operation, with certain restrictions, for air locks that are inoperable due to an inoperable door or interlock mechanism, and also allows separate Condition entry for each of the two air locks.

The purpose of the CTS air lock Action is to ensure the containment is not allowed to operate indefinitely in a condition such that it cannot perform its safety function. The changes are acceptable because the proposed ACTIONS will still ensure the containment safety function is met. Since there are two redundant doors in each air lock, only one OPERABLE air lock door is needed to be maintained closed to ensure the leak tightness requirements are met. The leak tightness of each door is verified, as required by ITS SR 3.6.2.1, in accordance with the Containment Leakage Rate Testing Program. In addition, the interlock mechanism only ensures that both doors in the air lock are not inadvertently opened at the same time. With either an OPERABLE air lock door locked closed, or a dedicated individual ensuring that only one door at a time is opened, the function of the interlock mechanism is being met. The allowances to open the air lock doors to perform repairs or other reasons is acceptable since the time the door is opened is short and the opening is under administrative controls.

Also, for the case where the air lock door is opened for reasons other than to effect repairs, the time period (7 days) is short. These changes are designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.1.3.b requires testing of the containment airlock interlock once per 6 months. ITS SR 3.6.2.2 requires testing of the containment airlock interlock every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 6 months (i.e., a maximum of 7.5 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 ITS SR 3.6.2.2 is to ensure that the containment airlock interlock prevents more than one of the containment airlock doors from opening at a time.

CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 11, Rev. 0, Page 43 of 494

Attachment 1, Volume 11, Rev. 0, Page 44 of 494 DISCUSSION OF CHANGES ITS 3.6.2, CONTAINMENT AIR LOCKS This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

Typically, the interlock is installed after each refueling outage, verified OPERABLE with the Surveillance. If the need for maintenance arises when the interlock is required, the performance of the interlock Surveillance would be required following the maintenance. In addition, when an air lock is opened during times the interlock is required, the operator first verifies that one door is completely shut before attempting to open the other door. Therefore, the interlock is not challenged except during actual testing of the interlock.

Consequently, it should be sufficient to ensure proper operation of the interlock by testing the interlock on a 24 month interval.

Testing of the air lock interlock mechanism is accomplished through having one door not completely engaged in the closed position, while attempting to open the second door. Failure of this Surveillance effectively results in a loss of containment OPERABILITY. Administrative controls and training do not allow this interlock to be challenged for normal ingress and egress. One door is opened, all personnel and equipment as necessary are placed into the air lock, and then the door is completely closed prior to attempting to open the second door. This Surveillance is contrary to processes and training of conservative operation, in that it requires an operator to challenge an interlock during a MODE when the interlock function is required. The door interlock mechanism cannot be readily bypassed; linkages must be removed to allow bypass of the interlock, which are under the control of station processes such as temporary modifications, primary containment closure procedures, and out of service practices. Failure rate of this physical device is very low based on the design of the interlock.

Historically, the Frequency of this interlock verification was established to coincide with the Frequency of the overall air lock leakage test. According to 10 CFR 50, Appendix J, Option A, this Frequency is once per 6 months.

However, Appendix J, Option B, to which CNP Units 1 and 2 are currently licensed, allows for an extension of the overall air lock leakage test Frequency to a maximum of 30 months.

Therefore, it is proposed to change the required Frequency for this Surveillance to 24 months. With the allowance of ITS SR 3.0.2, this provides a total of 30 months, which corresponds to the overall air lock leakage test Frequency. In this fashion, the interlock can be tested in a MODE where the interlock is not required. 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 11, Rev. 0, Page 44 of 494

Attachment 1, Volume 11, Rev. 0, Page 45 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 45 of 494

, Volume 11, Rev. 0, Page 46 of 494 , Volume 11, Rev. 0, Page 46 of 494

, Volume 11, Rev. 0, Page 47 of 494 , Volume 11, Rev. 0, Page 47 of 494

, Volume 11, Rev. 0, Page 48 of 494 , Volume 11, Rev. 0, Page 48 of 494

, Volume 11, Rev. 0, Page 49 of 494 , Volume 11, Rev. 0, Page 49 of 494

Attachment 1, Volume 11, Rev. 0, Page 50 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2, CONTAINMENT AIR LOCKS

1. The headings for ISTS 3.6.2 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation.

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 11, Rev. 0, Page 50 of 494

Attachment 1, Volume 11, Rev. 0, Page 51 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 51 of 494

, Volume 11, Rev. 0, Page 52 of 494 , Volume 11, Rev. 0, Page 52 of 494

, Volume 11, Rev. 0, Page 53 of 494 , Volume 11, Rev. 0, Page 53 of 494

, Volume 11, Rev. 0, Page 54 of 494 , Volume 11, Rev. 0, Page 54 of 494

, Volume 11, Rev. 0, Page 55 of 494 , Volume 11, Rev. 0, Page 55 of 494

, Volume 11, Rev. 0, Page 56 of 494 , Volume 11, Rev. 0, Page 56 of 494

, Volume 11, Rev. 0, Page 57 of 494 , Volume 11, Rev. 0, Page 57 of 494

, Volume 11, Rev. 0, Page 58 of 494 , Volume 11, Rev. 0, Page 58 of 494

, Volume 11, Rev. 0, Page 59 of 494 , Volume 11, Rev. 0, Page 59 of 494

, Volume 11, Rev. 0, Page 60 of 494 , Volume 11, Rev. 0, Page 60 of 494

, Volume 11, Rev. 0, Page 61 of 494 , Volume 11, Rev. 0, Page 61 of 494

Attachment 1, Volume 11, Rev. 0, Page 62 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.2 BASES, CONTAINMENT AIR LOCKS

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

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. Editorial/grammatical error corrected.

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

5. The words in the ISTS do not convey the complete intent of the actual ISTS Condition and when the Condition should be entered. Therefore, to be consistent with the actual ISTS Condition words, the Bases have been modified.

6. The Bases statement that entry through the OPERABLE air lock is preferred when entering the containment to repair an inoperable air lock door has been deleted. The divider barrier must be breached (i.e., opened) in order to access one air lock by entering through the other air lock, and the ITS requires the divider barrier to be closed. Therefore, it is not practical to enter through the OPERABLE air lock when accessing the other air lock to repair its inoperable door.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 62 of 494

Attachment 1, Volume 11, Rev. 0, Page 63 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 63 of 494

Attachment 1, Volume 11, Rev. 0, Page 64 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.2, CONTAINMENT AIR LOCKS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 64 of 494

, Volume 11, Rev. 0, Page 65 of 494 ATTACHMENT 3 ITS 3.6.3, Containment Isolation Valves , Volume 11, Rev. 0, Page 65 of 494

, Volume 11, Rev. 0, Page 66 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 66 of 494

Attachment 1, Volume 11, Rev. 0, Page 67 of 494 ITS 3.6.3 A.1 ITS LCO 3.6.3 L.1 SR 3.6.3.2 and A.2 ACTIONS Note 1 Add proposed ACTIONS Note 2 A.3 Add proposed ACTIONS Note 3 A.4 Add proposed ACTIONS Note 4 A.5 A.6 ACTION A, ACTION B, M.1 ACTION C 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for ACTION B 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for L.2 ACTION C or check valve with flow secured ACTION D L.3 A.7 L.4 181 Page 1 of 10 Attachment 1, Volume 11, Rev. 0, Page 67 of 494

Attachment 1, Volume 11, Rev. 0, Page 68 of 494 ITS 3.6.3 A.1 ITS L.5 24 SR 3.6.3.5 L.13 actual or LA.1 not locked, sealed, or otherwise secured in L.6 position SR 3.6.3.4 L.7 in accordance with the Inservice A.8 Testing Program Page 2 of 10 Attachment 1, Volume 11, Rev. 0, Page 68 of 494

, Volume 11, Rev. 0, Page 69 of 494 ITS 3.6.3 A.1 Page 3 of 10 , Volume 11, Rev. 0, Page 69 of 494

Attachment 1, Volume 11, Rev. 0, Page 70 of 494 ITS 3.6.3 A.1 ITS See ITS 3.6.1 Add proposed ACTIONS Notes 2, 3, L.8 and 4 and ACTIONS A, B, and C See ITS ACTION D 3.6.1 L.9 Add proposed Required Actions A.2 and C.2 L.10 Required Actions Notes 1 and 2 and SRs 3.6.3.2 and 3.6.3.3 Note A.2 and C.2, and not locked, SR 3.6.3.2, sealed, or SR 3.6.3.3 secured ACTIONS Note 1, SR 3.6.3.2, or check valves with flow secured L.3 SR 3.6.3.3 See ITS 3.6.1 not L.10 SR 3.6.3.3 Page 4 of 10 Attachment 1, Volume 11, Rev. 0, Page 70 of 494

Attachment 1, Volume 11, Rev. 0, Page 71 of 494 ITS 3.6.3 A.1 ITS LCO 3.6.3, A.2 SR 3.6.3.1 SR 3.6.3.1 Add proposed ACTIONS Note 2 L.11 Add proposed ACTIONS Note 4 A.5 M.2 4

ACTION A A.6 L.12 Add proposed ACTION B L.11 ACTION D A.7 A.9 Add proposed SR 3.6.3.1 M.3 Page 5 of 10 Attachment 1, Volume 11, Rev. 0, Page 71 of 494

Attachment 1, Volume 11, Rev. 0, Page 72 of 494 ITS 3.6.3 A.1 ITS LCO 3.6.3 L.1 SR 3.6.3.2 and A.2 ACTIONS Note 1 Add proposed ACTIONS Note 2 A.3 Add proposed ACTIONS Note 3 A.4 Add proposed ACTIONS Note 4 A.5 A.10 L.2 ACTIONS A and C A.6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for ACTION C L.2 Add proposed ACTION B A.11 ACTION D A.7 L.4 Page 6 of 10 Attachment 1, Volume 11, Rev. 0, Page 72 of 494

Attachment 1, Volume 11, Rev. 0, Page 73 of 494 ITS 3.6.3 A.1 ITS L.5 24 SR 3.6.3.5 L.13 actual or LA.1 not locked, sealed, or otherwise SR 3.6.3.4 secured in L.6 position L.7 in accordance with the Inservice A.8 Testing Program Page 7 of 10 Attachment 1, Volume 11, Rev. 0, Page 73 of 494

, Volume 11, Rev. 0, Page 74 of 494 ITS 3.6.3 A.1 Page 8 of 10 , Volume 11, Rev. 0, Page 74 of 494

Attachment 1, Volume 11, Rev. 0, Page 75 of 494 ITS 3.6.3 A.1 ITS See ITS 3.6.1 Add proposed ACTIONS Notes 2, 3, L.8 and 4 and ACTIONS A, B, and C ACTION D See ITS L.9 3.6.1 Add proposed Required Actions A.2 and C.2 L.10 Required Actions Notes 1 and 2 and SRs 3.6.3.2 and 3.6.3.3 Note A.2 and C.2, and not locked, SR 3.6.3.2, sealed, or SR 3.6.3.3 secured ACTIONS Note 1, SR 3.6.3.2, or check valves with flow secured L.3 SR 3.6.3.3 See ITS 3.6.1 not L.10 SR 3.6.3.3 Page 9 of 10 Attachment 1, Volume 11, Rev. 0, Page 75 of 494

Attachment 1, Volume 11, Rev. 0, Page 76 of 494 ITS 3.6.3 A.1 ITS LCO 3.6.3, A.2 SR 3.6.3.1 SR 3.6.3.1 Add proposed ACTIONS Note 2 L.11 Add proposed ACTIONS Note 4 A.5 4 M.2 ACTION A A.6 L.12 Add proposed ACTION B L.11 ACTION D A.7 A.9 Add proposed SR 3.6.3.1 M.3 Page 10 of 10 Attachment 1, Volume 11, Rev. 0, Page 76 of 494

Attachment 1, Volume 11, Rev. 0, Page 77 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION 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 3.6.3.1 states that the Actions of CTS 3/4.6.3.1 are not applicable to the containment purge supply and exhaust isolation valves. The Actions for these valves are provided in CTS 3/4.6.1.7. The ITS combines these two CTS Specifications into one Specification, ITS 3.6.3. Therefore this CTS statement is not necessary and has been deleted.

The CTS 3.6.3.1 statement is a cross reference to direct the user to the proper actions to take when the containment purge supply and exhaust isolation valves are inoperable. This change is acceptable because the two CTS Specifications have been combined into one in the ITS and this statement is not needed. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.3 CTS 3.6.3.1 Action provides requirements to be taken for each containment isolation valve that is inoperable. The ITS includes an explicit Note (ACTIONS Note 2) that provides instructions for the proper application of the ACTIONS for ITS compliance (i.e., Separate Condition entry is allowed for each penetration flow path). This changes the CTS by providing explicit direction as to how to utilize the ACTIONS when a containment isolation valve is inoperable.

This change is acceptable because the addition of the Note reflects the CTS allowance to take the appropriate Actions on a per valve basis (the change to a penetration basis is discussed in DOC M.1). This change is designated as administrative since it does not result in a technical change to the CTS.

A.4 CTS 3.6.3.1 does not specifically require Conditions to be entered for systems supported by inoperable containment isolation valves. OPERABILITY of supported systems is addressed through the definition of OPERABILITY for each system, and appropriate LCO Actions are taken. ITS 3.6.3 ACTIONS Note 3 states "Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves." ITS LCO 3.0.6 provides an exception to ITS LCO 3.0.2, stating "When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered."

This changes the CTS by adding a specific statement to require supported system Conditions and Required Actions be entered, whereas in the CTS this would be done without the Note.

This change is acceptable because the addition of the ITS Note reflects the CTS requirement to take applicable Actions for inoperable systems. The ITS Note is CNP Units 1 and 2 Page 1 of 13 Attachment 1, Volume 11, Rev. 0, Page 77 of 494

Attachment 1, Volume 11, Rev. 0, Page 78 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES required because of the addition of ITS LCO 3.0.6, and because the requirement to declare supported systems inoperable is being retained. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.5 CTS 3.6.3.1 and CTS 3.6.1.7 do not include a reference to entering applicable Conditions and Actions of the CONTAINMENT INTEGRITY LCO (CTS 3.6.1.1)

(changed to containment OPERABILITY in the ITS). ITS 3.6.3 ACTIONS Note 4 states "Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage for a penetration flow path results in exceeding the overall containment leakage rate acceptance criteria." This changes the CTS by explicitly stating an existing requirement that the Containment Specification Actions be taken when the Containment LCO is not met as a result of containment isolation valve leakage exceeding limits.

This change is acceptable because it reinforces the existing CTS requirement to meet overall containment leakage limits. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.6 CTS 3.6.3.1 Action a requires restoring the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with one or more of the containment isolation valves inoperable, or taking one of the other specified compensatory actions.

CTS 3.6.1.7 Action a requires either restoring an inoperable containment purge supply or exhaust isolation valve or deactivating the automatic valve used to isolate the affected penetration in the closed position within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.6.3 does not state the requirement to restore an inoperable isolation valve to OPERABLE status, but includes other compensatory Required Actions to take within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , as applicable. This changes the CTS by not explicitly stating the requirement to restore an inoperable valve to OPERABLE status.

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 any technical changes to the CTS.

A.7 The CTS 3.6.3.1 Action and CTS 3.6.1.7 Action d state "The provisions of Specification 3.0.4 are not applicable." CTS 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted." ITS 3.6.3 does not contain the exception to ITS LCO 3.0.4, since ITS LCO 3.0.4 states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability may be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This changes the CTS by deleting an allowance because it is incorporated into ITS LCO 3.0.4.

CNP Units 1 and 2 Page 2 of 13 Attachment 1, Volume 11, Rev. 0, Page 78 of 494

Attachment 1, Volume 11, Rev. 0, Page 79 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES This change is considered acceptable because ITS LCO 3.0.4 has been changed such that the CTS allowance is not required to retain the same CTS requirement.

ITS 3.6.3 ACTIONS allow continued operation for an unlimited period of time, which together with ITS LCO 3.0.4, result in the same technical requirements as the CTS. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.8 CTS 4.6.3.1.3 (Unit 1) and CTS 4.6.3.1.3.1 (Unit 2) require the isolation time of each power operated or automatic containment isolation valve be determined to be within its limit when tested pursuant to Specification 4.0.5. ITS SR 3.6.3.4 requires verifying the isolation time of each automatic power operated containment isolation valve is within limits, with a Frequency in accordance with the Inservice Testing Program. This changes the CTS by stating that the Frequency is in accordance with the Inservice Testing Program.

The purpose of CTS 4.6.3.1.3 (Unit 1) and CTS 4.6.3.1.3.1 (Unit 2) is to verify the isolation time of each power operated or automatic containment isolation valve is tested in accordance with Specification 4.0.5, which provides the requirements for the Inservice Testing Program. This change is acceptable because the Frequencies regarding the containment isolation valves remain the same. The inservice testing requirements of CTS 4.0.5 have been moved to the Inservice Testing Program contained in Section 5.5 of the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.9 CTS 4.6.1.7.1, the Surveillance Requirement for the containment purge supply and exhaust system valves, states that the Surveillance Requirements of CTS 3/4.6.1.2 and CTS 3/4.6.3.1 apply. The ITS combines CTS 3/4.6.1.7 and CTS 3/4.6.3.1 into one Specification, ITS 3.6.3. In addition, the Surveillances of CTS 3/4.6.1.2, the Containment Leakage Specification, are adequately covered in ITS 3.6.1. Therefore this CTS statement is not necessary and has been deleted.

The CTS 4.6.1.7.1 statement is a cross reference to direct the user to the proper Surveillances for the containment purge supply and exhaust valves, since no additional Surveillances are listed in CTS 3/4.6.1.7. This change is acceptable because the two CTS Specifications (CTS 3/4.6.3.1 and CTS 3/4.6.1.7) have been combined into one in the ITS, and ITS 3.6.1 adequately covers the containment purge valve leakage test (as a part of the Type C leakage testing requirements), thus this statement is not needed. This change is designated as administrative because it does not result in any technical changes to the CTS.

A.10 (Unit 2 only) CTS 3.6.3.1 Action states that with one or more of the containment isolation valve(s) inoperable, "maintain at least one isolation valve OPERABLE in each affected penetration that is open." ITS 3.6.3 Conditions A and B Notes state "Only applicable to penetration flow paths with two containment isolation valves." ITS 3.6.3 Required Action A.1 requires the affected flow path be isolated by one of the means specified when one or more penetration flow paths have one containment isolation valve inoperable. ITS 3.6.3 Required Action A.1 assumes the other isolation valve is OPERABLE for the isolation function. If two valves in a penetration flow path with two containment isolation valves are inoperable, ACTION B provides the appropriate actions to be taken. This CNP Units 1 and 2 Page 3 of 13 Attachment 1, Volume 11, Rev. 0, Page 79 of 494

Attachment 1, Volume 11, Rev. 0, Page 80 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES changes the Unit 2 CTS by incorporating the concept of assuring that the second means of containment isolation for a penetration flow path is OPERABLE into the Conditions and Required Actions associated with ITS 3.6.3 ACTIONS A and B.

This change is acceptable because when one containment isolation valve in a penetration (with two containment isolation valves) is inoperable, the other containment isolation valve must be OPERABLE or the ITS requires Required Actions be taken for two inoperable containment isolation valves. This retains the CTS 3.6.3.1 concept of maintaining at least one isolation valve OPERABLE in each affected penetration that is open when one or more isolation valves are inoperable. This change is designated as administrative because it does not result in any technical changes to the Unit 2 CTS.

A.11 (Unit 2 only) CTS 3.6.3.1 Action does not include any actions when two containment isolation valves in a single penetration are inoperable and the associated penetration is open. Thus, CTS 3.0.3 must be entered if this occurs.

ITS 3.6.3 ACTION B states that with one or more penetration flow paths with two containment isolation valves inoperable, isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.6.3 ACTION D requires the unit be placed in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months if Required Action and associated Completion Time of Condition B is not met. This changes the Unit 2 CTS by stating the Actions to be taken for two containment isolation valves inoperable in the containment isolation valve Specification, rather than relying on CTS 3.0.3, which essentially contains the same Completion Times for isolating the affected penetration or placing the unit outside its MODE of Applicability.

This change is acceptable because it places CTS 3.0.3 requirements into the individual system Specification. This change is designated as administrative because it does not result in any technical changes to the Unit 2 CTS.

MORE RESTRICTIVE CHANGES M.1 (Unit 1 only) CTS 3.6.3.1 Action b allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to isolate the affected penetration when one or more containment isolation valves are inoperable.

ITS 3.6.3 Required Action B.1 will only allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to isolate the affected penetration when both valves in the same penetration are inoperable. This changes the Unit 1 CTS by decreasing the time allowed to isolate the affected penetration when both containment isolation valves in the same penetration are inoperable.

The purpose of the CTS 3.6.3.1 Action is to provide compensatory actions for inoperable containment isolation valves. However, when both valves in the same penetration are inoperable, the time allowed to isolate the affected penetration should be the same as that allowed to restore an inoperable containment, since the containment isolation valves support the leak tightness of the containment.

Therefore, this change is acceptable since the new time allowed is consistent with the time allowed when the containment is inoperable. This change is considered more restrictive because a shorter amount of time is provided to complete the ITS Required Action than is allowed in the Unit 1 CTS.

CNP Units 1 and 2 Page 4 of 13 Attachment 1, Volume 11, Rev. 0, Page 80 of 494

Attachment 1, Volume 11, Rev. 0, Page 81 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES M.2 CTS 3.6.1.7 Action a allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate the affected penetration (by closing and deactivating an automatic containment purge valve) when one containment purge valve in a penetration is inoperable. ITS 3.6.3 ACTION A only allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to isolate the affected penetration when one containment purge valve in a penetration is inoperable. This changes the CTS by decreasing the time allowed to isolate the affected penetration when one containment purge valve in the penetration is inoperable.

The purpose of the CTS 3.6.1.7 Action is to provide compensatory actions for when containment purge valves are inoperable. However, when one containment purge valve in the penetration is inoperable, the time allowed to isolate the affected penetration should be the same as that allowed to isolate all other similar type penetrations, since the containment purge valves support the leak tightness of the containment. Therefore, this change is acceptable since the new time allowed is consistent with the time allowed in the CTS 3.6.3.1 Actions when other similar containment isolation valves are inoperable. This change is considered more restrictive because a shorter amount of time is provided to complete the ITS Required Action than is allowed in the CTS.

M.3 CTS 3/4.6.1.7 does not provide any specific testing requirements for the containment purge supply and exhaust valves, other than those required by CTS 3/4.6.1.2 and CTS 3/4.6.3.1. ITS SR 3.6.3.1 requires a 31 day verification that the containment purge valves are closed, except for certain allowed reasons (consistent with the stated reasons of CTS 3.6.1.7). This changes the CTS by requiring a new Surveillance verifying containment purge valve position.

The purpose of ITS SR 3.6.3.1 is to ensure that the containment purge valves are only open for the specified reasons. The 31 day verification is consistent with the valve position verification required for non-automatic valves in CTS 4.6.1.1.a.1 and ITS SR 3.6.3.2. This change is acceptable because it provides additional assurance that the containment purge valves are in their correct post-accident position. This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.6.3.1.2 states that each containment isolation valve shall be demonstrated OPERABLE by verifying that on a "Phase A," Phase B," or "Containment Purge and Exhaust" isolation signal, each "Phase A," "Phase B,"

and "Containment Purge and Exhaust" isolation valve, respectively, actuates to its isolation position. ITS SR 3.6.3.5 requires verification that each automatic containment isolation valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal. This changes the CTS by moving the detail concerning what type of CNP Units 1 and 2 Page 5 of 13 Attachment 1, Volume 11, Rev. 0, Page 81 of 494

Attachment 1, Volume 11, Rev. 0, Page 82 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES signals are used to conduct the Surveillance Requirement to the Bases.

Changes associated with not requiring the Surveillance Requirement be conducted on valves locked, sealed, or otherwise secured in position are addressed by DOC L.6.

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

LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS 3.6.3.1 states that containment purge valves and locked or sealed closed valves may be opened on an intermittent basis under administrative control. ITS 3.6.3 ACTIONS Note 1 states "Penetration flow paths may be unisolated intermittently under administrative controls." This changes the CTS by allowing any penetration to be unisolated on an intermittent basis under administrative control, and not just containment purge valves and locked or sealed closed valves.

The purpose of the CTS 3.6.3.1 is to provide reasonable operational flexibility regarding containment penetrations. 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 allows any penetration flow path, and not just locked or sealed closed valves, to be opened on an intermittent basis under administrative control, except for the specific exceptions listed. The administrative controls used provide the same level of protection whether the flow paths include locked or sealed closed valves or not. 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) The Unit 1 CTS 3.6.3.1 Action states that with one or more of the containment isolation valve(s) inoperable, isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of one deactivated automatic valve secured in the isolation position, closed manual valve, or blind flange. The Unit 2 CTS 3.6.3.1 Action states that with one or more of the containment isolation valve(s) inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open, and isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of one deactivated automatic valve secured in the isolation position, closed manual valve, or blind flange. ITS 3.6.3 ACTION C, which only applies to penetration flow paths with only one containment isolation valve, requires that with one or more penetration flow paths with one containment CNP Units 1 and 2 Page 6 of 13 Attachment 1, Volume 11, Rev. 0, Page 82 of 494

Attachment 1, Volume 11, Rev. 0, Page 83 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES isolation valve inoperable, the penetration flow path be isolated by means similar to those specified in the CTS within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This changes the Unit 1 and Unit 2 CTS by extending the Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the inoperable containment isolation valve is in a single valve penetration. This also changes the Unit 2 CTS by providing an Action for a single valve penetration, consistent with the Unit 1 CTS, instead of entering CTS 3.0.3.

The purpose of the CTS 3.6.3.1 Action is to provide a degree of assurance that the penetration flow path with an inoperable containment isolation valve maintains the containment penetration isolation boundary. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, 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. In the case of a single valve penetration with an inoperable valve, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is a reasonable time period considering the relative stability of a closed system to act as a penetration isolation boundary, or the small diameter of the pipe penetration and the instrument to act as a penetration isolation boundary. This change is designated as less restrictive because additional time is allowed to restore the components to within the LCO limits than was allowed in the CTS.

L.3 (Category 4 - Relaxation of Required Action) The CTS 3.6.3.1 Action states that with one or more of the containment isolation valve(s) inoperable, isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one deactivated automatic valve secured in the isolation position (Action b), closed manual valve (Action c),

or blind flange (Action c). CTS 4.6.1.1.a.1 requires a periodic verification that the affected penetration remains isolated by the same methods. ITS 3.6.3 Required Action A.1 requires that with one or more penetration flow paths with one containment isolation valve inoperable, the affected penetration flow path be isolated by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

ITS 3.6.3 Required Action A.2 requires a periodic verification that the affected penetration remains isolated by one of the methods of ITS 3.6.3 Required Action A.1. This changes the CTS by allowing penetration flow paths with two containment isolation valves that have one containment isolation valve inoperable to use a check valve with flow through the valve secured as the means of isolating the penetration flow path.

The purpose of CTS 3.6.3.1 Actions b and c and CTS 4.6.1.1.a.1 is to provide assurance that the affected penetration flow path is isolated. This change is acceptable because the ITS 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 ITS 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. This change allows the flow path to be isolated by one check valve with flow through the valve secured. The requirement to isolate the flow path is retained, and using a check valve with flow through the valve secured is an appropriate method of isolation.

CNP Units 1 and 2 Page 7 of 13 Attachment 1, Volume 11, Rev. 0, Page 83 of 494

Attachment 1, Volume 11, Rev. 0, Page 84 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION 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.

L.4 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.3.1.1 describes tests that must be performed prior to returning a valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit. The ITS does not include these testing requirements. This changes the CTS by deleting this post-maintenance Surveillance.

The purpose of CTS 4.6.3.1.1 is to verify OPERABILITY of containment isolation valves following their maintenance, repair or replacement. 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 SR 3.0.1. The OPERABILITY requirements for the containment isolation valves are described in the Bases for ITS 3.6.3. 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-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.5 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.6.3.1.2 requires the demonstration of OPERABILITY of the containment isolation valves by verifying every 18 months that the automatic containment isolation valves actuate to the isolation position. ITS SR 3.6.3.5 requires the containment isolation valve test 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 ITS SR 3.0.2).

The purpose of CTS 4.6.3.1.2 is to ensure that the automatic containment isolation valves function properly on receipt of an automatic isolation signal. 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 CNP Units 1 and 2 Page 8 of 13 Attachment 1, Volume 11, Rev. 0, Page 84 of 494

Attachment 1, Volume 11, Rev. 0, Page 85 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES will be minimal. Extending the Surveillance test interval for the containment isolation valve automatic isolation test is acceptable because during the operating cycle, the containment isolation valves are cycled in accordance with the Inservice Testing (IST) Program, or justifications exist to document less frequent testing. This testing ensures that the containment isolation valves will function properly and will detect significant failures. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

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

CTS 4.6.3.1.2 requires verification that each containment isolation valve actuates to its isolation position. ITS SR 3.6.3.5 requires verification that each automatic containment isolation valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal. This changes the CTS by not requiring automatic valves locked, sealed or otherwise secured in position to be tested to verify that they automatically actuate to their isolation position. Changes associated with moving the details concerning the types of signals to the Bases are addressed by DOC LA.1.

The purpose of CTS 4.6.3.1.2 is to provide assurance that the automatic valves required to actuate in case of a design basis accident (DBA) isolate containment properly. 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. Automatic valves already in the isolated position and secured are not required to be tested to automatically actuate because, in case of a DBA, they are already in their required position. 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.7 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.3.1.3 (Unit 1) and CTS 4.6.3.1.3.1 (Unit 2) state that the isolation time of each "power operated or automatic" containment isolation valve shall be determined to be within its limit. ITS SR 3.6.3.4 states "Verify the isolation time of each automatic power operated containment isolation valve is within limits."

This changes the CTS by deleting the reference to the power operated containment isolation valves that are not automatic.

The purpose of CTS 4.6.3.1.3 (Unit 1) and CTS 4.6.3.1.3.1 (Unit 2) is to provide assurance that automatic containment isolation valves actuate within the times assumed in the DBA analyses. 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. Remote manual (i.e., non-automatic) power operated valves do not have an isolation time assumed in the DBA analyses since they CNP Units 1 and 2 Page 9 of 13 Attachment 1, Volume 11, Rev. 0, Page 85 of 494

Attachment 1, Volume 11, Rev. 0, Page 86 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES require operator action. Deleting reference to power operated, non-automatic isolation valve stroke time testing reduces the potential for misinterpreting the requirements of the Surveillance Requirement while maintaining the assumptions of the accident analysis. 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.8 (Category 4 - Relaxation of Required Action) CTS 4.6.1.1.a requires verification that all non-automatic containment isolation valves that are required to be closed are closed every 31 days. If a non-automatic valve that is supposed to be closed is found open, CTS 3.6.1.1 Action applies. That Action states "Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour 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 in Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." ITS 3.6.3 ACTIONS A, B, and C do not differentiate between automatic and non-automatic valves and allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate the affected flow path. ITS 3.6.3 allows continued operation with the inoperable containment isolation valve, but if the affected penetrations are not isolated, a shutdown to MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is required. In addition, ITS 3.6.3 ACTIONS Notes 2, 3 and 4 allow separate condition entry for each penetration flow path, require entry into the applicable Conditions and Required Actions for systems made inoperable by containment isolation valves, and require entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage for a penetration flow path results in exceeding the overall containment leakage rate acceptance criteria. This changes the CTS by providing 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate a penetration flow path affected by an inoperable non-automatic containment isolation valve, and allowing continued operation with an inoperable non-automatic containment isolation valve. This also changes the CTS by allowing separate condition entry for each penetration flow path with an inoperable non-automatic containment isolation valve, requiring entry into the applicable Conditions and Required Actions for systems made inoperable by inoperable non-automatic containment isolation valves, and requiring entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment,"

when leakage through a penetration flow path due to an inoperable non-automatic containment isolation valve results in exceeding the overall containment leakage rate acceptance criteria.

The purpose of the CTS 3.6.1.1 Action is to ensure that overall containment leakage rate does not exceed the accident analysis assumptions. 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. This change makes the actions for an inoperable non-automatic containment isolation valve consistent with the actions for all other types of containment isolation valves and ensures that leakage through a penetration flow path affected by an inoperable non-automatic containment isolation valve is isolated. This change is designated as CNP Units 1 and 2 Page 10 of 13 Attachment 1, Volume 11, Rev. 0, Page 86 of 494

Attachment 1, Volume 11, Rev. 0, Page 87 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.9 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.1.1.a.1 requires verification that specified containment penetrations are closed. ITS 3.6.3 Required Actions A.2 and C.2, ITS SR 3.6.3.2 and ITS SR 3.6.3.3 include similar requirements, but contain a Note that allows valves and blind flanges in high radiation areas to be verified administratively. In addition, ITS 3.6.3 Required Actions A.2 and C.2 include a second Note that allows verification of isolation devices that are locked, sealed, or otherwise secured to also be performed using administrative means. This changes the CTS by allowing certain valves and blind flanges to not require physical verification.

The purpose of CTS 4.6.1.1.a.1 is to provide assurance that containment penetrations are closed when necessary. 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. The position of containment isolation valves and blind flanges in high radiation areas that are required to be closed can be verified administratively, not requiring physical verification. Access to high radiation areas is limited, making access to the valves and blind flanges more difficult, and mispositioning less likely. For those isolation devices that are locked, sealed, or otherwise secured, plant procedures control their operation.

Therefore, the potential for inadvertent misalignment of these devices after locking, sealing, or securing is low. In addition, all the isolation devices were verified to be in the correct position (as required by ITS 3.6.3 Required Actions A.1 and C.1) prior to locking, sealing, or otherwise securing. 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.10 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.1.1.a.1 requires a verification that all penetrations not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves, secured in their positions. ITS SR 3.6.3.2 and ITS SR 3.6.3.3 require a verification that each containment isolation manual valve and blind flange that is located outside containment (ITS SR 3.6.3.2) or inside containment (ITS SR 3.6.3.3) and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. This changes the CTS by not requiring valves locked, sealed or otherwise secured be verified closed as part of the Technical Specification Surveillance Requirements.

The purpose of CTS 4.6.1.1.a.1 is to provide assurance that valves required to be closed are closed. 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. Valves are verified in position prior to being locked, sealed, or otherwise secured, and are not expected to change position because other controls are placed on them by the means of securing their position.

Valves that are locked, sealed, or otherwise secured in the closed position do not CNP Units 1 and 2 Page 11 of 13 Attachment 1, Volume 11, Rev. 0, Page 87 of 494

Attachment 1, Volume 11, Rev. 0, Page 88 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES require verification as part of ITS SR 3.6.3.2 or ITS SR 3.6.3.3 because these valves were verified to be in the correct position upon locking, sealing, or securing. 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.11 (Category 4 - Relaxation of Required Action) CTS 3.6.1.7 Action a only allows one containment purge supply and one containment purge exhaust valve to be inoperable. If more than one supply valve and one exhaust valve is inoperable, CTS 3.0.3 (which requires a unit shutdown) must be entered. ITS 3.6.3 includes ACTIONS Note 2, which allows separate Condition entry for each containment purge supply and exhaust penetration. ITS 3.6.3 ACTION B also allows both containment purge supply or exhaust valves in the same penetration to be inoperable, provided the affected penetration is isolated within one hour (and verified isolated every 31 days per ITS 3.6.3 Required Action A.2). This changes the CTS by allowing more than one containment purge supply valve and more than one containment purge exhaust valve to be inoperable simultaneously, without requiring a unit shutdown.

The purpose of CTS 3.6.1.7 Action a is to ensure that the containment isolation function is maintained when a containment purge supply and/or exhaust valve is inoperable. This change is acceptable because the containment isolation function can still be maintained: a) with both valves in one or more supply and exhaust penetrations inoperable; or b) one valve in both of the supply penetrations or one valve in both of the exhaust penetrations inoperable.

Isolation capability is maintained since the ITS still requires the affected penetration to be isolated. In addition, this allowance (to have more than one valve in a penetration inoperable or to have valves in both redundant penetrations inoperable for a short period of time) is consistent with the allowance currently provided in CTS 3/4.6.3.1 (ITS 3.6.3) for all other containment penetrations. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.12 (Category 4 - Relaxation of Required Action) CTS 3.6.1.7 Action b allows operation to continue with a containment purge valve inoperable and the associated penetration isolated only until the next required valve test. ITS 3.6.3 ACTION A does not include this restriction. This changes the CTS by allowing operation with an inoperable containment purge valve for an unlimited amount of time provided the associated penetration is isolated.

The purpose of CTS 3.6.1.7 Action b statement is to only allow operation until the next required Surveillance tests for the inoperable valve. However, this requirement is based upon the assumption that the inoperable valve will fail to meet the Surveillance Requirements in CTS 3/4.6.1.2 and CTS 3/4.6.3.1. For the tests of CTS 3/4.6.1.2, this may not be true, since the test of CTS 3/4.6.1.2 is a leakage test (Type C) and the valve could be inoperable for reasons other than leakage. In addition, if the purge valve leakage is such that the Type C limit is exceeded (there is not an individual purge valve leakage limit), then ITS SR 3.6.1.1 will be failed and ITS 3.6.1 will enforce the proper requirements. As such, the CTS 3.6.1.7 Action b statement is not needed for the leakage test CNP Units 1 and 2 Page 12 of 13 Attachment 1, Volume 11, Rev. 0, Page 88 of 494

Attachment 1, Volume 11, Rev. 0, Page 89 of 494 DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES requirements of the containment purge valves. CTS 3/4.6.3.1 has Surveillance requirements to verify the containment purge valves isolate on a proper signal and that their isolation time is within limits. Both of these Surveillances ensure that the containment purge valves can be placed in their post-accident condition.

However, with the penetration already isolated as required by CTS 3.6.1.7 Action a (ITS 3.6.3 Required Action A.1) and periodically verified isolated as required by CTS 3.6.1.7 Action b (ITS 3.6.3 Required Action A.2), there is no need to confirm the containment purge valves can be placed in their post-accident position because they already are in the post-accident position. In addition, this allowance (to allow operation for an unlimited time provided the affected penetration is isolated) is consistent with that allowed for all other inoperable automatic containment isolation valves in CTS 3/4.6.3.1. As such, the CTS 3.6.1.7 Action b statement is not necessary for the isolation and stroke time test requirements of the containment purge valves. Therefore, this change is acceptable for the above described reasons. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.13 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.3.1.2 requires verification of the containment isolation on a "test" or "isolation" signal. ITS SR 3.6.3.5 specifies that the signal may be from either an "actual" or simulated (i.e., test or isolation) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.6.3.1.2 is to ensure that the containment isolation valves (Phase A, Phase B, and Containment Purge and Exhaust valves) 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 cannot 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.

CNP Units 1 and 2 Page 13 of 13 Attachment 1, Volume 11, Rev. 0, Page 89 of 494

Attachment 1, Volume 11, Rev. 0, Page 90 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 90 of 494

, Volume 11, Rev. 0, Page 91 of 494 , Volume 11, Rev. 0, Page 91 of 494

, Volume 11, Rev. 0, Page 92 of 494 , Volume 11, Rev. 0, Page 92 of 494

, Volume 11, Rev. 0, Page 93 of 494 , Volume 11, Rev. 0, Page 93 of 494

, Volume 11, Rev. 0, Page 94 of 494 , Volume 11, Rev. 0, Page 94 of 494

, Volume 11, Rev. 0, Page 95 of 494 , Volume 11, Rev. 0, Page 95 of 494

, Volume 11, Rev. 0, Page 96 of 494 , Volume 11, Rev. 0, Page 96 of 494

Attachment 1, Volume 11, Rev. 0, Page 97 of 494 3.6.3 4

INSERT 1

, provided only valves in one containment purge supply penetration and one containment purge exhaust penetration are open.

Insert Page 3.6.3-6 Attachment 1, Volume 11, Rev. 0, Page 97 of 494

, Volume 11, Rev. 0, Page 98 of 494 , Volume 11, Rev. 0, Page 98 of 494

Attachment 1, Volume 11, Rev. 0, Page 99 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES

1. The headings for ISTS 3.6.3 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made.

2. The restriction in ACTIONS Note 1 concerning purge valves has been deleted, consistent with the current licensing basis.

3. The bracketed term "or more," added to ISTS 3.6.3 Condition A Note, Condition B Note, and Condition B, is not adopted. At CNP, only two valves in each penetration addressed by Conditions A and B are required. This is consistent with the current licensing basis.

4. All ISTS requirements (ACTIONS and Surveillance Requirements) related to containment purge valve leakage have been deleted. The containment purge valves at CNP do not have resilient seats, thus individual leakage limits do not apply. ISTS SR 3.6.3.1 has been deleted since the containment purge valves are not required to be sealed, and ISTS SR 3.6.3.10 has been deleted since the containment purge valves are not required to be blocked from full opening. Furthermore, ISTS SR 3.6.3.2 (ITS SR 3.6.3.1) has been modified to: a) allow the containment purge valves to also be open for maintenance activities; and b) allow only one containment purge supply penetration and one containment purge exhaust penetration to be open (i.e., both supply or both exhaust penetrations cannot be open at the same time).

These changes are consistent with the current licensing basis. The remaining Surveillances have been renumbered due to these deletions.

5. Conditions, Surveillance Requirements and other references to shield building bypass are not retained. Shield building bypass is not part of the CNP design.

6. ISTS Condition C Note has been modified to delete the requirement that the penetrations with only one isolation valve be in a closed system. The CNP design includes only two types of penetrations with one containment isolation valve; a penetration that includes a closed system, and a penetration that is an instrument line penetration. The instrument line penetrations are similar to the Boiling Water Reactor excess flow check valve penetrations, which are allowed a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in NUREG-1433 (and do not include the closed system words in the Condition Note). The CNP instrument line penetrations are very small in diameter (1/2 inch) and include an instrument at the end of the line to act as a penetration isolation boundary (which is analogous to a closed system). Therefore, allowing a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months isolation time for these penetrations is acceptable.

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

8. ISTS SR 3.6.3.6 and SR 3.6.3.9 have been deleted since these Surveillances are for plants with subatmospheric containments, and CNP has an ice condenser containment.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 99 of 494

Attachment 1, Volume 11, Rev. 0, Page 100 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES

9. Typographical/grammatical error corrected to be consistent with similar words in SR 3.6.3.2.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 100 of 494

Attachment 1, Volume 11, Rev. 0, Page 101 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 101 of 494

, Volume 11, Rev. 0, Page 102 of 494 , Volume 11, Rev. 0, Page 102 of 494

Attachment 1, Volume 11, Rev. 0, Page 103 of 494 B 3.6.3 1 INSERT 1 In addition, for one penetration both barriers are provided by a single blind flange, since the blind flange has two separate seals (each of the two seals is considered a barrier for the purposes of this LCO). An exception to the requirement for two barriers applies to those penetrations which carry instrument sensing lines. Such penetrations consist of single manual valve (normally open) and a closed system outside containment, which is considered an extension of the containment liner.

1 INSERT 1A Input from Engineered Safety Features Actuation System (ESFAS) 1 INSERT 1B isolate upon receipt of a Containment Radiation - High signal or a Safety Injection Input from ESFAS signal Insert Page B 3.6.3-1 Attachment 1, Volume 11, Rev. 0, Page 103 of 494

, Volume 11, Rev. 0, Page 104 of 494 , Volume 11, Rev. 0, Page 104 of 494

, Volume 11, Rev. 0, Page 105 of 494 , Volume 11, Rev. 0, Page 105 of 494

, Volume 11, Rev. 0, Page 106 of 494 , Volume 11, Rev. 0, Page 106 of 494

, Volume 11, Rev. 0, Page 107 of 494 , Volume 11, Rev. 0, Page 107 of 494

, Volume 11, Rev. 0, Page 108 of 494 , Volume 11, Rev. 0, Page 108 of 494

, Volume 11, Rev. 0, Page 109 of 494 , Volume 11, Rev. 0, Page 109 of 494

, Volume 11, Rev. 0, Page 110 of 494 , Volume 11, Rev. 0, Page 110 of 494

, Volume 11, Rev. 0, Page 111 of 494 , Volume 11, Rev. 0, Page 111 of 494

, Volume 11, Rev. 0, Page 112 of 494 , Volume 11, Rev. 0, Page 112 of 494

, Volume 11, Rev. 0, Page 113 of 494 , Volume 11, Rev. 0, Page 113 of 494

, Volume 11, Rev. 0, Page 114 of 494 , Volume 11, Rev. 0, Page 114 of 494

, Volume 11, Rev. 0, Page 115 of 494 , Volume 11, Rev. 0, Page 115 of 494

, Volume 11, Rev. 0, Page 116 of 494 , Volume 11, Rev. 0, Page 116 of 494

, Volume 11, Rev. 0, Page 117 of 494 , Volume 11, Rev. 0, Page 117 of 494

, Volume 11, Rev. 0, Page 118 of 494 , Volume 11, Rev. 0, Page 118 of 494

, Volume 11, Rev. 0, Page 119 of 494 , Volume 11, Rev. 0, Page 119 of 494

, Volume 11, Rev. 0, Page 120 of 494 , Volume 11, Rev. 0, Page 120 of 494

Attachment 1, Volume 11, Rev. 0, Page 121 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES

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

2. The Bases are changed to eliminate a statement classifying check valves as active devices. Information Report SECY-77-439, dated August 17, 1977, states "Check valves are classified as active components for the purposes of functional specification, inservice inspection, testing, and valve design (re: Regulatory Guide 1.146). Check valves are classified as passive components for the purposes of single failure and system design." The reference in the ISTS 3.6.3 Bases that is deleted is part of a discussion that addresses failures of automatic valves for the purposes of single failure. This is not accurate for check valves at CNP.

3. 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.

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

5. Typographical/grammatical error corrected.

6. The words in the ITS 3.6.3 ACTIONS B.1 Bases, concerning how Required Action A.2 works, has been deleted. This description is already in the ACTION A.1, A.2 Bases, and does not need to be repeated. This is consistent with many other Bases descriptions of ACTIONS, which do not include a description of other Conditions' Required Actions that may also be required when in another ACTION.

This is also consistent with the BWR ISTS Bases, NUREG-1433 and NUREG-1434.

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

8. The statement that the isolation times of the containment isolation valves are in the Inservice Testing Program has been deleted from ITS SR 3.6.3.4 (ISTS SR 3.6.3.5).

The isolation times of the containment isolation valves are in the Inservice Testing Program, and this has already been stated in the second paragraph of the ISTS LCO Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 121 of 494

Attachment 1, Volume 11, Rev. 0, Page 122 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 122 of 494

Attachment 1, Volume 11, Rev. 0, Page 123 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 123 of 494

, Volume 11, Rev. 0, Page 124 of 494 ATTACHMENT 4 ITS 3.6.4, Containment Pressure , Volume 11, Rev. 0, Page 124 of 494

, Volume 11, Rev. 0, Page 125 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 125 of 494

Attachment 1, Volume 11, Rev. 0, Page 126 of 494 ITS 3.6.4 A.1 ITS LCO 3.6.4 ACTION A ACTION B SR 3.6.4.1 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 126 of 494

Attachment 1, Volume 11, Rev. 0, Page 127 of 494 ITS 3.6.4 A.1 ITS LCO 3.6.4 ACTION A ACTION B SR 3.6.4.1 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 127 of 494

Attachment 1, Volume 11, Rev. 0, Page 128 of 494 DISCUSSION OF CHANGES ITS 3.6.4, CONTAINMENT PRESSURE 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 None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 128 of 494

Attachment 1, Volume 11, Rev. 0, Page 129 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 129 of 494

, Volume 11, Rev. 0, Page 130 of 494 , Volume 11, Rev. 0, Page 130 of 494

Attachment 1, Volume 11, Rev. 0, Page 131 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.4, CONTAINMENT PRESSURE

1. The type of Containment (Atmospheric, Dual, and Ice Condenser) and the Specification designator "A" are deleted since they are unnecessary (only one Containment Pressure Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Subatmospheric Containment Pressure Specification (ISTS 3.6.4B) is not used and is not shown.

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 11, Rev. 0, Page 131 of 494

Attachment 1, Volume 11, Rev. 0, Page 132 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 132 of 494

, Volume 11, Rev. 0, Page 133 of 494 , Volume 11, Rev. 0, Page 133 of 494

, Volume 11, Rev. 0, Page 134 of 494 , Volume 11, Rev. 0, Page 134 of 494

, Volume 11, Rev. 0, Page 135 of 494 , Volume 11, Rev. 0, Page 135 of 494

, Volume 11, Rev. 0, Page 136 of 494 , Volume 11, Rev. 0, Page 136 of 494

, Volume 11, Rev. 0, Page 137 of 494 , Volume 11, Rev. 0, Page 137 of 494

Attachment 1, Volume 11, Rev. 0, Page 138 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.4 BASES, CONTAINMENT PRESSURE

1. The type of Containment (Atmospheric, Dual, and Ice Condenser) and the Specification designator "A" are deleted since they are unnecessary (only one Containment Pressure Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Subatmospheric Containment Pressure Specification Bases (ISTS B 3.6.4B) is not used and is not shown.

2. Typographical/grammatical error corrected.

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

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 138 of 494

Attachment 1, Volume 11, Rev. 0, Page 139 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 139 of 494

Attachment 1, Volume 11, Rev. 0, Page 140 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.4, CONTAINMENT PRESSURE There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 140 of 494

, Volume 11, Rev. 0, Page 141 of 494 ATTACHMENT 5 ITS 3.6.5, Containment Air Temperature , Volume 11, Rev. 0, Page 141 of 494

, Volume 11, Rev. 0, Page 142 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 142 of 494

Attachment 1, Volume 11, Rev. 0, Page 143 of 494 ITS 3.6.5 A.1 ITS LCO 3.6.5 ACTION A ACTION B SR 3.6.5.1 within limits LA.1 SR 3.6.5.2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 143 of 494

Attachment 1, Volume 11, Rev. 0, Page 144 of 494 ITS 3.6.5 A.1 ITS SR 3.6.5.2 LA.1 SR 3.6.5.1, SR 3.6.5.2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 144 of 494

Attachment 1, Volume 11, Rev. 0, Page 145 of 494 ITS 3.6.5 A.1 ITS LCO 3.6.5 ACTION A ACTION B SR 3.6.5.1 within limits LA.1 SR 3.6.5.2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 145 of 494

Attachment 1, Volume 11, Rev. 0, Page 146 of 494 ITS 3.6.5 A.1 ITS SR 3.6.5.2 LA.1 SR 3.6.5.1, SR 3.6.5.2 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 146 of 494

Attachment 1, Volume 11, Rev. 0, Page 147 of 494 DISCUSSION OF CHANGES ITS 3.6.5, CONTAINMENT AIR TEMPERATURE 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 LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.1.5.1 and CTS 4.6.1.5.2 include specific locations where containment temperatures are to be measured and the method of determining the average temperatures. ITS SR 3.6.5.1 and ITS SR 3.6.5.2 do not include these details. This changes the CTS by moving the description of how compliance with the Technical Specification LCO is determined 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 verify containment average air temperatures are within limits. Also, this change is acceptable because these types of procedural details will be adequately controlled in the 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 None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 147 of 494

Attachment 1, Volume 11, Rev. 0, Page 148 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 148 of 494

, Volume 11, Rev. 0, Page 149 of 494 , Volume 11, Rev. 0, Page 149 of 494

, Volume 11, Rev. 0, Page 150 of 494 , Volume 11, Rev. 0, Page 150 of 494

Attachment 1, Volume 11, Rev. 0, Page 151 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.5, CONTAINMENT AIR TEMPERATURE

1. The type of Containment (Ice Condenser) and the Specification designator "B" are deleted since they are unnecessary (only one Containment Air Temperature Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Atmospheric and Dual Specification (ISTS 3.6.5A) and the Subatmospheric Specification (ISTS 3.6.5C) are not used and are not shown.

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

3. The LCO Note that allows the minimum temperature limit to be reduced to 60°F in MODES 2, 3, and 4 has been deleted since it is unnecessary. The CTS already allow the minimum temperature to be 60°F in MODES 1, 2, 3, and 4; thus the ITS LCO 3.6.5 minimum temperature limit is 60°F, and a Note modifying the minimum temperature is not needed.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 151 of 494

Attachment 1, Volume 11, Rev. 0, Page 152 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 152 of 494

, Volume 11, Rev. 0, Page 153 of 494 , Volume 11, Rev. 0, Page 153 of 494

, Volume 11, Rev. 0, Page 154 of 494 , Volume 11, Rev. 0, Page 154 of 494

Attachment 1, Volume 11, Rev. 0, Page 155 of 494 B 3.6.5 4 INSERT 1 at Pa is 196°F for the containment upper compartment and 244°F for the containment lower compartment.

3 INSERT 2 The limiting DBA for the peak clad temperature analysis is a large break LOCA. For this analysis, the bounding range for the upper containment initial temperature is 60°F to 100°F and the bounding range for the lower containment initial is 60°F to 120°F.

TSTF-401 INSERT 2A accident temperature profile assures that the containment structural temperature is maintained below its design temperature and that required safety related equipment will continue to perform its function.

Insert Page B 3.6.5B-2 Attachment 1, Volume 11, Rev. 0, Page 155 of 494

, Volume 11, Rev. 0, Page 156 of 494 , Volume 11, Rev. 0, Page 156 of 494

Attachment 1, Volume 11, Rev. 0, Page 157 of 494 B 3.6.5 3 INSERT 3 In the upper compartment, two locations at a nominal elevation of 712 ft 0 inches and a third location at a nominal elevation of 624 ft 10 inches are used. In the lower compartment, the locations at nominal elevations 626 ft 6 inches, 624 ft 10 1/2 inches, and 624 ft 0 inches are used.

Insert Page B 3.6.5B-3 Attachment 1, Volume 11, Rev. 0, Page 157 of 494

, Volume 11, Rev. 0, Page 158 of 494 , Volume 11, Rev. 0, Page 158 of 494

Attachment 1, Volume 11, Rev. 0, Page 159 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.5 BASES, CONTAINMENT AIR TEMPERATURE

1. The type of Containment (Ice Condenser) and the Specification designator "B" are deleted since they are unnecessary (only one Containment Air Temperature Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Atmospheric and Dual Specification (ISTS 3.6.5A) and the Subatmospheric Specification (ISTS 3.6.5C) are not used and are not shown.

2. Typographical/grammatical error corrected.

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

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 159 of 494

Attachment 1, Volume 11, Rev. 0, Page 160 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 160 of 494

Attachment 1, Volume 11, Rev. 0, Page 161 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.5, CONTAINMENT AIR TEMPERATURE There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 161 of 494

, Volume 11, Rev. 0, Page 162 of 494 ATTACHMENT 6 ITS 3.6.6, Containment Spray System , Volume 11, Rev. 0, Page 162 of 494

, Volume 11, Rev. 0, Page 163 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 163 of 494

Attachment 1, Volume 11, Rev. 0, Page 164 of 494 ITS 3.6.6 A.1 ITS LCO 3.6.6 LA.1 ACTION A A.2 ACTION B SR 3.6.6.1 A.3 SR 3.6.6.2 L.1 Add proposed Note 24 to SR 3.6.6.3 L.2 not locked, sealed, or otherwise secured in position SR 3.6.6.3 LA.2 actual or SR 3.6.6.4 Add proposed Note L.3 LA.2 to SR 3.6.6.4 actual or SR 3.6.6.5 L.3 LA.3 A.3 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 164 of 494

Attachment 1, Volume 11, Rev. 0, Page 165 of 494 ITS 3.6.6 A.1 ITS Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 165 of 494

Attachment 1, Volume 11, Rev. 0, Page 166 of 494 ITS 3.6.6 A.1 ITS LCO 3.6.6 LA.1 ACTION A A.2 ACTION B SR 3.6.6.1 A.3 SR 3.6.6.2 L.1 Add proposed Note 24 to SR 3.6.6.3 not locked, sealed, or otherwise secured in position L.2 SR 3.6.6.3 actual or LA.2 Add proposed Note L.3 SR 3.6.6.4 to SR 3.6.6.4 LA.2 actual or SR 3.6.6.5 L.3 LA.3 A.3 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 166 of 494

Attachment 1, Volume 11, Rev. 0, Page 167 of 494 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY 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 3.6.2.1 Action states that with one Containment Spray System inoperable, if the Containment Spray System is not restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then the unit must be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and to either restore the inoperable Containment Spray System to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . With an inoperable containment spray train not restored to OPERABLE status in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , ITS 3.6.6 ACTION B requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . ITS 3.6.6 does not contain the second phrase stating that the Containment Spray System (i.e., train) must be restored to OPERABLE status after the unit is in MODE 3, but combines the time allowed for restoration and to be in MODE 5 together into one Required Action to be in MODE 5.

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 CTS 3/4.6.2.1 is applicable in MODES 1, 2, 3, and 4. CTS 4.6.2.1.c.1 requires verification of the automatic actuation of the Containment Spray System valves.

CTS 4.6.2.1.c.2 requires verification of the automatic actuation of the Containment Spray System pumps. The requirements for these Surveillances are included in ITS SR 3.6.6.3 and SR 3.6.6.4, respectively; however, a Note has been included in the SRs that states that in MODE 4, only the manual portion of the actuation signal is required. This changes the CTS by not requiring automatic actuation in MODE 4.

The purpose of CTS 3/4.6.2.1 is to ensure the Containment Spray System is OPERABLE to support the safety analysis. The purpose of CTS 4.6.2.1.c.1 is to ensure the Containment Spray System valves operate upon receipt of an actuation signal, while the purpose of CTS 4.6.2.1.c.2 is to ensure that the Containment Spray System pumps start upon receipt of an actuation signal. 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. CTS Table 3.3-3 (ITS Table 3.3.2-1) specifies the requirements for the Containment Spray Instrumentation, and includes three actuation Functions: Manual Initiation, Automatic Actuation Logic and Actuation Relays, and Containment Pressure - High High. The Manual CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 11, Rev. 0, Page 167 of 494

Attachment 1, Volume 11, Rev. 0, Page 168 of 494 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY SYSTEM Initiation and Automatic Actuation Logic and Actuation Relays Functions are required to be OPERABLE in MODES 1, 2, 3, and 4. The Containment Pressure

- High High Function is only required to be OPERABLE in MODES 1, 2, and 3.

The Applicability of the Automatic Actuation Logic and Actuation Relays Function is consistent with the Manual Initiation Function, since the relays associated with the automatic actuation logic are also used to support the Manual Initiation Function. The Containment Pressure - High High Function is the only automatic actuation Function and it is only required to be OPERABLE in MODES 1, 2, and

3. Therefore, this change to the Applicability in CTS 4.6.2.1.c.1 and CTS 4.6.2.1.c.2 is made for consistency with the Containment Spray Instrumentation requirements in CTS, which does not require automatic actuation in MODE 4. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.2.1 states that two "independent" Containment Spray Systems shall be OPERABLE "with each spray system capable of taking suction from the RWST and transferring suction to the containment sump." ITS 3.6.6 requires two containment spray trains (i.e., systems) to be OPERABLE, but does not include the details of what constitutes OPERABILITY. This changes the CTS by moving the detail that the trains must be "independent" and the description of the capability of the trains (i.e., taking suction from the RWST and transferring suction to the containment sump) 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 two containment spray trains shall 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 the Bases 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 4.6.2.1.c.1 and CTS 4.6.2.1.c.2 require CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 11, Rev. 0, Page 168 of 494

Attachment 1, Volume 11, Rev. 0, Page 169 of 494 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY SYSTEM verification of the automatic actuation of containment spray components on a Containment Pressure - High-High signal. ITS SR 3.6.6.3 and SR 3.6.6.4 do not specify the name of the signal, but only specify an actuation signal. This changes the CTS by moving the detail concerning what type of signal is used to conduct the Surveillance Requirements 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 that appropriate containment spray pumps and valves start or actuate on an actuation signal. 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 the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.2.1.d states to perform "an air or smoke flow test through each spray header" to verify each spray nozzle is unobstructed. ITS SR 3.6.6.5 states to verify each spray nozzle is unobstructed. This changes the CTS by moving the details of how to perform the test 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 that spray nozzles are verified unobstructed. 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 the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.6.2.1.c requires each containment spray system to be demonstrated OPERABLE at least once per 18 months by verifying that each automatic valve in the flow path automatically actuates to its correct position and by verifying that each containment spray pump starts automatically. ITS SR 3.6.6.3 requires the same type of test to be performed on the containment spray valves while ITS SR 3.6.6.4 requires the same type of test on the containment spray pumps. The Frequency of testing for both ITS SR 3.6.6.3 and ITS SR 3.6.6.4 is 24 months. This changes the CTS by extending the Frequency CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 11, Rev. 0, Page 169 of 494

Attachment 1, Volume 11, Rev. 0, Page 170 of 494 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY SYSTEM 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 4.6.2.1.c is to demonstrate that all active components will function as required if an accident were to occur. 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 containment spray automatic actuation test is acceptable because the system is tested in accordance with the Inservice Testing Program throughout the operating cycle. This testing ensures that the active components (pumps and valves) will function properly and will detect significant failures of the system. Additional justification for extending the Surveillance test interval is that the Containment Spray System, including the actuating logic, is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one containment spray train. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.2.1.c.1 requires verification that each automatic valve in the flow path actuates to its correct position on a Containment Pressure - High-High signal.

ITS SR 3.6.6.3 requires verification that each automatic valve in the flow path that is not locked, sealed, or otherwise secured in position actuates to its correct position on an actual or simulated actuation signal. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from this test. Removal of the Containment Pressure - High-High signal reference is addressed by DOC LA.2.

The purpose of CTS 4.6.2.1.c.1 is to ensure that the containment spray valves that are required to automatically actuate upon receipt of an actuation signal 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 a Containment Pressure - High High signal in order to perform their safety function because they are already in the required position. Testing such valves would not provide any CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 11, Rev. 0, Page 170 of 494

Attachment 1, Volume 11, Rev. 0, Page 171 of 494 DISCUSSION OF CHANGES ITS 3.6.6, CONTAINMENT SPRAY SYSTEM additional assurance of OPERABILITY. Valves that are required to automatically 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.3 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.2.1.c.1 requires verification of the automatic actuation of the Containment Spray System valves on a "test" signal. CTS 4.6.2.1.c.2 requires verification of the automatic actuation of the Containment Spray System pumps on a "test" signal. ITS SR 3.6.6.3 and ITS SR 3.6.6.4 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 4.6.2.1.c.1 is to ensure the Containment Spray System valves operate upon receipt of an actuation signal while the purpose of CTS 4.6.2.1.c.2 is to ensure that the Containment Spray System pumps start 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 cannot 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.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 11, Rev. 0, Page 171 of 494

Attachment 1, Volume 11, Rev. 0, Page 172 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 172 of 494

, Volume 11, Rev. 0, Page 173 of 494 , Volume 11, Rev. 0, Page 173 of 494

, Volume 11, Rev. 0, Page 174 of 494 3.6.6 4 INSERT 1

-NOTE-In MODE 4, only the manual portion of the actuation signal is required.

Insert Page 3.6.6-1 , Volume 11, Rev. 0, Page 174 of 494

, Volume 11, Rev. 0, Page 175 of 494 , Volume 11, Rev. 0, Page 175 of 494

, Volume 11, Rev. 0, Page 176 of 494 3.6.6 4 INSERT 2

-NOTE-In MODE 4, only the manual portion of the actuation signal is required.

Insert Page 3.6.6-2 , Volume 11, Rev. 0, Page 176 of 494

Attachment 1, Volume 11, Rev. 0, Page 177 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.6, CONTAINMENT SPRAY SYSTEM

1. The type of Containment Spray System (Ice Condenser) and the Specification designator "C" are deleted since they are unnecessary (only one Containment Spray Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Containment Spray and Cooling Systems Specifications for Atmospheric and Dual Containments (ISTS 3.6.6A and ISTS 3.6.6B), Quench Spray System Specification for a Subatmospheric Containment (ISTS 3.6.6D), and Recirculation Spray System Specification for Subatmospheric Containment (ISTS 3.6.6E) are not used and are not shown.

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

3. CNP Units 1 and 2 have completed the first refueling outages. Therefore, the ISTS SR 3.6.6.5 bracketed Frequency of At first refueling is not needed and is removed.

4. ISTS SR 3.6.6.3 and ISTS SR 3.6.6.4 have been modified by a Note stating that in MODE 4, only the manual portion of the actuation signal is required. This change has been made to be consistent with ITS 3.3.2. CTS Table 3.3-3 (ITS Table 3.3.2-1) specifies the requirements for the Containment Spray Instrumentation, and includes three actuation Functions: Manual Initiation, Automatic Actuation Logic and Actuation Relays, and Containment Pressure - High High. The Manual Initiation and Automatic Actuation Logic and Actuation Relays Functions are required to be OPERABLE in MODES 1, 2, 3, and 4. The Containment Pressure - High High Function is only required to be OPERABLE in MODES 1, 2, and 3. The Applicability of the Automatic Actuation Logic and Actuation Relays Function is consistent with the Manual Initiation Function, since the relays associated with the automatic actuation logic are also used to support the Manual Initiation Function. The Containment Pressure -

High High Function is the only automatic actuation Function and it is only required to be OPERABLE in MODES 1, 2, and 3. Therefore, this change to the Applicability in ISTS SR 3.6.6.3 and ISTS SR 3.6.6.4 is made for consistency with the Containment Spray Instrumentation Specification in both the CTS and ITS, which does not require automatic actuation in MODE 4.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 177 of 494

Attachment 1, Volume 11, Rev. 0, Page 178 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 178 of 494

, Volume 11, Rev. 0, Page 179 of 494 , Volume 11, Rev. 0, Page 179 of 494

, Volume 11, Rev. 0, Page 180 of 494 , Volume 11, Rev. 0, Page 180 of 494

, Volume 11, Rev. 0, Page 181 of 494 , Volume 11, Rev. 0, Page 181 of 494

, Volume 11, Rev. 0, Page 182 of 494 , Volume 11, Rev. 0, Page 182 of 494

, Volume 11, Rev. 0, Page 183 of 494 , Volume 11, Rev. 0, Page 183 of 494

, Volume 11, Rev. 0, Page 184 of 494 , Volume 11, Rev. 0, Page 184 of 494

, Volume 11, Rev. 0, Page 185 of 494 , Volume 11, Rev. 0, Page 185 of 494

Attachment 1, Volume 11, Rev. 0, Page 186 of 494 B 3.6.6 11 INSERT 5 This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves.

Insert Page B 3.6.6C-5 Attachment 1, Volume 11, Rev. 0, Page 186 of 494

, Volume 11, Rev. 0, Page 187 of 494 , Volume 11, Rev. 0, Page 187 of 494

Attachment 1, Volume 11, Rev. 0, Page 188 of 494 B 3.6.6 8 INSERT 6 These Surveillances include a Note that states that in MODE 4, only the manual portion of the actuation signal is required. This is acceptable since the automatic portion of the actuation signal is not required to be OPERABLE by ITS 3.3.2, "Engineered Safety Features Actuation System (ESFAS) Instrumentation."

Insert Page B 3.6.6C-6 Attachment 1, Volume 11, Rev. 0, Page 188 of 494

, Volume 11, Rev. 0, Page 189 of 494 , Volume 11, Rev. 0, Page 189 of 494

Attachment 1, Volume 11, Rev. 0, Page 190 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.6 BASES, CONTAINMENT SPRAY SYSTEM

1. The type of Containment Spray System (Ice Condenser) and the Specification designator "C" are deleted since they are unnecessary (only one Containment Spray Specification is used in the CNP ITS). This information is provided in NUREG-1431, Rev. 2, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Containment Spray and Cooling Systems Specification Bases for Atmospheric and Dual Containments (ISTS B 3.6.6A and ISTS B 3.6.6B), Quench Spray System Specification Bases for a Subatmospheric Containment (ISTS B 3.6.6D), and Recirculation Spray System Specification Bases for Subatmospheric Containment (ISTS B 3.6.6E) are not used and are not shown.

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

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

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

5. The IST Program at CNP Units 1 and 2 is not required to provide information for trend performance. Therefore, these words have been deleted.

6. The Bases ASA section discussion of the inadvertent actuation of the Containment Spray System has been deleted because this incident does not describe how the Containment Spray System mitigates DBAs. In addition, analysis of an inadvertent Containment Spray actuation event is not part of the CNP licensing basis.

7. Typographical/grammatical error corrected

8. Changes are made to reflect those changes made to the Specification.

9. The statements describing explicit details of the design of the Spray Additive System have been deleted. These details are adequately covered by the Spray Additive System Specification (ITS 3.6.7), and do not need to be repeated in this Specification's Bases. The generic statement describing that the Spray Additive System injects sodium hydroxide solution using the Containment Spray System pumps is sufficient.

10. Editorial change made for clarity.

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

B 3.7.5, B 3.7.7, and B 3.7.8).

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 190 of 494

Attachment 1, Volume 11, Rev. 0, Page 191 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 191 of 494

Attachment 1, Volume 11, Rev. 0, Page 192 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.6, CONTAINMENT SPRAY SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 192 of 494

, Volume 11, Rev. 0, Page 193 of 494 ATTACHMENT 7 ITS 3.6.7, Spray Additive System , Volume 11, Rev. 0, Page 193 of 494

, Volume 11, Rev. 0, Page 194 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 194 of 494

Attachment 1, Volume 11, Rev. 0, Page 195 of 494 ITS 3.6.7 A.1 ITS LCO 3.6.7 SR 3.6.7.2, SR 3.6.7.3 LA.1 ACTION A ACTION B A.2 SR 3.6.7.1 SR 3.6.7.2 SR 3.6.7.3 LA.2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 195 of 494

Attachment 1, Volume 11, Rev. 0, Page 196 of 494 ITS 3.6.7 A.1 ITS L.1 24 not locked, sealed, or otherwise secured in position L.2 SR 3.6.7.4 actual or LA.3 L.3 SR 3.6.7.5 LA.4 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 196 of 494

Attachment 1, Volume 11, Rev. 0, Page 197 of 494 ITS 3.6.7 A.1 ITS LCO 3.6.7 SR 3.6.7.2, SR 3.6.7.3 LA.1 ACTION A ACTION B A.2 SR 3.6.7.1 SR 3.6.7.2 SR 3.6.7.3 LA.2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 197 of 494

Attachment 1, Volume 11, Rev. 0, Page 198 of 494 ITS 3.6.7 A.1 ITS L.1 24 not locked, sealed, or otherwise secured in position L.2 SR 3.6.7.4 actual or LA.3 SR 3.6.7.5 L.3 LA.4 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 198 of 494

Attachment 1, Volume 11, Rev. 0, Page 199 of 494 DISCUSSION OF CHANGES ITS 3.6.7, SPRAY ADDITIVE 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 because they do not result in technical changes to the CTS.

A.2 CTS 3.6.2.2 Action states that with the Spray Additive System inoperable, if the Spray Additive System is not restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then the unit must be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and to either restore the Spray Additive System to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . With an inoperable Spray Additive System not restored to OPERABLE status in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , ITS 3.6.7 ACTION B requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . ITS 3.6.7 does not contain the second phrase stating that the Spray Additive System (i.e., train) must be restored to OPERABLE status after the unit is in MODE 3, but combines the time allowed for restoration and to be in MODE 5 together into one Required Action to be in MODE 5.

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.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.2.2.b states that, as part of the Spray Additive System, two spray additive eductors each capable of adding NaOH solution from the chemical additive tank to a containment spray system pump flow are required.

ITS 3.6.7 states that the Spray Additive System shall be OPERABLE, but the details of what constitutes an OPERABLE system are moved to the Bases. This changes the CTS by moving the details of what constitutes a Spray Additive System to the Bases.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 11, Rev. 0, Page 199 of 494

Attachment 1, Volume 11, Rev. 0, Page 200 of 494 DISCUSSION OF CHANGES ITS 3.6.7, SPRAY ADDITIVE SYSTEM 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 have the Spray Additive System 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 4.6.2.2.b.2 requires the verification of the concentration of the NaOH solution "by chemical analysis." ITS SR 3.6.7.3 also requires verification of the concentration of NaOH solution, but does not include the method to perform the verification. This changes the CTS by moving the specific method (by chemical analysis) to the Bases.

The removal of this detail 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. The ITS still retains the requirement to verify the NaOH solution concentration. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases.

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

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.2.2.c requires verification that each automatic spray additive valve in the flow path actuates to its correct position on a Containment Pressure - High-High signal. ITS SR 3.6.7.4 does not specify the signal, but only specifies an actual or simulated actuation signal. This changes the CTS by moving the type of actuation signal to the Bases.

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. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

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 5 Attachment 1, Volume 11, Rev. 0, Page 200 of 494

Attachment 1, Volume 11, Rev. 0, Page 201 of 494 DISCUSSION OF CHANGES ITS 3.6.7, SPRAY ADDITIVE SYSTEM LA.4 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.2.2.d specifies that the spray additive flow test is accomplished by verifying flow rate from the spray additive tank test line to each Containment Spray System (i.e., train) with the spray pump operating on recirculation. ITS SR 3.6.7.5 states "Verify spray additive flow rate from each solution's flow path." This changes the CTS by moving the details regarding the test method to the Bases.

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. The ITS still retains the requirement to verify spray additive flow rate. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.6.2.2.c requires verifying that each spray additive automatic valve in the flow path actuates to its correct position at least once per 18 months. ITS SR 3.6.7.4 requires the same type of test 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 ITS SR 3.0.2).

The purpose of CTS 4.6.2.2.c is to demonstrate that all active components will function as required if an accident were to occur. 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 spray additive automatic actuation test is acceptable because the valves are tested in accordance with the Inservice Testing Program throughout the operating cycle. This testing ensures that the active valves will function properly and will detect significant failures of the system. Additional justification for extending the Surveillance test interval is that the Spray Additive System, including the actuating logic, is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one spray additive train. Based on the inherent system and component reliability and CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 11, Rev. 0, Page 201 of 494

Attachment 1, Volume 11, Rev. 0, Page 202 of 494 DISCUSSION OF CHANGES ITS 3.6.7, SPRAY ADDITIVE SYSTEM the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.2.2.c requires verification that each automatic valve in the spray additive flow path actuates to its correct position on a Containment Pressure - High High test signal. ITS SR 3.6.7.4 requires verification that each spray additive automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to its correct position on an actual or simulated actuation signal. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from this test. Removal of the Containment Pressure - High High signal reference is discussed in DOC LA.3.

The purpose of CTS 4.6.2.2.c is to verify that appropriate valves automatically actuate when they receive 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. Proper position of valves is verified before they are locked, sealed, or otherwise secured in position.

Administrative controls verify these valves are in their correct position before being locked, sealed, or otherwise secured, so they are not required to actuate on an actuation signal, and verification of their actuation is not required. The verification is to test that they actuate to their correct position, but these valves already are in their correct position. 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.3 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

Unit 2 CTS 4.6.2.2.c requires verification of the automatic actuation of the Spray Additive System valves on a "test" signal. While Unit 1 CTS 4.6.2.2.c does not use the term "test," it is implied. ITS SR 3.6.7.4 specifies 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 4.6.2.2.c is to ensure the Spray Additive System valves 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 cannot 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 CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 11, Rev. 0, Page 202 of 494

Attachment 1, Volume 11, Rev. 0, Page 203 of 494 DISCUSSION OF CHANGES ITS 3.6.7, SPRAY ADDITIVE SYSTEM because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 11, Rev. 0, Page 203 of 494

Attachment 1, Volume 11, Rev. 0, Page 204 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 204 of 494

, Volume 11, Rev. 0, Page 205 of 494 , Volume 11, Rev. 0, Page 205 of 494

, Volume 11, Rev. 0, Page 206 of 494 , Volume 11, Rev. 0, Page 206 of 494

Attachment 1, Volume 11, Rev. 0, Page 207 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.7, SPRAY ADDITIVE SYSTEM

1. The headings for ISTS 3.6.7 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made.

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 11, Rev. 0, Page 207 of 494

Attachment 1, Volume 11, Rev. 0, Page 208 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 208 of 494

, Volume 11, Rev. 0, Page 209 of 494 , Volume 11, Rev. 0, Page 209 of 494

, Volume 11, Rev. 0, Page 210 of 494 , Volume 11, Rev. 0, Page 210 of 494

Attachment 1, Volume 11, Rev. 0, Page 211 of 494 B 3.6.7 2 INSERT 1 There are portions of the containment that are not sprayed (e.g., steam generator enclosures and pressurizer enclosure). In order to account for these unsprayed regions, the analysis assumes that removal of iodine takes place only in the sprayed regions, while mass transfer of iodine from unsprayed to sprayed regions accounts for the decrease in the iodine concentration in the unsprayed regions Insert Page B 3.6.7-2 Attachment 1, Volume 11, Rev. 0, Page 211 of 494

, Volume 11, Rev. 0, Page 212 of 494 , Volume 11, Rev. 0, Page 212 of 494

, Volume 11, Rev. 0, Page 213 of 494 , Volume 11, Rev. 0, Page 213 of 494

Attachment 1, Volume 11, Rev. 0, Page 214 of 494 B 3.6.7 6 INSERT 2 This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves.

Insert Page B 3.6.7-4 Attachment 1, Volume 11, Rev. 0, Page 214 of 494

, Volume 11, Rev. 0, Page 215 of 494 , Volume 11, Rev. 0, Page 215 of 494

Attachment 1, Volume 11, Rev. 0, Page 216 of 494 B 3.6.7 2 INSERT 3 The test is performed by verifying the flow rate from the spray additive tank test line to each Containment Spray System train with each containment spray pump operating in the recirculation mode.

Insert Page B 3.6.7-5 Attachment 1, Volume 11, Rev. 0, Page 216 of 494

Attachment 1, Volume 11, Rev. 0, Page 217 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.7 BASES, SPRAY ADDITIVE SYSTEM

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

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 were made to the ISTS Required Action A.1 Bases to modify the reference to the Containment Spray System and move it to the end of the paragraph. The ISTS Bases states that the Containment Spray System would still be available and would remove some iodine from the containment atmosphere in the event of a DBA.

This statement may not always be true since both Containment Spray Systems could be inoperable while also operating within ISTS 3.6.7 ACTION A.

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

B 3.6.6).

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

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

B 3.7.5, B 3.7.6, and B 3.7.8).

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 217 of 494

Attachment 1, Volume 11, Rev. 0, Page 218 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 218 of 494

Attachment 1, Volume 11, Rev. 0, Page 219 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.7, SPRAY ADDITIVE SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 219 of 494

, Volume 11, Rev. 0, Page 220 of 494 ATTACHMENT 8 ITS 3.6.8, Hydrogen Recombiners , Volume 11, Rev. 0, Page 220 of 494

, Volume 11, Rev. 0, Page 221 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 221 of 494

Attachment 1, Volume 11, Rev. 0, Page 222 of 494 ITS 3.6.8 A.1 ITS LA.1 LCO 3.6.8 Add proposed Required Action A.1 Note L.1 ACTION A ACTION C Add proposed ACTION B L.2 24 L.3 SR 3.6.8.1 LA.2 24 L.3 L.4 SR 3.6.8.2 LA.2 SR 3.6.8.1 LA.2 SR 3.6.8.3 LA.2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 222 of 494

Attachment 1, Volume 11, Rev. 0, Page 223 of 494 ITS 3.6.8 A.1 ITS LA.1 LCO 3.6.8 Add proposed Required Action A.1 Note L.1 ACTION A ACTION C Add proposed ACTION B L.2 24 L.3 SR 3.6.8.1 LA.2 24 L.3 L.4 SR 3.6.8.2 LA.2 SR 3.6.8.1 LA.2 SR 3.6.8.3 LA.2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 223 of 494

Attachment 1, Volume 11, Rev. 0, Page 224 of 494 DISCUSSION OF CHANGES ITS 3.6.8, HYDROGEN RECOMBINERS 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 LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.4.2 states that two "independent" containment hydrogen recombiner systems shall be OPERABLE. ITS 3.6.8 also states that two hydrogen recombiners shall be OPERABLE, but does not specify that the hydrogen recombiners are "independent." This changes the CTS by moving the detail that the hydrogen recombiners are "independent" to the Bases.

The removal of this detail, which is 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 two hydrogen recombiners shall 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 4.6.4.2.a, CTS 4.6.4.2.b.2, CTS 4.6.4.2.b.3, and CTS 4.6.4.2.b.4 include details for performance of functional tests, a resistance to ground test, and a visual examination. ITS SR 3.6.8.1, ITS SR 3.6.8.2, and ITS SR 3.6.8.3 together require that each of these three types of tests be performed. This changes CTS by moving the detail of how these tests are performed to the Bases.

CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 224 of 494

Attachment 1, Volume 11, Rev. 0, Page 225 of 494 DISCUSSION OF CHANGES ITS 3.6.8, HYDROGEN RECOMBINERS 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 functional test, visual examination, and resistance to ground test.

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 13 - Addition of LCO 3.0.4 Exception) CTS 3.6.4.2 states, in part, that with one hydrogen recombiner 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 a hydrogen recombiner inoperable. ITS 3.6.8 Required Action A.1 specifies the same requirements as the CTS, except ITS Required Action A.1 Note states that "LCO 3.0.4 is not applicable." This changes the CTS by allowing entry into the MODE of Applicability with one hydrogen recombiner system inoperable.

The purpose of CTS 3.6.4.2 is to provide the capability for controlling bulk hydrogen concentration in containment to less than the lower flammable concentration following a design basis accident (DBA). 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 hydrogen recombiner inoperable. If the hydrogen recombiner is not restored to OPERABLE status within 30 days, the unit must be shutdown. During this time period the other hydrogen recombiner must be OPERABLE. Therefore, the capability for controlling bulk hydrogen concentration in containment to less than the lower flammable concentration following a DBA is maintained. This change is designated as less restrictive because the Required Action Note allows entry into the MODE of Applicability with one inoperable hydrogen recombiner system.

L.2 (Category 3 - Relaxation of Completion Time) CTS 3.6.4.2 does not provide an Action for two inoperable hydrogen recombiners. Thus, CTS 3.0.3 is required to be entered when both hydrogen recombiners are inoperable. ITS 3.6.8 ACTION B requires that with two hydrogen recombiners inoperable, to verify by administrative means that the hydrogen control function is maintained within one hour, and to restore one hydrogen recombiner to OPERABLE status within CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 225 of 494

Attachment 1, Volume 11, Rev. 0, Page 226 of 494 DISCUSSION OF CHANGES ITS 3.6.8, HYDROGEN RECOMBINERS 7 days. A shutdown is only required if the hydrogen control function is not maintained within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or if one hydrogen recombiner is not restored to OPERABLE status within 7 days. This changes the CTS by allowing both hydrogen recombiners to be inoperable for 7 days, provided the hydrogen control function is maintained, prior to requiring a unit shutdown, instead of entering CTS 3.0.3 immediately.

The purpose of CTS 3.6.4.2 is to provide the capability for controlling bulk hydrogen concentration in containment to less than the lower flammable concentration following a Design Basis Accident. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the alternate hydrogen control function. 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 allows 7 days to restore at least one inoperable hydrogen recombiner to OPERABLE status when both hydrogen recombiners are inoperable, instead of entering LCO 3.0.3. The criteria for allowing this additional restoration time verifies that an alternate means of performing the hydrogen control function is available. The alternate means of performing the hydrogen control function is described in letter AEP:NRC:00500, dated January 12, 1981. The description explains that the alternate means of hydrogen control ensures that failure of both recombiner systems will not leave the containment without hydrogen control capability.

Seven days is a reasonable time to allow two hydrogen recombiners to be inoperable because the hydrogen control function is maintained and because of the low probability of a LOCA that would generate hydrogen in the amounts capable of exceeding the flammability limit. 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 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.6.4.2.a requires the performance of a recombiner functional test to ensure the minimum heater sheath temperatures increase to

> 700°F within 90 minutes and is maintained for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

CTS 4.6.4.2.b.3 requires the performance of a recombiner system functional test to ensure the heater sheath temperatures increase to > 1200°F within 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and is maintained for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 4.6.4.2.b.2 requires the verification through visual examination that there is no evidence of abnormal conditions within the recombiners. CTS 4.6.4.2.b.4 requires the verification of the integrity of all heater electrical circuits by performing a continuity and resistance to ground test following the required functional tests. These tests are required to be performed every 18 months. ITS SR 3.6.8.1, SR 3.6.8.2, and SR 3.6.8.3 require the same testing requirements, however the Surveillance Frequency has been changed to 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 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 226 of 494

Attachment 1, Volume 11, Rev. 0, Page 227 of 494 DISCUSSION OF CHANGES ITS 3.6.8, HYDROGEN RECOMBINERS The purpose of CTS 4.6.4.2 is to verify the OPERABILITY of the containment hydrogen recombiner systems. 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 containment hydrogen recombiners is acceptable because the containment hydrogen recombiners are designed to be single failure proof, therefore ensuring system availability in the event of a failure of one hydrogen recombiner. Based on the inherent system and component reliability, the impact, if any, from this change on system availability is minimal.

The review of historical surveillance data revealed that there were a number of tests indicated as failures. These failures were reviewed and there were no failures indicative of a time-based failure mechanism 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 5 - Deletion of Surveillance Requirement) CTS 4.6.4.2.b.1 requires performing a CHANNEL CALIBRATION of all instrumentation and control circuits on each hydrogen recombiner once per 18 months. ITS 3.6.8 does not include this requirement. This changes the CTS by deleting a Surveillance Requirement.

The purpose of CTS 4.6.4.2.b.1 is to verify that the hydrogen recombiner instrumentation and control circuits respond correctly to known inputs. This change is acceptable because the deleted Surveillance Requirement is not necessary to be in Technical Specifications 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. The requirement to perform the functional test, visual examination, and resistance to ground test is retained and is adequate to verify that each hydrogen recombiner will perform its function when required. The hydrogen recombiners are manually initiated since flammable limits would not be reached until several days after a DBA. A CHANNEL CALIBRATION is still required as part of ITS 3.3.3 for the hydrogen analyzers, which are used to determine when to manually initiate the hydrogen recombiners. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 227 of 494

Attachment 1, Volume 11, Rev. 0, Page 228 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 228 of 494

, Volume 11, Rev. 0, Page 229 of 494 , Volume 11, Rev. 0, Page 229 of 494

, Volume 11, Rev. 0, Page 230 of 494 , Volume 11, Rev. 0, Page 230 of 494

Attachment 1, Volume 11, Rev. 0, Page 231 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.8, HYDROGEN RECOMBINERS

1. The headings for ISTS 3.6.8 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual (if permanently installed)). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made.

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

3. The hydrogen control function is maintained by one train of the Distributed Ignition System, one train of the Containment Spray System, and one train of the Containment Air Recirculation/Hydrogen Skimmer System, which are in the ITS.

Therefore, as discussed in the second Reviewer's Note to Bases ACTIONS B.1 and B.2, the periodic 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months verification is not required.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 231 of 494

Attachment 1, Volume 11, Rev. 0, Page 232 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 232 of 494

, Volume 11, Rev. 0, Page 233 of 494 , Volume 11, Rev. 0, Page 233 of 494

, Volume 11, Rev. 0, Page 234 of 494 , Volume 11, Rev. 0, Page 234 of 494

, Volume 11, Rev. 0, Page 235 of 494 , Volume 11, Rev. 0, Page 235 of 494

, Volume 11, Rev. 0, Page 236 of 494 , Volume 11, Rev. 0, Page 236 of 494

, Volume 11, Rev. 0, Page 237 of 494 , Volume 11, Rev. 0, Page 237 of 494

, Volume 11, Rev. 0, Page 238 of 494 , Volume 11, Rev. 0, Page 238 of 494

, Volume 11, Rev. 0, Page 239 of 494 , Volume 11, Rev. 0, Page 239 of 494

, Volume 11, Rev. 0, Page 240 of 494 , Volume 11, Rev. 0, Page 240 of 494

Attachment 1, Volume 11, Rev. 0, Page 241 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.8 BASES, HYDROGEN RECOMBINERS

1. Changes are made to be consistent with the changes made to the Specification.

2. 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.

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. The statement in the Applicable Safety Analyses Section concerning the design of the Hydrogen Purge System, which is a backup to the hydrogen recombiners (ISTS only), has been deleted since it is not appropriate to be discussed in this section of the Bases. The backup is discussed in the Bases for ACTIONS B.1 and B.2, since Required Action B.1 requires a backup to be maintained.

6. Reviewers Notes are deleted.

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

8. The words in the ISTS do not convey the complete intent of the actual ISTS Condition and when the Condition should be entered. Therefore, to be consistent with the actual ISTS Condition words, the Bases have been modified.

9. Changes have been made to be consistent with the ISTS Required Action.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 241 of 494

Attachment 1, Volume 11, Rev. 0, Page 242 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 242 of 494

Attachment 1, Volume 11, Rev. 0, Page 243 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.8, HYDROGEN RECOMBINERS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 243 of 494

, Volume 11, Rev. 0, Page 244 of 494 ATTACHMENT 9 ITS 3.6.9, Distributed Ignition System , Volume 11, Rev. 0, Page 244 of 494

, Volume 11, Rev. 0, Page 245 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 245 of 494

Attachment 1, Volume 11, Rev. 0, Page 246 of 494 ITS 3.6.9 A.1 ITS LCO 3.6.9 Add second part of LCO 3.6.9 L.1 ACTION A A.2 ACTION B ACTION C SR 3.6.9.1 LA.1 184 L.3 SR 3.6.9.2 L.1 SR 3.6.9.3 24 L.2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 246 of 494

Attachment 1, Volume 11, Rev. 0, Page 247 of 494 ITS 3.6.9 A.1 ITS LCO 3.6.9 Add second part of LCO 3.6.9 L.1 ACTION A A.2 ACTION B ACTION C SR 3.6.9.1 LA.1 184 SR 3.6.9.2 L.3 L.1 SR 3.6.9.3 24 L.2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 247 of 494

Attachment 1, Volume 11, Rev. 0, Page 248 of 494 DISCUSSION OF CHANGES ITS 3.6.9, DISTRIBUTED IGNITION SYSTEM (DIS)

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 3.6.4.3 Action b requires the performance of the Surveillance Requirement 4.6.4.3.a once per 7 days on the OPERABLE train until the inoperable train is restored to OPERABLE status. ITS 3.6.9 Required Action A.2 requires the performance of SR 3.6.9.1 on the OPERABLE train once per 7 days under the same conditions. This changes the CTS by deleting the detail that the Surveillance Requirement must be performed until the inoperable train is restored to OPERABLE status.

The purpose of CTS 3.6.4.3 Action b is to ensure the Surveillance Requirement is performed once per 7 days as long as the unit is operating in the Actions. ITS LCO 3.0.2 states that if the LCO is met prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. Since the requirement of CTS 3.6.4.3 Action b is stated in ITS LCO 3.0.2 and it is applicable to ITS 3.6.9, the explicit statement in the Required Action is not necessary. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.6.4.3.a requires the energization of the supply breakers to each train of the Distributed Ignition System (DIS) and the verification that at least 34 of 35 ignitors are energized. ITS SR 3.6.9.1 does not specify the total numbers of ignitors (i.e., 35). This changes the CTS by moving details of the total number of ignitors 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 CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 248 of 494

Attachment 1, Volume 11, Rev. 0, Page 249 of 494 DISCUSSION OF CHANGES ITS 3.6.9, DISTRIBUTED IGNITION SYSTEM (DIS) protection of public health and safety. The ITS still retains the requirement to energize each DIS train power supply breaker and verify > 34 ignitors are energized in each train. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS 3.6.4.3 requires both trains of the Distributed Ignition System (DIS) to be OPERABLE. CTS 4.6.4.3.b requires verification that each DIS train have at least one OPERABLE hydrogen ignitor in each region. Thus, this Surveillance Requirement effectively defines that OPERABILITY of a DIS train includes one hydrogen ignitor per containment region. ITS 3.6.9 requires both Distributed Ignition System trains to be OPERABLE and that each containment region shall have at least one OPERABLE hydrogen ignitor. ITS SR 3.6.9.2 also requires verification that at least one hydrogen ignitor is OPERABLE in each containment region. This changes the CTS by requiring only one OPERABLE hydrogen ignitor in each containment region, instead of the current requirement of one OPERABLE hydrogen ignitor per DIS train in each containment region.

The purpose of CTS 3.6.4.3 is to that the hydrogen in the containment can be burned in a controlled manner. This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When one DIS train does not have an OPERABLE hydrogen ignitor in a containment region, the other DIS train is still providing an OPERABLE hydrogen ignitor in the containment region. This remaining hydrogen ignitor is capable of burning the hydrogen in the associated containment region in a controlled manner. In addition, if during a DBA this remaining hydrogen ignitor fails, there would always be ignition capability in the adjacent containment regions that would provide redundant capability by flame propagation to the containment region with no OPERABLE hydrogen ignitors.

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 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.6.4.3.c requires verification that the temperature of each ignitor is a minimum of 1700°F every 18 months. ITS SR 3.6.9.3 requires the same verification every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 249 of 494

Attachment 1, Volume 11, Rev. 0, Page 250 of 494 DISCUSSION OF CHANGES ITS 3.6.9, DISTRIBUTED IGNITION SYSTEM (DIS)

The purpose of CTS 4.6.4.3.c is to ensure the surface temperature of each glow plug is measured to be greater than 1700°F to demonstrate that a temperature sufficient for ignition is achieved. 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 DIS temperature verification is acceptable because the DIS is verified to OPERABLE during the cycle by energizing the supply breakers and verifying at least 34 ignitors are energized. The DIS is a relatively simple, manually initiated system that does not interface or interact with other systems and is only dependent on power to operate. Thus, there are limited failure mechanisms that could impact the system. The primary operating element associated with the DIS is analogous to a glow plug that provides a localized ignition source for the hydrogen generated in the containment following certain accidents. Additional justification for extending the Surveillance test interval is that the DIS is designed to be single failure proof, therefore ensuring system availability in the event of a failure of one DIS train. Based on the inherent system and component simplicity and reliability, testing during the cycle, system redundancy, and results of the failure analysis evaluation, 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.3 (Category 9 - Surveillance Frequency Change Using GL 91-04 Guidelines, Non-24 Month Type Change) CTS 4.6.4.3.a requires energizing the supply breakers and verifying at least 34 ignitors per train are energized and CTS 4.6.4.3.b requires verifying at least one hydrogen ignitor per train is OPERABLE in each containment region. These tests are required every 92 days. ITS SR 3.6.9.1 and SR 3.6.9.2 require the performance of similar Surveillances (as modified by DOC L.1), but at a Frequency of 184 days. This changes the CTS by extending the Frequency of the Surveillances 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 purpose of CTS 4.6.4.3.a and b is to ensure the Distributed Ignition System will function as designed during an analyzed event. An evaluation of the surveillance interval extension was performed, based on the same approach described in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 250 of 494

Attachment 1, Volume 11, Rev. 0, Page 251 of 494 DISCUSSION OF CHANGES ITS 3.6.9, DISTRIBUTED IGNITION SYSTEM (DIS) 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 these Surveillances is acceptable because the Distributed Ignition System is a relatively simple, manually initiated system that does not interface or interact with other systems and is only dependent on electrical power to operate.

Thus there are limited failure mechanisms that could impact the system. The primary operating element associated with the Distributed Ignition System is analogous to a glow plug that provides a localized ignition source for the hydrogen generated in the containment following certain accidents. In addition, there are two independent and redundant trains, each of which is fully capable of performing the required safety function. The surveillance history was reviewed and did not indicate any failures that would impact the ability of the system to carry out its required safety function. Therefore, based on the inherent system and component simplicity and reliability, system redundancy, and the results of the failure analysis evaluation, 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 will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 251 of 494

Attachment 1, Volume 11, Rev. 0, Page 252 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 252 of 494

, Volume 11, Rev. 0, Page 253 of 494 , Volume 11, Rev. 0, Page 253 of 494

, Volume 11, Rev. 0, Page 254 of 494 , Volume 11, Rev. 0, Page 254 of 494

, Volume 11, Rev. 0, Page 255 of 494 , Volume 11, Rev. 0, Page 255 of 494

Attachment 1, Volume 11, Rev. 0, Page 256 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.9, DISTRIBUTED IGNITION SYSTEM (DIS)

1. The ISTS 3.6.10 title Hydrogen Ignition System has been changed to Distributed Ignition System consistent with the CNP site specific terminology. The headings for ISTS 3.6.10 include the parenthetical expression (Ice Condenser). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specifications to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made. In addition, the CNP design does not include the Hydrogen Mixing System. Therefore, ISTS 3.6.9 is not included in the ITS and ISTS 3.6.10 is renumbered as ITS 3.6.9.

2. 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 at least one hydrogen ignitor to be OPERABLE in each containment region.

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 one ignitor is inoperable in each train and the inoperable ignitors are in the same containment region, the LCO is still met. Thus, ACTION B 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.

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

4. The Frequency of ITS SR 3.6.9.1 and SR 3.6.9.2 has been changed from 92 days to 184 days. The technical justification for this change is consistent with the guidelines of Generic Letter 91-04, and is discussed in ITS 3.6.9 DOC L.3.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 256 of 494

Attachment 1, Volume 11, Rev. 0, Page 257 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 257 of 494

, Volume 11, Rev. 0, Page 258 of 494 , Volume 11, Rev. 0, Page 258 of 494

, Volume 11, Rev. 0, Page 259 of 494 , Volume 11, Rev. 0, Page 259 of 494

, Volume 11, Rev. 0, Page 260 of 494 , Volume 11, Rev. 0, Page 260 of 494

, Volume 11, Rev. 0, Page 261 of 494 , Volume 11, Rev. 0, Page 261 of 494

, Volume 11, Rev. 0, Page 262 of 494 , Volume 11, Rev. 0, Page 262 of 494

, Volume 11, Rev. 0, Page 263 of 494 , Volume 11, Rev. 0, Page 263 of 494

, Volume 11, Rev. 0, Page 264 of 494 , Volume 11, Rev. 0, Page 264 of 494

Attachment 1, Volume 11, Rev. 0, Page 265 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.9 BASES, DISTRIBUTED IGNITION SYSTEM (DIS)

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

2. 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, while the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2, there is no specific PSDC concerning containment atmosphere cleanup (hydrogen). Therefore, Bases references to the 10 CFR 50, Appendix A criteria have been deleted.

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

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

5. Typographical/grammatical error corrected.

6. The words in the ISTS do not convey the complete intent of the actual ISTS Condition and when the Condition should be entered. Therefore, to be consistent with the actual ISTS Condition words, the Bases have been modified.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 265 of 494

Attachment 1, Volume 11, Rev. 0, Page 266 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 266 of 494

Attachment 1, Volume 11, Rev. 0, Page 267 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.9, DISTRIBUTED IGNITION SYSTEM (DIS)

There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 267 of 494

, Volume 11, Rev. 0, Page 268 of 494 ATTACHMENT 10 ITS 3.6.10, CEQ System , Volume 11, Rev. 0, Page 268 of 494

, Volume 11, Rev. 0, Page 269 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 269 of 494

Attachment 1, Volume 11, Rev. 0, Page 270 of 494 ITS 3.6.10 A.1 ITS LA.1 LCO 3.6.10 ACTION A ACTION B L.1 actual or simulated L.2 SR 3.6.10.1, LA.2 SR 3.6.10.4 actual L.2 or simulated signal SR 3.6.10.2 SR 3.6.10.3 L.3 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 270 of 494

Attachment 1, Volume 11, Rev. 0, Page 271 of 494 ITS 3.6.10 A.1 ITS LA.1 LCO 3.6.10 72 L.4 ACTION A ACTION B L.1 actual or simulated L.2 SR 3.6.10.1, LA.2 SR 3.6.10.4 actual L.2 or simulated signal SR 3.6.10.2 SR 3.6.10.3 L.3 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 271 of 494

Attachment 1, Volume 11, Rev. 0, Page 272 of 494 DISCUSSION OF CHANGES ITS 3.6.10, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ)

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.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.5.6 requires two "independent" containment air recirculation systems (referred to as the Containment Air Recirculation/Hydrogen Skimmer (CEQ) System in the ITS) to be OPERABLE. ITS 3.6.10 requires two Containment Air Recirculation/Hydrogen Skimmer (CEQ) trains to be OPERABLE, but does not specify that the trains are "independent." This changes the CTS by moving the detail that the trains are "independent" 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 two Containment Air Recirculation/Hydrogen Skimmer (CEQ) trains shall 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 the Bases 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 4.6.5.6.a requires verification that the motor operated valve in the suction line to the containments lower compartment opens "when the return air fan starts." ITS SR 3.6.10.4 requires verification that the CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 272 of 494

Attachment 1, Volume 11, Rev. 0, Page 273 of 494 DISCUSSION OF CHANGES ITS 3.6.10, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ)

SYSTEM motor operated valve in the suction line to the containment lower compartment opens on an "actual" or simulated actuation signal. ITS SR 3.6.10.4 does not specify the name of the actual signal, but specifies an actual actuation signal.

This changes the CTS by moving the type of actuation signal to the Bases. The change to allow a simulated signal is discussed in DOC L.2.

The removal of this detail 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. The ITS still retains the requirement that appropriate valves actuate on an actuation signal. Also, this change is acceptable because this type of procedural detail 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 the Bases 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.5.6 states that each Containment Air Recirculation System shall be demonstrated OPERABLE at least once per 3 months "on a STAGGERED TEST BASIS." The Surveillance Frequency for ITS SR 3.6.10.1, SR 3.6.10.2, SR 3.6.10.3, and SR 3.6.10.4 is also 92 days, but does not include the "STAGGERED TEST BASIS" requirement. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of CTS 4.6.5.6 is to demonstrate the OPERABILITY of the Containment Air Recirculation System. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested.

A number of studies have been performed which have demonstrated that staggered testing has negligible impact on component reliability. These analytical and subjective analyses have determined that staggered testing 1) is operationally difficult, 2) has negligible impact on component reliability, 3) is not as significant as initially thought, 4) has no impact on failure frequency, 5) introduces additional stress on components such as DGs potentially causing increased component failures rates and component wearout, 6) results in reduced redundancy testing, and 7) increases likelihood of human error by increasing testing intervals. Therefore, the Containment Air Recirculation System staggered testing requirements have been deleted. This change is designated as less restrictive because the intervals between performances of the Surveillances for the two trains can be larger or smaller under the ITS than under the CTS.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 273 of 494

Attachment 1, Volume 11, Rev. 0, Page 274 of 494 DISCUSSION OF CHANGES ITS 3.6.10, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ)

SYSTEM L.2 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.5.6.a requires verification of the automatic actuation of the return air fan on an auto-start signal (i.e., simulated) and that the motor operated valve in the suction line to the containments lower compartment opens when the return air fan starts (i.e., an actual signal). ITS SR 3.6.10.1 requires verification that each Containment Air Recirculation/Hydrogen Skimmer (CEQ) System fan starts on an "actual" or simulated actuation signal. ITS SR 3.6.10.4 requires verification that the motor operated valve in the suction line to the containment lower compartment opens on an actual or "simulated" actuation signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test. The change from "when the return air fans starts" to "actual" signal is discussed in DOC LA.2.

The purpose of CTS 4.6.5.6.a is to ensure that the CEQ System fan starts and the motor operated valve moves to the correct position 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 cannot discriminate between an "actual" or "simulated" 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.

L.3 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.5.6.d requires the return air fan to be manually started from the control room, and to verify the motor operated valve in the suction line to the containment's lower compartment opens when the return air fan starts. The ITS does not include this requirement.

This changes the CTS by deleting a Surveillance Requirement.

The purpose of CTS 4.6.5.6.d is to confirm that the CEQ System can be manually initiated from the control room. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify the equipment used to meet the LCO can perform its required safety function. 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 manual initiation test has been deleted. The CEQ System is assumed to initiate automatically in response to a containment high pressure signal. Manual initiation is not assumed. This change is designated as less restrictive because the Surveillance which is required in the CTS will not be required in the ITS.

L.4 (Category 3 - Relaxation of Completion Time) (Unit 2 only) CTS 3.6.5.6 Action states that with one CEQ train inoperable, restore the inoperable train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.6.10 Required Action A.1 states to restore the inoperable CEQ train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months under the same conditions. This changes the Unit 2 CTS by extending the Completion Time for restoration of an inoperable CEQ Train from 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 274 of 494

Attachment 1, Volume 11, Rev. 0, Page 275 of 494 DISCUSSION OF CHANGES ITS 3.6.10, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ)

SYSTEM The purpose of the CTS 3.6.5.6 Action is to provide an adequate period of time to restore an inoperable CEQ Train to OPERABLE status. 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 Completion Time for restoration of an inoperable CEQ Train has been extended from 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This proposed time is also consistent with the time to restore an inoperable CEQ train in the Unit 1 Technical Specifications. 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 Unit 2 CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 275 of 494

Attachment 1, Volume 11, Rev. 0, Page 276 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 276 of 494

, Volume 11, Rev. 0, Page 277 of 494 , Volume 11, Rev. 0, Page 277 of 494

Attachment 1, Volume 11, Rev. 0, Page 278 of 494 3.6.10 4 INSERT 1

-NOTE-Only required to be met in MODES 1, 2, and 3.

3 INSERT 2 Verify, with the return air fan discharge backdraft damper locked closed and the fan motor energized, the static pressure between the fan discharge and the backdraft damper is 4.0 inches water gauge.

Insert Page 3.6.14-1 Attachment 1, Volume 11, Rev. 0, Page 278 of 494

, Volume 11, Rev. 0, Page 279 of 494 , Volume 11, Rev. 0, Page 279 of 494

, Volume 11, Rev. 0, Page 280 of 494 3.6.10 4 INSERT 3

-NOTE-Only required to be met in MODES 1, 2, and 3.

Insert Page 3.6.14-2 , Volume 11, Rev. 0, Page 280 of 494

Attachment 1, Volume 11, Rev. 0, Page 281 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.10, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ)

SYSTEM

1. The ISTS 3.6.14 title "Air Return System (ARS)" has been changed to "Containment Air Recirculation/Hydrogen Skimmer (CEQ) System" consistent with the CNP site specific terminology. The headings for ISTS 3.6.14, include the parenthetical expression (Ice Condenser). This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specifications to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made. In addition, many Containment Specifications in the NUREG are not included in the CNP ITS due to design differences. Therefore, ISTS 3.6.14 is renumbered as ITS 3.6.10.

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

3. ISTS SR 3.6.14.2 has been replaced with ITS SR 3.6.10.2. This proposed Surveillance is consistent with the current licensing basis. The purpose of ISTS SR 3.6.14.2 is to confirm the operating condition of the fans, which is indicative of overall fan motor performance. The proposed Surveillance performs the same function.

4. The Applicability of ISTS SR 3.6.14.1 and SR 3.6.14.4 (ITS SR 3.6.10.1 and SR 3.6.10.4) has been modified to only require the Surveillances to be met in MODES 1, 2, and 3. This allowance is consistent with the current licensing basis in CTS 4.6.5.6.a. Also, this is acceptable since ISTS 3.3.2 (ITS 3.3.2) does not require the automatic initiation Functions to be OPERABLE in MODE 4, and while ISTS 3.3.2 (ITS 3.3.2) requires the Manual Initiation Function to be OPERABLE in MODE 4, the performance of a TADOT every 24 months is required and this will ensure the Manual Initiation Function is OPERABLE in MODE 4.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 281 of 494

Attachment 1, Volume 11, Rev. 0, Page 282 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 282 of 494

, Volume 11, Rev. 0, Page 283 of 494 , Volume 11, Rev. 0, Page 283 of 494

Attachment 1, Volume 11, Rev. 0, Page 284 of 494 B 3.6.10 2

INSERT 1 The CEQ fans are automatically started by the Containment Pressure - High signal in approximately 2 minutes after the containment pressure reaches the pressure setpoint.

This also supports the required ice melt during a small break loss of coolant accident (LOCA) to ensure adequate containment recirculation sump inventory for initiation of the recirculation mode. The hydrogen skimmer header isolation valve opens when the CEQ System fan starts.

2 INSERT 1A the core reflood time assumed in the LOCA peak clad temperature analysis is met.

Insert Page B 3.6.14-1 Attachment 1, Volume 11, Rev. 0, Page 284 of 494

, Volume 11, Rev. 0, Page 285 of 494 , Volume 11, Rev. 0, Page 285 of 494

, Volume 11, Rev. 0, Page 286 of 494 , Volume 11, Rev. 0, Page 286 of 494

, Volume 11, Rev. 0, Page 287 of 494 , Volume 11, Rev. 0, Page 287 of 494

, Volume 11, Rev. 0, Page 288 of 494 , Volume 11, Rev. 0, Page 288 of 494

Attachment 1, Volume 11, Rev. 0, Page 289 of 494 B 3.6.10 1 INSERT 3 This SR has been modified by a Note that states that this Surveillance is only required to be met in MODES 1, 2, and 3. This allowance is necessary since the specified delay (i.e., > 108 seconds and < 132 seconds) is only applicable to the automatic actuation signal (i.e., Containment Pressure - High), which is only required to be OPERABLE in MODES 1, 2, and 3. In addition, LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," requires the CEQ System Manual Initiation Function to be OPERABLE in MODE 4 and requires the performance of a TADOT every 24 months. This requirement will ensure the Manual Initiation Function can actuate the required equipment in MODE 4.

1 INSERT 4 Verifying, with the return air fan discharge backdraft damper locked closed and the fan motor energized, the static pressure between the fan discharge and the backdraft damper is 4.0 inches water gauge confirms one operating condition of the fan. This test is indicative of overall fan motor performance. Such tests confirm component OPERABLITY and detect incipient failures by indicating abnormal performance.

Insert Page B 3.6.14-4 Attachment 1, Volume 11, Rev. 0, Page 289 of 494

, Volume 11, Rev. 0, Page 290 of 494 , Volume 11, Rev. 0, Page 290 of 494

Attachment 1, Volume 11, Rev. 0, Page 291 of 494 B 3.6.10 1 INSERT 5 This SR has been modified by a Note that states that this Surveillance is only required to be met in MODES 1, 2, and 3. This allowance is acceptable since, in MODE 4, automatic operation is not required. LCO 3.3.2 requires only the CEQ System Manual Initiation Function to be OPERABLE in MODE 4 and requires the performance of a TADOT every 24 months. This requirement will ensure the Manual Initiation Function can actuate the required equipment in MODE 4.

Insert Page B 3.6.14-5 Attachment 1, Volume 11, Rev. 0, Page 291 of 494

Attachment 1, Volume 11, Rev. 0, Page 292 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.10 BASES, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ) SYSTEM

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

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

3. The CEQ fans are not automatically de-energized, but must be manually stopped after an automatic actuation. In addition, there is no current predetermined pressure value at which the fans are secured, post accident. Long term operation of the fans would be at the discretion of the plant evaluation team. Therefore, these statements have been deleted.

4. The ISTS 3.614 (ITS 3.6.10) Bases ASA section discussion of the inadvertent actuation of both the ARS and the Containment Spray System has been deleted since this incident does not describe how the system mitigates DBAs and is outside of the CNP current licensing basis to consider.

5. The word "required" has been deleted because there are only two trains of the CEQ System and both are required. This is consistent with the use of the word "required" in the ISTS.

6. 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 11, Rev. 0, Page 292 of 494

Attachment 1, Volume 11, Rev. 0, Page 293 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 293 of 494

Attachment 1, Volume 11, Rev. 0, Page 294 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.10, CONTAINMENT AIR RECIRCULATION/HYDROGEN SKIMMER (CEQ)

SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 294 of 494

, Volume 11, Rev. 0, Page 295 of 494 ATTACHMENT 11 ITS 3.6.11, Ice Bed , Volume 11, Rev. 0, Page 295 of 494

, Volume 11, Rev. 0, Page 296 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 296 of 494

Attachment 1, Volume 11, Rev. 0, Page 297 of 494 ITS 3.6.11 A.1 ITS Add proposed boron concentration upper limit M.1 LCO 3.6.11 SR 3.6.11.6 LA.1 SR 3.6.11.4 SR 3.6.11.1 SR 3.6.11.2 Add proposed total mass and zone requirements L.1 ACTION A ACTION B LA.2 SR 3.6.11.1 L.2 54 for SR 3.6.11.6 Add proposed SR SR 3.6.11.6 3.6.11.6 Note M.2 LA.1 SR 3.6.11.2 Add proposed boron concentration M.1 upper limit Add proposed total mass and zone requirements L.1 L.3 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 297 of 494

Attachment 1, Volume 11, Rev. 0, Page 298 of 494 ITS 3.6.11 A.1 ITS Add proposed total mass and zone requirements L.1 SR 3.6.11.2 SR 3.6.11.3 Add proposed ice mass L.1 requirement SR 3.6.11.2 SR 3.6.11.4 L.4 accumulation of ice on structural members comprising flow channels through the ice bed is

< 15% blockage of the L.1 total flow area for each safety analysis section L.4 SR 3.6.11.5 Add proposed ice basket wear/damage requirements L.1 Add proposed SR 3.7.11.7 M.3 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 298 of 494

Attachment 1, Volume 11, Rev. 0, Page 299 of 494 ITS 3.6.11 A.1 ITS Add proposed boron concentration upper limit M.1 LCO 3.6.11 SR 3.6.11.6 LA.1 SR 3.6.11.4 SR 3.6.11.1 SR 3.6.11.2 Add proposed total mass and zone requirements L.1 ACTION A ACTION B LA.2 SR 3.6.11.1 54 for SR 3.6.11.6 L.2 Add proposed SR 3.6.11.6 Note M.2 SR 3.6.11.6 LA.1 SR 3.6.11.2 Add proposed boron concentration M.1 upper limit Add proposed total mass and zone requirements L.1 L.3 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 299 of 494

Attachment 1, Volume 11, Rev. 0, Page 300 of 494 ITS 3.6.11 A.1 ITS Add proposed total mass and zone requirements L.1 SR 3.6.11.2 SR 3.6.11.3 Add proposed L.1 ice mass requirement SR 3.6.11.2 SR 3.6.11.4 L.4 accumulation of ice on structural members comprising flow channels through the ice bed is L.1

< 15% blockage of the total flow area for each safety analysis section L.4 SR 3.6.11.5 Add proposed ice basket wear/damage requirements L.1 Add proposed SR 3.7.11.7 M.3 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 300 of 494

Attachment 1, Volume 11, Rev. 0, Page 301 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED 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 M.1 CTS 3.6.5.1.a and CTS 4.6.5.1.b.1 specify a lower limit > 1800 ppm for stored ice boron concentration. ITS SR 3.6.11.6 specifies an upper and lower limit

(> 1800 ppm and < 2300 ppm) for stored boron concentration. This changes the CTS by adding an upper boron concentration limit for stored ice.

The purpose of the minimum boron concentration limit in CTS 3.6.5.1.a and CTS 4.6.5.1.b.1 is to assure reactor subcriticality in a post loss of coolant accident (LOCA) environment. The purpose of the new upper boron concentration limit is to assure the bounding value in the hot leg switchover timing calculation. This change is acceptable because the new limit will help assure the condenser ice boron concentration is within the limits assumed in the safety analysis. This change is designated as more restrictive, because it adds the upper limit to the ice condenser boron concentration requirements.

M.2 CTS 4.6.5.1.b.1 requires a chemical analyses to be performed on at least 9 representative samples of stored ice. ITS SR 3.6.11.6 requires a chemical analysis of the stored ice in at least one randomly selected ice basket from each ice condenser bay. This changes the CTS to require 24 samples (at least one randomly selected ice basket from each ice condenser bay) instead of requiring 9 representative samples.

The purpose of CTS 4.6.5.1.b.1 is to assure the chemical analyses is performed on a sufficient number of representative samples of stored ice. This change is acceptable because the proposed sampling requirement provides a better representation of the overall ice bed (i.e., at least one ice basket from each condenser bay instead of 9 representative samples). The change has been designated as more restrictive because it is more explicit on the sampling requirements and requires an increased number of ice bed samples for chemical analyses.

M.3 CTS 4.6.5.1 does not contain an explicit verification, by chemical analysis, that ice added to the ice condenser meets the boron concentration and pH requirements of CTS 3.6.5.1.a. ITS SR 3.6.11.7 requires this SR to be conducted during each ice addition. This changes the CTS by adding the ITS requirement of SR 3.6.11.7.

CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 11, Rev. 0, Page 301 of 494

Attachment 1, Volume 11, Rev. 0, Page 302 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED The purpose of ITS SR 3.6.11.7 is to ensure the initial ice fill and any subsequent ice additions meet the boron concentration and pH requirements of SR 3.6.11.6.

This SR is modified by a Note that allows the chemical analysis to be performed on either the liquid solution or on the resulting ice. If ice is obtained from offsite sources, the chemical analysis data must be obtained for the ice supplied. This change is acceptable because it provides additional assurance that the ice added is acceptable. This change is designated as more restrictive, because it adds a Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.5.1.a and 4.6.5.1.b.1 specify that the boron being used to meet the lower limit for stored ice boron concentration is in the form of sodium tetraborate and that the pH limit is normalized to 25°C. ITS SR 3.6.11.6 specifies an upper and lower limit (> 1800 ppm and < 2300 ppm) for stored boron concentration, but does not include the form of the boron (i.e., sodium tetraborate). ITS SR 3.6.11.6 also specifies the pH limit, but does not state that it is normalized to 25°C. This changes the CTS by moving the details that the boron must be in the form of sodium tetraborate and that the pH is normalized to 25°C to the Bases. The addition of the boron concentration upper limit is discussed in DOC M.1.

The removal of these details, which are related to system design limits, 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 3.6.11.6 still retains the requirement concerning the boron concentration limits and pH limits. 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 the Bases 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 limits is being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.5.1.a requires the verification that the maximum ice bed temperature is < 27°F using the ice bed temperature monitoring system. ITS SR 3.6.11.1 requires the verification that the maximum ice bed temperature is < 27°F. This changes the CTS by moving the detail concerning the system to be used to evaluate whether the ice bed temperature is

< 27°F to the Bases.

CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 11, Rev. 0, Page 302 of 494

Attachment 1, Volume 11, Rev. 0, Page 303 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED The removal of this detail for performing the Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify the maximum ice bed temperature is < 27°F. 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 the Bases 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 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 3.6.5.1.d and e requires that ice baskets contain at least 1144 lbs of ice and that there be 1944 ice baskets. CTS 4.6.5.1.b.2 requires weighing a sample of at least 144 ice baskets and verifying each ice basket contains 1144 lbs of ice (end of cycle). CTS 4.6.5.1.b.2 specifies the locations of the ice basket to be sampled and if any ice basket contains less than 1144 lbs of ice, additional ice baskets must be weighed. It also requires the weighed baskets to be divided into three sub-groups, with each sub-group averaging 1144 lbs of ice per ice basket.

Furthermore, a total ice weight of the 1944 baskets (2,222,000 lbs end of cycle) is also required to a 95% confidence level, and includes a maintenance allowance for mass determination accuracy. CTS 4.6.5.1.b.3 requires a verification, by a visual inspection of at least two flow passages per ice condenser bay, that the accumulation of frost or ice on the top deck floor grating, on the intermediate deck, and on flow passages between ice baskets and past lattice frames is restricted to a nominal thickness of 3/8 inches. If one flow passage per bay is found to have an accumulation of frost or ice greater than this thickness, a representative sample of 20 additional flow passages from the same bay shall be visually inspected. If these additional flow passages are found acceptable, the surveillance program may proceed considering the single deficiency as unique and acceptable. More than one restricted flow passage per bay is evidence of abnormal degradation of the ice condenser. CTS 4.6.5.1.d requires lifting (at least 12 feet) and visually inspecting the accessible portions of at least two ice baskets from each one-third of the ice condenser and verifying that the ice baskets are free of detrimental structural wear, cracks, corrosion or other damage. ITS SR 3.6.11.2 requires a verification of the total ice mass (2,200,000 lbs) by calculating the mass of stored ice in each of three radial zones by selecting, at random, 30 ice baskets in each zone. It also verifies each zone contains the required ice mass. ITS SR 3.6.11.3 requires a verification that each basket sampled in ITS SR 3.6.11.2 contains a minimum ice mass. ITS SR 3.6.11.4 requires a verification, by inspection, accumulation of ice on structural members comprising flow channels through the ice bed is < 15%

blockage of the total flow area for each safety analysis section. ITS SR 3.6.11.5 requires a visual inspection, for detrimental structural wear, cracks, corrosion, or other damage, two ice baskets from each group of bays (total of three groups).

The Bases for ITS SR 3.6.11.5 includes clarifying guidance that indicates the CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 11, Rev. 0, Page 303 of 494

Attachment 1, Volume 11, Rev. 0, Page 304 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED intent of the inspection is to perform an inspection of the full-length of the basket.

This changes the CTS in the following ways: for SR 3.6.11.2 - a) modifies the stored ice mass to 2,200,000 lbs by specifying the design basis value and removing the maintenance allowance for mass determination accuracy; and b) redefines the ice mass statistical sampling plan to include the entire ice bed (1944 baskets), divides the ice bed into three radial zones, and modifies the sample size to at least 30 baskets in each radial zone; for SR 3.6.11.3 - a) removes the reference to azimuthal distribution verification, and b) adds a new acceptance criteria value for minimum ice mass in each basket sampled by SR 3.6.11.2; and for SR 3.6.11.5 - a) removes the inherent reference to CTS 3.6.5.1.b.2 that provided the definition of azimuthal distribution, b) adds the current sampling distribution methodology directly to the SR for clarity, and c) removes the requirement to raise the ice basket at least 12 feet for the inspection.

The basic requirement for verification of ice condenser ice bed ice mass is to ensure a sufficient ice mass is available to provide a heat sink in the event of an energy release in containment from a loss-of-coolant accident (LOCA) or a steam line break (SLB). For these design basis accidents (DBAs), the ice would absorb energy and limit containment peak pressure and temperature during the accident transient. Limiting the pressure and temperature reduces the release of fission product radioactivity from containment to the environment in the event of a DBA.

The proposed change of the total stored ice mass (ITS SR 3.6.11.2) provides consistency with the design basis analysis. The acceptance criteria value is reduced by relocation of the mass determination accuracy to the Bases. The Bases state that the Surveillance is performed in the as-found condition (before ice bed maintenance and after ice bed sublimation). The current acceptance criteria value consists of the DBA analysis value and a one percent mass determination accuracy (weighing error) value, and the Surveillance is performed in the as-found condition (before ice bed maintenance and after ice bed sublimation for the cycle). The as-found performance of this Surveillance shows adequacy of total ice mass for the current operational cycle. As such, when the proposed SR change is coupled with the change to the SR Bases, there is no net change in total stored ice mass. Ice Condenser Utility Group (ICUG) operational history shows that sublimation rates vary within the ice bed requiring specific effort to maintain the ice bed mass inventory each outage. The ongoing process of monitoring the varying sublimation rates during the operating cycle and replenishing ice bed mass as needed is the basis for the Active Ice Mass Management (AIMM) concept. The maintenance effort (AIMM) restores the ice bed mass and distribution characteristics required for continued operation.

Therefore, the proposed change provides a clear tie to the design basis while crediting plant specific AIMM maintenance practices.

The proposed statistical sampling plan change (ITS SR 3.6.11.2) increases the parent population to include all ice baskets contained within the ice bed, stratifies that population into three radial zones that contain rows of ice baskets exhibiting similar characteristics, and requires at least 30 random sample ice baskets for ice mass verification in each radial zone. The stratified sampling allows sub-populations to be defined that have similar mean mass characteristics resulting in better estimates of total ice mass. A 30-ice basket random sample from each CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 11, Rev. 0, Page 304 of 494

Attachment 1, Volume 11, Rev. 0, Page 305 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED radial zone maintains a 95% confidence level for calculation of total stored ice.

The modified sampling methodology provides the validation of total ice mass and verification of ice mass distribution within the ice bed, in lieu of a limited azimuthal row-group Surveillance. The proposed ice bed sub-populations (radial zones) and sample size directly applies ICUG ice bed historical operating experience, provides clear linkage to statistical sampling methodology provided in NUREG-1475, "Applying Statistics," and supports validation of total stored ice for the long-term/overall DBA analysis.

The proposed change to remove limited azimuthal row-group ice distribution verification is replaced by the change in statistical sampling (ITS SR 3.6.11.3).

As stated above, the change in statistical sampling and crediting of AIMM processes provides inherent verification of ice mass distribution, making azimuthal row-group distribution verification redundant. A new minimum blowdown ice mass acceptance criteria value is added for each of the ice baskets sampled. The new acceptance criteria value (minimum blowdown ice mass for each basket sampled) ensures that an anomalous gross degradation of the ice bed does not exist, supports the DBA analysis during the blowdown phase, and directly applies the blowdown data from the original Westinghouse Waltz-Mill testing as described in the UFSAR.

The proposed change to the inspection of flow channels for accumulated ice (ITS SR 3.6.11.4) replaces the manner in which the inspection is performed and the acceptance criteria. The allowable 15% buildup of ice is based on the analysis of the sub-compartment response to a design basis LOCA with partial blockage of the ice condenser flow channels. The analysis did not perform detailed flow area modeling, but lumped the condenser bays into six sections ranging from 2.75 bays to 6.5 bays. Individual bays are acceptable with > 15% blockage, as long as 15% blockage is not exceeded for any analysis section. In addition, to provide a 95% confidence that flow blockage does not exceed the allowed 15%,

the visual inspection must be made for at least 54 (33%) of the 162 flow channels per bay.

The proposed change to the ice basket wear/damage SR (ITS SR 3.6.11.5) only provides clarification of the sampling methodology. Currently the Surveillance implicitly references the ice mass verification Surveillance for sampling methodology. Because the ice mass verification sampling methodology is proposed to change, the implicit reference is being removed and the current sampling methodology is completely defined.

The change to an 18 month Frequency for both the ice mass verification and the ice distribution SRs does not result in an overall reduction in the end-of-cycle ice mass. The process of replenishing the ice bed mass and the monitoring of varying sublimation rates during the operating cycle is the basis for AIMM. AIMM restores the ice bed mass and distribution characteristics required for continued operation. This includes sublimation allowances and ice mass determination accuracy. ICUG historical operating experience has shown that the ice condenser can meet and even exceed its design function without performing these Surveillances on a 9-month frequency. Additionally, this change in Frequency places performance of these SRs within the current time frame of the unit refueling outages.

CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 11, Rev. 0, Page 305 of 494

Attachment 1, Volume 11, Rev. 0, Page 306 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED Overall, ice condenser OPERABILITY is assured by numerous means during operation of the plant. The ice bed temperature is monitored at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to ensure temperatures are < 27°F (ITS SR 3.6.11.1). There are alarms in the control room that will indicate to the operator if any recorded temperature monitoring point within the ice bed approaches 27°F. The CNP staff performs walkdowns of the refrigeration system (chillers, air handling units, and glycol circulation pumps) to evaluate its ability to function. Inspections are required of intermediate deck doors to ensure they are not impaired. This activity ensures that no abnormal degradation of the ice condenser is occurring due to condensation or frozen drain lines in localized areas.

L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.5.1.b.1 requires the chemical analyses on the stored ice to be performed once every 18 months. ITS SR 3.6.11.6 requires the chemical analyses on the stored ice to be performed once every 54 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months to 54 months.

The purpose of CTS 4.6.5.1.b.1 is to ensure the boron concentration and pH of the stored ice is within the appropriate limits. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change extends the test from 18 months to 54 months. The change to 54 months is acceptable since the sodium tetraborate has been proven effective in maintaining the boron content for long storage periods, and it also enhances the ability of the solution to remove and retain fission product iodine. In addition, the change is acceptable since a new Surveillance has been added (SR 3.6.11.7) that requires a chemical analysis of any new ice added to the ice bed and a verification that the ice meets the boron concentration and pH limits of SR 3.6.11.6. The addition of this new Surveillance is discussed in DOC M.3. This change is designated as less restrictive because Surveillance will be performed less frequently under the ITS than under the CTS.

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

CTS 4.6.5.1.b.1 requires a verification by chemical analyses that the 9 representative samples of stored ice have a boron concentration of at least 1800 ppm and a pH of 9.0 to 9.5 at 25°C. ITS SR 3.6.11.6 requires the verification, by chemical analysis of the stored ice in at least one randomly selected ice basket from each ice condenser bay, that ice bed boron concentration is > 1800 ppm and < 2300 ppm and pH is > 9.0 and < 9.5. In addition, a Note is included that allows the boron concentration and pH values obtained from the individual samples to be averaged. This changes the CTS by allowing the chemical analysis to average the boron concentration and pH values of the samples instead of requiring each sample to meet the requirements. Other changes to CTS 4.6.5.1.b.1 are discussed in DOCs M.1, M.2, and LA.1.

The purpose of CTS 4.6.5.1.b.1 is to ensure the ice contains the appropriate boron concentration and pH so that when it melts after a DBA it meets the requirement for borated water for the ECCS recirculation mode of operation and for the Containment Spray mode. This change is acceptable because it has been CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 11, Rev. 0, Page 306 of 494

Attachment 1, Volume 11, Rev. 0, Page 307 of 494 DISCUSSION OF CHANGES ITS 3.6.11, ICE BED determined that the relaxed Surveillance Requirement acceptance criteria continues to ensure the ice bed can perform its required function. This change allows the chemical analysis results to be averaged in determining whether the boron concentration and pH limits are satisfied instead of evaluating each sample individually. The allowance to average the values is acceptable since during a DBA the ice would melt and mix with the reactor coolant to form a suction source in the containment recirculation sump. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.4 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.5.1.c requires a visual inspection every 18 months, of each ice condenser bay, to ensure the accumulation of frost or ice on the lower inlet plenum support structures and turning vanes is restricted to the specified thickness. CTS 4.6.5.1.b.3 requires the inspection of the top deck floor grating, on the intermediate deck and on flow passages between ice baskets and past lattice frames for accumulation of frost or ice. The ITS does not include these Surveillance Requirements; it only requires this inspection of the "flow channels," which includes the area between ice baskets, past lattice frames, and wall panels, as indicated in the Bases for ITS SR 3.6.11.4. This changes the CTS by deleting the requirement to inspect the top deck floor grating, the intermediate deck, and the lower support structures and turning vanes for accumulation of frost or ice.

The purpose of CTS 4.6.5.1.c and CTS 4.6.5.1.b.3 is to ensure the flow area for the steam air mixture through the ice bed is sufficient to ensure the appropriate flow. This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the blockage criteria assumed in the safety analysis are met. Thus, appropriate portions of the flow path (i.e., flow channel) will continue to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analysis are protected. Due to significantly larger flow area in the regions of the top deck floor grating, the lower inlet plenum support structures, and turning vanes, a significant amount of buildup of ice on these structures would be required to degrade air and steam flow. Therefore, these structures are excluded as part of a flow channel for application of the 15% blockage criteria. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

CNP Units 1 and 2 Page 7 of 7 Attachment 1, Volume 11, Rev. 0, Page 307 of 494

Attachment 1, Volume 11, Rev. 0, Page 308 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 308 of 494

, Volume 11, Rev. 0, Page 309 of 494 , Volume 11, Rev. 0, Page 309 of 494

Attachment 1, Volume 11, Rev. 0, Page 310 of 494 3.6.11 TSTF-429 INSERT 1 2

Verify total mass of stored ice is > [2,200,000] lbs by calculating the mass of stored ice, at a 95% confidence level, in each of three Radial Zones as defined below, by selecting a random sample of > 30 ice baskets in each Radial Zone, and 3 Verify:

a 1. Zone A ([radial rows 7, 8, and 9]) has a total mass > [733,400] lbs ;

3 2 b 2. Zone B ([radial rows 4, 5, and 6]) has a total mass > [733,400] lbs ; and c

3. Zone C ([radial rows 1, 2, and 3]) has a total mass > [733,400] lbs.

Insert Page 3.6.15-1 Attachment 1, Volume 11, Rev. 0, Page 310 of 494

, Volume 11, Rev. 0, Page 311 of 494 , Volume 11, Rev. 0, Page 311 of 494

Attachment 1, Volume 11, Rev. 0, Page 312 of 494 3.6.11 TSTF-429 INSERT 2 Verify that the ice mass of each basket sampled in SR 3.6.15.2 is > 600 lbs.

11 1 TSTF-429 INSERT 3 as defined below:

a. Group 1 - bays 1 through 8;

b. Group 2 - bays 9 through 16; and

c. Group 3 - bays 17 through 24.

Insert Page 3.6.15-2 Attachment 1, Volume 11, Rev. 0, Page 312 of 494

, Volume 11, Rev. 0, Page 313 of 494 , Volume 11, Rev. 0, Page 313 of 494

Attachment 1, Volume 11, Rev. 0, Page 314 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.11, ICE BED

1. The headings for ISTS 3.6.15 include the parenthetical expression (Ice Condenser).

This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specifications to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made. In addition, many Containment Specifications in the NUREG are not included in the CNP ITS due to design differences. Therefore, ISTS 3.6.15 is renumbered as ITS 3.6.11. In addition, the SRs have been put in the proper order, based on the Frequency.

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

3. Minor editorial corrections have been made to the changes made by approved TSTF-429, Rev. 3 to be consistent with the format of the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 314 of 494

Attachment 1, Volume 11, Rev. 0, Page 315 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 315 of 494

, Volume 11, Rev. 0, Page 316 of 494 , Volume 11, Rev. 0, Page 316 of 494

, Volume 11, Rev. 0, Page 317 of 494 , Volume 11, Rev. 0, Page 317 of 494

, Volume 11, Rev. 0, Page 318 of 494 , Volume 11, Rev. 0, Page 318 of 494

, Volume 11, Rev. 0, Page 319 of 494 , Volume 11, Rev. 0, Page 319 of 494

, Volume 11, Rev. 0, Page 320 of 494 , Volume 11, Rev. 0, Page 320 of 494

, Volume 11, Rev. 0, Page 321 of 494 , Volume 11, Rev. 0, Page 321 of 494

Attachment 1, Volume 11, Rev. 0, Page 322 of 494 B 3.6.11 TSTF-429 INSERT 2 Ice mass determination methodology is designed to verify the total as-found (pre-maintenance) mass of ice in the ice bed, and the appropriate distribution of that mass, using a random sampling of individual baskets. The random sample will include at least radial 30 baskets from each of three defined Radial Zones (at least 90 baskets total). Radial Zone A consists of baskets located in rows [7, 8, and 9] (innermost rows adjacent to the 8 6 Crane Wall), Radial Zone B consists of baskets located in rows [4, 5, and 6] (middle rows of the ice bed), and Radial Zone C consists of baskets located in rows [1, 2, and 3]

(outermost rows adjacent to the Containment Vessel). structure 2

The Radial Zones chosen include the row groupings nearest the inside and outside walls 8 of the ice bed and the middle rows of the ice bed. These groupings facilitate the statistical sampling plan by creating sub-populations of ice baskets that have similar mean mass and sublimation characteristics. discussed in Reference 2, except visual estimation which is precluded by Reference 3. 9 Methodology for determining sample ice basket mass will be either by direct lifting or by alternative techniques. Any method chosen will include procedural allowances for the accuracy of the method used. [The number of sample baskets in any Radial Zone may 8

be increased once by adding 20 or more randomly selected baskets to verify the total mass of that Radial Zone.] (Ref. 3) 9 In the event the mass of a selected basket in a sample population (initial or expanded) cannot be determined by any available means (e.g., due to surface ice accumulation or obstruction), a randomly selected representative alternate basket may be used to replace the original selection in that sample population. If employed, the representative alternate must meet the following criteria:

a. Alternate selection must be from the same bay-Zone (i.e., same bay, same 8 Radial Zone) as the original selection, and

3

b. Alternate selection cannot be a repeated selection (original or alternate) in the current Surveillance, and cannot have been used as an analyzed alternate selection in the three most recent Surveillances.

The complete basis for the methodology used in establishing the 95% confidence level in the total ice bed mass is documented in Reference 4 and approved in Reference 5. 2 2 3 The total ice mass and individual Radial Zone ice mass requirements defined in this 8 Surveillance, and the minimum ice mass per basket requirement defined by SR 3.6.15.3, 11 1 are the minimum requirements for OPERABILITY. Additional ice mass beyond the SRs is maintained to address sublimation. This sublimation allowance is generally applied to 8 baskets in each Radial Zone, as appropriate, at the beginning of an operating cycle to ensure sufficient ice is available at the end of the operating cycle for the ice condenser to perform its intended design function.

The Frequency of 18 months was based on ice storage tests, and the typical sublimation allowance maintained in the ice mass over and above the minimum ice mass assumed in the safety analyses. Operating and maintenance experience has verified that, with Insert Page B 3.6.15-5a Attachment 1, Volume 11, Rev. 0, Page 322 of 494

Attachment 1, Volume 11, Rev. 0, Page 323 of 494 B 3.6.11 TSTF-429 INSERT 2 (continued) the 18 month Frequency, the minimum mass and distribution requirements in the ice bed are maintained.

Insert Page B 3.6.15-5b Attachment 1, Volume 11, Rev. 0, Page 323 of 494

, Volume 11, Rev. 0, Page 324 of 494 , Volume 11, Rev. 0, Page 324 of 494

Attachment 1, Volume 11, Rev. 0, Page 325 of 494 B 3.6.11 TSTF-429 INSERT 3 11 Verifying that each selected sample basket from SR 3.6.15.2 contains at least 600 lbs of 1

ice in the as-found (pre-maintenance) condition ensures that a significant localized 8 degraded mass condition is avoided.

2 Reference This SR establishes a per basket limit to ensure any ice mass degradation is consistent with the initial conditions of the DBA by not significantly affecting the containment pressure response. Ref. 4 provides insights through sensitivity runs that demonstrate 2 that the containment peak pressure during a DBA is not significantly affected by the ice 11 mass in a large localized region of baskets being degraded below the required safety analysis mean, when the Radial Zone and total ice mass requirements of SR 3.6.15.2 8 1 are satisfied. Any basket identified as containing less than 600 lbs of ice requires appropriately entering the TS Required Action for an inoperable ice bed due to the 8

potential that it may represent a significant condition adverse to quality.

2 A As documented in Ref. 4, maintenance practices actively manage individual ice basket 8 2 mass above the required safety analysis mean for each Radial Zone. Specifically, each 8 basket is serviced to keep its ice mass above [1132] lbs for Radial Zone A, [1132] lbs for 6 8 Radial Zone B, and [1132] lbs for Radial Zone C. If a basket sublimates below the safety analysis mean value, this instance is identified within the plants corrective action program, including evaluating maintenance practices to identify the cause and correct CNP 2 any deficiencies. These maintenance practices provide defense in depth beyond compliance with the ice bed surveillance requirements by limiting the occurrence of 8 individual baskets with ice mass less than the required safety analysis mean.

Insert Page B 3.6.15-6 Attachment 1, Volume 11, Rev. 0, Page 325 of 494

, Volume 11, Rev. 0, Page 326 of 494 , Volume 11, Rev. 0, Page 326 of 494

, Volume 11, Rev. 0, Page 327 of 494 , Volume 11, Rev. 0, Page 327 of 494

Attachment 1, Volume 11, Rev. 0, Page 328 of 494 B 3.6.11 2 INSERT 4

, although the removal of iodine from the containment atmosphere by the sodium tetraborate is not assumed in the accident analysis TSTF-429 INSERT 4A The SR is designed around a full-length inspection of a sample of baskets, and is intended to monitor the effect of the ice condenser environment on ice baskets. The groupings defined in the SR (two baskets in each azimuthal third of the ice bed) ensure that the sampling of baskets is reasonably distributed.

Insert Page B 3.6.15-8 Attachment 1, Volume 11, Rev. 0, Page 328 of 494

, Volume 11, Rev. 0, Page 329 of 494 , Volume 11, Rev. 0, Page 329 of 494

Attachment 1, Volume 11, Rev. 0, Page 330 of 494 B 3.6.11 TSTF-429 INSERT 5

2. Topical Report ICUG-001, "Application of the Active Ice Mass Management (AIMM) Concept to the Ice Condenser Ice Mass Technical Specifications,"

Rev. 3, September 2003.

TSTF-429 INSERT 6

3. NRC Letter dated September 11, 2003, "Safety Evaluation for Ice Condenser Utility Group Topical Report No. ICUG-001, Revision 2, RE: Application of the Active Ice Mass Management Concept to the Ice Condenser Ice Mass Technical Specification (TAC No. MB3379)."

6 INSERT 7 UFSAR, Tables 5.3-1 and 5.3.2-1.

Insert Page B 3.6.15-9 Attachment 1, Volume 11, Rev. 0, Page 330 of 494

Attachment 1, Volume 11, Rev. 0, Page 331 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.11 BASES, ICE BED

1. Changes have been made to be consistent with 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. 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 ISTS 3.6.15 (ITS 3.6.11) Bases ASA section includes a discussion concerning the ECCS cooling effectiveness during the core reflood phase of a LOCA analysis.

This discussion does not relate to how the ice bed is credited in the analysis for the mitigation of DBAs. Therefore, the discussion is deleted.

5. The discussion concerning Surveillance Frequencies is not appropriate in the ACTIONS Bases. It is adequately addressed in the Surveillance Requirement Bases. Therefore, the discussion has been deleted.

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

7. Typographical/grammatical error corrected.

8. Minor editorial corrections have been made to the changes made by approved TSTF-429, Rev. 3 to be consistent with the format of the ITS.

9. These changes to the Bases are a result of the NRC SER (dated 9/11/03) accepting ICUG-001, Rev. 2.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 331 of 494

Attachment 1, Volume 11, Rev. 0, Page 332 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 332 of 494

Attachment 1, Volume 11, Rev. 0, Page 333 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.11, ICE BED There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 333 of 494

, Volume 11, Rev. 0, Page 334 of 494 ATTACHMENT 12 ITS 3.6.12, Ice Condenser Doors , Volume 11, Rev. 0, Page 334 of 494

, Volume 11, Rev. 0, Page 335 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 335 of 494

Attachment 1, Volume 11, Rev. 0, Page 336 of 494 ITS 3.6.12 A.1 ITS LCO 3.6.12 Add proposed ACTIONS Note 1 L.1 Add proposed ACTIONS Note 2 L.2 Add proposed ACTION A M.1 ACTION B ACTION C ACTION D Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months L.3 SR 3.6.12.1 LA.1 L.4 SR 3.6.12.5 SR 3.6.12.4 Perform a torque test SR 3.6.12.6 LA.2 Page 1 of 6 Attachment 1, Volume 11, Rev. 0, Page 336 of 494

Attachment 1, Volume 11, Rev. 0, Page 337 of 494 ITS 3.6.12 A.1 ITS LA.2 SR 3.6.12.2 SR 3.6.12.7 LA.3 Page 2 of 6 Attachment 1, Volume 11, Rev. 0, Page 337 of 494

Attachment 1, Volume 11, Rev. 0, Page 338 of 494 ITS 3.6.12 A.1 ITS SR 3.6.12.3 Page 3 of 6 Attachment 1, Volume 11, Rev. 0, Page 338 of 494

Attachment 1, Volume 11, Rev. 0, Page 339 of 494 ITS 3.6.12 A.1 ITS LCO 3.6.12 Add proposed ACTIONS Note 1 L.1 Add proposed ACTIONS Note 2 L.2 Add proposed ACTION A M.1 ACTION B ACTION C ACTION D Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months L.3 SR 3.6.12.1 LA.1 L.4 SR 3.6.12.5 SR 3.6.12.4 Perform a torque test SR 3.6.12.6 LA.2 Page 4 of 6 Attachment 1, Volume 11, Rev. 0, Page 339 of 494

Attachment 1, Volume 11, Rev. 0, Page 340 of 494 ITS 3.6.12 A.1 ITS LA.2 SR 3.6.12.2 SR 3.6.12.7 LA.3 SR 3.6.12.3 Page 5 of 6 Attachment 1, Volume 11, Rev. 0, Page 340 of 494

Attachment 1, Volume 11, Rev. 0, Page 341 of 494 ITS 3.6.12 A.1 ITS SR 3.6.12.3 Page 6 of 6 Attachment 1, Volume 11, Rev. 0, Page 341 of 494

Attachment 1, Volume 11, Rev. 0, Page 342 of 494 DISCUSSION OF CHANGES ITS 3.6.12, ICE CONDENSER DOORS 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 M.1 The CTS 3.6.5.3 Action provides compensatory actions for one or more ice condenser doors open or otherwise inoperable. Power operation may continue for up to 14 days provided the ice bed temperature is monitored at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and the maximum ice bed temperature is maintained less than or equal to 27°F. A new requirement has been added (ITS 3.6.12 ACTION A) that addresses inoperabilities associated with one or more ice condenser inlet doors that are physically restrained from opening. The new requirement only allows one hour to restore the inlet door to OPERABLE status. This changes the CTS by adding a more restrictive ACTION for inlet doors which are physically restrained from opening.

The purpose of the CTS Action is to provide adequate compensatory actions for all inoperabilities associated with inlet doors. The CTS 3.6.5.3 Action allows 14 days with an inoperable condenser inlet door. This change is acceptable because the new action provides a short period of time to restore the inoperable ice condenser inlet door to OPERABLE status when it is not able to perform it safety function (i.e., open) because it is physically restrained. The ITS ACTION is necessary to return operation to within the bounds of the safety analysis. The one hour Completion Time is consistent with the ACTIONS for the Containment in ITS LCO 3.6.1. This change is designated as more restrictive as it allows less time to restore the inoperability than in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.6.5.3.1.a requires the inlet doors to be verified closed "by the inlet door position monitoring system." ITS SR 3.6.12.1 requires the same verification, however the detail on the method to perform the verification is not specified. This changes the CTS by moving the detail on the method to verify the inlet doors are closed to the Bases.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 11, Rev. 0, Page 342 of 494

Attachment 1, Volume 11, Rev. 0, Page 343 of 494 DISCUSSION OF CHANGES ITS 3.6.12, ICE CONDENSER DOORS The removal of this detail 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. The ITS still retains the requirement to verify the ice condenser inlet doors are closed. 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 4.6.5.3.1.b.3 requires testing of each one of the inlet doors and verifying that the torque required to open each door is less than 195 inch-pounds when the door is 40 degrees open. This torque is defined as the "door opening torque" and is equal to the nominal door torque plus a frictional torque component. CTS 4.6.5.3.1.b.4 requires testing of each one of the inlet doors and verifying that the torque required to keep each door from closing is greater than 78 inch-pounds when the door is 40 degrees open. This torque is defined as the "door closing torque" and is equal to the nominal door torque plus a frictional torque component. CTS 4.6.5.3.1.b.5 requires a calculation of the frictional torque of each door tested in accordance with 3 and 4, above. The calculated frictional torque shall be less than or equal to 40 inch-pounds. ITS SR 3.6.12.6 requires the performance of a torque test on each inlet door. This changes the CTS by moving the torque design limits and definitions to the Bases.

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. The ITS still retains the requirement to perform a torque test on the inlet doors. Also, this change is acceptable because the removed information 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.

LA.3 (Type 3 - Removing Procedural Details for meeting TS Requirements or Reporting Requirements) CTS 4.6.5.3.2.b requires an inspection of each ice condenser intermediate deck door by visually verifying no structural deterioration, by verifying free movement of the vent assemblies, and by ascertaining free movement when lifted with the applicable force shown. CTS 4.6.5.3.2.b also lists the required lifting force for various doors. ITS SR 3.6.12.7 requires the same inspections, however the locations of the doors and associated lifting forces are CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 11, Rev. 0, Page 343 of 494

Attachment 1, Volume 11, Rev. 0, Page 344 of 494 DISCUSSION OF CHANGES ITS 3.6.12, ICE CONDENSER DOORS not listed. This changes the CTS by moving the locations of the doors and associated lifting forces to the Bases.

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. The ITS still retains the requirement to verify free movement of each intermediate door. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.6.5.3 provides an Action for one or more inoperable ice condenser doors. ITS 3.6.12 provides similar ACTIONS, however a Note is added to the CTS Action (ITS 3.6.12 ACTIONS Note 1) that states "Separate Condition entry is allowed for each ice condenser door." This modifies the CTS by providing a specific allowance to enter the Action for each ice condenser door separately.

The purpose of the CTS 3.6.5.3 Action is to minimize the time the unit is operating with inoperable ice condenser doors. 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. ITS 3.6.12 ACTION A has been added (as discussed in DOC M.1) to minimize the time one or more ice condenser inlet doors are inoperable due to being physically restrained from opening. The Completion Time for restoration is one hour. ITS 3.6.12 ACTION B covers the condition of one or more ice condenser doors inoperable for reasons other than Condition A (i.e., the doors physically will not open) or not closed. The Completion Time to restore a door in this condition is 14 days. In addition, during this 14 day period, the ice bed temperature must be verified to be < 27°F once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The addition of ITS 3.6.12 ACTION A minimizes the time the ice condenser doors are inoperable by being physically restrained from opening and therefore minimizes the time allowed to be outside the containment analysis assumptions. When operating in ITS 3.6.12 ACTION B, the verification of the ice bed is OPERABLE is ensured by verifying the ice bed temperature is < 27°F.

Therefore, the Completion Time of 14 days is appropriate. The addition of the ITS 3.6.12 ACTIONS Note 1 is acceptable since the proposed compensatory CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 11, Rev. 0, Page 344 of 494

Attachment 1, Volume 11, Rev. 0, Page 345 of 494 DISCUSSION OF CHANGES ITS 3.6.12, ICE CONDENSER DOORS actions minimize risk associated with continued operation while providing time to repair inoperable features. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) The CTS 3.6.5.3 Action provides specific actions to be taken if an ice condenser intermediate deck or top deck door is open or inoperable. ITS 3.6.12 ACTIONS Note 2 states that when an ice condenser intermediate deck or top deck door is inoperable for a short duration solely due to personnel standing on or opening the door to perform required Surveillances, minor preventative maintenance, or system walkdowns, entry into associated Conditions and Required Actions is not required. This changes the CTS by allowing an intermediate deck or top deck door to be inoperable for a short duration to perform routine evolutions without requiring entry into the associated Actions.

The purpose of the CTS 3.6.5.3 Action is to minimize the time the unit is operating with inoperable ice condenser doors. This change is acceptable because the doors are inoperable only for short durations, and the reason for the inoperability is to either perform required Surveillances, perform preventative maintenance to improve reliability of the doors or ensure the doors do not become inoperable, or simply to be walking on or opening the doors for inspections. In addition, during this short duration, the ice bed temperature is normally continuously monitored (as described in the Bases). This helps to ensure that an ice bed temperature change due to an open door will be detected and appropriate actions taken (as required by ITS 3.6.11). Also, the number of doors walked on simultaneously (and therefore, potentially incapable of opening) is small when compared to the total number of doors. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.5.3.1.a requires the inlet doors of the ice condenser to be "continuously monitored" and determined to be closed by the Inlet Door Position Monitoring System. ITS SR 3.6.12.1 requires the verification that all inlet doors are closed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by allowing the ice condenser inlet doors to be monitored less frequently. The change to the method of verifying the ice doors are closed is discussed in DOC LA.1.

The purpose of CTS 4.6.5.3.1.a is to ensure the ice condenser inlet doors are closed. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The inlet doors will open when there is significant pressure buildup in the containment lower compartment. During an accident this pressure buildup is generated by the energy introduced by the Reactor Coolant System blowdown or by operation of the Containment Air Recirculation/Hydrogen Skimmer System.

During normal operation these conditions are not expected and the doors should remain closed. Therefore the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered sufficient. 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 5 Attachment 1, Volume 11, Rev. 0, Page 345 of 494

Attachment 1, Volume 11, Rev. 0, Page 346 of 494 DISCUSSION OF CHANGES ITS 3.6.12, ICE CONDENSER DOORS L.4 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.6.5.3.1.b requires verification that each ice condenser inlet door is OPERABLE every 18 months during shutdown. Testing includes verification of the torque required to initially open each door, verification that the opening of each door is not impaired by ice, frost, or debris, and verification of the opening and closing torques when the door is 40 degrees open. ITS SR 3.6.12.4, SR 3.6.12.5, and SR 3.6.12.6 require the same testing every 18 months, with no restriction as to when (i.e., during shutdown) the test can be performed. This changes the CTS by deleting the requirement to perform the Surveillances during shutdown.

The purpose of CTS 4.6.5.3.1.b is to ensure the ice condenser inlet doors are OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions. The control of the unit conditions appropriate to perform the test is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. This change is designated as less restrictive because the Surveillance may be performed at plant conditions other than shutdown.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 11, Rev. 0, Page 346 of 494

Attachment 1, Volume 11, Rev. 0, Page 347 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 347 of 494

, Volume 11, Rev. 0, Page 348 of 494 , Volume 11, Rev. 0, Page 348 of 494

Attachment 1, Volume 11, Rev. 0, Page 349 of 494 3.6.12 3

CTS INSERT 1 DOC L.2 2. When an ice condenser intermediate deck or top deck door is inoperable for a short duration solely due to personnel standing on or opening the door to perform required Surveillances, minor preventative maintenance, or system walkdowns, entry into associated Conditions and Required Actions is not required.

Insert Page 3.6.16-1 Attachment 1, Volume 11, Rev. 0, Page 349 of 494

, Volume 11, Rev. 0, Page 350 of 494 , Volume 11, Rev. 0, Page 350 of 494

, Volume 11, Rev. 0, Page 351 of 494 , Volume 11, Rev. 0, Page 351 of 494

Attachment 1, Volume 11, Rev. 0, Page 352 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.12, ICE CONDENSER DOORS

1. The headings for ISTS 3.6.16 include the parenthetical expression (Ice Condenser).

This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specifications to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made. In addition, many Containment Specifications in the NUREG are not included in the CNP ITS due to design differences. Therefore, ISTS 3.6.16 is renumbered as ITS 3.6.12.

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

3. The ISTS Bases for ACTIONS B.1 and B.2 (last sentence) state that entry into Condition B is not required due to personnel standing on or opening an intermediate deck or top deck door for short durations to perform required Surveillance, minor maintenance such as ice removal, or routine tasks such as system walkdowns. As documented in Part 9900 of the NRC Inspection Manual, Technical Guidance -

Licensee Technical Specifications Interpretations, and in the ITS Bases Control Program (ITS 5.5.12), neither the Technical Specifications Bases nor Licensee generated interpretations can be used to change the Technical Specification requirements. Thus, since the ISTS do not provide for this option, the Bases cannot change the Technical Specifications requirement. To preclude this problem, a Note has been added to the ITS (ACTIONS Note 2) to allow an intermediate deck or top deck door to be inoperable (i.e., open or incapable of opening) for short durations during the ISTS Bases specified evolutions. During this time, the ice bed temperature should be continuously monitored to ensure the open door does not result in ice bed temperature greater than the limit. This new Note maintains the intent of the ISTS Bases allowance.

4. The requirement in ISTS SR 3.6.16.1 (ITS SR 3.6.12.1) to use the Inlet Door Position Monitoring System has been deleted. The Bases for this Surveillance has been revised to state that the verification of the inlet doors is normally performed using the Inlet Door Monitoring System. This change is made because if the Inlet Door Position Monitoring System is inoperable, then the Surveillance requiring verification that all inlet doors are closed will not be met. However, no inlet doors may actually be open. The requirements of the Inlet Door Position Monitoring System in CTS 3/4.6.5.4 have been relocated to the Technical Requirements Manual as documented in CTS 3/4.6.5.4 DOC R.1 and the Split Report. This relocation is consistent with the analysis documented in WCAP-11618, "Methodically Engineered Restructured and Improved Technical Specifications, MERITS Program - Phase II Task 5, Criteria Application," including Addendum 1, and the NRC Staff Review of NSSS Vendor Owners Groups Application of The Commission's Interim Policy Statement Criteria To Standard Technical Specifications, Wilgus/Murley letter dated May 9. In addition, this change is consistent with other Surveillance Requirements that require verification of certain parameters and do not include in the Surveillance Requirement the specific instrumentation used to perform the verification.

5. The bracketed first Frequency (3 months during first year after receipt of license) in ISTS SR 3.6.16.3, SR 3.6.16.4, SR 3.6.16.5, and SR 3.6.16.6 has been deleted since it no longer applies to CNP Units 1 and 2. Both units are more than 3 months CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 352 of 494

Attachment 1, Volume 11, Rev. 0, Page 353 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.12, ICE CONDENSER DOORS from the receipt of the license. The SRs have been put in the proper order, based on the Frequency.

6. Typographical/grammatical error corrected.

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.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 353 of 494

Attachment 1, Volume 11, Rev. 0, Page 354 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 354 of 494

, Volume 11, Rev. 0, Page 355 of 494 , Volume 11, Rev. 0, Page 355 of 494

, Volume 11, Rev. 0, Page 356 of 494 , Volume 11, Rev. 0, Page 356 of 494

, Volume 11, Rev. 0, Page 357 of 494 , Volume 11, Rev. 0, Page 357 of 494

, Volume 11, Rev. 0, Page 358 of 494 , Volume 11, Rev. 0, Page 358 of 494

, Volume 11, Rev. 0, Page 359 of 494 , Volume 11, Rev. 0, Page 359 of 494

, Volume 11, Rev. 0, Page 360 of 494 , Volume 11, Rev. 0, Page 360 of 494

, Volume 11, Rev. 0, Page 361 of 494 , Volume 11, Rev. 0, Page 361 of 494

, Volume 11, Rev. 0, Page 362 of 494 , Volume 11, Rev. 0, Page 362 of 494

, Volume 11, Rev. 0, Page 363 of 494 , Volume 11, Rev. 0, Page 363 of 494

, Volume 11, Rev. 0, Page 364 of 494 , Volume 11, Rev. 0, Page 364 of 494

Attachment 1, Volume 11, Rev. 0, Page 365 of 494 B 3.6.12 2 INSERT 5 T (OPEN) is known as the "door opening torque" and is equal to the nominal door torque plus a frictional torque component. T(CLOSE) is defined as the "door closing torque" and is equal to the nominal door torque minus a frictional torque component.

Insert Page B 3.6.16-7 Attachment 1, Volume 11, Rev. 0, Page 365 of 494

, Volume 11, Rev. 0, Page 366 of 494 , Volume 11, Rev. 0, Page 366 of 494

Attachment 1, Volume 11, Rev. 0, Page 367 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.12 BASES, ICE CONDENSER DOORS

1. Changes have been made to be consistent with changes made to the ITS.

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

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

4. The ISTS 3.6.16 (ITS 3.6.12) Bases ASA section includes a discussion concerning the ECCS cooling effectiveness during the core reflood phase of a LOCA analysis.

This discussion does not relate to how the Ice Condenser Doors are credited in the analysis for the mitigation of DBAs. Therefore, the discussion is deleted.

5. Changes have been made to be consistent with the Specification. In the specific case of changing the words "one or more" to "an" and "doors are" to "door is" in ACTIONS A.1 and B.1 and B.2 Bases, this was done since separate Condition entry is allowed for each inoperable door.

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

7. The Bases wording is deleted because the Bases places additional restrictions than those specified in the Specification. In accordance with the Specification, if ACTION B is not met for any reason (Required Actions B.1 or B.2 not met), then the default ACTION is ACTION C, while the ISTS Bases requires Required Actions D.1 and D.2 to be applied if the temperature verification is not made. The Required Actions in the Specification are consistent with the current allowances in the CTS, therefore the change is appropriate.

8. The words in the ISTS do not convey the complete intent of the actual ISTS Condition and when the Condition should be entered. Therefore, to be consistent with the actual ISTS Condition words, the Bases have been modified.

9. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 367 of 494

Attachment 1, Volume 11, Rev. 0, Page 368 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 368 of 494

Attachment 1, Volume 11, Rev. 0, Page 369 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.12, ICE CONDENSER DOORS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 369 of 494

, Volume 11, Rev. 0, Page 370 of 494 ATTACHMENT 13 ITS 3.6.13, Divider Barrier Integrity , Volume 11, Rev. 0, Page 370 of 494

, Volume 11, Rev. 0, Page 371 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 371 of 494

Attachment 1, Volume 11, Rev. 0, Page 372 of 494 ITS 3.6.13 A.1 ITS LCO 3.6.13, SR 3.6.13.1 A.2 Add proposed Condition A Note A.3 one or more LCO 3.6.13 Note ACTION A ACTION C SR 3.6.13.1, SR 3.6.13.3 SR 3.6.13.2 Page 1 of 6 Attachment 1, Volume 11, Rev. 0, Page 372 of 494

Attachment 1, Volume 11, Rev. 0, Page 373 of 494 ITS 3.6.13 A.1 ITS LCO 3.6.13 A.2 Add proposed ACTIONS B and C A.4 ACTIONS B and C L.2 24 SR 3.6.13.4 L.1 SR 3.6.13.5 Page 2 of 6 Attachment 1, Volume 11, Rev. 0, Page 373 of 494

Attachment 1, Volume 11, Rev. 0, Page 374 of 494 ITS 3.6.13 A.1 LA.1 LA.1 SR 3.6.13.4 ITS Page 3 of 6 Attachment 1, Volume 11, Rev. 0, Page 374 of 494

Attachment 1, Volume 11, Rev. 0, Page 375 of 494 ITS 3.6.13 A.1 ITS LCO 3.6.13, A.2 SR 3.6.13.1 Add proposed Condition A Note A.3 one or more LCO 3.6.13 Note ACTION A ACTION C SR 3.6.13.1, SR 3.6.13.3 SR 3.6.13.2 Page 4 of 6 Attachment 1, Volume 11, Rev. 0, Page 375 of 494

Attachment 1, Volume 11, Rev. 0, Page 376 of 494 ITS 3.6.13 A.1 ITS LCO 3.6.13 A.2 Add proposed ACTIONS B and C A.4 ACTIONS B and C 24 L.1 L.2 SR 3.6.13.4 SR 3.6.13.5 Page 5 of 6 Attachment 1, Volume 11, Rev. 0, Page 376 of 494

Attachment 1, Volume 11, Rev. 0, Page 377 of 494 ITS 3.6.13 A.1 LA.1 LA.1 SR 3.6.13.4 ITS Page 6 of 6 Attachment 1, Volume 11, Rev. 0, Page 377 of 494

Attachment 1, Volume 11, Rev. 0, Page 378 of 494 DISCUSSION OF CHANGES ITS 3.6.13, DIVIDER BARRIER INTEGRITY 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 3.6.5.5 requires the personnel access doors and equipment hatches between the containments upper and lower compartments to be OPERABLE and closed. CTS 3.6.5.9 requires the divider barrier seal to be OPERABLE. ITS LCO 3.6.13 requires the divider barrier integrity to be maintained. This changes the CTS by combining the divider barrier requirements of CTS 3.6.5.5 and CTS 3.6.5.9 into one LCO statement.

The purpose of CTS 3/4.6.5.5 and CTS 3/4.6.5.9 is to provide requirements pertaining to containment divider integrity. This change is acceptable because moving these requirements to one LCO, ITS 3.6.13, centralizes the requirements. In addition, the requirement in CTS 3.6.5.5 for the personnel access doors and equipment hatches between the containments upper and lower compartments to be closed is covered by CTS 4.6.5.5.1 (ITS SR 3.6.13.1),

thus it is part of maintaining divider barrier integrity. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.6.5.5 Action provides the actions to take when a personnel access door or equipment hatch is inoperable. ITS 3.6.13 ACTION A provides an action for one or more personnel access doors or equipment hatches open or inoperable. In addition, ITS 3.6.13 Condition A includes a Note that allows separate Condition entry for each personnel access door or equipment hatch. This modifies the CTS by providing a specific allowance to enter the Action for each inoperable personnel access door or equipment hatch.

This change is acceptable because it clearly states the current requirement. The CTS considers each personnel access door or equipment hatch to be separate and independent from the others. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.6.5.9 Action does not state what action to take if the divider barrier seal is inoperable while in MODE 1, 2, 3, or 4; it only includes a requirement that the divider barrier seal be restored to OPERABLE status prior to increasing Reactor Coolant System temperature above 200°F (i.e., MODE 4). Thus, entry into CTS 3.0.3 is required if CTS 3.6.5.9 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 a shutdown 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 3.6.13 ACTION B requires that if the divider barrier seal is inoperable, it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.6.13 ACTION C requires that if the Required Action and associated Completion Time are not met (i.e., the divider barrier seal is not restored to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), the unit must be in CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 378 of 494

Attachment 1, Volume 11, Rev. 0, Page 379 of 494 DISCUSSION OF CHANGES ITS 3.6.13, DIVIDER BARRIER INTEGRITY 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 . This changes the CTS by stating the ACTIONS within the Specification rather than deferring to CTS 3.0.3.

In addition, it deletes the Action to restore the limits prior to entering MODE 4.

The purpose of CTS 3.0.3 is to place the unit outside the MODE of Applicability within a reasonable amount of time in a controlled manner. CTS 3.6.5.9 is silent on these actions, deferring to CTS 3.0.3 for the actions to accomplish this. This change is acceptable because the ACTIONS specified in ITS 3.6.13 adopt ISTS structure for placing the unit outside the MODE of Applicability without changing the time specified to enter MODE 3 and MODE 5. In addition, deletion of the current Action of CTS 3.6.5.9 is acceptable because CTS 3.0.4 (ITS LCO 3.0.4) already precludes entering the MODE of Applicability when the LCO is not met.

Therefore, it is not necessary to include these requirements as specific actions in ITS 3.6.13. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.6-2 specifies the divider seal acceptable physical properties. The table includes the tensile strength and elongation property as well as the material type. The material must be Uniroyal 3807 or equal, defined as meeting at least the requirements discussed in Question 5.98 of the Plants FSAR. ITS SR 3.6.13.4 only includes the tensile strength and elongation property requirements. This changes the CTS by moving the material type to the UFSAR.

The removal of this detail, which is 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 test for tensile strength and elongation. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. The UFSAR is controlled under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 379 of 494

Attachment 1, Volume 11, Rev. 0, Page 380 of 494 DISCUSSION OF CHANGES ITS 3.6.13, DIVIDER BARRIER INTEGRITY LESS RESTRICTIVE CHANGES L.1 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.6.5.9 requires verification that each divider barrier seal is OPERABLE every 18 months during shutdown. CTS 4.6.5.9.a requires removal of two divider barrier seal test coupons and verifying that the physical properties of the test coupons are within the acceptable range. CTS 4.6.5.9.b requires a visual inspection of at least 95% of the seals entire length, verification that the seal and seal mounting bolts are properly installed, and verification that the seal material shows no visual evidence of deterioration. ITS SR 3.6.13.4 and SR 3.6.13.5 require the same testing every 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2). The change to the requirement to perform the Surveiilances during shutdown is discussed in DOC L.2.

The purpose of CTS 4.6.5.9 is to ensure the divider barrier seals are 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. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that any failures found during surveillance testing either involved situations in which the safety function was not impaired or was the result of an event-driven activity. Therefore there were no time-based failure mechanisms found. 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 divider barrier seal is acceptable because there are not any time-based failure mechanisms that would be adversely affected by an increase in the surveillance interval to 24 months (30 months maximum). Based on the inherent system and component reliability, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.6.5.9 requires verification that each divider barrier seal is OPERABLE every 18 months during shutdown. CTS 4.6.5.9.a requires the removal of two divider barrier seal test coupons and verifying that the physical properties of the test coupons are within the acceptable range. CTS 4.6.5.9.b requires a visual inspection of at least 95% of the seals entire length, verification that the seal and seal mounting bolts are properly installed, and verification that the seal material shows no visual evidence of deterioration. ITS SR 3.6.13.4 and SR 3.6.13.5 require the same testing every 24 months, with no restriction as to when (i.e., during shutdown) the test can be performed. This changes the CTS CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 380 of 494

Attachment 1, Volume 11, Rev. 0, Page 381 of 494 DISCUSSION OF CHANGES ITS 3.6.13, DIVIDER BARRIER INTEGRITY by deleting the requirement to perform the Surveillances during shutdown. The change to the Frequency of the Surveillance is discussed in DOC L.1.

The purpose of CTS 4.6.5.9 is to ensure the divider barrier seals are OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions. Portions of the divider barrier seal Surveillance Requirements could be performed in other than shutdown conditions, without jeopardizing safe plant operations. The control of the unit conditions appropriate to perform the test is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do no dictate unit conditions for the Surveillance. This change is designated as less restrictive because the Surveillance may be performed at plant conditions other than shutdown.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 381 of 494

Attachment 1, Volume 11, Rev. 0, Page 382 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 382 of 494

, Volume 11, Rev. 0, Page 383 of 494 , Volume 11, Rev. 0, Page 383 of 494

, Volume 11, Rev. 0, Page 384 of 494 , Volume 11, Rev. 0, Page 384 of 494

, Volume 11, Rev. 0, Page 385 of 494 , Volume 11, Rev. 0, Page 385 of 494

Attachment 1, Volume 11, Rev. 0, Page 386 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.13, DIVIDER BARRIER INTEGRITY

1. The headings for ISTS 3.6.17 include the parenthetical expression (Ice Condenser).

This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate Specifications to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made. In addition, many Containment Specifications in the NUREG are not included in the CNP ITS due to design differences. Therefore, ISTS 3.6.17 is renumbered as ITS 3.6.13.

2. ISTS 3.6.17 Condition A covers one or more personnel access doors or equipment hatches open or inoperable, other than for personnel transit entry. There is no ACTION in ISTS 3.6.17 for when a door or hatch is open for personnel transit entry; therefore LCO 3.0.3 is required to be entered if this occurs. This is not the intent of the Specification. Therefore, a Note has been added to the LCO to identify that the personnel access doors may be opened intermittently under administrative control for personnel transit. In addition, the phrase "other than for personnel transit entry" has been deleted from Condition A, since it is not needed with the addition of the Note.

3. Changes have been made to be consistent with other similar Notes in the Specifications.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 386 of 494

Attachment 1, Volume 11, Rev. 0, Page 387 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 387 of 494

, Volume 11, Rev. 0, Page 388 of 494 , Volume 11, Rev. 0, Page 388 of 494

, Volume 11, Rev. 0, Page 389 of 494 , Volume 11, Rev. 0, Page 389 of 494

, Volume 11, Rev. 0, Page 390 of 494 , Volume 11, Rev. 0, Page 390 of 494

, Volume 11, Rev. 0, Page 391 of 494 , Volume 11, Rev. 0, Page 391 of 494

, Volume 11, Rev. 0, Page 392 of 494 , Volume 11, Rev. 0, Page 392 of 494

, Volume 11, Rev. 0, Page 393 of 494 , Volume 11, Rev. 0, Page 393 of 494

, Volume 11, Rev. 0, Page 394 of 494 , Volume 11, Rev. 0, Page 394 of 494

Attachment 1, Volume 11, Rev. 0, Page 395 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.13 BASES, DIVIDER BARRIER INTEGRITY

1. Changes have been made to be consistent with 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 have been made to be consistent with the Specification. Specifically, the words were changed since separate Condition entry is allowed for each inoperable door and hatch.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 395 of 494

Attachment 1, Volume 11, Rev. 0, Page 396 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 396 of 494

Attachment 1, Volume 11, Rev. 0, Page 397 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.13, DIVIDER BARRIER INTEGRITY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 397 of 494

, Volume 11, Rev. 0, Page 398 of 494 ATTACHMENT 14 ITS 3.6.14, Containment Recirculation Drains , Volume 11, Rev. 0, Page 398 of 494

, Volume 11, Rev. 0, Page 399 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 399 of 494

Attachment 1, Volume 11, Rev. 0, Page 400 of 494 ITS 3.6.14 A.1 ITS LCO 3.6.14 ACTIONS A and C Add proposed ACTIONS A and C A.2 L.1 SR 3.6.14.3 LA.1 Page 1 of 4 Attachment 1, Volume 11, Rev. 0, Page 400 of 494

Attachment 1, Volume 11, Rev. 0, Page 401 of 494 ITS 3.6.14 A.1 ITS Two L.2 LCO 3.6.14 ACTIONS B and C Add proposed ACTIONS B and C A.2 required L.2 SR 3.6.14.2 Add SR 3.6.14.1 M.1 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 401 of 494

Attachment 1, Volume 11, Rev. 0, Page 402 of 494 ITS 3.6.14 A.1 ITS LCO 3.6.14 ACTIONS A and C Add proposed ACTIONS A and C A.2 L.1 SR 3.6.14.3 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 402 of 494

Attachment 1, Volume 11, Rev. 0, Page 403 of 494 ITS 3.6.14 A.1 ITS Two L.2 LCO 3.6.14 ACTIONS B and C Add proposed ACTIONS B and C A.2 required L.2 SR 3.6.14.2 Add SR 3.6.14.1 M.1 Page 4 of 4 Attachment 1, Volume 11, Rev. 0, Page 403 of 494

Attachment 1, Volume 11, Rev. 0, Page 404 of 494 DISCUSSION OF CHANGES ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

A.2 The CTS 3.6.5.7 Action does not state what action to take if the ice condenser floor drains are inoperable while in MODE 1, 2, 3, or 4; it only includes a requirement that the ice condenser floor drains be restored to OPERABLE status prior to increasing Reactor Coolant System temperature above 200°F (i.e.,

MODE 4). The CTS 3.6.5.8 Action does not state what action to take if the refueling canal drains are inoperable while in MODE 1, 2, 3, or 4; it only includes a requirement that the refueling canal drains be restored to OPERABLE status prior to increasing Reactor Coolant System temperature above 200°F (i.e.,

MODE 4). Thus, entry into CTS 3.0.3 is required if CTS 3.6.5.7 or CTS 3.6.5.8 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 a shutdown 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 3.6.14 ACTION A requires that if one ice condenser floor drain is inoperable, it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS 3.6.14 ACTION B requires that if one required refueling canal drain is inoperable, it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.6.14 ACTION C requires that if the Required Action and associated Completion Time are not met (i.e., the ice condenser or refueling canal drain is not restored to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), the unit must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by stating the ACTIONS within the Specification rather than deferring to CTS 3.0.3. In addition, it deletes the Actions to restore the limits prior to entering MODE 4.

The purpose of CTS 3.0.3 is to place the unit outside the MODE of Applicability within a reasonable amount of time in a controlled manner. CTS 3.6.5.7 and CTS 3.6.5.8 are silent on these actions, deferring to CTS 3.0.3 for the actions to accomplish this. This change is acceptable because the ACTIONS specified in ITS 3.6.14 adopt ISTS structure for placing the unit outside the MODE of Applicability without changing the time specified to enter MODE 3 and MODE 5.

In addition, deletion of the current Actions of CTS 3.6.5.7 and CTS 3.6.5.8 is acceptable because CTS 3.0.4 (ITS LCO 3.0.4) already precludes entering the MODE of Applicability when the LCO is not met. Therefore, it is not necessary to include these requirements as specific actions in ITS 3.6.14. 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 4 Attachment 1, Volume 11, Rev. 0, Page 404 of 494

Attachment 1, Volume 11, Rev. 0, Page 405 of 494 DISCUSSION OF CHANGES ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS MORE RESTRICTIVE CHANGES M.1 CTS 4.6.5.8 requires the refueling canal drain be demonstrated OPERABLE prior to increasing the Reactor Coolant System temperature above 200°F after each partial or complete filling of the canal with water. ITS 3.6.14.1 adds a new Surveillance to verify by visual inspection, every 92 days and prior to entering MODE 4 from MODE 5 after each partial or complete fill of the canal, that there is no debris present in the upper compartment or refueling canal that could obstruct the required refueling canal drains. This changes the CTS by adding the additional Surveillance verification.

The purpose of the additional Surveillance of ITS SR 3.6.14.1 is to provide additional assurance the required refueling canal drains are OPERABLE. Prior to and during operation, the debris could be present in the upper containment or refueling canal that eventually may obstruct the refueling canal drain. This change is acceptable because it provides additional assurance that the refueling canal drain will be capable of performing its function. This change is designated as more restrictive because it adds a Surveillance verification to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) (Unit 1 only) CTS 4.6.5.7.d requires the verification that the 12 inch drain line from the ice condenser floor to the containment lower compartment is unrestricted. ITS SR 3.6.14.3 requires the verification that the drain line from the ice condenser floor to the lower compartment is unrestricted.

This changes the Unit 1 CTS by moving the reference to the pipe size (12 inches) to the UFSAR.

The removal of this detail, which is 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 verify the drain line from the ice condenser floor to the containment lower compartment is unrestricted. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. The UFSAR is controlled under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Unit 1 Technical Specifications.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 11, Rev. 0, Page 405 of 494

Attachment 1, Volume 11, Rev. 0, Page 406 of 494 DISCUSSION OF CHANGES ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS LESS RESTRICTIVE CHANGES L.1 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.6.5.7 requires verification that each ice condenser floor drain is OPERABLE every 18 months during shutdown by verifying that valve gate opening is not impaired by ice, frost or debris, verifying that the valve seat is not damaged, verifying that the valve gate opens when a force of < 100 lbs is applied, and verifying that the drain line from the ice condenser floor to the containment lower compartment is unrestricted. ITS SR 3.6.14.3 requires the same testing every 18 months, with no restriction as to when (i.e., during shutdown) the test can be performed. This changes the CTS by deleting the requirement to perform the Surveillance during shutdown.

The purpose of CTS 4.6.5.7 is to ensure the ice condenser floor drains are OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The proposed Surveillance does not include the restriction on unit conditions. The control of the unit conditions appropriate to perform the test is an issue for procedures and scheduling, and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillances that do no dictate unit conditions for the Surveillance. This change is designated as less restrictive because the Surveillance may be performed at plant conditions other than shutdown.

L.2 CTS 3.6.5.8 states that "The refueling canal drains shall be OPERABLE." In this case, since there are three installed refueling canal drains, all three must be OPERABLE. ITS LCO 3.6.14 states "two refueling canal drains shall be OPERABLE." This changes the CTS by only requiring two of the three refueling canal drains to be OPERABLE. In addition, due to this change, the word "required" has been added to the Actions and the Surveillance Requirements since not all installed refueling drains are required to be OPERABLE.

The purpose of CTS 3.6.5.8 is to ensure the refueling canal drains are OPERABLE so that they can meet their design function. The design function of the refueling canal drains is to provide a main return path to the lower containment compartment for Containment Spray System water sprayed into the upper containment compartment. This change is acceptable because any two of the three refueling canal drains provide a sufficient flow rate of water to meet the analysis assumptions for ensuring sufficient containment recirculation sump water inventory following any accident that requires Emergency Core Cooling System swapover from the refueling water storage tank to the containment recirculation sump. Calculations performed conclude that three refueling canal drains provide a flow capacity of 2.1 times the flow rate of 5002 gpm assumed in the containment recirculation sump water inventory analysis. The most limiting combination of two refueling canal drains were calculated to provide a flow capacity of 6750 gpm, or approximately 1.35 times the analytically assumed flow rate of 5002 gpm. Therefore, the analysis of containment recirculation sump water inventory is not affected by the proposed reduction of OPERABLE refueling canal drains from three to two. This change is designated as less CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 11, Rev. 0, Page 406 of 494

Attachment 1, Volume 11, Rev. 0, Page 407 of 494 DISCUSSION OF CHANGES ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS 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 11, Rev. 0, Page 407 of 494

Attachment 1, Volume 11, Rev. 0, Page 408 of 494 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 408 of 494

, Volume 11, Rev. 0, Page 409 of 494 , Volume 11, Rev. 0, Page 409 of 494

, Volume 11, Rev. 0, Page 410 of 494 , Volume 11, Rev. 0, Page 410 of 494

, Volume 11, Rev. 0, Page 411 of 494 , Volume 11, Rev. 0, Page 411 of 494

Attachment 1, Volume 11, Rev. 0, Page 412 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS

1. The headings for ISTS 3.6.18 include the parenthetical expression (Ice Condenser).

This identifying information is not included in the CNP ITS. This information is provided in the NUREG to assist in identifying the appropriate specifications to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made. In addition, many Containment Specifications in the NUREG are not included in the CNP ITS due to design differences. Therefore, ISTS 3.6.18 is renumbered as ITS 3.6.14.

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

4. The number of required refueling canal drains has been changed from all (which is three in the CNP design) to two. Any two of the three installed refueling canal drains provide sufficient flow capacity to meet the licensing basis analysis assumptions. In addition, since more refueling canal drains are installed than are required by the LCO, the word "required" has been added to the ACTIONS and Surveillance Requirements, consistent with the format of the ITS.

5. ISTS SR 3.6.18.1 requires that each refueling canal drain be verified unplugged and free of debris every 92 days and prior to transition to MODE 4 from MODE 5 after each partial or complete fill of the refueling canal. The SR also requires verification, at the same Frequencies, that no debris is present in the upper containment or refueling canal that could obstruct the refueling canal drains. ITS SR 3.6.14.1 will require verification that there is no debris present in the upper containment or refueling canal that could obstruct the required refueling canal drains every 92 days and prior to transition to MODE 4 from MODE 5 after each partial or complete fill of the canal. ITS SR 3.6.14.2 will require that each required refueling canal drain blind flange is removed and the drain is not obstructed by debris prior to transition to MODE 4 from MODE 5 after each partial or complete fill of the canal. The 92 day Frequency has not been included in the ITS for the verification that the required refueling canal drains are not plugged and are free of debris. This is acceptable since the refueling canal drains are difficult to access during power operation because of their location in the bottom of the lower refueling canal, and performance of this verification would result in significant dose with little added benefit. This assessment is based on the following factors:

a. The most likely time for debris to be introduced into containment is in MODES 5 and 6 or while defueled during outage activities. The Surveillance to verify the refueling canal drains not plugged and free of debris and the Surveillance to verify the upper containment and refueling canal are free of debris will be performed after these activities prior to transition to MODE 4, as required by the ITS; and

b. After entry into MODE 4 and during operation in MODES 1 through 4, the new requirement to verify the upper containment and refueling canal are free of debris will be performed every 92 days.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 412 of 494

Attachment 1, Volume 11, Rev. 0, Page 413 of 494 JUSTIFICATION FOR DEVIATIONS ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS Furthermore, the CTS does not require a 92 day Frequency for verification of refueling canal drains; only the transitional Frequency is required. Thus, the deletion of the 92 day Frequency is consistent with the current licensing basis.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 413 of 494

Attachment 1, Volume 11, Rev. 0, Page 414 of 494 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 414 of 494

, Volume 11, Rev. 0, Page 415 of 494 , Volume 11, Rev. 0, Page 415 of 494

, Volume 11, Rev. 0, Page 416 of 494 , Volume 11, Rev. 0, Page 417 of 494 , Volume 11, Rev. 0, Page 417 of 494

, Volume 11, Rev. 0, Page 418 of 494 , Volume 11, Rev. 0, Page 418 of 494

, Volume 11, Rev. 0, Page 419 of 494 , Volume 11, Rev. 0, Page 419 of 494

, Volume 11, Rev. 0, Page 420 of 494 , Volume 11, Rev. 0, Page 420 of 494

Attachment 1, Volume 11, Rev. 0, Page 421 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.14 BASES, CONTAINMENT RECIRCULATION DRAINS

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

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

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

4. The Bases have been changed to be consistent with changes made to the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 421 of 494

Attachment 1, Volume 11, Rev. 0, Page 422 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 422 of 494

Attachment 1, Volume 11, Rev. 0, Page 423 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.2 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 3.6.5.8 states that "The refueling canal drains shall be OPERABLE." In this case, since there are three installed refueling canal drains, all three must be OPERABLE. ITS LCO 3.6.14 states "two refueling canal drains shall be OPERABLE. This changes the CTS by only requiring two of the three refueling canal drains to be OPERABLE. In addition, due to this change, the word "required" has been added to the Actions and the Surveillance Requirements since not all installed refueling drains are required to be OPERABLE.

The purpose of CTS 3.6.5.8 is to ensure the refueling canal drains are OPERABLE so that they can meet their design function. The design function of the refueling canal drains is to provide a main return path to the lower containment compartment for Containment Spray System water sprayed into the upper containment compartment.

This change is acceptable because any two of the three refueling canal drains provide a sufficient flow rate of water to meet the analysis assumptions for ensuring sufficient containment recirculation sump water inventory following any accident that requires Emergency Core Cooling System swapover from the refueling water storage tank to the containment recirculation sump. Calculations performed conclude that three refueling canal drains provide a flow capacity of 2.1 times the flow rate of 5002 gpm assumed in the containment recirculation sump water inventory analysis. The most limiting combination of two refueling canal drains were calculated to provide a flow capacity of 6750 gpm, or approximately 1.35 times the analytically assumed flow rate of 5002 gpm.

Therefore, the analysis of containment recirculation sump water inventory is not affected by the proposed reduction of OPERABLE refueling canal drains from three to two. 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 relaxes the requirement for all three of the installed refueling canal drains to be OPERABLE, requiring only two of the three refueling canal drains to be OPERABLE when in MODES 1 through 4. The refueling canal drains are not initiators of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. Any CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 423 of 494

Attachment 1, Volume 11, Rev. 0, Page 424 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS two of the three installed refueling canal drains provide a sufficient flow path to allow Containment Spray System water sprayed into the upper containment compartment to be returned to the lower containment compartment in accordance with accident analysis assumptions, including margin. In addition, reducing the size of the flow path through the refueling canal drains potentially reduces the peak upper and lower containment compartment pressures following an accident by reducing the amount of steam and air that bypasses the ice condenser. 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 potentially alters the physical configuration of the plant, but not the overall methods governing normal plant operation. Requiring only two of the three refueling canal drains to be OPERABLE when in MODES 1 through 4, and conversely allowing one of the three refueling canal drains to be plugged when in MODES 1 through 4, cannot initiate an accident. The refueling canal drains are passive internal containment components, and do not directly or indirectly interface with the Reactor Coolant System or ECCS, or any other safety-related structure, system, or component except for the refueling canal, during normal plant operation. In MODES 1 through 4, the refueling canal is fully drained, and only serves as a passive barrier between the upper and lower containment compartments. Consequently, the refueling canal drains cannot cause of failure of any of these structures, systems, or components during normal plant operation that could cause an accident. 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 margin of safety pertinent to the proposed change includes providing assurance that ECCS, containment cooling and pressure suppression, and Containment Spray System functional requirements will be met following a design basis accident, specifically for loss-of coolant accident (LOCA) or main steam line break (MSLB) events. The refueling canal drains perform a safety-related function following a LOCA or MSLB accident by providing a flow path for Containment Spray System water sprayed into the upper containment compartment to the lower containment compartment. Assurance of minimum required containment recirculation sump water inventory during and following switchover of suction for the ECCS and Containment Spray System pumps from the refueling water storage tank to the containment recirculation sump provides this assurance.

Calculations performed conclude that three refueling canal drains provide a flow capacity of 2.1 times the flow rate assumed in the containment recirculation CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 424 of 494

Attachment 1, Volume 11, Rev. 0, Page 425 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.6.14, CONTAINMENT RECIRCULATION DRAINS sump water inventory analysis. The most limiting combination of two refueling canal drains were calculated to provide approximately 1.35 times the analytically assumed flow rate. Therefore, the analysis of containment recirculation sump water inventory is not affected by the proposed reduction of OPERABLE refueling canal drains from three to two, and margin still exists between the calculated and analytically assumed flow rate. 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 3 Attachment 1, Volume 11, Rev. 0, Page 425 of 494

Attachment 1, Volume 11, Rev. 0, Page 426 of 494 ATTACHMENT 15 Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 11, Rev. 0, Page 426 of 494

Attachment 1, Volume 11, Rev. 0, Page 427 of 494 CTS 3/4.6.5.2, Ice Bed Temperature Monitoring System Attachment 1, Volume 11, Rev. 0, Page 427 of 494

, Volume 11, Rev. 0, Page 428 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 428 of 494

, Volume 11, Rev. 0, Page 429 of 494 CTS 3/4.6.5.2 R.1 Page 1 of 4 , Volume 11, Rev. 0, Page 429 of 494

, Volume 11, Rev. 0, Page 430 of 494 CTS 3/4.6.5.2 R.1 Page 2 of 4 , Volume 11, Rev. 0, Page 430 of 494

, Volume 11, Rev. 0, Page 431 of 494 CTS 3/4.6.5.2 R.1 Page 3 of 4 , Volume 11, Rev. 0, Page 431 of 494

, Volume 11, Rev. 0, Page 432 of 494 CTS 3/4.6.5.2 R.1 Page 4 of 4 , Volume 11, Rev. 0, Page 432 of 494

Attachment 1, Volume 11, Rev. 0, Page 433 of 494 DISCUSSION OF CHANGES CTS 3/4.6.5.2, ICE BED TEMPERATURE MONITORING SYSTEM ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.6.5.2 provides requirements on the Ice Bed Temperature Monitoring System. The Ice Bed Temperature Monitoring System monitors the temperature of the ice bed to ensure that the ice bed temperature does not increase above the required limits undetected. However, the Ice Bed Temperature Monitoring System is not required to ensure the ice bed temperature is maintained within limits. Another Technical Specification (that is being retained) will continue to ensure that temperature is maintained within the required limits. 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 3/4.6.5.4 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The Ice Bed Temperature Monitoring System is 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 Ice Bed Temperature Monitoring System Specification does not satisfy criterion 1.

2. The Ice Bed Temperature Monitoring System is not a process variable, design feature, or operating restriction 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 Ice Bed Temperature Monitoring System Specification does not satisfy criterion 2.

3. The Ice Bed Temperature Monitoring System is 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 Ice Bed Temperature Monitoring System Specification does not satisfy criterion 3.

4. The Ice Bed Temperature Monitoring System is 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-78) and summarized in Table 1 of WCAP-11618, the Ice Bed Temperature Monitoring System CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 433 of 494

Attachment 1, Volume 11, Rev. 0, Page 434 of 494 DISCUSSION OF CHANGES CTS 3/4.6.5.2, ICE BED TEMPERATURE MONITORING SYSTEM was found to be non-significant risk contributors to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Ice Bed Temperature Monitoring System is not important for any scenarios modeled in the CNP site-specific PRAs. The Ice Bed Temperature Monitoring System Specification does not meet criterion 4.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 434 of 494

Attachment 1, Volume 11, Rev. 0, Page 435 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 435 of 494

Attachment 1, Volume 11, Rev. 0, Page 436 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.6.5.2, ICE BED TEMPERATURE MONITORING SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 436 of 494

Attachment 1, Volume 11, Rev. 0, Page 437 of 494 CTS 3/4.6.5.4, Inlet Door Position Monitoring System Attachment 1, Volume 11, Rev. 0, Page 437 of 494

, Volume 11, Rev. 0, Page 438 of 494 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 438 of 494

, Volume 11, Rev. 0, Page 439 of 494 CTS 3/4.6.5.4 R.1 Page 1 of 2 , Volume 11, Rev. 0, Page 439 of 494

, Volume 11, Rev. 0, Page 440 of 494 CTS 3/4.6.5.4 R.1 Page 2 of 2 , Volume 11, Rev. 0, Page 440 of 494

Attachment 1, Volume 11, Rev. 0, Page 441 of 494 DISCUSSION OF CHANGES CTS 3/4.6.5.4, INLET DOOR POSITION MONITORING SYSTEM ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3/4.6.5.4 provides requirements on the Inlet Door Position Monitoring System. The Inlet Door Position Monitoring System monitors the position of the ice bed inlet doors during normal operation to ensure that the ice bed inlet doors do not open (which could allow the ice bed temperature to increase above the required limits). However, the Inlet Door Position Monitoring System is not required to ensure the inlet doors remain closed and ice bed temperature is maintained within limits. Other Technical Specifications (that are being retained) will continue to ensure that the inlet doors remain closed and temperature is maintained within the required limits. 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 3/4.6.5.4 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The Inlet Door Position Monitoring System is 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 Inlet Door Position Monitoring System Specification does not satisfy criterion 1.

2. The Inlet Door Position Monitoring System is not a process variable, design feature, or operating restriction 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 Inlet Door Position Monitoring System Specification does not satisfy criterion 2.

3. The Inlet Door Position Monitoring System is 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 Inlet Door Position Monitoring System Specification does not satisfy criterion 3.

4. The Inlet Door Position Monitoring System is 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 CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 441 of 494

Attachment 1, Volume 11, Rev. 0, Page 442 of 494 DISCUSSION OF CHANGES CTS 3/4.6.5.4, INLET DOOR POSITION MONITORING SYSTEM Section 4.0 (Appendix A, page A-78) and summarized in Table 1 of WCAP-11618, the Inlet Door Position Monitoring System was found to be non-significant risk contributors to core damage frequency and offsite releases. I&M has reviewed this evaluation, considers it applicable to CNP Units 1 and 2, and concurs with the assessment. The Inlet Door Position Monitoring System is not important for any scenarios modeled in the CNP site-specific PRAs. The Inlet Door Position Monitoring System Specification does not meet criterion 4.

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

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 442 of 494

Attachment 1, Volume 11, Rev. 0, Page 443 of 494 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 443 of 494

Attachment 1, Volume 11, Rev. 0, Page 444 of 494 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.6.5.4, INLET DOOR POSITION MONITORING SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 444 of 494

Attachment 1, Volume 11, Rev. 0, Page 445 of 494 ATTACHMENT 16 Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 11, Rev. 0, Page 445 of 494

Attachment 1, Volume 11, Rev. 0, Page 446 of 494 ISTS 3.6.9 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 446 of 494

, Volume 11, Rev. 0, Page 447 of 494 , Volume 11, Rev. 0, Page 447 of 494

, Volume 11, Rev. 0, Page 448 of 494 , Volume 11, Rev. 0, Page 448 of 494

Attachment 1, Volume 11, Rev. 0, Page 449 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.9, HYDROGEN MIXING SYSTEM (HMS)

1. The CNP design does not include the Hydrogen Mixing System. The hydrogen mixing function is performed by the Containment Air Recirculation/Hydrogen Skimmer System, which is controlled by ITS 3.6.10 (ISTS 3.6.14). Therefore, ISTS 3.6.9 is not included in the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 449 of 494

Attachment 1, Volume 11, Rev. 0, Page 450 of 494 ISTS 3.6.9 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 450 of 494

, Volume 11, Rev. 0, Page 451 of 494 , Volume 11, Rev. 0, Page 451 of 494

, Volume 11, Rev. 0, Page 452 of 494 , Volume 11, Rev. 0, Page 452 of 494

, Volume 11, Rev. 0, Page 453 of 494 , Volume 11, Rev. 0, Page 453 of 494

, Volume 11, Rev. 0, Page 454 of 494 , Volume 11, Rev. 0, Page 454 of 494

, Volume 11, Rev. 0, Page 455 of 494 , Volume 11, Rev. 0, Page 455 of 494

, Volume 11, Rev. 0, Page 456 of 494 , Volume 11, Rev. 0, Page 456 of 494

Attachment 1, Volume 11, Rev. 0, Page 457 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.9 BASES, HYDROGEN MIXING SYSTEM (HMS)

1. Changes are made to be consistent with changes made to the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 457 of 494

Attachment 1, Volume 11, Rev. 0, Page 458 of 494 ISTS 3.6.11 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 458 of 494

, Volume 11, Rev. 0, Page 459 of 494 , Volume 11, Rev. 0, Page 459 of 494

Attachment 1, Volume 11, Rev. 0, Page 460 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.11, IODINE CLEANUP SYSTEM (ICS)

1. The CNP design does not include the Iodine Cleanup System. Therefore, ISTS 3.6.11 is not included in the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 460 of 494

Attachment 1, Volume 11, Rev. 0, Page 461 of 494 ISTS 3.6.11 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 461 of 494

, Volume 11, Rev. 0, Page 462 of 494 , Volume 11, Rev. 0, Page 462 of 494

, Volume 11, Rev. 0, Page 463 of 494 , Volume 11, Rev. 0, Page 463 of 494

, Volume 11, Rev. 0, Page 464 of 494 , Volume 11, Rev. 0, Page 464 of 494

, Volume 11, Rev. 0, Page 465 of 494 , Volume 11, Rev. 0, Page 465 of 494

Attachment 1, Volume 11, Rev. 0, Page 466 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.11 BASES, IODINE CLEANUP SYSTEM (ICS)

1. Changes are made to be consistent with changes made to the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 466 of 494

Attachment 1, Volume 11, Rev. 0, Page 467 of 494 ISTS 3.6.12 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 467 of 494

, Volume 11, Rev. 0, Page 468 of 494 , Volume 11, Rev. 0, Page 468 of 494

Attachment 1, Volume 11, Rev. 0, Page 469 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.12, VACUUM RELIEF VALVES

1. The CNP design does not include the Vacuum Relief Valves. Therefore, ISTS 3.6.12 is not included in the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 469 of 494

Attachment 1, Volume 11, Rev. 0, Page 470 of 494 ISTS 3.6.12 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 470 of 494

, Volume 11, Rev. 0, Page 471 of 494 , Volume 11, Rev. 0, Page 471 of 494

, Volume 11, Rev. 0, Page 472 of 494 , Volume 11, Rev. 0, Page 472 of 494

, Volume 11, Rev. 0, Page 473 of 494 , Volume 11, Rev. 0, Page 473 of 494

Attachment 1, Volume 11, Rev. 0, Page 474 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.12 BASES, VACUUM RELIEF VALVES

1. Changes are made to be consistent with changes made to the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 474 of 494

Attachment 1, Volume 11, Rev. 0, Page 475 of 494 ISTS 3.6.13 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 475 of 494

, Volume 11, Rev. 0, Page 476 of 494 , Volume 11, Rev. 0, Page 476 of 494

, Volume 11, Rev. 0, Page 477 of 494 , Volume 11, Rev. 0, Page 477 of 494

Attachment 1, Volume 11, Rev. 0, Page 478 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.13, SHIELD BUILDING AIR CLEANUP SYSTEM (SBACS)

1. The CNP design does not include the Shield Building Air Cleanup System.

Therefore, ISTS 3.6.13 is not included in the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 478 of 494

Attachment 1, Volume 11, Rev. 0, Page 479 of 494 ISTS 3.6.13 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 479 of 494

, Volume 11, Rev. 0, Page 480 of 494 , Volume 11, Rev. 0, Page 480 of 494

, Volume 11, Rev. 0, Page 481 of 494 , Volume 11, Rev. 0, Page 481 of 494

, Volume 11, Rev. 0, Page 482 of 494 , Volume 11, Rev. 0, Page 482 of 494

, Volume 11, Rev. 0, Page 483 of 494 , Volume 11, Rev. 0, Page 483 of 494

, Volume 11, Rev. 0, Page 484 of 494 , Volume 11, Rev. 0, Page 484 of 494

Attachment 1, Volume 11, Rev. 0, Page 485 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.13 BASES, SHIELD BUILDING AIR CLEANUP SYSTEM (SBACS)

1. Changes are made to be consistent with changes made to the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 485 of 494

Attachment 1, Volume 11, Rev. 0, Page 486 of 494 ISTS 3.6.19 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 486 of 494

, Volume 11, Rev. 0, Page 487 of 494 , Volume 11, Rev. 0, Page 487 of 494

, Volume 11, Rev. 0, Page 488 of 494 , Volume 11, Rev. 0, Page 488 of 494

Attachment 1, Volume 11, Rev. 0, Page 489 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.19, SHIELD BUILDING

1. The CNP design does not include the Shield Building. Therefore, ISTS 3.6.19 is not included in the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 489 of 494

Attachment 1, Volume 11, Rev. 0, Page 490 of 494 ISTS 3.6.19 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 490 of 494

, Volume 11, Rev. 0, Page 491 of 494 , Volume 11, Rev. 0, Page 491 of 494

, Volume 11, Rev. 0, Page 492 of 494 , Volume 11, Rev. 0, Page 492 of 494

, Volume 11, Rev. 0, Page 493 of 494 , Volume 11, Rev. 0, Page 493 of 494

Attachment 1, Volume 11, Rev. 0, Page 494 of 494 JUSTIFICATION FOR DEVIATIONS ISTS 3.6.19 BASES, SHIELD BUILDING

1. Changes are made to be consistent with changes made to the Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 494 of 494

ML041200376

Text

Navigation menu

Search